This page gives guidelines on how to respond to the Scottish consultation on their current position on fracking and other forms of unconventional oil and gas production. Anyone in the UK can respond to this consultation, and the deadline is Tuesday 18th December.
What’s this consultation about? I thought Scotland had already banned fracking.
Not exactly. The Scottish government currently have a moratorium on fracking and other forms of unconventional oil and gas (UOG). However, this is not currently a permanent ban and the Scottish government are currently ‘finalising their position’. The consultation invites comments on the predicted impacts of the policy on the environment and business, and also allows people to comment on what would happen if fracking were allowed to take place.
Didn’t they already have a consultation on this last year?
Yes, they certainly did, and it received over 60,000 responses, with over 99% opposing fracking. In October 2017, the Scottish parliament voted in favour of the Scottish government’s preferred position to not support unconventional oil and gas, which you can read about here. However, for this to be finalised the policy requires a strategic environmental assessment (SEA) and a business and regulatory impact assessment (BRIA). Both of these have now been completed and are the subject of the current consultation. You can read more about the background on Drill or Drop.
And do you have to live in Scotland to respond to this?
No, anyone in the UK is allowed to respond to the consultation. What happens in Scotland will have an impact on the rest of the UK, and of course climate change affects everyone.
What should be the main thrust of my response?
However much or little you write, we recommend that you make it clear that you support the Scottish government’s Preferred Policy Position to oppose fracking and other forms of unconventional gas exploitation. If all you do is state this in the first box and add a few more comments, this is still very helpful.
OK, I’m in. Where do I start?
The SEA concluded: “Allowing unconventional oil and gas development in Scotland, could result in significant negative effects on the environment, even when taking account of existing regulation and consenting processes.” It also said that there could be harm to air and water quality, climate factors, public health and safety, biodiversity, the setting of historic sites and the character and quality of landscapes.
The BRIA concluded “The total economic impact of unconventional oil and gas is estimated to be relatively low, and is not comparable to the current offshore industry in Scotland.. It also said that the scale of production in Scotland would be relatively low in comparison to European or international gas production and would be unlikely to have an impact on global gas supply prices, and therefore on consumer energy costs.”
The BRIA also said the Committee on Climate Change had warned that emissions from production of unconventional gas and oil would need to be offset through cuts in emissions elsewhere in the economy. It made the point that communities, particularly those in areas where fracking was likely to take place, had yet to be convinced there was a strong enough case of national economic importance, when balanced against risk and disruption. Which is something of an understatement, given the strength of opposition in Scotland to fracking and other forms of UOG.
The first five questions in the consultation relate to the SEA, which you can read here. The main conclusions are on pages 3-13 if you don’t want to read through the whole thing. Here are the consultation questions and some possible ways to answer.
1 What are your views on the accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report?
Experts who have reviewed the SEA feel that this has been done in a proper way, so we suggest a short answer here, along the following lines (as with all consultations, please put your ideas in your own words if possible).
Hey, this one’s easy! What’s the next question?
2 What are your views on the predicted environmental effects as set out in the Environmental Report?
The SEA concluded: “Allowing unconventional oil and gas development in Scotland, could result in significant negative effects on the environment, even when taking account of existing regulation and consenting processes.”
So, you can respond as follows:
You can of course go in to more detail on any of the above points – the important thing is to make it clear that you support the Preferred Policy Position (which is to oppose fracking).
3 What are your views on the ‘reasonable alternatives’ outlined in the Environmental Report? Please provide any other ‘reasonable alternatives’ which you think should be considered.
Here are some points you can make on the reasonable alternatives, which can be found on page 22-23 of the SEA.
4 What are your views on the findings of the SEA and the proposals for mitigation and monitoring of the environmental effects set out in the Environmental Report?
The section on Mitigation starts on page 172 of the report, while the page on Monitoring can be found on page 178.
5 Do you have any views on the proposals contained within the Scottish Government’s preferred policy position statement? There is no need to restate views already expressed in relation to the Talking “Fracking” public consultation as these have been, and will continue to be, taken into account as we move towards finalising the Scottish Government’s policy position.
The Talking Fracking consultation referred to in the above question is the one last year which resulted in 60,000 responses and the current position opposing fracking. Here is a brief answer to this question that you can use or adapt.
This box is also the place to add any further concerns you have on the impacts of fracking that you haven’t written elsewhere.
6 What are your views on the opportunities and challenges that each of the 3 options set out in the partial BRIA could have for businesses?
The options referred to are on p6 of the BRIA, which you can see here. Option one is the Preferred Policy Position – ie opposing UOG – option 2 is ‘business as usual’ and option 3 is setting up a pilot project to see what the impacts are. We are, of course, recommending option 1, so here’s a possible answer. Again, please rephrase if you can.
And that’s it! The rest of the form asks you to write your personal details, etc. And don’t forget to click send.
So is that the last consultation this year, then?
I wish. There is one more that we’ll get to soon… watch this space!