Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report

10 OIL AND GAS

Chapter summary

• A key theme emerging was the need for more recognition of the impact of this sector on climate change; with some queries as to the compatibility of the oil and gas policies with the strategic objectives and policies relating to climate change.
• There were some requests for more detail on the decommissioning or re-use of oil and gas infrastructure.
• There were some concerns on the impact of the oil and gas sector, particularly in regards to the environment; for example, the provision of safeguards for the historic environment.
• There were also a number of calls for greater consideration of the interactions between the oil and gas sector and other sectors.
• There were also a small number of requests for references to the need for co-ordination between marine and land use planning, or for other relevant legislation to be considered; for example, the UK implementation of the EU offshore safety directive.

10.1 The Draft National Marine Plan introduced this chapter by noting that the Scottish Government supports a low carbon economy that involves the move away from fossil fuel based energy consumption towards investment in renewable energy and increased energy efficiency. That said, oil and gas are set to remain a source of energy while Scotland moves towards a future based on renewable energy. In 2012 Scotland launched its oil and gas industry strategy with an over-arching objective to maximise recovery of reserves through a focus on industry-led innovation, enhancing skills base and supply chain growth.

10.2 The Draft NMP went onto examine key issues for marine planning, outlined six oil and gas policies and assessed the future for the oil and gas sector.

Comments on Oil and Gas, Chapter 9

10.3 Two questions were asked:

Question 19: Do you have any comments on Oil and Gas, Chapter 9?

Question 20: Are there alternative planning policies that you think should be included in this chapter?

10.4 As can be seen from table 10.1, 44 respondents across a range of sub-groups provided a response to question 19.

Table 10.1 Question 19: Do you have any comments on Oil and Gas?

Respondent group
Individuals (16)	2
Academic / scientific (7)	3
Aquaculture (5)	-
Energy (12)	4
Environment / conservation (9)	7
Fisheries (13)	3
Historic / Heritage (5)	3
Industry / transport (9)	2
Local Authority (15)	9
Local coastal partnership (7)	3
Local group (5)	-
Other public sector (10)	5
Recreation / Tourism (7)	2
Other (4)	1
Total (124)	44

10.5 A number of themes emerged, most cited by a small number of respondents. As with other sectoral chapters, some respondents noted their support for this chapter or for different elements of this chapter.

10.6 One theme was that of climate change, with the key comment being that this chapter needs to have more recognition of the impact of this sector on climate change. A small number of respondents questioned the compatibility of the oil and gas policies with the strategic objectives and policies relating to climate change. These comments came primarily from respondents within the environment/ conservation sector and the public sector.

10.7 While most comments relating to climate change were in relation to the impact of the oil and gas sector on climate change, one respondent noted that climate change could lead to more severe weather which could impact on the oil and gas infrastructure and health and safety within the sector. A respondent within the environment/ conservation sector commented that where possible, preference should be given to renewable energy rather than fossil fuel extraction.

10.8 A few comments were made in relation to the decommissioning or re-use of oil and gas infrastructure, with some requests for more consideration given to this in the NMP. One respondent in the academic/ scientific sector suggested that research is needed to improve the evidence base regarding either the impact of the removal of the infrastructure, or the impact of leaving this in place. Another respondent within the public sector commented that Marine Scotland and the Scottish Government need to work with the industry and regulators to ensure that decommissioning activities consider future use for CO2 storage.

10.9 An issue related to this and raised by respondents primarily within the fishing sector, was the identification of sea areas that would have least impact on fisheries and other sensitive areas for the mooring of redundant rigs and structures that are awaiting decommissioning. There was also a suggestion that impacts on marine nature conservation need to be considered within an Environmental Impact Assessment for any decommissioning programme.

10.10 A number of respondents commented on the impacts of the oil and gas sector, many of which related to the impact on the environment. There was a request for the NMP to provide a clear direction to marine planners to prevent new oil and gas exploration in areas considered to pose significant environmental risks. Three respondents within the historic/ heritage sector commented,

"The potential for offshore oil and gas exploration and development to impact upon the historic environment and the need for appropriate safeguards should be recognised in policy and supporting text. Although it is true that 'offshore oil and gas exploration and development is subject to a requirement for an environmental impact assessment' (which will consider the impact of development, amongst other things, on the marine historic environment), this potential impact should be addressed in the National Plan."

10.11 Other impacts that respondents would like to see addressed in the NMP included the impact on small scale geodiversity features on the seabed, the impact of potential oil spills, the impact on other related industries.

10.12 There were also some calls for a greater consideration within this chapter of the interactions between the oil and gas sector and other sectors such as recreation and tourism, fisheries or shipping.

10.13 There were also a small number of requests for references to the need for co-ordination between marine and land use planning, or for other relevant legislation to be considered; for example, the UK implementation of the EU offshore safety directive.

10.14 One Local Authority respondent noted they are currently considering their position on mineral extraction and looking at its policy on shale gas and requested consultation on any developments affecting the marine environment in their area.

Additional policies for this chapter

10.15 Several respondents noted additional policies to be included in this chapter and these were as follows:

Decommissioning

• More detail/ attention could be given to the decommissioning of existing oil and gas extraction infrastructure, particularly in terms of any potential policies that may affect and/ or guide this;
• There is currently no clear policy to ensure that closure, abandonment and de-commissioning of oil and gas infrastructure is regulated in a manner conducive to re-use of depleted reservoirs by interested CO ₂ storage operators;
• Additional policies should be included that consider the decommissioning of oil and gas infrastructure;
• Guidance on decommissioning and the potential use of structures as artificial reefs would merit further consideration within the plan;
• A policy that supports integration between Regional Marine Plans and Local Development Plans should be included in the NMP. Where opportunities to develop new land based facilities to support decommissioning of oil and gas infrastructure are identified, it is essential that marine and land use planners co-ordinate efforts to ensure appropriate land use allocation in the right locations;
• We believe that ports will be required to play an important part in the future in terms of de-commissioning some oil and gas equipment; this could represent a significant new business opportunity for ports and the Scottish economy. Greater recognition in the NMP could be made of this to support future developments in the area.

Pollution

• A planning policy associated with action to minimise the effect of any pollution caused by an accident on a platform or damage to a vessel transporting oil. One of the consequences of an oil spill would be that affected cruising areas would become much less attractive with a consequent effect on local economies;
• A planning policy associated with procedures were there to be a pollution causing incident - this affects all users of marine areas so protocol and research into likely impacts needs to be assessed.

Other

• A policy on retention (as in Chapter 8) which encompasses any and all impacts of the oil and gas sector on migratory fish - this policy should be cross-referenced with this chapter;
• A policy or statement detailing what will be set out in the regional marine plans with regard to this section;
• A policy that rewards responsible management of these resources for the future;
• A policy against fracking.