Unconventional oil and gas consultation: analysis of responses

12. Risks/challenges of an unconventional oil and gas industry (Q9)

12.1 This chapter discusses respondents' overall views relating to the risks or challenges of an unconventional oil and gas industry in Scotland. Question 9 invited comments as follows:

Question 9: Overall, and in the light of the available evidence, what do you think would be the main risks or challenges, if any, of an unconventional oil and gas industry in Scotland?

12.2 Altogether, 29,962 respondents addressed this question. This comprised 127 organisations; 14 discussion groups; 3,921 individuals; 20,726 standard campaign respondents and 5,174 petition signatories.

Overview of responses to Question 9

The predominant view was that the development of an unconventional oil and gas industry in Scotland would carry substantial risks – to health and wellbeing, to communities, to the environment, and to the economy. These risks were generally seen to be long-term and irreversible. Respondents with these views had no confidence in any regulatory framework, irrespective of how strict or robust it is, to adequately manage these risks or to prevent accidents and incidents.

The alternative view was that all industrial activities have risks – particularly if they are located in areas of high population density. However, the risks of an unconventional oil and gas industry were seen to be minimal and manageable, and Scotland's regulatory regime was considered to be well equipped to deal with these. Independent monitoring of the industry would ensure that operations are well managed at all stages, from planning and exploration, through to decommissioning and aftercare. Respondents with these views thought that the biggest challenge was to address public misinformation and build public confidence in the industry.

12.3 'Risks' and 'negative impacts' were mainly identified by those opposed to the development of an unconventional oil and gas industry in Scotland. Most often, respondents discussed the risks of an unconventional oil and gas industry in terms of the risks to: health and wellbeing, communities, the environment, and the economy. Responses to this question frequently took the form of lengthy bulleted lists which recapped points previously made by respondents elsewhere in their submissions. These views have been set out in detail in the earlier chapters of this report ( Chapters 4 to 10) and so are summarised only very briefly here.

12.4 Some respondents also identified political risks and, occasionally, business-related risks. The former were raised by respondents of all types (individual, organisational) regardless of their views on unconventional oil and gas; the latter tended to be highlighted by those working in the oil and gas industry or other supporters of the industry.

12.5 Regarding challenges, those opposed to the development of an unconventional oil and gas industry identified a range of challenges if a decision is taken to lift the existing moratorium and allow the development of an unconventional oil and gas industry in Scotland. These challenges related mainly to the mitigation of risks and the development and enforcement of an effective regulatory framework. By contrast, respondents supporting the establishment of the industry often discussed different types of challenges – related to allaying community concerns and addressing misinformation, which they saw as necessary to enable the industry to proceed.

12.6 The following general points should be noted:

• As suggested in Chapter 11, most respondents saw only risks from the development of an unconventional oil and gas industry in Scotland and no benefits. The risks were considered to be 'substantial', 'serious', 'long-term', 'irreversible' and 'global' as well as local.
• Respondents often referred to 'evidence' in their comments. However, on the basis of the same evidence, some respondents drew the conclusion that the risks of an unconventional oil and gas industry were too great to proceed, others drew the conclusion that the risks were minimal and manageable, and a third group saw the risks as 'unknown' or 'unknowable'.

Summary of main risks

12.7 The main risks identified by respondents in relation to the development of an unconventional oil and gas industry are summarised below. It is worth emphasising that these risks, and the potential negative impacts resulting from them, were seen to be inter-related. Thus, the same risk ( e.g. water contamination) could have multiple negative impacts – on health, on the environment, on communities and on the economy.

Risks to health and wellbeing

12.8 Respondents pointed to the potential for negative impacts on physical health from contaminants (in air, water or land), pollutants and carcinogenic chemicals. These risks were seen to be greatest for the vulnerable ( i.e. children, the elderly, those with existing health conditions) and those living near drilling sites. Some respondents also highlighted the potential for impacts on mental health and wellbeing (related to noise, odours, traffic and pollution).

12.9 Those opposed to the development of an unconventional oil and gas industry and those in favour both commented that there is a lack of evidence regarding health impacts. Most often, respondents saw this as a reason not to establish an industry in Scotland; the alternative view was the current evidence provides no reason not to proceed.

Risks to communities

12.10 Respondents saw the potential for negative impacts on the quality of life in communities (in relation to noise, pollution, traffic, etc. as noted above), and on housing and home ownership (being unable to sell a house, falling house prices, difficulties obtaining insurance or a mortgage). They also saw the potential for an unconventional oil and gas industry to cause division within communities if some were seen to benefit from the industry while others experienced only negative impacts. Related to this, community benefit schemes linked to an unconventional oil and gas industry, in particular, were seen to be potentially divisive. However, there was also a view that if an industry were established, the community benefit scheme would be inadequate or fail to provide any real benefit to communities.

12.11 There was a view that the consultation paper had not given adequate attention to discussing the risks to quality of life issues, and the potential effects of an unconventional oil and gas industry on local social and cultural life. Some respondents commented that industrial activities can have a cumulative effect on communities, and many of the communities that may be affected by an unconventional oil and gas industry were already coping with the effects of large-scale industrial waste facilities, incinerators, and landfill sites nearby.

12.12 Discussion groups often highlighted local incidents and accidents from current and historic industrial activities which they said had not been well-managed by the respective industries or by the regulatory bodies established to oversee and monitor them.

Risks to the environment

12.13 Respondents discussed the risks of pollution (air, water and land); the risks of earthquakes; the negative visual impact of wells and drilling sites; and the risks to wildlife and habitats. In addition, there were frequent comments about the risks of fugitive methane emissions; the risks of maintaining a dependence on fossil fuels; the risks of removing the urgency to invest in cleaner, greener approaches to energy generation; and the consequences of all these things for climate change. Finally, respondents saw risks associated with the restoration of land ( i.e. that it may take decades for land to be returned to its original state and / or that the cost of restoration will end up having to be funded by the public purse).

12.14 Some respondents discussed the geology of Scotland, the ways in which Scotland's geology differs from that in countries where hydraulic fracturing has previously been carried out, and the potential for earthquakes and subsidence.

Risks to the economy

12.15 Respondents opposed to unconventional oil and gas discussed the risks of job losses and reputational damage to tourism and the food and drink sector; the risks of further job losses in the offshore oil and gas industry; the risk of diverting investment away from developing a low carbon economy; and the risks of increased costs to taxpayers related to the regulation of the industry.

12.16 Those supporting the establishment of an unconventional oil and gas industry also identified economic risks – they saw the risks of not moving ahead in terms of Scotland's increased dependence on imported gas; job losses; and a loss of future investment.

Additional risks (not previously discussed)

Political / societal risks

12.17 Respondents on both sides of the debate identified a range of political risks related to the establishment of an unconventional oil and gas industry in Scotland. Those who were opposed to the industry tended to focus on the potential risks if a decision is taken to establish an industry. These included: (i) the risk of local communities losing faith in government / politicians and the political process; (ii) the risk of public resistance, dissent, and legal challenges from communities; and more broadly, (iii) the risk to Scotland's reputation as a progressive nation and a world leader on climate change and in promoting renewables.

12.18 Those in support of the industry highlighted: (i) the risk that politicians and other stakeholders might make decisions about unconventional oil and gas based on political motives rather than an informed understanding of the evidence; and (ii) the risk of a lack of political leadership (potentially resulting in a missed opportunity for Scotland). Occasionally, among this group, there were suggestions that if a decision is taken to establish an unconventional oil and gas industry, there was a risk of government mismanagement of the industry and the consequent potential benefits.

Business risks

12.19 The potential for business risks were generally raised by respondents supportive of the development of an unconventional oil and gas industry. They saw risks in the possibility that the industry may be less viable / valuable than anticipated; that there may be legal challenges from communities; or that the industry may be dissuaded from investing in Scotland due to public opposition and a lack of political support.

12.20 Occasionally, those who were opposed to the industry also highlighted business-related risks, but these were of a different nature to those above. Some in this group saw a risk that the industry might grow beyond initial expectations 'once it had a foothold' in Scotland; others saw a risk that it would not 'deliver its promised benefits' ( i.e. in terms of jobs, quality of jobs, community benefit schemes, decommissioning / restoration of land).

Challenges

12.21 In the main, respondents identified challenges that would arise if an unconventional oil and gas industry were established in Scotland. These challenges were seen to relate to:

• Developing and enforcing effective regulation
• Monitoring environmental effects throughout the whole lifespan of a well – and beyond, after the restoration of land
• Mitigating negative impacts (on the environment, on communities, on the economy, etc.)
• Meeting climate change commitments.

12.22 Those in favour of the development of an unconventional oil and gas industry highlighted different types of challenges. The most significant of these was in relation to building public confidence in the industry. Those who raised this issue emphasised the challenges of countering misinformation spread by the 'anti-fracking lobby', persuading the public that the industry is safe, and obtaining planning consent to proceed. It was suggested that one way of doing this would be to undertake initial exploratory work (or a pilot project) in one low risk area away from densely populated communities. This would allow a better assessment of the risks and the viability of the industry in Scotland.

Managing the risks and challenges

12.23 In discussing the risks and challenges of developing an unconventional oil and gas industry in Scotland, respondents also sometimes discussed their views on whether and how the perceived risks could be managed.

12.24 The predominant view was that the risks were simply too great, and therefore, no unconventional oil and gas industry should be established. A slight variation on this view was that no matter how small the risks, accidents and incidents will happen, and these are likely to have severe and long-lasting effects. A third, related view was that Scotland has no need for additional sources of gas (because there are still reserves in the North Sea, and because of Scotland's focus on moving to a low carbon economy); therefore whatever the risks are, they should not be taken.

12.25 Respondents who were opposed to the development of an unconventional oil and gas industry also repeatedly queried whether there was sufficient technical expertise, capacity and resources within local authorities and regulatory bodies. There were also concerns that even if a strict regulatory framework were developed, the likelihood was that standards and enforcement activities would become more relaxed over time. Overall, this group had little confidence in the ability of regulatory bodies to prevent accidents or incidents, or to robustly monitor activities in this area. (These issues have been discussed in detail in Chapter 10 of this report.)

12.26 The alternative view was that the unconventional oil and gas industry had no more risks than many other industries, and far fewer risks and challenges than the offshore oil and gas industry. Respondents in this group argued that the Scottish Government's own expert scientific panel had concluded that the challenges of establishing an onshore industry were not insurmountable, and they emphasised that any impacts to communities could be minimised through careful site selection. They also argued that Scotland's regulatory regime was well equipped to take on the task of monitoring and overseeing this new industry.