Scotland's draft Climate Change Plan: 2026-2040: strategic environmental assessment - environmental report

2. Assessment approach

2.1. What is Strategic Environmental Assessment (SEA)?

2.1.1 SEA is a systematic method for considering the likely environmental effects of certain Plans, Programmes or Strategies. It identifies potential significant environmental effects and, where relevant, describes how negative effects can be avoided or reduced or where positive effects could be enhanced.

2.1.2 The Environmental Assessment (Scotland) Act 2005^[14] (‘the 2005 Act’) requires all qualifying policies, plans, programmes and strategies (referred to generally as ‘plans’) to undergo SEA. The 2005 Act requires that the environmental effects of a qualifying plan are assessed and the findings set out in an Environmental Report. The Environmental Report and the plan to which it relates must then be open for public consultation, providing an opportunity for the public to express their views on the proposals and assessment findings.

2.1.3 The CCP (2026-2040) is considered to fall under Section 5(4) of the 2005 Act and this Environmental Report has been prepared in accordance with the Act. The SEA process includes the following stages:

• Scoping: establishing significant environmental topics, setting the environmental baseline, developing the proposed method(s) and intended approach to the assessment, and setting out the proposed consultation period;
• Environmental Assessment: assessing the likely significant environmental effects of the proposed plan and any reasonable alternatives, and consulting on both the draft plan and Environmental Report;
• Post Adoption Statement: setting out how the assessment and the consultation results have been taken into account in the finalised plan;
• Monitoring: monitoring the significant environmental effects of the implementation of the plan.

2.2. Structure of the Environmental Report

2.2.1 This Environmental Report includes the following information:

• Section 1 introduces the CCP and sets out the relationship to other plans, programmes and strategies.
• Section 2 details the approach to the assessment.
• Section 3 describes the current baseline environmental conditions and environmental protection objectives.
• Section 4 presents the assessment findings and outlines potential mitigation.
• Section 5 presents the secondary, cumulative and synergistic effects.
• Section 6 sets out the monitoring arrangements

2.3. SEA activities to date

2.3.1 The CCP builds on the previous Climate Change Plan and subsequent update (CCPu), produced in 2018 and updated in 2020 to recognise the potential role the CCPu could play in supporting a green and resilient recovery from Covid-19, whilst aiming to achieve the GHG emissions reduction targets^[15]. Both the 2018 Climate Change Plan and the CCPu were supported by SEA Environmental Reports^[16],[17] which have been taken into account where relevant in undertaking this SEA. In addition, many of the policies and proposals for inclusion in the Waste sector package are also actions from Scotland’s Circular Economy and Waste Route Map to 2030, published in 2024, and have been subject to SEA during development.

2.3.2 A SEA Scoping Report was submitted to the SEA Gateway in September 2025. Comments were received from the SEA consultation authorities (Scottish Environment Protection Agency, NatureScot and Historic Environment Scotland) who were broadly content with the proposed approach. Where suggestions have been made for additional references to relevant legislation, plans, programmes and strategies these have been added into the Environmental Report. Where more detailed comments on the baseline have been received, these have been taken into account and used to provide an updated baseline section.

Scoping the environmental topics

2.3.3 The Scoping Report considered that all environmental topics should be scoped into the assessment due to the potential for effects to occur across all topics. This Environmental Report therefore considers the following SEA topics, and their inter-relationships:

• Air
• Biodiversity, flora and fauna
• Climatic factors
• Cultural heritage
• Landscape and geodiversity
• Material assets
• Population and Human Health
• Soil
• Water

2.4. Assessment methodology

2.4.1 This SEA was jointly undertaken by the Scottish Government SEA team and officials within the Scottish Government’s Directorate for Energy and Climate Change. The assessment provides an opportunity to consider the opportunities to further enhance any likely significant positive effects and to avoid or minimise any negative effects that may arise.

2.4.2 The assessment takes account of previous SEAs including the SEA Environmental Report of both the CCPu and the 2018 CCP. A broad narrative-style assessment has been undertaken in keeping with the strategic nature of the draft CCP.

2.4.3 The approach to the assessment was as follows:

• Previous relevant SEA Environmental Reports were reviewed alongside the development of the baseline, and new or continuing pressures and trends were identified.
• Policies and proposals contained in the draft CCP were grouped and assessed collectively under their respective sectoral outcomes, with a particular focus given to the proposed new and boosted policies and proposals developed since the previous CCPu. The findings for this stage of the assessment are set out in Appendix A, which outlines the predicted effects across a range of environmental receptors.
• Drawing on the findings from the first stage of assessment, the overall effects for each sector were determined. These have been set out in a narrative format in Section 4.
• Section 5 sets out the potential cumulative, synergistic and in-combination effects likely to arise across all of the sectors.

Assessing significance

2.4.4 The 2005 Act requires the Environmental Report to set out the likely significant environmental effects expected from the proposed plan. The following factors have been taken into account:

• The magnitude or scale of effects.
• The sensitivity of the receiving environment including existing known problems and potential effects on designated areas or landscapes.
• The likely probability, duration, frequency, reversibility, cumulative effects, transboundary effects, risks to human health or the environment, and the magnitude and spatial extent of the effects where known.

2.4.5 The Environmental Report aims to focus primarily on effects that are considered to be significant when considered in relation to the above criteria.

2.5. Mitigation and enhancement

2.5.1 The CCP sets out a series of climate change mitigation measures and the ambitions, policies and proposals to meet Scotland’s climate change statutory targets. They are also likely to have beneficial impacts for adapting to and improving resilience to the predicted effects of climate change.

2.5.2 Where negative and positive effects are identified through the SEA recommendations have been made, where possible, for both mitigation and enhancement measures respectively.

2.6. Consideration of reasonable alternatives

2.6.1 The 2005 Act requires the Environmental Report to identify and assess any reasonable alternatives to the plan or programme, taking into account its objectives and geographical scope.

2.6.2 The SEA must appraise not only the objectives, but reasonable alternatives to these. This implies that alternatives that are not reasonable do not need to be subject to appraisal. Part (b) of Regulation 14(2) notes that reasonable alternatives will take into account the objectives of the plan, as well as its geographical scope. Therefore, alternatives that do not meet the objectives of national policy are unlikely to be reasonable.

2.6.3 Consideration of alternatives was undertaken as the emerging plan developed. The extent to which alternatives for the CCP could be considered ‘reasonable’ was influenced by the legislative framework for the document. The context for reasonable alternatives is limited by the requirements to meet ambitious statutory climate change targets. Therefore, reasonable alternatives do not include consideration of a ‘do nothing’ scenario, as the CCP is a legislative requirement of The Climate Change (Scotland) Act 2009^[18].

2.6.4 Based on the current legislative context, and the declared climate emergency, it was identified that the current ambition can only be to achieve the maximum emissions reductions possible, reflected across all sectors based on current technical and practical limitations, and it was therefore concluded that no reasonable alternative could be identified. Possible mitigation and enhancement has, however, been considered for each CCP sector where relevant and applicable and the findings from this assessment are presented in Section 4.

2.7. Consideration of the guiding principles on the environment

2.7.1 The assessment process for the plan has included consideration of the guiding principles as set out in section 13(1) of the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021 (the Continuity Act)^[19]. The principles are as follows:

• The principle that protecting the environment should be integrated into the making of policies.
• The precautionary principle as it relates to the environment.
• The principle that preventative action should be taken to avert environmental damage.
• The principle that environmental damage should as a priority be rectified at source.
• The principle that the polluter should pay.

2.7.2 The Strategic Environmental Assessment process ensures the integration of environmental protection throughout policy development. During the assessment, potential significant environmental effects, both positive and negative, have been considered, and opportunities for avoiding or mitigating negative impacts while enhancing positive ones actively sought. This will help to inform future CCP updates where relevant and appropriate including any measures to avert environmental damage. In this way the assessment can help ensure that any resulting actions from the CCP are made in full knowledge of the likely effects on the environment as well as opportunities for avoiding or rectifying them.

2.8. Limitations and uncertainty

2.8.1 Schedule 3 of the 2005 Act sets out that Responsible Authorities should identify any difficulties encountered during the assessment process.

2.8.2 The policies and proposals have been developed progressively alongside the Environmental Report assessment process, which has therefore meant that assessment has concentrated on broad environmental impacts in line with the available level of detail.

2.8.3 There are varying levels of detail in relation to some of the policy actions described, which mean the scale of environmental effects may be unclear or difficult to assess with certainty.

2.8.4 Furthermore, the content of the draft CCP refers both to the continuation of current actions and the expansion and enhancement of these in some cases. Where outcomes/policies/actions relate to increased knowledge sharing, training, and partnership working, the scale of environmental effects achieved through these is challenging to assess.

2.8.5 Other limitations include the balance in the assessment of the role of other regulatory processes in mitigating/enhancing environmental effects.