Scottish climate change adaptation programme 2019-2024: strategic environmental assessment

2 Approach to the environmental assessment

2.1 Purpose of the Environmental Report and key facts

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

2.1.2 SEA is required by the Environmental Assessment (Scotland) Act 2005 (The 2005 Act), and involves the following key stages:

Screening – determining whether the plan is likely to have significant environmental effects and whether an SEA is required;

Scoping – establishing the method for the assessment and setting out the consultation period for the plan;

Environmental Report – assessing the emerging content of the plan and setting out the likely significant environmental effects, and publishing the Environmental Report alongside the consultation on the plan; and

Adoption – preparing and publishing a post-adoption statement.

2.2 SEA activities to date

2.2.1 Screening and scoping of the draft programme was undertaken in September 2018 and a combined screening and scoping report was submitted to the SEA gateway inviting views from the consultation authorities. This determined that an SEA was required as due to the potential for significant positive and negative environmental effects. All of the SEA topics (climatic factors, biodiversity including flora and flora, population and human health, soil, water, air, material assets, cultural heritage and landscape) were scoped into the assessment. The comments received have been taken into account in the preparation of the Environmental Report.

2.3 Developing a methodology

2.3.1 The assessment methodology has been refined from that originally identified within the scoping report, which proposed a focused set of SEA objectives. The finalised approach (see table 1 below) has been developed to better reflect the high-level nature of the emerging draft programme. It draws on experience gained from other relevant SEA work including that undertaken on SCCAP1.

2.3.2 Key stages in the assessment methodology are illustrated in the following table.

Table 1: Key stages in assessment methodology

2.3.3 Early assessment work considered key environmental impacts of climate change on SEA topics from the CCRA and other environmental information to inform the development of the environmental baseline.

2.3.4 The emerging SEA baseline was used to inform  discussions at six outcome workshops held during October, November and December 2018. The written outputs of these workshops were then fed into the development of the draft programme.

2.3.5 A review of the following SEA Environmental reports was undertaken to identify known environmental effects:

• Scotland’s Climate Change Adaptation Framework^[6]
• Scotland’s Climate Change Adaptation Framework Sector Action Plans^[7];
• First Scottish Climate Change Adaptation Programme ^[8];
• The Climate Change Bill^[9];
• The Climate Change Plan/Energy Strategy.^[10]

2.3.6 The finalised assessment takes the form of a broad narrative analysis of the draft programme. The key findings consider the likely significant effects of the draft programme and its overall effectiveness in addressing the key climate change impacts. This is discussed in turn for each of the seven high-level outcomes and their sub-outcomes. This approach provides a useful cross-check to ensure climate change impacts are addressed as fully and effectively as possible. Potential cumulative and synergistic impacts have also been considered. 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 the reasonable alternatives to the plan or programme, taking into account its objectives and geographical scope. The extent to which alternatives for the programme could be considered reasonable was influenced by the relevant legislative requirements, the inherent uncertainty associated with predicting the impacts of climate change, and the significant proportion of committed policy and action embodied in the draft programme. The following alternatives were not considered reasonable:

• ‘Do nothing’ scenario: This is not a reasonable alternative because the requirement for the programme is established in legislation and because it would not address the risks posed by climate change.
• Theme based approach (in keeping with SCCAP1) or a Sector based approach: These approaches were not considered as reasonable alternatives because the actual content of the programme would not be sufficiently different to generate different environmental effects.

2.4.2 In keeping with the Scottish Government’s general move to an outcomes focus, the draft programme takes an outcome-led approach. This approach was recommended by the Committee on Climate Change’s Adaptation Committee as an opportunity to build on and improve upon the framework set by SCCAP1, and to align with  the most recent consultation on national outcomes.^[11].

2.5 Risks/potential limitations of the assessment

2.5.1 As the assessment progressed, the approach taken was simplified in order to provide clear findings and the assessment underwent continual adjustment to reflect the emerging content of the draft programme.

2.5.2 Given the subject matter and taking into account the high-level nature of the draft programme there is an inherent degree of uncertainty regarding both the effects of climate change and of the draft programme across all the SEA topics.