Beavers in Scotland: consultation on the strategic environmental assessment

Historic Environment Scotland

Scope and level of detail

We note that the historic environment has been scoped into the assessment. On the basis of the information provided, we are content with this approach and are satisfied with the scope and level of detail proposed for the assessment, subject to the detailed comments provided below.

Noted

Environmental Topics to be scoped in and out of the assessment process

We welcome that the historic environment has been scoped into the process. As the scoping report notes, when considering policy relating to wild animals there will be a degree of uncertainty in the prediction of environmental effects. In this regard much of the assessment of potential effects on the historic environment will be generic in nature.

Agreed - this uncertainty will be recorded in the ER

Environmental Topics to be scoped in and out of the assessment process

We note that this section proposes to scope gardens and designed landscapes ( GDLs) out of the assessment yet baseline information on these historic environment assets has been provided in the Environmental Characteristics of Beaver Areas section of the report. Elements of beaver activity can include tree felling, dam building and construction activity that has the potential for significant effects on attributes of GDLs through important tree loss, disruption of water features and increased erosion. Therefore it is likely that the assessment findings and generic mitigation outputs from the assessment of effects on the historic environment would be equally applicable to GDLs and we would advise that this should not be scoped out as the assessment can provide beneficial management advice for the mitigation of beaver activity in these sensitive sites.

Agreed - GDLs will be included to the ER

Reasonable Alternatives

We are content to agree with the preferred option and reasonable alternatives suggest within the scoping report. The work already carried out within the future scenarios section of the Beavers in Scotland Report (2015) provides a sound starting point for the assessment of these alternatives.

Noted

Assessment Methodology

We note that the assessment will be narrative based and we welcome the draft example of a table for the presentation of findings. We particularly welcome the approach of considering the likely environmental effects of different forms of beaver activity and consider it a sound method for identifying effects and tailoring mitigation. It will be important that an approach to the monitoring of this is built into the outcomes of the assessment.

Noted and agreed

SEA Environmental Objectives

We are content to agree with the suggested SEA objective for the historic environment

Noted

Consultation period for the Environmental Report

We note that the Environment Report, Policy Statement and Draft Management Framework are proposed to be out for public consultation for a period of 6 weeks. We can confirm that we are content with this consultation period.

Noted

Scottish Natural Heritage

Scope and level of detail

Subject to the specific comments set out in the Annex to this letter, SNH is content with the scope and level of detail proposed for the environmental report.

Noted

Consultation period for the environmental report

SNH notes that a period of 6 weeks is proposed for consultation on the Environmental Report and is content with this proposed period.

Noted

General Approach

The SEA Scoping report is well set out and easy to follow. It would be good to see this approach and simple layout continued in the Environmental Report.

Noted

Setting the Context

I note that there is no reference to Local Authority plans in the section on Relevant Plans Programmes and Strategies. Local Authority plans could be affected by this policy and may need changing to support delivery of Scottish Governments Policy on Beavers in Knapdale and Tayside.

The policies in local authority plans are likely to be generic in relation to the potential core beaver woodland areas and it would be difficult to attribute anything meaningful from this policy.

Baseline information

The maps for baseline information need to be at a bigger scale to ensure the information in them can be used and easily interpreted in the final Environment Report.

Agreed, these will be presented as A3 format in Appendix 1

The population distribution maps seem to focus on the main towns and cities but both Knapdale and Tayside geographical areas are made up of small rural communities. It is important to ensure that the assessment considers how these communities could be affected by the Policy, e.g. impact on their infrastructure. As well as the more urban areas already identified.

Agreed, beavers and their interactions with the human environment are assessed under material assets - specifically forestry, fisheries, agriculture and infrastructure.

The baseline information identifies National Scenic Areas, however earlier in the scoping report these were scoped out because it was felt that they would not be impacted by the Policy. I assume they have been included as context to both areas, but this is not clear.

Agreed, these will not be included in the ER.

Significant issues

There are a number of Natura sites in both areas identified in the Policy. These have been highlighted in the baseline data. Where relevant an assessment to determine significant effect of the policy on these sites If in the result of the assessment indicates there is likely to be a significant effect on the Natura sites then a Habitats Regulations Appraisal will be required.

Agreed. A HRA of Natura sites has been undertaken. This will be an Annex of the ER.

Please note that if a Habitats Regulations Appraisal is required it can be undertaken in parallel with SEA, it is important that the findings of both appraisals are separate and clearly documented and that the record of the Habitats Regulations Appraisal uses the correct terminology, applying them appropriately. In practice, it is easier to set out the Habitats Regulations Appraisal in a separate record, and where appropriate provide a cross-reference to it in the Environmental Report.

Agreed. The SEA and HRA are separate documents.

SEA objectives

The SEA scoping details objectives which are being linked to receptors identified, however there are no targets associated with them and/or details of how achievement will be measured.

The assessment is not target related but it is intended that any indicators to assess the effectiveness of the policy will be identified at monitoring

Assessment Methodology

The assessment methodology includes a review of alternatives, assessment criteria, however, it does not include details of known indicators or monitoring arrangements. A description of the indicators chosen and the associated monitoring arrangements is needed.

As above

Scottish Environment Protection Agency

Relationship with other Plans, Policies and Strategies ( PPS

Some of the PPS included have themselves been subject to SEA. Where this is the case you may find it useful to prepare a summary of the key SEA findings that may be relevant to the Beavers in Scotland programme. This may assist you with data sources and environmental baseline information and also ensure the current SEA picks up environmental issues or mitigation actions which may have been identified elsewhere.

Noted

Baseline Information

SEPA holds significant amounts of environmental data which may be of interest to you in preparing the environmental baseline, identifying environmental problems, and summarising the likely changes to the environment in the absence of the PPS, all of which are required for the assessment. Many of these data are now readily available on SEPA's website. We would refer you to the following which are of particular relevance:

• Flood Risk Management Strategies and Local Flood Risk Management Plans are partnership strategies which focus action in the areas with the greatest risk of flooding and which provide details on proposed actions, funding and delivery timescales http://apps.sepa.org.uk/FRMStrategies/
• The River Basin Management Plan for the Scotland River Basin District 2015-2027 contains details of the pressures on the water environment and objectives to be achieved in line with Water Framework Directive objectives www.sepa.org.uk/media/163445/the-river-basin-management-plan-for-the-scotland-river-basin-district-2015-2027.pdf

Noted

Scoping In / Out of Environmental Topics

With regard to the topics which fall within our remit (air, soil, water, material assets, human health and climatic factors) and based on the information provided to date we are content with the topics proposed to be scoped into the assessment.

Soils and geomorphology were scoped into the assessment process. However consideration of any significant effects on soils and geomorphology is captured within the sections on woodland, freshwater and material assets as these elements are too closely interconnected with these topics to separate out in any meaningful way.

We understand that effects related to flooding will be considered across the whole range of environmental receptors which have been identified in section 6 of the scoping report. We consider this to be appropriate and note that a specific SEA objective associated with this will be used

Agreed

With regards to material assets it would be useful to include consideration of the potential impacts on strategic transport corridors from changes in other areas (such as changes to morphology or flooding regimes) which may result from beaver activity. Such activity may influence erosion and deposition in watercourses adjacent to main road and rail infrastructure even if the beaver activity is not in direct proximity.

Consideration of A9 dualling programme included.

We understand that many of the issues to be considered in the assessment are related to the water environment and will therefore be assessed under this SEA topic. It will be important to clearly identify the individual elements being considered (e.g. geomorphology, water quality, fauna, flora, etc.) as well as their interrelationships with each other and the other SEA topics under consideration in order that significant effects can be documented in a way which clearly identifies potential cause and effect relationships

Agreed. Interrelations are embedded throughout the assessment. The nature of these is also discussed in assessment limitations.

Implications for non-native species might also usefully be considered (either under the water topic or biodiversity, fauna and flora) in terms of whether the presence of beavers potentially enhances or reduces the risk of spread or establishment of any existing, or potential future introductions of freshwater or riparian high impact non-native species.

Agreed

Alternatives

We are satisfied with the alternatives outlined in Section 5 of the scoping report. These should be assessed as part of the SEA process and the findings of the assessment should inform the choice of the preferred option. This should be documented in the Environmental Report.

Noted

Methodology for Assessing Environmental Effects

We support the use of SEA objectives in the assessment as they will allow a systematic, rigorous and consistent framework with which to assess environmental effects in relation to the environmental receptors identified in Section 6 of the scoping report.

Agreed

Mitigation and enhancement

We would encourage you to be very clear in the Environmental Report about mitigation measures which are proposed as a result of the assessment. These should follow the mitigation hierarchy (avoid, reduce, remedy or compensate).

One of the most important ways to mitigate significant environmental effects identified through the assessment is to make changes to the plan itself so that significant effects are avoided. The Environmental Report should therefore identify any changes made to the plan as a result of the SEA.

Where the mitigation proposed does not relate to modification to the plan itself then it would be extremely helpful to set out the proposed mitigation measures in a way that clearly identifies: (1) the measures required, (2) when they would be required and (3) who will be required to implement them. The inclusion of a summary table in the Environmental Report such as that presented below will help to track progress on mitigation through the monitoring process.

Agree and this structure is reflected in the mitigation section of the ER.

Monitoring

Although not specifically required at this stage, monitoring is a requirement of the Act and early consideration should be given to a monitoring approach particularly in the choice of indicators. It would be helpful if the Environmental Report included a description of the measures envisaged to monitor the significant environmental effects of the plan.

Noted

Consultation period

We are satisfied with the proposal for a 6 week consultation period for the Environmental Report

Noted