The Moratorium on planning permission for unconventional gas in Scotland does not cover Underground Coal Gasification, according to Fergus Ewing, despite him saying in parliament in 2013 that this process (whether ‘offshore’ or not) IS subject to the usual planning permissions within Scottish Government powers. If you are concerned about underground coal gasification within our riverside communities and under our seabed, you might want to consider writing to Fergus Ewing, Minister for Business, Energy and Tourism St Andrew’s House, Edinburgh, EH1 3DG.
It’s really important that you write this in your own words, so that he understands the full scale of public opinion. Appreciating that access to accurate information is quite difficult to find, to help here is a list of evidence which was compiled by the Our Forth community group:
*When Claire Baker MSP asked you during your Ministerial Statement, whether the moratorium you announced would apply to UCG you indicated that it would not, saying that ‘the powers that we possess apply to onshore planning activities. As the member will know, they don’t not apply to offshore activities, such as those that I believe would be covered by UCG.’
*However, the Firth of Forth is classed as ‘onshore’ until a line between approximately Elie and North Berwick, since:
*The Petroleum (Production) (Landward Areas) Regulations 1995 sets out definition of landward/onshore and hence what’s covered by PEDL license. Specifically for the Forth: NT496864 Eyebroughy to NT496993 Elie Ness.
*This is explicitly referenced in BGS report dated 14 December 2014, THE CARBONIFEROUS SHALES OF THE MIDLAND VALLEY OF SCOTLAND: GEOLOGY AND RESOURCE ESTIMATION’ ‘The Forth Estuary and Firth of Forth were included to just offshore of the ‘bay closing line’ where the distinction between ‘onshore’ and offshore’ is made for UK licensing purposes. The Firth of Forth has been included in the resource estimation for this study, though it is not currently included in a Strategic Environmental Assessment and so cannot be offered in the 14th UK Onshore Licensing Round.’
*Furthermore, in response to Claire Baker’s parliamentary question S4W-16783 you stated that ‘Potential UCG operators who have been granted a licence from the UK Coal Authority cannot commence activities in Scotland until other rights and permissions covering the various elements involved’ are met. You continue to say that ‘any development proposal onshore, concerning onshore or offshore underground coal gasification would require planning permission along with the relevant SEPA licenses and permits before activities can begin in Scotland.’
*In offshore gas extraction, there is onshore infrastructure which requires planning permission
*Why do you assert that these aspects of UCG wouldn’t be included within the Scottish Government’s statement and the principle therein of safeguarding public health, if they are within Government powers?