To the Advertising Standards Authority, from Ken Wilkinson
24/Sept/2015.
Regarding a paid for advert published in the Malton Gazette in the week of 23 Sept 2015.
I would like to complain about the content of this advert as I believe it contravenes your guidelines.
Complaint 1.
Frack Free Ryedale (FFR) have used a quote from a draft report from DEFRA that was never completed. It did not pass the standards required and did not present any new research. This was only published after a freedom of information request. As such this report would not represent a reasonable view of the matters being discussed.
To quote
‘This paper is an early draft of an internal document; it is not analytically robust. Work on it has since been discontinued.
The draft paper was intended as a review of existing literature. It includes early, often vague, assumptions which are not supported by appropriate evidence. These were never intended as considered Defra positions or as statements of fact.
Containing no new evidence, the paper simply refers to data from overseas studies which cannot be used to predict impacts in the UK with any degree of reliability. The author of the paper was not asked to consider, and did not have an in-depth knowledge of, the UK regulatory framework.
In June 2012, the Royal Society and Royal Academy of Engineering report concluded that environmental (and health and safety) risks can be managed effectively in the UK if operational best practices are enforced through regulation. The UK has a rigorous and robust regulatory regime which is fully capable of preventing and managing any risks.’
As such, the use of this document as a source of data that will be used to inform the public is not acceptable and I believe that breaches your guidelines.
Complaint 2.
FFR have made a statement that ‘Fracking IS bad for business’. It would appear that the source for this is the DEFRA report above. However, even the flawed report uses the word ‘may’ several times, to indicate conditional statements. They are, by their very nature, only indicating a possibility.
FFR have stated that fracking IS bad for business with no evidence to support that.
The press widely reported that ‘Fracking could generate 33 billion pounds and 64000 jobs’ in a report prepared by Earnst and Young, in 2014.
as such it would appear that FFR have presented an unsupported statement that does not follow expert opinion. As such this would appear to have breached your guidelines.
Complaint 3.
the phrase ‘industrialisation of the countryside’ used in the last statement is problematic.
On 24th April 2013, the ASA passed a judgement regarding a similar matter concerning Cuadrilla and a complaint made by Refracktion. ASA complaint A12-203806. In this Cuadrilla claimed that the land usage was small, and the ASA appeared to have agreed with that assertion, as the complaint was rejected.
A similar complaint was made in the Lancashire Planning debate, with Cuadrilla, and the idea that this type of development is ‘industrialisation’ was rejected by the planners.
The development of industries in a country or region on a wide scale
defines industrialisation as ‘an economic organization of society built largely on mechanized industry rather than agriculture, craftsmanship, or commerce’.
Other dictionaries use a similar definition, namely that the extent of the industry must be large, and have the effect of displacing other ways of living, such as farming or tourism. It also indicates something that would be permanent.
The drilling and operations proposed by the local drilling company are temporary, and as such cannot be considered as industrialisation.
A small number of wellpads, each one having possibly 24 wells, one every 3 miles, and well concealed behind trees, would hardly constitute ‘industrialisation’. In the UK, we have an extensive gas infrastructure, and it is all buried, out of view, and safe. In the area where FFR are trying to influence opinion, there are 8 producing wells that have been drilled in the last 20 years or so, and these were not noticed. They also did not affect local tourism or business.
FFR would appear to be trying to further the impression that wells would be drilled vertically, with no regard to the local environment, as this aerial view from FFR’s leaflet that was distributed in the area tries to show. This is from an old coal gas project in Australia, and as such is not a fair comparison. It take no account of local planning law, or the ability to drill horizontally, or the fact that no one is planning this kind of development.
It also fails to recognise the study done by AMEC in 2013, that visualises various scenarios for the development of shale gas using horizontally drilled wells. On pages 29 and 30 of this you can see wellpads with up to 24 wells are visualised. It also states that the ‘Minimum distance between well pad sites …...5 km in most densely developed areas’.
Looking at the impact of a wellpad, they are assessed as being of 2 to 3 hectares. Looking at a 5 km square, that amounts to a land take of around 1/10th of one percent, or 1 in a thousand. This would be the only surface impact, once pipelines were installed. The drilling with its rig, is only a temporary installation, and so not ‘industrialisation’.
The picture here is of the visible impact of KM8 well, where work is proposed. It will look exactly the same after the proposed work that FFR are complaining about.
As guidance, please see the following links, regarding the surface impact on the tiny amount of land that would be used.
This graphic from the govt DECC shows the minimal surface impact of a multiwell site.
Each mark is a well that has been drilled in the North Yorkshire area for hydrocarbons. (courtesy Third Energy).
This is one of the 10 wellpads in beautiful Poole harbour, where 100 wells have been drilled. They are difficult or impossible to see, as they are all carefully sited and concealed. They have drilled under the millionaires retreat, Sandbanks, reportedly the fourth most expensive land in the world.
When communicating with Frack Free Ryedale, could you please keep my name anonymous, describing me simply as ‘a concerned member of the public’ or similar.
I would also appreciate that this matter be taken to the council for adjudication. I have brought three complaints in the last two years against misinformation from ‘anti’ frack groups. In all three cases, they withdrew, and promised not to present the adverts again.
In view of the intense discussion over this technology it would only seem fair, and in the public interest, that the ASA actually makes a ruling on these matters, rather than accept the promises of a group that may well completely ignore the ASA’s views. I asked for this to be done on two previous complaints, but that was ignored.
Regards, Ken Wilkinson.