Alexa Morrison, Conservation Policy Officer at RSPB Scotland, takes a look at fracking and the different types of unconventional gas proposals coming forward in Scotland.

Fracking is a hot topic in Scotland – what is RSPB Scotland’s position?

Fracking and unconventional gas are coming under some intense heat in Scotland at the moment. You might feel it’s hard to avoid the subject, with even the world’s most famous animated environmentalist, Lisa Simpson, railing against Mr Burns’s plot to frack for shale gas (which involves pumping water, sand and chemicals down wells at high pressure to fracture shale rock and release the gas) below Springfield, in a new episode of the Simpsons this month.

There is certainly a lot to talk about. Plans for what could be the UK’s first commercial-scale coal bed methane extraction at Airth are due to be decided by Scottish Ministers. A vast chunk of Scotland, stretching across the Midland Valley is part of the new round of onshore oil and gas licensing by the UK Government. Companies have just finished bidding for the rights to extract shale gas and coal bed methane.

Areas in red have been offered up to unconventional gas industries in the new round of oil and gas licensing, with yellow areas already licensed. Licensed areas still require planning permission and other environmental consents before they can go ahead.

Recently, Cluff Natural Resources announced that it has estimated there could be up to 335 million tonnes of coal under the Firth of Forth, and it will apply for planning permission for the UK's first underground coal gasification (UCG) plant. Fracking is always required for shale gas, but it is not used for UCG and only sometimes used for coal bed methane extraction – all ‘unconventional gases’ as they are more difficult to extract than conventional reserves. However, this does not mean these technologies are risk-free. On the contrary, they entail a number of environmental risks that we are only just beginning to get to grips with.

In September, when Scotland was reflecting on a big decision of its own, the UK Government announced its decision to allow drilling at depths of at least 300m under properties without the owner’s consent, hoping to make the development process easier for the shale gas industry. What was striking was the weight of public opposition; 99% of respondents to the consultation objected. It’s difficult to recall another consultation producing such a clear message of public disquiet.

RSPB was part of that ignored 99%. We’ve been voicing our concerns about unconventional gas for some time, having set out our position in our ‘Are we fit to frack?’ report, published in March. This was the first assessment of its kind on the likely impacts of shale gas in the UK, and came with ten recommendations to make the (largely untested) regulatory regime more fit for purpose. If allowed to run ahead at pace, fracking could increase fragmentation of habitats, making it more difficult for nature to find a home.

There are risks of water contamination from well failure. We also know climate change is one of the biggest threats to biodiversity. Science is telling us, in no uncertain terms, that avoiding dangerous levels means leaving the majority of remaining fossil fuels in the ground. Forging ahead with ‘new frontiers’ of fossil fuels, whether that is shale gas, coal bed methane or UCG, at the time we need to focus on growing green energy, is misguided and could risk becoming ‘locked-in’ to high carbon development.

Gannet colony at Bass Rock in the Firth of Forth. Andy Hay (

So what’s next for unconventional gas in Scotland? The Scottish Government has so far certainly talked about unconventional gas more cautiously that its UK counterparts, but has by no means ruled it out. New Scottish Planning Policy has set out requirements for risk assessments and buffer zones around sensitive areas, and more energy powers for Holyrood (e.g. control over licensing) are being raised in the ‘devo-max’ process. This could allow for decisions to be made closer to where the impacts are, but it is still far from clear how the Scottish Government would use those powers. And ultimately, let’s not forget that Holyrood already has the final say over whether proposals can go ahead, via its control of the planning system.

We hope the Scottish Government will maintain a cautious approach, and listen to the concerns of the public. We need to remain focused on the benefits of energy efficiency and well-sited renewable energy, and crucially also ensure that our special places for wildlife are protected.

What has RSPB done to respond to the risks of unconventional gas?

  • In March, RSPB came together with other conservation charities to publish the ‘Are We Fit to Frack’ report, an evidence-based review of potential environmental impacts of frackingWith Scottish Environment LINK, RSPB Scotland supported this removal of presumption of support for unconventional gas extraction from Scottish Planning Policy, and supported a presumption against it until environmental concerns have been fully addressed
  • We objected to an automatic right of access for shale gas developers below 300m under private property. RSPB is now talking to politicians about the Infrastutructure Bill, which will introduce this automatic right of access, and exploring opportunities to use this piece of legislation as a way to limit fracking’s environmental impact.
  • We engaged with the Strategic Environmental Assessment for the new, 14th round of Onshore Oil and Gas Licensing, calling for sensitive areas for wildlife to be excluded from the licensing process.
  • We have responded to several draft Local Development Plans in Scotland, which set out regional planning approaches, highlighting the environmental risks of unconventional gas and recommending a precautionary approach.