# Unlocking the subsurface through knowledge controversy: how earthquakes induced by deep geothermal drilling have politicized the subsurface environment

Justin Missaghieh-Poncet, Xavier Arnauld de Sartre

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## ► To cite this version:

Justin Missaghieh-Poncet, Xavier Arnauld de Sartre. Unlocking the subsurface through knowledge controversy: how earthquakes induced by deep geothermal drilling have politicized the subsurface environment. The Extractive Industries and Society, 2026, 25, pp.101780. 10.1016/j.exis.2025.101780. hal-05287137

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Submitted on 29 Sep 2025

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Original article

# Unlocking the subsurface through knowledge controversy : how earthquakes induced by deep geothermal drilling have politicized the subsurface environment

Justin Missaghieh-Poncet* , Xavier Arnauld de Sartre

Université de Pau et des Pays de l'Adour, E2S UPPA, CNRS, TREE, France

## ARTICLE INFO

**Keywords:**

Energy transition

Volumetric spatiality

National regulatory frameworks

Politicisation of the environment

Gouvernance of subsurface

## ABSTRACT

The expansion of geothermal energy extraction from new geological contexts in France is prompting the development of ‘enhanced’ geothermal systems (EGS). However, the subsurface is a complex environment in which multiple uncertainties arise because of its confinement, both physical and in terms of access to knowledge and power, and which cannot easily be modified. We analyse how the seismicity induced by geothermal drilling in the Strasbourg region (France) has given rise to a public debate that has brought the subsurface out of its confinement and into political and civic arenas in particular. To attempt to understand how this occurred, we analysed interviews, press reports and grey literature, from which it transpired, firstly, that the cause of the earthquakes can be traced back to negligence and a culture of confidentiality on the part of the operating company, which underestimated certain models and failed to seek any outside opinion. Secondly, failures in the enforcement of subsurface regulations at the central government level were found to be due to a loss of expertise in the relevant government departments as a result of government reforms, which subsequently led to a reform of the mining code to re-establish a measure of control. Thirdly, we found that the earthquakes triggered the involvement of new interested parties, particularly from the civic and political spheres, which brought out issues relating to environmental and risk management through demands for more open access to knowledge about the subsurface. In effect, these earthquakes were the catalyst that enabled subsurface issues to break out of the expert sphere and into political and citizens’ arenas. However, what emerges is a process of politicization of subsurface environments that is still incomplete : the positions of the various players are open to question as regards governance, which, notwithstanding emerging demands, remains in the hands of central government and industrialists with little prospect of broader involvement.

## 1. Introduction

It is widely recognized that controversies are of critical importance to ensure a sound basis for appropriation by society of technology or innovation. The exchanges that take place during a controversy enable the various parties to take each other’s points of view into account, but they also highlight the vulnerabilities of technologies or policies and bring out proposals for supporting measures to ensure that the innovation is properly deployed and can be used or enjoyed as widely as possible. But controversies are not easy to manage, because they appear at a late stage in the process of socializing technology, interested parties are not always prepared to discuss diverging points of view, the public sector does not always play its role, and so on.

This is particularly true for technologies designed to exploit the subsurface. Although various uses of the subsurface may be of interest in pursuing an energy transition, especially for its geothermal energy potential, natural hydrogen extraction or energy storage, projects involving the subsurface are struggling to emerge, sometimes because of opposition from the public. Dialogue is particularly difficult in this context, which has become subject to ringfencing for multiple reasons : the difficulty of gaining direct experience of the subsurface, the need for costly techniques, the expenses involved, the importance of knowledge for operators and the ways in which projects are conceived. More than any other, the subsurface is an environment where cooperation with the public is only considered for the final stage. And yet, it is because of this restricted access that the need to cooperate with the public is even more

<footnote>* Corresponding author.</footnote>

<footnote>E-mail addresses: justin.missaghieh-poncet@univ-pau.fr (J. Missaghieh-Poncet), xavier.arnauld@cnrs.fr (X. Arnauld de Sartre).</footnote>
crucial than elsewhere.

Analysing the difficulties and patterns that arise in controversies over subsurface energy projects, and how they play out, is particularly important not only to avoid losing the potential contributions of the subsurface to the energy transition, but also because they exemplify the difficulties of debates over the energy transition itself. Our starting point was a controversy that arose at a late stage during the deployment of a deep geothermal drilling project, which revealed the failures in discussions, the expectations of the various parties with an interest in the subsurface and, therefore, the conditions required for the politicization of this subsurface environment to take place on a sound basis. This article examines how unexpected events (in this case, earthquakes) sparked controversy and drove governance reforms that could have been anticipated if stakeholders had considered the various ways in which the subsurface can be appropriated.

The case was that of the earthquakes induced by an 'enhanced' geothermal drilling process in the Eurométropole de Strasbourg (conurbation of Strasbourg). Our aim was to show how the emergence of an unmentioned phenomenon – earthquakes – made it possible to define the conditions required to secure effective support for the deployment of geothermal energy extraction by EGS and, more broadly, for other subsurface technologies. Securing effective support means not only involving the various interested parties, but also implementing tools for monitoring and integrating subsurface matters into a broader policy.

We begin by exploring how the controversial nature of an environmental issue makes it possible to politicize it in the threefold sense of citizens' involvement, political choice and the implementation of tools to support deployment – which is particularly complex for the subsurface environment. We then describe the context in which EGS was introduced in the Eurométropole de Strasbourg, and the controversy that emerged with the earthquakes that occurred in 2019 and 2020. After presenting our methodological framework, we analyse the various aspects of the politicization of the subsurface that this controversy brought to the fore, before concluding as to the conditions in which this strongly ringfenced environment became politicized.

## 2. Why subsurface issues need to be politicized

A great many recent studies emphasize that successfully implementing an energy transition requires members of society to be involved, in various ways, in the deployment of transition mechanisms (Krupnik et al., 2022). While this is widely recognized, the fact that members of society have been endlessly called upon for decades no doubt means that their involvement is struggling to move beyond good intentions. Many dimensions come into play in the socialization of a technology : we have to consider the different temporal scales (as the technology matures) and spatial scales (which players are involved), as well as the diversity of the parties involved and to be involved... Controversies, however uncontrolled, are often a key opportunity to establish a dialogue that can evolve into a debate.

The governance of the subsurface can be examined through the lens of technical democracy (Callon et al., 2001; Fischer, 2000; Jasanoff, 2003). This perspective posits that technical issues are not solely the domain of experts but can also be engaged with and debated by citizens, especially in contexts characterized by uncertainty and risk – as with subsurface. However, if this literature is set in the context of dealing with an uncertain world, how we should act in a world that is deliberately made uncertain – as, we will see, it is the case in the context we have studied.

This domain is examined by ignorance studies (Gross, 2007; 2016). Uncertainty lies in different kinds of ignorances. Gross distinguishes ignorance and non-knowledge : ignorance is something that we don't even know that we don't know, while non-knowledge is a known limit of

knowledge (we know that we don't know). This non-knowledge can be taken into account in decision-making (active non-knowledge) or ignored (passive non-knowledge). This definition can be further refined by incorporating additional conceptual distinctions. Secrecy (Roberts, 2022) refers to the non-sharing of information, or its suppression. Negative knowledge (Knorr-Cetina, 1999) is knowledge that is considered dangerous or negligible, and which is not taken into account in decision-making. Strategic ignorance (McGoey, 2019) refers to the deliberate dissimulation of inconvenient information. However, a controversy of the type that can arise in contexts of technical democracy can lead to a clarification of the type of non-knowledge at stake, and in so doing modify the way in which a technology can be politicized and governed.

Many studies have looked into ways of integrating wind turbines, photovoltaic panels and so on, but much less literature is available on integrating subsurface technologies and what there tends to reflect anti-extraction stances more often than co-construction. Political geology, and authors outside this conceptual framework, focus on the implications of the fact that the subsurface environment is less politicized than most others (Billé, 2020; Bobbette and Donovan, 2019; Bosworth, 2023; Clark, 2017; Elden, 2013; Hawkins, 2020; Klinke, 2021; Squire and Dodds, 2020), especially when looking into how the subsurface is transformed, exploited and sometimes even destroyed by capitalist economies. These analyses show that one of the characteristics of the subsurface environment is that its study is confined to expert arenas : since it is difficult to experience directly, knowledge of it necessarily demands technical expertise and the use of expensive technology – non-knowledge is much less expensive in comparison. Legitimized spokespersons are from technical backgrounds (Kinchy et al., 2018), engineers and geologists, for example ; furthermore, acquiring knowledge on the subsurface environment is very costly and is only paid for if its usefulness is proven – in other words, if it is linked to economic interests. This technical 'ringfencing' of the subsurface confines its understanding to a restricted circle of experts, and such understanding rarely leaves these circles : it is not highly politicized because it is not generally understood by interested parties from outside the world of technology and industry. When activities on the subsurface can pose a serious risk, the incentive to maintain strategic ignorance is all the stronger because knowledge about the subsurface is limited. However, its politicization is necessary for a technical democracy to take root.

The issue of the politicization of the subsurface is particularly addressed in the case of France, which has been the subject of a fairly rich debate on the reappropriation of the subsurface in recent decades, in a context of energy transition and the implementation of public policies seeking to resume its exploitation. However, the literature shows that the politicization of the subsurface is incomplete (Arnauld de Sartre and Chailleux, 2021; Chailleux et al., 2022). Furthermore, with few exceptions, this literature studies material resources (critical materials, gas) and waste. In the case of geothermal energy, we are in a situation of "extraction without material" (Missaghieh-Poncet, 2024), effectively changing the socio-technical infrastructure and the issues surrounding it.

The issue of politicization of the subsurface thus becomes critical. 'Politicization is any action that marks an issue as political, drives political processes, builds a polity (e.g. a political system and its institutions), changes a polity or policy, or shapes policies' (Wiesner, 2021, p. 21). This definition makes it possible to distinguish three aspects of the politicization process : a new issue must become a political problem, it must be appropriated by citizens, and it must give rise either to new conflicts or to new regulations. The transformation into a policy is the culmination of the process. However, if the public authorities take on responsibility, this can lead to different outcomes : renewed ringfencing (Desvallées et al., 2020), which will remove the issue from the political arena, an exacerbation of conflicts (Bobba and Hubé, 2021) or
the implementation of policies and compromises to manage the issues that arise (Flinders and Buller, 2006). The latter solution is a form of communalization of the issue, which comes up in the case of the subsurface : Porada et al. (2024) show that subsurface resources trigger territorial conflicts, and propose new forms of territorial organization as the balance of power evolves – echoing the work of Gormally et al. (2018), who refer to arenas of governance of the subsurface as for other areas, such as climate, energy or the oceans.

In the case we are considering here, we hypothesize that a controversy over the earthquakes induced by industrial activity carried out in the name of the energy transition has deepened a process of politicization of the subsurface. This leads to a review, albeit still imperfect, of its governance by State agencies, in order to move away from its traditionally ringfenced status and to propose alternative forms of governance.

### 3. EGS-induced earthquakes in Alsace have opened up the subsurface to politicization

EGS deployment in Alsace has begun a gradual process of derestriction in three main stages, which we describe below.

#### 3.1. Deployment of deep ('enhanced') geothermal drilling in Alsace : a ringfenced technology

Geothermal energy extraction is based on the doublet principle : heat is extracted in fluid form (brackish hot water) from a subsurface reservoir. Once the heat has been used on the surface to power a heating network or an electricity generator (Manzella et al., 2019, p. 4), the fluid is reinjected into the subsurface. However, the right geological conditions for this kind of extraction are rare : there has to be both good water circulation in the subsurface (known as permeability) and temperature gradients that allow hot water to be extracted without drilling too deep (drilling being the most expensive operation in subsurface heat extraction). It is very rare to find a match between the demand for heat on the surface and the required subsurface characteristics (heat and permeability). To remedy this, industrialists looking to extract geothermal energy in situations with the right thermal gradients are improving permeability by creating or widening existing faults beneath the area of interest, applying what is known as an enhanced geothermal system, or EGS (Breede et al., 2013; Lu, 2018). This term refers to the use of stimulation techniques, including hydraulic fracturing (fracking), to create faults in underground reservoirs. This is a complex process and is still experimental because of the uncertainties associated with the structure of the subsurface, but it does enable geothermal drilling to be extended to areas initially considered to be less favourable.

In France, an 'enhanced' drilling system enabled geothermal energy to be deployed outside the Paris Basin (BP), where it was initially developed. The technical and economic conditions were favourable : the geological layer, known as the Dogger, underlying the large housing estates in the Paris metropolitan area was ideal for geothermal heat extraction. In the 1970s, at the time of the oil crisis, the economics of extracting geothermal heat were also favourable because this subsurface region was already well documented thanks to drilling for oil. However, elsewhere than under these very favourable conditions, geothermal energy was not very profitable. From 2012 onwards, when the French Ministry of Ecology decided to revive the sector outside the Paris Basin, geothermal drilling to produce electricity and heat made a comeback enabled by EGS technology. A geothermal power plant using EGS technology was developed in Soultz-sous-Forêts (Alsace) : initially a scientific pilot, it later became an industrial project. Since then, some twenty drilling permits have been approved or processed. In mainland France, EGS projects are concentrated in three regions : in the South-West, the Massif Central and Alsace. Alsace is of interest because of a

thermal anomaly that enables more heat to be captured without deep drilling. An industrial and scientific ecosystem has also emerged around geothermal energy : in addition to the Soultz plant, an academic chair has been established through a partnership between the university and Électricité de Strasbourg Géothermie (ES-G), and a number of drilling permits have been applied for.

In addition, the climate plan for the Eurométropole de Strasbourg combines the recovery of residual heat to supply the heating network with geothermal power generation projects. Two of these have been set up in the Strasbourg area : one in Vendenheim by Fonroche Géothermie (FG), and the other in Illkirch-Graffenstaden by Électricité de Strasbourg Géothermie. The first project was launched in 2014, initially in the Port-aux-Pétroles District, before being moved – because of protests – to Vendenheim, close to a refinery undergoing conversion (Chavot et al., 2018). The first drilling operations got under way from 2018 to 2020. The Illkirch-Graffenstaden project was launched in the same year, 2014 : drilling began in 2018 and testing took place from 2018 to 2020, when the project was halted due to the earthquakes in Vendenheim.

These operations were met with restrained but significant protest. In 2015, during the public inquiry, the project was challenged by local residents, most of whom were opposed to it, with almost 85 % of comments in German. There were two types of concerns. The first focused on the risks associated with the project, in terms of both seismic activity and the soil and groundwater pollution associated with drilling in an industrial oil storage site close to a relatively affluent residential area. The second was the lack of public information and doubts about the company's ability to carry out the project. These were the reasons that led the company to move the project to Vendenheim.

However, the drilling of geothermal boreholes in Vendenheim triggered a series of earthquakes. The first occurred in 2019 (magnitude 3, on 12th November), prompting the prefecture to demand a series of tests. A year later, more earthquakes occurred (magnitude 2.8, on 4th December). The Prefecture froze all projects, halting the Fonroche project on the 7th December and justifying its decisions on the grounds that the projects 'no longer offer the essential safety guarantees and must therefore be halted' (press release dated 7th December 2020). The Prefecture was thus exercising its policing role in the mining sector by monitoring geothermal activity and invoking the precautionary principle to prevent any earthquakes that could compromise public safety. The controversy that followed the earthquakes led to a redefinition of the rules of the game for geothermal energy extraction.

#### 3.2. Controversy over subsurface uncertainties

The controversy arose over whether the earthquakes were induced or not, and stemmed from the fact that the earthquakes did not occur at the drilling site itself (Fig. 1).

The first earthquakes caught people off guard because they occurred in the Robertsau District, a few kilometres south of the Vendenheim power plant. Acting on its own initiative, Strasbourg's geosciences research institute, EOST, took responsibility for the publication of a preliminary analysis of the events, which suggested that an unstable geological structure had been activated by the drilling operations. The company contested this and said that the earthquakes were of natural origin, not related to its activities. A report published in November 2019 by a group of experts, including EOST, concludes that excessive pressure during injection destabilized the fault network (the fault system extends over several kilometres). This analysis was confirmed in its second report (CNRS INSU, U Montpellier, BRGM, INERIS), published in 2022, which criticized the company for failing to adopt a precautionary approach to the issue of risk.

However, the company's response was a refusal to acknowledge its responsibility. Another report published in May 2020 and written by the French risk management institute (INERIS) and the French geological
<figure><img src="image_4.png" /><figcaption>Fig. 1. Map showing the earthquakes caused by the Geoven project in Strasbourg between 2019 and 2020.</figcaption></figure>

survey organization (BRGM), indicated that the origin of the earthquakes could not be established with certainty :

‘On the basis of the data and documents consulted, the BRGM & Ineris third-party expert report of February 2020 indicates that it is not possible to conclude whether or not there is a causal link between the Strasbourg earthquakes and the operations conducted at the Vendenheim site. Further scientific analysis of these data is therefore required in order to characterize the mechanisms involved (aseismic shifts, poro-elastic effects, etc.) and to attempt to determine the origin of the seismicity in Strasbourg, although there is no guarantee that this can be done’ (p. 4).

The Prefecture requested studies to understand the origin of the earthquakes and recommended that the operator carry out tests (known as the ‘safety phase’). These tests are said to have generated the second series of earthquakes, leading to the clear conclusion that the operator was responsible and to the shutdown of operations. The report is unambiguous for the company :

‘The lack of robust data for the construction of a geological model implied poor knowledge of the reservoir structure and poor evaluation of the risk of seismicity. In such a situation, with a constrained model, several alternative models taking into account the regional context should have been developed and investigated, rather than choosing to run a single structural model. This would have made it

possible to define more conservative scenarios to frame drilling operations and developments. Generally speaking, Fonroche Géothermie’s (FG) operational procedures have always been based on favourable scenarios. [...] This has caused risks to be underestimated. In addition, the management of operations, particularly during the so-called ‘safety phase’ in November 2020, was based on the value of reservoir overpressurisation, which is an interpreted value and not a measured value, with several hypothetical input parameters. As a result, FG’s operational protocols for ensuring the safety of wells are questionable’. (Report 2022, p. 6–7)

This report refers back to the uncertainty highlighted in the BRGM and INERIS report : it is true that establishing the origin of an earthquake is difficult, and that acting on the subsurface environment is complicated, but the uncertainties linked to this environment can be managed by taking several scenarios into account rather than just one optimistic scenario that is favourable to the industry’s operations. This means acknowledging that something may happen rather than saying that we don’t know what will happen in order to make uncertainty become non-knowledge.

## 4. Methodology

To investigate the causes and consequences of this controversy, we conducted 10 semi-structured interviews with key players (civil servants, elected representatives, local residents’ associations, geoscientists) in the Alsace region and central government and made an extensive analysis of documents of different types (expert reports, administrative reports from the prefecture and intermunicipal agencies, press releases, industry reports, local and national press).

Table 1 provides an overview of the interviews conducted.

We also examined the abovementioned reports and conducted a press analysis. Regarding the reports, we based our analysis on several expert-authored public documents :

<table><thead><tr><td>Date</td><td>Authors</td><td>Title (translated from the French)</td></tr></thead><tbody><tr><td>November 2019</td><td>Coordinator P. Bernard (CNRS)</td><td>INSU Working Group on 'Strasbourg Seismicity, 12 Nov 2019'</td></tr></tbody></table>

(continued on next page)

<table><caption>**Table 1**
Interviews conducted.</caption><thead><tr><td>Code</td><td>Position/organization</td><td>Date</td></tr></thead><tbody><tr><td>Strasbourg_Association1</td><td>Local residents' association</td><td>2021-05-13</td></tr><tr><td>Strasbourg_Association2</td><td>Local residents' association</td><td>2021-05-20</td></tr><tr><td>Strasbourg_Association3</td><td>Local residents' association</td><td>2021-05-25</td></tr><tr><td>Strasbourg_Association4</td><td>Local residents' association</td><td>2021-05-27</td></tr><tr><td>Strasbourg_EMS</td><td>Local councillor on the intermunicipal committee</td><td>2021-10-28</td></tr><tr><td>Strasbourg_EOST1</td><td>Geoscientist</td><td>2021-05-21</td></tr><tr><td>Strasbourg_EOST2</td><td>Geoscientist</td><td>2021-06-15</td></tr><tr><td>Strasbourg_Arverne</td><td>Competing company</td><td>2021-06-16</td></tr><tr><td>Strasbourg_ES</td><td>Competing company</td><td>2022-06-27</td></tr><tr><td>TFR_DGEC1</td><td>Central government - Ministry for Energy and Climate</td><td>2022-01-18</td></tr></tbody></table>
(continued)

<table><thead><tr><td>Date</td><td>Authors</td><td>Title (translated from the French)</td></tr></thead><tbody><tr><td>February 2020</td><td>P. Dominique, M. Terrier (BRGM) F. De Santis, E. Klein (INERIS)</td><td>Expert Report on the Technical Note: 'Analysis by Fonroche Géothermie of the Strasbourg event on 12 November 2019 and proposed ramp-up of the Vendenheim doublet'.</td></tr><tr><td>September 2020</td><td>F. De Santis (INERIS), M. Terrier (BRGM)</td><td>Vendenheim geothermal site: Update on actions taken by Fonroche Géothermie since the submission of the third-party expert report in February 2020</td></tr><tr><td>April 2022</td><td>M. Terrier (BRGM), F. De Santis (INERIS), R. Soliva (University of Montpellier), B. Valley (University of Neuchâtel), D. Bruel (École des Mines, Paris), Y. Geraud (University of Lorraine), J. Schmittbuhl (CNRS)</td><td>Phase 1 report by the committee of experts set up to support administration of the GEOVEN geothermal loop</td></tr></tbody></table>

We analysed 220 press articles, collected between 1 September 2020 and 28 February 2021. We read all the articles and classified their content by theme. These articles, including many from the regional press and the *Dernières Nouvelles d'Alsace* newspaper in particular, as well as the national press, were collected using the 'Europresse' database and through a Google Alerts watch for the word 'geothermal'. They were entered into a database management software specializing in the press<fnref n="1" /> and grouped by date and newspaper so that subsequent qualitative analyses could identify the topics raised. The qualitative analysis was conducted in two distinct stages. Initially, a lexicometric analysis was performed using Iramuteq software<fnref n="2" /> to identify the principal themes. Subsequently, a thorough reading of the articles was undertaken, during which notes were taken, and the main themes were extracted. These themes included the role of geothermal energy in the region, insurance-related concerns, and earthquake liability. The identified themes were then cross-referenced according to chronological sequences and media types, which encompassed regional and national press, as well as specialized press categories such as professional, environmental, and economic publications.

## 5. Derestiction and politicization through controversy

Our hypothesis here is that the controversies surrounding the earthquakes led to the politicization of the subsurface environment by demonstrating the low level of appropriation by citizens and politicians of the subsurface environment, which left its management to industry. This low level of appropriation emerged as a new problem (the first stage of politicization), leading citizens and politicians to define the right ways of using this environment, which ultimately gave rise to a new policy. In conclusion, we shall see whether or not this new policy is likely to derestrict the environment in question.

### 5.1. An emerging public concern

The earthquakes did not emerge as a problem out of the blue. The public and technical stakeholders knew of the possibility of their occurrence, since they had led to the suspension of several geothermal drilling operations. The controversy brought out several factors.

The first factor was that, without oversight, the industry processed data favouring its operations. It did so by allowing a systematic underestimation of the risks. This represents negative knowledge, where

certain limits are ignored. This led to gaps in the data and in a choice of models that were subsequently deemed to be over-optimistic because no fault models were considered, as pointed out in the 2022 expert report:

> "It appears that there was no continuous acquisition of the various well data and parameters on the Vendenheim site until October 2020. In fact, prior to this period, most measurements were taken only when operations aiming to control or improve well or reservoir properties (stimulation) were under way in one or other of the two wells. [...] As regards the construction of the geological model at the Vendenheim site, the input data are few and unreliable. [...] Through the information collected, the operator seemed to be seeking to validate a preconceived model rather than to test it. [...] This also resulted in the operator under-dimensioning the area to be considered in its geological, hydrological and geomechanical models. [...] The lack of robust data for the construction of a geological model led to poor knowledge of the reservoir structure and a poor evaluation of the risk of seismicity. [...] In general, FG's operating procedures were always based on favourable scenarios [...] This resulted in an underestimation of the risks". (Report dated 26 April 2022, p. 4-7)

The main criticism levelled at the industry is that by underestimating certain models and data, it was able to process the data in a way that favoured its own interests, and thus presenting a form of negative knowledge.

Secondly, how data and data processing algorithms were shared with the scientists prevented them from checking on activities by keeping them at a distance:

> 'Fonroche never asked us to manage their network of seismological stations, which is done by private partners. So the data we use to monitor them is strictly public data and we are totally independent' (Researcher at EOST, May 2021).

> "Well, we didn't have all the information so we couldn't say categorically what was happening – in particular, we didn't have precise pressure measurements and we didn't know what Fonroche was doing to the reservoir. That was confidential information that we didn't have" (Researcher at EOST, June 2021)

> 'Because Fonroche didn't communicate any of this data to anyone. Pressure, injection, all that. So in fact, they spent three months on agreements between the expert committee and Fonroche about what they could ask Fonroche to do". (Researcher at EOST, May 2021)

The manufacturer claimed that the information was confidential and covered by trade secrets to explain the restrictions. An agreement had to be signed with the company before it would release the data, a posteriori, for the feedback analysis.

Thirdly, this non-knowledges made it difficult to prove that the company was responsible for the earthquakes. Even though the geoscientists interviewed had no doubt about the induced origin of the earthquakes, proving a causal link is a very complex matter. The criticism was not directed at the earthquakes' origin but at the insufficient data. A note from INERIS/BRGM dated 17 September 2020 concluded as follows:

> 'The situation found at Vendenheim following the magnitude 3.1 event revealed a lack of preparation and coordination by the parties involved (operator, RéNaSS and DREAL) for a situation that was not really unforeseeable. It is suggested that the parties involved discuss ways of managing shared data (seismic, geodetic and operational) and of classifying earthquakes of undetermined/natural/induced or triggered origin. The experts stress the importance here of guaranteeing continuous capability, over time, for scientific cross-analysis of seismic monitoring data with operating data (i.e. injection forcing as a driver of induced seismicity) and with knowledge of the geological environment. This capability was not yet in place at the

<footnote n="1">¹ PressDB, https://framagit.org/</footnote>

<footnote n="2">² Iramuteq, https://iramuteq.org/</footnote>
time of the third-party assessment. Feedback will be of benefit to all stakeholders with a view to improving risk control and managing any unusual situations that may arise in the future' (p. 5).

This strategic ignorance, secrecy and coordination led to suspicions that the state was not fulfilling its responsibilities of enforcing regulations and ensuring safety in the mining sector. A city council member in Strasbourg told us the following :

'About the drilling, before the project, the DREAL, [which means] the State, promised that "We'll be checking, we'll be getting the drilling results from the previous day every morning at 8 a.m. and I'll analyse them and if I see the slightest problem, I'll call a halt", but there you have it, State supervision, in Vendenheim anyway, well it's frankly gone out the window. You can't really say so, but everyone understands it' (Strasbourg.EMS, elected official of the Strasbourg Eurometropole).

What appears to be at stake here is the possibility of derestricting knowledge about the underground world, allowing it out of the industrial sphere to ensure that scientists and experts can check on activities and that the State can fulfil its policing role – which would amount to a major overhaul of subsurface governance.

## 5.2. Appropriation by new players

These earthquakes triggered appropriation by new players, which is part of the politicization process. Three factors indicate that this process is under way : knowledge on the part of elected representatives, implementation of a strategy to ensure that geothermal extraction is acceptable and aspirations to citizen governance.

The 2020 earthquakes were widely covered in the press and generated debates (particularly among elected representatives) about the geothermal potential in Alsace. Our analysis of the corpus of press articles cited above sheds light on the dynamics at work. Two sequences stand out. The first, from 24th September to 1st December 2020 (41 articles), is regional in scope. The press coverage focused on the resumption of injection tests after a year's pause following the induced earthquakes towards the end of 2019. In late September, these tests triggered seven mini-earthquakes of a magnitude between 1.1 and 2.7, followed by aftershocks. At the time, the company admitted its involvement. In response, the prefecture convened an emergency meeting between elected officials, the industrial company and the DREAL, at which it was agreed that the test protocol had been too optimistic. Despite this, the company continued to uphold the safety of its technology. The second sequence, from 4th to 10th December 2020 (96 articles), concerned a series of earthquakes that occurred on 4th December, ranging in magnitude from 2.6 to 3.5. The event was covered nationally and by regional dailies outside Alsace itself. On 7th December, the prefecture announced that the project would be suspended and asked the DREAL to conduct an administrative enquiry. A debate emerged in the press, instigated by elected representatives, in which opposition to the project also reflected political divisions. In its defence, the company attributed the microseismicity to the technology itself, particularly when faults were created between the two wells. Meanwhile, the industrial players attempted to the distance themselves from the matter, distinguishing Fonroche's operation from other projects and highlighting technologies deemed to be safer. The third sequence, from 11th December to 14th January (82 articles), is dominated by claims for compensation against the company. However, a new series of earthquakes occurred from 25th to 27th December, peaking at magnitude 2.5 on the 25th, which was attributed to an easing of stresses on the reservoir. At the beginning of January, media attention focused on the administrative investigation, the initial results of which highlighted several anomalies in the tests carried out compared to the conditions set out for injection. Our analysis of comments on social networks (Authors., 2025) highlights their reactive nature, mainly

stressing how the earthquakes were sensed and giving voice to opposition to the technology for safety reasons.

This increasing awareness of subsurface risks is also reflected in our interviews with elected representatives :

'It's really interesting. And I have to admit that if we hadn't had these earthquakes, we wouldn't be asking ourselves these questions.' (Elected member of Eurométropole de Strasbourg, June 2021) "We've had these earthquakes [laughs] and so it's quite funny, because these industrial earthquakes are going to make us do things differently, rethink everything, bring citizens and local authorities back to the centre of the debate, be wary of the expediency of industrial projects and so question and maybe review our model, ask ourselves whether smaller-scale models, more decentralized models, more democratic ones obviously, could, should perhaps be invented, to improve the acceptability of the energy transition, make it better.' (Elected member Eurométropole de Strasbourg, June 2021)

The earthquakes not only revealed the reality of the subsurface environment, but also the challenges of its management.

As a result, on 18th December 2020, the Eurometropole set up a six-month commission to define the 'conditions for public acceptance' of geothermal drilling called Information and Evaluation Mission on deep geothermal energy [MIE] (Eurometropole deliberation 18/12/2020). Over and above the issue of acceptability, the challenge was to define an energy mix that would successfully support the region's energy transition policy. The Eurometropole energy planning document published in 2019 indeed relies on a 'local renewable zero-emission energy resource that is both competitive and non-intermittent' (p. 109 of its Climate Plan Strategy for 2030, published in 2019), in order to cover 11 % of its heating needs from the urban geothermal heating network and from the two geothermal power plants in particular. The committee held thirteen meetings between February and August 2021, with attendees including elected representatives, scientific representatives (BRGM, EOST, Karlsruher Institut für Technologie, etc.), representatives from nine environmental and local residents' associations, and six randomly selected citizens.

Although the committee put forward a number of proposals, it also revealed that subsurface issues are not particularly politicized. As revealed in an interview with an elected official who chaired the commission, it had to disseminate 'independent scientific expertise' to make the project more transparent, and also take steps for the 'empowerment' of the associations so that the necessary 'citizens' counter-expertise' could emerge (Elected Official With the Strasbourg Eurometropole, June 2021). The crux of the problem is the lack of technical understanding of the subsurface other than in the hands of experts. If citizens had a better understanding of the technical issues at stake, they would be in a better position to argue against the company's experts and thus ensure a proper balance between public safety issues and corporate profitability.

This commission produced a report, summarized into five measures under a 'Protocol of the Eurométropole de Strasbourg', which sets out the conditions that would make geothermal drilling acceptable :

'Priority to the production of HEAT for the region ; proven and shared KNOWLEDGE of the targeted resources and scientific monitoring before and during the development and operation of the projects ; territorial CONSENSUS for the projects within the municipalities concerned ; the authors call on the Eurométropole de Strasbourg' to make every effort to ensure that the municipalities concerned are closely involved in the projects that concern them and to ensure that they support these projects ; COOPERATION between the operator and the local area, by seeking public and citizen involvement in the governance of the projects ; Compliance with tried, tested and internationally recognized project methodologies (Best Practice), under the OVERSIGHT of independent experts and monitoring that involves local authorities and citizens.' (MIE report)

This protocol establishes the conditions for the acceptability of
geothermal energy, including its use (heat production), the rules of project governance (knowledge sharing, consensus, cooperation, oversight) and the players involved (local authorities, citizens, scientists). By politicizing the subsurface and defining its exploitation, it brings out three fundamental dimensions of the commons, i.e. the resource, the community and governance (Dardot and Laval, 2014; Ostrom, 2020), thus considering the subsurface as a territorial common good. In other words, the establishment of this 'protocol' reflects a will to regain control over the use of the subsurface and the deployment of technologies, with a more specific choice of methods. In this case, the subsurface will be used to produce heat rather than electricity, involving a wide range of parties with an interest in the deployment of projects – especially local elected representatives and citizens – and setting up a counter-expertise system in association with the above-mentioned parties. This 'expanded governance', based on the principle of subsidiarity and the involvement of local players, stands in opposition to the current model of devolution, i.e. central government representation at the local level, through the prefecture and decentralized departments, which are responsible for supervising the industrialist. Local players therefore want to see a change in the political model by calling for territorial governance (Epstein, 2015).

A third consequence must also need to be considered : the desire of local stakeholders for knowledge about the subsurface. This is reflected in ‘participatory research’ schemes such as Sismocitoyen,<fnref n="3" /> which involves the deployment of inexpensive seismic micro-sensors in private homes, to provide a finer mesh of seismic monitoring.

### 5.3. A new regulatory framework

Politicization of the subsurface environment can be found in other place than Alsace, where there are demands for clearer regulation of this environment. The controversy over induced seismicity in Alsace revealed that the State had not exercised its policing role. In theory, in exchange for a concession and the use of resources by the industrialist, the latter must submit its project to critical evaluation by the relevant State agency, in the interest of operational safety :

‘There is also a lack of State oversight monitoring of this activity, and I think this is due to developments over the last twenty years in which we have seen the State disengaging to some extent from subsurface issues, focusing only on environmental protection and risks and not on a proper understanding of subsurface techniques, on what is being done, how it is being done and, above all, on proper exploitation of subsurface resources. In my opinion, we are entirely dependent on the operator’ (interview with a central government official, 2021).

“The operator must submit its work programme every year [to the authorities]. [...] There really needs to be this capacity for verification, because we are partners after all. The Ministry issues the licence, while the operator looks for substance, for resources, in the collective interest and in the name of the State. In recent years, therefore, the State has tended to regard mining and mining licences like any other industrial activity. But although this is an activity in which the State is a stakeholder, it is no longer evaluating its own resources, but delegating it instead to private companies. However, it still shares the risk because it is the State that chooses the operator, it is the State that validates the company’s technical and financial capacity, it is the State that validates the work programme, and it is the State that comes to the rescue if the company defaults. So the State finds itself in a precarious position. In recent years, we have tended to view this activity as an industrial one, lowering our expert eye to

some extent, losing that expert eye on what the State was doing” (interview with a central government official, 2021).

The authorities' lack of oversight can be explained by a loss of State competence. This can be explained by the 2009 restructuring of decentralized administration, which merged directorates dealing with industrial and environmental issues. This internal reorganization, when the supervisory Ministry changed from Industry to Planning, changed their respective priorities, which altered the internal balance of power between the various engineering departments (Lascoumes et al., 2014; Le Bourhis and Martinais, 2014):

“We’re focusing more on risks, whereas before, with the DRIREs, we took a more comprehensive view of subsurface activity, including economic, technical, risk and environmental aspects [...] [...] This could have led to a dimished ability of regional governments to grasp mining regulations. They are more accustomed to the Environmental Code than the Mining Code. So I think there it a bit of a cacophony. I’m not sure if this what caused the various difficulties, but in any case, the new context was confusing” (interview with a central government official, 2021).

The lack of knowledge about the subsurface is harmful because it is important that external monitoring exists in an environment where companies do not like to monitor themselves. They are willing to take risks to increase their profits :

“It can be a good thing for the operator, because at the end of the day, they can say, you know, ‘I don’t have to worry’. On the other hand, the operators I’ve known for a long time were happy to have this external view, because there might be a chain of command, a player, a parent company elsewhere that says “You’ve got to be more profitable in France, you’ve got to get more out of the deposits, and so on”. And then they say “well yeah, but the authorities disagree”. [...] This counter-power can be very useful, to ensure, as has been more or less the case in France until now, that subsurface exploitation and operations are properly planned. [...] The balance of power ensured that the activity could continue without causing major damage. There were minor incidents, but really nothing serious” (Interview With a central government official, 2021).

The balance of power between the government and industry helps to reduce risks by providing an outside view of the project. The idea was that the State would delegate responsibility for safety to a private player in exchange for resource extraction. However, the lack of oversight casts doubt on this tacit agreement. In 2023, after the earthquakes induced by the industry, the government published a Guide to good practice for controlling seismicity induced by deep geothermal drilling (BRGM and INERIS, 2023). This document is in line with the 2021 reform of the mining code, which requires that project developers to produce a risk prevention plan for seismic events and submit it to the relevant authorities. The goal was to give the authorities greater control over industry. First, the publication defines and examines the mechanics of induced seismicity. It then reviews several seismic incidents in France and around the world. Thirdly, it provides feedback and case studies to identify the factors that cause seismic risk (geomorphological structures, fluid flow, operational parameters, etc.). It then provides a methodology for evaluating the seismic risks of a project at each stages of deployment, as well as recommendations for reservoir monitoring. Finally, it proposes a methodology for managing geothermal projects using a series of best practices based on the industry's state-of-the-art traffic light rating system. The white paper uses a didactic approach to summarize the best industry practices. It worth noted that several of the authors of this white paper are also contributed to the Strasbourg earthquake expert reports, suggesting a strong link.

Contrary to what the Strasbourg political declaration suggests, the net result, rather than joint governance of the subsurface, i.e. involving multiple interested parties in the area, would be a redefinition of the

<footnote n="3">³ The Sismo-citoyen project https://sismo-citoyen.fr/sismologie-citoyenne-mettre-en-dialogue-science-et-societe/ (access 13 March 2025)</footnote>
ways in which the government manages a public good by increasing its control over projects.

## 6. Discussion – the subsurface makes a political comeback

The controversy over earthquakes induced by industrial activity has highlighted how an environment that cannot be directly experienced, and knowledge of which is restricted to certain boundaries, can be politicized. Politicization happens when a public problem is newly recognized and labelled, leading citizens to adopt it and create new laws to address it. However, the problem here was not the earthquakes themselves, but the as government's oversight of industrialists: because of the difficulty of knowing anything about the industrial activities (a strategic ignorance), the controversy focused on whether it was possible to qualify the origin of the earthquakes; this was the point over which political and citizen appropriation took place, and which gave rise to regulation by the government – in the form of a white paper and a legal reform.

This was accomplished by acknowledging the presence of an existing environment, whose neglect can affect the upper surface. Local stakeholders, particularly elected officials and residents, have become more aware of the existence of a three-dimensional environment, including a vertical dimension, and they now recognize the need for better regulation of this third dimension. This is consistent with the results of political geology, specifically those of Gormally et al. (2018) or Arnauld de Sartre and Chailleux (2021) which demonstrate the incomplete politicization of the subsurface environment, or the work of Boutaud and Jandel (2023) which highlights the limited awareness of this environment in public policy.

In this case, the policy was to transfer the management of a public asset from the State to a private entity, with State oversight. But the State's loss of control has tipped the balance of power in favour of the private sector, leading to a loss of self-regulation to the point of causing earthquakes. The State is reasserting its role, but in new ways. A new debate is arising as to whether the new arrangements should assign a public good to the private sector, or manage it as a common good. In essence, this is what the public and local elected representatives are advocating for. However, it is not the State's role to transform the subsurface into a common good, as this would not align with the current legal framework. Contrary to the aspirations of local stakeholders, no framework for technical democracy has been implanted in the subsurface. This absence precludes the management of the subsurface as a common good.

However, this process for resolving the controversy has several limitations, in addition to the inherent characteristics of the subsurface and the uncertainty surrounding its structure. The first limitation is that the policy change is relatively new, so there is no conclusive feedback about its effects. The second limitation is the restriction of access to knowledge and its dissemination. The issues that arise are increasingly technical nature and require highly specialized expertise to understand. However, most of the data are deemed to be confidential due to its strategic importance to the industry, making it difficult to share relevant information widely among the public. According to Gross's typology of non-knowledge (2007; 2016), the initial context is that non-knowledge, where additional studies are required to understand the subsurface. This subsequently transitions into a form of secrecy characterized by industrial actors intentionally restricting knowledge from other stakeholders. Secrecy manifests in two ways. First, there's negative knowledge, whereby certain characteristics of the subsurface are deliberately ignored in modelling. Secondly, there is strategic ignorance, where certain information is deliberately concealed from stakeholders.

The third limitation concerns the way in which control over the subsurface is organized. France's legal organizational model is still centralized, with central government remaining the focal point for the allocation of subsurface resources, monitoring and public safety, so that in effect, central government is managing a public asset in opposition to

aspirations towards greater control over the subsurface at the local territorial level, with broader governance that includes citizens and elected representatives. The reform was therefore only minor, and instead of producing a profound paradigm shift in the matter of subsurface governance, it reflects the government's desire to reclaim over the project by regaining its critical perspective. This would allow for a real balance of power. Last but not least, the reform does not address the criticisms of those who do not trust consultation mechanisms or who consider that there is a lack of transparency of projects or technologies. However, that is another story.

## 7. Conclusion

The subsurface environment is one that has become ringfenced due to the vast amounts of capital required to understand and manage it, so that, despite being a potential source of major risks, the public appropriates it very little. However, as this environment belongs to the State in the case of France, it is easy for the latter to exercise control over subsurface activities. Indeed, when it delegates subsurface explorations and extraction activities to an industrial third party, it can impose control over the activities conducted. Still, due to government reform, the decline in subsurface-related activities and the loss of subsurface expertise among government agents, the State's control has gradually become less coercive. This has allowed one industrial player to continue to conduct studies that align with its interests, but has also justified a refusal to share data with scientific players that could have called the company's studies into question. As a result, failures in the State-delegated management of a public asset generated a series of earthquakes, and the controversies that followed triggered moves among local politicians and citizens towards appropriation of their subsurface environment and its management through an improvement and a better share of its knowledge, with demands that it should be managed as a common good and that they should have their say.

Clearly, this is not the path the French government is taking, mainly because the current mining law makes it impossible to manage the area in this way. However, there is a real opportunity here to involve local people more closely in the management of the subsurface environment and to improve technical democracy. However, this would require a paradigm shift in the ways in which the energy transition is implemented, which the centralizing French State does not seem ready for – especially as there is nothing to suggest, at this stage, that exploiting the subsurface in the interests of the energy transition is a priority.

### CRediT authorship contribution statement

Justin Missaghieh-Poncet: Writing – review & editing, Writing – original draft, Conceptualization. Xavier Arnauld de Sartre: Writing – review & editing, Supervision, Writing – original draft.

### Declaration of competing interest

The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.

### Acknowledgements

We acknowledge Ilona Bossanyi for the translation and Shamime Garenne for the proofreading. This work received government funding managed by the French National Research Agency under France 2030, reference number "ANR-22-PESP-0011".

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