Strategic Environmental Assessment (SEA) of the Scottish Climate Change Bill: Consultation Proposals: Environmental Report

7. Recommendations for Mitigation and Enhancement

7.1 Maximising Environmental Gain in the SCCB

7.1.1 The previous assessments show that the proposed SCCB and measures likely to be implemented as a result of it, will generally promote significant environmental benefits. However care must be taken with legislation that deals with an environmental topic, as benefits will not be uniform and conflicts can exists across the environmental spectrum. Policies and action on reducing emissions will not necessarily be benign across all aspects of environmental media.

7.1.2 Annex 1 of the SEA Directive requires the Environmental Report to include measures to prevent, reduce or offset any significant adverse effects. Many of the environmental effects identified in this report are likely to be as a consequence of measures which may be brought forward as a result of the Bill, rather than a direct result of SCCB proposals, as any environmental effect will largely depend on the nature of the measure implemented. The recommendations here refer to such indirect effects of the Bill. Many of these measures were first mentioned in the assessment tables ( Section 5) and have been further expanded on below in Section 7.2.

7.1.3 The following key points are important to note for future considerations of emissions reduction measures implemented under the Bill:

• Take account of the inter-dependencies of different aspects of the environment.
• Recognise the long term threat of climate change to the environment when making difficult decisions about environmental trade offs, but also that carbon reduction should not come at any cost; environment effects should be carefully considered.
• Apply long term thinking to problems as well as identifying quick wins; for example, investment in research and development may help identify long term solutions.
• More coordinated and better-integrated inter- and intra- sectoral action is required, as well as working towards policy harmonisation throughout and between Governments.
• Environmental, social and regulatory assessments may be needed at all stages of implementation (for example SEA, EIA, RIA, HIA, EqIA).
• The consequences of climate change are global, and could be catastrophic in nature. There is a growing need to reduce emissions, adapt to changes that are already happening and plan and prepare for other expected climate change effects (such as potential GHG release from Scottish soils). Over time, climate change adaptation and emissions reduction is more likely to require an integrated approach.

7.2 Mitigation and Enhancement by SEA Topic

7.2.1 The following section discusses potential prevention, reduction and offset measures for the significant adverse effects identified in Section 6. Some of these recommendations are within the remit of the Scottish Government while others presently are not. However they are included here as it is important to develop an understanding of where change needs to occur, such that the Scottish Government can seek to influence change, and also to understand what measures are needed from other public bodies, such that influence and guidance can be directed.

7.2.2 Comments presented below reflect the independent conclusions of the consultancy team.

Climatic Factors
(Annex 1 of the SEA Directive requires Climatic Factors to be assessed as a topic in its own right)

• Scotland holds roughly 0.1% of the world's population, but accounts for around 0.2% of global CO2 emissions, which is a disproportionate amount. Meeting the 80% target will have no real impact on climate unless other countries follow the example set. Although all reductions are important, regardless of source location, the more sustainable and responsible approach would be to drive action to meet the proposed SCCB target through domestic reductions, as far as possible, with mechanisms to credit Scotland's emissions overseas employed only to address the most difficult emissions to remove. Should other countries follow this example, and substantially limit their domestic emissions, then there may be real positive impacts on global climate change.
• It is vital that the SCCB drives integrated, cross-sectoral policy making and review at all levels, where potential conflicts with the target are identified and resolved, such that all policies work towards emissions reductions, limiting conflicts. A key factor will be effective resourcing for monitoring strategies that actually drive remedial action and review. Collecting data and commitments to monitoring must be augmented with the ability to take corrective action.
• The 80% reduction target should drive measures in Scotland to improve energy efficiency, reduce fossil fuel use and phase out high carbon processes.
• Reporting on actual emission levels and reductions should be encouraged. Credits and capped allowances should be counted, however to maintain transparency, these should be clearly distinguished from actual reductions.
• Introducing measures to report action and progress towards targets must be augmented with recommendations that suitable SEA/ EIA and Life Cycle Assessments are employed to ensure that the most sustainable carbon and energy choices are made, in consideration of wider environmental implications and mitigation of impacts on other environmental receptors.
• To deliver SCCB targets, the measures discussed in the Scottish Climate Change Programme (2006) document should be reviewed to go further and newly developed policies should include commitments on emissions and identified reduction measures.
• Action to meet targets set by the SCCB should take account of, and drive adoption of, the adaptation strategies discussed in the Potential Adaptation Strategies for Climate Change in Scotland (2001) report and in any new Scottish Adaptation Strategy. As a guiding principle, adaptation measures should not increase emissions.
• An integrated rural strategy for Scotland, facilitating greater integration between land managers, public bodies and support mechanisms, could help drive appropriate coordinated action that improves soil and natural heritage management whilst limiting land use GHG emissions.

Biodiversity, Flora and Fauna

• The SCCB should drive suitable and appropriate action on renewables but not without due regard for biodiversity. Any action taken to meet SCCB targets should be mindful of potential impacts on natural habitats and the adaptation of habitats and species to changing climate. Best practice must be employed during renewables construction in order to minimise impacts on biodiversity. Appropriate EIA, which follows location guidance, should help minimise disturbance.
• Biodiversity breaks, inter-cropping and uncultivated boundary regimes should be a central focus when developing biomass resources. Moving to suitable woody biomass, or woodland pasture, with the provision of appropriate habitat connections will help facilitate species migration. Options for land use change to biomass production should be subject to appropriate EIA.
• The EU Habitats Directive (92/43/ EEC) can have a major influence on the development process and could represent a constraint on emissions reduction measures driven by the SCCB. Adequate consideration of impacts affecting biodiversity should be considered at all levels, from strategic planning to project management and appropriate EIA/ SEA/ AA should help.
• The Scottish Forestry Strategy highlights the potential for forestry to make a significant contribution to mitigating and adapting to climate change over the coming decades. Action to meet SCCB targets should encourage measures including afforestation, biomass use, increased use of wood for construction, and reducing timber miles. However, these must be advised by appropriate assessments of impacts upon other environmental receptors, including biodiversity, long-term soil quality, the water environment and cultural heritage.
• Care should be taken to ensure that schemes such as tree planting only occur in appropriate habitats and with appropriate species where great care is taken to understand local conditions. Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing local biodiversity effects to avoid impact transference.
• Long-term thinking and planning actions will avoid short-term reactionary measures that could seriously impact biodiversity resources.

Water

• Options for land use change to biomass should be subject to appropriate EIA, assessing impacts on local water environments. Measures are included within the Biomass Action Plan, which must be properly adhered to and evaluated.
• Similarly, any action to improve the emissions impact of Scottish agriculture, advised by the upcoming sectoral Climate Change Action Plan, should help improve water environments by having a knock-on effect in reducing diffuse pollution effects. Agricultural best practice mitigation is required throughout the life cycle of biomass production. Riparian zones and uncultivated field borders should protect water environments. Biomass production should not exacerbate intensive agriculture/ diffuse pollution/ fertiliser emissions.
• Provisions and actions brought forward as a result of the SCCB should not contribute to deterioration in water quality or lead to targets being missed e.g. compromise the number of water bodies reaching "good ecological status", targeted under the EU Water Framework Directive. This includes all scales and forms of hydro-generation projects. Consent applications for hydro projects must be accompanied by suitable assessments of low flow effects and impacts on ecology. Short term project mitigation and best practice is required to avoid construction impacts.
• Systemic water leakage should be addressed as a priority measure to improve energy efficiency and water resource efficiency. Education must reinforce linkages between water use/ efficiency and energy use/ efficiency.
• Careful testing and research needs to be undertaken to understand water resource effects before carbon storage is implemented.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing localised effects on water environments to avoid transference.
• The upcoming Flooding Prevention Bill may help address domestic adaptation strategies.

Air Quality

• Appropriate technology selection, based on life cycle analysis, EIA and the energy efficiency hierarchy should drive the introduction of combined technologies such as anaerobic digestion, gasification and CHP over purely electricity from direct waste incineration. Long-term carbon accounting and maximising fuel efficiencies should direct investment choice, rather than short term cost considerations.
• Air quality impacts of biomass/ waste combustion projects should be scrutinised appropriately through EIA and controlled through existing local air quality and pollution control regimes. CHP requires real heat recovery and use to maximise energy efficiencies. These issues apply even at the microgeneration scale.
• The SCCB target could help drive action on other environmental quality targets, by encouraging greater action on transport, waste management and other potentially polluting activities. Overall commitment to air quality should be taken into account, particularly in terms of potential influence of land use decisions, specific contributions of the transport sector and local air quality implications of energy choices. In particular, there is a need to focus on reducing vehicle use in order to improve air quality in Scotland's urban centres.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing local air quality effects to avoid impact transference. Programmes that improve local air quality by reducing emissions from existing industrial plants and transport should be a high priority.

Human Health

• Increasing healthcare needs and tourism numbers suggest priority for micro-renewables support for health and tourism facilities to reduce demand on primary energy production.
• Consent or grant applications for community heating, CHP, energy from waste or combustion projects should be accompanied by a suitable assessment, possibly a Health Impact Assessment, of air quality and human health effects.
• Financial incentives are required to drive energy efficiency improvements within older properties and to encourage widespread uptake. Individuals may not take action if initial costs are prohibitive. Energy efficiency incentives could also limit the impact of fuel poverty on high risk groups.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing local health effects to avoid impact transference. Projects need to take account of local health needs and take great care not to adversely affect the conditions of the local population who may often already be living in extreme poverty.
• Government should promote the long-term health benefits of moving to low carbon systems and limiting all GHG emissions, including transport emissions.

Population

• Energy efficiency and demand reduction present the best opportunities for reducing emissions in the short-term; however changing end user behaviour is difficult as it is not purely technical in nature. Efficiency initiatives must be accompanied by effective education to ensure people are informed and are aware of the cost and environmental benefits of efficient use.
• Significant investment in education is required, at all levels, to encourage personal responsibility and realise behavioural change. Opportunities to incorporate effective energy awareness amongst business leaders and senior managers will encourage buy-in at employer levels and develop an organic cascade of efficiency measures/ messages from the top-down.
• Financial costs associated with chosen emissions trajectories must be spread equitably and the polluter pays principle should be applied, with provision made for those in hardship and fuel poverty. Health Impact Assessment, Sustainability Assessment, Equality Impact Assessments should be utilised to ensure energy efficiency measures, implemented under the SCCB, are targeted effectively at low income and vulnerable groups. Future domestic trading schemes must not disadvantage those who are unable to afford, or have access to measures, or inadvertently impact upon vulnerable members of society, such as the elderly or disabled.
• Product prices must evolve to incorporate energy and embodied carbon costs to encourage behaviour change. Life cycle assessments and energy ratings for all consumer products should become the norm, with inefficient products and those with high embodied carbon phased out.
• Financial mechanisms are required to reduce vehicle use or stricter standards imposed on manufacturers to improve fuel efficiency, as voluntary modal shift is unlikely to deliver the high, long-term and continued savings required.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing effects on local populations to avoid impact transference. CDM must ensure transfer does not lead to local environmental degradation or have a negative impact on the local population, and their livelihoods, as many communities already live in extreme poverty. Ideally, transfer is based around the principles of sustainable livelihoods and long term, may lead to enhanced opportunity and new local industry.

Soil

• SPP6 and SNH provide location guidance for renewable energy developments, which should be strictly adhered to in order to avoid increasing risks of high carbon soils GHG release. Existing planning regime should offer protection to sensitive/ protected habitats, however soil issues and potential for increased GHG emissions should be expressly considered through EIA and in planning decisions for large installations or community sites.
• At the microgeneration scale, the planning regime could be reviewed to allow easier integration of measures not covered by permitted development. Cumulative soil impacts may be limited by providing additional guidance on positioning microgeneration technologies.
• SCCB targets and the Biomass Action Plan for Scotland (2007) should help encourage appropriate development of the biomass sector. Options for land use change to biomass should be subject to appropriate EIA and provide a suitable assessment of impacts on the local soil environment, as a condition of relevant grant criteria. Life-cycle assessments of the land use change would help identify the most sustainable options.
• Carbon sequestration in soils offers part of the long-term solution but may be impacted negatively by increasing temperature and droughts resulting in net emissions from peats. Requires appropriate evidence base and active habitat management to minimise risks.
• Hard standings and soil sealing for new infrastructure should be minimised as far as possible, with an increased emphasis on brownfield redevelopment. Any new development should incorporate SUDS systems to minimise the impacts of soil sealing as well as appropriate development EIA, planning and best practice measures.
• Promote the processing of waste soils and soil materials into secondary aggregates. Encourage the recovery of waste soil material as opposed to disposal and primary extraction at all opportunities.
• There is a need for Scottish agriculture to adapt and manage the risks associated with climate change and to make its contribution to mitigation. Actions to meet SCCB targets should seek to enhance the opportunities for the agriculture sector to both reduce its own emissions, while also offering potential mitigation strategies e.g. development of carbon sinks, reduction in livestock methane emissions.
• Appropriately managed organic waste recycling can improve soil carbon content, increase water retention and reduce flood risks and targeted inputs and NVZ guidance/ requirements could be extended to all agricultural businesses. SG/ ERAD are in the process of producing an Agricultural Climate Change Action Plan, which may offer more informed detail and additional insight to help advise future action in the sector.
• The SRDP should help contribute to SCCB targets, particularly in terms of climate adaptation and wider environmental benefits. Land Management Contracts and measures to improve environmental stewardship within the land management sectors should help maintain soil resources.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice when assessing local effects on soils to avoid impact transference.
• Long-term planning will help avoid short-term reactionary measures that could seriously impact non-renewable soil resources. The upcoming Scottish Soil Strategy may help address domestic adaptation strategies and the maintenance of high carbon stores.

Material Assets

Energy

• Short-term investment in rapid renewables growth could lead to phasing out of conventional fossil fuel supply; however renewables projects should be subject to appropriate SEA/ EIA/ AA and planning consent to identify impacts and develop effective environmental mitigation strategies. In particular biomass projects should be subject to suitable EIA or AA as a pre-condition to any relevant grants or awards with effective mitigation strategies developed.
• Small-scale and micro-renewables will reduce loading and strain on the grid. Grid infrastructure should be updated to encourage distributed generation and feed-in to the network from community and micro-renewables to realise maximum benefit. This may be outwith the remit of devolved policy; however Government should lobby/ encourage forward planning for grid infrastructure investment and upgrades to support the supply/ demand and growth of all renewable energy forms. Must be done with minimum of disruption and environmental impact.
• Technological fixes such as carbon capture and storage do not reduce upstream energy emissions, and capturing end-of-pipe emissions may detract from investment in other more immediate and 'green' technologies. Emissions from fossil fuel power stations may be captured and stored through CCS, but this could present other environmental problems. Support for CCS should be considered in light of further research to identify and manage potential impacts before it is implemented.

Waste

• Investment decisions for waste facilities should consider maximising carbon efficiency in conjunction with BPEO. Pre-treatment of biomass to release natural gas will improve fuel efficiencies. Reduced waste to landfill will extend operations whilst improving energy security. The principles of the waste hierarchy must also include maximised energy potential and minimised GHG emissions.
• Landfill gas (methane) is now routinely collected, however separation of organic waste at source would allow more efficient treatment and gas collection. Anaerobic digestion of organic wastes followed by incineration allows win-win results with efficient collection of methane and CHP incineration to maximise calorific efficiency.
• The Scottish Government should encourage the most polluting waste management facilities to adopt alternative technologies and use grey water for waste processing activities. In the medium-long term, ensure all former and present inert waste management sites are re-developed with a view to enhancing the local environment and for the benefit of local populations.
• Regulatory measures and strategic drivers should encourage recycling in multiple occupancy dwellings and measures should be put in place to ensure the waste management needs of low income families are met.
• Ensure innovative methods of waste management are introduced for remote rural locations, such as community skips.
• Encourage consideration of possible waste production at the design stage by promoting lifecycle assessments for new products.
• Promote the use of secondary aggregates in new builds and other construction activities. Use procurement as a driver and a controlling mechanism for reducing waste and promoting resource management.
• A national level capacity and infrastructure study would facilitate better planning and communication of the need for waste management facilities. Recycling facilities need to be of appropriate scale and take into consideration landscape impact. Ensure that during and post operation efforts to integrate the facilities within the landscape have a beneficial impact.

Built Environment

• Building and engineering standards need strengthening to account for carbon emissions throughout the design, procurement, transportation and construction phases, and the planning system could require consideration of carbon issues to be accounted for in applications and decisions. The SCCB target could lead to carbon becoming a material consideration in planning and consent decisions, possibly through amendments to the Planning etc (Scotland) Act 2006.
• Life cycle or input-output analyses should apply to future development consents to encourage maximum energy and emissions efficiency throughout the development cycle.
• Sustainable design guidance/ requirements should be strengthened to require local sourcing wherever feasible, and maximise passive energy gain in all developments.
• Civil engineering and building standards/ codes need strengthened to prioritise linkages between activities, material choices and emissions/ efficiencies. Environmental and energy efficiency award schemes should be strengthened to incorporate whole project/ life cycle costs.
• EIA may not recognise cumulative development effects therefore SEA guidance should be strengthened to reprioritise consideration of emissions and climate implications.

Transport

• Fuel prices will continue to rise with global demand and diminishing supplies, alternative win-win fuels should be actively supported to encourage market penetration. The SCCB target will help drive biofuel adoption in Scotland, promoting uptake and integration of biofuel mixes and biodiesel. Biodiesel from waste should be seen as a win-win option and more eco-friendly than the primary production and extraction of fuel from biomass.
• The Renewable Transport Fuel Obligations Order ( RTFO), whilst reserved to Westminster, is likely to be an important mechanism by which the targets of the SCCB can be realised. The SCCB target may help inform future incarnations of the Order as the potential for GHG mitigation in this manner is explored to help support entrants and innovation.
• Routinely screening imported biofuels to determine sustainable source and local impacts mitigation before sale in Scotland would be beneficial, although international trading rules may present barriers to selection and screening.
• Lobbying for rapid international agreement on aviation and maritime emissions would help maintain target credibility and buy-in from other sectors. May be possible to start accounting for UK domestic aviation and commercial maritime emissions and encourage entry to a UKETS.

Cultural Heritage (including Historic Environment)

• Planning processes and appropriate EIA incorporating Landscape or Historic Land Use Assessments should address any historic environment issues; however provisions enabled by the SCCB should take account of, and should not negatively impact on, historic resources. Particularly when making locational decisions on renewables development.
• Energy efficiency measures and microgeneration options within conservation and non-designated, but locally important, areas must be sympathetic to local cultural heritage. However, in accordance with the need to reduce emissions widely, designations should not prevent progress, effective compromises between planning authorities and conservation bodies must be identified and new positive attitudes developed towards change and development in the landscape.
• Microgeneration may be allowed within permitted development, however planning authorities and Historic Scotland should agree an approach and advise. Cumulative impacts need to be considered within the Government's preferences/ priorities for emissions reductions measures against conservation of historic settings. Due to the fact that older buildings are more likely to be less energy efficient, microgeneration can go some way to reducing the energy burden of older building stock.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice and be sympathetic to local cultural requirements, involving appropriate local consultation, to avoid negatively impacting local cultural and historic environments.

Landscape

• There is a need to recognise the particular sensitivities of specific landscapes that may be impacted by climate change mitigation measures. Programmes resulting from the SCCB should reflect the aims of the EU Landscape Convention, by considering impacts of projects/ proposals on designated and non-designated landscapes, particularly in terms of potential loss of distinguishing features.
• Landscape is important for Scottish tourism and cultural heritage however; appropriate use of Scotland's wind resources must be seen as a valid imperative to mitigate wider environmental damage from GHG emissions, including microgeneration options.
• Careful consideration of the siting and species of plant grown for biomass production is required. Use of virgin or unimproved farmland should be avoided. Lowland arable sites present less visual impact. Shrubs and trees can be used to limit the effects of sudden changes. Wildlife corridors should be maintained.
• Appropriate EIA including Landscape Character Assessments should be a pre-requisite of any renewables or biomass project or grant application and mitigation of landscape impacts should follow Forestry Commission and SNH guidelines. Similarly planning processes, locational guidance and appropriate EIA should address landscape and soil issues to minimise disturbance of either.
• Landscape assessments are subjective and localised NIMBY-ism may be outweighed in the long-term by a higher imperative to reduce emissions. These issues must be considered against other energy option impacts including re-investment in nuclear or coal fired generation. Emissions reduction will lead to some difficult landscape choices.
• Improved guidance on land management at the catchment or landscape scale, as opposed to farm boundary scales, should help address some landscape issues. Action and guidance will be driven by Land Management Contracts, River Basin Management Planning, Flood Prevention and Climate Adaptation Strategies.
• Future infrastructure development should be advised by appropriate landscape assessments and planning to minimise visual impacts.
• Overseas emission reduction projects that are funded or supported by Scotland must be subject to UK/ EU standards and best practice and sympathetic to local landscapes, involving appropriate local consultation, to avoid negatively impacting potentially poorly protected landscapes.