Chapter 2 - Approach to the Assessment
2.1 The methodology set out in this chapter describes the approach that has been taken to the SEA of the CCPu to date.
2.2 The SEA process began in early 2020 with the production of a Screening/Scoping Report for the update to the CCP. The Screening/Scoping Report outlined the environmental baseline for the plan area as well as the policy context and key sustainability issues. It was considered that all environmental topics should be scoped into the SEA due to the potential for likely significant effects to occur across all topics:
- Climatic Factors / Emissions Reduction
- Population and Human Health
- Biodiversity, Flora and Fauna
- Cultural Heritage and the Historic Environment
- Material Assets (Waste, Energy, Transport and Land Use).
2.3 Due to the nature of the update and the hierarchy in which it sits, the assessment has been undertaken at the strategic, national level. The approach to the assessment reflects the national status of the update and the consequently high-level nature of the assessment it requires.
2.4 As noted previously, the draft update will seek to build on and complement the existing CCP published in February 2018. Reflecting the ambitious nature of the plan, it was anticipated that achieving the GHG emissions targets would require maximum possible emissions savings (whilst ensuring that nobody is left behind, reflecting a just transition) across the sectors. The assessment has considered policies which are new, boosted or maintained.
SEA of Reasonable Alternatives
2.5 Part 14(2) of the 2005 Act requires that:
“The report shall identify, describe and evaluate the likely significant effects on the environment of implementing (a) the plan or programme; and (b) reasonable alternatives to the plan or programme, taking into account the objectives and the geographical scope of the Plan or Programme”.
2.6 The context for the alternatives is limited by the requirement to meet the ambitious climate change targets. The 2005 Act requires that the Scottish Government also identify, describe and evaluate the likely significant effects on the environment of any reasonable alternatives to the CCPu. This section outlines what has been assessed, including the reasonable alternatives that have been considered.
2.7 In considering what a “reasonable” alternative is, the Scottish Government’s commitment to decarbonise the whole energy system and tackle climate change has been taken into account. The CCP is being updated to reflect the increased ambition of the new targets set in the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019.
2.8 The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, which amends the Climate Change (Scotland) Act 2009, sets targets to reduce Scotland's emissions of all greenhouse gases to net-zero by 2045 at the latest, with interim targets for reductions of at least 56% by 2020, 75% by 2030, 90% by 2040. To help ensure delivery of the long-term targets, Scotland’s climate change legislation also includes annual targets for every year to net-zero. Scotland’s target of net-zero emissions by 2045, five years ahead of the UK, is firmly based on what the independent Committee on Climate Change (CCC) advise is the limit of what can currently be achieved. The 2019 Act also embeds the principles of a Just Transition, which means reducing emissions in a way which tackles inequality and promotes fair work, at the heart of Scotland’s approach to reaching net-zero.
2.9 In considering potential reasonable alternatives to be included in the assessment the approach to alternatives for the 2017 Environmental Report for the Scottish Government Climate Change Plan was considered. The previous assessment was based on two broad scenarios for emissions reduction in Scotland: a Central Scenario and High Ambition Scenario. These scenarios illustrated broad indicative packages of measures that could be used to meet varying overall levels of emission reduction. However, 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. The previous approach to alternatives is therefore no longer reasonable in the current legislative context.
2.10 A further option of assessing those policies and proposals in the CCPu which were identified as ‘maintained’ and assessing these as ‘boosted’ was considered. Review of the ‘maintained’ policies and proposals identified that these were policies for which it is not reasonable to ‘boost’ due to the nature of the text. For example, continuing a partnership approach, or undertaking research to improve the evidence base for a sector are actions for which undertaking more action or action on an accelerated timescale is not realistic. This further reflects the legislative context for the CCPu (noting that the CCPu document itself is non-statutory), and the need for the update to achieve maximum emissions reduction based on current technical and practical limitations.
2.11 The outcomes, policies and proposals have been appraised against the SEA topics outlined above, with scores being attributed to indicate likely sustainability effects on each objective. In line with the SEA of the current CCP, effects are identified as either positive, negative, mixed or neutral.
Table 2.1: Key to symbols and colour coding
+ Effects are positive overall for that environmental topic
0 Effects are neutral overall for that environmental topic
- Effects are negative overall for that environmental topic
+/- Effects are mixed (positive/negative) overall for that environmental topic
2.12 The assessment framework is structured around each SEA topic and includes combined justification text for the scores.
2.13 The approach to the assessment was as follows:
- Assessment matrices were developed for each sector considered in the draft Plan. These tables set out the potential for impacts across a range of environmental receptors for each boosted or new policy and proposal included within that sector (see Appendix B). These matrices reflect the drat SEA objectives for NPF4.
- Drawing on the findings from the first stage of assessment, summary tables show the combined effect of the individual polices and proposals. Findings are displayed for each sector included in the draft Plan (Chapter 4).
- This is followed by narrative text (Chapter 4) which sets out the consideration of potential cumulative, synergistic and in-combination effects likely to arise from boosted and new policies and proposals, the maintained policies, and the wider policy context across all of the sectors.
2.14 Schedule 2 of the 2005 Act identifies criteria for determining the likely significance of effects on the environment (see Table 2.2) which will be reflected in the approach to scoring set out in the assessment.
Table 2.2: Approach to scoring
(a) the probability, duration, frequency and reversibility of the effects
Low – Not likely to have an effect
High – Highly likely to have an effect
Short-term – 0-1 years
Medium-term – 1-2 years (up to the end of strategy period)
Long-term – 2+ years (beyond the end of the strategy period)
Continual; defined by number of occurrences; or intermittent
Whether the effect can be reversed (i.e. can the receptor return to baseline condition) without significant intervention
(b) the cumulative nature of the effects
Where several options each have insignificant effects but together have a significant or combined effect. This includes synergistic effects, which is when effects interact to produce a total effect greater than the sum of the individual effects.
(c) the transboundary nature of the effects
Effects beyond Scotland’s boundary.
(d) the risks to human health or the environment
Whether the impact of the effect would present a risk for people and the environment.
(e) the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected)
High – High proportion of the receptor affected
Low – Low proportion of the receptor affected
National/Transboundary – Effects on Scotland or England
International – Effects extending to the UK or beyond
(f) the value and vulnerability of the area likely to be affected due to:
(i) special natural characteristics or cultural heritage
(ii) exceeded environmental quality standards or limit values
(iii) intensive land-use
Impact of the effect on the value or condition of the existing area.
(g) the effects on areas or landscapes which have a recognised national, Community or international protection status
Impacts on areas with national, community or international protection.
Difficulties Encountered and Data Limitations
2.15 Schedule 3 of the 2005 Act states that Responsible Authorities should identify any difficulties encountered during the assessment process.
2.16 The development of the policies and proposals has been an ongoing process alongside the assessment and this evolution has required the assessment to focus on high level environmental impacts to reflect the level of detail available on the policies and proposals.
2.17 Key limitations of the assessment process relate to information on the likely scale and extent of development brought about by some of the policies and proposals. Other limitations include the balance in the assessment of the role of other regulatory processes in mitigating environmental effects. This is particularly an issue where there is uncertainty on the scale of development, particularly between different sectors.
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