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.

7. Strategic Environmental Assessment


7.1 Strategic Environmental Assessment (SEA) is the assessment of the likely significant environmental effects that a public plan, programme or strategy will have on the environment if implemented. Where possible, it proposes how negative effects can be avoided or reduced and identifies opportunities for positive effects to be maximised. An Environmental Report has been published alongside the IIP. It should be noted that responses to questions in this section include those from the three environmental statutory consultees, namely: Historic Environment Scotland, NatureScot, and Scottish Environment Protection Agency (SEPA).

Question 5a

What are your views on the accuracy and scope of the environmental baseline set out in the Environmental Report?

7.2 Almost half of consultation respondents did not answer Question 5a, or noted that they had no comment to make on the accuracy and scope of the environmental baseline set out in the Environmental Report, or had not read the Environmental Report (circa 43%). It is primarily organisations that did not answer the question, and across all sub-groups (absolute numbers are highest for Construction and Built Environment; Energy, Telecoms, Water and Waste; Local Government; Natural Environment and Climate Change).

7.3 Where comments are provided, there are many organisations that provide some positive feedback (this includes positive responses across all organisation sub-groups, with absolute numbers in this category highest for Local Government, and Construction and Built Environment). There are a variety of comments which state that respondents are "generally content" with the accuracy and scope of the environmental baseline or "concur" with the scope of key environmental issues considered within the report. Other comments are that it appears to be a "fair", "comprehensive", "broad", "robust", "insightful" and/or "relevant" assessment.

7.4 Several consultation responses "welcomed" the document's acknowledgement of the importance and significance of the climate emergency, its "awareness of transitioning to Net Zero" and "the identification of biodiversity as a baseline asset for Scotland, including the links made to climate change adaptation". As noted earlier, the new Common Investment Hierarchy is welcomed given its stronger focus on climate change.

7.5 There is also broad recognition within some of these responses that the environmental baseline is a "high-level policy position and that there are limitations around providing a detailed assessment" at this stage. This point is reported on further below, as there is wider feedback that considers the environmental baseline to be "very generic" or that it "lacks detail", or that it "does not set out Scotland-specific indicators".

7.6 Support expressed for the accuracy and scope of the environmental baseline set out in the Environmental Report is therefore often caveated with wider points of note/concern or suggestions for improvement.

7.7 First, there are various comments that "the summary findings are a little cursory" for particular aspects of infrastructure or aspects could be given "greater prominence" in the environmental baseline set out in the Environmental Report or it could "better reflect" their importance as "major valued assets" within the document, and/or to ensure close alignment with the Common Investment Hierarchy. These suggestions often align with respondents thematic infrastructure areas of interest or expertise. For example, circular economy approach/process, climate change, natural environment (e.g. habitats/species development, biodiversity), digital and data, and transport are all flagged up to varying degrees.

7.8 In some cases, further details or suggestions are provided for how the environmental baseline set out in the Environmental Report could be further improved and developed. These are considered in turn below.

7.9 There is sign-posting to additional reference documents that may further inform the Scottish Government's thinking and development of the environmental baselines. This includes reference to, for example:

7.10 Campaign Response 1 and Campaign Response 2 also note 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. They express support for a vision and approach that integrate and support co-investment in environment and growth as guiding principles.

7.11 Second, there are various comments that highlight challenges in making an informed judgement on the environmental baseline's accuracy due to limited or a lack of quantification. It is mentioned that "more data is required on potential impacts to assess priorities" or that "assessing the accuracy is hampered by the number of variables and their subjectivity". Further feedback notes the challenges are high-level, limited baseline data may present in terms of supporting a robust or accurate assessment of trends, progress and impacts.

7.12 Indeed, there are various comments that identify a requirement for further development work on the environmental baseline, more detail and/or additional national and/or project specific outcome measurements. Some go onto provide suggested/additional measures. The comments often refer back to the suggestions for indicators, tools or methodologies identified at Questions 3a and 3b. Enabling a Natural Capital Approach (ENCA) would be an example of this.

7.13 There are a few specific points on the appropriateness of certain datasets within the baseline (e.g. SIMD) and provision of suggested alternatives to ensure a more "nuanced and rounded understanding of issues and opportunities in rural and remote locations" e.g. Towards Inclusive Growth (TwIG) project that HIE is working on alongside researchers from the James Hutton Institute and Biomathematics and Statistics Scotland (BioSS). Further suggestions are provided to fill real and/or perceived gaps in the environmental baseline to aid consistency (e.g. consideration of indirect gases, a measure of the total consumption of electricity).

7.14 Finally, there is some specific feedback on the narrative within the Environmental Report on consideration of "reasonable alternatives", including from the three statutory consultees. While there is some acknowledgment that the narrative has been informed by the Infrastructure Commission for Scotland's findings, the main points or concerns raised can best be summarised as follows:

  • The position outlined in the Environmental Report is said to limit the range of options that can be considered (e.g. scope, nature, scale) as well as limit decision-making. On the one hand, some note that "do nothing" or business as usual should be considered as a reasonable alternative. On the other, some report that a "fundamental change in focus of the draft Plan" should be considered with regards to meeting Net Zero targets specifically.
  • With regards to the Draft IIP points are also raised regarding a lack of transparency and clarity on how the Scottish Government has taken on board the Common Investment Hierarchy to inform decision-making for the current round of national projects outlined in the Draft IIP, and that it is also not clear how an assessment of environmental impacts have been considered.

Question 5b

What are your views on the predicted environmental effects of the Draft IIP as set out in the Environmental Report?

7.15 A similarly large proportion of consultation respondents did not answer Question 5b, or noted they had no comment to make on the predicted environmental effects of the Draft IIP as set out in the Environmental Report (circa 45%).

7.16 Where comments are provided, there are a relatively high proportion that provide some positive feedback on the predicted environmental effects of the Draft IIP as set out in the Environmental Report. The following quotes are broadly reflective of the variety of comments made by these respondents:

  • "Content that the predicted environmental effects as stated in the report are accurate and reasonably considered".
  • "The environmental effects of the IIP assess and identify the key effects of the themes and opportunities including clearly highlighting the significant effects. Identifying opportunities for enhancement and mitigation for each theme assessed and assumptions/links to other SEA are also a welcome addition to the assessments".

7.17 Further, there is feedback that acknowledges or welcomes specific references made within this section of the Environmental Report, for example, to natural infrastructure, nature-based solutions, and the positive effects natural heritage can have (e.g. support for biodiversity, climate change mitigation/adaptation).

7.18 Similarly to Question 5a (and other consultation questions), many of these respondents go onto caveat positive feedback with additional points of note/concern or provide suggestions for how the predicted environmental effects of the Draft IIP as set out in the Environmental Report could be further developed or improved. All other consultation respondents who provide comment on Question 5b do likewise. This includes the three statutory consultees.

7.19 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.

7.20 Linked to this, are wider comments that emphasis competing objectives across the three themes in the Common Investment Hierarchy. As an example, delivering new commercial premises to support employment creation opportunities via inward investment versus the carbon emissions associated with new build infrastructure projects. There are considered to be discrepancies between achieving and delivering against the three themes (e.g. some impacts can be contradictory rather than complementary). This aligns to wider feedback in support of adopting a "unified" or "systems-wide" approach to infrastructure strategy, planning, investment and prioritisation.

7.21 There are also a number of comments that highlight infrastructure projects of all types will have both positive and negative environmental impacts, and that these need to be considered fully. Technical assessments, such as Environmental Impact Assessment (EIA) and Habitat Regulations Appraisal (HRA) are identified as useful and can help mitigate environmental impacts. A point raised is that these assessments tend to be very "localised", and that there is a lack of clarity within the Environmental Report around how the positive or negative environmental impacts at a national level are to be understood.

7.22 Another common theme to emerge is natural infrastructure, with wide support expressed for this and nature based solutions to be to be embedded in the Draft IIP. However, feedback included that the benefits and impacts of natural infrastructure projects had not been sufficiently captured in the Draft IIP/Environmental Report, alongside a lack of clarity with regard how these benefits/impacts will be appraised and measured.

7.23 There is unanimous support expressed for the Draft IIP vision that places inclusive net zero carbon economy at the core. Indeed, a number of consultation respondents in their response to Question 5b note the urgency of the global climate emergency and the importance of increasing the pace of change on decarbonisation. However, there are various comments that note that this position appears to be at odds to the "significant commitments to investment in grey infrastructure contained in the Draft IIP" or to the many "high carbon infrastructure projects" in the Draft IIP.

7.24 There is also some 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. Both Campaign Responses are among the consultation responses that consider the Draft IIP to be at odds with Scottish Government policy, and suggest that there should be a greater focus on the transition to Net Zero (and more detail on how this is expected to be achieved).

Question 5c

What are your views on the proposals for mitigating, enhancing and monitoring the environmental effects set out in the Environmental Report?

7.25 Almost half of consultation respondents did not answer Question 5c or said that they had no comment to make on the proposals for mitigating, enhancing and monitoring the environmental effects set out in the Environmental Report.

7.26 There are then a mix of comments that provide positive feedback on the proposals and/or request greater clarity or detail.

7.27 Similarly to previous consultation questions, there are many comments which "welcome" the proposals and recommendations for mitigating, enhancing and monitoring the environmental effects set out in the Environmental Report, or note that it is "covered satisfactorily at a high level", or that respondents "agree" or are broadly "content" with the proposals.

7.28 Wide support is expressed for enhanced monitoring arrangements (i.e. on the environmental side to measure contribution towards net zero carbon). It is considered important that the "full nature of risks and opportunities are presented to ensure the most appropriate developments that protect the environment are prioritised". This would also support the transition to Net Zero.

7.29 There is also strong support among consultation respondents for arrangements to align with, and build on, existing national monitoring and reporting requirements, where possible (e.g. National Performance Framework, Scotland's climate change adaptation programme).

7.30 In this regard, 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.
  • Support consistency in reporting practices at all levels.
  • Fit well with a joined-up and "systems-wide" approach to place-based infrastructure planning.

7.31 Data availability is, however, noted as crucial. As are aspects such as having established/agreed/consistent outcome indicators, and a clear environmental baseline to monitor improvements against.

7.32 There are a few comments that allude to the need for "plan-specific monitoring" to determine "what the actual impacts have been".

7.33 There is a consensus that monitoring and reporting on environmental effects is an essential part of the process, and it should be built into the IIP from the outset. There are a variety of comments that note the important role monitoring and reporting of the environment effects set out in the Environmental Report will play in helping to ensure that progress and delivery (success or otherwise) is routinely measured, monitored, and tracked (and to identify any areas which require further action).

7.34 While there are a number of comments that note this section in the Environment Report is "reasonably well covered" from a transparency, scrutiny and accountability perspective on the status and delivery of projects set out in the Draft IIP, there is also a request for more detail to be provided. For example, it is mentioned that there is a need for organisations to develop a better understanding of the extent to which any increase in monitoring requirements will impact on internal capacity and resources. There is some, but limited reference to the future establishment of Scotland's new environmental body, Environmental Standards Scotland, with feedback that it could provide "greater guidance and input into the detail of the framework as it is developed".

7.35 Aligned to this, are a number of wider points that note the importance of:

  • Streamlining reporting requirements.
  • Minimising the potential for duplication of effort.
  • Ensuring that monitoring is used to add value and identifying lessons learned nationally, regionally and locally (e.g. greenhouse gas emissions, biodiversity, job creation).
  • Investment in SMART data systems and data capture to massively increase the accuracy and immediacy of data in this area.

7.36 Finally, the Campaign Responses are among the relatively few consultation respondents to 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".

"The environment must be prioritised, and projects should not be commissioned where environmental damage will result. 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".

Campaign Response 1

7.37 Statutory consultees also express disappointment with the proposals and missed opportunities, as considered below:

  • Historic Environment Scotland note that the assessment presented has not picked up a number of potential positive effects for the historic environment as a result of the plan – "Given that part of this consultation is focused on how to make informed decisions on investment and how to measure outcomes it is disappointing that the outputs of the environment assessment have been limited in this area".
  • SEPA highlight the importance of mitigation and enhancement proposals being embedded in the finalised plan and the need to consider strategic as well as local level mitigation. It notes disappointment that the focus of the Environmental Report is largely on mitigation delivered through "existing consenting mechanisms and where EIA at the project level prior to work being undertaken"…"Strategic level mitigation e.g. criteria for the avoidance of placing infrastructure in sensitive areas or tools to be used at optioneering stages (such as natural capital assessment) could help to ensure that environmental considerations are addressed upfront rather than at the end delivery stage when mitigation may be considerably more costly and may also have the unwanted consequence of extending project delivery times….the SEA could have been used to compare different investment criteria in terms of their ability to deliver overall enhancement through infrastructure projects. In so doing it could have been used to aid the development of a more detailed framework for consideration of future investment proposals which would support delivery of the proposed investment hierarchy. Such an approach would help to embed environmental enhancement in future decision-making and could lead to significant cumulative benefits".



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