In 2019, we welcomed the now lifted moratorium on fracking,

In 2022 the government has announced the lifting of the moratorium. but what actually defines fracking? 

Below is a breakdown of why we want a BAN to include all forms of fracking
The controversy of the definition of fracking is best explained by The House of Commons Housing, Communities and Local Government Committee - Planning guidance on fracking Eighth Report of Session 2017–19

'We therefore believe that the Infrastructure Act 2015 definition is unsuitable in the planning context and recommend that it should not be liquid or volume-based. While we welcome the Government’s intention to unify the definitions of fracking used in the Infrastructure Act 2015 and the National Planning Practice Guidance due to the resultant lack of clarity and uncertainty in using multiple definitions, we are highly concerned at the Government’s suggestion that the Infrastructure Act definition will replace the current definition in a revised National Planning Practice Guidance. 

We call on the Government to amend the Infrastructure Act definition to ensure public confidence that every development which artificially fractures rock is subject to the appropriate permitting and regulatory regime.'


It is apparent that the three tests of the Committee for Climate Change (CCC) that apply to fracking should apply to all onshore oil and gas production in the UK, whatever the method or technique of extraction. 

Why is shale gas any different to gas extracted by acid stimulation or mini-fracks for instance? The same 3 tests must apply. 

As the National Audit Office states. 'The Department considers it can meet its climate change objectives while developing shale gas, but it has not yet developed the necessary technology.'

The National Audit Office (NAO) report has identified the lack of responsibility for onshore wells, not just shale wells, compared to offshore

The NAO States ‘The Department (BEIS) recognises its responsibility for decommissioning offshore oil and gas infrastructure, but not for onshore wells, including shale gas wells. In January 2019, we reported that government is ultimately liable for the total costs of decommissioning offshore infrastructure that operators cannot decommission. The Department discloses this risk in its financial accounts. In contrast, there is no equivalent legislation that establishes government liability for decommissioning onshore wells.’

The definition of fracking should be simple, consistent and without constraints about the volumes of fluid used.  


The rationale for this is set out below.


Geoscientists have suggested that the narrow definitions of fracking could allow fracking in the UK to “creep under the radar”. (1)


Professor Haszeldine told The Guardian that analysis of more than 17,000 gas wells fracked in the US from 2000-2010 showed that 43% would not be defined as fracking under UK rules. Of 4,500 US fracked oil wells, 89% would not be covered by the UK definition. (2)


The government classes shales as ‘unconventional’ sources of oil and gas, whereas limestone and sandstone rocks are ‘conventional sources’. This overlooks unconventional 'tight' (low-permeability) limestone and sandstone where hydrocarbons can be found and the industry want to use unconventional methods of extraction. 


There is no universal definition of ‘unconventional’ oil and gas, but the consensus is that the hydrocarbons are held in tight rock,(3) are unevenly concentrated and widely dispersed, and can be extracted by acidisation (using acid to stimulate a geological formation) or High Volume Hydraulic Fracturing (HVHF).  The UK definition of HVHF is based solely on how much fluid is needed for extraction: 10,000 cubic metres or more per well. (4)


The UK definition of ‘fracking’ will allow flouting of the rules by operators simply reducing the amount of fluid they are to use to ensure they fall under the threshold of 10,000 cubic metres.  Also the industry will aim to create confusion around the terms ‘conventional’ and ‘unconventional’ which are not fully defined.  This completely overlooks tight (low permeability) limestone and sandstone formations. (5)


In a written parliamentary question earlier this year, Dr David Drew MP asked the Secretary of State for BEIS whether the consent process for acidising is the same as for fracking. In response, Claire Perry MP stated “Acidisation refers to a number of techniques used to clean wells to improve productivity”.  This inaccurate statement highlights the concerns of Brockham Oil Watch and others, who fear acid stimulation and its environmental consequences are not sufficiently understood by politicians and, as a consequence, are not subject to appropriate regulation. (6)


In North Yorkshire where the Joint Minerals and Waste Plan (for North Yorkshire County Council, North Yorks Moors Park Authority, and City of York Council) is currently undergoing its Examination in Public, the definition of fracking in the plan has no volumetric constraint.  
  1. https://www.nature.com/articles/548393a
  2. https://www.theguardian.com/environment/2016/apr/13/uk-governments-fracking-definition-could-allow-drilling-without-safeguards
  3. permeability less than 0.1 millidarcies
  4. Provision 50, Infrastructure Act 2015
  5. the Weald Basin in southern England where UK Oil and Gas (UKOG), Angus Energy and Europa are exploring for oil in the ‘tight’ Kimmeridge limestones
  6. https://www.parliament.uk/business/publications/written-questions-answers-statements/written-question/Commons/2019-03-04/227944/
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