Background and Strategic Environmental Assessment (SEA)
This is a non-technical summary of the Environmental Report of the draft Cleaner Air for Scotland 2 (CAFS2).
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. SEA provides an opportunity for the public to express their views on the draft strategy and on an Environmental Report setting out the assessment findings. The Environmental Report has been prepared in accordance with the Environmental Assessment (Scotland) Act 2005.
The SEA focused on air, population and human health and climatic factors and for completeness a light touch consideration of water, soil, biodiversity and material assets (land) was also included for Theme 7 as relevant to agricultural emissions proposals. The Environmental Report sets out the assessment findings and makes recommendations for mitigation and enhancement where appropriate.
Early comments from the SEA Consultation Authorities (NatureScot, SEPA and Historic Environment Scotland) have been taken into account in shaping how the assessment has been undertaken, what it covers, and the level of detail in the Environmental Report.
Cleaner Air for Scotland 2 (CAFS2)
In November 2015, the Scottish Government published ‘Cleaner Air for Scotland – The Road to a Healthier Future’ (CAFS). This was the first Scottish air quality strategy separate from the rest of the UK and sought to bring together the major policy areas relevant to air quality - climate change, transport, planning, health and energy - within one overarching framework. The strategy set out around 40 actions relating to these policy areas, with the primary focus being on urban air quality, and also covers the Local Air Quality Management (LAQM) system.
In November 2018, an independently led review of CAFS was commissioned. The purpose of the review was to assess progress in implementing the actions contained in CAFS and to identify priorities for additional actions to deliver further air quality improvements. Both the review findings and wider views were used to inform the development of the draft CAFS2.
The draft CAFS2 is centred around 10 themes, reflecting the high level recommendations arising from the CAFS independent review. Each theme is underpinned by actions. The draft CAFS2 structure is set out in the table below.
1. Health – a precautionary approach
Actions that focus on assessing and commissioning research on health impacts associated with air pollution.
2. Integrated policy
Actions that focus on existing policy integration across sectors to support the delivery of co-benefits for air quality.
Actions that focus on embedding air quality improvements in plans and polices such as the Place Standard.
Actions that focus on research to improve current air quality data.
5. Behaviour change
Actions focus on the development of a public engagement strategy on air quality in Scotland and the undertaking of a baseline survey of current public awareness of air pollution health effects and source contributors.
6. Industrial Emissions regulations
Actions that focus on the continuing application of existing EU air standards and themes and explore potential additional measures (i.e. industrial emissions).
7. Tackling non-transport emissions sources
Actions that focus on educational incentives and encouraging the reduction of air pollution associated with domestic combustion.
Introduction of legislation to control the supply of the most polluting domestic fuels.
Agricultural emissions, nitrogen deposition and environmental impacts
Actions to support agricultural emission reduction including a voluntary code of good agricultural practice, as well as review, investigation and monitoring of nitrogen deposition and environmental impacts.
Actions to introduce Low Emission Zones into Scotland’s four largest cities (Edinburgh, Glasgow, Dundee and Aberdeen), minimise travel and support active travel, as well as ensure public transport provision.
9. Governance, accountability and delivery
Actions focus on effective governance and joined up delivery of the draft CAFS2.
10. Further progress review
Action focus on reviewing progress on actions identified by the draft CAFS2 and ensuring further developments, challenges and actions can be identified.
Key Environmental Pressures
The following figure summarises key pressures relevant to CAFS2 by topic.
- Key pressures include emissions from industrial, domestic, agricultural, natural and transboundary sources. In urban areas, transport emissions are the biggest source of air pollution.
- Emissions of the majority of air pollutants have declined in recent years, with ammonia declining at a slower rate than other pollutants. Ammonia is recognised as a key air pollutant that can have significant effects on both human health and a detrimental impact on soils, water and biodiversity.
- Poor air quality continues to affect human health and the environment in some areas.
- Air and soil quality are linked through common sources of pollution.
- Changes in land use and management can result in change in soil organic matter which impacts on soils’ ability to perform its range of functions.
- Soil pollution and contamination can be locally significant and threats to soil can be exacerbated by mis-use of chemicals; waste management; and, recycling operations during development.
- Ammonia deposition can lead to the acidification of soil which can degrade the natural environment leading to excessive nitrogen being supplied to sensitive habitats, negatively impacting biodiversity.
Population and Human Health
- Key pressures include outdoor air pollution which is known to causes damage to human health. Highly urbanised areas are likely to have higher concentrations of pollution than rural locations.
- Health impacts can be associated with indoor air pollution with sources differing by setting but including emissions from burning fuels for heating and cooking.
- Air pollution and the consequent impacts on human health are not evenly spread and disproportionately linked to more vulnerable groups and deprived areas.
- Air pollution can cause damage to plants and animals and other impacts on biodiversity that can result in species loss, habitat change and increased sensitivity to environmental stresses.
- Ammonia is a key pollutant and nitrogen deposition is a key pressure on a wide range of habitats. Nitrogen emissions from combustion plants, intensive agriculture and transport causes acidification, eutrophication and direct tissue damage to plants.
- Key pressures include land use intensification and change, pollution and climate change.
- Air quality and climate change are intrinsically linked and key pressures include greenhouse gas emissions from a range of sectors including transport, agriculture and related land uses, business/Industry, energy, and residential.
- Climate change has the potential to exacerbate key pressures on a range of environmental receptors.
- Climate change could alter current patterns and concentrations of air pollution.
- Key inter-related climate change risks such as shortages in the public water supply, agriculture, energy generation and industry; risk to natural capital, including terrestrial, coastal, marine and freshwater ecosystems, soils and biodiversity; and new and emerging pests and diseases, and invasive non-native species, affecting people, plants and animals.
- Key pressures in some areas include changes to water flows and levels, invasive species, poor water quality and overall ecological condition.
- Key pressures on freshwater include man-made barriers to fish migration, physical changes to beds and banks and rural diffuse pollution .
- Similarly to soil, ammonia deposition can lead to the acidification of water, degrading the natural environment and negatively impacting biodiversity, flora and fauna.
- Groundwater quality can be affected by diffuse rural pollution and discharges from industry, whereas groundwater flow and levels can be affected by agricultural irrigation and industry.
- Diffuse pollution as a result of atmospheric deposition can effect both water and air quality and increased nitrogen concentrations can lead to acidification and eutrophication of water bodies.
- Key pressures include emissions associated with agricultural practices, mostly dominated by ammonia release when slurries, manures and nitrogen fertilisers come into contact with air, leading to diffuse pollution in water and soil.
- Intensive land use/ land management practices are leading to pressure on associated natural resources such as land (and environmental receptors such as soil, water and biodiversity).
What are the assessment findings?
The draft CAFS2 is likely to have significant positive effects on air quality, population and human health and climatic factors. This is likely to result from new legislative proposals to control the supply of the most polluting domestic fuels coupled with new supportive measures to target domestic emissions. Actions identified to target agricultural emissions, nitrogen deposition and environmental impacts including a code of good agricultural practice for Scotland (theme 7) has potential to further contribute to positive effects on these topics. By drawing together existing air quality improvement polices and proposals in a co-ordinated way across a range of topic areas including health, planning and transport (themes 2, 5, 6, and 8), CAFS2 can also cumulatively contribute to broad positive effects for air quality, population and human health and climatic factors.
The potential for effects in-combination with other plans, programmes and strategies has also been considered. The draft CAFS2 has the potential to positively and cumulatively contribute across a wide range of Scottish Government policy areas. Air quality improvement is captured across a range of national plans, policies and programmes (for example placemaking and sustainable transport policy) and these are recognised within the draft CAFS2.
Taking into account the high level nature of the draft CAFS2, there is a degree of uncertainty regarding the environmental impacts that may arise as a result of future actions targeting domestic and agricultural emission reduction (theme 7). The assessment also identifies the potential for localised positive effects on the majority of SEA topics (air, population and human health, water, soil, biodiversity and material assets) as a result of actions undertaken to support the implementation of theme 7. For example, actions focusing on agricultural emissions such as the development of a voluntary code of agricultural practice for improving air quality in Scotland has the potential to realise localised positive effects on soil, water, biodiversity and material assets. Where any future plans, projects, and proposals are developed as a result of actions identified by CAFS2, these will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act 2005.
What are the conclusions and recommendations/opportunities for enhancement?
The SEA findings support the inclusion of theme 7 as actions associated with targeting domestic and agricultural emissions, nitrogen deposition and environmental impacts go further than CAFS (2015) which focused on air quality, and particularly transport as the largest source of urban air quality issues. In regard to actions identified to address and support a reduction in domestic combustion emissions, the SEA findings support the introduction of legislation to control the supply of the most polluting domestic fuels. This is because a consistent national approach, as opposed to local approaches, is likely to have a greater impact on reducing domestic combustion emissions.
In regard to actions targeting agricultural emissions, nitrogen deposition and environmental impacts the SEA findings support the inclusion of actions that seek to further consider risks associated with ecological effects from nitrogen deposition such as the development of a voluntary agricultural code and research.
Further, any voluntary code of good agricultural practice could be subject to an early review process to assess its effectiveness and compliance. If the review indicates that insufficient progress was being made, the need for direct regulatory intervention will be considered. This SEA can provide a useful starting point in considering opportunities for realising wider environmental benefits.
The SEA findings also support:
- The inclusion of themes 1 and 5 as actions that support research and public engagement and behaviour change can contribute to continued efforts to reduce preventable air pollution and support the delivery of long term sustained change in environmental quality generally, and air pollution specifically.
- The inclusion of themes 2 and 6 as actions that support strong policy alignment across wider Scottish Government policy objectives. This is because air pollution, climate change, carbon reduction and mobility are strongly interconnected. Effective policy co-ordination across these broad themes, at both central and local government levels, can help to realise multiple environmental benefits.
- The inclusion of themes 3 and 8 as actions that draw together existing place-making and sustainable transport policy. For example, embedding place-making principles, with a strong focus on nature based solutions, across policy areas can support a cleaner, healthier and more attractive environment. Similarly, sustainable transport policy that promotes active travel has the potential to increase physical activity, significantly reduce cardiovascular incidence and mortality, and has been shown to reduce all-cause mortality. Measures to reduce air pollution from road transport and to increase levels of active travel can therefore amplify benefits to public health.
The following opportunities for enhancement have also been identified:
- To obtain maximum environmental benefits under theme 7 (Domestic emissions) a particular focus could be given to urban areas/those outside existing Smoke Control Areas as a means to realise greatest impact.
- To obtain the maximum environmental benefits under theme 7 (agricultural emissions, nitrogen deposition and environmental impacts), it is recommended that early and targeted action should be focused on agricultural practices that can realise multiple environmental benefits. This includes a focus on practices which can deliver both ammonia emission reductions and support the recovery of as much nitrogen as possible. Not only will this reduce agricultural emissions but can contribute to positive localised effects on people, water, soil, biodiversity and material assets.
- To obtain the maximum environmental benefits under health and integrated policy proposals (themes 1 and 2) a focus could be given to evidence and research focused on urbanised areas as these are recognised as being more vulnerable to air pollution.
- To obtain maximum environmental benefits across the wider policy proposals, there may be further opportunities to identify alignment with other existing Scottish Government policy and to apply lessons learnt from COVID-19 as a means to further support improved air quality.
What are the proposals for mitigation and monitoring?
A wide range of existing programmes are already in place at the national and local level to report on environmental status and assess performance against relevant environmental indicators. Further, given that the draft CAFS2 draws together existing plans, programme and strategies that will contribute to improved air quality, monitoring of these Plans, Programmes and Strategies will also be relevant.
An annual progress report has been published for each year of the current CAFS (2015 – 2020). An enhanced and strengthened annual performance report has been proposed as part of CAFS2. A CAFS2 Delivery Group will also be convened with a clear remit, including the authority to ensure that the actions in the new strategy are effectively delivered. It is therefore recommended that the monitoring for SEA purposes is an integral part of the monitoring of the strategy.
What reasonable alternatives have been considered?
The 2005 Act requires the Environmental Report to identify, describe and evaluate the likely significant effects on the environment of reasonable alternatives to a plan, programme, or strategy taking into account its objectives and geographical scope. The extent to which alternatives could be considered reasonable was influenced by the relevant legislative requirements and takes into account those existing policies and actions, the content of which has been set out elsewhere in higher level plans, programmes and strategies.
A ‘do nothing’ scenario was not considered a reasonable alternative because this is considered incompatible with the objective of delivering further air quality improvements while maximising greenhouse gas emission reductions and improving health outcomes in relation to air.
The draft CAFS2 aims to address multiple outcomes based on the above. In addition, the overarching themes were developed by the independent steering group and their underpinning actions are considered collectively in achieving the objectives of the strategy and therefore no single action or an alternative approach to it can be viewed as a reasonable means to deliver the overarching objective to improve air quality.
Taking this into account we do not consider that there are any reasonable alternatives to the draft CAFS2,
How to comment on the Environmental Report
Respondents are asked to submit responses to this Environmental Report directly to the Scottish Government by closing date of 7 January 2020.
You can respond:
- Online: You can respond online using the Scottish Government’s consultation platform, Consultation Hub, at: https://consult.gov.scot/environmental-quality/cleaner-air-for-scotland-2. Consultation Hub allows you to save and return to your responses while the consultation is still open. A copy of your final response will be emailed to you.
- By email to firstname.lastname@example.org.
- In writing to Cleaner Air for Scotland 2, Environmental Quality Unit, Directorate for Environment and Forestry, Scottish Government, Victoria Quay, Edinburgh EH6 6QQ
Following the consultation, a SEA Post-Adoption Statement will be prepared. The Statement will reflect on the comments received on the Environmental Report and the draft CAFS2 and will explain how these have been taken into account in finalising the Strategy.
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