5. Views on the predicted environmental effects (Q2)
5.1 Sections 5–13 of the Environmental Report set out an assessment of the predicted environmental effects in relation to the (nine) SEA topic areas – for both the preferred policy position and for the 'reasonable alternatives'. These effects were summarised in section 14 of the Environmental Report. A Non-Technical Summary of the SEA findings was also provided. Question 2 in the consultation document asked for views on the predicted environmental effects.
Question 2: What are your views on the predicted environmental effects as set out in the Environmental Report?
5.2 A total of 175 respondents (37 organisations and 138 individuals) commented at Question 2.
5.3 The predominant view was that the environmental effects set out in the Environmental Report represented, if anything, a rather optimistic view of the likely environmental impacts of the development of the unconventional oil and gas industry. This view was expressed by community councils and other community groups, third sector organisations, one local authority and most individuals. The alternative view, expressed by oil and gas business and industry respondents and by a handful of individuals, was that the predicted environmental effects were unsubstantiated and / or exaggerated and did not take into account the tight regulatory environment in which development of the industry would take place.
5.4 The main issues raised by respondents are discussed below. The following should be noted:
- A range of both organisational and individual respondents, but particularly public sector organisations, simply said they 'agreed with the assessments in the Environmental Report', thought these were 'well considered and articulated' and 'were consistent with other measurements and approaches', but did not elaborate further. Thus no further analysis is possible in respect of these responses.
- A wide range of respondents did not engage directly with the question but simply reiterated their views that the development of unconventional oil and gas was too risky and dangerous to be pursued; a 'precautionary approach' was required given the uncertainties involved; and developing unconventional oil and gas would make Scotland's climate change targets harder to achieve. These respondents thought that the development of an unconventional oil and gas industry should be opposed in any circumstances; and that the Scottish Government's preferred policy position should be supported / adopted. These comments have been addressed elsewhere in this report and are not repeated here.
Predicted environmental effects are underestimated / understated
5.5 It was common for both organisational and individual respondents to say that they 'agreed' or 'supported' or 'fully agreed' or 'fully supported' the assessment of the predicted environmental effects as set out in the Environmental Report. However, they then went on to say they thought the conclusions (i) 'did not go far enough' or were 'overly cautious' in identifying the (damaging) environmental impacts or (ii) were based on evidence which was now 'out of date'. This view – that the predicted environmental effects set out in the Environmental Report are underestimated – was offered by community councils and other community groups, third sector organisations, one local authority and most individuals.
5.6 All areas covered in the Environmental Report were mentioned in relation to the view that the predicted environmental effects were understated. The 'impact types' mentioned most often in this regard were: air quality and air pollution; water and soil pollution; noise pollution (from heavy traffic); odour nuisance; methane emissions ('fugitive emissions'); impacts on human health / public health (including public safety); biodiversity; impacts on landscape and cultural heritage; seismicity; greenhouse gas emissions and climate change. Respondents emphasised that the effects of developing the unconventional oil and gas industry on these topic areas would be highly detrimental and, in some cases, they cited (additional) evidence to support their contentions (see Chapter 3).
5.7 The comments on human health focused on the health and welfare of the local populations directly affected. There was reference to the potential for birth defects, and to negative impacts on mental health and wellbeing due to stress as well as to noise, light and other environmental pollution. Respondents argued that the public health and mental health impacts had been given a low priority in the SEA process, and that the expertise to judge these was missing from the list of authors of the Environmental Report. Some of these respondents particularly highlighted the negative impacts on the health and wellbeing of children.
5.8 There was an especially strong focus on the issue of climate change. Repeated references were made to the report published by the IPCC in October 2018 and to the importance of stepping up efforts to meet the targets for the reduction of greenhouse gas emissions set out by the Scottish Government. Pursuing unconventional oil and gas development was seen as being completely inconsistent with the Scottish Government's climate change objectives. Respondents thought that the IPCC report reinforced the SEA and provided new reasons to support the SEA conclusions.
5.9 One individual who described himself as a professional engineer raised specific questions in relation to a number of elements of the environmental assessment, which he thought underplayed the risks / impacts. This respondent was of the view that whilst the report assumed that wells need to last around 20 years, in fact the lifespan would need to be measured in thousands of years if contamination was to be contained.
Predicted environmental effects are exaggerated / overstated
5.10 All business / industry organisational respondents, and a small number of individual respondents thought that the predicted environmental effects set out in the Environmental Report were 'overstated', 'exaggerated', 'incomplete' and / or 'unsubstantiated'.
5.11 The main issue identified by these respondents was that, in their view, the assessments reported in the Environmental Report did not take account of existing planning procedures or the systems which are currently in place (in England) to monitor and mitigate industry risks. Organisational respondents listed a wide range of mitigation measures currently undertaken by UOG companies (in England) (including undertaking baseline assessments, utilising 'zero bleed' pneumatic controllers, transportation of flowback fluid to a licensed waste handler, etc.) which they thought could be, and should be, applied in Scotland. Moreover, these respondents argued that comparisons with the US are not relevant, since the regulatory controls are much less stringent there.
5.12 This group of respondents went on to argue that if the 'proper' mitigation processes (i.e. those currently applied in England) were applied, the risks would be 'negligible' or at worst 'minor negative' in most cases.
5.13 Respondents who thought the predicted environmental effects were overstated also made a number of other points about the assessment, including the following:
- No conclusions about the environmental impacts can be drawn unless and until a number of test sites have been commissioned, monitored, and evaluated.
- The assessment that the preferred policy position would mean an effective ban on unconventional oil and gas development in Scotland was incorrect given the recent legal ruling.
- It is not clear why the SEA concludes that there is not enough data to assess whether or not shale oil and gas produced in Scotland would provide a net environmental benefit as compared to oil and gas produced elsewhere.
- Outsourcing to other countries the negative environmental aspects of providing oil and gas to the Scottish economy might make the Scottish Government's climate change targets easier to achieve, but the rest of the world will suffer.
- The probability of any of the identified risks occurring has not been discussed.
5.14 In addition, one respondent questioned what they saw as the underlying assumption of the SEA that onshore oil and gas is the only sector which could have a negative impact on the environment. In their view, many other sectors could also cause such impacts.