Energy Efficient Scotland: strategic environmental assessment

This Strategic Environmental Assessment (SEA) investigates the likely significant effects on the environment by the implementation of the Energy Efficient Scotland programme.

6 Environmental Objectives

6.1 Review of the Baseline information

Biodiversity, Flora and Fauna

6.1.1 At a national level, it is noteworthy that whilst there are a wide range of pressures on biodiversity, climate change in particular has the potential to greatly impact [27] . The impact of the proposals at a national level is generally considered to be positive. However, at a local level, it is recognised that the installation of energy efficiency technologies has the potential to disturb some species, particularly those using roofs and wall cavities to nest or shelter. In the assessment the ability to mitigate has been included.


6.1.2 As soils play a significant role in terms of storing carbon and therefore help to regulate GHG emissions the impact of the proposals on existing resources has been undertaken. While Scotland's soils are considered to generally be in good health, there are a range of pressures on them. Climate change and loss of organic matter pose the most significant threat. At a national level this can only be done at a strategic level and it is considered that the overall impact of the programme and its constituent parts will be broadly positive. However, in certain assessments the need for a more local solution has been considered, particularly where there is a known likely impact at a localised level.


6.1.3 Scotland's water resources are generally considered to be in good condition [28] . However the localised impact of proposals on water quality and quantity must be assessed. This is particularly the case with local installation of energy efficiency schemes which use water as a resource directly through extraction and heat extraction. The impact at this level may therefore considered to be mixed.

Population and Human Health

6.1.4 The key consideration is the impact of the programme and its constituent parts to GHG emissions and the impact this has on human health. At both a national and local level this is likely to be positive and will, over time, have significant impact on the quality of lives across Scotland.


6.1.5 Air pollution can result in adverse impacts on both human health and can significantly affect many aspects of quality of life. Air pollution can also cause adverse effects in the wider environment [29] . Air quality is important for both short and long-term human health, and poor air quality can have impacts on people with existing health issues. At a national level the proposals are likely to have positive impacts primarily due to the reducing in GHG emissions and a reduction in reliance on fossil fuels. At a local level however, the installation of specific projects may have localised and short term imapcts caused through dust. There will be a need to consider this on a site by site basis and review the need for local solutions.

Climatic Factors

6.1.6 Climate change is considered to be one of the most serious environmental threats to sustainable development, with adverse impacts expected on human health, food security, economic activity, natural resources and physical infrastructure [30] . Adaptation to the effects of climate change is now acknowledged as being necessary to respond effectively and equitably to the impacts of climate change. The proposals under this programme are all designed to address this and have the need to make a positive contribution at their heart. This is at both a national and local level and are principally associated with reductions in GHG emissions.

Cultural Heritage and the Historic Environment

6.1.7 Scotland's many and varied historical sites are unique and irreplaceable. These sites and features are regarded as making a valuable contribution to our quality of life, cultural identity, education and economy. While the proposals are likely to have a positive impact on these properties by way of their energy efficiency standards, this may have mixed impact by way of the visual impact associated with the installation of measures. The impact at a national level is likely to be negligible, but at a local level, localised solutions will be required to mitigate.

Material Assets

6.1.8 The building stock across Scotland is a valuable resource and should be treated as such. The proposals aim to improve the energy efficiency of all buildings and as such will have a positive impact. The option to prioritise retrofitting and reuse of properties rather than demolition is positive both in terms of the impact on local communities and also on the stock as a source of captured carbon.

Landscape and Visual Impact

6.1.9 Land use change, incremental and on-going development such as infrastructure projects, and design all impact on the quality of Scotland's valuable landscape. The proposals, at a local scale, could have a mixed impact, depending on the measures being installed. Local solutions will be required to ensure that the impact is appropriate and that proposals contribute to the aim of making all of Scotland's local environments valued as attractive and healthy places to live [31] .


6.1.10 At a national level, Energy Efficient Scotland has at its heart the need to make a significant contribution to the meeting of climate change targets. As such it will, together with its constituent proposals, make a net positive contribution to the environment. Without the programme it is likely that the speed of travel will slow, and the opportunity to create a co-ordinated approach across Scotland will be lost.

6.2 Relationship with other Plans, Programmes and Strategies and Environmental Objectives

6.2.1 The Programme is one which is founded in making positive contributions to the environment through energy efficiency measures. As such, a wide range of environmental protection and improvement objectives are set out within existing legislation, policies, plans, programmes and strategies set at the EU, UK and Scottish levels. The following sections of this report provide an overview of the overarching objectives considered most relevant in the context for the preparation of the Programme and its delivery mechanisms. This wider policy context also demonstrates the close links between their development for example, their common ambitions and drivers.

Figure 2: The relationship of the Programme with other plans, programmes and policies
Figure 2: The relationship of the Programme with other plans, programmes and policies

6.2.2 A further overview of selected key plans, programmes and strategies and their objectives is set out in the environmental baseline section of this report. This has been developed to ensure that the objectives and ambitions are set out at an early stage in the development of the Programme and its delivery mechanisms and ensure they are appropriately reflected in the SEA process.

6.3 The Policy Context

6.3.1 The policy context for the delivery of the Programme and its package of projects is founded in two key pieces of legislation. The Climate Change (Scotland) Act 2009 (the 2009 Act) [32] ( section 2.1.1) set the statutory framework for GHG emissions reductions in Scotland, with targets for reductions by 80% in 2050, with an interim 2020 target of 42%. These targets are more ambitious than those for the UK as a whole, or the EU. The Housing (Scotland) Act 2001 [33] required the Scottish Executive to publish its first Poverty statement [34] which provided the first definition of fuel poverty. This statement, backed by the 2001 Act set a target to ensure, so far as reasonably practicable, that people are not living in fuel poverty in Scotland by November 2016.

6.3.2 The Climate Change Delivery Plan [35] , developed in 2009, set out the high level measures required in each sector to meet Scotland's statutory climate change targets, looking both up to 2020 and beyond. ( Climate Change (Scotland) Act 2009)

6.3.3 The Committee on Climate Change provides independent, expert advice to Scottish and UK Governments about all aspects of climate change. In July 2016, the Committee provided advice to Scottish Ministers on setting annual emission reduction targets for the years 2028-2032 [36] .

6.3.4 The Climate Change Plan [37] commits the Programme to the transformation of Scotland's building stock, with policy outcome 1 - 4 seeking radical improvements to the fabric of Scotland's domestic and non-domestic buildings resulting in a 30% reduction in energy intensity and emissions intensity of all buildings by 2032. It commits the Programme to a number of milestones which include the creation of regulation and standards and the supply of an offer of support for all building owners.

6.3.5 Section 53 of the 2009 Act placed a duty on Ministers to produce an adaptation programme to address the risks identified for Scotland in the UK Climate Change Risk Assessment [38] . The Climate Ready Scotland: Scottish Climate Change Adaptation Programme [39] was published in 2014 and outlined Scottish Ministers objectives. It also included a series of policies and proposals aimed at mainstreaming climate change adaptation across sectors and Scottish Government portfolios, with the aim of achieving measured reduction in climate change risks. The programme was structured into three themes, comprising adaptation in the natural environment, buildings and infrastructure networks and a climate ready society. The programme has had a focus of identifying and engaging key partners within business, communities and organisations, delivering case study successes, and in the dissemination of information.

6.3.6 The Infrastructure Investment Plan 2015 [40] set out priorities for investment and a long term strategy for the development of public infrastructure in Scotland. It outlined why and how the Scottish Government invests, and what it intends to invest in up to 2035 by sector. The Plan reflected upon the clear strategic direction for our infrastructure investment decisions set out in the Programme for Government and Scotland's Economic Strategy. This identifed the Programme as a national infrastructure investment priority, and as the cornerstone to achieving a substantive improvement to the energy and heat efficienty of our building stock, investing in the majority of our buildings to make them fit for Scotland's low carbon future. It has also committed multi-year funding which will give our delivery partners the certainty they need to deliver ambitious energy efficiency projects.

6.3.7 The Plan also reiterated Scotland's commitment to overarching objectives of decarbonisation of electricity generation and the heat sector by 2030 and 2050 respectively. It discussed investment aimed at improving energy efficiency in domestic and business context. It built upon Scotland's commitment to meeting targets of achieving 100% of energy demand and 11% of heat demand from renewables by 2020, and reducing end use energy consumption by 12% over the same period. The development of these targets took forward commitments for the promotion of renewable energy generation at the European level, principally in the Directive on Electricity Production from Renewable Energy Sources (2001/77/ EC) [41] .

6.3.8 The Conserve and Save: Energy Efficiency Action Plan [42] set out a range of supporting actions for the Scottish Government's commitment to reduce total final energy consumption by 12% by 2020. It was largely focused on reducing the amount of energy needed to heat and cool our homes, our workplaces and the energy consumed in industrial processes; principally by encouraging behavioural change and low carbon practices.

6.3.9 Most recently published, Scottish Energy Strategy: The future of energy in Scotland [43] commits the Scottish Government to the launch of a full Routemap for the Programme and to the introduction of the Transition Programme. It highlights the way in which the Programme will build on existing successful programmes such as Energy Efficiency Standards for Social Housing, Home Energy Efficiency Programmes Area Based Schemes and the Public Sector Non-domestic Energy Efficiency Framework and Project Development Unit, this strategy clarifies the Programme's focus to the mid-2020s to reduce energy demand in all buildings across Scotland, establishing solutions for switching heating supplies from high to low regrets lower carbon or renewable sources for properties off the mains gas grid. It will also encourage appropriately-sited low carbon district heating, where that is the most low regrets heat decarbonisation technology.

6.3.10 The Housing (Scotland) Act 2001 [44] set the first requirement for Scottish Ministers to publish a statement setting out the measures they have taken and intend to take for the purposes of ensuring, so far as reasonably practicable, that persons do not live in fuel poverty. This was first published by the Scottish Executive in 2002 and set out Scotland's definition of fuel poverty, i.e. that a household was fuel poor if energy costs to keep their home sufficiently warm were not less than 10% of their income (informally known as the '10% definition'). Backed by legislation, the statement also set a target to ensure, so far as reasonably practicable, that people are not living in fuel poverty in Scotland by November 2016. A review of the Fuel Poverty Strategy for Scotland is currently ongoing [45] and the Programme plays an integral part of that strategy. Following this review, we are committed to bringing forward a Fuel Poverty Bill in due course which will provide the required regulatory framework for the implementation of the review findings.

6.3.11 National Planning Framework ( NPF3) [46] was published alongside Scottish Planning Policy ( SPP) [47] in June 2014. These set out context for development planning in Scotland, providing a framework for the spatial development of Scotland as a whole. They focus on four principle themes: a successful, sustainable place; a low carbon place; a natural, resilient place; and a connected place; all of which share an overarching theme of sustainability and protecting natural and cultural assets.

6.3.12 NPF3 brought together plans and strategies in economic development, regeneration, energy, environment, climate change, transport and digital infrastructure, to provide a coherent vision of how Scotland should evolve over the next 20 to 30 years. NPF3 is clear that planning must facilitate the transition to a low carbon economy, and should help to deliver the aims of the Scottish Government's low carbon ambitions and the RPP programme. In particular, it noted that the energy sector accounts for a significant share of Scotland's GHG emissions, and highlighted the potential for opportunities in this sector, and others, to contribute towards these aims. The importance of strengthening infrastructure, such as the electricity transmission grid, was also noted alongside the overarching need to protect the natural environment and ensure that natural assets are used sustainably. ( Ambition - Opportunity - Place: Scotland's Third National Planning Framework)

6.3.13 Developed alongside NPF3, SPP was based around the same four themes. The SPP sets out the national planning policies for Scotland which reflect Scottish Ministers' priorities for operation of the planning system, and the development and use of land. It also set out policy principles for supporting low carbon transition that are consistent with national objectives and targets, supporting the development of a diverse range of energy generation options including the expansion of renewables and district heating, and reduction in GHG emissions and energy consumption. These policies also set out how the visions presented in NPF3 should be delivered on the ground. The SPP further noted the role of planning in protecting and making efficient use of Scotland's existing resources and environmental assets.


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