Coal extraction: consultation analysis

3 Findings

3.1 This chapter provides an analysis of the responses received to the Scottish Government's call for evidence on coal extraction. The first section presents a brief overview of the responses. This provides context for the remainder of the chapter, which summarises the findings of the thematic qualitative analysis.

Overview of responses

3.2 As noted in Chapter 2, a total of 21 responses were received in response to the call for evidence on coal extraction.

3.3 Most of the nine individuals who submitted responses provided short comments (no more than a few paragraphs), often containing statements of views rather than evidence per se. One individual provided a fuller response and an accompanying attached document.

3.4 Four individuals were opposed to coal extraction (mostly citing climate-related reasons), and five thought coal had a role, at least on a transitional basis, in meeting Scotland's future energy needs, and that this should be reflected in the refreshed Energy Strategy.

3.5 The 12 organisational responses ranged from short, single-point submissions to lengthier submissions presenting technical evidence and statistics.

3.6 Seven organisations (including public sector bodies, academic / research and environmental bodies) were opposed to future coal extraction – mainly citing climate-related reasons and expressing supported a transition to a low-carbon energy system.

3.7 Of the five remaining organisational responses, two expressed support for coal extraction for use in the heritage sector and more widely. These respondents cited economic, environmental and cultural arguments. The remaining three respondents did not express a view on future coal extraction but raised other relevant to the call for evidence.

3.8 The findings from the thematic qualitative analysis are set out below under three headings (i) support for future coal extraction (ii) opposition to future coal extraction (iii) other relevant issues. Key themes identified in the responses and addressed below included climate change and the transition to a low carbon economy, energy security and Scotland's energy mix, and the continuing need for coal in different economic sectors. The themes discussed by respondents were often interlinked; however, as far as possible, each topic is discussed in detail only once in the sections that follow.

Support for future coal extraction

3.9 There were two key linked themes in the responses from those who supported future coal extraction in Scotland: (i) energy security and (ii) the continuing need for coal in different economic sectors. Views on both of these issues are discussed below. Respondents in this group also often discussed climate change and the Scottish Government's stated policy objectives relating to the transition to a low carbon economy, and views on these issues are also presented.

Energy security and Scotland's energy mix

3.10 Respondents who supported future coal extraction argued that Scotland had plentiful coal reserves that should be exploited to improve the country's energy security. These respondents thought that domestic coal should be part of Scotland's energy mix as this would:

• Reduce reliance on expensive imported coal; offer economic, employment and environmental benefits; and avoid supply chain volatility caused by world events such as the war in Ukraine
• Offer a reliable and proven source of energy for use alongside renewables and / or until alternative renewable sources are available on a large enough scale to meet demand
• Help preserve Scotland's oil and gas reserves for other purposes (e.g. in the manufacturing and the chemical sectors)
• Help keep fuel prices at an affordable level.

3.11 Additionally, it was suggested by one respondent that coal is less vulnerable to hostile attacks than other fuel supplies such as oil and gas.

3.12 Some respondents said that the use of coal could be enhanced by ensuring it was used in the cleanest, most energy efficient and economical way.

3.13 Some respondents also called for the use of coal bed methane and coal gasification as alternative or additional sources of energy.

The continuing need for coal

3.14 Some respondents argued that, in addition to being a source of energy, coal fulfilled a number of important industrial and economic functions. They highlighted its use in the production of steel, aluminium, cement, carbon fibre and silicon metal, and its role in the manufacture of chemicals used in a range of different industrial processes. One respondent pointed to information produced by the British Geological Survey and the Centre for Sustainable Carbon detailing the various uses of coal.

3.15 Respondents made the point that there is currently no viable alternative to the use of coal in such industrial processes, and that Scotland will therefore continue to need a supply of coal for the foreseeable future. Without a domestic supply, Scotland would have to rely on imported coal. Respondents argued that imported coal was more expensive than domestic coal and had the effect of 'off-shoring' carbon emissions or even increasing them because of the distances involved in transporting such coal to its final destination.

3.16 Three respondents (two organisations and one individual) drew particular attention to the use of coal in the heritage sector. These respondents argued that:

• Heritage railways and other industrial heritage sites and attractions operating steam powered machinery have a very specific ongoing need for low volumes of high-quality coal which is currently imported at high (financial and environmental) cost.
• There is currently no alternative to using coal in this sector – one respondent said that development work was currently underway in this field but that there was no government support for research and development in this area.

3.17 These respondents said domestic coal extraction should be allowed to meet the needs of this niche low-emission sector.

3.18 Two of the respondents involved in the heritage sector also argued that coal had a place in Scotland's energy mix more generally, for economic and environmental reasons.

Climate change and the transition to a low carbon economy

3.19 Respondents who favoured further coal extraction often acknowledged the issue of climate change and / or the need to cut carbon emissions (or they accepted the Scottish Government's commitment to acting on these issues). However, these respondents argued that using domestically sourced rather than imported coal could contribute to an overall reduction in global carbon emissions, because of the shorter transportation distances involved. One respondent described the assumption that a ban on coal extraction in Scotland would reduce emissions as 'seriously flawed'.

3.20 These respondents made the point that coal would continue to be used within Scotland for many years to come (see paragraphs 3.14 to 3.18 above), and they claimed that relying on imported coal would 'commit the Scottish Government to nearly a quarter of a century of higher overall emissions for residual users of coal and substantial off-shoring of emissions'.

3.21 Respondents also made the following additional points:

• There was scope for mining operations to become carbon neutral, using electrical power and carbon off-setting
• The Government's net zero policy was out of step with the availability of suitable alternative energy sources such as renewables, and exploiting domestic carbon fuel sources would be required meantime
• Ensuring that people could afford to heat their homes should be prioritised over achieving net zero targets.

3.22 Respondents argued for (i) a strategy that differentiated between a position that was opposed to any extraction of fossil fuels and one that allowed some (limited) coal extraction, and (ii) an approach that recognised the different coal extraction processes, and the associated risks involved, and considered each application on its merits.

3.23 One individual said that further public debate was required on this issue.

Opposition to future coal extraction

3.24 As noted above, around half of respondents to the call for evidence expressed opposition to further extraction of coal in Scotland. The prime concern for these respondents was tackling climate change.

3.25 In general, these respondents emphasised the global challenge of climate change and the need to take immediate action on this issue. They highlighted Scotland's international climate change obligations and endorsed the Scottish Government's policy activity in this area. They argued that any future coal extraction would be incompatible with Scotland's wider efforts to move towards becoming a low carbon economy and would make it harder to meet the Scottish Government's net zero targets.

3.26 Respondents referred to the legally binding Paris Agreement on climate change and the scientific work of international bodies such as the Intergovernmental Panel on Climate Change (IPCC) and the International Energy Agency (IEA), which has highlighted the urgency of moving away from fossil fuel extraction and use. They also highlighted statements from the United Nations and the IEA calling for immediate action on this issue.

3.27 In making their case, several respondents drew attention to the particularly high carbon emissions associated with the extraction and burning of coal relative to other fossil fuels. The risks posed to human health and the environment from burning coal were also noted.

3.28 Respondents also countered some of the arguments put forward (above) by respondents who supported coal extraction, as follows:

• On the issue of energy security, respondents opposed to coal extraction argued that energy (and economic) security would be best addressed though a transition to clean energy sources, the development of renewables, and improvements in energy efficiency. One organisation cited work by the IEA which had concluded that it was possible to transition to a net zero stable and affordable energy system providing 'energy access and economic growth' without further coal exploration and extraction.
• On the issue of the continuing use of coal, one respondent highlighted the use of coal in the steel industry as a major contributor to carbon emissions in the UK. This respondent argued that any effort to address carbon emissions had to address the decarbonisation of the steel industry too, albeit that this had to be tackled on an international level because of the global nature of the steel industry. This respondent expressed opposition to coal imports as well as domestic coal extraction.

3.29 In addition to highlighting the impact on climate change, respondents in this group also noted the negative effect of coal mining and coal use on the environment (e.g. in terms of water and air pollution), nature, and human health.

3.30 Respondents in this group were united in their view that the Scottish Government should take steps to prevent any future coal extraction in Scotland. Respondents urged the Scottish Government to:

• Adopt a policy position of no support for coal extraction in Scotland, and to enforce this using the powers available to them though the planning system
• Prioritise the achievement of existing net zero targets and ensure a 'managed and just transition' away from fossil fuels.

3.31 One organisational respondent suggested that the Welsh Government's 2021 Coal Policy Statement might provide a starting point for the Scottish Government in developing its own policy.

Other views

3.32 One individual provided a somewhat different view in their short response to the call for evidence. They made two points, suggesting that (i) coal extraction should not be considered until 'cleaner' processes for extraction were available, and that (ii) hydrocarbons (i.e. coal) represented a valuable and finite resource and should be reserved for processes other than energy production.

Other issues raised

3.33 Four further themes identified in the responses related to (i) Scotland's heritage, (ii) the legacy of the coal mining industry, (iii) the need for a just transition to a low carbon economy, and (iv) information and research. Each of these are discussed briefly below.

Scotland's heritage

3.34 A number of responses to the call for evidence discussed issues related to aspects of Scotland's heritage. These issues were raised by respondents in favour of further coal extraction, and those who did not offer a view on this overall issue.

Scotland's industrial heritage

3.35 Several respondents focused on industrial heritage in their responses and noted the importance of celebrating Scotland's long history of involvement in the coal industry, and the contribution made by miners and mining communities to the country's industrial and cultural heritage. These respondents drew attention to the importance of heritage sites and industrial museums in this context – highlighting the benefits they brought to the tourism sector and the economy as a whole, their role in encouraging interest in science and technology in new generations, and their ongoing need for some residual coal supply. There were calls for this to be recognised in any policy.

Scotland's historic environment

3.36 One public sector respondent noted that the move away from carbon fuels would necessarily entail a greater reliance on renewable energy sources, including wind farms. This respondent called for future developments in this area to be implemented sensitively. They highlighted the impact such development could have on the way the historic environment is 'understood, appreciated, and experienced', and called for 'a mix of appropriately sited and designed renewable energy sources…deployed to meet our future energy needs'.

The legacy of the coal mining industry

3.37 Organisational respondents raised three issues with regard to dealing with the legacy of former coal mining sites: ensuring safety, exploiting sites as a future energy source, and restoring sites for community benefit. These issues were raised by respondents opposed to further coal extraction, and those who did not offer a view on this overall issue. Both positive and negative legacy issues were identified. Each issue is discussed briefly below.

• Ensuring the safety of former coal mining sites: The ongoing challenge of ensuring the safety of old mine works was raised by some respondents. It was particularly noted that polluted water discharging from old mines could contaminate the local water system and have a negative impact on local ecology and the environment. Current post-mining monitoring and mitigation activity was said to involve significant resources. This activity would be required for some time into the future and adequate future provision would have to made for this to ensure a safe and 'nature positive' transition to a low carbon economy.
• Exploiting former coal mines as a future energy source: Two respondents noted that the water in abandoned mines could be used as a source of clean geothermal energy that could help Scotland meet its net zero emissions target. One respondent said that the heat energy contained in the water in former mines could provide up to 30% of Scotland's heating needs, and that developing this resource could bring social and economic benefits. A second academic respondent highlighted their own research facility which was already investigating the potential to use the 'proven but not widely realised' technology of mine-water heat abstraction.
• Restoring old coal mining sites for public benefit: Several respondents noted the importance of transforming old mining sites 'from environmental liabilities into assets for local communities', providing green spaces for people and habitats for encouraging wildlife and nature. Respondents cited examples in Scotland that could provide lessons for future restorative work. However, one respondent expressed concern that the standard of such remedial work may suffer because of a shortfall in funding.

Ensuring a just transition to a low carbon economy

3.38 Two organisational respondents emphasised the importance of achieving a 'just' transition to a low carbon economy – both for communities affected by historical mining activities and for those employed in high carbon industries. In relation to this latter group, these respondents said there should be support so that people can gain the necessary skills to take up employment in new fields such as the renewables sector. They also called on the Scottish Government to work with the trade unions and with workers themselves in addressing this issue, and to use the Just Transition Fund to provide training for industries of the future. However, it was pointed out that the fact that there was currently no coal extraction in Scotland would mean that a policy position opposed to future extraction would not have any direct impact on people working in these industries.

3.39 One respondent argued that action was needed to ensure a just transition globally, as well as within individual countries.

Information and research

3.40 Finally, one academic organisation highlighted the availability of detailed geological information on mineral resources in Scotland that could be used to inform decision making in this area.