Air Departure Tax: consultations and environmental report
Consultations relating to our policy for an overall 50% Air Departure Tax (ADT) reduction by the end of the current session of Parliament. Includes a Strategic Environmental Assessment (SEA).
Consultation Two: An assessment of the likely significant environmental effects ( SEA Environmental Report) - Part One
Introduction
The following paragraphs set out a summary of the Strategic Environmental Assessment undertaken on the Scottish Government's policy for an overall 50% reduction in Air Departure Tax by the end of the current session of the Scottish Parliament. This includes information on how the assessment process was undertaken and the main findings and recommendations.
This summary is intended as an easy to read overview of the full assessment which can be found in Part Two of this report. Part Two sets out detailed information on the assessment process, including how the assessment was undertaken and the evidence used to inform the assessment process.
Brief description of the policy
The Scottish Government aims to reduce the overall burden of Air Departure Tax by 50% by the end of the current session of the Scottish Parliament. Important decisions have yet to be taken on how the overall 50% reduction could be delivered, including how the reduction will be distributed, across tax bands ( e.g. short-haul and long-haul flights) and tax rates. It is intended that responses to this consultation will help shape the tax bands and tax rate amounts which will be set out in secondary legislation in the autumn.
How will the preferred policy option sit within the wider context of Scottish Government policies and ambitions?
Scotland's Economic Strategy sets out ambitions to create a more cohesive and resilient economy that improves opportunities for business and the people of Scotland alike, based upon increasing competitiveness and tackling inequality. The importance of transport infrastructure is also set out in a number of publications such as Scotland's Infrastructure Investment Plan, National Planning Framework 3 and Scotland's National Transport Strategy.
Once developed, the legislative proposals for Air Departure Tax will also sit within the context of Scottish Government policies for meeting ambitious statutory targets for the reduction of greenhouse gas emissions, as set by the Climate Change (Scotland) Act 2009. In January 2017, the draft Climate Change Plan: the draft Third Report on Policies and Proposals 2017-2032 was published for parliamentary scrutiny. This builds on previous reports and explores options for sectors across the economy to reduce Scotland's greenhouse gas emissions. Additionally, the Scottish Government has confirmed its intention to bring forward a new Climate Change Bill to establish a new and more testing 2020 emissions target.
What is Strategic Environmental Assessment?
In Scotland, public bodies are required to assess, consult and monitor the likely impacts of their plans, programmes and strategies on the environment. This process is known as Strategic Environmental Assessment. Further guidance on Strategic Environmental Assessment, the assessment process, including statutory requirements, is available on the Scottish Government website.
Strategic Environmental Assessment is a means to judge the likely impact of a public plan on the environment and to seek ways to minimise that effect, if it is likely to be significant, by:
- systematically assessing and monitoring the significant environmental effects of plans, programmes and strategies;
- ensuring that expertise and views are sought throughout the process from Scottish Natural Heritage, the Scottish Environment Protection Agency and Historic Environment Scotland; and,
- providing an opportunity for public participation in the decision making process, including a requirement to provide a statement as to how these opinions have been taken into account (a "Post Adoption Statement").
At the screening and scoping stage views were sought from the three Statutory Consultation Authorities. As a matter of good practice and in the interest of transparency, public consultation was also undertaken at this stage. The Screening and Scoping Report was published for consultation on 14 March 2016 and set out a range of information, including proposals on how the assessment would be taken forward.
How was the assessment undertaken?
As noted above, the Strategic Environmental Assessment process started with the production of a Screening and Scoping Report that was issued for public consultation in March 2016. Views were sought at this early stage to help inform the assessment process and ensure the assessment proceeded with an effective evidence base, informed by key stakeholders, organisations and individuals.
Following this initial period of consultation, the assessment builds on the work set out in the Screening and Scoping Report and has been informed by the comments received. Further information on the assessment process is set out below under relevant headings.
The identification of likely effects and development of key assumptions
Early in the assessment process it was considered that there was the potential for the proposed policy - to reduce the overall tax burden of Air Departure Tax by 50% - to have a range of environmental effects. Furthermore, it was noted that some of the environmental effects considered likely to arise would occur at altitude and were therefore likely to be experienced over a larger geographical envelope; others would be felt more at a local level. As such, it was proposed that the assessment would consider the potential effects at differing geographical scales.
To better establish the environmental effects of a 50% reduction in the overall tax burden, three key assumptions were used in the assessment. These are set out below. The assumptions were developed by drawing on research undertaken by Transport Scotland and informed through discussions with the Scottish Government's Air Departure Tax stakeholder forum, the Consultation Authorities, and were subject to wide stakeholder engagement through public consultation at screening and scoping stage.
It is envisaged that a range of different pathways could be applied to meet the 50% reduction in the overall tax burden. Illustrative scenarios have therefore been included in the assessment process to help frame the discussion on the likely environmental impacts of the preferred policy option, and to inform consideration of how the different pathways to achieve an overall 50% reduction could influence these impacts. This has included the consideration of applying the proposed 50% reduction in the overall Air Departure Tax burden equally to all flight types or applying the tax reduction through a sliding scale approach. For example, applying a zero tax charge to all short-haul flights and maintaining the tax charged on long-haul flights at current UK Air Passenger Duty levels, or vice versa.
Key assumptions
1: The proposal to reduce Air Departure Tax in Scotland will lead to an increase in the overall number of flights and could potentially create opportunities for new routes to be created.
2: An increase in flight numbers will lead to an increase in overall greenhouse gas emissions ( CO 2 and non- CO 2 emissions) in the short-term, even with advances in technology.
3: An increase in passenger and flight numbers will place increased pressure on existing airport and interconnecting infrastructure.
Consideration of Reasonable Alternatives
It is a requirement when undertaking a Strategic Environmental Assessment that consideration is given to the potential for significant environmental effects of reasonable alternatives to the plan, programme or strategy being assessed. The assessment considered "no reduction in the overall tax burden of Air Departure Tax compared to the overall tax burden of UK Air Passenger Duty" as a reasonable alternative. It is considered that this represents a "like for like" approach as the tax rate amounts would remain the same as that currently set under UK Air Passenger Duty. Under this approach, it is considered that activity in the sector would likely continue on the current predicted path.
It is also a requirement that the assessment sets out information on how the environment will change in the absence of the plan, programme or strategy. Many of the environmental trends identified as likely to be affected by the policy proposals are also considered likely to continue in the absence of the preferred policy option. For example, it is considered that greenhouse gas emissions and pressure placed on infrastructure would likely remain consistent with current levels of growth in the industry in the absence of the preferred policy option. As discussed above, it is considered that the reasonable alternative represents a like for like approach as the tax rate amounts would remain the same and, as such, activity in the sector would likely continue on the current path as predicted. For the purposes of this assessment, it is considered that the assessment findings concerning the impacts likely to arise from the reasonable alternative can also be considered to apply to the evolution of the baseline in the absence of the policy.
Consideration of current and future work to reduce emissions
Across the aviation industry there are a number of goals and commitments that have been made to improve efficiency and reduce emissions. Future global measures have also been developed and agreed. Additionally, developments in aircraft technology and engine efficiency, alongside airspace management, can improve performance and reduce the impacts from aviation.
Furthermore, the impact of some of the above measures will extend beyond helping to reduce emissions and can have wider benefits, for example, reducing air pollutants or noise. Some efficiency measures may also lead to airports being able to carry more passengers within their existing infrastructure, reducing pressure to expand.
The above factors have been taken into account during the assessment process.
Limitations experienced in the assessment process
Research work has been undertaken by Transport Scotland in 2017 to estimate the greenhouse gas emissions of a 50% reduction in Air Departure Tax, and updates similar research undertaken in 2014. This research has been used to inform this Strategic Environmental Assessment, including the development of key assumptions (further information on this research can be found in Part Two of this Report).
A number of assumptions were used in these research projects, for example a direct relationship between the number of passengers and the estimated amount of emissions was assumed. It is however noted that there a number of unknown factors were discovered in taking forward the research, such as the response to the reduced tax in the distribution of passengers between domestic and international flights.
Other limitations experienced during the Strategic Environmental Assessment process concern the impacts on overall emissions that may arise as a result of potential changes in the way people travel. It is not within the scope of this assessment to undertake the modelling work that would be required to examine the impact on overall emissions to an acceptable level, should a modal shift arise.
Finally, there are uncertainties surrounding the outcome of the Brexit negotiations which will have implications for the future of the UK's and Scotland's continued participation in the EU Emissions Trading Scheme. This is currently the main mechanism for delivering emissions reduction from international aviation.
What are the environmental impacts of aviation?
In 2014, transport, including international aviation and shipping, was the second highest source of Scottish greenhouse gas emissions after the energy supply sector. Passenger numbers have also increased, with over 25 million air terminal passengers using Scottish airports in 2015. Four of Scotland's main airports, Edinburgh, Glasgow, Aberdeen and Inverness accounted for the majority of passenger numbers in 2015. There are also many regional airports spread across the country, many servicing remote areas.
Aircraft emit a range of greenhouse gases throughout different stages of flight and are fairly unique in that some of these gases are emitted into the higher levels of the atmosphere. There are many factors that affect the amount of emissions during flight. Some of these are within the ability of the airline to manage, such as operational measures; others are not, for example the weather.
Certain emissions from aviation, though not direct greenhouse gas emissions, can also contribute towards climate change. The warming and cooling effects of these emissions arise as a direct result of the height at which they are emitted. The scale of the impact these emissions can have on climate change can also be greater as a result of the high altitudes in which they are emitted. This is known as the multiplier effect.
Closer to the ground, airport related operations also contribute to climate change, for example passengers and workers travelling to and from the airport, ground support vehicles and airport buildings.
Aviation can also lead to pressure on local air quality and to concerns regarding noise exposure. Aircraft noise is generated by both the engine and the airframe. Noise during activities such as take-off and landing is the most clear, however other activities such as from taxiing aircrafts and airport vehicular traffic also generate noise. Additionally, nose impacts can also arise through increased traffic to and from airports, and from construction activities. Noise can lead to a number of impacts on human health; for example sleep disturbance, fatigue and annoyance. Noise disturbance and the impact of this is a complex area, and whilst studies have demonstrated the links between noise disturbance and stress, the relationship between noise exposure and their potential adverse effects on people is of variable quality.
Air pollution can also impact on human health, both in the short and long-term, and those with pre-existing health issues may be more vulnerable to poor air quality over long time periods. Air pollution can also have wider harmful effects on the environment. Whilst air quality has improved over the last few decades, there are some towns and cities where air quality has been identified as a concern. Aircraft engines, support vehicles and equipment, and vehicles accessing the airport are the main aviation sources of emissions that affect air quality.
Many airport masterplans consider that existing infrastructure would continue to accommodate current levels of passenger numbers; however, new development may be required in the future. Additionally, an increase in travel to and from these transport hubs may also arise due to increased passenger and flight numbers. The development of new infrastructure can lead to a number of environmental impacts, for example loss of habitat and noise disturbance from construction activities.
Airports are also significant users of resources such as water and energy, and can generate significant amounts of waste.
What are the likely environmental effects of the preferred policy option?
The following sections summarise the assessment findings of the preferred policy option of a 50% reduction in the overall tax burden of Air Departure Tax by the end of the current session of the Scottish Parliament, which is estimated to be 2021. Additionally, consideration was given to a number of illustrative scenarios that could be adopted to meet the 50% reduction in the overall tax burden set out in the preferred policy option. The findings have been set out under the headings of national and local implications, reflecting the assessment approach that was undertaken to consider the potential for environmental impacts to occur at differing geographical scales.
The assessment also considered a reasonable alternative to the preferred policy option. A summary of the findings of this assessment has been included below.
Summary of findings: National Impacts
Based on the latest research undertaken by Transport Scotland in 2017, the introduction of a 50% reduction in Air Departure Tax (applied proportionally equally across all flight types) could lead to increased emissions from aviation in the first year (which is assumed to be 2018), relative to where they would be in the absence of the policy. Furthermore, the predicted increase in emissions would be greater than that initially estimated in the 2014 research undertaken by Transport Scotland.
Aviation currently accounts for less than 4% of total Scottish emissions. The increase in aviation emissions forecast as a result of the 50% reduction in Air Departure Tax is estimated to represent less than 0.3% of the Scottish total.
It is recognised in the assessment that there are a number of different ways that the proposed tax reduction could be applied in order to achieve a 50% reduction in the overall tax burden. This could include applying a zero tax charge to all short-haul flights and maintaining the tax charged on long-haul flights at current UK Air Passenger Duty rates, or vice versa. The impacts of the different approaches to applying the tax reduction in terms of passenger numbers will likely differ. For example, applying a zero tax rate amount to only short-haul flights has the potential to lead to a greater increase in passenger numbers over current levels, compared to either reducing the tax equally across all flight types or only on long-haul flights. This view has been based on current understanding of ticket pricing and demand and there being fewer long-haul flights operating from Scottish airports, and therefore fewer passengers.
There are a number of factors that can influence the greenhouse gas emissions likely to arise from increased aviation activity and it has not been possible to consider all of these in undertaking this assessment. These include the potential start-up of new flight routes and/or destinations, the extent to which a shift in modes of transport could arise and the effect that certain aviation emissions have at atmosphere (known as the multiplier effect). It has also not been possible to assess the impact on overall emissions that technological and operational improvements, alongside the development of global measures, will have in a meaningful way.
Significant progress has been made by the industry in establishing goals for reducing aircraft greenhouse gas emissions on a per-flight basis and efficiency is expected to improve continuously through to 2050 and beyond. However, it is also projected that greenhouse gas emissions will continue to grow in line with demand if greater improvements are not made.
There are also a wide range of relevant plans, programmes and strategies within which the preferred policy option will sit if implemented, and these include those that set out long-term visions and ambitions for development and investment in Scotland. Further relevant considerations include the current ambitions and objectives of the Scottish Government with regard climate change which are set through a range of policies and proposals. The Scottish Government has committed to keeping Scotland at the forefront of global climate action by responding to the Paris Agreement with a Climate Change Bill setting new, evidence-based, statutory emission reduction targets.
In light of the ambitious climate change targets, managing the environmental implications that are considered likely to arise from the introduction of the preferred policy option is likely to present some challenges. It is considered that a 50% reduction in the overall tax burden of Air Departure Tax will lead to short-term increases in greenhouse gas emissions, relative to where they would otherwise be, even with efficiency measures in place. If the preferred policy option were to be reached through a scenario of applying a zero tax rate amount only to short-haul flights, there is the potential that this could lead to higher passenger numbers than if a tax reduction was applied only to long-haul flights or proportionally equally to all flight types. In turn, this could have an influencing effect on overall greenhouse gas emissions.
Medium to long-term it is more challenging to predict the amount of future increases in greenhouse gas emissions. Projecting the estimated emissions beyond the short-term is complex and based on a number of key drivers. Technical developments and industry aspirational goals, in addition to future global measures, will play key roles in reducing emissions. However, the future of global measures, and the exact form these will take, is uncertain in light of wider political changes. A number of uncertainties also exist that could influence significance, such as the creation of new routes and the multiplier effect.
It was also noted that there would likely be negative effects for the environment, for example biodiversity, flora and fauna, linked to the effects of climate change, which could be made worse by increased air traffic movements.
Climatic Factors
Related SEA topics: Climate change impacts are likely to have a direct or indirect impact on the other SEA topics
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Summary of findings: Local Impacts
It has been assumed that the introduction of the preferred policy option will lead to increased passenger and flight numbers, both of which will place increased pressure on existing airport and interconnecting infrastructure. The degree of pressure experienced will also be influenced by the extent to which the expected increase in passenger numbers are realised.
Currently, some airport masterplans set out an objective of the best use of existing infrastructure before developing new facilities. However, they also note that in the medium to long-term, it is likely that increased pressure from passenger growth could lead to development at some airports. The development of any new infrastructure can have a number of impacts on the environment including; biodiversity, soil and cultural heritage. There is also the potential for benefits to arise through the provision of new airport and interconnecting infrastructure.
Further pressure in air quality may arise at local level as a result of increased flights, in addition to surface traffic to and from airports, with the potential for negative effects on air quality. A number of areas are currently designated as having air quality issues and increased pressure from any activity that contributes to air pollution could exacerbate existing problems.
Whilst it is a relevant consideration, it has not been possible for this assessment to consider the implications of potential changes in the way people travel and the impact on emissions. Road traffic movement is a complex issue and a number of factors outwith the aviation sector influence modal shift. Surface action strategies are also produced by some airports, promoting alternative travel options to and from the airport. It is considered likely, however, that the projected growth in the aviation sector could contribute to a number of pressures experienced at local level that influence air quality.
Aircraft noise, and exposure to this, is likely to remain a key concern. A number of airports produce noise maps and operational and technological improvements continue to be sought to reduce the noise generated from aircraft. Any increase in flight numbers or changes to flight patterns will continue to present a challenge in terms of how the industry can maintain growth whilst addressing concerns regarding noise implications.
The impacts identified as likely to arise at a local level are considered secondary impacts. Factors such as the ability of individual airport capacity to facilitate the predicted growth are relevant considerations and it is noted that these secondary impacts would be outwith the preferred policy option to influence.
There is the potential for the impacts to be long-term in nature, for example from development and operational activity, in addition to short-term impacts from construction activities. Their significance will be dependent on factors such as current operational activities and mitigation applied at individual airports and the extent of the increase in passenger numbers.
Population and Human Health
Related SEA topics: Many of the issues that affect population and human health have direct or indirect impacts on other SEA topics such as air quality
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Air Quality
Related SEA topics: Air quality can directly or indirectly impact on other SEA topics such as biodiversity and population and human health
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Biodiversity, Flora, and Fauna
Related SEA topics: Biodiversity, flora, and fauna impacts have direct or indirect effects on other SEA topics such as air, water, and soil quality
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Soil
Related SEA topics: Loss of soil or poor quality soils can have direct or indirect impacts on other SEA topics such as biodiversity and water quality.
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Water
Related SEA topics: Water quality and quantity can have a direct or indirect impact on other SEA topics such as biodiversity and population and human health
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Landscape, Cultural Heritage, and Historic Environment
Related SEA topics: Climate change can have direct or indirect impacts on landscape, cultural heritage, and the historic environment
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Material Assets
Related SEA topics: Changes made to material assets can directly or indirectly impact on other topic areas, such as air quality and population and human health
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Summary of findings: Reasonable Alternative
As part of the assessment process, a reasonable alternative was considered and compared to the preferred policy option. The assessment considered the following reasonable alternative: no reduction in the overall tax burden of Air Departure Tax compared to the overall tax burden of UK Air Departure Tax. As discussed previously, this is viewed as a "like for like" approach as the tax rate amounts would remain the same as that currently set under UK Air Passenger Duty. Under this approach, it is considered that there would be no reduction in tax rate amounts and, as such, there would be no additional impact on passenger and flight numbers. Activity in the sector would likely continue in the current trend.
Research undertaken by Transport Scotland in 2017 concluded that the preferred policy option of a 50% reduction in the overall tax burden of Air Departure Tax would lead to an increase in greenhouse gas emissions, relative to where they would otherwise be. As the reasonable alternative is viewed as not likely to have an impact on passenger and flight numbers, it would therefore seem reasonable to assume that no additional impact on greenhouse gas emissions would arise beyond that currently projected.
A number of indirect impacts have been identified throughout the assessment as likely to arise from increased activity in the aviation sector. These include impacts on noise exposure, biodiversity, and air quality. It is considered that these pressures would likely remain consistent with current levels of industry activity under the reasonable alternative.
It is a requirement when undertaking a Strategic Environmental Assessment that consideration is also given to how the environment would change in the absence of the policy. Many of the trends and pressures identified throughout this assessment are considered likely to continue on the current path if the preferred policy option was not implemented. As such, it is considered that the assessment findings of the impacts likely to arise from the reasonable alternative can also be considered to apply to how the environment would change if the preferred policy were not put in place.
What monitoring was proposed?
There are a number of measures in place that set out a requirement to report on greenhouse gas emissions, for example requirements set out in the Climate Change (Scotland) Act 2009. Reporting includes the annual Official Statistics publication of the "Scottish Greenhouse Gas Emissions". This publication sets out details of emissions levels for a range of gases and also provides information on whether or not the statutory annual targets have been met.
Scotland's emissions are adjusted to take into account trading in the EU Emissions Trading System for the purpose of reporting progress towards statutory targets as outlined within the Climate Change (Scotland) Act 2009. Global efforts to address emissions from aviation are being led by industry through the International Civil Aviation Organization. Most significant has been the development and agreement on the Carbon Offsetting and Reduction Scheme for International Aviation, a global market-based measure aimed at delivering a goal of carbon neutral growth in aviation from 2020. Once implemented, the measures will require all airlines to monitor emissions on all international routes. All European Union countries will join the scheme from the beginning.
In March 2017, the Committee on Climate Change provided advice to the Scottish Government on the new Scottish Climate Change Bill. Advice was provided on a range of issues and included a recommendation that the overall accounting framework shift to one based on actual emissions, rather than adjusting for activity as currently undertaken for purposes of the EU Emissions Trading System.
Given the known spatial nature of Scotland's airports, monitoring at the local and project levels will be an important consideration. A wide range of environmental monitoring programmes are currently in place and are relevant to the potential issues identified. This includes the monitoring of designated sites that have been identified as being located in near proximity to airports and transport routes, such as those designated for their biodiversity and habitat interests. Additionally, noise maps are produced and updated every five years and air quality is currently monitored across a range of local sites in Scotland.
What were the conclusions and recommendations of the assessment?
In light of the ambitious climate change targets, managing the environmental effects that are considered likely to arise from the preferred policy option may present some challenges. The policy to introduce a 50% reduction in the overall tax burden of Air Departure Tax is likely to lead to short-term increases in greenhouse gas emissions, relative to where they would without the policy, even with efficiency measures in place. It is more challenging to predict the implications of any increase in greenhouse gas emissions and the significance of these in the medium to long-term.
A number of secondary impacts were identified as likely to arise. These included increased pressure on local air quality and potential changes to noise exposure, both of which have the potential to have negative impacts on population and human health. Aircraft noise, through changes in flight numbers and patterns, is likely to remain a key challenge in how the industry can grow whilst addressing concerns on this.
There is the potential that new infrastructure will be required as a result of increased pressure from growth in the aviation sector, and this could lead to a number of environmental effects. It was also noted that there may be national level impacts across the environment as a result of climate change, the effects of which could be made worse through increased aviation activity.
The significance of the impacts identified in the assessment will be dependent on a number of factors. This includes operational activities and technological developments, with many of these applied at individual airports. The scale and location of any proposed airport development will also influence the impacts that may arise. The extent to which the preferred policy leads to increases in passenger numbers will also influence the significance of the impacts and this is likely to differ depending on how the 50% reduction in the overall tax burden is delivered.
Recommendations
A key part of the Strategic Environmental Assessment process is to identify ways in which the impacts that have been identified can be reduced. As noted earlier, it is considered that the impacts of the preferred policy will be felt at differing geographical scales. Some will be experienced over a larger geographical area, others are likely to be realised at a more local level.
There are limitations to the measures that can be proposed in this assessment to reduce the identified impacts as many of these will be outwith the preferred policy to influence. Measures to reduce the impacts will be best placed and most beneficial when they are undertaken in a way that reflects the differing geographical scales. For example, international and global measures to address the impacts of global emissions, or within lower level plans and strategies that set out action to meet any new climate change target. Additionally, local level consideration is likely to be given at project level to any new infrastructure requirements. Whilst the future of many of the global measures to reduce emissions is uncertain, they are likely to play a key part in addressing global emissions.
Continued and future action with regards climate change, set through a range of Scottish Government policies, proposals and strategies, is also supported. This includes the potential to include new and testing targets through the development of the new Scottish Climate Change Bill, alongside a change in the overall accounting framework to one based on actual emissions.
Significant improvements have been made to date through technical and operational improvements within the industry to reduce emissions. These, alongside collaborative goals agreed within industry on climate change action, are also supported. Continued progress will be necessary to improve efficiencies within the industry.
The assessment notes and supports the commitment made by the Scottish Government to undertake further assessment work on the potential impacts for noise levels that may arise through changes in air traffic movements.
Airport masterplans will continue to play a key role in stakeholder engagement, providing a means for airport operators to set out how they propose to take forward strategic airport decisions for specific projects. Action taken within the industry to establish and maintain effective community engagement are also supported and encouraged at all times where possible.
Next steps
Responses received during this consultation will be analysed and used as part of the decision-making process, along with a range of other available information and evidence. We will publish a report of this analysis for each consultation.
Thereafter, the next stage in the SEA process is the production of a post-adoption SEA Statement. The post-adoption Statement will reflect on the findings of the assessment and consultation, and will explain how the issues raised have been considered and addressed in the preparation of the secondary legislation setting out tax bands and tax rate amounts for Air Departure Tax that will be laid before the Scottish Parliament in the autumn.
How can I provide comment on this Environmental Report?
Public views and comments are invited on both the consultation on this Environmental Report and on the Scottish Government's policy for an overall 50% reduction in Air Departure Tax by the end of the current session of the Scottish Parliament.
Responses should be submitted by Friday 15 September 2017 and these can be submitted online, by email or by post. Details on how to submit responses has been set out in the introductory 'How to respond' section of this document.
Respondents may find the following first four questions helpful to provide a focus for their responses on this Environmental Report. Please note that responses do not need to be confined to these questions, and more general comments on this Environmental Report are welcomed in question 5.
Questions:
1. 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).
2. What are your views on the predicted environmental effects as set out in the Environmental Report?
3. Are there any other environmental effects that have not been considered?
4. Do you agree with the conclusions and recommendations set out in the Environmental Report?
5. Please provide any other comments you have on the Environmental Report.
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