Make your voice heard - take part in the public consultation today
The Scottish Government is consulting the public on whether they should allow unconventional gas extraction (fracking) to go ahead, or ban it. The consultation closes on May 31st, 2017.
4 ways to take part in the consultation
1. On-line as an individual.
The Broad Alliance Comms team has written answers to the questions posed in the consultation (scroll down to see them). You could use them as they are, or edit them to reflect your own views and priorities.
To take part in the consultation, click here https://consult.scotland.gov.uk/energy-and-climate-change-directorate/fracking-unconventional-oil-and-gas/consultation/subpage.2016-07-07.1474135251/
2. Send a group response.
Use the questions and our model answers to hold a discussion in your group and arrive at your own set of answers. Then one member of the group can respond using the on-line form. When you complete the information at the end, you just need to give the name of your group.
3. Quick Response
Complete Friends of the Earth Scotland’s quick response here:
4. By Post
You can order a paper copy of the Consultation Document to complete and return by post (other formats are available such as large print/braiile). The number to phone is 0131 244 9380. Or you could just print off and use this model letter prepared by South Lanarkshire Against Unconventional Gas.
Broad Alliance model answers
Q1: What are your views on the potential social, community and health impacts of an unconventional oil and gas industry in Scotland?
The social, community and health impacts are entirely negative. Therefore my view is that there should be no unconventional oil and gas industry in Scotland.
Social impacts would include destruction of trust between people and government, imposing a dirty industry with health and environment risks on communities, without their consent, to enable short-term profits for fracking companies.
Community impacts would include loss of environmental assets, increased traffic disrupting community life and cohesion, falling house prices, difficulty attracting modern, clean industries that will supply jobs of the future.
Health risks are clearly set out in the Public Health Scotland impact study and therefore the precautionary principle must apply. Since it was written, further significant peer-reviewed studies from the United States have highlighted that the health of people, including unborn children, suffers when they live close to fracking operations.
Q2: What are your views on the community benefit schemes that could apply, were an unconventional oil and gas industry to be developed in Scotland?
It is a bribe to try to convince individuals and local authorities to accept fracking. There is no guarantee anything will be paid. Companies can declare losses to limit payments. The fracking companies will not pay for fixing damaged road surfaces, bridges and other infrastructure, or for cleaning up spills of fracking fluids on the public roads. As with the coal industry, and the first shale industry, the public purse will be left to clean up when the companies have left.
Q3: What are your views on the potential impact of unconventional oil and gas industry on Scotland’s economy and manufacturing sector?
I agree with KPMG, authors of the government’s impact study, who confirmed that it would “not make a significant contribution to Scotland’s economy”. It will negatively impact manufacturing, distracting focus from support for industries that would contribute to a sustainable economic future. It will damage tourism and the Scotland “brand”, especially for food and drink.
Q4 What are your views on the potential role of unconventional oil and gas in Scotland’s energy mix?
The KMPG impact study confirms that fracked gas will be mainly for INEOS to extract Ethanol to make plastics. It might contribute a maximum of 5.5 years of Scotland’s need for fuel gas over 42 years. But INEOS is planning to use any fuel gas for its plant at Grangemouth. Therefore it will not be part of Scotland’s domestic energy supply. So, as KPMG also confirms, it will not reduce consumer gas prices.
Q5: What are your views on the potential environmental impacts of an unconventional oil and gas industry in Scotland?
This is a dirty, dangerous fossil fuel extraction industry. It would happen in Scotland’s most populated area with the fracking companies allowed to decide how close to people’s homes they put the wells. Local authorities trying to prevent it would have to challenge the fracking companies at expensive planning enquiries, and pay for their own environmental impact studies, diverting money from other services with no guarantee they would win their case. There will be leaks of fracking fluids, both from split fracking pipes and on site during production. This puts the water supply at risk. There will be further leaks when the flowback water is being transported on Scotland’s roads to treatment plants. The evidence is that treatment of fracking fluid is only partially successful, especially in terms of radioactive materials. We should not put it in our rivers and seas. There will be methane leaks, which is bad for health, especially children’s health. There will be long periods of 24-hour noise and vibration and all-night lighting which is damaging to people’s mental health and wellbeing. There will be more heavy traffic, with the attendant pollution.
Q6: What are your views on the potential climate change impacts of unconventional oil and gas industry in Scotland?
The Climate Change Committee impact study told the Scottish government that fracking is only acceptable if 3 tests are met:
1. There are cuts in emissions in other industries, including agriculture, to make up for fracking. Why should other industries do this? Who will make them?
2. Fracked gas is balanced against a reduction in imports. With INEOS committed to importing fracked gas from the United States, this cannot be achieved.
3. There is intensive well-by-well monitoring. SEPA could not provide this level of monitoring, and the public should not have to pay for the introduction of a new regulatory regime.
In other words, the 3 climate tests cannot be met and therefore fracking should not be permitted.
Global warming scenarios all point to the fact that the majority of fossil fuel reserves must remain unused if global temperature rises are to be kept to the Cop21 agreement of 2˚C. Scotland must play its part by banning Unconventional Oil and Gas Extraction.
Q7: What are your views on the regulatory framework that would apply to an unconventional oil and gas industry in Scotland?
There is currently no appropriate regulatory framework for unconventional gas; one would have to be created as the Government’s own report makes clear. This would cost a significant amount of public money, at a time of cuts and austerity. The Scottish Environmental Protection Agency (SEPA) has confirmed that its regulation policy is as follows: “SEPA’s enforcement philosophy is to use the minimum amount of formal regulation necessary to secure compliance. An exceedance of an environmental quality standard is not in itself indicative of non-compliant or illegal activity on the part of the operator and thus a breach would not necessarily precipitate significant enforcement action.” This approach has already proved inadequate in a range of industries. In terms of fracking it would be disastrous.
Q8: Overall, and in light of the available evidence, what do you think would be the main benefits, if any, of an unconventional oil and gas industry in Scotland?
There would be no benefits to Scottish communities or the Scottish economy as a whole.
Q9: Overall, and in 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?
- Danger to health especially the health of children and the unborn.
- Risk to mental health and well-being of communities near fracking wells.
- Creation of “sacrifice zones” where people will be unable to sell their homes and new development is halted both for housing and clean business.
- 24-hour noise pollution and heavy traffic carrying dangerous cargos on rural roads.
- Scotland unable to meet its climate targets
- Damage to tourism, food and drink industries
- Cost to taxpayer of intensive monitoring and regulation
- Negative impact on development of clean, sustainable jobs.
Q10: If you have any other comments on the issues discussed in this consultation, please provide them here.
1. The First Minister promised in the Scottish Parliament that unless it could be proved that fracking could be done without risk to health and the environment, it would not be permitted. The Scottish Government’s own impact studies higlight significant health, enviromental and climate risks. On that basis, the government should keep its promise and ban fracking.
2. KPMG says there is no significant benefit to Scotland’s economy – why is unconventional gas even being considered?
3. How will the Scottish Government make other industries and agriculture cut their emissions to make up for the emissions from fracking, as proposed by the Climate Change Committee?
4. The public will end up paying for the clean up and abandoned wells if the market fails – this is already happening in the United States. There is speculation that future licences might include bonds to be held in trust to pay for any clean-up should the company go bankrupt or fail to fulfil its obligations – a kind of insurance policy. But it is not clear that the licences already granted by the UK government can be amended to include bonds.
5. This is a Scotland-wide consultation but the views of communities that will be most affected must have more weight in the decision-making process. It is already clear that there is no social licence for fracking in the currently licensed areas.