Unconventional oil and gas consultation: analysis of responses

9. Potential climate change impacts (Q6)

9.1 This chapter discusses respondents' views on the potential climate change impacts of unconventional oil and gas.

9.2 Pages 46–48 of the consultation paper covered issues relating to the potential climate change impacts of unconventional oil and gas. This section referred to Scotland's current climate change targets and provided a link to the Scottish Government's third Climate Change Plan, which was published in draft in January 2017. ^[17]

9.3 This section also discussed the analysis provided by the UK Committee on Climate Change. This Committee was asked to advise on 'the potential impact of unconventional oil and gas on Scottish and global greenhouse gas emissions'. In doing this, the Committee used the production scenarios developed in the Scottish Government-commissioned economic impact assessment. (See Chapter 6 for further discussion of the economic impact assessment.)

9.4 In their response to this request, the UK Committee on Climate Change set out 'three tests' as being prerequisites for Scotland being able to meet its climate change targets while developing an unconventional oil and gas industry. These were that:

(i) Emissions are limited through tight regulation. Within this, much greater clarity is required over the respective roles of different actors in the regulatory system particularly around fugitive emissions.

(ii) Fossil fuel consumption remains in line with the requirements of Scottish emissions targets. Scottish unabated fossil energy consumption must be reduced over time within levels previously advised by the Committee. This means that unconventional oil and gas production must displace imported gas rather than increase domestic consumption.

(iii) Emissions from production of unconventional oil and gas are offset through reductions in emissions elsewhere in the Scottish economy.

9.5 Question 6 asked respondents for their views on the potential climate change impacts of an unconventional oil and gas industry in Scotland.

Question 6: What are your views on the potential climate change impacts of an unconventional oil and gas industry in Scotland?

9.6 Altogether, 20,382 respondents addressed this question. This comprised 119 organisations, 14 discussion groups, 3,746 individuals and 16,503 standard campaign respondents.

Overview of responses to Question 6

Almost all respondents agreed that Scotland should tackle climate change, reduce its greenhouse gas emissions, and make the transition to a low carbon economy; just a handful of respondents thought that this was not an important policy objective.

The predominant view was that an unconventional oil and gas industry in Scotland would increase greenhouse gas emissions, have a negative impact on climate change, and thus also a negative impact on Scotland's ability to meet the climate change targets to which it was legally committed. These respondents did not view unconventional oil and gas as a 'cleaner' fuel that could help Scotland in its transition to a low carbon economy; and they were particularly concerned about the impact of fugitive emissions of methane gas.

By contrast, there were a range of alternative views including that the development of an unconventional oil and gas industry in Scotland would have no impact, a negligible impact or a small positive impact on climate change (and hence on climate change targets). Respondents with these views thought that unconventional oil and gas could provide an important 'transition' or 'bridging' fuel as Scotland moves to a low carbon economy; this group also thought that a robust regulatory framework would control and mitigate any risks relating to climate change generally and fugitive methane emissions in particular.

9.7 There were two opposing views about the climate change impacts of unconventional oil and gas: that it would have a negative impact, or that it would have a positive or neutral impact. The two groups of respondents holding these views both cited evidence from the consultation paper and from a range of other sources in support of their position. These views are discussed in detail below.

Negative impact on climate change

9.8 Many respondents who believed the development of an unconventional oil and gas industry would have negative impacts on climate change described climate change as 'the biggest issue of our time'. They emphasised the scientific consensus that existed around the causes of climate change, and also its effects (droughts, earthquakes, tsunamis, storms, etc.). Respondents also focused on the extent to which climate change affected everyone – both current and future generations. The specific susceptibility of vulnerable groups – the poor, children, the elderly – to the effects of climate change was highlighted.

9.9 These respondents also focused on the significant contribution that burning fossil fuels makes to greenhouse gas emissions – and therefore to climate change – and argued that fossil fuels should be 'left in the ground'.

9.10 These respondents referred repeatedly to a range of statements set out in the consultation paper as follows:

• 'An unconventional oil and gas industry is likely to lead to increased greenhouse gas emissions, which would make it more challenging to achieve Scottish climate change targets.' (page 6)
• 'The high level of ambition embodied in Scottish annual emissions targets means that finding offsetting effort elsewhere in order to accommodate even moderate additional emissions from unconventional oil and gas production or other sources ( e.g. aviation) would be challenging.' (page 47: statement from the UK Committee on Climate Change)
• 'The implications for greenhouse gas emissions of unconventional oil and gas exploitation are subject to considerable uncertainties, both regarding the size of any future industry and the emissions footprint of production.' (page 47)
• 'However, within the context of Scotland's climate change legislation, an unconventional oil and gas industry would create challenges in meeting Scotland's ambitious and world-leading climate change targets.' (page 53).

9.11 Moreover, these respondents also believed that the 'three tests' set out by the Committee on Climate Change described above ( paragraph 9.4) were not currently, and could not be, achieved. In particular, they wished to know which industries would provide the 'offsetting effort' described above. These respondents challenged the Scottish Government observation in the consultation paper that the impact on climate change would be 'broadly neutral' (page 53) given the lack of definitive evidence available.

9.12 The other themes raised by these respondents covered: achieving climate change targets; the regulatory framework; and unconventional oil and gas as a 'transitional' technology. Each of these is discussed in turn below.

Achieving climate change targets

9.13 Respondents in this group did not think that the climate change targets set out by the Scottish Government could be achieved if an unconventional oil and gas industry was developed. They saw these targets as very important, and pointed out that some of the targets stemming from the 2015 UN Paris Accord were legally binding; failure to achieve them was therefore viewed with grave concern.

9.14 Respondents thought that up until now, Scotland had a good record in achieving greenhouse gas emissions targets; indeed, they felt that Scotland was a role model and provided leadership for other countries in relation to climate change. Investing in unconventional oil and gas was thought to undermine this and to 'give the wrong signal' about Scotland's commitment to reducing greenhouse gas emissions.

9.15 Some of these respondents explicitly mentioned that, in the 'grand scheme of things', Scotland's contribution to global greenhouse gas emissions was very small indeed; even if Scotland decreased its emissions to zero, there would be a minimal impact on the global picture. However, notwithstanding this, respondents thought it was vital that Scotland takes its commitments to greenhouse gas reduction seriously and offers a world-leading example to other countries.

9.16 Overwhelmingly, these respondents thought that in order to achieve climate change targets Scotland's focus should be on developing renewable technologies. In this context, the unconventional oil and gas industry was seen as a distraction. (See Chapter 7 for a discussion of renewable technologies and the role of unconventional oil and gas in Scotland's energy mix.)

The regulatory framework

9.17 These respondents did not believe that the regulatory framework would be capable of monitoring, enforcing, or controlling greenhouse gas emissions. They did not think the skills or personnel were available to deliver on this and they asked who would bear the (substantial) costs of regulation. The potential impacts of Brexit on the regulatory framework, and whether this would result in a dilution of standards, was also raised.

9.18 Respondents queried whether detailed risk mitigation plans had been produced and more specifically, they focused on whether these were sufficient to control methane gas emissions during fracking operations (both vented emissions and unintentional leaks). Respondents repeatedly highlighted the large relative impact of methane gas compared to CO ₂ on global warming and they did not believe regulation was, or could be, adequate to control this. ^[18] (See Chapter 10 for further discussion of the regulatory framework.)

Unconventional oil and gas as a 'transitional' technology

9.19 Respondents did not agree with the argument that unconventional oil and gas could provide a 'transitional' technology to a low carbon future. They thought the timetable didn't allow for this; fracking would not make a significant contribution to energy demands overall until 'too late' (the late 2030s) by which time, they thought, other technologies would be available. Moreover, the fact that the United States had experienced a drop in its greenhouse gas emissions following the development of the shale gas industry was not seen by these respondents to be relevant to Scotland, given the very different energy mix (including the use of coal) in the United States.

Positive or neutral impact on climate change

9.20 Respondents who thought that developing an unconventional oil and gas industry in Scotland would have a positive, neutral or negligible impact on climate change cited in their responses the statement in the consultation paper that: 'An unconventional oil and gas sector in Scotland is likely to have a broadly neutral impact on global greenhouse emissions if it is tightly regulated.' ^[19] Respondents in this group, who were generally in favour of developing the industry in Scotland, believed that the three tests by the UK Committee on Climate Change (see again paragraph 9.4) had already been achieved or could be achieved in the future.

9.21 These respondents often highlighted the small scale of Scotland's contribution to overall global warming, and the (likely small) scale of any potential unconventional oil and gas industry that would be developed. They did not think Scotland's approach in relation to reducing greenhouse gas emissions was of any significance at an international level.

9.22 This group of respondents focused their comments on the following topics, all of which were linked to the three tests described above: regulation of the unconventional oil and gas industry, displacement of imported gas and other sources, the role of shale gas in transitioning to a low carbon economy, and the use of shale gas within the Scottish economy. These are discussed below.

Regulation of the unconventional oil and gas industry

9.23 These respondents highlighted the importance of appropriate regulation within the industry. Issues relating to regulation are discussed in greater detail in Chapter 10 but the main points raised here were that: (i) the ( EU, UK and Scottish) regulations and standards applied in Scotland are much higher than those applied elsewhere (in particular in the United States); (ii) the regulations and standards should be further strengthened as identified in the consultation paper, the regulatory gaps should be addressed, and the industry should strive to continuously improve its regulatory framework; and (iii) there should be proper monitoring and controls in place to regulate and minimise fugitive methane emissions. ^[20]

Displacement of imported gas

9.24 This group of respondents emphasised the importance of using domestically produced gas rather than imported gas. This was often mentioned in the context of displacing imported shale gas from the United States where the environmental protections and regulatory frameworks were thought to be weaker. Respondents often located this view within a moral / ethical context, emphasising that 'we should not expect other countries to do our dirty work for us' or to take risks that we do not wish to take ourselves. (Similar ethical issues were raised in relation to role of unconventional oil and gas in Scotland's energy supply – see paragraph 7.21, point 4.)

Transition to a low carbon economy

9.25 These respondents thought that unconventional oil and gas provided an important and valuable 'bridging' fuel (or 'transition' fuel) as Scotland (and the UK more generally) transitions to a low carbon economy. Respondents argued that a low carbon economy would take many decades to achieve and that both conventional and unconventional oil and gas would be required for many years to come.

9.26 This group of respondents thus saw an unconventional oil and gas industry as a sensible solution for the short to medium term. They pointed repeatedly to the reduction in greenhouse gas emissions which had been achieved by the United States following its transition away from (conventional) coal and oil to shale gas. More broadly, respondents favoured using unconventional oil and gas to displace / replace any other energy sources that were known to have greater greenhouse gas emissions / greater 'carbon footprint' / greater lifecycle emissions associated with their extraction, production and use ( e.g. coal, diesel).

Use of unconventional oil and gas

9.27 Respondents emphasised that whatever impact the extraction and production processes had, the overall impact of the development of an unconventional oil and gas industry on greenhouse gas emissions would depend on the use to which any extracted shale gas was put. The impacts would be different, depending on whether domestic shale gas was used: (i) to displace imported liquefied natural gas, (ii) to substitute for oil and diesel or, (iii) as petrochemical feedstock. In relation to the latter, it was argued that the impacts on greenhouse gas emissions would be minimal.