Independent Review of Underground Coal Gasification - Report

7. Community and Public Interests

7.0 Establishing community views of UCG is challenging. No detailed surveys have been conducted nor is the "community" itself easy to delineate and interrogate. Establishing what the community understands of, and "thinks about" UGE technologies and practices and separating out the specific UCG component, assumes a widespread provision of information and that having been well assimilated.

7.1 Community interests in and views of UCG are assembled here from interviewing the Broad Alliance, and their submission to me, from discussions and interview with CoSLA and Falkirk Council officers, from a literature and media search, from views shared by local activists with FoE and me and reported by them and from consideration of inputs to related activities such as the Dart Public Enquiry. The submission from the Broad Alliance is at Annex 2.

7.2 To obtain some context, a search was made of UGE more generally in relation to public engagement. Assessments of public attitudes to unconventional gas extraction are still few but the UK shale study by Whitmarsh et al (2015) is instructive. The study revealed significant ambivalence but also highlighted a perception of more risks than benefits. The study's conclusions continue,

"the public is highly heterogeneous in relation to shale gas attitudes: prior knowledge appears to be associated with more favourable attitudes, although demographics and environmental values are overall strongest influences on perceptions. Recognising this heterogeneity is important for effective engagement with different audiences; for example, those with strong pro-environmental values are likely to be difficult to persuade of the benefits of shale gas unless shale gas can be successfully framed as relatively environmentally benign.

"…providing information about a particular benefit (economic or environment) of shale gas in general made attitudes more positive, particularly amongst those who are the most ambivalent. It is this undecided group who will be most susceptible to persuasive information, be this from pro- or anti-fracking sources."

7.3 Shackley et al (2004), produced some of the earliest and most informative work on public perception of UCG. The Tyndall Centre study was in the Silverdale area of Staffordshire, conducted in 2003. There is a great deal of detail in the report and I have chosen to extract an extensive part of the summary here. The authors set the scene,

"One of the uncertainties affecting the potential use of Underground Coal Gasification ( UCG) is the potential for public opposition to emerge. A proposed trial project in Silverdale, close to Stoke-on- Trent, elicited negative public reactions and was subsequently abandoned. This is despite the fact that the actual proposal related only to the initial drilling stages."

7.4 The situation locally was complicated by challenges to the authority of CA, the role of DTI and the closure of the local mine. The authors state that as a one-off proposal at a preliminary/ pilot stage was not representative of other cases generally. However, the project proposal surfaced issues around a lack of perceived need, concerns for safety, environmental impacts, etc. A focus group was set up and views elicited. The methods involved are described, views presented and suggestions made on how such processes of engagement could be developed and utilised in future.

7.5 The report goes on: "All of the focus group participants recognised the potential of UCG as a secure source of energy for the UK in the years to come, so long as it is safe to human health and the environment and cost effective. It was recognised that there could also be net economic benefits to be reaped if the UK comes to acquire a technical mastery of the process and can export the technology overseas. However, there were also substantial concerns regarding UCG. All of the group members agreed that in its present state any UCG trial site or commercial site situated nearby a local community seems to provide no advantages to the locale but puts the inhabitants at potential risk of industrial hazards. Many communities would feel like a 'guinea pig' if it were to accept being part of a trial. It was therefore concluded that future trial tests should be conducted in more remote areas. This finding reflects very closely the findings of the literature on siting of potentially hazardous sites, and the experience of the Silverdale case.

7.6 "A major problem with UCG is that the public would probably perceive it as a high-risk system that has the potential for deleterious effects in terms of health and safety to the local community. There is a general feeling in the focus group that fire hazards and explosions could easily occur and that there is potential for environmental degradation. The high level of concern arises from the perceived lack of control of a combustion process occurring underground and from the perception of a high level of uncertainty concerning the potential hazards. Operators, authorities and governmental regulatory bodies are faced with the challenge of providing evidence of the risks, as well as constructing a due process for making decisions, that will help to build trust in the technology with local communities.

7.7 "With regard to its environmental performance, UCG was criticised in that it is still burning fossil fuel, which does not seem in accordance with low-carbon energy systems. Although a feasible option would be to capture the CO ₂ and store it underground (not necessarily close to the UCG extraction site) this still presents the problem for some of the focus group participants of linking together two controversial, not fully tested and potentially dangerous technologies. Overall, it was felt by this group that UCG should only be considered in combination with carbon capture and storage ( CCS). Several participants of the focus group favoured further development of UCG until it is a ready-to-use technology, but that it should only be implemented on a large scale if other energy supplies fail; i.e. UCG should be viewed (according to these members of the group) primarily as a potential back-stop technology.

7.8 " UCG was still viewed by most members of the group as a good energy safety net for the UK and several suggestions were made as to how to improve its public perception and integrate it more closely within a sustainable energy programme. First of all one must overcome the public's lack of confidence towards developers, operators and regulators. The main mechanism suggested to achieve this was through greater transparency of operations and clear information regarding the day-to-day processes, safety measures and environmental impacts of the UCG plant. This could be done through:

• Creating an information/community centre where people can easily inform themselves and ask questions. Up-to-date information on operations and plans would be made available. This could be complemented by occasional public events by regulatory and operational bodies and open days where the public could access the plant.
  
• Providing a budget to the local community so they can employ independent reviewers and experts in order to cross-examine all data and ensure good practice and conduct of operations. In this way, the local community would have greater confidence in the regulatory process and underlying data thus improving mutual trust.
  
• Getting the media to advertise such collaborative schemes and to provide a publication avenue for information and developments.
  
• Providing a written statement regarding the responsibilities, duties and liabilities to be undertaken by each responsible party in the event of an incident.
  Secondly, UCG should be presented to the community within a package of improvement measures such as:
  • Combining UCG with other, more labour intensive industrial developments as part of an employment initiative, or else with local regeneration schemes. This might involve energy sector developments, such as a UCG Technology Centre or development of local industry based on UCG gas for heating and chemical production.
  • Producing hydrogen from the product gas, which could be used to kick-start a local hydrogen economy scheme such as providing the fuel for town buses. This could then provide environmental benefits as well as helping the area become a pioneer of hydrogen technology and infrastructure.

7.9 "This project was a pilot stage investigation, which made use of an existing group that had prior knowledge of, and discussions about, climate change and of carbon capture and storage. This is likely to have influenced the perceptions of the group regarding the role of UCG in the UK's energy system. Furthermore, the composition of the group was not at all representative of the British public. Further research could involve holding more focus groups with a wider cross-section of the public in terms of: gender, socio-economic group (occupation), age, place of residence, psychographic profile, etc. A further activity might involve conducting face-to-face surveys with a larger sample of the public." Shackley et al (2004)

7.10 The report concludes, "If a specific proposal for a UCG demonstration site is being considered, a 'citizen panel' consisting of a cross-section of the public in the locale might be constituted in order to provide advice on how a proposal should be developed. The local public and stakeholder reaction should be part of site selection process, alongside the more tangible issues such as coal geology, hydrogeology and other planning issues. Other possibilities for the future could include: development of a professional communication strategy, before any trial site is selected, setting up of an information web site, and the production of other suitable publications."

7.11 Many of the issues, perceptions and attitudes reported and suggested in the Silverdale Study align with views presented a decade and more later by community representatives in Scotland and this is reflected in the submission of the Broad Alliance at Annex 2. A lack of confidence in operators, regulators and government was evident in discussion and the situation is more complicated as a result of knowledge of former mining, even if active coal mining is now more distant in time, impacts being even less certain as well as the sub-estuarine context, the historic lack of consultation or engagement about projects likely to influence the community and its environment, as well as increased awareness of climate imperatives and the performance of the industry internationally.

7.12 There is no similar work from the Scottish context but studies appear to have been undertaken with sociological, psychological and other health objectives. It would be highly desirable to collate and expand this work as well as obtaining baseline data on perceptions in this context.

7.13 Within the National Planning Framework discussed earlier, there are objectives for land-use planning that makes Scotland "a low carbon place", with an ambition that we have greater "wellbeing and opportunity", and with "increase(d) solidarity". Community planning is also highlighted. The ways in which the planning system will deliver this and how the public generally and specific local communities in particular, might be more fully engaged in consideration of significant infrastructure, is not clearly spelled out. Using existing planning processes, up to and including Public Inquiries, planning appeals and call-in mechanisms connected to representations and petitions, etc. would all be considered in scope. It raises the question of whether this is sufficient and if or how this could be done better.

7.14 A particular challenge is in identifying "the community". In the case of a project under the FoF, what and where is the community? What is local? Which community? Gasified coal panels somewhere under the Firth wouldn't have a community over them. In some respects the whole estuary area and communities on both sides of the river would be in scope. More likely perhaps the notion and framing of community might rather relate to those closest to, or surrounding, the onshore syngas facility and not the sub-marine, sub-estuarine site itself. However, those along a pipeline route, a further processing facility or geologically connected to hazards of seismicity, or groundwater, air quality, light, vibration, noise or transport issues might be justifiably included. It is a question to consider.

7.15 Consideration too might be given to how a community engages or agrees to be involved. It might be that consideration of the potential use of a voluntarism approach and the lessons learned from the UK Committee on Radioactive Waste Management's ( CoRWM) public consultation approach both generally and around the West Cumbria casework would also be beneficial ( DEFRA, 2006 and later DECC published materials from CoRWM). CoRWM has engaged widely in challenging circumstances but has also looked at public engagement, planning processes and delivering longer-term challenges on the basis of a partnership between the implementer and the community in France, Sweden and Finland, is exploring this in the UK context and also recently provided advice to the Australian Nuclear Fuel Royal Commission.

7.16 Whilst clearly not the same as radioactive wastes, UCG presents challenges to the status quo at community level and if imposed (as perceived) rather than embraced, difficulties are likely to be considerable given the evidence considered. It would be advisable for there to be careful consideration of lessons that can be learned about using long term approaches; establishing public positions and concerns, engaging communities and ensuring they are best able to be informed, take informed decisions and share in the development, custody and benefits of a local activity. These issues seem to remain areas of real challenge and opportunity.

7.17 An additional consideration, to some extent framing any issues around regulation, industry performance, energy policy, etc. is the question, "Does a General Social Licence to operate exist?", through what is essentially a moral and ethical position assessment. Is it right to exploit UCG and further carbon from coal or to impose a balance of costs and benefits such that it is possible for a perception to be broadcast that private benefits are being set against public (social/environmental etc.) costs without explicit public support or consent? If, however temporarily, the trajectory of decarbonisation or carbon exploitation were seen to be being reversed, would compensations be sufficient to support the case?

7.18 The UK government has proposed a fund to support communities where UGE progresses in England. Community trusts for some renewables exist in Scotland and have proved beneficial for community developments ensuring a flow of benefits from energy projects.

7.19 A further question exists around the distribution of costs and benefits. Without CCS, UCG would likely be a net contributor of GHGs. Progressing without it would make the Scottish and global impacts greater. Not managing liabilities effectively would leave Scotland and the community exposed to negative impacts. Generally these raise issues of morality and of fairness. Similarly, how is engagement achieved? Is demonstrable support actually required? Planning process and the policy of the day would give projects a permissive or oppositional context. Voluntarism would more likely ensure consent of a community. The levels of opposition seen around the Hands Across the Forth and Frack Off events in 2015 as well as earlier around the Dart CBM project at Airth simply serve to highlight the challenge.

7.20 The Broad Alliance submission at Annex 2, Concerned Communities of Falkirk reports (2014, 2015) and FoES (2015) as well as FoEI (2016) raise a range of issues about community concerns.

7.21 Contextualising and summarising these through the Broad Alliance Submission, these concerns appear to be as follows:

• UCG will have a negative impact on climate targets for Scotland, especially without CCS
• The industry has a poor reputation and has performed poorly worldwide
• Kincardine and FoF generally are unsuitable areas for licensing UCG not least on the basis of the geological conditions, history and information inadequacies
• Earthquake risks are considered serious and uncertain
• Environmental and health and safety impacts of tests worldwide are negative and plainly damaging, although poorly documented and could affect communities and workers
• Regulators do not have the tools or the staff to do the job properly, including the licensing and monitoring work needed
• Operators have stated operations are safe and will not cause damage but information available, including legal cases, contradicts this and raises concern and doubt
• If it has been banned in Queensland, why is it acceptable here?
• BA has no confidence that community views will be adequately considered in any specific application
• Economic opportunities are believed to be seriously overstated
• If UCG progresses it will damage the reputation of affected areas, their economic wellbeing and scope for green investment

7.22 These issues are understandable and at least in part supported by the evidence available. It seems reasonable to consider that all ought essentially to be taken seriously and addressed with specific responses based upon robust interpretations of the evidence, connected to new or publicised existing performance data and other relevant evidence, together set against a stance of reasonable precaution.

7.23 The views represented are strongly held and suggest sufficiently deeply rooted negative attitudes that no short-term dramatic improvement seems likely.

References

Concerned Communities of Falkirk. (2014) Submission to the public inquiry on dart energy coal bed methane proposal, Falkirk, Scotland, 2012-2015.

Concerned Communities of Falkirk. (2015) Community voices,
http://www.faug.org.uk/ about/community-voices

DEFRA (2006) Response to the Report and Recommendations from the Committee on Radioactive Water Management ( CoRWM) by the UK Government and the Devolved Administrations.
http://130.88.20.21/uknuclear/pdfs/corwm-govresponse.pdf
See also https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/330641/CoRWM_3157_2013-14_Annual_Report_FINAL.pdf

And linked documents assessing the French, Swedish, Finish and other experience in public engagement and voluntarism.
http://www.tcpa.org.uk/spatial-planning-and-energy-for-communities
https://rwm.nda.gov.uk/publication/societal-aspects-of-geological-disposal/?download

and

Strandberg, U. and Andren, M (2011) Nuclear Waste Management in a Globalised World. See c p122 on Reconstructing legitimacy through deliberative appraisal. This considers voluntarism and dialogue against previous directive processes for locational decisions.
https://books.google.co.uk/books?id=qQLcAAAAQBAJ&pg=PA125&lpg=PA125&dq=Voluntarism+and+CoRWM&source=bl&ots=OZl2xqGZxj&sig=tOv6o9EFnYGVB44TZcSWa_VlN-&hl=en&sa=X&ved=0ahUKEwiE45XT2ObOAhUBKMAKHc5OByoQ6AEIPTAG#v=onepage&q=Voluntarism and CoRWM&f=false

Friends of the Earth Scotland. (2015) Broad Alliance letter to MPs on Infrastructure Bill,
http://www.blog.foe-scotland.org.uk/index.php/2015/01/broad-alliance-letter-to-mps-on-infrastructure-bill/

Shackley, S., Reiche, A. and Mander, S. (2004) The Public Perceptions of Underground Coal Gasification ( UCG): A Pilot Study. Tyndall Centre for Climate Change Research, Working Paper 57 ("The Silverdale Case")

Whitmarsh, L, Nash, N, Upham, P, Lloyd, A, Verdon, JP and Kendall, J-M (2015) UK Public perceptions of shale gas hydraulic fracturing: The role of audience, message and contextual factors on risk perceptions and policy support. Applied Energy 160, 15 December 2015, 419-30
http://www.sciencedirect.com/science/article/pii/S0306261915010727