Consultation on the Draft Scottish Climate Change Adaption Programme: Analysis of Responses

9 Strategic Environmental Assessment Report

9.1 This chapter presents an analysis of respondents' views on the Strategic Environmental Assessment (SEA) Report. This was included in the consultation as a separate document.

9.2 The Scottish Government carried out an SEA of the Programme, as required by the Environmental Assessment (Scotland) Act 2005. The purpose of the SEA was to ensure that environmental considerations were incorporated into the development of the Programme. An SEA is a systematic process which sets out the key environmental issues arising from the Programme in an Environmental Report. The consultation asked six questions about the Environmental Report:

Question 6a: To what extent does the Environmental Report set out an accurate description of the current environmental baseline?

Question 6b: Do you agree with the predicted environmental effects of the draft adaptation programme, set out in the Environmental Report?

Question 6c: Do you agree with the recommendations set out in the Environmental Report?

Question 6d: Do you agree with the proposals for monitoring of the environmental effects of the draft programme set out in the Environmental Report?

Question 6e: Are you aware of any further environmental information that will help to inform the environmental assessment findings?

Question 6f: Are you aware of other 'reasonable' alternatives to the adaptation programme and its content that should be considered as part of the SEA process?

Description of the current environmental baseline (Q6a)

9.3 Twenty-nine (29) respondents answered Question 6a. Of these, 17 (59%) thought that the SEA either "fully" or "mostly" set out an accurate description of the current environmental baseline, while 12 (41%) thought that it only "partially" or "poorly" did so. (Table 9.1.) The latter group included 4 out of 14 local authority respondents, 2 of the 3 education / research respondents and 2 of the 3 non-governmental organisations (NGOs).

Table 9.1: Question 6a - To what extent does the environmental report set out an accurate description of the current environmental baseline?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	1	1	3
Local authority & CPPs	2	8	4		14
NGOs		1		2	3
NHS or health-related		2	2		4
Other public bodies		1			1
Private sector		1			1
Transport		1			1
Individual respondents			1		1
Total	2	15	9	3	29
Total percentages	7%	52%	31%	10%	100%

9.4 Twenty-one (21) respondents (31% of all respondents) provided comments at Question 6a. Those who had ticked "fully" or "mostly" in response to Question 6a thought that the SEA had set a "wide reaching" and "accurate" environmental baseline and had done so in a "succinct" and "clear" manner. It was also described as "appropriate for the level of assessment". However, those who ticked "partially" or "poorly" in response to Question 6a thought that:

• A more comprehensive baseline assessment was needed. However, respondents thought the policies and proposals in the Programme should be more clearly defined to enable progress to be measured. Respondents thought it would be useful if data were provided on the number of adaptation measures already in place.
• The current description of the baseline contained "subjective statements".
• The SEA had been conducted at a high level, and as a result much detail and many environmental impacts were likely to have been missed or poorly described.

9.5 Those who had ticked "mostly" went on to make suggestions for additions or improvements to the SEA, including for example:

• Taking into account more recent reports from the Intergovernmental Panel on Climate Change (IPCC) which indicate that the effects of climate change are taking place more rapidly than current models suggest
• The baseline should refer to current issues in the marine environment, and include marine resources as material assets
• Incorporating appropriate datasets to provide an accurate baseline in relation to green space (e.g. Scotland's Greenspace Map; Scottish Household Survey; Central Scotland Green Network (CSGN) priorities).

Predicted environmental effects of the Programme (Q6b)

9.6 Twenty-seven (27) respondents answered Question 6b. Of these, 19 (70%) said they agreed with the predicted environmental effects of the Programme as set out in the SEA and 8 (30%) said they did not. (Table 9.2.)

Table 9.2: Question 6b - Do you agree with the predicted environmental effects of the draft adaptation Programme, set out in the Environmental Report?

Respondent Type	Yes	No	Total
Conservation & planning			0
Education & research	2	1	3
Local authority & CPPs	10	4	14
NGOs	1	2	3
NHS or health-related	3	1	4
Other public bodies	1		1
Private sector	1		1
Transport	1		1
Individual respondents			0
Total	19	8	27
Total percentages	70%	30%	100%

9.7 Twenty (20) respondents (30% of all respondents) made comments at Question 6b. Some respondents described the predicted environmental effects set out in the SEA as "acceptable", "sensible" and "robust". Others expressed the view that, because the Programme was "vague" and "lacked detail", this made it difficult to assess whether the Programme would address the predicted environmental effects set out in the SEA. In addition, while it was thought that the policies set out in the Programme would have a beneficial effect for the environment, at the same time it was thought that the SEA over-stated the benefit of the Programme itself, since many of the policies included in the Programme were already in existence and being implemented.

9.8 Respondents made a range of other comments about the predicted environmental effects of the Programme, including for example, that:

• The potential negative impacts of the Programme were thought to be downplayed, and the potential for "unpredicted" or unintended effects were not acknowledged
• The challenge of implementation and the issue of funding were not addressed.

Recommendations in the Environmental Report (Q6c)

9.9 Twenty-five (25) respondents answered Question 6c. Of these 22 (88%) agreed with the recommendations set out in the SEA and 3 (12%) disagreed. (Table 9.3.)

Table 9.3: Question 6c - Do you agree with the recommendations set out in the Environmental Report?

Respondent Type	Yes	No	Total
Conservation & planning			0
Education & research	2	1	3
Local authority & CPPs	10	2	12
NGOs	3		3
NHS or health-related	4		4
Other public bodies	1		1
Private sector	1		1
Transport	1		1
Individual respondents			0
Total	22	3	25
Total percentages	88%	12%	100%

9.10 Twenty-one (21) respondents (31% of all respondents) made comments at Question 6c. In general, even where respondents indicated their agreement with the recommendations (by ticking "Yes"), they also made suggestions for improvements. For example, support was expressed for the recommendations made in relation to soil conservation, water quality and the resilience of the energy and food supply sectors. However, respondents wanted to see specific measures identified in the current Programme in relation to these issues so that appropriate action could be taken within the next Programme.

9.11 Respondents thought the recommendations would be strengthened by making them more specific and incorporating proposals / actions for taking them forward. They also wanted to see additional recommendations that would address:

• Rising sea levels and coastal erosion
• Water quality and quantity
• Shorter-term (as well as longer-term) impacts on landscapes and communities
• Future-proofing of climate mitigation strategies
• Future-proofing of critical infrastructure.

Proposals for monitoring the environmental effects of the Programme (Q6d)

9.12 Twenty-five (25) respondents answered Question 6d. Of these, 19 (76%) said that they agreed with the proposals for monitoring the environmental effects of the Programme and 6 (24%) said they did not. (Table 9.4.)

Table 9.4: Question 6d - Do you agree with the proposals for monitoring of the environmental effects of the draft programme set out in the Environmental Report?

Respondent Type	Yes	No	Total
Conservation & planning			0
Education & research	2	1	3
Local authority & CPPs	9	3	12
NGOs	1	2	3
NHS or health-related	4		4
Other public bodies	1		1
Private sector	1		1
Transport	1		1
Individual respondents			0
Total	19	6	25
Total percentages	76%	24%	100%

9.13 Eighteen (18) respondents (27% of all respondents) provided additional comments at Question 6d. Respondents welcomed the plans to monitor the effects of the Programme and agreed that monitoring for the SEA should be an integral part of the monitoring for the Programme. It was suggested that the monitoring of the SEA and the Programme may be further integrated with the monitoring of related plans, programmes and strategies and their associated SEAs as this would minimise duplication of effort.

9.14 In relation to monitoring, respondents also commented that:

• Current monitoring networks are a legacy of past initiatives or regulatory requirements and are not necessarily fit to measure the effects of present and future climate change. It was suggested that an additional policy on environmental monitoring could be added to the Programme, with a comprehensive plan to monitor environmental change.
• Arrangements for monitoring lack sufficient detail (e.g. identification of lead authorities, timescales, funding and co-ordination).
• The indicators used to measure the impacts and progress of the Programme should monitor both potential positive and negative environmental effects.
• As noted previously in Chapter 5, monitoring undertaken through voluntary citizen science initiatives should be encouraged, but should not be considered a substitute for professional monitoring.

Additional information to help inform the environmental assessment findings (Q6e)

9.15 Twenty-five (25) respondents answered Question 6e. Of these 19 (76%) indicated that they were not aware of any further environmental information that would help inform the environmental assessment findings, and 6 (24%) said they were aware of additional information. (Table 9.5.)

Table 9.5: Question 6e - Are you aware of any further environmental information that will help to inform the environmental assessment findings?

Respondent Type	No	Yes	Total
Conservation & planning			0
Education & research	2		2
Local authority & CPPs	9	3	12
NGOs		3	3
NHS or health-related	4		4
Other public bodies	2		2
Private sector	1		1
Transport	1		1
Individual respondents			0
Total	19	6	25
Total percentages	76%	24%	100%

9.16 Eleven respondents (16% of all respondents) made further comments in response to Question 6e. Some of those who responded "No" to Question 6e nevertheless made suggestions - along with those respondents who said "Yes" - about additional information that would help inform the SEA findings. The following sources of additional information were identified:

• Living with Environmental Change (LWEC) - in particular, the report cards on terrestrial biodiversity and water
• Adaptation Scotland (described as "a useful source of collated environmental information") and the adaptation tool hosted on Scotland's Environment Web (SEweb) portal
• Scotland's Greenspace Map; Scottish Household Survey; Central Scotland Green Network (CSGN) priorities; and Glasgow and Clyde Valley Green Network Opportunities Mapping (in relation to green space, as noted above in paragraph 9.5 above)
• Economics of Climate Resilience (ECR) project (which would provide a more detailed consideration of the environmental impacts of climate change)
• Marine information (annual report card published by the Marine Climate Change Impacts Partnership)
• Report by the Adaptation Sub-committee (in England) on "Managing the land in a changing climate - progress report 2013" - this is focus on England, but nevertheless provides recommendations that are useful to Scotland
• Findings from academic research - and it was suggested that government funding to universities or other research bodies for climate change research should be contingent upon the findings of that research being shared with public bodies.

Alternatives to the Programme (Q6f)

9.17 Twenty-seven (27) respondents answered Question 6f. Of these, 23 (85%) said they were not aware of other 'reasonable' alternatives to the Programme. Four respondents (15%) said they were aware of alternatives. (Table 9.6.)

Table 9.6: Question 6f - Are you aware of other 'reasonable' alternatives to the adaptation programme and its content that should be considered as part of the SEA process?

Respondent Type	No	Yes	Total
Conservation & planning		1	1
Education & research	2	1	3
Local authority & CPPs	12	1	13
NGOs	3		3
NHS or health-related	4		4
Other public bodies	1		1
Private sector		1	1
Transport	1		1
Individual respondents			0
Total	23	4	27
Total percentages	85%	15%	100%

9.18 Nine (9) respondents provided further comment in relation to Question 6f. This represents 13% of all 67 respondents.

9.19 None of the respondents proposed alternatives to the Programme. However, suggestions were made in relation to additions to its structure and / or content, including for example:

• Considering the potential benefits of a sectoral approach using the five themes of the UK CCRA Evidence Report. This was seen to provide a more practical basis for setting focused objectives and also more consistent with previous publications including the UK CCRA.
• Giving higher priority in the Programme to historic environment assets and cultural landscapes. While it appeared that the risks to these things had been identified in the SEA, it was not clear that they were adequately addressed in the Programme itself.
• Identifying climate analogues (i.e. using existing data to visualise what Scotland's climate might be like in the future and comparing this to climates experienced in other parts of the UK today).
• Using "foresight or scenario exercises" in relation to specific topic areas. For example, it was suggested the Defra website gave useful examples in relation to food security that could potentially be replicated in other areas.