Provisional Position Statement on Unconventional Gas Production in Warwickshire: Underground Coal Gasification
Last Update: 14th January 2014
1 Background
1.1 Underground Coal Gasification is a process which is designed to extract synthetic methane from underground coal seams which cannot be accessed by conventional mining techniques. It involves the partial combustion of coal in situ under restricted levels of oxygen enabling the combined conversion of coal to synthetic gas and its extraction. The process is achieved by drilling at least two bore holes into the deposits. One delivers oxygen and steam/water to the coal seam – the other brings the synthetic gas to the surface.
1.2 Commercial gasification plants are apparently operational in Australia, China and South Africa.
1.3 The practice of Underground Coal Gasification at a commercial scale is relatively new. Scientific data on the environmental and social impacts does not seem to be have been collated in independent peer-reviewed publications. Nevertheless, the limited evidence that has been presented seems to show that a number of significant environment risks appear to be associated with Underground Coal Gasification. The process is highly contentious and significant environmental concerns have been raised by local communities in Australia and the USA.
1.4 An application for a conditional licence to investigate the potential for Underground Coal Gasification in the Princethorpe area has been made by Cluff Natural Resources. This will be determined by The Coal Authority on behalf of the Department of Energy and Climate Change.
1.5 National planning context: The NPPF Ministerial Foreword of the NPPF states:
"Our natural environment is essential to our wellbeing, and can be better looked after than it has been. Habitats that have been degraded can be restored. Species that have been isolated can be reconnected. Green Belt land that has been depleted of diversity can be refilled by nature – and opened to people to experience it, to the benefit of body and soul."
Paragraphs 90 and 91:
"Certain other forms of development are also not inappropriate in Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt. These are:
- mineral extraction;
- engineering operations;
- local transport infrastructure which can demonstrate a requirement for a Green Belt location;
- the re-use of buildings provided that the buildings are of permanent and substantial construction; and
- development brought forward under a Community Right to Build Order.
When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources."
It should be noted that there are currently many effects that will have a cumulative impact on biodiversity including the revision of Local Plans, and major infrastructure projects notably HS2.
2 Some reported environmental risks that have been associated with Underground Coal Gasification
2.1 The main environmental risks that have been reported (Sources: Frack-Off website; UGC Association, The Coal Authority) and which are likely to be relevant in the Princethorpe area include:
2.2 Contamination by pollutants
The process of partially burning coal underground can apparently produce a large number of potentially harmful and carcinogenic hydrocarbons including benzene, toluene, ethyl-benzene and xylene. Large amounts of these compounds are apparently brought to the surface by the process and may contaminate ground and surface waters. Large volumes of incompletely burned residue are also likely to remain in situ and may provide an on-going source of contamination.
Apparently it is impossible to precisely control the combustion process and to predict the pathways by which such contaminants move deep underground. However the most common paths to the surface is via the wells themselves. Of three recent tests projects in Australia two have apparently been shut down following these compounds being released into the atmosphere.
The underlying geology of Warwickshire is highly faulted and so the probability of contamination of groundwater would seem to be high.
2.3 Waste Disposal
Large volumes of highly contaminated water will be produced by the process and it is not clear how this will be handled at the surface. The water used to control the process will emerge along with other liquids and particulates drawn up with the exhaust gases. Large volumes of liquid and solid waste will require treatment – presumably the latter to land fill? It seems unlikely that this could be completely contained within the processing plants.
2.4 Air Pollution & Flaring
Reports have indicated that significant quantities of hydrocarbons (e.g. phenols and benzene) are produced as by-products of the gasification process. Much of this will be carried to the surface by the product gas. Large volumes of carbon dioxide and other combustion products will be emitted from sites and power stations. Emergency flaring and uncontrolled emissions are likely to occur.
2.5 Subsidence
As fire burns along the coal seams, new unsupported voids will be created. These are likely to collapse and lead to subsidence of the overlying geology (potentially leading to habitat change / damage and alteration of groundwater flows; causing damage to buildings and infrastructure). Subsidence has been a common feature of the geology of coal mining in Warwickshire and this would seem to be a high risk but with the added complication of potentially contaminated groundwater.
2.6 Underground Coal Fires
The geology of Warwickshire is littered with faults and abandoned mine workings. If a supply of oxygen from an uncontrolled source reached the burning coal, the coal seam could continue to burn indefinitely. An uncontrolled fire may not be confined to the target coal seam.
2.7 Climate Change
The use of Underground Coal Gasification to produce synthetic methane has not been included in the calculations of carbon emissions used in international climate change assessments. This new carbon release is therefore additional to that already accounted for and will add a new source of atmospheric carbon to exacerbate climate change.
3 Key Environmental Assets and Issues ‘at risk’ in the Princethorpe Area
3.1 Key areas of interest for Warwickshire Wildlife Trust in the Princethorpe Area:
- The Princethorpe Woodlands Living Landscape area – the largest concentration of large ancient woodlands in Warwickshire and the focus of a major restoration project. Ancient woodlands have developed over several hundred years and are irreplaceable.
- A number of important SSSIs, which include important assemblages of species, many with high number of invertebrate species which will be particularly vulnerable to any contamination of water or changes to drainage.
- A number of local wildlife sites, country park and nature reserves managed by several conservation organisations and local authorities.
- An important pond, stream and river network especially the upper reaches of the River Leam and Avon catchment. This network is already failing to meet Water Framework Directive standards and is subject to a major project (a national priority) to clean up the contamination.
- A number of protected species which rely on clean groundwater systems including otter, crayfish, water vole and great crested newt.
- A large number of people live in and adjacent to the proposed Underground Coal Gasification area. A significant and important proportion of the drinking water supply to local towns comes from this catchment via the River Avon and Draycote Water reservoir. Parts of mid -Warwickshire obtain drinking water from underground sources.
- Transport infrastructure: The route of the proposed HS2 passes across the licence area – and this infrastructure could be highly vulnerable to subsidence.
- The area has significant landscape, recreational and food production interests.
3.2 With the limited amount of information available at this stage, it is currently impossible to adequately evaluate the significance, likelihood or severity of the reported risks in relation to the natural environment and the associated conservation interest / heritage assets in the Princethorpe area.
4 Warwickshire Wildlife Trust’s Position on Underground Coal Gasification
4.1 The Trust recognises the importance to society of securing safe and sustainable sources of energy. These clearly underpin economic activity, growth and jobs which are important for everyone.
4.2 However, the Trust is extremely concerned about the potential risks arising from the proposed development of Underground Coal Gasification in Warwickshire. It is far from clear, on the information available, that Underground Coal Gasification is either safe or sustainable. In the absence of any reliable information on which the potential impacts on people and wildlife can be reliably assessed, we can have little or no confidence that Warwickshire’s environment will be safeguarded.
4.3 The Trust is therefore opposed to the development of Underground Coal Gasification in Warwickshire because of the multiple environmental risks it poses. These risks have the potential to be highly significant and severe; and the probability that they will arise would seem to be high.
These risks include the possible contamination of groundwater, which could severely harm communities, wildlife and ecosystems.
The Trust will continue to oppose the use of Underground Coal Gasification until these serious concerns have been comprehensively and convincingly addressed through full and independent environmental impact assessments.
4.4 As a result of the uncertainty about environmental impacts and their significance, the Trust believes that the precautionary principle should be followed in respect of this proposal. We call upon the Coal Authority and Warwickshire County Council to take a precautionary approach in determining the applications for Underground Coal Gasification in Warwickshire.
4.5 The Trust also opposes Underground Coal Gasification in principle on the grounds of climate change risk. This is one of the most serious threats facing wildlife and society - and we believe that every possible step should be taken to reduce our dependence on fossil fuels and to develop renewable alternatives. The Trust believes that the prospect of Underground Coal Gasification is a potentially backward development, in terms of meeting climate commitments and emission targets.
4.6 In summary, on the evidence so far presented, The Trust considers that in situ coal gas extraction is incompatible with our responsibility to address climate change and to protect wildlife and the natural environment. The uncertainty surrounding this proposal is unfortunate given the other major planning proposals currently being undertaken.
The clean technologies that can actually limit climate impacts, improve energy efficiency and deliver cheaper energy over time are being side-lined by the focus on exploiting new unconventional carbon energy sources. There is no evidence that the gas produced will reduce household energy bills.
The Trust calls on the Government to re-focus effort on use of sustainable forms of energy which would allow us to prosper in the long-run by providing safe, clean and renewable energy to fuel our economy, whilst minimising the negative impact on biodiversity.
The issue of energy consumption has also slipped from the national agenda. Energy efficiency must also remain high on the national agenda.