7 Comments on the Environmental Report
7.1.1 The five questions used in the consultation to help frame responses on the Environmental Report are provided below. Corresponding views and comments received have been summarised in the sections that follow.
1. What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process?
2. Should any additional evidence sources be used in the Environmental Report? Please provide details.
3. What are your views on the predicted environmental effects as set out in the Environmental Report?
4. Do you agree with the conclusions and recommendations set out in the Environmental Report?
5. Please provide any other further comments you have on the Environmental Report.
7.2 What are your views on the evidence set out in the Environmental Report?
7.2.1 76 participants replied to this question. Substantive responses to the question came from a mixture of organisations (28 responses) and individuals (27 responses). There were positive responses from approximately three quarters of the organisations that responded. Some of these respondentssuggested additions to consider, for example opportunities, issues or more context and/or provision of baseline data, or changes intended to give greater emphasis to certain topics (such as the importance of forests and woodlands in relation to Scotland's cultural and historic environment, links between the strategy and the UKFS, and more mention of forestry activity that damages the environment). One response called for more detail about how the evidence presented had been used to inform the assessment process. Somestakeholders commented that the biodiversity topic was missing from the Table 4 on page 37 of the Environmental Report.
7.2.2 The Scottish Government welcomes and notes this feedback. The baseline evidence was presented in Appendices C and D of the Environmental Report; showing the state of the current environment with some areas discussed further in the narrative of Section 3. The baseline evidence was used to inform the assessment of each priority and where interactions between the priorities and baseline receptors were identified, these were drawn out in greater detail. It was considered, given the high level nature of the strategy, that an assessment of the draft policy against each baseline indicator would be out of keeping with the scope and level of detail of the strategy.
7.2.3 Section 3.3 of the Environmental Report set out the likely evolution of the environment without implementation of the strategy by considering the current state of the environment, past trends detailed in Appendices C and D and the environmental opportunities/issues associated with the Forestry Strategy.
7.2.4 Similarly, the potential interaction of key effects of other plans, programmes and strategies with the Forestry Strategy were considered at a high level reflecting the strategic nature of the assessment and the likely environmental effects.
7.2.5 The evidence base was developed and refined in line with comments received at scoping stage in recognition of the inherent relationships between certain topics such as landscapes and historic assets. The historic environment was scoped into the assessment. However in light of the feedback from the SEA Consultation Authorities, changes have since been made to the Strategy to more clearly set out the need to protect and conserve important historic monuments and features.
7.2.6 The UKFS Compliance Procedure was launched in October 2018. This is a new process that will provide evidence on how the Scottish Government will ensure that relevant actions taken to support the delivery of the Strategy will meet the UKFS requirements. This formal process was established to ensure that breaches of the UKFS are properly dealt with, and that standards in sustainable forestry are maintained. It details the corrective actions or sanctions that will be sought from owners or their agents, sets out the process of investigation and explains the laddered approach to the actions that the Scottish Government will take. These procedures will apply to all Forestry Commission Scotland (Scottish Government) forestry approvals and consents (namely Forest Plans, Felling Licenses, Forestry Grant Scheme contracts, and Environmental Impact Assessment (EIA) consented operations), as well as illegal felling and non-consented EIA operations. They will not replace existing procedures, but will instead be undertaken alongside them and where legal procedures do not exist. Non-compliance with the UKFS could result in a warning letter with mitigation measures or the suspension or revocation of permissions. Further details of the UKFS Compliance Procedures can be found online.
7.2.7 The omission of biodiversity as a topic from Table 4 on page 37 relates to a drafting error in that table and does not affect the overall assessment which included full consideration of, and reporting on the biodiversity topic.
7.3 Should any additional evidence sources be used in the Environmental Report?
7.3.1 53 participants responded to this question. Many respondents (27 individuals and 20 organisations) including the consultation authorities, offered substantive comments on the need for additional evidence sources in the SEA. The comments were varied; and each respondent referenced a different source or type of evidence. Comments included specific sources for review, consultation with specific stakeholder groups, more evidence and measurement of specific SEA topics and effects.
7.3.2 The Scottish Government is content with the level of detail included within the Environmental Report. Whilst the comments received and suggested evidence sources are not considered to alter the results of the assessment, where applicable, they will be noted for future reference.
7.4 What are your views on the predicted environmental effects?
7.4.1 This question received the largest number of responses on the SEA with 81 comments. A small number of participants agreed with the predicted effects. Many participants described potential impacts from the implementation of the draft strategy that they felt could be given a higher profile in the SEA. These varied according to the respondent and included: historic environment considerations, wider positive impacts of community ownership and management of forests; improved landscapes, provision of employment in rural areas; value of forestry for natural flood catchment; and, the contribution of non-native species to natural capital. Approximately a quarter of the respondents to this question felt there could have been greater consideration of the negative impacts of the expansion of forests, with specific mention of potential damage in relation to habitats and biodiversity, water quality and open landscapes. One respondent disagreed with conclusions on afforestation and a few felt that consideration of afforestation should have been expanded.
7.4.2 A few respondents discussed other factors that may affect some of the predicted effects. Comments received were varied and concerned different aspects of the assessment, for example, threats to new planting from deer, and on the importance of forests and woodlands in relation to the historic environment.
7.4.3 Other comments included suggestions that the high-level nature of the strategy impeded the ability to assess whether or not the predicted effects were likely. Some respondents shared their suggestions on which effects should be prioritised. Two participants suggested that they would like to see a range of alternative scenarios presented in the SEA; one asked for more detail about the SEA assessment process and on the mitigation of residual effects. Another respondent sought further information and a commitment on how positive impacts will be achieved and negative impacts mitigated via implementation of the strategy; suggesting that the Environmental Report should identify those areas within the future action plan on which further assessment work should focus.
7.4.4 Given the high-level nature of the strategy, the Scottish Government considers that the assessment of effects was pitched at an appropriate level. Comments regarding mitigation have been noted and will help inform the strategy implementation process. Comments regarding implementation and monitoring are dealt with in section 9.
7.5 Do you agree with the conclusions and recommendations set out in the Environmental Report?
7.5.1 67 participants responded to this question. Just over half said they agreed with the conclusions and recommendations in the SEA. There were also some calls for more detail in the overall strategy and the SEA, these included: requests for greater consideration of an issue of particular interest to the respondent; calls for greater consideration of the potential negative impacts of the strategy, particularly in relation to habitat and biodiversity but also on the historic environment; and suggestions of alternative conclusions. A small number of respondents disagreed with assumptions and conclusions made in the SEA. These included concerns raised by the SEA Consultation Authorities in relation to ensuring compliance with the UKFS and the relationship between the Strategy and the UKFS. The Consultation Authorities also suggested that mitigation measures could be enhanced and proposals on next steps be better developed.
7.5.2 The Scottish Government is content with the level and scope of the assessment and believes it to be a proportionate assessment of all the SEA topics with conclusions and recommendations clearly noted within the report. The Strategy does not set out the actions which will be required to deliver the strategy and this will require action across a range of private and public partners which includes the Scottish Government, its agencies and other public authorities. Where applicable, the plans and programmes associated with this activity will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act 2005.
7.5.3 Section 7.2 outlines how concerns around the historic environment and the links between the Strategy and the UKFS were addressed in the final Strategy, and section 9 discusses monitoring and implementation.
7.6 Please provide any further comments you have on the Environmental Report
7.6.1 A total of 55 participants responded to this question. Of these, 27 respondents provided substantive additional comments on the Environmental Report, typically reiterating points made in response to earlier questions. The SEA Consultation Authorities also called for: greater recognition of Scotland's historic environment in the Strategy and SEA; indicators to be developed and monitored in relation to heritage assets and cultural aspects of the landscape; the Strategy to be monitored widely against its impact on the environment, not just in relation to woodland cover; more detail to be provided on how environmental effects were considered during the Strategy's development since no reasonable alternatives were identified; and the opportunity to be involved in developing the next steps of the Strategy.
7.6.2 Other points included comments about the SEA document, for example in relation to its length and format; these varied from descriptions of finding it useful, to suggesting it was too long, to asking for inclusion of a direct link to the SEA within the strategy and other presentational considerations. There were also questions raised about specific matters of forestry practice or the baseline evidence.
7.6.3 The Scottish Government is content with the level of detail and extent of assessment in relation to the high level nature of the strategy. Detail of how comments on historic environment have been addressed is provided in section 7.2. Comments made in relation to alternatives are discussed in section 8 and monitoring is covered in section 9 of this report. 8 Reasons for selecting the Forestry Strategy as adopted
Email: Bob Frost