The future of energy in Scotland: consultation analysis

7. Environmental Report

7.1. Views were invited on three questions concerning the Strategic Environmental Assessment ( SEA) Environmental Report.

7.2. Responses were received from the SEA consultation authorities - Scottish Environmental Protection Agency ( SEPA), Scottish Natural Heritage ( SNH) and Historic Environment Scotland ( HES) - individuals, third sector / NGO groups and organisations in the Local Government sub-group.

7.3. A summary of responses from individuals, third sector / NGO groups and organisations in the Local Government sub-group are outlined below. More detailed responses from the SEA consultation authorities are included in a summary box at the end of each question in this section.

Accuracy and scope of information

Q18: What are your views on the accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report? (Please give details of additional relevant sources)

7.4. Only 13 respondents provided any commentary to this question; 5 of these were Individuals.

7.5. Two respondents in the Third Sector / NGO group felt that the current draft Energy Strategy is weak on environmental / biodiversity issues including spatial impacts.

7.6. An organisation in the Local Government sub-group noted that the accuracy and scope of the SEA are reasonable for its purpose, and a Community based organisation that this is a reliable document.

7.7. Of the responses from Individuals, one respondent commented that they did not agree with the baseline; another that the baseline pays insufficient attention to the need for renewable energy generated to meet demand or to consider energy footprint and energy consumption.

7.8. Another Individual felt that the SEA focuses on the uptake of renewable energy or decarbonisation but the Strategy also focuses on other sources such as continuing to support North Sea oil and gas and CCS development.

7.9. A respondent from the Academia / Research / Training group said they were unable to access this document while one from the Local Government sub-group said poor signposting had meant they had not responded to the SEA questions ^[4] .

Summary of the SEA consultation authorities' responses to Question 18:

All three Consultation Authorities were content with the accuracy and scope of the baseline material used in the Environmental Report.

HES highlighted their own published guidance which can help to ensure a number of policies identified in the draft Energy Strategy are implemented without impacting negatively on the Historic Environment.

Predicted environmental effects

Q19: What are your views on the predicted environmental effects as set out in the Environmental Report?

7.10. Only 16 respondents, 11 of which were Individuals, commented on this question.

7.11. While there was agreement with the predicted environmental effects as set out in the Environmental Report, there were also some qualifying comments.

7.12. An organisation in the Renewable sub-group commented that for these to be achieved, there needs to be strong policy support and that this needs to be recognised in the SEA.

7.13. A Local Government organisation felt that while the predicted environment effects are reasonable, any assessment needs to be carried out in the context of socio-economic benefits. They also commented that: "Fragile communities live and work in the areas of best wind resource and their human interests should be a factor in decision making".

7.14. One Individual noted that the Environmental Report focuses on renewable energy but that there should be flexibility with the scope and environmental effects as more information becomes available and as the Energy Strategy is actioned at a project level.

7.15. Another Individual felt that the predicted environmental effects are understated as the draft Energy Strategy does not consider / mention:

• the embedded energy and related emissions from exports and;
• water usage from CCS

Summary of the SEA consultation authorities' responses to Question 19:

All three consultation authorities were generally content with the predicted environmental effects.

Both HES and SNH felt that the assessment would have benefited from a more nuanced approach to the potential for negative and positive effects to arise from the draft Energy Strategy: For example, the potential for negative impacts from the retro-fitting of energy efficiency measures to traditional or historic buildings, and the risk that not all biomass feedstocks would be produced sustainably was noted. The reuse of infrastructure was supported, and the recognition of the potential for new effects on heritage assets and their setting from actions to meet the new target for generating electricity from renewables was also welcomed. In particular, the potential for negative effects to arise from larger onshore wind turbines was noted.

SEPA considered that the summary tables in the Environmental Report were useful, and felt that it would have been beneficial for these tables to have set out the full range of effects. Further they suggested the summary tables be revisited and included in the Post Adoption Statement, in addition to being used for monitoring and future strategy review exercises. SEPA also noted that a number of uncertainties were set out in the Environmental Report with regard potential impacts and that these would benefit from further consideration during the finalisation of the draft Strategy. In particular, they considered that issues that would benefit from the drawing out of specific impacts and areas of uncertainty at a strategic / national level include CCS, biomass, network management and infrastructure management. Whilst SEPA recognised that it may not be possible to specifically address these issues at present, they felt that it would be helpful for the Post Adoption Statement to highlight these important strategic considerations and uncertainties to ensure that they are effectively monitored and addressed as future details emerge.

Mitigation and monitoring of the environmental effects

Q20: What are your views on the proposals for mitigation and monitoring of the environmental effects set out in the Environmental Report?

7.16. Only 18 respondents, across a range of sub-groups but including a few Individuals, commented on this question and most reiterated points made to earlier questions or noted their support for the Strategy as a whole.

7.17. A Public Sector / Delivery Agency / Regulator respondent agreed with the conclusion that many of the effects identified will be mitigated through existing mechanisms.

7.18. Two Individuals were concerned that the proposals for mitigation and monitoring environmental effects are inadequate.

Summary of the SEA consultation authorities' responses to Question 20:

SEPA were of the view that further clarity on where responsibility lies for specific mitigation should be provided in the Post Adoption Statement. They also highlighted that some identified effects will require strategic consideration, especially ones that are not covered by planning or other regulation at the local level. They recommend that the Post Adoption Statement provide clarification on how the data produced from the proposed monitoring mechanisms will be used in monitoring the environmental effects of the strategy.

HES considered there was scope for a more nuanced assessment of potential negative and positive impacts. However they welcomed the recognition in the assessment findings that the installation of energy efficiency measures have the potential to have an adverse impact on traditional buildings and their character, having noted that this consideration was missing in other sections of the Environmental Report. Further, they noted that it will be important for the final Strategy to recognise that impacts arising from sectors will also require to be addressed as part of the relevant decision making processes, including Environmental Impact Assessment.

SNH recommended that a programme of awareness raising among contractors be developed to reduce disturbance to bats.