Onshore unconventional oil and gas in Scotland: analysis of responses to consultations

4. Accuracy and scope of the SEA information (Q1)

4.1 The SEA process involves, among other things, establishing baseline environmental information relevant to the policy under consideration. As stated in the Environmental Report, the purpose of this baseline is to 'provide a description of the environmental characteristics against which the changes arising from the policy are assessed'. The report goes on to state that it is usual to consider how the baseline would have continued to evolve in the absence of the policy that is being assessed. This means that underlying environmental trends are taken into account.

4.2 The environmental baseline for the SEA addressed the following nine topics: (i) air; (ii) water; (iii) soil; (iv) climatic factors; (v) biodiversity, flora and fauna; (vi) cultural and archaeological heritage; (vii) landscape and geodiversity; (viii) material assets; and (ix) population and human health. Full details of the information included in the baseline for each of these topics was presented in an annex to the SEA, with additional information presented in the sections covering the findings for each topic.

4.3 Views on the accuracy and scope of the baseline information were sought as follows:

Question 1: What are your views on the accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report?

4.4 A total of 182 respondents (39 organisations and 143 individuals) commented at Question 1.

Key messages

4.5 A substantial group of respondents (mainly individuals but also a range of organisations) endorsed the information set out in the Environment Report.

4.6 However, a second substantial group of respondents expressed concerns about the SEA baseline information, although the extent and nature of the concerns varied. Among this group, the predominant view was that the SEA information was accurate, but that its scope was not fully comprehensive. The alternative view, expressed by oil and gas business and industry respondents and a handful of individuals, was that the SEA information exhibited 'serious errors, inaccuracies and inconsistencies'.

4.7 These views are discussed in further detail below. However, the following should be noted:

• Some respondents (individuals in particular) did not provide any comments on the SEA information but instead used their responses to state their opposition to development of an unconventional oil and gas industry. Such views are not considered in the analysis presented below which concentrates on comments on the accuracy and scope of the SEA information.
• Business / industry respondents and a few individuals provided detailed comments on the approach used in conducting the SEA. These comments have been covered in Chapter 3 and, as far as possible, are not repeated here.

Endorsement of the SEA baseline information

4.8 Those respondents who endorsed the baseline information (mainly individuals but also some community groups, community councils, public and regulatory bodies and third sector organisations) generally provided only brief comments outlining their positive views on the information used, or otherwise commending the Environmental Report. Typically, such respondents said that they were 'happy with', 'confident about' or had 'no problem with' the accuracy and scope of the information, or said that they thought the report was 'comprehensive' or 'non-biased'. In a few cases, respondents stated that their view was based on 'the best of their knowledge', given their limited expertise in the area. Some public bodies noted that previously raised concerns had been satisfactorily addressed.

Concerns about the SEA baseline information

4.9 Those respondents who expressed concerns about the baseline information fell into two main groups:

• Most frequently, respondents (both organisations and individuals) accepted the accuracy of the information but were critical of differing aspects of its scope (i.e. what had and had not been included for individual topics, and the level of detail presented) and / or how the information had been used in Environmental Report. This view was expressed by community councils, other community groups, third sector groups, a single local authority, and a range of individuals.
• An alternative perspective was put forward by industry and business respondents and a few individual respondents. This group of respondents made a range of detailed comments and criticisms about the information included in the Environmental Report relating to its accuracy and how it had been interpreted, the assumptions (operational and economic) underlying the assessment, and the conclusions drawn.

4.10 Respondents made a very wide range of detailed points in their responses and provided references and web links for additional evidence which they thought should have been included in the baseline assessment. The remainder of this chapter further details of the main views expressed.

Acceptance of accuracy but concerns about scope

4.11 Respondents who accepted the accuracy of the information but who had concerns about aspects of its scope drew attention to additional evidence and published data from the UK and around the world. This included recently-published evidence (2017 onwards), and covered SEA topics such as health, seismic activity (including information related to unconventional oil and gas operations in Lancashire, England and Groningen in the Netherlands), operational failure, air pollution, water pollution, land use, climate change (including recent work carried out by the Intergovernmental Panel on Climate Change^[3]).

4.12 Additionally, various respondents highlighted a range of different issues which they felt were not adequately accounted for (or were omitted) in the SEA baseline. These included:

• Specific issues such as health impacts (including mental health), air, noise and light pollution, carbon emissions, seismic activity (and the impact on pre-existing underground mining works), structural damage to buildings (and the liabilities arising therefrom), disposal of NORM (naturally occurring radioactive material) waste, the impact of abandoned installations, the environmental impact of increased mining for frac sand (a type of sand used to help open underground cracks during the hydraulic fracturing process), impacts on biodiversity, flora and fauna
• The social and community impacts of unconventional oil and gas extraction – it was argued that the justification for excluding this from the SEA was not clear, and that the inclusion of 'place-based' impacts on communities was merited and in line with guidance set out in the Scottish Government's 2014 Scottish Planning Policy statement^[4]
• The risk of inadequate industry standards and operational failure and accidents, and evidence on this from around the world
• The wider climate change context and the need to limit carbon emissions
• The characteristics of specific PEDL areas (including the presence of historic mining works)
• The existence of Community Charters in PEDL areas.^[5]

4.13 Looking ahead, some respondents in this group emphasised the importance of establishing a robust independent baseline to allow for effective future monitoring.

Concerns about accuracy, interpretation and underlying assumptions

4.14 Business / industry respondents and a few individuals argued that the information used exhibited 'serious errors, inaccuracies and inconsistencies'. These respondents offered a wide range of comments about the evidence included in the SEA, the assumptions underlying the assessment and the conclusions drawn, as outlined below:

• Evidence: A range of detailed points were highlighted by respondents. For example, they thought that the SEA and / or the evidence it drew on had:
  • Drawn selectively from evidence (including from the KPMG report commissioned by the Scottish Government^[6] and work carried out for SEPA^[7])
  • Not taken a UK-wide or global perspective in assessing environmental costs and benefits and, in particular, had not accounted for potential imports in the calculation of carbon emissions
  • Incorrectly applied evidence on super-emitters (i.e. large-scale gas production sites that account for a disproportionate share of methane emissions) to the Scottish context
  • Failed to consider coalbed methane (CBM) and underground coal gasification (UCG) separately, and make CBM-specific situations clear
  • Not included relevant evidence relating to offshore practices
  • Not taken account of evidence on the impact of existing onshore wells in Scotland
  • Not provided sufficient information on the proposed pilot project to allow proper assessment.
• Assumptions: Respondents thought that the discussion of unconventional oil and gas operations and related mitigation processes and regulatory approaches did not reflect up-to-date practice and procedures in the UK. (These issues are covered in further detail in Chapter 7 in relation to Question 4).
• Conclusions: There was a view that the SEA conclusions were not evidence based. Additionally, it was argued that the SEA carried out by the UK Government Department of Environment and Climate Change (DECC) for the 14th PEDL Round should have been referenced in the Environmental Report, and that an explanation of how the Scottish Government's current SEA had reached different conclusions to those reported by DECC should have been provided. (See again Chapter 7 for further detail.)

Other concerns about the SEA baseline information

4.15 In a few cases, respondents (all individuals) simply provided brief comments describing the baseline information or the Environmental Report as 'inadequate', 'insufficient' or 'inaccessible', or they expressed scepticism about the information and the report because of the possibility of bias and the potential impact of 'vested interests'.