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

Strategic Environmental Assessment (SEA) of the Scottish Climate Change Bill: Consultation Proposals: Final Environmental Report (Post-Consultation Issue) November 2008


Appendix E High Level (Preliminary) Options Assessments

SCCB
Consultation Proposal/Option

Rationale / Assumption

Anticipated Positive Effects/ Strengths

Anticipated Negative Effects/ Weaknesses

Major areas of influence on SEA Topics/ Issues

Recommendations/ Additional Measures

Ways of setting the target - what is the target?

80% reduction target

Emission reductions target based on percentage of 1990 and 1995 Kyoto baselines.

Based on current understanding of climate change i.e. "the credible science of the day".

By meeting this target we are likely to meet any international targets that may be set in future.

Takes a baseline and demands a percentage reduction without excuses.

Independent of company growth.

Forces government to seek to ensure that businesses implement ever more stringent measures in order to meet targets, driving innovation.

Enforces the spirit of the Bill.

Easy to understand and compare reductions across sectors.

Simple and easy to communicate

May reach plateau prior to meeting 80% targets.

Could cause businesses significant costs.

Will likely require stringent fiscal measures to enforce. Scotland will need to invest significantly to realise appropriate levels of emissions reductions, in conjunction with realistic financial incentives and penalties for organisations to encourage sufficient action.

Tyndall Centre suggest that focussing on final percentage reductions could have little relevance in avoiding dangerous climate change.

Air quality, human health in the short term.

Soil, water quality and material assets in the medium term.

Landscape, historic environment and population in the long term.

Indirect effects on biodiversity.

Long term benefits for climatic factors, material assets.

Long term impacts upon landscape and historic environment.

Indirect mixed effects on human health, population and biodiversity.

Independent body to ensure goals are met despite possible changing political environment.

Full enforcement powers required.

Changes to legislation would require Government level intervention.

Reduction should be ultimate goal.

Mitigation measures should be considered as a secondary role.

Scotland has an advantage over the rest of the UK with the potential for massive use of renewable energy.

Should include international aviation and shipping as soon as international method to do so is devised.

Use cumulative carbon budgets

Sets a stringent fixed total emissions allowance to 2050 which reductions must meet.

Provides an absolute target required to stabilise global temperatures at no more than 2°C above those found in pre-industrial global temperatures.

Aims to consider share of global emissions to stabilise CO2 at levels to minimise temperature increases (eg. +2 oC).

Ensures that enough is being done.

Encourages early action to be taken.

Allows more certainty in planning.

Focuses on limiting total emissions rather than reducing them below a baseline level.

Issues on the division of total budget between sectors.

Fairness of the division between countries.

Global participation - has to be mandatory.

How will it be enforced?

Stringent reduction measures required very early to have any chance of success under this regime.

Financial implications may not be acceptable.

Air quality, human health in the short term.

Soil and water quality and climactic factors in the medium term.

Landscape, historic environment and population in the long term.

Short-medium term impacts upon population, material assets.

Long term impacts on landscape.

Long term benefits for human health, biodiversity and all other SEA Topics.

Trading mechanisms should be provided.

Needs to be a global regulatory body.

Reward for early meeting of budget?

Should be a legal obligation to stay within the budget.

Tyndall Centre identifies demand reduction as key to driving cumulative savings.

Changes to targets should only be accepted in light of new scientific discoveries; it should not be a 'get-out-clause'.

Use interim carbon budgets

Scottish Government is minded to have multi-year budgets of at least three years. Multiples of two years fit with the financial budget cycle (the comprehensive spending review is every two years). Choices for the length of the budget period are:

  • Four years - fits with the Scottish Parliamentary cycle;
  • Five years - fits with the UK Climate Change Bill periods, current EUETS phase and Kyoto period;
  • Six years - multiple of financial budget cycle but allows more time to adjust policies; or
  • Eight years - fits with possible future EUETS phases (2012 onwards).

Flexibility - long and short term strategies can be implemented.

Sets targets in people's lifetimes meaning they are more likely to act.

If a target is 50yrs away people are less likely to worry about it.

More reactive.

There is a risk that budgets may be increased if they're not being met.

Could discourage some early action as companies may decide to 'save' actions for later budgets if earlier budgets are met.

Few short term gains as slow and steady approach.

Most significant effects will be medium to long term.

Need to ensure that overall these budgets allow the total 2050 target to be met.

Range of mechanisms required.

Over-achievement could be traded however it should be discouraged.

Limited borrowing between periods could be allowed but only in exceptional circumstances.

Process needs to be totally transparent.

Should include international aviation and shipping as soon as international method to do so is devised.

Use consumption based footprint measure

Establishing a current footprint (carbon/ ecological) and reducing it to meet the actual organisational size.

Holistic look at total business resources.

Would slow the process down as organisations gathered information and calculated their footprint.

No national standard.

Not an absolute target so risks overall 80% not being met.

All SEA topics will be influenced however there are unlikely to be many in the short term.

Medium and long term goals are more likely with this route.

Would require every business to invest time and money in establishing a baseline.

Will take a long time before any baseline is set.

Needs a formal and agreed assessment process to ensure this is done correctly.

Use Kyoto baselines to set target

Baseline set to1990 (and 1995 for F-gases) levels with reduction gains measured from that point.

Recognised baseline.

All countries are familiar with it.

Acknowledges efforts that have already been made since 1999.

Kyoto baseline already agreed so will save time.

Some countries will already be below the baseline

(Russia closing much of heavy industry)

Baseline doesn't really influence SEA topics, except in the extreme long term.

It is the reduction measures that matter.

Should the targets be changeable?

Changes to targets should only be accepted in light of new scientific discoveries or recognised changes in the way climate change manifests itself.

There should be no 'get-out-clause'.

Will encourage further research.

Reductions in all GHG emissions are valid due to higher GWP values.

May be seen as a get out clause for businesses.

Could detract from the imperative for early action.

Changing targets/ periods could encourage slow response and ultimately affect all SEA topics.

Possibly in light of new scientific discovery or to change from percentage reductions target to cumulative carbon target.

Needs to be closely monitored.

2 oC threshold must take account of all emissions sources.

Focus on
(1) CO2 emissions only
(2) CO2, CH4 & NOx emissions
(3) basket of six GHGs

All 6 GHG contribute to climate change.

Although CO 2 is emitted in the greatest volumes, other gasses are more harmful.

Methane has a GWP 23 times that of CO 2 while SF6 has a GWP of 23,900

By considering all GHG we are tackling the problem on 6 fronts.

Most beneficial reductions can be targeted first.

Potential gains from reducing lower levels of high GWP emissions can add to extra 20% Scotland is seeking to achieve.

May encourage use of equally harmful gases not listed or identified.

Fewer people have control of, for example SF 6, while everyone can reduce CO 2.

Potential to reduce non-CO 2GHGs further is less than for CO 2. It is possible that Scotland could end up having to 'overcompensate' and reduce CO2 beyond 80% in order to meet a target based on the basket of GHGs.

More short and medium term benefits than if only CO 2 or 3 gases where considered.

If considering the basket of gases, big cuts could be realised in agriculture, but not if CO 2 only is considered.

Different sectors could have different budgets for different gases.

Use net domestic emissions measured through the GHG inventory

GHG Inventory provides accurate information, based on current knowledge, from which reduction targets could be set and compared.

Background data already available so immediate savings can be made and measured

Data already being collected and easily accessible.

Complies with UNFCCC requirements.

Not all business emissions are measured.

Purely measurement and data recording mechanism.

In itself has little influence on SEA topics.

Reporting in itself will have little impact.

Use an end user inventory or have individual targets for energy efficiency and renewable electricity.

Considers energy demand and use, as opposed to supply side emissions provided in GHG Inventory.

Allows flexibility and encourages innovation and initiative.

Targets reductions on a more personal/ business/ corporate responsibility level.

Potentially more onerous to record data, collate and allocate emissions - could lead to further delays and maybe difficult to enforce.

Supply side linkages already well developed.

Some companies are reactive rather than pro-active and need targets to be set.

Worth considering after initial periods to augment GHG Inventory approach.

Reduction actions should not be held up until such a system is in place.

An end user inventory could be developed eventually.

Existing emissions inventories are limited.

Personal carbon allowances could be developed.

Most significant target before 2020 or after?

Largest savings made early this century are more beneficial due to the time lag and persistence of GHG in the atmosphere.

Set a precedent.

Encourages action on identifying and committing to largest, early savings.

Encourages action on implementing proven technologies - quick wins.

Businesses could incur large costs in a relatively short period.

May need incentives to drive early action/ change.

Include international aviation/ shipping emissions

They are a growing source of emissions.

Aviation emissions recognised as more harmful than terrestrial emissions.

Not including them places increased pressure on other sectors/ businesses.

Important route to reduce emissions and encourage efficiency.

Public perception improves - at the moment may be negative with respect to skewed logic of promoting personal responsibility against major GHG emitting sectors.

Costs passed to consumer (long term benefit in reducing consumption).

Places onus on travel companies not just on passengers.

Will cause rise in prices of both travel and related products.

Costs passed to consumer.

May restrict access to travel - personal freedoms.

Difficulties in obtaining international agreement on mechanisms - must be agreed.

Some companies may fold under extra costs - competition efficiencies.

Continued lack of clarity and action on issue will impact all SEA topics.

Positive action will likewise benefit all SEA topics in the medium to long term.

Requires agreement by companies to absorb some of the cost.

Scottish Government may be unable to influence international agreement.

SCCB
Consultation Proposal/Option

Rationale / Assumption

Anticipated Positive Effects/ Strengths

Anticipated Negative Effects/ Weaknesses

Major areas of influence on SEA Topics/ Issues

Recommendations/ Additional Measures

Monitoring the target - Measures

Source of independent advice?

(1) Using UK Committee or

(2) Dedicated Scottish body

(3) Existing Scottish Organisation

Government initially proposes to use the services of the UK Independent Committee on Climate Change, for 3 years, and then appraise whether advice is appropriate for Scotland.

Sufficient expertise may not be available in Scotland at this time.

A dedicated department within an existing organisation is a possible compromise.

Requires long-term remit outwith influence of election timescales.

Allows evolution through phases of climate change budgets and targets without political constraint.

In time, a dedicated Scottish body with responsibility for climate change could help drive co-ordinated action across government departments and private sectors.

Could concentrate solely on climate mitigation and adaptation.

Setting up a new dedicated Scottish body is likely to (negligibly) increase resource use in the short term, but could help reduce overall resource use in the longer term.

Do we have the necessary expertise?

What could a Scottish Committee offer that the UK version could not?

Will influence all SEA Topics to some degree and could provide periodically revised guidance on SEA and EIA to ensure wider environmental issues are not significantly subsumed by climate action.

Should consist of technical experts and a wider stakeholder group to continue to give a representative balance.

Balance needs to be achieved between independence from government and accountability.

SEA consideration would suggest that long-term, a dedicated body may be required to provide advice and coordinate action across sectors to meet both UK and Scottish targets.

Mandatory annual reporting

Reporting progress on an annual basis.

Will not set targets.

Builds on existing mechanisms.

Ensures all sectors report on progress, and encourages continual improvement.

Allows real trend analysis after consecutive reporting periods.

Will help adjust interim budgets.

May be very little being done in such short time periods.

Time consuming.

Maintains focus on short term results.

Reporting itself will have little or no influence.

Indirect impacts associated with energy and paper use.

Annual reports can be used to highlight successes but must be completely transparent on real progress achieved.

Best to provide on-line report mechanisms wherever possible - reduce paper reporting.

Introduce statutory guidance or enact provisions for public sector

Voluntary schemes are currently available.

May not drive change as effectively as statutory requirements or enforcement.

Will drive improvements.

All would need to take part, rather than just the more environmentally conscious.

Supply chain management and sustainable procurement can drive private sector suppliers to improve, but must be properly implemented/ strictly enforced.

Voluntary measures based on businesses mechanisms (eg. CSR) and energy reviews are not sufficient in their own right.

May put pressure on smaller enterprises.

Air quality, human health in the short term.

Soil and water quality in the medium term.

Landscape, historic environment and population in the long term.

Government support should be considered.

There are organisations that provide advice and support, eg. CT, EST, Envirowise etc.

These could be expanded and more widely used.

Use of Best Value duty to introduce mitigation measures.

Best Value should be amended/ strengthened to take account of mitigation and adaptation.

Provides a non-legislative vehicle for improvements that could directly impact emissions.

Best Value incorporating proper evaluation of climate issues will help address embodied costs of carbon.

Best Value may still offer more credence to financial and social considerations (more short term).

Could rely on business to implement change as not statutory.

Any influence will be in the medium and long term depending on success of measures.

Introduce reporting mechanisms for certain parts of the public sector on action to reduce or adapt to climate change.

Can feed into national level reporting mechanisms.

Some form of reporting mechanism is required to improve transparency on climate action.

Establishes the requirement for action.

Ensures continued focus on action over time.

Could consider some form of Climate Action Plan for public sector.

Demonstrates leadership from national and local government.

Annual reporting may increase focus on short term change.

Time consuming.

May maintain focus on short term goals.

Reporting with have little influence, however the action taken could have significant localised effects.

Reported to appropriate body with enforcement powers.

Setting appropriate reporting periods is important.

Worth considering climate action plans and reporting on progress, with information on short-medium-long term actions/ benefits.

Should the Bill allow the means of measuring the target to be changed through secondary legislation?

Only in light of new scientific knowledge/ understanding.

Provides a contingency measure in the event of future discoveries/ technological breakthroughs.

Maybe result in potential for abuse.

Measurement in itself will have little effect.

Should the Bill allow the level of 2050 target to be changed through secondary legislation?

Changes to targets should only be accepted in light of new scientific discoveries or changes in the way climate change has manifested itself, there should not be a 'get-out-clause'

Provides a contingency in case there are new discoveries in the future.

Could undermine the overall target.

With this provision present it may provide a disincentive.

This will depend on how the target is changed. There will likely be a lag between the change and the influence.

Any change to the 2050 target needs to be based on credible scientific and independent advice.

This could be in the form of a formal recommendation made by the Committee on Climate Change.

SCCB
Consultation Proposal/Option

Rationale / Assumption

Anticipated Positive Effects/ Strengths

Anticipated Negative Effects/ Weaknesses

Major areas of influence on SEA Topics/ Issues

Recommendations/ Additional Measures

Ways of meeting the target.

Use of international credit scheme (Clean Development Mechanism - CDM)

Provide mechanisms for those who do not meet targets to buy credits/ allowances from those who do.

Clean development potentially credits developed nation for technology transfer that limits emissions elsewhere.

Additional least cost abatement solution.

Benefits conscientious companies/ countries.

CDM helps limit potential growth of emissions in other countries.

Helps drive global approach and presents markets for renewables and energy efficient technologies.

Provides a mechanism for buying emissions credit, but does not drive emissions reduction in home country.

Credits potentially based on assumptions of savings made.

Potentially dilutes the example set by Scotland, 'selling our savings' we could allow other countries to benefit without doing enough themselves.

CDM offers long-term transboundary climate benefits.

Little or no short term influence with potential for detrimental medium and long term influence if reductions are not realised in home country.

Offset and International Credit Schemes (eg. CDM) do not necessarily drive emissions reductions in source country/ sector.

Could be considered within the total allowed in a particular budget period.

Domestic reductions and behavioural change more preferable.

Should be discouraged as a priority measure to meet the Scottish target as could hinder domestic reductions achievement.

Use of EU & domestic credit and trading schemes

Provides a mechanism for those who can't meet targets to buy more allowance whilst those below targets can sell.

Cap and trade schemes offer less onerous regulatory and administrative mechanisms to drive emissions reductions/ abatement.

Competitive schemes also drive innovation.

Could help drive economy towards low carbon and renewable energy.

Could see a skewed result as industries/ processes that make effective early change sell credits and heavy polluters continue to emit.

Many emissions not currently covered.

We could be seen to be "buying our way out".

Emissions trading in itself not likely to directly impact SEA topics.

If successful in driving reductions, then indirect benefits on all topics could be realised over the long-term.

Should only adversely affect SEA topics if caps are inappropriate.

International aviation and shipping should be included when appropriate mechanisms are agreed.

If properly designed and effective then offers potential significant contribution to credible target.

Use of carbon offset schemes

Offsetting carbon provides a two pronged approach.

Reduce (sequester) and mitigate.

Offset schemes can include carbon sequestration and 'green' energy developments.

Can be part of an integrated approach in conjunction with direct emission reductions.

Allows emissions that can't be reduced (at least immediately) to be mitigated through sequestration.

Allows larger gains to be made towards targets.

End of pipe mechanism.

Potential excuse to emit.

Will not reduce direct emissions.

Offsetting can be very complicated and difficult to quantify.

Potential impacts on landscape, soil, water and biodiversity.

Positives if afforestation managed correctly.

Difficult to control impacts of offsetting elsewhere - these impacts could be significant across topics.

Needs to be properly monitored.

National standards need to be established with agreed conversion factors.

Positive impacts associated with limiting levels of offsetting and focusing efforts on actual emissions reductions.

Carbon offsetting should be considered after emissions reduction measures.

Offsetting has limits and there should be recommendations for a balanced approach and potential limits in its use, in order to drive focus on emissions reduction rather than offsets.

Increase renewables integration

Renewable energy has fewer GHG emissions than conventional energy production methods.

Renewables materials are sustainably produced through life cycle assessments.

Reduced emissions of CO2.

Some established technologies now cost effective to implement.

Greater energy security.

More control over energy prices.

Potential for small scale renewable production to 'feed-in' to grid with suitable upgrades.

Research and innovation continues to present opportunity.

Once the majority of energy demand is met by renewables, and if conventional fossil fuel generation is phased out, emissions and energy demand reduction are not so significant.

Increased land use change.

Potential for increasing GHG emissions related to development and land disturbance.

Potential for climate change to increase GHG emissions from peaty soils and renewables installation to exacerbate.

Renewable technologies do not address demand reduction.

Could encourage consumption if energy becomes cheaper.

Large scale renewables projects typically have implications for infrastructure.

Benefit dependent on whether baseline energy demand continues to rise.

Short term impacts on material assets, soils, water and biodiversity, possibly detrimental.

Medium-long term positive impacts on air, human health, population.

Potential for long-term impacts on landscape, historic environment.

Encourage use of small-scale and micro-renewable technologies with government support.

Planning process needs to be made easier and quicker to use.

Grid infrastructure issues need resolved - German 'feed-in tariff' example worth considering.

Short term, GHG gains from installing proven renewables must be considered in line with wider environmental costs/ benefits.

Smaller scale, localised generation is more efficient and should be encouraged as it takes burden off infrastructure.

Renewables materials should be sustainably produced and subject to an accredited/ verified life cycle analysis.

Increase energy efficiency measures

Making products/ processes/ buildings and people more energy efficient.

Enabling powers within the Bill could be a "home" for other legislation - building standards (possibly including existing buildings) and waste management are possible targets.

Allows a continued standard of living while reducing impacts.

Low-cost gains available.

Businesses should realise cost savings through energy efficiencies.

Long-term gains in lifetime energy use of buildings.

Improved energy efficiency should reduce demand, demand reduction key to reducing cumulative emissions within current generating structures.

Phase out of non-energy efficient light bulbs example could be and applied to other technologies.

Depends on behavioural change and buy-in from the general public -requires education to change perceptions/ awareness of benefits.

May encourage increased consumption and demand as efficient items seen to use less energy.

Cost and waste implications of replacement, and improving thermal/ energy performance of older buildings.

Neutral impacts are generally observed for energy efficiency measures.

A combination of improved efficiency and reduced demand will have significant benefits on reducing raw material use and extraction, thereby providing secondary or indirect benefits for all SEA topics.

Wider government support should be considered.

Consideration of extension of subsidies/ grants for domestic improvement measures - especially for the fuel poor and those on income support.

Germany has a programme of retrofitting existing building stock to improve energy efficiency.

Encourage use of energy efficient technologies.

This will drive the development of energy efficient products.

Companies could be encouraged to sell services not energy, e.g. the customer would buy a "warm home with lighting" rather than units of gas/ electricity.

This would put energy efficiency in the realm of the supplier.

Change industrial processes

Updating processes to reduce energy/ resource demand and waste emissions.

Encourage clean technology by design over end-of-pipe solutions.

Carbon capture and storage technology is in its infancy.

Reduced resource use.

Improved supply chains and raw materials from wastes.

Reductions in polluting incidents.

Reduced running costs.

Could help drive innovation and competition.

Potentially high initial costs.

Waste and consumption during changeover.

Inertia/ resistance in industries.

There are potentially other, less 'drastic' measures that can be implemented first.

Difficult for government to realise/ drive change, relies on private sector to take the lead.

May require incentives/ subsidies.

The risks to the environment from CCS are not proven; the technology could have negative and positive effects.

Possible impacts depending on leakage potentials.

Potential for negative short term impacts however more likely beneficial in the medium to long term.

Varied impacts possible at a local level.

Replacement or new industrial process designs should be subject to life cycle assessment to ensure minimisation of energy and resources.

Carbon capture and storage could help provide long-term option for industry.

More sustainable solutions should consider means to prevent emissions rather than storage.

Government should focus primarily on industries which are not covered by the EUETS, as those emissions are being addressed.

Increase resource efficiency

Using resources in a more efficient way.

Resources include water, raw materials and wastes.

Resource use has knock-on impacts on the wider environment through energy consumption, processing and transport.

Companies/ businesses could realise cost savings if properly reviewed.

Maintains stocks - lowers depletion rates, more resource security.

Lowers water resource demand.

Reduces associated activities - mining, manufacture, transport

Encourages reuse, recycling and consideration of waste as raw material as an extension.

Resource use driven by consumer demand, difficult to achieve without affecting productivity/ profits.

Requires buy-in, support and change in individual companies.

Presents potential benefits for all SEA topics.

Life cycle assessments and other input-output or mass balance techniques can help improve resource efficiency.

Reduce consumption

Combination of efficient resource use, energy efficiency, and more efficient processes.

Restricting demand and consumption will require combination of pricing effects and education.

Moving to a less consuming society will have wide ranging benefits for all environmental media.

Scottish Government can control education and promotion e.g. energy efficiency measures.

Difficult for government strategies to control personal behaviour.

Little control over this at a Scottish level.

Lack of fiscal power.

Efficiency could drive consumption of other goods.

Less consumerism - less resource use - less polluting processes - fewer emissions - healthier environment

Potential benefits across all SEA topics.

Taxes and price increases not always best way to encourage behaviour change, subsidy and reward options must be identified.

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