Cleaner Air for Scotland 2: environmental report

4. Assessment findings and recommendations

4.1. Introduction

4.1.1 This section sets out the likely significant environmental effects that are expected as a result of the draft CAFS2.

4.1.2 The assessment takes the form of a broad narrative analysis of themes 1, 2, 3, 5, 6 and 8 together with a more detailed analysis of theme 7 - Tackling Non Transport Emissions Sources.

4.1.3 Themes relating to data (theme 4); governance, accountability and delivery (theme 9) and further progress review (theme 10) were not considered likely to have significant environmental effects because they relate to administrative or procedural matters and consequently they have been scoped out of the assessment.

4.1.4 Where any actions identified in CAFS2 themselves give rise to new plans, programmes or strategies, or to new more detailed project proposals, these will themselves be subject to consideration under the relevant statutory assessment and consenting requirements, including the 2005 Act.

4.2. Theme 7 - Tackling Non Transport Emissions Sources

4.2.1 This theme provides new policy proposals and supportive measures that focus on domestic (household) burning as well as agriculture, as two sectors not previously addressed in detail in CAFS, but which make an important contribution to air pollution in Scotland.

4.2.2 The consideration of performance and standards for domestic fires, stoves and fuels, and local authority powers to permit and control these, have the potential to deliver significant improvements in air quality beyond current regulatory and management approaches. The development of actions to target agricultural emissions, nitrogen deposition and environmental impacts including a code of good agricultural practice for Scotland has potential to further contribute to positive effects on these topics.

What are the key environmental pressures relevant to this theme?

4.2.3 Key environmental pressures relevant to this theme relate to air, population and human health, climatic factors, soil, water, biodiversity and material assets.

4.2.4 Pressures on air quality include emissions from domestic and agricultural sources with ammonia declining at a slower rate than other pollutants. Burning fuels for heating negatively affects both indoor and outdoor air quality through the release of combustion particles and gases (such as CO, CO₂, NO_x). Poor air quality continues to affect human health and the environment in some areas.

4.2.5 Pressures on population and human health include poor outdoor and indoor air quality which can also exacerbate existing health conditions with impacts not evenly spread across different demographics and geographies.

4.2.6 Climate change-related changes in temperature and atmospheric circulation have the potential to exacerbate poor air quality and associated health problems. The burning of hard fuels contributes to climate change through the emission of greenhouse gasses which also release pollutants such as particulate matter.

4.2.7 Pressures on soil, water, biodiversity and material assets include land management linked to agricultural practices and associated emissions, including from the release of pollutants such as ammonia.

What are the likely significant environmental effects of this theme?

4.2.8 This theme is likely to have significant positive effects on air quality, population and human health and climatic factors. New policy to target domestic combustion emissions at a national level combined with support for appliance improvements and education/incentives have the potential to deliver significant improvements in air quality beyond current regulatory and management approaches. The development of a code of agricultural practice to target agricultural emissions has potential to further contribute to positive effects on these topics.

Actions focusing on domestic combustion emissions

4.2.9 Actions targeting domestic emissions under this theme include the introduction of legislation to control the supply of the most polluting domestic fuels. Other supportive measures include education/initiatives, working with a range of stakeholders and commissioning research to support emissions reduction. These actions are likely to result in significant positive effects on air quality, population and human health, and climatic factors.

4.2.10 The introduction of legislation to control the supply of the most polluting domestic fuels, which includes a ban on house coal, restricting the sulphur content of smokeless fuels to 2%, and prohibiting the sale of wet wood, also has the potential to lead to significant positive effects on air quality, population and human health and climatic factors. Prohibiting the use of wet wood could lead to a significant reduction in emissions if its use is replaced by dried wood, which has 80% less emissions, including a reduction in sulphur dioxide. In urban areas, it is often the cumulative effect of a number of appliances in a relatively small geographic area which makes a notable contribution to overall emissions, rather than emissions from an individual stove or fireplace.

4.2.11 Actions to encourage the uptake of Ecodesign stoves and the replacement of pre-Ecodesign appliances have the potential to lead to reductions in particulate matter emissions, which alongside nitrogen oxide and sulphur oxide are the main pollutants resulting from domestic combustion. This is due to the Ecodesign particulate matter limit being 55% lower than the current UK testing regime for exempting appliances for use in Smoke Control Areas (SCAs). This is likely to contribute to positive effects for air quality and climatic factors (due to their intrinsic link) and, as a result, population and human health.

4.2.12 Improvements in air are likely to be both in relation to outdoor and indoor air quality, including a reduction of nuisance (smoke). This would also serve to improve air quality in areas where solid fuel might not be the main source of heat but where wood burning stoves have been installed as a secondary or amenity heating source.

4.2.13 Future actions to support domestic emission reductions also have the potential to result in localised positive effects on air and population and human health through improved air quality. In addition, measures to support improved energy efficiency of stoves have the potential to lead to a reduction in fuel poverty. Effects associated with the installation of Ecodesign stoves in individual dwellings on material assets and, in particular, the built environment, are considered to not be significant.

Actions focusing on Agricultural Emissions, nitrogen deposition and environmental impacts

4.2.14 Actions targeting agricultural emissions, nitrogen deposition and environmental impacts under this theme include the development of a voluntary code of good agricultural practice, as well as review, investigation and monitoring of nitrogen deposition and environmental impacts. These actions have the potential to contribute to positive effects on air quality, population and human health, climatic factors. The development of a voluntary agricultural code also has the potential for localised positive effects on soil, water, biodiversity and material assets (land).

4.2.15 The development of a voluntary code has the potential to increase the efficiency of and to reduce the overall (amount) use of ammonia. Ammonia is a reactive nitrogen compound which is released when slurries, manures and nitrogen fertilisers come into contact with the air. It produces odours and is mobile, combining with acids and particulates, resulting in polluting and nuisance effects. A reduction in ammonia emissions resulting from changes in agricultural practices could contribute to positive effects on air quality (including odour), climatic factors (NOx emissions) and population and human health (in relation to air quality effects).

4.2.16 Other actions identified have the potential to result in localised positive effects on soil, water, biodiversity and material assets (land). For example, a reduction in leaching of N-based fertiliser in watercourses and on land/ soil associated with good agricultural practice, can lead to reduced levels of N, thus preventing eutrophication and acidification^[21], contributing to localised positive effects on biodiversity, water and soil.

4.2.17 There is also potential for localised positive effects in relation to material assets, such as land where a code of practice to support nitrogen emissions reductions is implemented. This has the potential to lead to changes in agricultural practices, and as a result increase the efficient use of land. For example, practices which retain as much nitrogen as possible by reducing losses to the atmosphere or leaching in soil and water, can maximise nitrogen use efficiency and thus returns from farm inputs and good practice in managing soil, manure, fertiliser and feed will help reduce ammonia emissions (and other nitrogen losses).

Does the theme address key environmental problems identified?

4.2.18 The introduction of legislation to control the supply of the most polluting domestic fuels, which includes a ban on house coal, restricting the sulphur content of smokeless fuels to 2% and prohibiting the sale of wet wood has the potential to lead to significant positive effects on air quality, population and human health and climatic factors. Additional actions identified to support tackling non transport emissions sources (focused on domestic and agricultural emissions) are also likely to contribute to positive localised effects for soil, water, biodiversity and material assets, contributing to addressing the key environmental pressures identified in section 3.

4.2.19 It should also be noted that in regard to actions that target agricultural emissions reductions, the draft CAFS2 recognises that the most effective measures to reduce these impacts are those which directly reduce emissions of ammonia to the atmosphere, as opposed to attempting to introduce post emissions mitigation. Pre-emissions mitigation strategies can be useful and include separation of sensitive receptors from local sources and the use of shelterbelts to enhance both dispersion through increasing turbulence and capture of ammonia close to source. Pre-emissions mitigation has the potential to mitigate against a range of localised environmental effects on both human and ecosystem health and reduce the need for post emissions mitigation.

Opportunities for Enhancement

4.2.20 To obtain the maximum environmental benefits under theme 7 (Domestic emissions) a focus could be given to urban areas/those outside of existing Smoke Control Areas. This is because urban areas are often recognised as having increased levels of particulate matter pollution and there are currently limited controls on the installation of domestic wood burners and flues. This can lead to poor air quality and smoke/ odour nuisance.

4.2.21 To obtain the maximum environmental benefits under theme 7 (agricultural emissions, nitrogen deposition and environmental impacts), it is recommended that early and targeted action should be focused on practices that can realise multiple environmental benefits. This includes a focus on practices which can deliver both ammonia emission reductions and support the recovery of as much nitrogen as possible. Not only will this reduce agricultural emissions but can contribute to positive localised effects on people, water, soil, biodiversity and material assets.

4.3. Wider policy proposals^[22]

4.3.1 Wider policy proposals under the draft Strategy do not themselves set out new polices and proposals but in combination these themes can support improved air quality through research and behaviour change (themes 1 and 5), policy integration and application (themes 2 and 6) and by drawing together existing Scottish Government policy to support positive outcomes for air quality across the themes of placemaking and sustainable transport (themes 3 and 8).

What are the key environmental problems relevant to this theme?

4.3.2 Key environmental problems relevant to these themes relate to air, population and human health and climatic factors.

4.3.3 Pressures on air quality include emissions from industrial, domestic, agricultural, natural and transboundary sources and poor air quality continues to affect human health and the environment in some areas.

4.3.4 A key pressure on population and human health is outdoor air pollution which is known to cause damage to human health across a wide range of conditions and is likely to be more prevalent in highly urbanised areas. Air pollution and the consequent impacts on human health are not evenly spread and disproportionately linked to more vulnerable groups and deprived areas.

4.3.5 Climate change has the potential to exacerbate poor air quality and has the potential to exacerbate key pressures on a range of environmental receptors. Air quality and climate change are intrinsically linked as they both arise from broadly the same sources. Key pressures on climate change include greenhouse gas emissions from a range of sectors including transport (37%), agriculture and related land uses (24%), business/Industry (22%), energy (15%), and residential (15%).

What are the likely significant environmental effects of the wider policy proposals?

4.3.6 These themes are likely to cumulatively contribute to positive effects on air quality, population and human health and climatic factors.

Actions focusing on research and behaviour change

4.3.7 Actions focusing on further research in relation to public health seek to adopt a precautionary approach which supports continued efforts to reducing preventable air pollution beyond domestic and international air quality standards; this has the potential to contribute to broad positive effects on climatic factors, air and population and human health.

4.3.8 For example, actions that support evidence gathering and research on air pollution reduction at a national level can contribute to positive effects on climatic factors, air and population and human health. Further actions to consider issues associated with indoor air pollution and population exposure to air pollution have the potential for improved human health in a range of settings/locations.

4.3.9 Proposals relating to behaviour change seek to support the development of complimentary and co-ordinated strategies as a means to deliver required behavioural change outcomes and can contribute to broad positive effects on climatic factors, air and population and human health.

4.3.10 For example, actions that focus on behaviour change (especially alongside appropriate policy intervention) can support positive effects on air quality and population and human health. This is because public information provision, awareness and behavioural change are interlinked and integral to the delivery of long term sustained change in environmental quality generally, and air pollution specifically.

Actions focusing on policy integration and application

4.3.11 Policy integration proposals seek to support policy integration across climate change, transport delivery, public health and related polices and as such can contribute to broad positive effects on climatic factors, air and population and human health.

4.3.12 For example, ensuring the close co-ordination of climate change, transport delivery, public health and related policies has the potential to maximise co-benefits across a number of environmental receptors. Policy integration at national and local levels that targets greenhouse gases and air pollutants share common sources, notably transport, energy generation and land use practices, and will thus benefit from many of the same policy interventions.

4.3.13 By ensuring EU environmental themes remain at the heart of environmental law and policy in Scotland, proposals on industrial emissions regulation can also contribute to broad positive effects on climatic factors and air.

4.3.14 For example, actions that seek to ensure the continued implementation of EU environmental requirements into domestic legislation are likely to contribute to positive effects on climatic factors and air quality. These requirements have so far demonstrated that controls placed on industry are a proportionate and effective mechanism in the reduction of greenhouse gas emissions.

Actions drawing together existing placemaking and sustainable transport policy (themes 3 & 8)

4.3.15 Existing place-making proposals seek to embed air quality improvements in placemaking plans and policies, and can contribute to broad long term positive effects on population and human health, climatic factors and air.

4.3.16 Existing placemaking actions such as the use of the Place Standard tool^[23] aim to address the accumulation of challenges resulting from historical policies and decisions in relation to the built environment, road layouts and other infrastructure, with the aim of co-delivering improvements in air quality as a by-product of improving the quality of places and ensuring that future developments are future-proofed.

4.3.17 Utilising a version of the Place Standard tool which focuses on improving air quality has the further potential to support localised long-term positive environmental effects on air and population and human health. For example, actions that embed air quality improvements associated with place making (such as co-location of infrastructure/amenities to minimise travel) could contribute to reducing the amount of air pollutants and greenhouse gas emissions resulting from new development.

4.3.18 Existing transport actions which recognises air quality improvements associated with transport plans and polices are also likely to contribute to broad long term positive effects on population and human health, climatic factors and air.

4.3.19 For example, actions under existing legislation such as the Transport (Scotland) Act 2019 promotes the implementation of Low Emission Zones (LEZs) in Scotland’s four largest cities and sets out proposals on active and bus travel.

4.3.20 Similarly, the new National Transport Strategy (NTS2)^[24], published in February 2020, sets out an ambitious and compelling vision for Scotland’s transport system for the next 20 years which is underpinned by four priorities – reducing inequalities, taking climate action, helping deliver inclusive economic growth and improving our health and wellbeing.

4.3.21 NTS2 will therefore contribute to the delivery of improved air quality for example through its focus on embracing new technologies, better public transport provision and constraints upon private vehicle use, especially in urban centres where pollution and congestion are most acute. Increasing modal shift to public transport and active travel is also key to further reductions in transport emissions that are recognised as the biggest contributor to air pollution in Scotland.

Do the themes address key environmental pressures identified?

4.3.22 Actions identified across the wider policy proposals in the draft Strategy are likely to contribute to addressing the key environmental pressures identified. This is because these themes can support improved air quality through research and behaviour change (themes 1 and 5), policy integration and application (themes 2 and 6) and drawing together existing Scottish Government policies that contribute to air quality across the themes of placemaking and sustainable transport (themes 3 and 8).

Opportunities for Enhancement

4.3.23 To obtain maximum environmental benefits across wider policy proposals there may be further opportunities to identify alignment with other existing Scottish Government policy. Whilst the SEA findings support the focus on opportunities to integrate primarily climate change, public health and transport policies identified by the draft CAFS2, a consideration of wider Scottish Government policies such as those with a focus on soil health, biodiversity or land use, for example the next iteration of the Land Use Strategy, have the potential to lead to benefits across the wider environment.

4.3.24 Further, in addition to recognising alignment with other existing Scottish Government policy, future actions under CAFS should also take into account experiences from Covid-19. For example, this could be through recognising the need for a green recovery which supports Scotland’s emergence from the global pandemic. This may provide opportunities for businesses and organisations as a result of the pandemic to operate differently, and more sustainably. This has potential for additional environmental benefits that can contribute further to improving air quality in the long term.

4.3.25 To obtain the maximum environmental benefits under health and integrated policy proposals (themes 1 and 2) a focus could be given to evidence and research focused on urbanised/deprived areas as these are recognised as being more vulnerable to air pollution.