Unconventional gas

By Lin Bunten, Head of Operations – Energy, Scottish Environment Protection Agency. This article first appeared in the summer 2014 edition of the RSGS's magazine, The Geographer.

While evidence has shown that the extraction of unconventional gas can present a number of risks to the environment, and some of the technologies being used in this area are new to environmental regulators, many of the processes (such as borehole construction) are not new, and neither is the job of regulating those practices to ensure that they do not harm the environment.

In Scotland, the main type of unconventional gas currently undergoing exploration is coal bed methane (CBM). Unlike shale gas, CBM extraction does not necessarily require fracking, as the seams already naturally contain fractures or fracture easily. In Scotland, as in the rest of Europe, the industry is relatively new and operations are still in the exploration stage.

There are currently three active exploration sites in Scotland: Airth, Falkirk; Deerdykes, North Lanarkshire; and Canonbie, Dumfries & Galloway. These sites have been granted planning permission by local authorities, and licences by SEPA and other regulatory bodies, to carry out exploration drilling. Planning permission is currently being sought for CBM production at Airth.

Regulation - SEPA is just one of a number of organisations involved in regulating unconventional gas extraction in Scotland, along with the Department of Energy and Climate Change (DECC), local authorities, the Health and Safety Executive, and The Coal Authority. We are committed to ensuring that there is a high level of protection for the environment, and we believe that, along with other regulatory bodies, we have a wide range of regulatory tools that can be used effectively to control and mitigate the environmental impacts that may be caused by unconventional gas activities.

We believe these regulatory tools already provide a high level of protection to the environment, but if further evidence demonstrates that more protection is required, we will support the Scottish Government in bringing forward further measures.

Environmental Issues - Potential environmental impacts can include effects on groundwater and surface water from drilling and fracturing, and increased greenhouse gas emissions and health impacts from fugitive gas releases.

Effects on groundwater and surface water -SEPA is responsible for protecting and improving the environment of Scotland, and we do this by enforcing a number of regulations designed to protect the air, land and water environment. For example, the Water Environment (Controlled Activities) (Scotland) Regulations (commonly known as CAR) control:

• potential risks of cross-contamination of aquifers due to poor borehole construction;

• pollution from an unexpected release of gas or fracturing fluid into other parts of the water environment;

• pollution from the uncontrolled disposal of liquid or solid waste;

• the abstraction of uncontrolled quantities of water.

Increased greenhouse gas emissions and health impacts - Emissions of methane and other volatile organic compounds are regulated by local authorities under the Management of Extractive Waste (Scotland) Regulations 2010, and by SEPA through the Pollution Prevention and Control (Scotland) Regulations 2012 (PPC). The PPC regulations are designed to control emissions to the environment from certain specified activities. The initial exploration for gas, drilling etc does not require a PPC permit. However, the extraction process cannot begin unless all required environmental licences are in place.

As well as contributing to climate change, fugitive emissions have the potential to impact on human health and the environment. SEPA and the local authority will ensure that operators make full use of technologies that reduce fugitive emissions to air and undertake comprehensive monitoring during production to assess health risks, which will help inform regulation.

The Scottish Government has set ambitious targets for reducing greenhouse gas emissions, and the impact of unconventional gas extraction on these targets has not yet been fully assessed. ClimateXChange is currently commissioning a research project to estimate greenhouse gas emissions associated with the exploration and extraction of onshore unconventional gas in Scotland, and how these compare to other energy sources