Unconventional oil and gas consultation: analysis of responses

13. Other comments (Q10)

13.1 The final consultation question asked respondents for any other comments on issues discussed in the consultation paper:

Question 10: If you have any other comments on the issues discussed in this consultation, please provide them here.

13.2 Altogether, 55,688 respondents addressed this question. This comprised 142 organisations, 14 discussion groups, 3,422 individuals, 21,077 standard campaign respondents and 31,033 petition signatories.

13.3 This chapter presents a summary of the comments made at Question 10. It also: (i) considers respondents' comments made in response to preceding questions which did not directly address the questions as posed, and (ii) discusses themes which recurred in comments across all questions.

13.4 In many cases, respondents used Question 10 to restate their views on the potential social, economic and environmental impacts of an unconventional oil and gas industry if it were established in Scotland; such comments have been covered in the preceding chapters and are not discussed here again.

13.5 The three main themes identified at Question 10 related to: (i) the case respondents put forward for and against the development of an unconventional oil and gas industry; (ii) their views about the next steps in the process of making of a decision about the future of unconventional oil and gas in Scotland; and (iii) issues relating to the current evidence base. In addition, respondents also frequently used Question 10 to explain why the issue of fracking was of personal interest to them. These comments are considered first.

Context and personal perspectives of the respondents

13.6 When discussing their views about unconventional oil and gas, respondents often made their personal perspective on fracking clear, indicating, for example, that they were a parent, a grandparent, a resident of an area which had been earmarked (potentially) for fracking, a person with relevant academic or professional expertise, etc. Respondents living outside of Scotland often explained that their interest in the consultation was based on a personal connection to Scotland (as a past resident, a regular visitor, or because they had a family member living in Scotland).

13.7 There was particular concern expressed about the situation in England where hydraulic fracturing has been allowed to proceed despite widespread opposition from local residents and local authority refusal to grant planning consent. Respondents based in these areas often called on the Scottish Government to help support them in their opposition to fracking in their own communities, by 'taking the lead' in the UK, and there were frequent calls for a UK-wide ban.

13.8 Some respondents also commented that they saw fracking as an issue of international significance. Those opposed to fracking indicated that they were opposed to the practice not only in Scotland, but elsewhere as well. Occasionally, respondents from outside the UK referred to their own (mainly negative) experiences of fracking or other large-scale industrial developments in their own countries.

13.9 Respondents also referred to a range of reports (academic and non-academic), media reports and films and often stated that their own views about fracking had been informed by what they saw as 'the evidence' contained therein.

The case for and against fracking

13.10 As noted above, respondents frequently used Question 10 as an opportunity to state, or restate, their views of fracking. (Note that the consultation did not contain a question which specifically asked about support or opposition to fracking.) As discussed in Chapter 3 of this report, the overwhelming majority of respondents explicitly stated that they were opposed to fracking and the development of an unconventional oil and gas industry in Scotland. It was common for respondents to say this in just a few words, for example: 'ban fracking', or 'I don't want fracking in Scotland', without expanding further. Less often, respondents indicated support for fracking. Some in this group also offered very brief comments such as: 'I am for fracking', 'I want fracking to happen in Scotland', and 'Get on with it'.

13.11 However, some respondents provided further information, and these comments are considered here.

The case against fracking

13.12 Those opposed to fracking often discussed their strength of feeling on this issue, and appealed to the Scottish Government to 'do the right thing' and 'ban fracking once and for all'. Arguments were often presented in terms of a democratic imperative, with respondents urging the Government to 'listen to the people of Scotland', including those in communities likely to be affected who, it was said, were overwhelmingly opposed. Respondents emphasised the importance of this decision for Scotland and the people of Scotland, now and for future generations. Other points highlighted in the responses included the following:

• The nature of fracking is such that its negative impacts would be serious, long-term, and irreversible.
• There were many examples of detrimental environmental and health impacts elsewhere in the world, some of which had led to an explicit ban on fracking ( e.g. France, Netherlands, New York, etc.).
• Scotland is a small country and the potential drilling sites are in highly populated areas which are already compromised by previous mining activity, so the implications of proceeding would be very different from those in America, Australia, Canada, etc., which were large countries with much lower population densities.
• The geology of Scotland is different to other countries where fracking has taken place. While some respondents suggested that Scotland's geology made it unsuitable for fracking, others suggested that the negative impacts of fracking would be potentially much greater because of Scotland's geology.
• Scotland's future is with renewables, energy efficiency and a move away from carbon fuels; respondents were positive about Scotland's action to date in these areas and called for the Government to further prioritise this work.

13.13 At a more general level, the Scottish Government was urged to look at what was happening elsewhere in the world, and / or to take a long-term view in making its decision.

The case for unconventional oil and gas

13.14 In contrast, those in favour of the development of an unconventional oil and gas industry in Scotland urged the Government to make a decision based on the evidence (which they thought supported the case), rather than what they described as 'vocal campaigns' and (uninformed) 'public opinion'. This group thought that Scotland should take advantage of what they saw as an important opportunity in terms of industrial and technological gain and economic benefit. In making their case, these respondents emphasised that:

• Scotland has a strong tradition in engineering and innovation and has the expertise to make a success of unconventional oil and gas, and to take a leading role in the industry.
• Scotland risks falling behind other nations as they move ahead with investments and developments in this industry, and there are potentially economic costs to not proceeding which need to be considered.

13.15 These respondents called for the Government to be 'brave' and take a strong stance in allowing the development of an unconventional oil and gas industry for the benefit of all. There was also a view among this group that the use of the term 'fracking' in the consultation paper was unfortunate as this was perceived to be an emotive term with negative connotations; it was suggested that it would have been preferable to refer instead to 'onshore gas extraction' and to move the debate beyond discussions about the method of extraction and focus instead on the importance of having secure and diverse sources of energy as Scotland makes the transition to a low carbon economy.

Decision making – the next steps

13.16 Another significant theme in respondents' comments at Question 10 related to their understanding of, or views about, what the next steps for the Scottish Government should be in making a decision about the future of unconventional oil and gas in Scotland.

13.17 Although, in the main, respondents simply argued for either a ban on fracking or for fracking to be allowed to proceed, there were also some variations on these ideas, with a small number of respondents suggesting that: (i) the moratorium should be extended, (ii) there should be a temporary ban, or (iii) Scotland should delay its decision while continuing to monitor emerging evidence and developments elsewhere. Respondents who were supportive of the development of an unconventional oil and gas industry often said they were keen to see a 'quick and final decision' on the issue.

13.18 There were also comments about the respective roles of the Scottish Government and UK Government in making the decision. Those opposed to the establishment of an unconventional oil and gas industry thought this decision should be taken by the Scottish Government (or Parliament). At the same time, some respondents thought that any attempt to ban fracking in Scotland might be outwith the powers of the Scottish Parliament and open to being overturned by the UK Government or to legal challenge from the oil and gas industry. Respondents who raised this issue suggested that extending the current moratorium might, therefore, be an equally effective solution. There were calls for clarity on this issue, and clarity on the technical difference between a 'ban' and a 'moratorium'.

13.19 Those supportive of the development of an unconventional oil and gas industry in Scotland sometimes suggested that exploratory drilling might begin in a limited way, and this could be monitored and evaluated to assess the viability of the industry and its likely impacts. It was suggested that test sites located away from populated areas should be selected to allow their impact to be assessed in less risky circumstances, and that exploratory projects should work closely with local communities.

The role of different stakeholders in the decision making process

13.20 Respondents on all sides of the debate about unconventional oil and gas endorsed the importance of community engagement and community participation in the decision making process, and the importance of properly informed debate at national and local level. There was a range of comments about the influence of different lobby groups. Most often, those opposed to unconventional oil and gas expressed concerns about the potential for big business to use their power to influence the decision. Respondents who raised these concerns called for the decision to be taken in the interests of the people of Scotland rather than in the interests of energy companies and their shareholders. In contrast those supportive of an unconventional oil and gas industry argued that environmental groups promoting an anti-fracking agenda were dominating the debate at the expense of local communities. There was a view that more emphasis should be placed on getting the views of affected communities.

13.21 In a few cases, respondents called for a national referendum to be held on the issue, or for local referenda to be held in potentially affected areas. Others argued that the case for unconventional oil and gas needed to be judged on a case-by-case basis in local contexts.

The Scottish Government position

13.22 Respondents opposed to fracking frequently commended the Scottish Government for its stance to date on this issue – and on other issues relating to the environment and sustainability. In urging the Scottish Government to ban fracking, respondents argued that to do otherwise would be inconsistent with the Scottish Government's 'progressive' agenda and existing strategic commitments and priorities on climate change, on renewables, and on tackling social and health inequalities. They also thought that the decision on unconventional oil and gas could not be taken in isolation but should take account of other wider policy issues, including the Government's overall energy strategy.

13.23 Respondents also suggested that a decision to allow unconventional oil and gas extraction to go ahead would represent a significant 'u-turn' with regard to the Government's stated position. ^[23] Moreover, some respondents were concerned that the decision to consult on the issue already indicated that the Government may be shifting its position (or may be prepared to do so).

13.24 In endorsing the Scottish Government's current stance on environmental issues, respondents often suggested that Scotland was providing leadership in this area. As such, they thought the Scottish Government could build on this position, acting as an example to other countries around the world, including within the UK, if unconventional oil and gas extraction were banned in Scotland.

13.25 Respondents supportive of unconventional oil and gas took a different view. They argued that it was the role of government to take strategic and often difficult decisions on behalf of the whole population; to ensure that the country reaped the potential benefits of economic opportunities; to ensure effective regulation to mitigate risks; and to educate people about 'risk' and work to alleviate public concerns. Respondents urged the Scottish Government to be 'bold' and 'show vision' in allowing an unconventional oil and gas industry to proceed. Furthermore, respondents in this group argued that development of the industry in Scotland would support the Scottish Government's aim of growing the economy and be in line with its energy and industry strategies.

Evidence and information

13.26 Finally, the third major theme in respondents' comments at Question 10 (and across other questions) was in relation to the evidence and information available to inform the decision about a possible development of an unconventional oil and gas industry in Scotland.

13.27 Respondents frequently voiced support for the evidence-based approach taken by the Scottish Government to date, and they highlighted the importance of learning from experience elsewhere. Alongside that support, however, there was also concern about a lack of conclusive evidence on particular issues, and the extent of assumptions and 'unknowns'. There was also criticism from a range of perspectives that the evidence and the consultation paper either downplayed or exaggerated the risks of hydraulic fracturing, was not impartial, or was incomplete. Some respondents also called for clarity as to how the responses to the public consultation would be used in reaching a decision on the role of unconventional oil and gas in Scotland, and how different types of evidence would be weighed in that process.

13.28 Some respondents called for the Scottish Government to take a 'precautionary approach' towards unconventional oil and gas. However, there were varying interpretations of exactly what that might mean for policy in this area. Some respondents argued that the lack of conclusive evidence about the impacts of hydraulic fracturing – or the presence of any risk, however small – meant that fracking should be banned outright. Others thought that risks could be managed, and that fracking should proceed on a limited and cautious, and well-regulated basis while the industry bedded down and more evidence was gathered.

13.29 Respondents made a range of other more specific points, including that:

• There was insufficient evidence at the current time to reach a decision and more research was needed. (This was particularly raised by those who had ambivalent or mixed views about unconventional oil and gas.)
• There were specific gaps and inadequacies in the work commissioned by the Scottish Government. Gaps included the absence of an environmental impact assessment, a hydrology report, an equalities or communities impact assessment; research on wildlife impacts; and a representative survey of the general public in Scotland. Shortcomings included the limitations of the health impact assessment; the absence of long-term monitoring data; and the narrow focus of the economic report. Research on the wider implications of unconventional oil and gas for Scotland's infrastructure was also called for.