COMMUNICATION FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the exploration and production of hydrocarbons (such as shale gas) using high volume hydraulic fracturing in the EU
Date: 2014-01-22
Institutions: European Commission
Subjects: environmental research, hydraulic machinery, mining extraction, natural gas, natural hazard, renewable energy













EUR-Lex - 52014DC0023 - EN











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52014DC0023

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the exploration and production of hydrocarbons (such as shale gas) using high volume hydraulic fracturing in the EU /* COM/2014/023 final */









COMMUNICATION FROM THE COMMISSION TO
THE COUNCIL AND THE EUROPEAN PARLIAMENT
on the exploration and production of
hydrocarbons (such as shale gas) using high volume hydraulic fracturing in the
EU
(Text with EEA relevance)
1.            Introduction
In a fast-evolving energy landscape
characterised by the need to decarbonise our energy system, increasing global
competition for resources and rising energy prices and price differentials with
some of our main competitors, European economies and citizens require energy which
is sustainable, affordable and with a secure and reliable supply. These objectives
are the drivers of EU energy policy.
However,
today and in the near future, the EU is still facing a number of energy
challenges including an increasing import dependency and related risks to security
of supply, the completion of the internal energy market and the impact of
energy prices on competitiveness.  
These
challenges are particularly reflected in natural gas, which currently accounts
for one quarter of the EU’s primary energy consumption and could contribute to
the reduction of greenhouse gas emissions in the short to medium term, should
it replace more carbon intensive fossil fuels. However, for the last two
decades, the production from conventional reservoirs has steadily declined. The
EU’s natural gas import dependency has risen up to 67% in 2011 and is projected
to continue increasing, putting the EU in greater direct competition with
global demand for natural gas. Some Member States rely on a single supplier and
often on a single supply route for 80-100% of their gas consumption. 
High
reliance on imports and low diversification of energy resources, among other
factors[1],
have contributed to increasing prices in the EU, in particular compared to some
of our main competitors. Whilst still being lower than prices on some Asian markets,
natural gas prices are three to four times higher than in the US. This puts pressure on EU energy-intensive industries using gas or possible by-products
as feedstock.
Technological
progress has enabled access to unconventional fossil that were previously
technically too complex or too costly to extract. In the US, unconventional gas currently accounts for 60% of the domestic gas production with shale
gas featuring the highest growth rates. This significant increase in indigenous
natural gas production has resulted in lower gas prices in the US –and temporarily influenced prices of Liquefied Natural Gas imports into the EU - and made
available cheaper US coal supplies for export, notably into the EU, where coal
prices have plummeted by more than a third since 2011. 
Potential
reserves of natural gas from shale formations have triggered high expectations
also in parts of the EU: shale gas can be a possible substitute for more carbon-intensive
fossil fuels, an indigenous source of natural gas reducing dependency on non-EU
energy suppliers, as well as a possible driver of jobs, economic growth and
additional source of public revenues. Accordingly, some Member States are
actively pursuing shale gas exploration.
At
the same time, the risks -several of them with cross-border features-
associated with the high volume hydraulic fracturing technique, also commonly
referred to as "fracking", trigger concerns about public health and
environmental effects. An important part of the population also perceives an
insufficient level of precaution, transparency and public consultation in
relation to shale gas activities. Some Member States have decided to ban
hydraulic fracturing or establish moratoria.
In
this context, requests have been raised for EU action to ensure the safe and secure
 extraction of unconventional fuels. The European Parliament adopted two
resolutions in November 2012 respectively on environmental impacts[2] as well as on industrial,
energy and other aspects of shale gas and shale oil[3]. In October 2013, the
Committee of the Regions issued an opinion[4]
providing the perspective of local and regional authorities on unconventional
hydrocarbons. Most respondents to a public consultation carried out by the
Commission from December 2012 to March 2013 asked for additional EU action
related to unconventional hydrocarbons (e.g shale gas) developments in the EU[5]. In May 2013 the
European Council called for the development of indigenous energy sources to
reduce the EU’s external energy dependency and stimulate economic growth while
stressing the need to ensure their safe, sustainable and cost-effective
extraction and respecting Member States choices of energy mix.[6]
In
response, the Commission agreed to develop a framework for safe and secure
unconventional hydrocarbon extraction in the EU following the objectives:
–          
to ensure that opportunities to diversify energy
supplies and improve competitiveness can be safely and effectively taken up in
those Member states that choose to do so, 
–          
to provide clarity and predictability for both
market operators and citizens, including for exploration projects,
–          
to fully consider greenhouse gas emissions and
management of climate and environmental risks, including to health, in line
with public expectations.
Since 2012 the Commission has released a series of studies on
unconventional fossil fuels, in particular shale gas, addressing especially
potential energy market and climate impacts, potential risks for environment
and human health, regulatory provisions applicable in selected Member States
and the registration under REACH[7]
of certain substances potentially used in hydraulic fracturing[8]. 
This
Communication outlines the potential new opportunities and challenges stemming
from shale gas extraction in Europe. It accompanies a Recommendation providing
minimum principles for the exploration and production of hydrocarbons by means
of high volume hydraulic fracturing[9].
The objective of this Recommendation is to enable safe and secure development
of these resources, and to foster a level playing field for this industry in
all EU Member States that choose to develop them.
2.             Shale
gas Potential in the EU
Unconventional
hydrocarbon reserves in the EU are deemed to be significant. Based on currently
available information, natural gas production from shale formations seems to
have the highest potential in Europe compared to other unconventional fossil
fuels: technically recoverable shale gas resources have been estimated to
approximately 16 trillion cubic meters (tcm), which is much higher than for
tight gas (3 tcm) or coal bed methane (2 tcm)[10].
However, there is still significant uncertainty on the economically recoverable
portion of these resources. As exploration projects develop, further knowledge
on the economically recoverable resources from shale formations and other
unconventional sources of gas and oil will be gained. 
There
has been no commercial production of shale gas in the EU yet, although a few
pilot production tests have already been conducted. Commercial production could
start in 2015-2017 in the most advanced Member States.
While
the EU will not become self-sufficient in natural gas, natural gas production
from shale formations could, at least partially, compensate the decline in the
EU's conventional gas production and avoid an increase in the EU's reliance on gas
imports. Indeed it would be, in a best case scenario, able to contribute almost half of the EU’s total gas production and meet about
around 10 % of the EU gas demand by 2035[11].
It could offer Member States with a high import dependency the possibility to
diversify their energy sources and enhance their security of supply. This obviously
needs to be seen in the context of a potential overall share of unconventional
gas of approximately 3% of the overall EU energy mix by 2030 in a best case
scenario[12].

The
direct price effect on European regional gas markets is likely to remain
moderate, especially if compared to the evolution in the US. This is due to expected relatively low volumes and higher production costs and the fact
that prices are still largely set through long term oil-indexed contracts. 
But
even a moderate decrease or avoided increase in gas prices – for instance
through an increased or maintained negotiation position towards non-EU gas suppliers
- would be beneficial for Member States, in particular for those highly reliant
on imports, and for consumers and businesses, especially energy intensive industries.

Shale
gas activities also have the potential to bring direct or indirect economic
benefits to EU Member States, regions and local communities as well as enterprises
and citizens, for instance through regional investments in infrastructure,
direct and indirect employment opportunities, and public income via taxes, fees
and royalties.
Under
certain conditions, shale gas also has the potential to bring climate benefits
if it substitutes more carbon intensive fossil fuels and does not replace
renewable energy sources. Greenhouse gas emissions from shale gas production in
Europe could, while being estimated to 1-5% higher per unit of electricity
generated compared to conventional natural gas extracted in the EU (provided
emissions are properly controlled), be 41% to 49% lower than emissions from
coal-based electricity generation, 2% to 10% lower than emissions from
electricity generated from conventional pipeline gas produced outside Europe,
and 7% to 10% lower than electricity generated from LNG imported into Europe[13]. However, to realise this
benefit compared to natural gas imports, greenhouse gas emissions associated with
the extraction process, notably methane, need to be properly mitigated.  
3.           Environmental
Risks and public Concerns
Experts
agree that shale gas extraction generally leads to a larger environmental
footprint compared to conventional gas development[14]. This is due to the
fact that it requires a more intensive well stimulation technique, it mainly
takes place on-shore and it would cover much wider areas. In addition, as productivity
of shale gas wells is generally lower than conventional wells, more wells need
to be drilled. Some of these risks and impacts could have cross border
implications, for example in case of water and air pollution.
In the current state of technological
development, shale gas extraction requires the combined use of high volume
hydraulic fracturing and directional (especially horizontal) drilling.  So far,
experience in Europe has been focused essentially on low volume hydraulic
fracturing in some conventional and tight gas reservoirs, mostly in vertical
wells, constituting only a small part of past EU oil and gas operations.
Drawing on the North American experience where the high volume hydraulic
fracturing has been broadly used, operators are now testing further this
practice in the EU.
Especially
hydraulic fracturing, a process by which fracturing fluid – a mixture
consisting typically of water, sand and chemical additives (generally between
0.5% and 2% of the total fracturing fluid)- is injected under high pressure to
break the rock, open and enlarge fractures to enable the hydrocarbons to flow
into the well, has raised a wide range of environmental concerns. Between 25-90
% of the initially injected fracturing fluids are expected to remain underground,
depending on geological conditions.
One
of the main environmental concerns is the risk of contamination of ground and
surface waters. In most Member States, groundwater is an important source of
drinking water or other purposes. The contamination risk is notably linked to
the chemicals used in the hydraulic fracturing process. Groundwater
contamination can occur in case of leaks, through e.g. improper well design or casing,
uncontrolled induced fractures or existing faults or abandoned wells. These risks
can be identified and mitigated by a careful site selection based on
underground risk characterisation and by the proper insulation of the well from
the surrounding geological formations. Surface water contamination can occur if
the high volume of wastewater produced is not properly managed and treated.
Such wastewater typically contains the chemical additives injected as part of
the fracturing fluid as well as possibly highly saline water and naturally
occurring heavy metals and radioactive materials from the shale formations. Instances
of water contamination by gas have been reported in the US in cases where the well was improperly insulated from the geological formations.
Another
water-related risk concerns the impact on water demand, especially in areas
where water is scarce. Extraction of natural gas from shale formations through
high volume hydraulic fracturing requires larger quantities of water[15] than the extraction of
gas from conventional reservoirs, and part of the water is not recovered. The extraction
of water for drilling and hydraulic fracturing can put additional stress on
aquifers in areas where water is scarce and already competes with other uses
(e.g. industry, agriculture, drinking water). This can also impact local
ecosystems, thereby affecting biodiversity. Water management plans can help
ensuring that water is used efficiently. Where this is environmentally sound
and in accordance with existing EU legislation, re-use of flowback water returning
to the surface after hydraulic fracturing can contribute to reducing the demand
for fresh water. 
The
quality of soil may also be negatively affected by leaks and spillage, if
fracturing fluids and wastewater are not adequately handled.
Unless
captured and mitigated, fugitive methane emissions can occur during shale gas
exploration or production, which would have a negative impact on local air
quality and the climate. Air emissions can also result from increased transport[16] and from on-site
equipment. Good practices exist to prevent and mitigate air emissions and
should systematically be used.
With
current technologies, a large number of wells and related infrastructure are
needed for shale gas extraction. This may have impacts on land fragmentation
and local road traffic, both of which can have consequences for local
communities and biodiversity. This risk needs to be addressed also in case of
competing uses of land in a given region e.g. for agriculture or tourism. Other
issues that have been identified relate to the risk of induced seismicity. 
These
environmental risks, also entailing health risks[17], have led to varying
degrees of public concern, which not infrequently result in outright opposition
to shale gas projects. 
In
addition, there is a public perception of insufficient level of precaution,
transparency and consultation applied to shale gas activities. About 60% of
individual respondents to the Commission consultation[18] stressed the lack of
transparency and public information among the main challenges of the sector
development. In particular, they identified the asymmetry of information
between the operators and competent authorities or the
general public as a problem, especially with
respect to the composition of fracturing fluids and the geological conditions
in which fracking is to take place.
Over
the past years, the Commission has received a large[19] number of queries from
the general public or its representatives. These queries express concerns and
doubts about the effectiveness of the current EU legislative framework, notably
as regards the EU legislation on mining waste, environmental impact assessment
or air and water protection. 
As
for many other industrial activities with environmental effects, local
populations tend to oppose developments that are too close to their homes (“Not
in My Backyard effect”)[20].
In several Member States, citizens' actions have prevented shale gas
exploration projects from going forward.
A
range of good technical and regulatory practices has emerged and with their
systematic application to exploration and production of shale gas, possible
negative impacts and risks can be managed and mitigated. But as long as these
environmental and health risks are not adequately addressed, as long as legal
uncertainties remain and there is a lack of transparency, public concerns will
persist. A number of experts[21]
consider that the lack of public acceptance represents a barrier to further shale
gas development[22].
The oil and gas industry itself has highlighted this as a key issue already
encountered at the exploration stage[23].
Therefore
addressing these risks and the public concern about safety of the operations is
of paramount importance to be able to reap potential benefits.
4.           Ensuring
protection of the environment, climate and public health
Both general EU legislation and specific pieces of EU
environmental legislation[24]
apply to shale gas activities from planning until cessation.
However, as shale gas exploration activities are
progressing, Member States have started interpreting the EU environmental
legislation in different ways and some are developing specific national rules, including bans and moratoria. 
This has resulted in differing requirements from one Member State to another. For instance, some Member States conduct a
strategic environmental assessment prior to licensing to take into account the
cumulative effects of shale gas projects and require a systematic environmental
impact assessment when hydraulic fracturing is intended to be used whereas
others do not. Another area with apparent divergent interpretation is the water
and mining waste legislation. 
This is leading to a fragmented and increasingly complex
operating framework within the EU which hinders the proper functioning of the
internal market. The different approaches by public authorities may lead to a
lack of level playing field and give rise to recurrent concerns regarding the
suitability of the environmental safeguards and precaution measures. A risk that
national interpretations are legally challenged further affects the
predictability for investors. 
Since the EU environmental legislation was developed at a
time when high volume hydraulic fracturing was not used in Europe, certain
environmental aspects associated with the exploration and production of fossil
fuels involving this practice are not comprehensively addressed in current EU
legislation. This in particular concerns issues such as strategic environmental
assessment and planning, underground risk assessment, well integrity,
integrated and consistent requirements in terms of baseline and operational
monitoring, capture of methane emissions and disclosure of fracturing fluid
composition on a well by well basis.
5.            Towards
an EU Framework  
Experts
including from the International Energy Agency and other reputed organisations
have confirmed the need for robust and clear rules to accompany shale gas
developments to ensure that
negative impacts can be reduced and risks can be managed.
In
2011, the Commission services issued a guidance summarising the main pieces of
applicable EU environmental legislation [25]
and a specific guidance on the applicability of the Environmental Impact
Assessment (EIA) Directive (2011/92/EU) to shale gas projects[26]. 
However
a number of national and local authorities are still calling for additional
urgent EU action in this area. The general public is also asking for clear
information on what is required for safe shale gas extraction. 
Existing
guidance was therefore not considered sufficient to provide clarity and predictability
for public authorities, market operators and citizens. This is why the
Commission adopted a Recommendation which outlines minimum principles which, if
fully applied, would contribute to enabling shale gas activities while ensuring
that climate and environmental safeguards are in place. This Recommendation is
complementary to the existing EU acquis and builds on previous work conducted
by the Commission services. It neither implies that Member States are under any
obligation to pursue the exploration or exploitation of shale gas activities if
they choose not to nor that Member States are prevented from maintaining or
introducing more detailed measures matching the specific national, regional or
local conditions. 
In
particular, the Recommendation invites Member States, when applying or adapting
their legislation applicable to hydrocarbons involving high volume hydraulic
fracturing, to ensure that:
·          
a strategic environmental assessment is carried
out prior to granting licenses for hydrocarbon exploration and/or production
which are expected to lead to operations involving high-volume hydraulic
fracturing in order to analyse and plan how to prevent, manage and mitigate
cumulative impacts, possible conflicts with other uses of natural resources or
the underground;
·          
a site specific risk characterisation and
assessment is carried out, related to both the underground and the surface, to
determine whether an area is suitable for safe and secure exploration or
production of hydrocarbons involving high volume hydraulic fracturing. It would
inter alia identify risks of underground exposure pathways such as induced
fractures, existing faults or abandoned wells; 
·          
baseline reporting (e.g. of water, air,
seismicity) takes place, in order  to provide a reference for subsequent
monitoring or in case of an incident;
·          
the public is informed of the composition of the
fluid used for hydraulic fracturing on a well by well basis as well as on waste
water composition, baseline data and monitoring results. This is needed to
ensure that the authorities and the general public have factual information on
potential risks and their sources. Improved transparency should also facilitate
public acceptance;
·          
the well is properly insulated from the
surrounding geological formations, in particular to  avoid contamination of
groundwater;
·          
venting (release of gases into the atmosphere)
is limited to most exceptional operational safety cases, flaring (controlled
burning of gases) is minimised, and gas is captured for its subsequent use
(e.g. on-site or through pipelines). This is needed to mitigate negative
effects of emissions on the climate, as well as on local air quality.
It
is also recommended that Member States ensure that companies apply best
available techniques (BAT), where applicable and good industry practices to
prevent, manage and reduce the impacts and risks associated with exploration
and production projects. Industry should strive for maximum transparency in
their operations and constantly improve technologies and operating practices. In order to draw up BAT reference documents, the Commission will
organise an exchange of information between Member States, the industries
concerned and non-governmental organisations promoting environmental
protection.
In
addition, the Commission is reviewing the existing reference document (BREF) on
extractive waste under the Mining Waste Directive so as to cover notably the
management of waste from hydrocarbon exploration and production involving high
volume hydraulic fracturing, in order to ensure that waste is appropriately
handled and treated and the risk of water, air and soil pollution is minimised.
It will also propose to the European Chemicals Agency
to make certain changes in the existing database of registered chemicals under
REACH so as to improve and facilitate the search of
information on registered substances used for hydraulic fracturing purposes. This
will be subject to consultation with stakeholders.
It
is also necessary to continue increasing our knowledge on unconventional
hydrocarbon extraction technologies and practices also in order to further
reduce potential health and environmental impacts and risks. In this context,
it is also essential that information is open and transparent to the public. To facilitate this
process, the Commission will establish a European Science and Technology
Network on Unconventional Hydrocarbon Extraction, bringing together
practitioners from industry, research, academia as well as civil society. The
Network will collect, analyse and review results from exploration projects as
well as assess the development of technologies used in unconventional gas and
oil projects. Further research in the field on
understanding, preventing and mitigating environmental impacts and risks of
shale gas exploration and exploitation is also announced in the 2014-2015 work
programme of Horizon 2020.  The latter also announces a grant aimed at
supporting the development and implementation of evidence base for research and
innovation policies in the area of unconventional gas and oil.
In
order to ensure adequate risk management and to avoid administrative burden for
operators, Member States should ensure that permitting authorities have
sufficient resources and knowledge of the process and that the permitting
procedure is appropriately coordinated. They must consult citizens and
stakeholders early on, before operations are starting. Member States and their competent authorities are also encouraged to exchange good regulatory
practices and other knowledge. The Commission will facilitate such exchange
through the Technical Working Group of Member States on environmental aspects
of unconventional fossil fuels. 
The
Commission will closely monitor the implementation of the Recommendation
through a publicly available comparison of the situation in Member States in
the form of a scoreboard. This is designed to increase transparency and
assess progress in each Member State on applying the principles set in the
Recommendation. 
Member States and national competent authorities
should inform the public on key issues related to the operations in order to
enhance transparency and restore public trust. Member States are invited to give
effect to  the principles set out in the Recommendation 6 months after its
publication and to inform the Commission on measures they have taken in response
to the Recommendation. 
The Commission will
review the extent to which this approach is effective in implementing the
principles set out in the Recommendation and in providing predictability and
clarity to citizens, operators and public authorities. It will report to the
Parliament and the Council within 18 months after publication in the Official
Journal. It will decide whether it is necessary to put forward legislative
proposals.
5. Conclusions
Member
States are responsible for deciding on their energy mix while giving due regard to the need to
preserve and improve the quality of the environment. It
is therefore for the Member States to decide whether to explore or produce natural gas from shale formations or other unconventional
hydrocarbon resources. However, those that do so will have to make sure that
proper conditions are in place for doing that. Among these conditions and in
order to help address public's concerns, they will need to take measures to
prevent, manage and reduce the risks associated with such activities.
Building on the existing EU legislation and on available and further
improving practices and technologies, the Commission calls upon Member States
which are currently exploring or plan to explore and produce their
unconventional hydrocarbon resources such as shale gas to properly implement
and apply existing EU legislation and in doing so, or in adapting their
implementing legislation to the needs and specificities of unconventional hydrocarbon
resources to follow the accompanying Recommendation to make sure that proper
conditions for their safe and secure development are in place, also taking into
account possible effects on neighbouring countries. 
With this Recommendation, the Commission aims at supporting Member
States in ensuring that the environment is safeguarded, resources are used
efficiently and the public is informed, while enabling potential energy
security and competitiveness benefits to be reaped in those Member States who
wish so.
Finally, it should be recalled that the
EU's long-term objective is to become a resource-efficient low-carbon economy. In the short to medium term, natural gas and the availability of new
sources of indigenous fossil fuels, such as natural gas from shale formations,
can play a role in the transformation of the energy sector provided it
substitutes more carbon intensive fossil fuels. In any case, the long term
objective of decarbonising our energy system will require continued improvement
of energy efficiency, energy savings and increased uptake of low carbon
technologies, in particular renewable energies.
[1]         Communication of the Commission to the European Parliament, Council,
Economic and Social Committee, and Committee of the Regions : Energy prices and
costs in Europe 
[2]            http://www.europarl.europa.eu/sides/getDoc.do?type=TA&reference=P7-TA-2012-0443&language=EN
[3]            http://www.europarl.europa.eu/sides/getDoc.do?type=TA&reference=P7-TA-2012-0444&language=EN
[4]               http://cor.europa.eu/en/news/Pages/fracking-environmental-impact.aspx
[5]               http://ec.europa.eu/environment/integration/energy/pdf/Shale%20gas%20consultation_report.pdf

[6]               http://register.consilium.europa.eu/doc/srv?l=EN&t=PDF&gc=true&sc=false&f=ST%2075%202013%20REV%201&r=http%3A%2F%2Fregister.consilium.europa.eu%2Fpd%2Fen%2F13%2Fst00%2Fst00075-re01.en13.pdf
[7]                Regulation 1907/2006/EC on the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH)
[8]               http://ec.europa.eu/environment/integration/energy/uff_studies_en.htm
[9]               p.m to add reference when available
[10]             Estimates for OECD Europe from International Energy
Agency (IEA) Golden Rules 2012. Estimates vary depending on sources. See also
"Unconventional gas: potential energy market impacts in the European
Union", JRC 2012.
[11]             IEA 2012
[12]             IEA 2012,
Unconventional gas production in Europe in 2035 is
reported at 27% of  285 bcm, hence 77 bcm. At the same date, Europe is reported
to consume 692 bcm of gas.  Hence, European unconventional gas production would
represent some 11% of its gas consumption in a best case scenario. Applied to
the projected share of gas in the energy mix of at most 30% (IEA), unconventional
gas would therefore represent some 3% of the EU energy mix in 2030.
[13]             IEA 2012  AEA 2012 study "Climate impact of
potential shale gas production in the EU" commissioned by the
Directorate-General for Climate Action of the European Commission, based on a
hypothetical case study using US primary data and a 100 year global warming
potential of methane. The study stresses the need to collect further data.
[14]             IEA 2012
[15]             When assessed on a per unit of energy produced, this is
2000 to 10 000 times more than
conventional gas, IEA Golden Rules report, 2012. Water consumption per shale
gas well varies depending on geological specificities but typically amounts on
average to about 15 000 m3 per well.
[16]             E.g  of water, chemicals, sand for hydraulic
fracturing  and wastewater resulting thereof.
[17]         Assessment
of health impacts is only starting, due to the novelty of the practice at the
current scale. However, main concerns relate to the direct impacts in terms of
air emissions and indirect impacts in terms of potential water pollution by
chemicals, some being recognised as carcinogens. Water contamination can in
turn lead to contamination of live animals, food and feed. Worksite health
hazards include silica hazards, handling of chemicals, exposure to diesel
particulate and exhaust gases from equipment as well as high noise levels. 
[18]             Unweighted rate, rising to about 80 % in the weighted
case.
[19]        Over a hundred of parliamentary questions and letters, more
than 3800 e-mails and more than ten petitions were received by the Commission,
some of which signed by some 15 000 citizens.
[20]             According to the Flash Euro-barometer survey conducted
on the basis of interviews of over 25 000 European citizens in September 2012, three
quarters of the respondents would be concerned if a shale gas project were to
be located in their neighbourhood, with 40% being very
concerned.
[21]             E.g. International Energy Agency Golden rules report
2012; US Department of Energy 90 days report
[22]             Public acceptance was among the three main challenges
identified by respondents in the EC public consultation.
[23]             E.g JRC IET workshop on shale gas, March 2013
[24]             See section 3.2 of the Impact assessment [insert ref
when available]. The applicable legislation includes the EIA Directive, Mining
Waste Directive, Water Framework Directive, REACH, Biocidal Products Directive,
Seveso II and III (under certain conditions), Habitats and Birds Directives and
Environmental Liability Directive (for activities listed under Annex III). 
[25]             http://ec.europa.eu/environment/integration/energy/uff_news_en.htm
[26]             http://ec.europa.eu/environment/integration/energy/pdf/guidance_note.pdf