The bare, hard ‘fracks’
THE ancient Rapa Nui people of Easter Island believed that every Moai statue (a gargantuan monolithic wooden human figure) that they built as a tribute to their ancestors would lead to greater material prosperity for their society.
Ironically, the construction of the Moai statues contributed to environmental degradation when extreme deforestation necessary for the raw material to build the Moai statues destabilised an already precarious ecosystem which, in turn, led to the near extinction of their population.
Recent media reports abound with news of Pakistan’s substantial reserves of shale gas and oil with the Minister of Petroleum and Natural Resources claiming that Pakistan has the ninth largest reserves of shale gas and oil in the world.
If the reports are true, this is a welcome development for Pakistan which is energy-hungry and foreign exchange-poor and whose import bill is dominated by payments for foreign oil.
Nevertheless, regardless of the veracity of such reports, our government must, prior to allowing exploration of shale gas, recognise that shale gas exploration is not free from serious environmental hazards and any exploration for shale gas must be strictly controlled under environmental regulations.
It is far too easy for the government to get carried away by the potential economic benefits of shale oil and gas deposits while ignoring the environmentally harmful effects of irresponsible exploration activities.
Shale gas is mostly composed of methane. Unlike conventional gas, shale gas is produced directly from the source rock (shale) deep underground by using the technique known as fracking, which involves systematic fracturing of the shales to enable the gas to flow. And therein lies the rub.
Fracking is a technique that uses substantial quantities of water, mixed with chemicals, pumped at high pressure into sub-par rock to create narrow fractures that create paths for the gas to flow into the well bore to the surface.
It is fracking which exposes the local environment to serious potential hazards. In fact, in 2011, the UK government imposed a moratorium on shale gas explorations after two seismic tremors associated with fracking for shale gas occurred in Lancashire.
Among the other risks involved in fracking for shale gas is the serious one of groundwater contamination during fracking, either through methane contamination or by contamination of the very chemicals used during the fracking process to fracture shale rocks deep underground.
Fracking involves using very large quantities of surface or ground water and this makes the consequences of fracking even worse. Not only is clean water used to fracture shale rock but this method also risks contaminating existing ground water resources and sub-par aquifers.
The water that returns from the well (flow-back) is likely to be contaminated and harmful for humans and its storage and disposal needs to be carefully planned.
With such significant risks to the local environment and population, the regulatory framework for shale gas exploration has to be meticulously devised and rigorously enforced.
To begin with, the operator must be responsible for the safety of the wells and the site. Well operators must conform to complex well head integrity regulations.
Blow out prevention technology should be made mandatory to prevent fugitive emissions of methane which is more environmentally damaging than comparable conventional gas emissions.
There must also be proper safeguards put in place for the efficient disposal of flow-back water in a manner which is not hazardous for the local environment, people and farmland.
To mitigate the risks of seismic activity and earthquakes, operators ought to be required to review the available information on faults in the area of the well to confirm that wells are not drilled close to existing faults which could trigger an earthquake.
Seismicity should be carefully monitored for several weeks prior to commencement of fracking operations to provide a baseline against which seismicity can be compared during and after fracturing operations commence. If abnormal seismic activity is observed, operations must be stopped forthwith.
In order to implement such a rigorous safety regime, the regulator and monitoring agencies would have to work in a coordinated manner. Not only would the federal and provincial environment protection agencies be involved but the appropriate health department would also have to monitor the health of people in the local areas where shale gas exploration is conducted.
The shale gas exploration licence fees can be easily used to fund such regulatory activities.
At present the approach to energy industry regulation in Pakistan is ad hoc and reactionary. In relation to shale gas, all the regulatory checks and balances ought to be put in place before the first exploratory shale gas well is drilled.
A strict code of practice ought to be developed backed up by high level engineering expertise in the regulator’s office so that when well designs based on latest technologies are submitted they are critically reviewed.
In short, the risks related to water pollution, seismic activity, air pollution and well safety should be coordinated and mitigated through proper enforcement of regulations but for that we must first codify the appropriate regulations.
Pakistan must not commence shale gas exploration activities until the regulatory framework is in place. Shale gas may well be the ray of light for many countries looking for new sources of energy like the UK and Pakistan but without the necessary regulatory safeguards we risk each shale gas well drilled becoming our very own Moai statue.
The writer is an international commercial lawyer.
rabel.akhund@akhundforbes.com