Cleaner Air for Scotland 2: environmental report

2. Approach to Strategic Environmental Assessment

2.1. Purpose of this Environmental Report

2.1.1 As part of the preparation of the draft CAFS2, the Scottish Government is carrying out a Strategic Environmental Assessment (SEA) of its proposed content. SEA is a systematic method for considering the likely significant environmental effects of certain plans, programmes and strategies. SEA involves the following key stages:

• Screening – determining whether the strategy is likely to have significant environmental effects and whether an SEA is required;
• Scoping – establishing a method for assessment and setting out the consultation period for the strategy;
• Environmental Assessment – assessing the emerging content of the strategy and setting out its likely significant environmental effects and proposing, where possible, how negative effects can be avoided or reduced and how positive effects can be maximised; the Environmental Report is published alongside the consultation draft strategy;
• Post Adoption Statement – preparing and publishing a post-adoption statement outlining how the SEA has influenced the final strategy.

2.1.2 This report has been prepared in accordance with the Environmental Assessment (Scotland) Act 2005 (“the 2005 Act”) and sets out the findings of the environmental assessment stage. The Cleaner Air for Scotland 2 strategy is considered a qualifying plan under section 5 (4) of the 2005 Act.

2.2. SEA activities to date

2.2.1 Screening and Scoping was undertaken in August 2019 and a combined screening and scoping report was submitted to the SEA gateway inviting views from the SEA statutory consultation authorities (SEPA, NatureScot and HES). This determined that an SEA was required due to the potential for significant positive effects for population and human health, air and climatic factors.

2.2.2 Based on the comments received from the consultation authorities, water, soil, biodiversity and material assets (land) were subsequently scoped into the iterative assessment process (Table 2). This was because it was considered that proposals targeting agricultural emissions, nitrogen deposition and environmental impacts had the potential for positive effects across these topics. However as the assessment progressed, an early finding of no likely significant effects for these topics was identified and therefore more detailed assessment work was not progressed. For completeness however, a light touch consideration of these topics is included.

Table 2. Scoping of SEA topics

Air Quality

√

Population and Human Health

√

Climatic Factors

√

Soil

√

Water

√

Biodiversity, Flora and Fauna

√

Material Assets

√

Cultural Heritage

X

Landscape

X

2.3. SEA Methodology

2.3.1 The finalised assessment approach has been developed to reflect the high-level nature of the emerging draft CAFS2 which is shaped around 10 themes focusing on Health; Integrating policy; Place-making; Data; Public engagement and Behavioural Change; Industrial Emission Regulation; Tackling Non-Transport Emissions Sources; Sustainable Transport; Governance, Accountability and Delivery; and, Further Progress Review (Table 1).

2.3.2 Early assessment work considered key environmental pressures associated with air quality on the scoped in SEA topics. This included the consideration of a range of environmental information including outputs from a Plantlife workshop held in November 2019.

2.3.3 Not all of the themes were considered likely to have significant environmental effects. Themes 4, 9, and 10 concerning data, governance & accountability, and on review arrangements, were scoped out of the assessment because they relate to administrative or procedural matters.

2.3.4 The finalised assessment takes the form of a broad narrative analysis of themes 1, 2, 3, 5, 6 and 8 (hereafter referred to as “the wider CAFS2 policy proposals”) together with a more focused analysis of Theme 7 - Tackling Non Transport Emissions Sources, because this theme includes new proposals for legislation to address domestic combustion emissions as well as other measures to target domestic combustion and agricultural emissions, nitrogen deposition and environmental impacts.

2.3.5 Potential cumulative and in-combination effects have also been considered and opportunities to enhance environmental benefits have also been included where identified.

2.4. Alternatives

2.4.1 The 2005 Act requires the Environmental Report to identify, describe and evaluate the likely significant effects on the environment of reasonable alternatives to a plan, programme, or strategy taking into account its objectives and geographical scope. The extent to which alternatives could be considered reasonable was influenced by the relevant legislative requirements and takes into account those existing policy and actions, the content of which has been set out elsewhere in higher level plans, programmes and strategies.

2.4.2 A ‘do nothing’ scenario was not considered a reasonable alternative because this is was considered incompatible with the objective of delivering further air quality improvements while maximising greenhouse gas emission reductions and improving health outcomes in relation to air.

2.4.3 The draft CAFS2 aims to address multiple outcomes based on the above. In addition, the overarching themes were developed by the independent steering group and their underpinning actions are considered collectively in achieving the objectives of the strategy and therefore no single action or an alternative approach to it can be viewed as a reasonable means to deliver the overarching objective to improve air quality.

2.4.4 Taking this into account we do not consider that there are any reasonable alternatives to the draft CAFS2.

2.4.5 Opportunities for enhancement have been identified throughout where appropriate and the development of any subsequent policy or proposals that set out actions or measures to meet the Strategy’s objectives will themselves be subject to consideration under the 2005 Act.

2.5. Risks/ potential limitations of the assessment

2.5.1 As the assessment progressed, the approach was refined to best reflect the emerging content of the draft CAFS2 and to provide clear assessment findings.

2.5.2 A degree of inherent uncertainty was recognised where actions (such as further research and assessment) have the potential to result in future proposals, and where the detailed implementation of actions identified in the draft CAFS2 is yet to be determined The focus of the assessment therefore was on actions which sought to implement new legislation targeting domestic emission reduction and supportive measures to improve air quality.