Infrastructure investment plan 2021-2022 to 2025-2026 - draft: consultation analysis

Independent analysis of consultation responses to the Scottish Government's Draft Infrastructure Investment Plan 2021-22 to 2025-26. The consultation ran from 24 September 2020 to 19 November 2020.

Executive Summary

1. This Executive Summary presents an overview of the main themes arising from the consultation responses to the Scottish Government Draft Infrastructure Investment Plan (IIP) for Scotland 2021-22 to 2025-26.

2. In 2018, the First Minister announced a National Infrastructure Mission to increase Scotland's annual infrastructure investment so that it reaches internationally competitive levels by the end of the next Parliament. To support delivery of the National Infrastructure Mission, Scottish Ministers established an independent Infrastructure Commission for Scotland.

3. The Infrastructure Commission for Scotland has since published two reports: A "Blueprint for Scotland" (January 2020) and Phase 2 Delivery Findings Report (July 2020)[1]. The Scottish Government is currently considering the findings of the Phase 2 report and will publish a formal response in due course.

4. Scottish Ministers agree with the recommendations within the Phase 1 report[2], and the Draft IIP shows how they will be implemented in Scotland. In doing so, the Draft IIP seeks to set out a clear vision for our future infrastructure - to support and enable an inclusive net zero emissions economy. The Draft IIP sets out the Scottish Government's long-term vision for Scottish infrastructure, shows how it will choose the right future investments, and sets out a five-year programme of further improvements.

5. The consultation on the Draft IIP did not seek to repeat the earlier engagement process progressed by the Infrastructure Commission for Scotland. Rather, it sought wide-ranging views and feedback on specific areas with regards to the ways the Scottish Government plans to implement the Commission's recommendations, to ensure the right final approach.

6. A total of 147 consultation responses were received, including considerable Campaign Responses linked to the A96 Action Group (around one-third of all responses). This limitation aside, the consultation attracted responses from across a wide range of infrastructure thematic areas, including: Construction and Built Environment, Natural Environment and Climate Change, Travel and Transport, Local Government, Energy, Telecoms, Water and Waste, Business and Enterprise, and Health, Education and Public Services.

7. The findings of the consultation will be used by the Scottish Government to finalise the IIP in early 2021, and it will be published thereafter.

Table 1: Summary Analysis Feedback
Consultation Question Main Feedback
1a) Do you support the inclusion of natural infrastructure in our definition of infrastructure?
  • A vast majority agreed (95%).
  • There is broad agreement that the proposed definition reinforces the important role and contribution that natural infrastructure plays in society. The proposed change to the definition is welcomed.
  • Natural infrastructure is an integral part of the social, economic and environmental fabric of society, and plays an invaluable role. Broadening the definition could help address the issue of natural infrastructure often being under-valued in terms of its contribution towards inclusive economic growth.
  • There is a request for: a clearer definition of natural infrastructure and a detailed explanation of the intended benefits/consequences of widening the definition. A suggestion is that additional examples and illustrations of natural infrastructure investment and the benefits, impacts and the value it helps to deliver would be helpful.
1b) Do you agree with the wording proposed for the revised definition?
  • A majority agreed (62%).
  • Our analysis confirms that there is universal agreement with the definition in broad terms. However, consultation respondents reported that the definition could be further clarified, improved and/or strengthened, and/or provided suggested wording or phrasing changes.
  • Much of the commentary seeks clarification on the proposed definition, and more specifically on terminology. A common theme is that the Draft IIP could define more clearly what is meant by the various terms used in its proposed definition of infrastructure (e.g. "natural assets", "networks").
  • Common feedback is that natural infrastructure could be better described, illustrated and understood (in the proposed definition of infrastructure as well as in the Draft IIP more generally), including the multiple benefits that arise from natural infrastructure.
  • There is also some feedback that the definition could be enhanced by adopting a definition that is consistent with that applied elsewhere in order to better understand the potential opportunities around nature-based solutions.
  • Reference is made to, for example, adopting the International Institute for Sustainable Development (IISD) definition of national infrastructure in full, and reviewing the work of the Scottish Forum on Natural Capital on the well-being economy monitor.
2a) Do you agree that the steps proposed in the Common Investment Hierarchy are the right ones?
  • A majority agreed (64%).
  • The Common Investment Hierarchy is broadly welcomed and considered a sensible approach in principle.
  • There is also general agreement and recognition of the merits and benefits of maintaining, enhancing or repurposing existing assets – but that the Common Investment Hierarchy represents a significant shift in practice.
2b) If you think any adjustments are needed to the proposed investment hierarchy, please provide suggested changes (and evidence, where appropriate) to support your answers.
  • Much of the wider commentary relates to the graphical depiction and visualisation of the Common Investment Hierarchy as presented in the Draft IIP, and the perceived rigid or simplistic message it conveys.
  • There is a perceived lack in emphasis or explicit reference across each step of the hierarchy to consideration of natural infrastructure and assets, and a route map to achieving net zero emissions by 2045. These could be more strongly reflected and integrated across the hierarchy and Draft IIP.
  • The main feedback is that in its current form the hierarchy:
    • Does not take cognisance of regional differences in the provision and quality of existing infrastructure.
    • Could strike a better balance to ensure that future need and opportunities are addressed.
    • Could be stronger in terms of ensuring that infrastructure investment decisions deliver "system-wide" benefits.
  • A key theme that emerged from consultation responses is a request for further/additional guidance and greater clarity within the Draft IIP on, for example:
    • The detail of the Common Investment Hierarchy.
    • The parameters that would be expected to be applied to each stage.
    • How the move between each of the four steps is justified.
    • How the hierarchy is expected to be applied and implemented in practice.
    • How the hierarchy is to be applied to natural capital infrastructure.
    • The processes involved to ensure that clear and transparent decisions are made at each stage of the process.
    • The level at which the hierarchy will be applied.
3a) Do you agree that a dashboard of indicators is the best approach to enable informed decisions to be taken about the long-term trade-offs and choices in our infrastructure investments?
  • There is wide-ranging support for a dashboard of indicators to be adopted. A majority of consultation respondents support the proposed approach (circa 70%). Among other things, this is considered vital to ensure a clear, transparent, and consistent approach or set of parameters against which to inform (balanced) decision making.
  • There is equally strong support for developing a robust framework to ensure a holistic assessment of infrastructure investment, and for assessing impact and contribution towards outcomes.
  • There is recognition that the dashboard should provide sufficient flexibility in terms of application across a wide range of infrastructure types. It should also be agile, responsive and adaptive to changes in the external environment e.g. the global coronavirus (COVID-19).
  • There is also support for the dashboard to be underpinned by the National Performance Framework, Scottish Centre for Regional Inclusive Growth Dashboard, and the United Nation (UN) Sustainable Development Goals (SDG). The general view is that these frameworks are sufficiently broad, and a sensible starting point.
  • There is, however, wider acknowledgment that:
    • More development work is required to finalise the Common Investment Hierarchy before outcomes/indicators can then be finalised (e.g. a co-design approach is recommended).
    • Further guidance is needed on how the dashboard will be applied in practice and how the indicators will be used to appraise different types of infrastructure projects.
    • Clear appraisal methodology would need to be developed in order for infrastructure investment to be considered holistically.
    • That weighting of indicators could be considered
3b) What outcomes (and/or indicators) do you think should be included in developing a common assessment framework for prioritising infrastructure investment?
  • There is broad support for the three proposed themes of the common assessment framework. The themes are considered appropriate as overarching areas of focus for the framework, and for outcomes and indicators to be selected that reflect these.
  • There is wide acknowledgement of the inherent challenges that are likely to be encountered in the design of such a framework given difficulties in comparing different types of infrastructure projects.
  • There is recognition that metrics to assess the infrastructure impact on the delivery of net zero and inclusive economic growth outcomes is under-developed.
  • The final measures of success would need to go beyond traditional economic measures and include a broad mix of quantitative and qualitative indicators.
  • Data quality, relevance and availability is considered critical to support a consistent approach to comparing investment propositions and to inform decision-making.
  • Related points are around the importance of:
    • Ensuring indicators are robust, SMART (i.e. specific, measurable, attainable, relevant and time-bound), manageable and meaningful.
    • Establishing a clear baseline position to enable progress to be tracked.
    • Reflecting a spatial dimension within the framework.
    • Data should be capable of being monitored at a local/regional as well as at a national level.
3c) Are there existing tools or methodologies you are aware of which you think the Scottish Government could draw on or adopt in developing its framework?
  • A majority of consultation respondents made specific reference to existing tools or methodologies that the Scottish Government could draw on or adopt in developing its framework.
  • A wide variety of suggestions are put forward, including a mix of third party as well as consultation respondents' own tools, datasets, or methodologies.
  • In excess of 50 tools or methodologies were specified.
  • The feedback points to several existing outcome frameworks, including those at a Scotland level and those that are infrastructure specific. Albeit there is recognition that this is perhaps less well developed in Scotland for natural infrastructure.
  • There is clear support for building on existing approaches in Scotland as well as best practice from elsewhere (e.g. UK, international).
  • Further, there is a clear and strong willingness and openness among consultation respondents to share thinking, information and approaches, and for a collaborative approach to be undertaken between the Scottish Government and key stakeholders to further develop the framework.
4a) Do you support the planned approach to developing a new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets?
  • A majority agreed (72%).
  • Many respondents acknowledge the limitations of the current taxonomy approach. There is common feedback that the approach is too simplistic and/or that it is out-dated and fails to gather sufficient quantitative data.
  • The general view is that the current taxonomy approach does not capture and assess the full impact of emissions made by infrastructure investment.
  • In the context of ambitious national emissions targets to be met by 2030 and 2045, the general consensus among respondents is that the current approach is not fit for purpose, and that developing a new approach is therefore crucial and urgent.
4b) Please explain and support your response with evidence
  • The new approach should include consideration and assessment of the emissions throughout the whole lifecycle of infrastructure investment.
  • Any new approach should consider both embodied emissions and whole life emissions. This would allow more informed decisions on infrastructure investment, and a more accurate reflection of their contribution to national emissions targets.
  • There is broad consensus that the most appropriate approach would comprise a combination of the different options. There is broad support to explore further the use of Baseline and Intervention and Gap Analysis approaches to provide a more useful and meaningful assessment than the current taxonomy approach.
  • Benefits of this approach include an ability to: set targets; quantify and assess trends and changes to a greater degree of accuracy; and undertake comparative analysis between different types/scale of infrastructure projects.
5a) What are your views on the accuracy and scope of the environmental baseline set out in the Environmental Report?
  • A large proportion of respondents did not answer Question 5a.
  • Where comments are provided, there are many that provide positive feedback. This includes a variety of comments which state that respondents are generally content with the accuracy and scope of the environmental baseline/report.
  • Others commented that it appears to be a fair, comprehensive, robust or relevant assessment. Several consultation responses welcomed the document's acknowledgement of the importance and significance of the climate emergency.
  • Feedback regarding the accuracy and scope of the environmental baseline set out in the Environmental Report is often caveated with wider points of note/concern or suggestions for improvement (e.g. too high level, too generic, lacks detail, a little cursory).
  • There are various comments that note aspects that could be given greater prominence or be better reflected in the environmental baseline set out in the Environmental Report to ensure close alignment with the Common Investment Hierarchy.
  • Challenges in making an informed judgement on the environmental baseline's accuracy are highlighted due to limited or a lack of quantification or degree of subjectivity.
  • Indeed, there are various comments that identify a requirement for further development work on the environmental baseline, more details and/or additional national and/or project specific outcome measurements. Some responses provided suggested/additional measures.
5b) What are your views on the predicted environmental effects of the IIP as set out in the Environmental Report?
  • A large proportion of respondents did not answer Question 5b.
  • Where comments are provided, there are a high proportion that provide some positive feedback on the predicted environmental effects of the Draft IIP as set out in the Environmental Report (e.g. fair assessment, predicted environmental effects as stated in the report are accurate and "reasonably considered").
  • Similar to Question 5a such comments are often caveated (and match points raised by other respondents who provided feedback).
  • A key theme, including from two statutory consultees (Historic Environment Scotland and NatureScot), is that looking at the component parts of the Common Investment Hierarchy in isolation has the potential to under value the wider cumulative environmental effects/consequences of the hierarchy.
  • Linked to this, are wider comments across consultation responses that emphasis competing objectives across the three themes in the Common Investment Hierarchy.
  • There is unanimous support expressed for the Draft IIP vision that places inclusive net zero carbon economy at the core.
  • However, there are various comments that note that this position appears to be at odds to the number of perceived high carbon infrastructure projects in the Draft IIP. There is feedback that the predicted environmental effects of the Draft IIP as set out in the Environmental Report are "inaccurate" or "lack credibility" as a result. There is feedback that the Draft IIP is at odds with Scottish Government policy, and it is suggested that there should be a greater focus/detail on the transition to Net Zero.
5c) What are your views on the proposals for mitigating, enhancing and monitoring the environmental effects set out in the Environmental Report?
  • A large proportion of respondents did not answer Question 5c.
  • There are a mix of comments that provide positive feedback on the proposals and/or request greater clarity or detail (e.g. proposals are welcomed, it is covered satisfactorily at a high level).
  • Wide support is expressed for enhanced monitoring arrangements (i.e. on the environmental side to measure contribution towards net zero carbon).
  • There is also strong support among consultation respondents for arrangements to align with, and build on, existing national monitoring and reporting requirements (e.g. National Performance Framework, Scotland's climate change adaptation programme). There is strong support for not "reinventing the wheel".
  • In the main, the proposals are considered to: be a sensible approach; represent a more efficient and effective use of resources; help ensure consistency in reporting practices; and fit well with a joined-up and "systems-wide" approach to place-based infrastructure planning.
  • Data availability is noted as crucial. As are aspects such as having an established/ agreed/consistent set out outcome indicators, and a clear environmental baseline to monitor improvements against.
  • A few consultation respondents note that the proposals for mitigating, enhancing and monitoring the environmental effects set out in the Environmental Report are either "disappointing", "inadequate" or "do not go far enough".



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