Heat in buildings strategy: strategic environmental assessment

4. Approach to the Assessment

4.1 Purpose

4.1.1 As part of the preparation of the draft Strategy the Scottish Government (SG) is carrying out a Strategic Environmental Assessment (SEA) of its proposed content. SEA is a systematic method for considering the likely significant environmental effects of certain plans, programmes and strategies. SEA involves the following key stages:

• Screening – determining whether the Strategy is likely to have significant environmental effects and whether an SEA is required;
• Scoping – establishing a method for assessment and setting out the consultation period for the Strategy;
• Environmental Assessment – assessing the emerging content of the Strategy and setting out its likely significant environmental effects in an Environmental Report to be published alongside the consultation draft Strategy; and
• Post Adoption Statement – preparing and publishing a post-adoption statement.

4.1.2 This report has been prepared in accordance with the Environmental Assessment (Scotland) Act 2005 ( “the 2005 Act”) and sets out the findings of the environmental assessment stage.

4.2 SEA activities to date

4.2.1 Screening and Scoping was undertaken in November/December 2019 and a combined screening and scoping report was submitted to the SEA gateway inviting views from the consultation authorities. This determined that an SEA was required due to the potential for significant positive effects on climatic factors, population and human health and air and mixed effects on material assets.

4.2.2 The comments received from the statutory consultation authorities have been taken into account in the preparation of the Environmental Report. It is noted that as the draft Strategy developed, its focus was increasingly on setting a vision for the decarbonisation of Scotland’s homes and buildings and the near-term actions that can support deployment of energy efficiency measures and low and zero emissions heat technologies. As the draft Strategy developed it was considered appropriate to scope landscape and cultural heritage into the assessment to ensure that any potential significant effects linked to the identification of strategically important energy efficiency and heat technologies could be given due consideration.

4.2.3 Where the potential for localised indirect effects are identified, including on those topics scoped out of the assessment (biodiversity, water, and soil) these will also be noted, as relevant.

Table 2. Scoping of SEA topics

Climatic factors

√

Biodiversity, flora and fauna

x

Population and human health

√

Soil

x

Water

x

Air

√

Cultural and historic heritage

√

Landscape

√

Material assets

√

4.3 SEA Methodology

4.3.1 The assessment methodology has been refined from that originally identified within the scoping report, which proposed a set of assessment questions. The finalised approach has been developed to reflect the high level nature of the draft Strategy. It also draws on findings from other relevant SEA work. Key stages in the assessment methodology are described below.

Stage 1

Identify relevant environmental information to inform the Environmental baseline

Stage 2

Review and collate findings of previous relevant SEA Environmental reports and summarise key findings to provide an overview of known effects

Stage 3

Assess potential for likely environmental effects (including consideration of potential cumulative, synergistic and in-combination effects) of the draft Strategy’s key components :

• A new 2045 vision and wide supportive energy efficiency and heat decarbonisation outcomes
• Setting a new heat target.

Stage 4

Consider how the key components of the draft Strategy address key environmental issues identified, and make recommendations where appropriate for enhancing environmental benefits.

4.3.2 Early assessment work identified key environmental issues across the scoped in topics. A considerable amount of work has already been undertaken exploring the environmental effects of existing energy-related (including heat decarbonisation) polices and proposals. Of significance is the SEA of the Climate Change Plan Update (2020)^[46].

4.3.3 Other SEAs of relevance that have been reviewed and relevant findings taken account of include the following:

• The Heat Generation Policy Statement (2015)^[47]
• The Climate Change Plan and the Energy Strategy (2017)^[48]
• Energy Efficient Scotland (2018)^[49]
• Climate Change (Emissions Targets Reduction) (Scotland) Act (2019)^[50]
• The Scottish Government’s Programme for Extending Permitted Development Rights in Scotland: A Sustainability Appraisal (2019)^[51]
• Draft Infrastructure Investment Plan (2020)^[52]

4.3.4 The finalised assessment takes the form of a broad narrative analysis of the draft Strategy’s vision and the wide energy efficiency and heat decarbonisation outcomes it identifies and the proposal to set a new heat target in the final Strategy. Potential cumulative, synergistic and in-combination effects have also been considered as relevant and opportunities for environmental enhancement have also been identified.

4.4 Alternatives

4.4.1 The 2005 Act requires the Environmental Report to identify, describe and evaluate the likely significant effects on the environmental of reasonable alternatives to a plan, programme, or strategy taking into account its objectives and geographical scope.

Do nothing/Business as Usual

4.4.2 Do nothing/business as usual is not a reasonable alternative to the draft Heat in Buildings Strategy because the Climate Change (Scotland) Act 2019 requires plans to be laid that set out the pathway to reaching our net zero and interim emissions reduction targets. As such, a heat decarbonisation Strategy is necessary.

4.4.3 In relation to the setting of a target for low and zero emissions heat, a new target is required in order to comply with the Climate Change (Scotland) Act 2009^[53] (Section 61), which sets out a requirement to prepare and publish a plan for the promotion of renewable heat, including a renewable heat target, and to review the plan at least every two years.

4.4.4 To date, the 2009 Renewable Heat Action Plan ^[54] has fulfilled this duty and set a renewable heat target for 2020.

4.4.5 In order to meet our statutory interim climate targets as set out in the Climate Change Act 2019, and ensure long-term delivery of our net-zero objectives, the Update to the Climate Change Plan sets out that by 2030 over a million households will need to convert to a zero or low emissions heating system. Reducing emissions from homes will mean converting the vast majority of the 167,000 off-gas homes that currently use high emissions oil, LPG, and solid fuels, as well as at least 1 million homes currently using mains gas, to low or zero-emissions heating. By 2030, we will also need to convert an estimated 50,000 of Scotland’s non-domestic properties to low or zero emissions sources of heat.

4.4.6 The draft Strategy therefore sets out the intention, through a finalised Strategy, to set a new heat target, to help monitor and track progress along the pathway for reducing emissions in buildings, as set out in the Update to the Climate Change Plan.

4.4.7 Views are invited, through the consultation, on the framing of a new target.

4.4.8 The assessment considers, in broad terms, the likely significant effects of the setting of a new heat target which has the delivery of net-zero objectives at its heart, which focuses on heat in buildings, and which is compatible with statutory fuel poverty targets. Any future target that includes industrial heat would need further consideration against the requirements of the 2005 Act.

Ambition

4.4.9 We acknowledge that, in setting a new heat target there are differing levels of ambition in delivering net zero objectives. At a minimum the setting of a new heat target would need to support the delivery and the deployment pathway for reducing emissions in buildings as set out in the Climate Change Plan Update.

4.4.10 Wherever possible the assessment seeks to draw out the potential for differing environmental effects where a new heat target supports the accelerated delivery of emissions reductions.

Consideration of alternative energy efficiency and heat technology scenarios as a means to deliver the decarbonisation of homes and buildings in line with statutory climate change targets

4.4.11 There are different strategic technologies that are available now, or could become available in the future, to reduce emissions from space and water heating. These include electric heating options such as heat pumps and storage heaters, heat networks and potentially the use of renewable or low carbon hydrogen as a replacement for methane gas in the mains gas network. As such there is a mix of technology options for reduce emissions.

4.4.12 The main technologies available for deployment today, which are likely to remain the main strategic options for the next ten years, are electric solutions (and in particular heat pumps) and heat networks. Subject to the safety and commercial case being established we may see 100% hydrogen becoming available in parts of the gas network towards the end of the decade.

4.4.13 As such, at this point in time, it is considered that there are no reasonable alternatives to a mixed or blended technology pathway as the most effective and credible means of achieving our statutory emission reduction targets in the heat in buildings sector. The assessment does however draw out, wherever possible, the potential likely significant environmental effects associated with key strategic energy efficiency measures and heat technologies identified as having a role to play.

4.4.14 Finally, it is noted that future PPS are likely to set further and more specific ambitions in this context. Of significance will be technology specific PPS (such as any new and emerging hydrogen and bioenergy PPS) as well as lower tier plans. Where any future policies and proposals are developed, these will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act.

4.5 Uncertainty and potential limitations of the assessment

4.5.1 The subject matter of this assessment means that there are a number of areas of uncertainty, some of which would only be resolved as deployment of energy efficiency measures or low and zero emissions heat technologies takes place. These include:

• The precise siting and location of any new development associated with usage and deployment of identified technologies at a range of scales (such as individual appliances as well as a need for any new or upgraded infrastructure);
• The need to secure all relevant permissions and licences (such as those associated with the operation of new heat networks);
• The role technologies could play in the longer term; and
• Relevant emerging PPS (such as national technology specific PPS and future lower tier plans).

Existing planning and consenting regimes and regulatory processes, allied to good working practices and monitoring, can help ensure that potential adverse effects are avoided and positive effects enhanced.