4. Opinions expressed on the Environmental Report
4.1.1 Question 12 of the consultation on a new Climate Change Bill invited opinions on assessing the environmental impacts of the proposals. The question contained five sub-questions (a – e) to help frame responses on the Environmental Report and these are provided below. Corresponding views and comments received have been summarised in the sections that follow.
- What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process? (Please give details of additional relevant sources)
- What are your views on the predicted environmental effects as set out in the Environmental Report?
- Are there any other environmental effects that have not been considered?
- Do you agree with the conclusions and recommendations set out in the Environmental Report?
- Please provide any other further comments you have on the Environmental Report.
4.1.2 Questions 12 a – e received between 127 and 149 responses. Across these questions, most respondents who expressed a view on the Environmental Report were supportive of its use of evidence and agreed with the predicted environmental effects the Environmental Report set out, as well as its conclusions and recommendations. Of those respondents who criticised the report in general terms, many suggested that this should consider emissions from the production of goods and services elsewhere that are consumed in Scotland. Some respondents claimed that the Environmental Report does not adequately address the urgency of climate change because the Bill proposals are not ambitious enough. A small number of respondents commented that the report is unclear or biased.
4.1.3 Many respondents did not comment in detail on the report, stating that they did not have an opinion, or that the document was too complex. Responses below have been amalgamated under the two headings of views expressed on the evidence and assessment of the Environmental Report, and the report's findings. This is the case as these were the SEA questions which received detailed responses. In addition, respondents included a number of other comments, including on mitigation and monitoring, which are also detailed below.
4.2. Evidence and assessment process
4.2.1 The SEA consultation authorities and respondents who provided detailed feedback, described the evidence used to inform the assessment process and set out in the report as comprehensive, well-summarised and clear. They considered that the approach taken, which includes a review of previous relevant assessments, was appropriate. Respondents welcomed the inclusion of references to transport and planning strategies and evidence on the potential health impacts of the proposals.
4.2.2 Some respondents expressed a view that aspects of the report required further consideration or that parts of it relied on assumptions or narrow evidence bases thus limiting the scope for accurate predictions to be made. Some respondents offered additional relevant sources to address perceived gaps in the evidence to inform the assessment process, including articles, Scottish and UK government publications and research from organisations like the Centre for Alternative Technology.
4.2.3 Some respondents suggested topics they felt could be included in greater detail in the evidence set out in the report, including:
- management planning for river basins and flooding;
- agriculture and land use;
- pollution and air quality;
- ocean acidification;
- the spread of human and animal diseases;
- the impacts of fossil fuel extraction; and
- emerging energy sources, such as hydrogen and bioenergy.
Scottish Government response
4.2.4 The additional information provided by respondents is helpful and will be taken into consideration in subsequent SEA work, where appropriate. We are satisfied that this does not alter the findings of the assessment as outlined in the Environmental Report.
4.3. Predicted environmental effects
4.3.1 There was agreement among most respondents and the SEA consultation authorities that the assessment represents adequately the range of environmental impacts which may occur. They highlighted that proposals will impact positively on global climate, and often specified positive secondary impacts that could result from decreased emissions, such as improved health and air quality, and increased biodiversity. Some respondents welcomed the inclusion of potential negative effects in the report as well, specifically the impacts of new energy infrastructure.
4.3.2 Respondents highlighted the importance of mitigation through project planning and monitoring as well as through the reuse of existing infrastructure. A few respondents claimed that there are likely to be other environmental effects that have not been considered in the report, but which cannot yet be predicted.
4.3.3 While some respondents said that the predicted environmental effects were presented clearly in the report, and were consistent with recent research on climate change, others identified gaps in the effects provided. Some respondents said that the environmental effects of renewable energy sources, Carbon Capture and Storage (CCS) technologies and any other infrastructure required to meet the targets, will need to be considered further. They considered the possibility that negative environmental effects currently generated by traffic in one location could be replaced by negative effects from energy generation elsewhere, suggesting that a strategic approach may be required to monitor and address cumulative negative effects.
4.3.4 Several respondents referred to the inclusion of references to CCS in the report, and expressed both opposition to and support for its proposed use.
Scottish Government response
4.3.5 The SEA Environmental Report explored the environmental effects resulting from the strategic ambitions of the Bill and not as a result of potential specific mechanisms to deliver these. We note the comments received in this respect and will take into account comments on areas for consideration in future plans, programmes and strategies, as applicable.
4.4. Other comments on the Environmental Report
4.4.1 Some respondents commented on features of the report that they supported, including the emphasis on adaptation, the use of renewable energy technologies and the need for planning and policy alignment across sectors. Respondents often emphasised the importance of additional assessments as proposals are put in place, requesting that the principle for the development of a monitoring scheme should be embedded in the Bill. They said that this monitoring must consider the achievement of national policy objectives alongside the proposed targets, with sector-specific accounting and policies, and consultation on strategic issues.
4.4.2 Other comments that some respondents offered on the structure and context of the Report include:
- providing the views of statutory consultees in an appendix;
- making links with relevant UN Sustainable Development Goals;
- examining additional reasonable alternatives to the proposed targets, such as tighter interim targets;
- assessing the environmental effects of a range of scenarios for interim targets; and
- considering food production as its own category.
4.4.3 Although Question 12 was about the Environmental Report, some respondents expressed views on the predicted environmental effects of climate change more generally, emphasising the uncertainty in modelling any future climate change and encouraging the Scottish Government to prepare for worse case scenarios. Of those who commented directly on the Environmental Report, there was general agreement that the report gave an accurate assessment of these effects. In addition, some respondents provided suggestions to reduce specific sectoral emissions to address the effects of climate change.
4.4.4 Respondents and the SEA consultation authorities also provided a number of comments on mitigation and monitoring with the latter discussed in section 6 of this Post Adoption Statement. Regarding mitigation, comments received acknowledged that as the Bill set a strategic ambition and not a delivery mechanism, mitigation measures are difficult to envisage at this point. Respondents also noted the recognition of synergies identified between mitigation and adaptation and their role in securing a resilient low carbon society. Comments also included a request for outlining more detailed mitigation measures.
Scottish Government response
4.4.5 The provisions in the 2019 Act will now inform the preparation of a range of Scottish Government strategic documents, including but not limited to, an update to the 2018 Climate Change Plan.
4.4.6 In relation to the comments on adaptation, the Scottish Government recognises that whilst reducing emissions will be key to Scotland's fight against future climate change, we must also prepare for the changes which are already locked in. We are already seeing warming in Scotland, with more extreme weather events and rising sea levels. As a nation we must adapt to these changes. The 2019 Act does not make substantive changes to the statutory framework of the 2009 Act on climate change adaptation matters, as this is working well. In September 2019, we published our second 5-yearly statutory Climate Change Adaptation Programme under the 2009 Act, which is designed to deliver a step-change in collaboration and secure the benefits of a climate-ready and resilient nation. The new Programme sets out how we are responding to risks covering a range of global warming scenarios with around 170 policies and proposals across Scotland. The Programme is derived from the UN Sustainable Development Goals and Scotland's National Performance Framework.