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.

Annex B - Campaign Responses

Regarding the inclusion of natural infrastructure within the proposed definition of infrastructure, Campaign Response 1 and 2 raise similar points. Firstly, that aspects of the International Institute for Sustainable Development (IISD) definition of national infrastructure have been omitted within the Draft IIP proposed definition, and suggested it be adopted in full. There is specific reference with Campaign Response 1 to the need to include "and then intentionally managed to provide multiple benefits for the environment and human wellbeing". Both suggested (albeit in slightly terms terms) that the Scottish Government should "adopt a stronger position in protecting the Natural Infrastructure and a commitment that infrastructure projects are assessed on the basis of do not harm to the environment, sense of place or human wellbeing". Campaign 1 notes that there is not a "sufficiently ecosystem services-based approach" and that natural capital and ecosystem services approaches are well-recognised models for sound, informed and proportionate decision making and important for sustainable development" – and should be "fully adopted by Scottish Government as the basis for the new common approach".

While both Campaign Responses agreed with the steps proposed in the common investment hierarchy, there were concerns that "the aspirations of this common hierarchy are only reflected in the introductory warm words of the document and are not reflected in the detail of the draft infrastructure investment plan." To this end, both Campaign Responses noted the "unacceptable" absence of "natural" in relevant sections and questioned whether the priorities of the common investment hierarchy "will be respected when the desire to meet political strategies and outcomes outweighs the process set out". This view was reinforced for the Campaign Respondents as they felt "the focus largely remains on new road building rather than rail, buses and trains" with insufficient evidence of investment in natural infrastructure, such as capture and storage strategies, low carbon heating and/or passive housing standards, which was "inconsistent" with the proposed new definition of infrastructure. For both Campaign Responses, the detail of the Draft IIP signals "business as usual…with little evidence of tipping the balance away from legacy high carbon plans" while also noting that the "the legal requirement to meet zero emissions targets is not adequately represented in the hierarchy".

Both Campaign Responses agreed that the dashboard of indicators is a "useful" and "well-established" approach. However, the proposed dashboard set out in the Draft IIP was deemed not "fit-for-purpose" as it an illustration which only "comprises categories with no objectives, no deliverables or milestones" and "does not provide any key performance indicators (KPIs)". It was noted that the dashboard of indicators must contain objectives and KPIs that are "SMART (Specific, Achievable, Measurable, Resourced, Time-bound)". Additional outcomes and indicators included:

  • Implementation of a Social and Environmental Index (SEI) model for decision making which "directly considers relevant social and environmental benefits and costs". This was also supported by Campaign Response 2;
  • Implementation of a Financial and Economic Index (FEI) model to "condense the minimum amount of relevant information required to appropriately represent the financial and economic effects, derived from projected infrastructure investments and assessed against Natural Capital implications". It was also stated that "the preservation and conservation of Natural Capital should be prioritised and enshrined in law…to achieve sustainable and resilient places". This was also supported by Campaign Response 2;
  • An outcome that "investment decisions are proportional and put citizens and the environment first" with a related KPI to ensure that "the infrastructure budget shows a clear needs-driven expenditure, which is evidence based and the expenditure is supported by the local citizens".
  • An outcome related to strengthening social capital and a related KPI to ensure "co-design with citizens in all road infrastructure projects and appropriate percentage of all other large capital projects";
  • An outcome related to ensuring "opportunities for all to benefit from green economic recovery and growth" with related KPIs including "short-term objective of 100% broadband connectivity for all citizens", "100% of council and social housing have improved insulation", and "100% of council and social housing have low carbon heating installed"; and
  • An outcome for "disadvantaged individuals to have improved opportunities and support" with a related KPI to ensure that the "Scottish Government gives more financial support to organisations that provide opportunities for disadvantaged individuals".

Combining the use of "other well established and more appropriate web based tools" with objectives and KPIs would "enable strong strategic decision making" and aid "better accountability and transparency".

Other tools and methodologies suggested by Campaign Response 1, most of which related to green infrastructure and natural capital, included:

  • The Infrastructure Prioritization Framework published by the World Bank (also noted in Campaign Response 2)[6];
  • Manual of Green Infrastructure Functionality Assessment – Decision Support Tool published as part of the ERDF-funded Interreg Central Europe Project MaGICLandscapes 'Managing Green Infrastructure in Central European Landscapes';
  • Signposting to various green infrastructure resources used as part of the North West Climate Change Action Plan in England;
  • GRaBS Adaptation Action Planning Toolkit published by University of Manchester;
  • Principles of Natural Capital Accounting published by ONS;
  • Green Infrastructure Resource Library (GIRL) produced for the Green Infrastructure Partnership; and
  • Natural Capital Committee's Green Book guidance on embedding natural capital into public policy appraisal.

Campaign Response 1 (responded no) and Campaign Response 2 (responded yes) differed on the planned approach to developing a new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets. Despite differing on the closed response, the qualitative feedback was largely similar. For example, both Campaign Response 1 and 2 highlighted the importance of conducting attributional lifecycle assessments as it would be "indefensible to undertake major infrastructure projects without a full account of the impact of the project on emissions, reduction in carbon sequestration and storage during construction and operation".

However, the feedback did not include any specific preferences or comments on the four options for the new approach. Instead, Campaign Response 1 and 2 used this space to underline the required urgency for action as "the window for making the right choices is uncomfortably narrow [as] the lifespans of most infrastructure and related physical investment means that future GHG emissions are going to be locked in by investment choices in the next decade". It was also stated that there should be a focus on investment in the "right kind of infrastructure" which is "low-emission, energy-efficient and climate-resilient" to "manage climate risks and deliver long-term sustainable growth".

In terms of the accuracy and scope of the Environmental Report, Campaign Response 1 and Campaign Response 2 stated that there is "not a lot of detail on how to reduce emissions and how to use our limited carbon budget to build the net zero infrastructure we need", and provide further comments on specific aspects such as transport, human health, soil, water and biodiversity. Overall, the feedback from the Campaign Responses was that the Environmental Report "fails to recognise the urgency of the situation and that the measures proposed will not meet the Paris Agreement Goals".

Campaign Response 1 felt that the predicted environmental effects of the Draft IIP were mostly considered within the Environmental Report and "welcomed" the recommendations. However, there was "considerable concern that at the inception of the IIP there is already an acknowledgment that negative environmental impacts may be consequential outcomes of the implementation of the plan" and notes that there is contrast between the recommendations set out in the Environmental Report and certain aspects of the Draft IIP, particularly transport e.g. support for dualling of the A9 and A96. For Campaign Response 2, the Draft IIP "lacks creditability" as a result of these contradictions.

In terms of the proposals for mitigating, enhancing and monitoring the environmental effects, Campaign Response 1 stated that "this is the most disappointing part…because approach is inadequate and there is a lack of critical appraisal, and assessment of optimal methodology and implementation approaches". Both Campaign Responses reported that there should be a consideration of avoidance as the step before mitigation which would "negate the need for any mitigation".

When avoidance cannot be achieved, Campaign Response 1 stated that:

"If under very limited circumstances, there is no alternative but to cause negative impact on the environment, the project must be designed to be carbon negative or at worst carbon neutral. There can be no allowances for carbon positive projects if the zero emissions targets are to be met in 15 years…Unless the project can unequivocally be seen to be carbon negative (or neutral at worst case) then it should not receive any funding".



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