Onshore conventional oil and gas - call for evidence: analysis of responses

3 Findings

3.1 This chapter presents the main findings from an analysis of the responses to the call for evidence on onshore conventional oil and gas. An initial descriptive overview of the responses is provided. This is then followed by a qualitative, thematic analysis of the responses.

Overview of responses

3.2 Of the nine individuals who submitted responses to the call for evidence, all submitted very short comments (in some cases, just a line or two) containing views, rather than evidence per se. Among these respondents, four were opposed to the development and / or extraction of onshore conventional oil and gas (for climate-related or other reasons), and five thought it should have a role in Scotland's refreshed Energy Strategy for reasons of energy security.

3.3 The 15 organisational responses were more variable in nature and length – ranging from short, single-point submissions to lengthier submissions presenting technical evidence and statistics. Four organisations (all from the oil and gas industry) supported further exploration and exploitation of onshore oil and gas by conventional means (for economic and energy security reasons). Some also supported development of unconventional oil and gas. As the subject of unconventional oil and gas was out of scope in relation to this call for evidence, this material has not been analysed. Eight organisations (including public sector bodies, academic and environmental bodies) were not supportive of the development of onshore conventional oil and gas reserves (primarily for climate-related reasons). The latter group thought Scotland should stay focused on transitioning fully towards a low-carbon energy system. The three remaining organisational respondents did not express a view for or against onshore conventional oil and gas development in Scotland, but rather discussed issues relating to future information and data needs, and the place of oil and gas in heritage / historical attractions.

3.4 The main points made in response to the call for evidence are summarised below. Key themes in the responses related to climate change, energy security, economic impacts, the need for a just transition to a net-zero economy, information and data and its importance for future decision-making, and the role of oil and gas in heritage sites and attractions.

Support for the development of onshore conventional oil and gas

3.5 Respondents who expressed support for the development and extraction of onshore conventional oil and gas in Scotland gave two main reasons: (i) that it was in the interests of Scotland's energy security – as least in the short to medium term, and (ii) that significant carbon reductions would result from developing a domestic source of onshore conventional oil and gas. This group also highlighted the potential economic benefits for Scotland.

Energy security

3.6 Respondents in favour of developing onshore conventional oil and gas production highlighted the ongoing uncertainty of the war in Ukraine and the way in which this was putting Scotland's energy security at risk. They suggested that there was an opportunity for Scotland to develop its own oil and gas supply that is not subject to price fluctuations on the world market and would provide a security of supply.

3.7 Moreover, this group argued that it would be necessary to continue oil and gas production in the short to medium term, until Scotland's energy needs could be fully and securely met from renewable sources. It was suggested that onshore oil and gas exploration licences could be awarded with specific end dates so that, as Scotland required less oil and gas, production could be reduced and finally stopped.

3.8 One respondent from the oil and gas industry pointed out that production of oil and gas in the North Sea is declining. This respondent suggested that, by 2035 Scotland's use of gas may be higher than the gas being produced from the Scottish sector of the North Sea. Thus, there is an ongoing need to source additional oil and gas supplies to meet Scotland's energy demands, at least on a transitional basis. This, it was suggested, needs to be recognised in forward planning.

3.9 However, at the same time, there was a recognition that exploration (i.e. 3D seismic surveys) would be required to assess the full potential for onshore conventional oil and gas production in Scotland, and there was also an acknowledgement that, based on historical drilling, Scotland's onshore conventional oil and gas reserves are likely to be 'modest' in quantity.

Climate change

3.10 Respondents who supported the development of onshore conventional oil and gas in Scotland frequently pointed to the potential environmental benefits of pursuing a policy that enabled this to go ahead. They suggested that allowing some limited onshore conventional oil and gas production would be a step towards achieving Scotland's net zero ambitions, as onshore production in Scotland could replace oil and gas production with higher associated emissions.

3.11 This group noted that energy imports to Scotland have increased in recent years, and they argued that onshore domestic oil and gas production would be less carbon intensive than importing oil and gas. Furthermore, it would also result in fewer carbon emissions than current offshore domestic production, since workers would be able to travel by bus instead of helicopter and it may be possible to pipe onshore gas directly into the local gas grid, rather than spending energy on pumping it from offshore.

3.12 They also suggested that onshore oil and gas production would complement and facilitate other forms of clean energy, in particular geothermal energy, as it may be possible to repurpose oil and gas boreholes for borehole thermal energy storage (BTES).

3.13 It was suggested that 'limited (rather than unlimited)' onshore production would help achieve Scotland's climate change targets, and there was a view that, 'if the Scottish Government decided to ban onshore oil and gas production, it could be criticised for not being serious about climate change'.

Potential economic benefits

3.14 Respondents in favour of onshore conventional oil and gas suggested that onshore oil and gas would bring economic benefits to Scotland and to local communities, which would, in turn, bring social and health benefits.

3.15 One respondent in this group commented that companies involved in onshore production would pay significant sums in business rates and would also pay tax at a rate of 65%. Furthermore, oil and gas operations would create jobs and stimulate economic activity. Reference was made to the prosperity that the oil and gas industry brought to Aberdeenshire, which has a greater life expectancy and fewer areas of multiple deprivation than other parts of Scotland.

Other points raised

3.16 Other points made by respondents supporting onshore conventional oil and gas – in most cases, usually by just one or two respondents – were that:

• Oil and gas are not only needed for energy, but also for the pharmaceutical industry and a range of manufacturing purposes. It was suggested that 'it makes no sense' to import these resources when Scotland has the raw materials in the ground.
• The oil and gas industry pledged (in October 2021) to work towards net zero in its operations. Targets have been set to halve greenhouse gas emissions by 2030, to achieve a 90% reduction by 2040, and to reach net zero by 2045. As these targets would be easier to achieve in onshore production (as compared with offshore), it may be possible to meet these targets earlier in onshore development.

Opposition to the development of onshore conventional oil and gas

3.17 In general, respondents who were opposed to the development and extraction of onshore conventional oil and gas in Scotland focused their arguments on the issue of climate change. Other themes frequently arising in the responses from this group related to: (i) energy security, and (ii) the need for a just transition to a net zero economy. Less often, respondents discussed the potential economic impacts of any possible onshore conventional oil and gas development, which, in the views of this group, were largely negative.

Climate change

3.18 There were three recurring points made by respondents in this group regarding the issue of climate change. The first point was that any new onshore conventional oil and gas developments would be inconsistent with Scotland's stated climate change ambitions. The second was that pursuing such a policy would undermine Scotland's international obligations. The third, and final point was that the Scottish Government should continue to focus on developing and investing in renewables and other clean energy sources, and reducing energy consumption.

Inconsistent with Scotland's stated net zero ambitions

3.19 First, respondents argued that the development of new onshore conventional oil and gas reserves would be inconsistent with Scotland's stated ambitions to achieve net zero by 2045 and would decrease the likelihood of Scotland achieving this target. Respondents described any possible onshore conventional oil and gas development as a 'backward step'.

3.20 They argued that such a policy would also conflict with expert scientific advice on reaching net zero and undermine the Scottish Government's credibility with the public. The point was made that public credibility is important given that, in order to achieve Scotland's targets, the public will be increasingly asked to make changes in their own lives (for example, in reducing personal car use and replacing fossil fuel boilers).

3.21 Respondents in this group wanted the Scottish Government to continue to adopt an approach that would fully support the delivery of the current Climate Change Plan^[2] and align with the position set out in the draft Fourth National Planning Framework (NPF4), which states that 'planning applications that seek to explore, develop and produce fossil fuels will not be supported other than in exceptional circumstances'.^[3]

3.22 This group emphasised that a policy of no support for onshore conventional oil and gas would ensure that (i) the Scottish Government's net zero targets do not become unnecessarily harder to meet, (ii) the Scottish Government is seen to be consistent with its own stated ambitions, and (iii) the Government's approach is in line with expert advice.

3.23 One academic respondent pointed out that, as the level of carbon emissions produced by the UK is lower than the global average, there could in theory be some environmental 'advantage' to developing onshore domestic oil and gas production. However, this same respondent also noted that the UK is not outperforming its biggest import partner, Norway, which has significantly cleaner operational production. Furthermore, they commented that the UK Government's stance in relation to continued domestic production has drawn criticism from climate change policy analysts.

Undermines international obligations

3.24 Second, respondents argued that any future extraction of oil and gas in Scotland would be contrary to, and undermine, Scotland's international obligations. This group pointed to the legally binding Paris Agreement (signed by the UK Government), recommendations of the Intergovernmental Panel on Climate Change (IPCC) which called for an end to all new development of fossil fuels, and the endorsement of the IPCC recommendations by the United Nations.

3.25 Some respondents also commented that other countries (including Denmark, Costa Rica, Ireland, France, etc.) have all ended support for new fossil fuel extraction within their territories.

Prioritise clean energy sources and reduce consumption

3.26 Finally, respondents who were opposed to the development of new onshore conventional oil and gas reserves repeatedly stated that the Scottish Government's priorities and investment should be focused on producing green energy and reducing energy demands. One Central Belt local authority respondent commented that, in terms of future planning within their area, the focus would continue to be on these issues, rather than developing oil and gas facilities or refineries.

3.27 Some respondents highlighted specific areas where the Scottish Government should focus its efforts. These included: improving the energy efficiency of Scotland's housing stock, facilitating the electrification of heating, and exploring the opportunities of geothermal energy.

Energy security

3.28 Respondents who were opposed to the development of onshore conventional oil and gas argued that such development would not provide greater energy security.

3.29 One respondent cited research which indicated that onshore conventional oil and gas resources in Scotland were likely to be very small. This respondent noted that the only areas with proven petroleum systems in Scotland were located in Skye, Easter Ross, the Sutherland Coast and the Midland Valley, all of which have previously been tested by well bores. This same respondent commented that, given the time required between exploration success and field development approval, any Scottish onshore licences awarded now were unlikely to contribute to a supply of oil and gas until the 2030s. Thus, in the short term, onshore conventional oil and gas will not improve Scotland's energy security.

The negative economic impacts of new onshore oil and gas production

3.30 Respondents who were not supportive of the development of onshore conventional oil and gas in Scotland argued that a continued reliance on oil and gas was impoverishing people in Scotland.

3.31 These respondents argued that the primary driver of the recent surge in the cost of energy bills was the international wholesale cost of gas. They pointed out that there would be no guarantee that any gas extracted in Scotland would remain in the UK; instead, they suggested, oil and gas operations were carried out by private companies and any supplies would be sold on the global market to the highest bidder. They noted that UK households in the UK were being pushed into fuel poverty because of the sudden shortage of oil and gas elsewhere in the world.

3.32 They also pointed out that any suggestion that the development of new onshore conventional oil and gas reserves in Scotland would address the current energy crisis failed to take account of the timescales involved (as discussed in paragraph 3.29 above). Given that any onshore conventional oil and gas development would be unlikely to produce a supply of oil and gas before the 2030s, a policy supporting such a development would not alleviate the current energy crisis. Instead, it was suggested that the simplest solution to the current crisis was to use less gas. This would require a 'concerted and rapid effort' to improve the energy efficiency of Scottish homes, increase the energy generation capacity of renewables, and support the transition in domestic heating systems from gas to heat pumps.

3.33 In addition, one respondent cited evidence suggesting that any onshore oil and gas operations in Scotland were likely to be relatively small, and therefore the associated employment potential of such operations would be limited.

Just transition to a net zero economy

3.34 In terms of creating a fair and just transition to a net zero economy, some respondents discussed the need to support oil and gas workers to gain training and employment in other sectors such as the renewables industry. Those who raised this issue argued that continuing to pursue the expansion of fossil fuels would undermine the wider strategy needed to ensure a well-managed phase-out of the fossil fuels industry in Scotland. This, in turn, could put the livelihoods of oil and gas workers at risk.

3.35 The point was also made that, given that there is currently no onshore oil and gas production in Scotland, there can be no impact on workers from a policy of not supporting onshore conventional oil and gas.

3.36 One respondent also highlighted the importance of working towards a 'nature positive' just transition. This respondent said that, as well as facing a climate crisis, the world is also facing a 'nature crisis' and they expressed concern that an increasing reliance on renewables may put increasing pressure on environmentally sensitive areas. It was suggested that the transition to a low-carbon economy should not be at the expense of nature or the natural environment. Specific concern was expressed about the use of increasingly taller turbines, which has created pressure on the natural environment and also on the way Scotland's historic environment is understood, appreciated and experienced. It was suggested that, as Scotland comes to rely more and more on renewable energy, that efforts needed to be made to ensure that renewable energy systems are 'appropriately sited and designed'.

Other points raised

3.37 Among those opposed to the development of onshore conventional oil and gas, there was one further point made, which was unrelated to those discussed above. One respondent suggested that oil and gas provided a 'precious finite source of long-chain molecules', which are highly valuable and cannot always be synthesised in a laboratory.

Other views and issues raised

3.38 As noted above, three respondents made submissions to the call for evidence, but did not express a view in favour of, or opposed to, the development of onshore conventional oil and gas. Two of these respondents discussed issues relating to data and information needs, and one discussed matters relating to Scotland's history, heritage and visitor attractions.

Data and information needs

3.39 Two academic / research bodies emphasised the importance of preserving and sharing historical information about Scotland's onshore geology, which has been produced in previous searches for, and the development of, onshore and inshore oil, gas and coal.^[4] It was noted by one of these respondents that important information on historical wells and boreholes is not necessarily easily or freely available to the general public (because of current licencing arrangements), and that action was needed to ensure that this important information is not lost and can inform future decision-making by the Scottish Government.

3.40 Such information would be crucial during Scotland's transition away from fossil fuels. It would help to inform decisions – not only about future developments of conventional (or unconventional) oil and gas – but also in the search for appropriate locations for the underground storage of carbon dioxide and hydrogen, or for possible sources of geothermal energy.

3.41 It was also suggested that this information should be made available in a form that members of the public could also access and understand without the need for complex and expensive software.

Heritage sites and attractions

3.42 One respondent highlighted the role that the oil and gas industry has played in the 'story of modern Scotland'. This respondent suggested that this role should be recognised as part of Scotland's transition away from fossil fuels. The way in which Scotland's coal mining history has been preserved was held up as an example of how this might be done.

3.43 This respondent also highlighted that there was likely to be some residual requirement for oil and gas in order to maintain Scotland's heritage attractions which feature historic machinery and modes of transportation – such as heritage railways. It was noted that these attractions are important aspects of Scotland's visitor economy and can encourage the study of STEM subjects and the development of traditional skills.^[5]