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

1

1. General Comments

The scoping report is clear in its intentions to undertake a high level assessment based around the 80% target.

This is broadly accepted, although we do feel that it would also be useful in the Environmental Report to provide a degree of direction to other plans and programmes in terms of the requirement to assess matters in more detail.

An extensive policy review has been undertaken in line with the Scottish SEA Gateway Guidance and Templates, which considers existing plans, programmes and strategies.

A key element in reaching the ambitious 80% reduction target will be the appropriate revision of existing targets/ commitments as current policies/ strategies are renewed.

The SEA will discuss effective policy renewal across all sectors to take account of the 80% target.

The SEA will recommend strong action to meet the challenge of emissions reductions in all sectors; the SEA will also identify the need for further assessment at lower strategic tiers.

2

1.General Comments

One issue that is peculiar to SEA of a Bill consultation is how the SEA will embrace the parliamentary process.

As the Bill progresses through parliament, it may be subject to change and some of those changes may lead to significant environmental effects.

It would be useful to know - and for this to be explained in the Environmental Report - how SEA and the parliamentary process will work.

We appreciate that this may not have been bottomed out yet and that this is the first Bill consultation to be subject to SEA, but some discussion on this issue would be helpful.

Noted.

The SEA will specifically appraise the options included in the Consultation Proposals for the Scottish Climate Change Bill; it is not intended to assess the Bill itself.

These proposals will be assessed to make recommendation on the best environmental options for Scotland.

After consultation on the proposals, the SEA will assess any resultant significant changes, and will close with the submission of the Scottish Climate Change Bill to the Scottish Parliament.

At that point an SEA Post-Adoption Statement will be produced setting out how the SEA process has informed the development of policies for the Bill.

An overview of the process will be included in the Environmental Report.

3

1. General Comments

It would be helpful if the Environmental Report (unlike the scoping report) were paragraph numbered.

Noted.

The ER will have numbered paragraphs.

4

2. Detailed Comments

-Context

SEPA notes that it is not intended to re-iterate the background to climate change, although it is not clear if that is for just the scoping report or if this is intended to be the case for the Environmental Report also.

While SEPA is content with this approach for the scoping report, it would be worthwhile providing some background information on Scotland's contribution to climate change and the effects it may in turn have on Scotland's environment and people.

This would significantly aid consultation on the Environmental Report and also help you to meet the requirement to report relevant aspects of the state of the environment as set out in Schedule 3 of the Act.

Such a brief summary is provided in SEPA's recent scoping report on its Climate Change Plan, which you would be welcome to utilise if helpful.

Noted.

To meet the requirements of Schedule 3 of the Act, an overview of Scotland's contribution to Global Emissions (currently approximately 0.2%) and the likely effects of climate change in Scotland will be included.

The summary of effects will be based on established UKCIP scenarios and the SNIFFER Handbook of Climate Trends across Scotland.

SEPA have been kind enough to forward a copy of their CCP Scoping Report for reference.

Will be incorporated into the Baseline chapter of the ER.

5

2. Detailed Comments

-Description of Consultation Proposals

This section concisely sets out the proposals in the Bill consultation.

You may find that it is useful to use the SEA to help address some of the issues described on page 4.

For example, studying the environmental effects of including (or not) international credits, aviation and shipping may help to resolve these issues.

This may also be the case for helping decide whether interim targets should be a budget or percentage reduction or whether banking and borrowing should be permitted.

Accordingly, you may wish to analyse these as options.

Due to the time constraints on this project, a simplified high-level evaluation of the options listed on Pg4 of the Scoping Report will be included.

These appraisals will be informed by Government cost/benefit analysis ( RIA) of various options, but may well result in different conclusions by considering the options from a purely environmental viewpoint.

Will be incorporated in the environmental assessment sections of the ER.

6a

2. Detailed Comments

-Scope of the Proposals

Table 1 is useful in identifying which parts of the Bill consultation are intended to be included within the scope of the Environmental Report.

SEPA agrees that the 80% target and the interim periods should be assessed.

Noted.

As above.

6b

2. Detailed Comments

-Scope of the Proposals

The proposed requirement for mandatory annual reporting and establishing a source of independent advice in themselves SEPA would agree are unlikely to lead to significant environmental effects, however there may be indirect effects depending on the extent to which these will inform future target setting.

The fact that these will directly contribute and report progress on the 80% target should mean that effects will be considered through this, but it may be worth briefly commenting on how the annual reports and independent advice will link into the process.

Annual reporting is not considered to have significant environmental impacts in itself, and it is considered that the processes governing the linkages between annual reports and independent advice are not best addressed in this SEA.

Our recommendation would be that these issues may be better addressed through the regulatory impact analyses.

None

6c

2. Detailed Comments

-Scope of the Proposals

SEPA considers that the framework of enabling provisions to deliver climate change policies could lead to significant effects, but would agree with your assertion that this will depend upon the nature and extent of detail of the enabling provisions.

It would be worth clarifying in the Environmental Report whether and how enabling provisions may be captured in the assessment process and how their environmental effects will be considered.

Due to the draft nature of the proposals, detailed information on enabling provisions were not available, in fact the consultation will be asking for input from the public on which enabling provisions should be included.

Therefore, specific enabling provisions may have been captured in the high level options assessment, but have not been directly addressed as such.

None.

6d

2. Detailed Comments

-Scope of the Proposals

SEPA would agree that all of the SEA issues need to be scoped into the assessment at this stage as per your Table 2.

This is consistent with our own approach to assessment of SEPA's climate change plan.

Noted.

All SEA topics will considered throughout the assessment process.

N/A

7

2. Detailed Comments

- Relevant plans and programmes

Appendix A sets out those plans and programmes (and indeed a whole range of initiatives from targets through to different renewable energy technologies) which are already linked into the climate change agenda.

While SEPA notes the attempt to show how these initiatives might positively or negatively effect the environment in Appendix A, it is not clear how this either provides information about the content of relevant plans and programmes and their relationship to the Bill consultation nor about how this may contribute to the assessment.

Further clarification of this might be helpful.

We will provide a PPS review consistent with the approach outlined in the Scottish SEA Gateway Guidelines and Templates.

This review will highlight policies for which it may be appropriate to consider strengthening elements aimed at reducing emissions in order to help meet targets set by the SCCB.

This PPS review, in conjunction with baseline evidence will inform the SEA assessments and recommendations.

Full PPS review to be included as an appendix to the ER.

Key issues will be highlighted within ER section on relevant plans and programmes.

8

2. Detailed Comments

-Baseline environmental information

As noted above, SEPA recommends that it would be worthwhile providing some background information on Scotland's contribution to climate change and the effects it may in turn have on Scotland.

This would aid consultation on the Environmental Report and help you to meet the requirement to report relevant aspects of the state of the environment set out in Schedule 3 of the Act.

Brief, relevant extracts from key documents such as the Climate Change Programme, the SNIFFER handbook of climate trends across Scotland and from SEPA's State of the Environment Report.

Noted.

Each SEA Topic will be addressed through summary paragraphs outlining the key environmental issues under the topic heading, at the national scale.

An appreciation of climate change pressures will be included.

SEA Topic summaries and issues will be included within the baseline section of the ER.

The UKCIP02 High Emissions scenario will be adopted as the basis for the likely evolution of the environment, in the absence of the SCCB.

9

2. Detailed Comments

- Reasonable alternatives

It appears that consideration of reasonable alternatives is being carried out at an early stage and there appears to be good scope for strategic level assessment. This is supported.

The five alternatives identified would appear to be appropriate.

As noted above, you may find it helpful to include some of the issues pondered on page 4 as alternatives in order to assist your consideration of these matters during preparation of the Bill consultation.

The alternatives listed in the Scoping Report were based mainly on varying target settings.

These were not considered appropriate for the SEA in the light of the fact that the highest target, in aiming to result in greatest emissions reductions, would be seen as the preferred environmental option and could lead to bias in the assessment of other, lower targets.

Some of the options on Pg4 were identified as more suitable for assessment as alternatives within the SEA, as recommended.

Alternatives assessed with full matrices provided in Appendix F.

10

2. Detailed Comments

-Reasonable alternative

It is not clear whether it is intended to build the national level carbon footprint approach into the assessment.

Similar to above, you may find it helpful to include such discussions in the assessment

It is NOT intended to build the national level carbon footprint approach into the assessments.

The SEA will recommend that this measure be considered for assessing suitable policies at the appropriate strategic tier, where sufficient time has been built into the project to allow footprinting methodologies to be employed.

Recommendation on Carbon Footprint measures to be included.

11

2. Detailed Comments

- Methodological framework

SEPA acknowledges that as the Bill consultation will be very high level that the assessment will reflect this.

It is important, however, that where lower level plans and programmes (and also enabling provisions where appropriate) are better placed to do more detailed assessment that this is recommended where appropriate in the Environmental Report.

Noted.

The SEA will assess the potential for a more holistic approach to be taken to climate change mitigation and adaptation in the short-medium term to help realise reduction targets as soon as possible, but in a managed, sustainable and equitable manner.

Recommendations on lower level assessments to be included.

Comments on future work/ research needs/ enabling provisions.

12

2. Detailed Comments

- Methodological framework

What would be useful in the assessment is to capture and summarise the typical environmental effects of technologies aimed at reducing greenhouse gas emissions - for example, renewables, biomass fuels.

Much of this could be sourced from similar high level assessments of (for example) Scottish marine renewables, Scottish Planning Policy 6 and Scottish Natural Heritage's Biomass Policy.

Noted.

An appreciation of the environmental implications of some key technological options will be included in alternatives assessments.

This assessment will build on the PPP/ PPS review and baseline details to help develop an overarching picture of the likely implications of emissions mitigation methods.

Will be included within the environmental assessment section and Appendix F of the ER.

13

2. Detailed Comments

- Methodological framework

SEPA notes that further work on developing the method to be used to undertake the assessment will take place following the appointment of a contractor.

While it may have been useful to have had some of this detail in the Scoping Report (eg is it intended to use objectives ?), the basic principles of what is described in the second paragraph appear appropriate.

It is not clear, however, how you might use the scoring system to assess the environmental effect of the target on other plans and programmes and what value this will provide.

SEPA would be very pleased to discuss methods with you as your thinking on this progresses.

We have decided to follow the advice of Historic Scotland and adopt a modified Dutch E-Test methodology as the principal means of assessing likely future implications of the SCCB target.

Combining this assessment tool with other assessments within the SEA, will help ascertain key recommendations that may be appropriate to specific sectors, as well as at the national government level.

We will NOT be using specific SEA Objectives in this case.

Outline explanation of modified e-test methodology will be included in the ER.

The choice of assessment methodologies will be covered within the ER.

14

1.3 Scope of assessment and level of detail

I agree that the environmental assessment should explore the environmental implications that may arise from the 80% statutory emissions reduction target, and suggest that the assessment should identify the positive environmental effects that may arise from reducing the impacts of climate change, and also the potentially negative effects that could arise from measures proposed to reduce and adapt to climate change.

In order to limit the scope, this SEA will focus on the effects of emissions mitigation, within the context of continuing climate change to 2050/ 2080 from the UKCIP and SNIFFER scenarios.

The positive environmental effects of reducing the impacts of climate change are beyond the scope of this SEA, as concerted global action is not guaranteed.

Effects, local to Scotland, of emissions reduction will be discussed and highlighted.

In order to limit the scope, this SEA will focus on the effects of emissions mitigation.

Climate change adaptation may be referred to in conjunction with other environmental mitigation strategies, as a result of considerations.

15a

1.4 Scope of assessment and level of detail

Undertaking environmental assessment at this high level is challenging and I welcome the intention to carry out an environmental assessment of the Scottish Climate Change Bill consultation.

One of the key outcomes of the environmental assessment process will be the identification of measures to mitigate any potentially adverse or uncertain effects identified in the assessment; for example, how the potentially negative effects that may arise from the 80% target will be avoided through secondary legislation and lower plans, programmes and policies e.g. Scottish Planning Policies.

This should be clearly documented in the Environmental Report.

Noted.

The SEA will assess the potential for a more holistic approach to be taken to climate change mitigation and adaptation in the short-medium term to help realise reduction targets as soon as possible, but in a managed, sustainable and equitable manner.

However, it is anticipated that at this high-level, the SEA will recommend that such secondary legislation and lower level plans should be subject to appropriate environmental assessments to identify applicable mitigation measures at the appropriate location and scale.

Recommendations on lower level policy and secondary legislation assessments to be included.

Comments on future work.

15b

Annex A: Detailed Comments

- Context, environmental problems, current environmental situation (2)

Climate change may directly affect historic environment features, for example increases in storminess or rising sea levels may affect coastal or riverine sites that may be vulnerable to erosion.

In addition, direct effects on historic environment features may arise from changes in weather patterns for example damage to historic buildings from flooding or extreme weather events, or adverse effects on buried archaeology from changes in hydrology.

Impacts on the historic environment may also arise from measures to reduce emissions and adapt to climate change, for example renewable energy developments (wind farms, biomass, micro-renewables), flood defences etc.

Noted.

These potential impacts will be recorded within the Historic Environment section of the ER baseline and in the consideration of emissions reduction measures.

Include within baseline sections and appraisal of emissions reduction options.

15c

Annex A: Detailed Comments

- Description of the consultation proposals (3)

This section clearly sets out the proposals that are likely to be included in the Bill consultation.

I note that there are a number of areas where further analysis is required before the Government comes to a view, and it may be useful to use the SEA to help consider these options.

Noted.

Areas listed requiring further analysis will be appraised through a high-level options analysis.

Include in environmental assessment sections of the ER.

16a

Annex A: Detailed Comments

-Scope of the proposals

I consider that it would be useful to explore the environmental implications of the enabling provisions in the SEA.

I accept that the environmental impacts of the enabling provisions will depend on their nature and that these are not yet known, however it would be useful in the ER to identify any generic environmental issues and/or the environmental issues that require further consideration at a more detailed level of policy-making.

Noted.

Initial enabling provisions may include powers to introduce:

Carbon Trading Schemes

Duties for Public Bodies

Statutory Guidance

Regulatory Regimes

Charging Schemes

These will be included in the high level options and alternatives assessments.

16b

Annex A: Detailed Comments

-Scope of the proposals

Table 2 sets out the scope of the environmental assessment in terms of the environmental parameters identified in Schedule 3 of the Act and I note that the historic environment has been scoped into the assessment.

Simply for information, the "historic environment" is defined in Section 16(3) of the Public Appointments and Public Bodies etc. (Scotland) Act 2003 as

"… any or all of the structures and places in Scotland of historical, archaeological or architectural interest or importance".

SHEP 1 (para 2.3) builds on this definition by identifying that the historic environment encompasses built heritage features (ancient monuments, archaeological sites and landscapes, historic buildings, townscapes, parks, gardens and designed landscapes, as well as marine heritage) and the context or setting in which they sit, and the patterns of past use, in landscapes and within the soil, and also in our towns, villages and streets.

The historic environment also has less tangible aspects recognised as the historical, artistic, literary, linguistic and scenic associations of places and landscapes.

The definitions provided will be incorporated within the relevant sections of the ER.

Include descriptions within baseline and appropriate environmental assessment sections of the ER.

17a

Annex A: Detailed Comments

- Relevant plans and programmes and strategies

I note that the consultation proposals will not include information on the measures to deliver the required reduction in emissions, and that any emissions reductions are likely to arise from the continued or increased use of the delivery mechanisms set out in Scotland's Climate Change Programme, and through the development of new policies.

Appendix A identifies the policy areas and programmes that are already linked to the climate change agenda and begins to identify the environmental issues associated with each policy/action.

There are a number of measures included in this table where potential impacts on the historic environment should be recognised, and I consider that further discussion is required on this point before the environmental assessment is undertaken.

Noted.

The consultancy team forwarded a copy of the modified e-test methodology and invited Historic Scotland to attend the participatory workshop where concerns may have been discussed.

None.

17b

Annex A: Detailed Comments

- Relevant plans and programmes and strategies

Simply for information I have set out below a list of some of the potential issues for the historic environment that may arise from the measures included in Appendix A:

• onshore wind energy developments may have adverse effect on the site and setting of historic environment features depending upon their location.
• offshore wind farms are less likely to significantly affect the historic environment.
• biomass energy developments may have adverse impacts on the historic environment. For example planting energy crops may directly affect buried archaeological remains, depending on the crop type, the previous land use and on the current state of survival of the historic remains.
• planting biofuel or energy crops may also alter the level of the water table, which can affect archaeological remains that have been preserved in waterlogged areas.
• microrenewable energy developments may adversely affect historic environment features and the wider historic character of settlements.
• a key issue is likely to be the cumulative effect of small scale impacts on the character of historic environment features such as Conservation Areas

Noted.

These impacts/ implications will be noted within the appropriate sections of the ER.

Utilise these issues within the baseline and environmental assessment sections of the ER.

18

Annex A: Detailed Comments

-Baseline environmental information

The Environmental Report should provide information on the environmental baseline that is relevant to the assessment.

Given the high level of this SEA, I would not expect detailed baseline information to be provided for the historic environment; however the ER should provide an understanding of what constitutes the historic environment and how it may be affected both by climate change and by the consultation proposals.

You may wish to review the baseline information set out in the Scoping Report prepared for the National Planning Framework.

Noted.

We will consider the definitions/ descriptions within the NPF Scoping Report, in conjunctions with those provided by Historic Scotland above.

Include within relevant sections of the ER.

19

Annex A: Detailed Comments

-Methodological framework for assessment of environmental effects

I agree that the environmental assessment will need to be undertaken at a high level to reflect the high level nature of the Scottish Climate Change Bill consultation.

I note the assessment methods will be considered further once a contractor has been appointed and I would welcome further discussion at this stage.

You may wish to consider using a modified version of the e-test, rather than the matrix based approach often used in SEA.

The e-test is designed to be used at a high level such as this and in my view will give you better results and the light touch that may be appropriate for this level of policy.

Noted and agreed.

We have decided to take this advice on board fully and investigated further the applicability of the e-test methodology.

We are agreed that the recommended method works as an exceptional appraisal tool at this strategic level and, when combined with other assessments in this SEA will help provide an excellent overview of likely implications of the SCCB.

Incorporate an explanation of the modified E-Test methodology and include sectoral assessment tables within the appendices to the ER.

20

Annex A: Detailed Comments

-Methodological framework for assessment of environmental effects

In considering the environmental effects of the 80% I would expect the assessment to identify the environmental implications of the key measures that are likely to be required to deliver this target, for example renewable energy developments, energy efficiency measures.

As noted above, Appendix A begins to do this with a number of the measures, however the reasons for assigning a particular score are not provided and consideration of historic environment interests does not seem to be consistent.

The environmental assessment should be undertaken systematically and the conclusions reached in the ER should be presented in a transparent manner.

Noted.

An appreciation of the environmental implications of some key technological options will be included.

This assessment will build on the PPP/ PPS review and baseline details to help develop an overarching picture of the likely implications of emissions mitigation methods.

Will be included within the environmental assessment section of the ER.

21

Annex A: Detailed Comments

-Methodological framework for assessment of environmental effects

A key outcome of the SEA will be the identification of the measures proposed to mitigate the potentially significant effects that may arise from the consultation proposals.

As you will be aware, mitigation measures may involve making changes to the consultation proposals as well as identifying other lower level plans that may act to mitigate any potentially adverse effects of the proposals.

Given the high level nature of the Scottish Climate Change Bill consultation it is likely that the policies included in lower level plans and strategies will act to mitigate any adverse effects arising from the consultation proposals e.g. land-use planning policies.

This should be clearly identified in the ER along with any expectations or recommendations for lower level policies or plans.

Noted.

The SEA will assess the potential for a more holistic approach to be taken to climate change mitigation and adaptation in the short-medium term to help realise reduction targets as soon as possible, but in a managed, sustainable and equitable manner.

Recommendations on lower level assessments to be included.

Comments on future work.

22

Annex A: Detailed Comments

- Next Steps

It would be helpful in the ER to describe how the remaining stages of the SEA process will be managed as the Bill progresses through the parliamentary process.

Noted.

The SEA will specifically appraise the options included in the Consultation Proposals for the Scottish Climate Change Bill; it is not intended to assess the Bill itself.

These proposals will be assessed to make recommendation on the best environmental options for Scotland.

After consultation on the proposals, the SEA will assess any resultant significant changes, and will close with the submission of the Scottish Climate Change Bill to the Scottish Parliament.

At that point an SEA Post-Adoption Statement will be produced setting out how the SEA process has informed the development of policies for the Bill.

An overview of the process will be included in the Environmental Report.

23

Annex A: Detailed Comments

- Next Steps

The Environmental Report should provide information on the methods proposed for monitoring the significant environmental effects of the Scottish Climate Change Bill consultation.

I would be happy to discuss suitable indicators for the historic environment if you would find it helpful.

The ER will include a section on indicators and monitoring proposals, however at this early stage, these may present options for consideration only.

Further work is required by the Scottish Government on identifying relevant indicators and monitoring methods.

Include indicators and monitoring proposals for further consideration by the Scottish Government.

24

Scope of assessment and level of detail

Subject to the specific comments set out below, Scottish Natural Heritage is content with the scope and level of detail proposed for the Environmental Report.

Noted.

N/A

25

Scope of assessment and level of detail

The scoping report acknowledges fully the seriousness of the issues around climate change facing Scotland now and for future generations, and draws on the most recent and reputable predictions of future greenhouse gas concentrations.

The proposal to include a target of an 80% reduction in emissions of all greenhouse gases from a baseline of the 1990 levels, by 2050 is challenging, but necessary, and in order to ensure that this is achieved SNH considers it essential that interim targets are set and met.

There is an acknowledged lack of clarity at this stage as to how such a significant reduction will be achieved with the plan that any provisions needed to deliver the 2050 target will be taken forward through future secondary legislation.

Interim targets will be assessed for their likely influence on the environment; however, at this stage it seems likely that the targets will act as more of an economic driver for emissions reductions.

Climate predictions suggest that change within the first half of this century is locked in, due to the legacy of previous emissions.

Most significant reductions made earlier within the period to 2050 will help reduce the likely severity of climate change during the latter half of this century and into the next, if co-ordinated at the global scale.

Interim targets will not really affect Scotland's local environment unless they drive the early uptake of emissions reduction measures globally.

Targets and interim budgets will be discussed within the environmental assessment section of the ER.

26

Scope of assessment and level of detail

This lack of any plans, and programmes, and strategies ( PPS) to deliver the required reduction in emissions make it difficult to comment on the potential impact on the Scottish environment and its biodiversity that any such measures may have.

Furthermore whilst it is important and commendable that such challenging targets are set by Scotland, if the measures taken are to have any effect at the global scale (and by default for Scotland) then many other countries, including the largest polluters will also have to follow suit.

The implications for Scottish Natural Heritage from any measures taken need to be seen in the context of this larger picture whereby additional pressures may be put on our natural heritage through local mitigation to meet the 80% reduction in Scottish emissions but with no equivalent reduction in climate change effects.

Noted.

The SEA will consider likely emissions reduction technologies and strategies within the context of continuing climate change.

The SEA will therefore not specifically consider climate adaptation, but will make recommendations based on additional environmental mitigations which may be required as Scotland takes the lead on emissions reduction.

The SEA will take into account existing climate pressures on species and habitats and make recommendation based on the assessment of additional issues to be considered following the introduction of the 80% target.

27

Scope of assessment and level of detail

The long list of policy areas and programmes already linked to the climate change agenda that are given in Annex/Appendix A of the Scoping Report merely serves to reinforce the scale and complexity of the challenge in meeting the 80% reduction in emissions by 2050 and any interim targets.

In preparing the Environmental Report it will be necessary to review this list and identify any other options that merit consideration such as further hydro schemes and nuclear generation.

Noted.

The SEA will provide high-level considerations of the environmental cost/benefits of these technologies.

The Scottish Government does not support nuclear power generation in Scotland and the UK Government does not currently propose to build any new nuclear power stations in Scotland.

A high-level assessment of likely emissions reduction technologies will be included within the environmental assessment section of the ER.

28

Scope of assessment and level of detail

In the absence of a clear set of PPS for how the target will be met, it is not possible at this stage to comment on the possible environmental impacts.

In order for the consultation on the Environmental Report to be meaningful SNH considers it will be necessary to at least offer some detail.

This should include both indications of the potential measures that could be used to help meet the target and also perhaps offer a variety of scenarios comprising different combinations of mitigating measures for which the environmental implications can be assessed.

This aspect of difficulty in assessing the Scottish Climate Change Bill proposals is noted and agreed.

The consultants will develop a methodology based on assumptions about the future; therefore there are many uncertainties in this SEA.

The consultants have therefore opted to concentrate on known and emerging technologies, but will not look at a range of scenarios with differing combinations of measures due to time constraints.

A 'business as usual' scenario will be considered as part of the environmental assessment and baseline sections of the ER.

The UKCIP02 high emissions scenario, in line with adoption of the precautionary principle, will inform the business as usual.