4. Opinions expressed on the Environmental Report
4.1.1. This section sets out how the responses to the Environmental Report accompanying the consultation on the Scottish Climate Change Adaptation Programme 2019-2024 have been taken into account as the programme was finalised. The following three questions related to the Environmental Report:
- Q8. What are your views on the accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report?
- Q9. What are your views on the predicted environmental effects as set out in the Environmental Report?
- Q10. What are your views on the findings of the SEA and the proposals for mitigation and monitoring of the environmental effects set out in the Environmental Report?
4.1.2. Comments on the Environmental Report were received from a range of participants, including public and third sector bodies. These also included the three SEA statutory Consultation Authorities - Scottish Environment Protection Agency (SEPA), Scottish Natural Heritage (SNH) and Historic Environment Scotland (HES).
4.1.3. 43 responses were received to Question 8 with 33 providing a comment, while Questions 9 and 10 received 42 responses with 30 and 33 substantive comments respectively. Overall, the comments received were generally supportive of the assessment process and of the findings set out in the Environmental Report. The views and comments received have been summarised below alongside the Scottish Government's response to them.
4.2. Accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report
4.2.1. Just over half of the consultation participants (43 out of 73) responded to Question 8. Ten of these stated that they had no comment to make, or words to that effect, leaving 33 substantive responses for analysis. Two thirds (22 out 33) of these responses conveyed general agreement with the accuracy and/or scope of the information, six participants made a general comment which did not express a clear view, four responses focused on aspects for further consideration, and another participant described their view as 'unsure'.
4.2.2. Positive reflections on the scope and accuracy varied, according to the respondent. Some shared general comments and observations; others highlighted specific aspects of the SEA they welcomed. Examples include comments on the alignment with the SCCAP outcomes, its extensive nature, and references to the considerable work undertaken in the development of the SEA. Some respondents confirmed their agreement without elaboration.
4.2.3. Just under a third of the respondents who provided a substantive response to question 8 (10 out of 33) indicated that they agreed with the overall accuracy of the report, but felt the scope was too broad or asked for greater focus on a specific issue. Two participants called for more reference to the urgent need to tackle climate change.
4.2.4. Respondents' suggestions of issues for greater coverage within the document varied, according to their specific area of interest or expertise. Some examples included further consideration of specific topics associated with biodiversity, human health and material assets.
4.2.5. The Statutory SEA Consultation Authorities also provided a number of comments relating to the environmental baseline, including a request for clarity on what was considered under the topic of climatic factors. They also recommended that future reviews of the SCCAP consider the topic of climatic factors in its wider sense and that SEA objectives in relation to the causes of climate change are included in future assessments.
Scottish Government response
4.2.6. We welcome the comments received. Where amendments or additions to the environmental baseline were suggested these have been noted and will be taken into account in future assessments where relevant. Where additional information has been suggested we are satisfied that this would not alter the assessment findings.
4.2.7. With reference to comments regarding consideration under the climatic factors topic specifically, the information used focused on the predicted likely effects of climate change and associated key pressures for Scotland. This approach was considered appropriate because of the focus of the programme on climate change adaptation specifically. The Scottish Government recognise the important links between climate change adaptation and mitigation. The programme's introduction recognises this in saying that Climate Change Adaptation and mitigation are intrinsically linked. Future iterations of the programme will consider developing these links further.
4.3. Predicted environmental effects as set out in the Environmental Report
4.3.1. The SEA Consultation Authorities and respondents generally agreed with the predicted environmental effects set out in the Environmental Report. Just over half of the consultation participants (42 out of 73) responded to Question 9. Twelve of these stated that they had no comment to make, or words to that effect, leaving 30 substantive responses for analysis. Over half (18 out 30) of these responses conveyed general agreement with the predicted impacts, and eight participants made a neutral or general comment which did not convey a clear view. Themes included agreement with the estimation of impact and disagreement or uncertainty concerning the predicted effects.
4.3.2. Over half of the substantive responses included comments indicating agreement that the predicted environmental impacts identified were reasonable. Four of these did not elaborate further, and five made additional positive comments about the scope, high-level approach, focus on specific issues or potential for the programme to achieve significant positive impact.
4.3.3. Four respondents made further comments on particular outcomes, including suggestions about widening or enhancing the scope to include effects on historical elements of the environment, mental wellbeing, catchment management and water supplies in rural areas and national food production, for example.
4.3.4. One participant disagreed with the predicted effects on the basis of them being too general, and another participant described their view as 'unsure', explaining that they did not feel mitigating actions were clear. Two respondents called for more urgency, and one suggested the impacts are underestimated but did not explain these comments.
4.3.5. One of the statutory SEA Consultation Authorities requested clarity on the predicted significant positive effects on climatic factors commenting that effects are limited to the context of adaptation and not the causes of climate change. Furthermore, they commented that predicted effects on SEA topics associated with adaptation behaviours are also largely limited to the context of adaptation to climate change.
Scottish Government response
4.3.6. The SEA identified likely significant positive effects across all SEA topics as a result of adaptation measures and accompanying plans which aim to maximise environmental benefits.
4.3.7. Taking account of the high level nature of the programme, the assessment identified an inherent degree of uncertainty regarding environmental impacts that may arise as a result of future actions undertaken to support adaptation outcomes. This includes a level of uncertainty and a potential for mixed/uncertain effects arising at the local level. This approach was considered proportionate to the strategic nature of the programme which set out a high level framework drawing together existing Scottish Government polices relating to climate change adaption. With regards to comments suggesting that the assessment could have given more consideration to effects contributing to the causes of climate change rather than limiting these to adaptation specifically, as indicated previously we consider the overall assessment approach to be in keeping with the focus of the programme.
4.4. Findings of the SEA and the proposals for mitigation and monitoring of the environmental effects set out in the Environmental Report
4.4.1. There were 42 responses to Question 10. Nine of these were 'no comment' or similar, leaving 33 substantive comments for analysis. Many of the comments provided in response to question 10 reiterated participants' responses to previous questions; reflecting their overall views on aspects of the draft programme.
Findings of the SEA
4.4.2. The majority view was of general agreement with the findings of the SEA. Eighteen participants indicated agreement with the findings, frequently highlighting elements that will support the achievement of outcomes such as the regulatory controls in place and the monitoring framework; one anticipated the National Forum on Adaptation will play a role in ensuring the Programme stays on track. Another highlighted their particular support for the opportunities for enhancement described within the document. Nine participants made general or neutral descriptive comments.
4.4.3. Eight participants disagreed with the findings, with varying explanations in their comments. Roughly half of this group (five respondents) made high-level observations. These included a general comment that issues had not been fully addressed, a view that 'more needs to be done', a call for the SEA to be more strategic with targets, actions and robust data analysis specifically. Another suggested that there should be clear links between the goals and identification of climate change risk. This respondent also felt there was an insufficient expression of the urgency of change required and mentioned an over-emphasis of and high expectations for the ability of behaviour change to effect impact.
4.4.4. Three disagreed on the basis that a particular topic needed greater prominence: one felt flooding should be reflected as the biggest climate change risk, one noted their disagreement on the basis that culture, and culture change are not addressed, another expressed a desire for the focus to be on the natural environment as the 'organising factor'.
Proposals for mitigation
4.4.5. Mixed comments on mitigation were received. Six respondents commented on mitigation. Three of these respondents shared general or descriptive comments in overall support of the approach and three suggested that more work is needed. Some felt the SEA should include greater coverage of mitigation measures, demonstrating how far identified mitigation measures have influenced the draft programme and how mitigation measures will be implemented. One participant suggested that a case study would be a valuable addition.
4.4.6. The statutory Consultation Authorities provided comments on mitigation and enhancement. These included a comment that the Environmental Report was not clear about how identified mitigation measures and enhancement opportunities have been or will be progressed. The Consultation Authorities also sought clarification on how mitigation identified within the Environmental Report has influenced the final Programme. Furthermore, a suggestion that where mitigation or enhancement proposals have not resulted in the modification of the final Programme, provisions for these as well as their timing and responsible body should be outlined in the Post Adoption Statement. Finally, a suggestion that project level regulatory controls, such as Environmental Impact Assessments, need to be augmented with more specific mitigation was included.
Monitoring of environmental effects
4.4.7. The majority of respondents were satisfied with the monitoring approach outlined. Over a third of the respondents who provided a substantive response to question 10 (14 participants) commented on monitoring, eight of whom were satisfied with the approach outlined. Three reiterated previous comments on the make-up or functioning of the governance body. These included suggestions that it should consist of non-governmental representatives from a range of sectors, take a multi-agency approach and report to Parliament through the Environment, Climate Change and Land Reform Committee.
4.4.8. Other comments on communication and suggested additions to the SEA were also received. These included six comments on communication which mostly emphasised the need for wider publicity of the urgency of the climate situation to encourage behaviour change and adaptation action. Suggestions included placing climate change on curricula, legislation and introducing incentives to bring about change. Suggested channels such as Adaptation Scotland's website were also identified. Specific additions to the SEA were also suggested and included a case study to illustrate the benefits of mitigation and the need to monitor urban greenspace and reverse its decline.
4.4.9. The statutory Consultation Authorities' commented on reasonable alternatives and the possibility of a further iteration of the Environmental Report. With regards to reasonable alternatives, clarity was requested on whether reasonable alternatives within the seven adaptation outcomes were considered and if the consideration of high level alternatives (i.e. risk-led, sector priorities) identified prior to the preparation of SCCAP2 included environmental considerations. With regards to the possibility of a further iteration of the Environmental Report, one of the Consultation Authorities inquired as to whether the more detailed chapters for the final SCCAP2 could warrant a further iteration of the Environmental Report.
Scottish Government response
4.4.10. Comments have been noted and will be taken into account in future SEAs where relevant. Where suggestions regarding the content of the assessment have been made, we are satisfied that they would not alter the overall findings of the assessment.
In response to the comments received on how mitigation measures identified in the Environmental Report will be progressed, it is considered that the mitigation envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment in implementing the Programme as set out in the Environmental Report is proportionate and in keeping with the content of the programme. Where future actions have the potential to result in uncertain/mixed adverse effects, further consideration should be given to opportunities to mitigate any such effects at project level. In response to comments received on how enhancement opportunities identified in the Environmental Report will be progressed, the content of the finalised programme was expanded upon in response to both the consultation responses and the opportunities identified in the Environmental Report. To obtain the maximum environmental benefits for Outcome 1, content was further developed to focus on support for communities that are recognised as being more vulnerable to negative impacts of climate change. For example, the inclusion of the National Flood Risk Assessment (NFRA) 2018 under this outcome recognises vulnerable communities through its designation of areas in Scotland that are vulnerable due to current and future flood risk to people, the environment, cultural heritage and economic activity.
4.4.11. Comments received on monitoring are considered in Section 6 below.
4.4.12. In response to comments received on reasonable alternatives, as the Programme developed the assessment approach was refined to focus on the seven adaptation outcomes. This approach was considered proportionate to the high level nature of the Programme itself. We note the comments regarding the possibility of a further iteration of the ER to reflect the expansion of the finalised programme following consultation. We consider that the focus of the assessment on the seven outcomes was proportionate to and in keeping with the strategic nature of the programme. Whilst it is recognised that the additional content provides further detail of actions that can support the delivery of the seven high level adaptation outcomes, we are satisfied that the further detail included does not alter the overall findings of the assessment as set out in the Environmental Report. Any further proposals, more detailed plans, programmes or strategies to give effect to the finalised programme would themselves require consideration under the Environmental Assessment (Scotland) Act 2005.