Scottish climate change adaptation programme 2019-2024: analysis of responses to consultation

6. Responses to the Strategic Environmental Assessment

Introduction

6.1 This chapter presents responses to consultation questions eight to ten, which asked respondents for their views on the Strategic Environment Assessment^[7].

The SEA
The consultation document includes an overview of the SEA. It concludes the draft Programme is likely to have significant positive environmental effects on climatic factors, by drawing together relevant adaptation measures to maximise their impact, capitalise on synergies and addressing any gaps. This approach to climate change adaptation can also optimise environmental benefits more widely, with likely positive environmental effects to biodiversity, population and human health, air, soil, water, material assets, cultural heritage and landscape. The environmental assessment has also identified the potential for mixed / uncertain effects arising from future adaptation measures at the local level. Individual projects would however be subject to consideration through the relevant regulatory regimes and appropriate mitigation applied. Finally, the Environmental Reports sets out opportunities for enhancement linked to the 7 draft programme outcomes.

Question 8: 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?

6.2 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 of the SEA for further consideration, and another participant described their view as 'unsure'. Themes in the comments are described below.

Agreement with scope and accuracy

6.3 Of the 22 who commented that they agreed with the scope and accuracy, the majority (13 respondents) indicated that the information presented was credible and comprehensive. 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.

6.4 Just under half (9 respondents) confirmed their agreement without elaboration; making short statements such as 'content with this'.

Aspects of the SEA for further consideration

6.5 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.

6.6 Respondents' suggestions of issues for greater coverage within the document varied, according to their specific area of interest or expertise, and are summarised below:

• Mention of biotechnology/GMOs.
• Statements on how the baseline is defined and greater specificity within the SEA in relation to risks.
• Consideration of impacts on migratory species and more emphasis on species only found in Scotland.
• More discussion about human health and air quality in urban environments and the need for green space.
• Expansion of the land use section, to include a landscape-scale approach which discusses ecosystem services.
• For the SEA to note that new renewable energy infrastructure might have negative effects on the historic environment, and to reflect more strongly on the interdependencies between natural and historic environment and landscapes.
• Expansion of coverage of all industry sectors, more detail on fuel supply and consideration of the supply chain for coastal and remote locations.
• Identification of flooding as the greatest climate change risk.
• A reassessment of the condition of native woods, based on the perception of there being an 'overly positive spin' on this issue within the SEA.
• A greater focus on potential mitigation measures to reduce threats to habitats and species and discussion of the impact of changes in the timing of seasonal events and migration patterns.

6.7 Three participants provided extensive comments which they noted covered their responses to questions 8 to 10. These detailed responses cover a broad range of elements within the 73-page SEA document and have been signposted to the Scottish Government for consideration. They are summarised below:

• Detailed response 1:
  • For a broader focus on working with nature and assessment within the SEA at the sub-outcome level. Other proposed changes included details of specific mitigation activities, for the Programme to indicate how behaviours could best be promoted, consideration of ways in which mitigation in relation to one outcome might harm adaptation in another, acknowledging that focusing adaptation efforts on the system most vulnerable to climate change impacts may not always create the maximum environmental benefit.
• Detailed response 2:
  • For the assessment to consider the potential for these adaptation activities to also impact on the causes of climate change
  • Qualification of the statement at 4.2.3 to explain that this is limited to the context of adaptation to climate change. Also note the statement at 4.9.6 similarly is generally limited to the context of adaptation to climate change and other SEA topics, such as health and wellbeing (in relation to housing conditions) or material assets (in relation to buildings).
  • For the post-adoption statement to clarify the scope of what was considered under the topic of climatic factors in the draft Programme assessment and future reviews of the Programme should discuss 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.
  • They suggested the SEA did not explain whether alternatives within the seven adaptation outcomes were considered in the assessment and welcomed this inclusion, on the basis that preparation contributing to consideration of environmental issues should be included in the SEA reporting even if it falls outwith the SEA process.
  • For more discussion of how the mitigation measures and enhancement opportunities noted in Section 4.9 have been or will be progressed and clarification within the Post Adoption Statement in this respect.
  • Where the mitigation or enhancement proposed does not relate to any modification to the programme itself, for the Post Adoption Statement to identify: (a) the measures required, (b) when they would be necessary and (c) who will be required to implement them.
• Detailed response 3:
  • For clarity as to how identified mitigation measures and opportunities have influenced the content of the draft Programme.
  • As referenced at 6.6, for inclusion within the Programme, under Outcome 6, of relevant narrative and policies relating to the historic environment. Linked to this, for the assessment of Outcome 5 to draw out more strongly the interdependencies between natural and historic elements of the environment and landscapes, and for this to have influenced the choice of policies included under this outcome; and, for the assessment to note that new renewable energy infrastructure also has the potential for negative effects on the historic environment.

Comments on presentation or wording

6.8 Two respondents reflected on the presentation of the SEA in their responses to question 8. One asked for a summary table to be included in the Post Adoption Statement. The other described additional policy links to incorporate within the SEA. They also mentioned some confusion arising from the inclusion of policies in the SEA which are not referenced in the consultation document.

6.9 One participant noted that young people found the question difficult to answer and suggested that in future child-friendly versions of consultation documents and questions should be produced.

Question 9: What are your views on the predicted environmental effects as set out in the Environmental Report?

6.10 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 of these (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 in the comments are described below.

Themes in agreement with the estimation of impact

6.11 Over half of the substantive responses included comments indicating agreement that the predicted environmental impacts set out in the Environmental report were a reasonable estimate. 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.

• 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.
• Three respondents stressed in their comments a demand for local and project level approaches for the programme to be achievable. Three remarked on the need to keep it under constant review as climate change and its impacts are complex and ever-changing. One suggested the emphasis is on awareness raising and behaviour change without increased government support for structural change.

Disagreement or uncertainty concerning the predicted effects

6.12 One participant disagreed with the predicted effects on the basis of them being too general, and another participant described their view as 'unsure', explaining 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 this comment.

Question 10: 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?

6.13 There were 42 responses to Question 10. Nine of these were 'no comment' or similar, leaving 33 substantive comments for analysis. Themes in these responses are described below.

Responses to the findings

6.14 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. The majority view was of general agreement with the findings.

6.15 Eighteen participants indicated agreement with the findings. These comments frequently highlighted elements that will support the achievement of outcomes such as the regulatory controls in place and the monitoring framework; one anticipated the National Forum 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.

6.16 Nine participants made general or neutral descriptive comments.

6.17 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 specified; another suggested 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 and high expectations for behaviour change to effect impact.

6.18 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 desired for the focus to be on the natural environment as the 'organising factor'.

Comments on monitoring

6.19 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.

Reflections on mitigation:

6.20 Six respondents commented on mitigation:

• Three shared general or descriptive comments in overall support of the approach.
• Three suggested more work is needed. They 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.

Communication

6.21 There were six comments on communication. These mostly emphasised a need for wide publicity of the urgency to encourage behaviour change and adaptation action. Suggestions included placing climate change on curricula, legislation and introducing incentives to bring about change. Two respondents suggested channels that could be used (Smart Village Scotland and Adaptation Scotland's website).

Additions to the SEA

6.22 Suggested additions to the SEA, as identified in participants' responses to question 10, are described below:

• Mention of the oil and gas industry and policies to promote clean and renewable energy.
• Local structures to address measures on coastal flooding.
• A case study to illustrate the scale of the benefits of mitigation.
• More emphasis on flooding as the most significant climate change risk.
• Place the natural environment, rather than behaviour change, at the heart of the Programme.
• New building standards to address overheating risk and installation of passive cooling.
• Need to monitor urban greenspace and reverse its decline.