Energy Efficient Scotland: strategic environmental assessment

This Strategic Environmental Assessment (SEA) investigates the likely significant effects on the environment by the implementation of the Energy Efficient Scotland programme.


7 Findings of the Assessment

7.1 Introduction

7.1.1 As discussed in Section 2, the assessment of the proposals involved three-stages. A detailed assessment of the individual policies and proposals (Stage 1) was initially undertaken and is set out in appendix C and D. This included an assessment of the milestones included with the proposal. This assessment was based on an assessment of the SEA objectives and criteria set out below (both positive and negative) of each policy and linked to the baseline data contained in Appendix A.

SEA Issues

SEA Objectives

Assessment Criteria

Biodiversity, Flora, Fauna

Conserve, protect and enhance Scotland's diversity of species, habitats and the natural heritage.

Protect and enhance of important habitats and connectivity.

Maintain and protect populations of European Protected Species, including their functioning habitat

Impact on diversity of species and habitats and their connectivity?

Impact on Designated Sites including Natura sites?

Protect or enhance green networks?

Soil

Maintain, protect and where possible enhance soil quality, geodiversity and carbon rich soils.

Impact on Carbon Rich Soils, Deep Peat and Priority Peatland Habitats?

Impact on the loss of prime agricultural areas (Class 1; 2 and 3.1)?

Impact on geologically designated features?

Impact on the carbon function of soils?

Water

To protect maintain and where possible and enhance the ecological status of the water environment.

Impact on the water environment?

Impact on potable water supply?

Potential flood impact?

Population and Human health

Work to eradicate fuel poverty

Work to reduce GHG which are harmful to human health

Reduce other environmental impacts which are harmful to human health

Impact on fuel poverty

Reductions in GHG as a result of the proposal

Impact on other environmental factors which impact human health

Air

Protect and improve, where possible, air quality across Scotland

Impact on national and local air quality requirements

Climatic Factors

Contribute to formal targets to reduce Green House Gas Emissions across Scotland

Reductions in GHG as a result of the proposal at both a national and local level

Cultural Heritage

To protect and where appropriate enhance the historic, built and cultural heritage.

Impact on loss of/ adverse impact on Scheduled Monuments and their setting and other archaeological sites?

Impact on Historic Gardens and Designed Landscapes?

Impact on Listed Buildings, Conservation Areas and other buildings of cultural significance?

Material Assets

Promote the sustainable use/reuse of all properties across Scotland to support sustainable development, reduce GHG emissions and make best use of this valuable resource

Impact on natural resources and material assets?

Minimise waste?

Mitigate impact on material assets?

Landscape

Protect our most scenic areas, reflect the importance of the interaction between people and the land, and aim to enhance areas where landscape qualities have been eroded over time

Impact on townscape features/setting.

Impact on Scotland's important landscapes, special qualities and character?

Impact on wild land?

7.1.2 The combined environmental effects were then considered (Stage 2)and the findings of this assessment stage are set out in the Summary Table below. The following key has been used:

⇧ Effects are positive overall for that environmental topic

⇕ Effects are mixed overall for that environmental topic

⇩ Effects are negative overall for that environmental topic

7.1.3 The accompanying narrative provides an over-arching and strategic analysis of the likely significant environmental impacts of each proposal. This includes the potential for cumulative and in-combination effects. (Stage 3).

Setting a Long Term Standard

Overall Significant Impacts

Population and Human Health

Climatic Factors

Material Assets

Biodiversity

Air

Cultural heritage

Landscape

Objectives of the Proposal

Improving energy efficiency in all buildings in Scotland

Support our work on eradicating fuel poverty

Reduce greenhouse gas emissions

Provide certainty and a clear direction of travel for building owners and business

Opportunities:

Opportunity to focus on households in fuel poverty who are some of our most vulnerable people

Build on the methodology underlying EPCs which provide a generally well understood model

Phasing in implementation to allow development in supply chain and skills development

Constraints:

Scale of task to target all properties in Scotland

Lack of baseline data on current energy efficiency of non-domestic sector

Effective communication will be required to demonstrate benefits of the proposal.

'Buy in' will be required to realise benefits.

Uncertainty in supply chain to meet early demand if high% take-up

Summary of findings

There is potential for broadly positive environmental effects. In particular, the setting of a long term standard could contribute to further reductions in GHG emissions ( climatic factors) by improving energy efficiency in buildings across Scotland, and thus reducing demand for fuel. The proposal aims to set milestones and end dates for compliance (subject to a review of progress) which will, in turn, drive the speed of works required by the standard, thus having a likely beneficial impact ( climatic factors, air, population and human health). There is potential for further benefits in improving flexibility of supply through energy efficiency measures installed to meet the standard ( material assets, population and human health) and reduced reliance on existing fossil fuel energy sources ( climatic factors). The ability to prioritise refurbishment over demolition will support the continued use of the existing building stock, thus having a positive impact on material assets.

There is potential for mixed or adverse effects associated with some aspects of the proposal, particularly those associated with development at a local scale. For example, the installation of energy efficiency measures could result in environmental effects, including impacts to biodiversity and air from construction activities and siting of developments, and visual impacts associated with retrofitting of measures to existing building stock. This is also the case with traditional and culturally significant properties ( cultural heritage). In the case of the former, specific environmental effects will be considered through the planning process such as Listed Buildings consent, and on a site by site basis, and the use of appropriate construction management measures such as Environmental Management Plans. In the case of the latter, the clarity provided regarding exceptions allows suitable mitigation.

Key findings

The introduction of a long term standard for all properties in Scotland is likely to have overall positive effects in contributing to meeting GHG emissions reduction targets. The extent of these benefits will depend on the level of take up of the measures. Directly linked to this, positive effects are therefore likely to air quality and population and human health.

Adverse effects on biodiversity are possible to be at a local level and will therefore require a local solution

EESSH

Overall Significant Impacts

Population and Human Health

Climatic Factors

Material Assets

Biodiversity

Air

Cultural heritage

Landscape

Objectives of the Proposal

Improving energy efficiency in all social housing in Scotland

Support our work on eradicating fuel poverty

Reduce greenhouse gas emissions

Provide certainty and a clear direction of travel

Opportunities:

Opportunity to focus on households in fuel poverty who are some of our most vulnerable people

Roll out experience gained from EESSH work already undertaken with some local authorities

Support for local authorities to allow public sector to act as exemplar

Constraints:

On-going concerns regarding some harder to treat properties and works in mixed tenure blocks Budgetary constraints over the life of the project

Requirement for Scottish Government's on-going role to drive this scheme

Summary of findings

There is potential for positive environmental effects. In particular, the setting of a 2032 standard and long term vision for 2040 could contribute to further reductions in GHG emissions ( climatic factors) by improving energy efficiency in the social rented sector across Scotland. The proposal aims to set milestones and end dates for implementation which will, in turn, drive the speed of works required by the standard, thus having a likely beneficial impact ( climatic factors, air, population and human health). There is potential for further benefits in improving flexibility of supply through energy efficiency measures installed to meet the standard ( material assets, population and human health) and reduced reliance on existing fossil fuel energy sources ( climatic factors). The ability to priortise refurbishment over demolition will support the continued use of the existing building stock, thus having a positive impact on material assets. The accelerated timeline for social housing (in comparison to other tenures) is also likely to have population and human health benefits, as it will improve the living conditions of those whose homes are affected.

There is potential for mixed or adverse effects associated with some aspects of the proposal, particularly those associated with development at a local scale. For example, the installation of energy efficiency measures could result in environmental effects, including impacts to biodiversity and air from construction activities and siting of developments, and visual impacts associated with the retrofitting of measures to existing building stock. This is also the case with traditional and culturally significant properties. In the case of the former, specific environmental effects will be considered through the planning process such as Listed Building consent, and on a site by site basis, the use of appropriate construction management measures such as Environmental Management Plans. In the case of the latter, the clarity provided regarding exceptions allows suitable mitigation.

Key findings

The roll out of the standard for social housing across Scotland is likely to have overall positive effects in contributing to meeting GHG emissions reduction targets. Directly linked to this, positive effects are therefore likely to air quality and population and human health.

Adverse effects on biodiversity are likely to be at a local level and will therefore require a local solution

LHEES

Overall Significant Impacts

Population and Human Health

Climatic Factors

Material Assets

Biodiversity

Air

Cultural heritage

Landscape

Objectives of the Proposal

Create a localised approach to the implementation of energy efficiency and heat decarbonisation measures on a local authority scale across Scotland

Support our work on eradicating fuel poverty

Reduce greenhouse gas emissions

Provide certainty and a clear direction of travel

Opportunities:

Opportunity to focus on households in fuel poverty who are some of our most vulnerable people

Build on pilots undertaken across Scotland

Create clarity in delivery timelines

Support investment in the Scottish supply chain

Constraints:

Ensuring local authorities have adequate resource

Consistency of approach across different local authorities.

Ensuring local supply chain remain involved and are appropriately skilled.

Effective communication required throughout.

Guarantee that minimum standards apply in terms of work carried out.

Adequate consumer protection framework in place (within context of Consumer Protection as a reserved issue)

Summary of findings

The impact of regulations to require the role out of LHEES is likely to have broadly positive with an acceleration of improvement in energy efficiency across Scotland, with particular focus likely on larger projects. This should result in a reduction in GHG emissions( climatic factors) with secondary benefits through improved human health, and air quality.

The roll out of LHEES is likely to have a mixed impact on material assets affected by the strategies and the installation of energy efficiency measures is recognised as having an impact on some biodiversity, Further, at a local scale, the installation works may have impacts associated with nuisance, including noise, dust, and visual impact. However these are likely to be short term in nature, and can be mitigated with careful use of construction management planning.

Similarly, provisions within regulations and guidance should recognise and respond to give assurance that interventions to buildings in general and particularly those of cultural significance and traditional buildings generally are only specified and undertaken after full consideration of the likely impact on the building.

Key findings

The roll out of the requirement for a LHEES is likely to have overall positive effects in contributing to meeting GHG emissions reduction targets.

Positive effects are also likely for population and human health and climatic factors

Adverse effects at a local level will require a local solution

District Heating Regulation

Overall Significant Impacts

Population and Human Health

Climatic Factors

Material Assets

Biodiversity

Air

Soil

Cultural heritage

Landscape

Water

Objectives of the Proposal

Reduce greenhouse gas emissions

Provide certainty and a clear direction of travel

Create a clear regulatory framework to manage the growth of district heating

Opportunities:

Provide clarity in requirements to allow development in supply chain

Confirm Scottish Government support for growth in the district heating sector

Constraints:

Ensuring local authorities have adequate resource

Consistency of approach across different local authorities.

Ensuring local supply chain remain involved and are appropriately skilled.

Effective communication required throughout.

Guarantee that minimum standards apply in terms of work carried out.

Adequate consumer protection framework in place (within context of Consumer Protection as a reserved issue)

Summary of findings

There is potential for broadly positive environmental effects from the creation of a regulation to manage district heating across Scotland. In particular, the creation of a regulatory system and the resulting growth in installation of district heating across new and existing developments in Scotland will reduce reliance on the existing heating supply network which relies on diminishing fossil fuels. Further, this will contribute to further reductions in GHG emissions ( climatic factors) by installation of improved energy efficient heating systems. Appropriate siting of district heating systems could have local environmental benefits where heat is supplied from a low or zero emission source that replaces fossil fuel generation, with the potential to improve air quality.

The proposal aims to grow this part of the energy generating supply chain, reducing reliance on centralised systems. thus having a likely beneficial impact ( climatic factors, air, population health). There is also potential for further benefits in improving flexibility of supply through district heating ( material assets, population and health).

There is potential for adverse effects associated with some aspects of the proposal, particularly those associated with development at a local scale. For example, the installation of district heating network infrastructure such as pipes could result in environmental effects, including impacts to biodiversity, soil, and material assets from construction activities and siting of developments.

The long term operation of district heating schemes, at a local level, may also have a mixed impact. Supply of sustainable materials to be used in biomass systems may have negative impacts, and must be sourced sustainably. This may also be the case with those systems using water as an operating resource. Specific environmental effects will be considered through the planning process, Environmental Impact Assessment ( EIA) and Habitats Regulations Appraisal ( HRA) and on a site by site basis, the use of appropriate construction management measures such as Environmental Management Plans.

Key findings

The regulation of district heating is likely to have overall positive effects in contributing to meeting GHG emissions reduction targets when heat is generated from low or zero emissions sources. Positive effects are also likely for air quality and climatic factors. The reduction in reliance on fossil fuel for heating will have multiple benefits

Adverse effects at a local level will require a local solution

7.2 Summary of Likely Environmental Impacts – Long Term Standards (including social housing - EESSH)

Primary Environmental Effects

7.2.1 The proposal of setting a long term standard for all properties across Scotland is likely to reduce GHG emissions and have positive impacts on climate change objectives. As the basis for this proposal relates directly to improving energy efficiency it is expected to have significant benefits for climatic factors given the contribution energy production and use makes to Scotland's GHG emissions [48] .

7.2.2 The proposal aims to set milestones and end dates for compliance (subject to review) which are expected to have direct positive impacts on the take up of energy efficiency measures, and so, for climatic factors, air quality and population and human health.

7.2.3 As part of the wider programme, this proposal in combination with the other parts of the Programme provides a significant opportunity to generate cross-cutting benefits across sectors. For example, investment, regulations and incentives through the Programme as a whole should help to reduce demand for energy and improve energy productivity. This could lead to a significant reduction in GHG emissions across the services, residential and industry sectors.

7.2.4 Localised adverse effects associated with the setting of a standard could be felt by biodiversity and air factors, primarily through construction phases. However the short term nature of these impacts is considered acceptable when compared to the overall benefits achieved.

7.2.5 Direct adverse effects may also result in traditional and culturally significant buildings, but the proposal does seek to identify and recommend suitable measures for this building stock. Further details would also be required on a site by site basis, through normal planning process.

Secondary Environmental Effects

7.2.6 Potentially secondary impacts have been identified from the proposal including further benefits in improving flexibility of supply through energy efficiency measures to meet the standard and reduce reliance on fossil fuel energy sources. The displacement or reduction of energy generated from traditional energy sources, and the provision of warmer, more energy efficient and energy secure housing stock will have positive effects including significant health benefits, and the Programme aims to target those in fuel poverty as a priority [49] .

7.3 Summary of Likely Environmental Impacts – LHEES

7.3.1 Primary environmental effects The strategic nature of LHEES to energy efficiency provides an opportunity to maximise benefits that may not be realised by a piecemeal incremental approach. This local approach builds on experience found in recent pilots and has been informed by recent consultation on the approach.

7.3.2 Improving the energy efficiency of Scotland's homes and buildings in the commercial, public and industrial sectors was recognised as a National Infrastructure Priority in 2015 [50] . Many of the benefits of a local authority scale approach gives focus to pragmatic installation and investment decisions, which will ensure the achievement of the objectives of the Programme.

7.3.3 At a local level, It is expected that the roll out of LHEES across Scotland is likely to have mixed impacts. In particular the installation of energy efficiency measures is recognised as having an impact on some biodiversity which can be managed or mitigated through licensing processes or site specific environmental management measures.

7.3.4 The installation of energy efficiency measures may have impacts associated with nuisance, including noise, dust, and visual. However these are likely to be short term in nature, and can be mitigated with careful use of construction management planning and dialogue with neighbours.

7.3.5 Further, there is potential for adverse effects associated with some aspects of the proposal, particularly those associated with development at a local scale. For example, the installation of energy efficiency measures could result in environmental effects, including impacts to biodiversity and material assets from construction activities and siting of developments. Supply of sustainable materials to be used in biomass systems may also have negative impacts, and must be sourced sustainably. Specific environmental effects will be considered through the planning process, and on a site by site basis, the use of appropriate construction management measures such as Environmental Management Plans.

Secondary Impacts

7.3.6 As above, benefits are expected in improving flexibility of supply through energy efficiency measures and reduce reliance on fossil fuel energy sources. The displacement or reduction of energy generated from traditional energy sources, and the provision of warmer, more energy efficient and energy secure housing stock will have positive effects including significant health benefits, and the Programme aims to target those in fuel poverty as a priority improving flexibility of supply through energy efficiency measures to meet the standard and reduce reliance on fossil fuel energy sources.

7.4 Summary of Likely Environmental Impacts – District Heating regulation

Primary environmental effects

7.4.1 It is expected that the introduction of regulations to manage district heating will have broadly positive environmental effects. In particular, the creation of a regulatory system and the resulting growth in installation of district heating across new and existing developments in Scotland will reduce reliance on the existing heating supply network which relies on diminishing fossil fuels. Further, this will contribute to further reductions in GHG emissions (climatic factors) by installation of improved energy efficient heating systems and of low and zero emissions heating sources.

7.4.2 There may be some localised adverse effects associated with some aspects of the proposal, particularly those associated with development at a local scale. For example, the installation of district heating network infrastructure such as pipes could result in environmental effects, including impacts to biodiversity, material assets and soil from construction activities and siting of developments. Supply of sustainable materials to be used in biomass systems may also have negative impacts, and must be sourced sustainably. Specific environmental effects will be considered through the planning process and proposed district heating consenting framework, and on a site by site basis, the use of appropriate construction management measures such as Environmental Management Plans. It is also noted that, at this level, every opportunity should be made to develop district heating schemes in combination with other major infrastructure projects.

7.4.3 As heat represents over half of all energy use in Scotland, heat efficiency measures will play a significant role in the reduction of energy use. Heat is integral to many industrial processes and there is potential for significant carbon savings from employing technologies and systems that recover excess heat from industrial processes [51] .

7.4.4 It could also help to incorporate energy storage within community and local energy generation projects to optimise local energy systems [52] . The delivery of smart local energy systems, focused on local needs should therefore help to optimise demand and increase energy efficiency across the network, and so secondary environmental benefits could be expected.

7.4.5 There is an opportunity to explore the potential deployment of new emerging energy sources and technologies, some of which have the potential to make a significant contribution to reducing GHG emissions. By supporting and exploring opportunities for new energy sources and technologies, including through demonstration projects, the growth of district heating has the potential to aid their future deployment and use, with likely reductions in GHG emissions. These may have mixed impacts on water resources and in particular emerging technology associated with the use of minewater is significant. Whilst embryonic, this uses of underground water resources, both as a low carbon source of heat, and also as a heat store from alternative sources of heat production, for example, heat from waste, are noteworthy. These will require detailed assessment at a project level but this assessment recognises the potential impacts.

Secondary Impacts

7.4.6 District heating projects will have some level of infrastructure requirements, whether for large-scale deployment or for local generation. In some instances, existing infrastructure may be reused. New infrastructure is also likely to be required. There is potential for environmental impacts associated with many such works that will require careful planning and management through applicable consenting regimes.

7.5 Summary of the Assessment Findings

7.5.1 The following sets out potential cumulative and in-combination effects likely to arise from the proposal. The findings have been informed by the previous stages of the assessment process.

+

Potential for positive environmental effects

-

Potential for negative environmental effects

+/-

Potential for mixed environmental effects

0

Potential for environmental effects has not been identified

Assessment question

LTS

EESSH

LHEES

DH

cumulative

In combination

Will the proposal contribute to meeting Scotland's climate change commitments?

+

+

+

+

+

+

Will the proposal contribute to the reduction in carbon generated as a result of energy use?

+

+

+

+

+

+

Is the proposal likely to improve air quality and human health?

+

+

+

+

+

+

Will the proposal have implications on infrastructure?

+/-

+/-

+/-

+/-

+/-

+/-

Is the proposal likely to have indirect or secondary environmental effects?

+/-

+/-

+/-

+/-

+/-

+/-

Can these potential effects be effectively managed, mitigated or enhanced?

+

+

+

+

+

+

Have alternatives to the proposal been considered in this assessment?

+

+

+

+

+

+

7.5.2 Regarding the impact the proposals will have on contributing to meeting Scotland's climate change commitments, all are expected to make a significant contribution to the reduction in GHG emissions. The proposals will work in combination and in a cumulative way to optimise their effects. For example measures to promote energy efficiency in residential and business sectors will be complemented by work on heating systems, and by work being carried out by local authorities to take a strategic view of emissions and efficiency measures within their geographical boundaries.

7.5.3 Regarding the impact the proposals will have on reducing carbon generated as a result of energy use, all are expected to make a contribution to reducing demand for energy through improved efficiency measures. Individually the setting of standards will drive improvements in efficiency in individual properties, setting milestones for compliance. Combined with this, work to promote and regulate district heating will improve efficiencies on a community wide scale, while the role out of LHEES will ensure local authority wide strategic decisions drive larger scale decisions on efficiency and emissions. Measures to promote district wide measures will help displace energy generated from traditional sources, reduce demand and pressure on existing networks and ensure greater flexibility, thus improving security of supply. In combination improvements in energy efficiency of housing stock, reducing energy demand and consumption and improving the resilience of energy infrastructure will all contribute to this.

7.5.4 Regarding the likely improvements in air quality and human health the proposals are likely to have a significant benefit to air quality in Scotland, with resultant benefits for human health. Air pollution often originates from activities that contribute to climate change, notably energy generation, and poor air quality can have implications for human health. Reducing emissions from energy generation is therefore likely to improve the air quality at a local and national level and proposals to promote the decentralisation of energy are likely to have overall benefits. All proposals have, at their heart, an objective to improve energy efficiency and this should be beneficial to human health at a local and national level, and could be particularly significant for vulnerable members of society with existing health complications such as respiratory issues. Further benefits are also likely through increasing energy efficiency in housing stock, making buildings more resilient to predicted effects of climate change

7.5.5 Regarding the likely impacts of the proposals on infrastructure, construction activities arising from improvements to existing building fabric may result in short term negative effects, most likely related to nuisance such as noise, dust, vibration, or visual impact. These are, however, likely to be localised and temporary. In many instances any adverse impacts may be mitigated through a combination of appropriate siting and design, local consultation and engagement, and on-site management measures. The overarching ambition of the proposals is to improve energy efficiency at the point of use and to reduce overall energy demand. If widely implemented, this should reduce pressure on existing energy infrastructure and help to optimise the use of energy resources. There will be a need for greater flexibility and appropriate infrastructure to facilitate a transition to a decarbonised energy sector.

7.5.6 Regarding the likely indirect or secondary environmental effects resultant from the proposals, there are a number of potential negative impacts that may arise as a result of construction and development work, and physical works to infrastructure. In some circumstances operational activities such as those resulting from noise disturbance arising from heat pumps, may be long term [53] . The installation of energy efficiency measures on existing domestic and non-domestic building stock could also have adverse effects. For example, where this involves work to the fabric of buildings there is potential for impacts on buildings of historic and cultural significance. In some circumstances, this could also have visual, landscape and/or townscape effects. Specific works, such as those on roofs or in roof cavities, may also have the potential for negative effects on biodiversity. Secondary benefits are also likely to arise on a range of environmental topics through the predicted reduction in GHG emissions. Climate change has been identified as a primary pressure on many environmental receptors including water and biodiversity. As such, it is likely that the implementation of the draft Plan and draft Strategy will help to reduce the pressures of a changing climate.

7.5.7 Regarding the means by which potential effects can be of effectively managed, mitigated or enhanced, the ambitions of the proposals are to meet Scotland's climate change commitments whilst improving energy efficiency and reduce GHG emissions. They are also likely to have beneficial impacts for adapting to and improving resilience to the predicted effects of climate change. Reducing demand for energy is a key component of both, and if widely implemented, should help to manage Scotland's energy systems more effectively, and reduce the need for additional energy and associated infrastructure. While there will be clear benefits, the potential for adverse environmental effects were also noted. In particular, adverse effects could arise from the development of new, or the upgrade of existing infrastructure. The potential for negative impacts on some aspects of the built environment was also noted. In particular, specific impacts will arise from retrofitting older buildings to improve energy efficiency, including undertaking works in roof spaces and attics. Existing mechanisms such as the planning process, EIA, HRA, and regulations relating to the management of protected species, will manage the potential for environmental effects prior to works commencing.

7.5.8 The area based nature of aspects of the Programme such as LHEES will also help to mitigate this potential impact through the consideration of cumulative impacts. This will be particularly relevant in areas that are designated for their cultural heritage. The potential for adverse impacts from the construction and operation of new energy developments will be further managed through the use of appropriate design and construction management measures at the project level. This should include, where appropriate, Environmental Management Plans. Existing regulatory regimes should ensure that any development projects will be subject to appropriate controls, minimising the potential impacts of activities and infrastructure. The assessment also identified a need for consideration to be given to the sources of heat used in district heating systems, and that some technologies can have negative implications at both the point of use and in the supply chain. For example, care should be taken in ensuring that the production of feed stocks for biomass is able to meet demand, and that the sourcing and management of any feedstocks used is undertaken sustainably, and that wherever possible, low or zero emission sources of heat are used.

7.5.9 Regarding the consideration of alternatives, a suite of critical success factors have been established for all aspects of the Programme, and all individual proposals and projects are assessed against these to quantify alternatives and score those accordingly. Set out in 5.7, this assessment has refined the options and come to a proposed way forward.

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