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Publication - Report

Unconventional oil and gas consultation: analysis of responses

Published: 3 Oct 2017
Part of:
Economy, Energy, Environment and climate change
ISBN:
9781788512794

Independent analysis of the Talking 'Fracking' consultation.

96 page PDF

961.9kB

96 page PDF

961.9kB

Contents
Unconventional oil and gas consultation: analysis of responses
Annex 1: Campaign responses

96 page PDF

961.9kB

Annex 1: Campaign responses

This annex provides further information about the campaign responses received in the consultation. Copies of all the standard campaign texts are provided below.

It should be noted that:

  • Each of the campaigns asked their supporters to provide variable levels of detail in relation to personal information ( i.e. name and contact details). Some campaigns asked for full postal addresses, others asked for email addresses only.
  • All campaign responses received in the consultation were checked to identify whether they were 'standard' or 'non-standard'. Non-standard responses were copied into the analysis database and put through the validation process described in Annex 3. Standard responses were not validated in the same way; they were simply counted and the numbers reported. Thus, there has been no process of identifying and removing invalid responses or duplicates within the standard campaign responses.
  • Within each of the campaigns, there were a small number of non-standard responses in which the respondent had edited the standard response to express support for fracking. These have been reported as non-standard campaign responses under the campaign through which they were received (see again Annex 3). However, technically, they are not campaign responses; they are personal responses to the consultation which the respondent simply chose to submit through the means provided by the campaign organisers.
  • A small number of standard campaign responses (mainly those submitted through the Friends of the Earth and Greenpeace campaigns) were from organisational respondents. These organisations are not included in the figures shown in Table 2.5 in Chapter 2, nor are they listed in Annex 4 of this report.

Avaaz online campaign

The Avaaz campaign provided a list of bullet points to assist respondents in drafting a consultation response which could then be submitted via the Avaaz website. For the purpose of the analysis, the text was seen as relating to Questions 1, 3, 6 and 10 of the consultation questionnaire.

Send a message to ban fracking

The Scottish government has announced a public consultation to help them make a final decision on a fracking ban.

We have just days to flood them with our voices. If enough of us write to them we can show the government the world is looking to them for leadership, and we could win.

Send a message now by using the tool on the right and feed in directly to the public consultation! Here are some talking points to consider, but remember -- the more personal, the better.

  • As a member of the Scottish public, I call on you to ban unconventional oil and gas from Scotland until we know it's 100% safe to our health.
  • There is overwhelming evidence that proves fracking chemicals are cancerogenic, can be linked to reproductive health problems and lead to dangerous water pollution.
  • Experts say economic benefits of fracking are exaggerated. Household energy bills won't be reduced and the estimated costs will be much higher than in US.
  • More and more states and counties across US and Australia are banning fracking. I ask you to act responsibly for the future of our homeland!
  • Burning fossil fuels is the key driver of global warming. Experts are warning: letting fracking industry in could mean that Scotland won't meet its legally binding climate targets. We can't afford to frack our planet.

Broad Alliance postcard campaign

The Broad Alliance – Communities against UOGE provided pre-printed postcards to be submitted as responses to the Scottish Government consultation. The postcards contained 9 points and a space for people to add their own personal comment. For the purpose of the analysis, the text was seen as relating to Questions 1-10 of the consultation questionnaire.

(1) The social, community and health impacts of unconventional oil and gas extraction ( UOGE) would be disastrous.

(2) The payments companies promise may never materialize and won't cover damage to environment and infrastructure (roads, bridges, land, water).

(3) UOGE is a threat to tourism, whisky and modern sustainable industries. Potential pollution of air, land and water puts the 'Scottish brand' at risk.

(4) 5.5 years' worth of gas over 42 years (Economic Impact Study) means that UOGE would not really contribute to Scotland's energy supply.

(5) The environment will suffer: loss of amenity, risk of toxic leaks, heavy traffic and pollution. Noise and light pollution from 24-hour working is bad for people and wildlife.

(6) We must tackle climate change by replacing fossil fuels; US studies show fracked gas can be worse than coal for the climate. Your government's Climate Impact Study says a UOGE industry would make it harder to achieve climate targets.

(7) The taxpayer would end up paying for monitoring, regulating and cleaning up, for no return. No regulation can make this high risk business safe.

(8) UOGE's contribution to GDP (0.1% over 42 years) and jobs (1,400 over 42 years) is negligible (Economic Impact Study).

(9) The main risk is to health, especially the health of children who are still developing. The challenge is for your government to have the courage and foresight to ban UOGE (fracking) here.

(10) Other points I want to make: …..

Broad Alliance: model answers to consultation questions

The Broad Alliance provided written answers to the questions posed in the Scottish Government consultation, inviting people to use them as they are, or edit them to reflect their own views and priorities. For the purpose of the analysis, the text below was seen as relating to Questions 1-10 of the consultation questionnaire.

Q1: What are your views on the potential social, community and health impacts of an unconventional oil and gas industry in Scotland?

  • The social, community and health impacts are entirely negative. Therefore my view is that there should be no unconventional oil and gas industry in Scotland.
  • Social impacts would include destruction of trust between people and government, imposing a dirty industry with health and environment risks on communities, without their consent, to enable short-term profits for fracking companies.
  • Community impacts would include loss of environmental assets, increased traffic disrupting community life and cohesion, falling house prices, difficulty attracting modern, clean industries that will supply jobs of the future.
  • Health risks are clearly set out in the Public Health Scotland impact study and therefore the precautionary principle must apply. Since it was written, further significant peer-reviewed studies from the United States have highlighted that the health of people, including unborn children, suffers when they live close to fracking operations.

Q2: What are your views on the community benefit schemes that could apply, were an unconventional oil and gas industry to be developed in Scotland?

  • It is a bribe to try to convince individuals and local authorities to accept fracking. There is no guarantee anything will be paid. Companies can declare losses to limit payments. The fracking companies will not pay for fixing damaged road surfaces, bridges and other infrastructure, or for cleaning up spills of fracking fluids on the public roads. As with the coal industry, and the first shale industry, the public purse will be left to clean up when the companies have left.

Q3: What are your views on the potential impact of unconventional oil and gas industry on Scotland's economy and manufacturing sector?

  • I agree with KPMG, authors of the government's impact study, who confirmed that it would "not make a significant contribution to Scotland's economy". It will negatively impact manufacturing, distracting focus from support for industries that would contribute to a sustainable economic future. It will damage tourism and the Scotland "brand", especially for food and drink.

Q4: What are your views on the potential role of unconventional oil and gas in Scotland's energy mix?

  • The KMPG impact study confirms that fracked gas will be mainly for INEOS to extract Ethanol to make plastics. It might contribute a maximum of 5.5 years of Scotland's need for fuel gas over 42 years. But INEOS is planning to use any fuel gas for its plant at Grangemouth. Therefore it will not be part of Scotland's domestic energy supply. So, as KPMG also confirms, it will not reduce consumer gas prices.

Q5: What are your views on the potential environmental impacts of an unconventional oil and gas industry in Scotland?

  • This is a dirty, dangerous fossil fuel extraction industry. It would happen in Scotland's most populated area with the fracking companies allowed to decide how close to people's homes they put the wells. Local authorities trying to prevent it would have to challenge the fracking companies at expensive planning enquiries, and pay for their own environmental impact studies, diverting money from other services with no guarantee they would win their case. There will be leaks of fracking fluids, both from split fracking pipes and on site during production. This puts the water supply at risk. There will be further leaks when the flowback water is being transported on Scotland's roads to treatment plants. The evidence is that treatment of fracking fluid is only partially successful, especially in terms of radioactive materials. We should not put it in our rivers and seas. There will be methane leaks, which is bad for health, especially children's health. There will be long periods of 24-hour noise and vibration and all-night lighting which is damaging to people's mental health and wellbeing. There will be more heavy traffic, with the attendant pollution.

Q6: What are your views on the potential climate change impacts of unconventional oil and gas industry in Scotland?

  • The Climate Change Committee impact study told the Scottish government that fracking is only acceptable if 3 tests are met:

    1. There are cuts in emissions in other industries, including agriculture, to make up for fracking. Why should other industries do this? Who will make them?

    2. Fracked gas is balanced against a reduction in imports. With INEOS committed to importing fracked gas from the United States, this cannot be achieved.

    3. There is intensive well-by-well monitoring. SEPA could not provide this level of monitoring, and the public should not have to pay for the introduction of a new regulatory regime.

    In other words, the 3 climate tests cannot be met and therefore fracking should not be permitted.

  • Global warming scenarios all point to the fact that the majority of fossil fuel reserves must remain unused if global temperature rises are to be kept to the Cop21 agreement of 2˚C. Scotland must play its part by banning Unconventional Oil and Gas Extraction.

Q7: What are your views on the regulatory framework that would apply to an unconventional oil and gas industry in Scotland?

  • There is currently no appropriate regulatory framework for unconventional gas; one would have to be created as the Government's own report makes clear. This would cost a significant amount of public money, at a time of cuts and austerity. The Scottish Environmental Protection Agency ( SEPA) has confirmed that its regulation policy is as follows: " SEPA's enforcement philosophy is to use the minimum amount of formal regulation necessary to secure compliance. An exceedance of an environmental quality standard is not in itself indicative of non-compliant or illegal activity on the part of the operator and thus a breach would not necessarily precipitate significant enforcement action." This approach has already proved inadequate in a range of industries. In terms of fracking it would be disastrous.

Q8: Overall, and in light of the available evidence, what do you think would be the main benefits, if any, of an unconventional oil and gas industry in Scotland?

  • There would be no benefits to Scottish communities or the Scottish economy as a whole.

Q9: Overall, and in light of the available evidence, what do you think would be the main risks or challenges, if any, of an unconventional oil and gas industry in Scotland?

  • Danger to health especially the health of children and the unborn.
  • Risk to mental health and well-being of communities near fracking wells.
  • Creation of "sacrifice zones" where people will be unable to sell their homes and new development is halted both for housing and clean business.
  • 24-hour noise pollution and heavy traffic carrying dangerous cargos on rural roads.
  • Scotland unable to meet its climate targets
  • Damage to tourism, food and drink industries
  • Cost to taxpayer of intensive monitoring and regulation
  • Negative impact on development of clean, sustainable jobs.

Q10: If you have any other comments on the issues discussed in this consultation, please provide them here.

1. The First Minister promised in the Scottish Parliament that unless it could be proved that fracking could be done without risk to health and the environment, it would not be permitted. The Scottish Government's own impact studies highlight significant health, environmental and climate risks. On that basis, the government should keep its promise and ban fracking.

2. KPMG says there is no significant benefit to Scotland's economy – why is unconventional gas even being considered?

3. How will the Scottish Government make other industries and agriculture cut their emissions to make up for the emissions from fracking, as proposed by the Climate Change Committee?

4. The public will end up paying for the clean up and abandoned wells if the market fails – this is already happening in the United States. There is speculation that future licences might include bonds to be held in trust to pay for any clean-up should the company go bankrupt or fail to fulfil its obligations – a kind of insurance policy. But it is not clear that the licences already granted by the UK government can be amended to include bonds.

5. This is a Scotland-wide consultation but the views of communities that will be most affected must have more weight in the decision-making process. It is already clear that there is no social licence for fracking in the currently licensed areas.

Friends of the Earth Scotland online campaign

Friends of the Earth provided a standard text which could form the basis of a response to the consultation which respondents had the option of personalizing. This could then be submitted to the Scottish Government consultation via the Friends of the Earth website. For the purpose of the analysis, the text below was seen as relating to Questions 1, 3, 4, 5, 6, 9 and 10 of the consultation questionnaire.

Fracking will hold back our efforts to fight climate change, poses serious public health risks and threatens communities across Scotland.

There is a significant body of evidence from around the world highlighting the serious risks of unconventional oil and gas extraction to the climate, our environment, health and communities. This is supported by key findings from the Scottish Government's own commissioned research.

In the context of the global climate crisis it is irresponsible for a country like Scotland, with a carbon intensive past and such abundant renewable resources, to open up a new frontier of fossil fuels. The UK Climate Change Committee's report you commissioned makes it clear that allowing the unconventional oil and gas ( UOG) industry to go ahead will make it much harder to meet our climate targets.

Health Protection Scotland's impact assessment has found evidence that a number of air and water-borne environmental hazards would be likely to occur as a result of UOG operations. It also confirmed that UOG workers' health could be at risk from the use of silica in fracking operations and that other hazards from the fracking industry could pose a risk to the health of nearby residents. Given significant evidence from around the world of serious public health risks posed by the industry, ranging from low birth weights to respiratory disease and cancers, the precautionary principle demands that unconventional gas extraction should not be allowed to go ahead.

Further, the research you commissioned on economic scenarios demonstrates that far from replicating the US shale boom, it is unclear if the industry is commercially viable at all in Scotland. Report authors KPMG warn that even if the industry were to get underway commercially, it would only be expected to contribute on average 0.1% GDP, and be unlikely to create plentiful skilled local jobs.

In the face of growing evidence of harmful impacts, the precautionary principle demands that fracking must not be allowed to go ahead.

I'm calling on the Scottish Government to act urgently to ban unconventional oil and gas. Please treat this as a response to the consultation 'Talking Fracking'.

Friends of the Earth Scotland postcard campaign

Friends of the Earth provided pre-printed postcards to be submitted as responses to the Scottish Government consultation. The postcards contained the statement shown below. For the purpose of the analysis, this was seen as relating to Questions 9 and 10 of the consultation questionnaire:

Fracking will hold back our efforts to reduce climate change, pose serious public health risks and threatens communities across Scotland.

A significant body of evidence from around the world highlights the serious risks of unconventional oil and gas extraction to the climate, our environment, health and communities. This is supported by key findings from the Scottish Government's own commissioned research. In the face of growing evidence of harmful impacts, fracking must not be allowed to go ahead.

I'm calling on the Scottish Government to act urgently to ban unconventional oil and gas. Please treat this as a response to the consultation 'Talking Fracking'.

Greenpeace online campaign

Greenpeace provided a list of bullet points to assist respondents in drafting a consultation response which could then be submitted via the Greenpeace website. The points were structured around three themes of environment, health and alternative energy sources. For the purpose of the analysis, this text was seen to relate to Questions 1, 4, 5, 6 and 10 of the consultation questionnaire.

'Talking points' provided:

My concerns about the environment

  • Land near Falkirk, Stirling and Cumbernauld has been earmarked for fracking. The fossil fuel industry should not be allowed to drill close to residential areas like these.
  • Fracked gas is a fossil fuel. Burning large quantities of it will release vast amounts of greenhouse gases and will accelerate climate change.
  • A single fracking site can produce thousands of gallons of contaminated wastewater, which could cause harm if leaked into the environment (Source: Fracking: The Evidence, Greenpeace report).

My concerns about health

  • The UK government's own research found that people living close to fracking sites may be forced to breathe in "noxious odours from venting gases." (Source: Shale Gas Rural Economy Impacts report)
  • The same report found that people may also be forced to live with "light pollution that affects sleeping patterns."
  • Research has shown that traffic associated with fracking can increase air pollution by up to 30% (Source: Newcastle University)
  • In the US, New York State and Maryland have banned fracking on public health and environmental grounds.

Scotland should invest in:

  • Scotland has huge potential for renewable power and should choose to back clean technologies instead of burning fracked gas.
  • First Minister Nicola Sturgeon has spoken out about the importance of tackling climate change. The Scottish government should now act on these words and commit to leaving shale gas in the ground.
  • Fracking firms claim shale gas could be used to heat homes. A better idea would be for the Scottish government to make sure homes are insulated so less energy is lost. This could also help slash consumer energy bills.

Scottish Greens online campaign

The Scottish Green Party provided brief background information and three prompt questions to assist people in drafting a response to the consultation. This could then be submitted to the Scottish Government as an email message via the Scottish Greens website. The prompts related to Questions 1, 6, 9 and 10 of the consultation questionnaire and so for the purpose of analysis the responses are seen as relating to these questions.

Tell the Scottish Government to #KeepItInTheGround

In November 2016, the Government published independent research on the impacts of fracking on our health, economy and communities. There is clear evidence that extracting unconventional fossil fuels will threaten our environments and endanger the health of those living near to fracking sites. Extracting more fossil fuels will make it harder to meet climate targets.

The economic impacts are also uncertain. The reports suggest that far from creating a booming new industry, fracking will contribute only 0.1% to Scotland's GDP. Scottish Greens have shown that by harnessing our renewable energy potential we can create over 200,000 jobs in safe and clean ways for future generations.

The Government's independent research contains plenty of evidence for keeping unconventional fossil fuels in the ground. But a permanent ban on fracking will only happen if we let Ministers know how important it is to halt this industry.

Fracking should have no place in Scotland's future. It's bad for the climate, bad for public health and won't boost our economy.

Help us ban fracking once and for all. Respond to our consultation and let the Scottish Government know why they should #KeepItInTheGround.

What are your views on the social, community and health impacts of fracking?

  • Fracking could affect me and my community by…

What are your views on the potential climate change impacts of fracking?

  • Fracking is bad for climate change because…

What are the main risks or challenges of an unconventional oil and gas industry in Scotland?

  • I think fracking should be banned because…

South Lanarkshire against Unconventional Gas ( SLAUG) letter campaign

SLAUG provided a model letter which could be submitted as a consultation response by individuals along with a standard Respondent Information Form. This campaign was also promoted on the Broad Alliance website. For the purpose of the analysis, the points made in the letter were seen as relating to Questions 1, 3, 5, 6, 7, 9 and 10 of the consultation questionnaire.

I am writing to support the campaign against unconventional gas extraction in Scotland to protect our health, economy, landscape and environment. I want Scotland to be world leaders in renewable energy thereby reducing the impact of carbon emissions into our atmosphere causing climate change. I support the submission of the Broad Alliance representing community organisations and people across Scotland to the national consultation. To this end I would ask the Scottish Government to support the collective evidence of the Broad Alliance and that of partner organisations such as SLAUG to ensure a national ban be applied in Scotland. In addition I would like to submit concerns:

Health

  • Airborne and water borne environmental hazards would be likely to occur as a result of unconventional oil and gas operations.
  • Fracking and disposal of waste water into deep injection wells have been found to be associated with increased seismicity.
  • Sufficient evidence of respirable crystalline silica (a component of hydraulic fracturing fluids) have occurred at levels that could pose a risk to the health of workers.
  • Evidence that hazards, such as airborne polycyclic aromatic hydrocarbons and trophospheric ozone and waterborne total dissolved solids and metal ions have occurred at levels that could risk health of residents.
  • Waterborne methane has occurred at levels that pose a potential explosive risk.
  • We believe there are inadequacies in the current regulatory framework in Scotland to monitor such threats.
  • The health evidence, despite some inadequacies, justifies adopting a precautionary approach. This should adopt best practice, regulatory frameworks and community engagement including a ban on all wells within a 2km radius of any households in Scotland.

Greenhouse gas emissions

  • There are considerable uncertainties about the implications of unconventional oil and gas for greenhouse gas emissions.
  • There should be a strong regulatory framework if exploitation of unconventional oil and gas goes ahead in Scotland to 'guarantee' the protection of communities and ensure personal accountability of breaches. The current regulatory framework for greenhouse gas emissions in Scotland is unclear about who is responsible for what. There may be gaps in current regulations over emissions to air, including fugitive methane.
  • Exploiting unconventional oil and gas by fracking on a significant scale is not compatible with Scottish climate change targets unless three tests are met:
  • Emissions from well development, production and decommissioning must be strictly limited, with tight regulation and close monitoring.
  • Fossil fuel consumption must remain in line with the requirements of Scottish emissions targets. Without carbon capture and storage, the use of fossil fuels in power generation, transport and buildings must be eliminated by 2060.
  • Additional production emissions from shale wells will need to offset through reductions elsewhere in the Scottish economy.

Economics

  • Unconventional oil and gas would only represent 0.1% of the Scottish GDP (central estimate)
  • By 2062, shale gas cumulative output is estimated at 947 billion cubic feet (central estimate) at current rates this represents 5.5 years of Scottish consumption. This assumes 20 pads, 15 wells per pad and production lifetime of each well of 15 years (central estimate). At peak, an estimated 80 full-time equivalent jobs per pad would be created or 1,400 jobs in total (central estimate) but at what cost to tourism, property valuations and renewable energy jobs?
  • If oil and gas prices were to remain at historically low levels it would be unlikely that unconventional oil and gas resources in Scotland could be developed economically. An extended period of low prices would make development unattractive and economic benefits would not materialise.
  • Development of unconventional oil and gas in Scotland would rely on an ability to obtain appropriate finance to support exploration and extraction. This would likely be detrimental to investments in renewable energy.

Transport

  • Local communities will experience rises in traffic numbers, potentially for a number of years, with increases in noise, emissions, road damage and risks of accidents.
  • Each shale gas well pad could require 13,000-93,000 vehicle movements over 20 years.
  • Coal bed methane well pads would require about 93,000 vehicle movements over 12 years.
  • Traffic movements could be 190 a week for two years during the development of a pad with 15 wells.
  • Other impacts include road surface damage, increased risk of accidents and release of hazardous material, air pollution, noise, threat to nature conservation.
  • All planning applications for unconventional oil and gas developments should require an Environmental Impact Assessment and Traffic Management Plan and be a minimum 2km from any residential household.
  • Enforcement officers should be appointed to ensure mitigation measures are implemented and enforced.

Induced seismic activity

  • A magnitude 4.4 earthquake (the largest linked to fracking at the time the report was compiled) would be felt by many people and may even cause some superficial damage if it happened in central Scotland.
  • There is a small probability of induced earthquakes large enough to be felt but the longer term impact on the strata below ground is uncertain.
  • Increases in earthquake activity in the US have been linked to waste water injection.
  • Lack of historical data and low background activity makes it hard to identify areas which might have a greater risk of induced seismicity from unconventional oil and gas operations.

Decommissioning, site restoration and aftercare

  • There is a regulatory gap and lack of any mechanism requiring long-term monitoring and responsibility for wells.
  • Decommissioned wells may leak gases if poorly constructed and abandoned contrary to international standards and industry best practice.
  • Poorly constructed wells may leak methane to air and allow subsurface leaks into groundwater as experienced at numerous sites where fracking has occurred worldwide.
  • Although the risk may be low, where hydrocarbons are under pressure the risk is greater if well integrity fails.
  • Leaks from decommissioned wells should be monitored for as long as the Scottish Environmental Protection Agency considers necessary.
  • Leaks from above ground tanks and pipes could contaminate ground and surface water.
  • Scotland's regulatory framework for decommissioning needs to ensure appropriate bonds and accountability. Devolution of licensing to the Scottish Government is an opportunity to strengthen powers requiring operators to provide financial guarantees to cover liabilities.
  • An annual levy on consented wells or a mutual fund should be established to cover the costs of repairing leaking.

I am of the view that 'The Paris climate change agreement' makes it imperative that we move to a post carbon economy. We need a permanent ban on the exploitation of unconventional oil and gas by any means, including test drilling in Scotland as these activities are wholly at odds with Scotland's obligations under this international agreement. Under the obligations of the agreement Scotland requires to make significant carbon reductions and hold the increase in the global average temperature to well below 2°C. However if we continue to exploit new forms of carbon fuel and increase pollution during the extraction and combustion of fracking this decision will be in direct opposition to agreement.

Scotland needs a safe, sustainable future. Does Scotland need fracking? No. Will fracking improve the health of Scotland? No. Will fracking improve the climate of Scotland? No. Will fracking improve the landscape of Scotland? No. Does Scotland want fracking? No. Scotland needs the Scottish Government to stand up not just for the people of Scotland but for the very earth that sustains us. Now is the time to take a bold, positive path towards a better Scotland, a positive Scotland and a sustainable Scotland for the betterment of all.


Contact

Phone: 0300 244 4000 – Central Enquiry Unit

The Scottish Government
St Andrew's House
Regent Road
Edinburgh
EH1 3DG