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

3. Policy Drivers and Context for the SCCB

3.1 Background

3.1.1 Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes an outline of relationships with other relevant programmes, plans and strategies ( PPS), and how their environmental protection objectives have been taken into account in the PPS review.

3.1.2 In this section, International, UK and Scottish Government policies that impact upon, or could influence the direction of, action taken under the auspices of the SCCB, are reviewed to provide the context for assessments and to identify any associated pressures or synergies. Section 3.4, provides a summary of some key Scottish PPS and presents annotated climate recommendations made within their associated SEAs. Appendix B provides a fuller PPS review.

3.2 Kyoto Protocol and EU Drivers

3.2.1 In response to the scientific consensus that human activities are having a noticeable effect on the worldwide climate, the Kyoto Protocol was agreed at the Third Conference of the Parties (CoP-3) to the UN Framework Convention on Climate Change ( UNFCCC) in Japan in 1997. This international agreement aims to reduce developed countries' emissions of greenhouse gases ( GHG's) by, on average, 5.2% below 1990 levels by 2008-2012. The Protocol entered into force in February 2005, following ratification by Russia.

3.2.2 The UK share of the collective Kyoto target, assumed by the European Union under the Protocol, is an emissions reduction of 12.5%. Early in 2007, and in advance of the December 2007 United Nations Climate Change Conference in Bali, Indonesia, all EU member states agreed to go further than Kyoto targets and commit to emissions reductions of 20% by 2020, increasing to 30% should international agreements be reached. These reductions would be based on the range of greenhouse gases and not on carbon dioxide (CO2) alone.

3.2.3 The two-week Bali conference included sessions of the Conference of the Parties to the UNFCCC, its subsidiary bodies as well as the Meeting of the Parties to the Kyoto Protocol. The conference culminated in the adoption of the 'Bali Roadmap', which initiates a two-year process of negotiations designed to agree a new set of emissions targets to replace those in the Kyoto Protocol and lead to a post-2012 international agreement on climate change. The final text does not mention specific emissions targets, but acknowledges that "deep cuts in global emissions will be required to achieve the ultimate objective" of avoiding dangerous climate change, and that delays in reducing emissions make severe climate impacts more likely.

3.2.4 The roadmap contains text on emissions cuts, the transfer of clean technology to developing countries, halting deforestation and helping poorer nations protect their economies and societies against the impacts of climate change. Consensus was reached on the principle of rewarding poorer countries to protect their forests, which is acknowledged as the cheapest single method of curbing climate change, and brings benefits in other environmental areas such as biodiversity and fresh water conservation.

3.2.5 The roadmap sets the parameters and aims for a further set of negotiations to be finalised by the 2009 UN Climate Conference, to be held in Denmark; by which stage, parties should have agreed a comprehensive plan for curbing global warming and adapting to its impacts. This will include:

• emissions targets for industrialised countries, possibly but not necessarily binding;
• some softer form of targets or ambitions for major developing countries;
• mechanisms for leveraging funds from carbon trading to fund adaptation projects.

3.2.6 Many economists believe that mandatory emissions targets are needed to create a meaningful global market and one of the most significant mechanisms is the EU Emissions Trading Scheme ( EUETS); the current aim of which is to help deliver CO2 emissions reductions where they are most cost-effective. The Scheme is a key feature of the European Climate Change Programme and the largest emissions trading scheme in the world. The EU's 'Linking Directive' (2004/101/ EC) amends the Emissions Trading Directive (2003/87/ EC) and provides for the use of credits from the Kyoto Protocol's project mechanisms in the EUETS. The Kyoto mechanisms provide a means for countries to be awarded credits for projects carried out in other countries that limit or reduce emissions:

• Joint Implementation ( JI) operates between developed countries that are Parties to the Protocol and have a quantified emissions reduction or limitation target (Annex I Parties).
• Clean Development Mechanism ( CDM) operates between one country which is a Party to the Protocol (Annex I) and another which does not have a target (non-Annex I Parties).

3.2.7 The EUETS began in January 2005 and is mandatory for large-scale emitters (see Table 3.1 below). The first phase runs to December 2007 and subsequent phases will last five years, with Phase II running from 2008-2012. The scheme is evolving however, and there are discussions on extending the period to 8 years, widening the scope to apply to other GHG's and increasing the sectoral coverage. An EC announcement on the future of the EUETS is expected by the end of January 2008. ³

3.2.8 In Scotland, the EUETS currently covers almost 50% of Scottish CO2 emissions and will play a vital role in driving emissions reductions across the country. Sections 5.35 to 5.46 of the SCCB consultation document outline the significant interplay between the EUETS, its potential effect on the Scottish target and the difficulties in working an effective solution. In effect, the EUETS could be a limiting factor on the effectiveness of the SCCB, in both the design and management of efforts to meet a domestic reduction target that is more challenging than the EUETS caps.

3.2.9 Should the scheme be extended to apply to all GHG's, and other sectors become eligible for inclusion, the overall impact on the trajectory of emissions reductions towards the SCCB target will need to be closely scrutinised, with suitable mechanisms introduced to track reductions achieved through the EUETS, in conjunction with reductions made outwith the scheme, to allow effective carbon budgets to be realised.

Table 3.1 EUETS Eligible Activities

Activities covered by the EU Emissions Trading Scheme
Energy activities Combustion installations with a rated thermal input exceeding 20 MW (excepting hazardous or municipal waste installations) Mineral oil refineries Coke ovens
Production & processing of ferrous metals Metal ore (including sulphide ore) roasting or sintering installations Installations for the production of pig iron or steel (primary or secondary fusion) including continuous casting, with a capacity exceeding 2,5 tonnes per hour
Mineral industry Installations for the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or lime in rotary kilns with a production capacity exceeding 50 tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day Installations for the manufacture of glass including glass fibre with a melting capacity exceeding 20 tonnes per day Installations for the manufacture of ceramic bricks by firing, in particular roofing tiles, bricks, refractory bricks, tiles, stoneware or porcelain, with a production capacity exceeding 75 tonnes per day, and/or with a kiln capacity exceeding 4m 3 and with a setting density per kiln exceeding 300kg/m 3
Other activities Industrial plants for the production of: (a) pulp from timber or other fibrous materials (b) paper and board with a production capacity exceeding 20 tonnes per day

3.2.10 A range of other international policies that could have an influence on the SCCB are reviewed in Appendix B, including EU energy efficiency and renewables plans/ programmes.

3.3 UK Climate Change Bill

3.3.1 The UK Bill puts into statute targets to reduce CO2 emissions through domestic and international action by at least 60% by 2050 and 26-32% by 2020, against the 1990 Kyoto baseline. The target will be reviewed, based on reports by an independent Committee on Climate Change on whether it should be even stronger still, and the implications of including other greenhouse gases and emissions from international aviation and shipping.

3.3.2 Five-year carbon budgets will set binding limits on CO2 emissions ensuring each year's emissions count. Three successive carbon budgets (representing 15 years) will always be in law - providing a balance between predictability and flexibility. Budgets will be backed by annual accountability and independent scrutiny.

3.3.3 Emission reductions purchased overseas can be counted towards the UK's targets, consistent with the UK's international obligations. This ensures emission reductions can be achieved in the most cost effective way, recognising the potential for investing in low carbon technologies abroad as well as action within the UK to reduce the UK's overall carbon footprint.

3.3.4 The Scottish Government will work in partnership with the UK Government and the Devolved Administrations to meet the CO2 reduction targets. The UK Climate Change Bill will set the direction for reserved policies, as the 60% target applies to the UK as a whole. The UK Bill will have an effect on Scottish emission levels; however the Scottish Government intends to go further by setting a higher 80% emissions reduction target (possibly on a range of GHG's, as well as CO2), where the Scottish Bill will be the driver for action in devolved areas of government.

3.4 Changing Our Ways: Scotland's Climate Change Programme (2006)

3.4.1 The first Scottish Climate Change Programme ( SCCP) was published in 2000 and formally reviewed between September 2004 and early 2006, in parallel with a review of the UK Climate Change Programme ( UKCCP). The updated SCCP was published in March 2006 and set out the main activities across a range of sectors in Scotland to address climate change. It supported Government's commitment to make an equitable contribution to UK targets, under the Kyoto Protocol, and more ambitious domestic goals to identify and realise potential carbon savings.

3.4.2 The SCCP quantified this contribution in carbon terms for the first time, through the Scottish Share concept. The SCCP set a Scottish Target to substantially exceed the Scottish Share by one million tonnes of carbon equivalent emissions by 2010. The main policy developments in key sectors, envisioned as contributing to carbon savings, were outlined. The Programme also set out the Government's role in assisting Scotland to adapt to the unavoidable impacts of climate change, and the mechanisms for moving forward and reporting progress.

3.4.3 The SCCP was expected to deliver environmental benefits through its contribution to global reductions of greenhouse gas emissions, thereby helping to avoid the most serious predicted impacts of climate change on Scotland's natural and built environments. The SCCP focused on devolved policy measures within the Government's control, although it was recognised that reserved policy measures can also have an impact in Scotland - in terms of emission reductions, reducing vulnerability, and wider positive or negative impacts on aspects of the environment.

3.4.4 An informal environmental assessment was conducted upon the SCCP, which recognised that:

" There is an important environmental dimension to climate change - global efforts to curb emissions are necessary to ensure we live within environmental limits - although it should be stressed that climate change has far reaching consequences for our economy and society as well. However, it is not always the case that policies which deliver carbon savings are necessarily benign on other aspects of the environment."

3.4.5 The assessment also states that the process resulted in a:

"Greater emphasis throughout the Programme on the need to tackle climate change in Scotland in a sustainable way, which includes consideration of wider environmental impacts, and that a mechanism to ensure this happens throughout the Government was needed as part of our mainstreaming of climate thinking. In addition, a specific recommendation was included in the SCCP to consider how climate factors are being addressed at policy, plan and programme level as part of the review of the SEA process and contribute to strengthening guidance if necessary."

3.4.6 It is anticipated that the Scottish Climate Change Bill will put an ambitious emissions reduction target into statute, and that whilst the measures and policies outlined within the SCCP (2006) will contribute; the statutory imperative to do more, as set by the target, should drive stronger action and a commitment to greater reductions (upon strategy or policy review), in conjunction with new measures and secondary legislation following the adoption of the SCCB.

3.5 Key Scottish Strategies and SEAs

3.5.1 In this section, some key Scottish sectoral PPS that are more specifically related to climate change and potential emissions reductions, and which have undergone SEA, are reviewed briefly. It is expected that targets introduced by the SCCB will act upon these strategies/ programmes to drive more ambitious commitments to action and help deliver effective emissions reductions.

3.5.2 It is also likely that strengthening SEA guidance or requirements on the consideration of climatic factors, to account for and address likely emissions effects will help maintain the long term focus on reducing emissions across all areas of government and policy review. (Section 8.29 of the SCCB consultation document discusses SEA and Question 31 aims to evaluate these considerations further).

SPP 6: Renewable Energy and SEA

3.5.3 SPP6 outlines how the Scottish Ministers expect the planning regime to facilitate development of renewables in Scotland. Planning authorities are expected to make positive provision for renewable energy developments by:

• Supporting a diverse range of renewable energy technologies including encouraging the development of emerging and new technologies.
• Recognising the importance of fully engaging with local communities and other stakeholders at all stages of the planning process.
• Guiding development to appropriate locations and providing clarity on the issues that will be taken in to account when assessing specific proposals.
• Maximising environmental, economic and social benefits.

3.5.4 An SEA was carried out for SPP6 ⁴ and the main findings relating to climate change were:

• Renewables were assigned a positive impact on climatic factors due to a reduction in CO2 emissions compared to other technologies.
• Siting of renewables projects was highlighted as having the potential to have negative impacts on climatic factors through the disturbance of peat soils.
• These measures were already considered in NPPG6, which represents the "status quo" for the assessment. Overall, SPP6 was not assessed as having an impact on climatic factors when compared against NPPG6 and the status quo.

3.5.5 Development of renewable capacity is vitally important for the success of the SCCB and statutory emissions reduction targets will help drive further uptake and integration of renewables across Scotland. The Scottish Government has recently announced new targets for energy supplied from renewable sources of 31% by 2011 and 50% by 2020, up from 40% by 2020.

3.5.6 As stated in the SEA, the key environmental concern will be the appropriate siting of installations and the minimisation of risks to carbon stores in soils.

Energy Efficiency and Microgeneration Strategy for Scotland and SEA

3.5.7 The first Energy Efficiency and Microgeneration Strategy for Scotland sets out the Government's aims for improving energy efficiency and encouraging a greater uptake of microgeneration. Energy efficiency and microgeneration can help achieve a low carbon future for Scotland's homes and workplaces and the Strategy takes and reflects a more joined-up approach.

3.5.8 Coupled to energy efficiency, microgeneration could make a significant contribution to tackling climate change, by ensuring reliable energy supplies and providing a powerful visual statement which helps to increase awareness and engage the public in taking action. It can provide a sustainable source of low carbon energy and help reduce carbon dioxide emissions from homes, small commercial buildings and community buildings, including leisure centres and schools.

3.5.9 An SEA⁵ of the Strategy was commissioned by the Scottish Government. The main relevant findings of which included:

• There will be no significant environmental effects of the Draft Strategy per se on biodiversity, soils, water and cultural heritage, as it does not directly promote development projects.
• Overall slight positive effects on air quality, climatic factors, human health, and neutral impacts on visual amenity.

3.5.10 As the built environment in Scotland is a major energy consumer, SCCB targets should help drive efficiency measures that reduce emissions from the use of buildings and throughout the development chain, to promote considerations of embodied energy and carbon emissions.

3.5.11 Wider benefits of energy efficiency measures can be demonstrated by the light bulb analogy, represented in Figure 3.1 below, where the power required for 10 units of light (heat) energy at the point of use, translates to roughly 130 units required in upstream extraction and transport, production, distribution, transmission and efficiency losses. Therefore, saving one unit of energy demand equates to saving up to 13 units required to supply that single unit to the point of use.

Figure 3.1 Light Bulb Energy Use and Upstream Energy Requirements

Source: Tyndall Centre for Climate Change

3.5.12 Many modern electrical appliances operate under similar inefficiencies therefore, at the national level, significant reductions in energy demand across homes and businesses can save a vast amount of energy, and hence help reduce overall emissions. However, there may be difficulties in ensuring the SCCB target reflects progress in energy efficiency, as demand may not change substantially eg. if a greater number of more efficient appliances are used.

Marine Renewables and SEA

3.5.13 Development of marine renewables could provide an important contribution to Scotland's renewable obligations and also to its wider climate change objectives. Recognising this, the Scottish Government commissioned an SEA⁶ to examine the environmental effects of developing wave and tidal power and to use the results to inform the preparation and delivery of the Scottish Government's strategy for the development of marine energy.

3.5.14 SEA Objectives were to assess, at the strategic level, the effects on the environment of meeting or exceeding the Marine Energy Group's estimate of 1,300 MW of marine renewable energy capacity around Scotland by 2020, and:

• To advise and support the Scottish Government in the development and implementation of its strategy for marine renewable energy and to inform future development of planning guidance for marine developers;
• To inform the project-level decision-making process for all stakeholders (to include regulators and developers), and
• To facilitate focused investment into the marine renewable energy sector in Scotland.

3.5.15 The primary question addressed in this SEA was: can wave and tidal stream energy contribute towards helping the Scottish Government achieve its (then) target for producing 40% of its electricity from renewable sources by 2020 without significant effects on the environment, and if so, how can this best be achieved?

3.5.16 The main conclusions included:

• Wave and tidal devices could have moderate to major significant effects on coastal processes, particularly in areas with high levels of erosion, accretion and long-shore drift.
• Failure of a device or part of a device could result in the accidental spillage or leakage of potentially polluting substances e.g. hydraulic fluids, lubricating oils, cleaning fluids, paints, or toxic substances.
• The effect on water quality depends on the quantity of potentially polluting substances released, the type of substance e.g. whether it is toxic or non-toxic, soluble or insoluble, and the sensitivity of receptors to the substance.
• The physical presence of vessels and equipment involved in the installation of marine devices could potentially disturb marine birds, mobile fish species and marine mammals.
• Marine noise generated during the installation and operation of devices could have major significant effects on marine birds, marine mammals and fish.
• Seabed disturbance during device installation and cable trenching could lead to increased levels of suspended sediment/ turbidity. This could potentially have moderate to major significant effects on benthic and shellfish species in close proximity to the works.

3.5.17 The framework provides a national context for development plans and planning decisions and will inform the ongoing programmes of the Government, public agencies and local government. It is also one of the factors the Government will take into account in coming to decisions on policy and spending priorities.

3.5.18 Action to meet the SCCB targets is likely to increase the focus on efforts to realise effective energy supplies from marine sources, and to help develop a market for Scottish technological expertise.

3.5.19 SEA would suggest that off-shore renewables decisions must take account of as many, if not more, environmental considerations as on-shore. Care must be taken to ensure that decisions on emissions reductions measures consider the cost (financial and environmental) of supporting off-shore renewables against similar capacity development of proven on-shore technologies.

National Planning Framework and SEA

3.5.20 The framework is a non-statutory planning policy document, which looks at Scotland from a spatial perspective and sets out an achievable long-term vision. It provides a view of Scotland as a place and identifies likely change to 2025 to ensure different areas can develop to their full potential. It also identifies key strategic infrastructure needs to allow planning for the right investment in the right places.

SNH Consultation Comment: "Paragraph 3.5.20 - Note that the National Planning Framework now has statutory status following the passage of the Planning (Scotland) Act 2006." SEA Response: Noted - the ER stated that the NPF is non-statutory and this is accepted as an error; however, the inclusion of this note is considered sufficient to address the error.

3.5.21 The framework provides a national context for development plans and planning decisions and will inform the ongoing programmes of the Government, public agencies and local government. It is one of the factors the Government will take into account in coming to decisions on policy and spending priorities.

3.5.22 The Scottish Government undertook a voluntary SEA⁷ of the Framework; its main findings with relevance to climate change were:

• All of the aims are likely to have some positive effects on the environment. Increased economic growth and competitiveness can deliver a higher quality of life, improved infrastructure and better environments. A commitment to environmental justice can ensure improved living environments and better health for disadvantaged communities. However, care will need to be taken to ensure that development promoted in furtherance of economic growth and competitiveness complements and reinforces environmental aims and objectives. Proposals will need to be carefully assessed at the development plan and project stages.
• Negative impacts on climate are possible if external links are developed or strengthened, mainly through better road links or encouraging air travel (though this can be mitigated through promoting more sustainable patterns of surface transport, countering long-distance commuting and using pricing to manage travel demand).
• Support for renewables development, better waste management, developing recycling capability, developing rail services, supporting public transport development, may all have a beneficial impact on climate, although there can be localised negative impacts on many of the SEA topics.

3.5.23 The process of updating the NPF commenced in 2006/7 and a new SEA Scoping Report has been submitted. Our understanding is that the completed SEA and associated assessments have not been reported as yet.

3.5.24 It is likely that the planning system will play a key role by either limiting or enabling certain actions taken to meet SCCB targets. SEA suggests that major advantages lie in developing a more holistic approach to climate change mitigation and adaptation that accounts for local environmental impacts in a managed, sustainable and equitable manner whilst allowing efficient and justifiable planning processes and decisions to be made.

Scotland's National Transport Strategy (2005) and SEA

3.5.25 We are travelling more by car in comparison with other terrestrial modes. We are also travelling more by plane; with one of the most significant changes in transport in recent years being the dramatic growth in air travel. These trends are expected to continue. The National Transport Strategy ( NTS) sets out three key challenges/ outcomes to be addressed through transport policy making for the next 20 years.

• Improve journey times and connections;
• Reduce emissions;
• Improve quality, accessibility and affordability.

3.5.26 NTS forecasts suggest total road traffic will grow by around 12% between 2005 and 2010 and by 22% between 2005 and 2015, with air travel predicted to rise by 150% between 2004 and 2030. To measure progress against strategic outcomes, a range of indicators will be developed, including the introduction of a carbon balance sheet for transport, to present the impact of all Scottish transport policies and projects that are expected to have a significant impact on carbon, whether positive or negative.

3.5.27 The voluntary SEA of the NTS⁸ presented a high level assessment which aimed to provide a framework for further more detailed environmental appraisal at regional and local levels, where there is greater certainty regarding the exact location, nature and specifications of different measures, especially in terms of proposals for new infrastructure. The main findings with respect to climate included:

• Promotion of policies to effect a stabilisation in overall traffic and less demand on the existing network through measures to reduce the need to travel, manage demand and encourage modal shift would have positive environmental benefits in terms of climatic factors, in particular carbon related emissions.
• Possible increase in the proportion of public transport vehicles would require promotion of cleaner fuels and technology to ensure benefits are maximised. Also a need to ensure targeted modal shift from the car to alternatives is not accompanied by an unintended shift from non-motorised to motorised transport that could potentially off-set any gains.
• Biofuels widely recognised as more environmentally sound option. Gains offset to a degree by cultivation processes and intensive land use which can lead to carbon emissions. However, potential scope to enhance environmental performance through developments in production processes and use of biomass to generate hydrogen for fuel cells from which water would be the only by-product.
• Careful management required to ensure released network capacity from measures to manage existing demand and encourage use of alternative modes to private car do not encourage uptake of space by other vehicles, resulting in no overall benefit to the environment.

3.5.28 Over time, Scottish transport emissions will play an increasingly important role in efforts to meet SCCB targets, and actions/measures identified in the NTS are likely to require strengthening to drive further reductions over limited timescales. It is also likely that fiscal measures need to be introduced to maximise modal shift, limit vehicle use and encourage greater fuel efficiencies.

SNH Consultation Comment: "Paragraphs 3.5.25-3.5.28 state that biofuels are widely recognised as a more environmentally sound option. This statement must be substantially qualified. International discussions are still underway with a view to ensuring that biofuels are based on sustainable production - for example using crops which do not replace valuable habitats and grown and harvested such that significant life cycle carbon savings are achieved. There are also global issues emerging about competition between land for biofuels and food. Biofuels are indeed likely to play an important role in carbon reduction for transport, but great care will be needed initially, with the real potential probably realised only when second generation biofuels (based on ligno-cellulose) become economic." SEA Response: The statement on biofuels was taken directly from the Government's own SEA of the National Transport Strategy. The issues raised by SNH are accepted and the ER does discuss sustainable sourcing, local impacts and international trading restrictions under Material Assets and Transport Mitigation on pages 33 and 42. It is accepted that there are significant difficulties and issues associated with the sustainable development and growth of acceptable biofuel solutions, but the ER simply recognises that they are likely to be of increasing importance within the future transport fuel mix. This inclusion of SNH's comment and the above statement recognising that there are potentially adverse side-effects associated with the cultivation and use of unsustainable biofuels, is considered sufficient to address SNH's comments.

Scottish Forestry Strategy and SEA

3.5.29 The Scottish Forestry Strategy ( SFS) is one of the key elements for the overall direction of rural development and industry in Scotland, in conjunction with the Scottish Rural Development Plan and the Next Steps Strategy for Agriculture. At the present time, each of these has distinct strategies and departments with distinct responsibilities. The SFS is the responsibility of Forestry Commission Scotland ( FCS) and the underpinning vision, to 2025 and beyond, is:

" Scotland's trees, woodlands and forests are a central part of our culture, environment and economy. People are benefiting widely from them, actively engaging with and looking after the resource for the use and enjoyment of generations to come."

3.5.30 The vision reflects the emphasis within the SFS on the three key social, environmental and economic strands of sustainability. This is supported by the principles of sustainability, social inclusion, and forestry for and with people. The three key outcomes of the SFS are:

• Improved health and well-being of people and their communities.
• Competitive and innovative businesses contributing to the growth of the Scottish economy.
• High-quality, robust and adaptable environment.

3.5.31 In 2005 FCS completed an SEA in conjunction with the review process for updating the SFS. ⁹ A summary of the key SEA findings, with respect to climate, would include:

• Climate change adaptation and mitigation provide both a challenge and an opportunity for the forestry sector. There is a need to ensure that the sector contributes as far as possible towards mitigation targets, through both short- and long-term projects that aim to reduce carbon emissions. This reflects the importance of balancing different mitigation strategies; for example, long-term carbon fixing compared to relatively short-term, high gain, projects such as renewable energy schemes. Indeed, climate change policy in Scotland provides a major challenge for most policy commitments, including forestry.
• There are opportunities where SFS objectives and themes could achieve additional benefits through enhancement. These include promoting the growth and management of trees, which provide multiple benefits by providing both economic and natural heritage value.
• Forestry should be considered within the wider context of rural land use and decision making. Woodlands can contribute to, and be supported by, farming practice and sustainable transport is a key national policy aim, to which the forestry sector has the potential to contribute.
• Rural development is a key policy priority in Scotland, with diversification, and economic development (including tourism) being important aims which sit alongside environmental protection and community development.
• Contextual analysis shows that there remain policy concerns that some environmental resources are continuing to be degraded. This is illustrated by a lack of progress towards meeting some of the key national indicators for sustainable development.

3.5.32 The SCCB targets should lead to greater action within sustainable forestry and land management to increase afforestation, provide woody biomass and further sequester carbon over the long-term.

A Forward Strategy for Scottish Agriculture: Next Steps and retrospective SEA

3.5.33 'A Forward Strategy for Scottish Agriculture: Next Steps', was produced in March 2006. Key desired outcomes for the industry are described as:

• being competitive in markets;
• being a driver of sustainable rural development; and
• being renowned for high environmental standards.

3.5.34 The Strategy includes the key goal that,

" Scottish agriculture should continue to be a leading player in the protection and enhancement of our environment, with increased emphasis on climate change and the promotion of a landscape-scale approach"

3.5.35 Within which, key actions include:

Action 9: Promote research into the commercial viability of alternative crops and biomass.

Action 14: Establish a stakeholder group to evaluate and monitor agriculture's response to climate change, through mitigation and adaptation.

Action 17: Implement action on diffuse water pollution based on sound science and the outcome of the current consultation exercise.

Action 15: Promote an integrated, landscape-scale approach to environmental improvement with clearly established local and regional priorities.

3.5.36 The SEA assessed the commitments within the Strategy and found that:

• Long-term positive impacts associated with the action on climate change, once the stakeholder group moves from evidence gathering to driving action on mitigation and adaptation. This is a key factor, as the effects of climate change are likely to become more pronounced in the coming years.
• Related action on the viability of energy crops and the development of an effective market will prove beneficial, with respect to carbon sequestration and work towards reducing Scotland's share of greenhouse gas emissions. However, potentially negative effects are associated with large scale conversion to monocultures and relatively intensive management processes, with respect to biodiversity and habitat networks, landscape and the historic environment. Again, effective assessment of these effects would be required at the local level with appropriate provision for inter-cropping or biodiversity breaks considered, as well as analyses of impacts on the local landscape, the historic environment and anticipated soil and water effects. These analyses should become part of the standard applications for energy crop schemes.
• Positive effects are to be expected with actions related specifically to diffuse water pollution, biodiversity action and developing a landscape scale approach to ensure effective, managed action on each of these factors.

3.5.37 SCCB targets should further drive action on climate change mitigation and adaptation, as noted above, and a report from the working group on agriculture and climate change is expected early in 2008.

Scottish Rural Development Plan and SEA

3.5.38 The reform of the Common Agricultural Policy ( CAP) in 2003 provided the opportunity to introduce, through the SRDP, Land Management Contracts which are intended to support the delivery of environmental, economic and social benefits. The SEA considered the environmental implications of the objectives for Land Management Contracts ¹⁰ ( LMC) and concluded that five main actions were identified as having potentially negative impacts:

1. Increased production of feedstock and energy crops for renewable energy production.
2. Construction of renewable energy plants within rural Scotland such as wind farms and hydropower schemes.
3. Increasing the number of rural processing facilities by the construction of new buildings.
4. The creation of recreational and tourism attractions which require land take.
5. Changes in the infrastructure of communities in rural Scotland.

3.5.39 All five could result in a range of impacts including the loss of land supporting biodiversity interests and priority and/or protected habitats and/or species, impacts on soil quality and quantity, impacts on the water environment and impacts on air quality and the release of greenhouse gases to the atmosphere.

3.5.40 Mitigation measures suggested included the development of a National Renewables Strategy to identify those areas where wind farms, hydropower schemes, biofuel plants (and associated biomass cropping sites), marine and coastal renewable schemes should be permitted and those areas where, due to a number of reasons such as the sensitivity of the environment and/ or remoteness from the National Grid, renewable plant development should not be permitted.

3.5.41 With regard to biomass cropping, mitigation included interspersing areas of monoculture biomass crops with new hedging, biodiversity crops or other habitats to break up the visual impact on the landscape and increase biodiversity levels, as well as the introduction of crop rotation to prevent large scale harvesting and associated negative environmental impacts.

3.5.42 Within its strategic goals, the SRDP now contains a priority commitment on tackling climate change and meeting relevant international and UK commitments on air quality by:

• reducing gaseous emissions from the management and use of rural land in ways which have a beneficial impact on climate change and air quality;
• enhancing the significant role played by carbon sinks in Scotland (e.g. peat and woodland);
• conserving soil organic matter and encouraging targeted fertiliser applications to reduce emissions to air in addition to climate change mitigation; and,
• adapting to climate change, considering the effects on flood risk and biodiversity in particular.

3.5.43 The SRDP does contain an outline action, measure and target for climate change:

Action - Woodland Planting Current Measure - 17% land cover Target - Increase

3.5.44 SCCB targets are likely to help drive the uptake of LMC measures over the medium-long terms.

Scottish Biodiversity Strategy

3.5.45 The Scottish Biodiversity Strategy ¹¹, "Scotland's Biodiversity: It's in Your Hands" which aims to conserve biodiversity for the health, enjoyment and wellbeing of the people of Scotland now and in the future, was published by the Scottish Government in May 2004. This strategy was developed in close partnership with the Scottish Biodiversity Forum, a broad based partnership of public, private and voluntary organisations; however, no SEA was conducted at the time.

3.5.46 At the local level, the Local Biodiversity Action Plan process ensures effective delivery on the ground as well as raising awareness of local biodiversity issues and action. The vision which the Strategy works towards is that by 2030, Scotland is recognised as a world leader in biodiversity conservation. Everyone is involved and everyone benefits.

3.5.47 It is likely that actions required to meet the SCCB targets may have some localised effects on biodiversity, however in many cases these should be addressed through EIA or Appropriate Assessment ( AA), should Natura 2000 sites (under European protection) be affected. Biodiversity issues require full and proper consideration, and can lead to delays in the planning process, potentially limiting the rate at which emissions reduction measures are implemented.

Note on the Nature Conservation (Scotland) Act 2004

3.5.48 Section 12 of the Nature Conservation (Scotland) Act 2004 relates to the exercise of functions in relation to Sites of Special Scientific Interest ( SSSI) specifically applying to "the exercise by a public body or office-holder of any function on, or so far as affecting, any land which is or forms part of a site of special scientific interest".

3.5.49 Section 12 (2) states that the body or office-holder must-

(a) consult SNH in relation to the exercise of the function,

(b) have regard to any advice given by SNH, and

(c) in exercising the function, take reasonable steps, so far as is consistent with the proper exercise of the functions of the body or office-holder, to-

(i) further the conservation and enhancement of the natural feature specified in the SSSI notification, and

(ii) maintain or enhance the representative nature of any series of sites of special scientific interest to which the SSSI notification contributes.

3.5.50 In developing the SCCB, the Scottish Government will consult a wide of range of stakeholders including SNH, and it is anticipated that the implementation of measures derived from the SCCB will be also guided by consultations with SNH, in line with the 2004 Act.

3.6 Comment on Extended PPP/ PPS Review

3.6.1 As part of its contribution to the international effort required on climate change, the Scottish Government is committed to achieving an 80% reduction in Scotland's emissions by 2050 and to place this in statute. The Scottish Government considers this to be an integral part of its overall purpose to deliver sustainable economic growth. To achieve this will require action on the part of every business, every household and will affect the daily lives of all the people of Scotland. ¹²

3.6.2 Scotland emits 0.2% of worldwide greenhouse gases however, with only 0.1% of the world's population; this is a disproportionately large level of emissions. Although the magnitude of Scotland's emissions is small in global terms, as a developed nation, Scotland has a distinguished legacy of leading in industrial innovation, production and manufacture and hence, a moral imperative to take a lead in providing another example of best practice in innovation and industrial adaptation to reduce its emissions burden. Climate change and greenhouse gas mitigation presents an extremely complicated, long-term problem that must be addressed in a rational, coordinated, cross-sectoral manner. The SCCB may therefore lead to wide ranging policy reviews and specific commitment to emissions targets across each policy area.

3.6.3 It is expected that the statutory target set by the SCCB will provide a much more effective incentive/driver for action across many more policies, strategies and initiatives than the (mostly) voluntary measures in place today. Appendix B provides an overview and analysis of a wide range of policies that will be influenced by the SCCB, and a summary highlights the following issues relating to the SCCB target:

• The Bill will set a national target for emissions reduction within a statutory framework.
• SCCP schemes present strategic objectives to meet Scottish obligations, but with the Bill likely to implement quantitative carbon budgeting periods, there is a lack of commitment on quantifying actual reductions to be realised. SCCB targets should drive such commitments.
• There is co-ordinated target-based action within those sectors currently operating within the EUETS, and although this may present a limiting factor for the SCCB target, complementary sectoral targets may help drive progress. At present, it is feasible that actors within other sectors ignore the issue, assuming savings are being made elsewhere.
• Carbon reduction measures outlined in the National Transport Strategy, specifically those resulting from devolved policies, offer very limited projected contributions to the Scottish Share of emissions reductions. Little quantified information is provided on how to manage or control transport-derived greenhouse gas emissions in Scotland.

3.6.4 There is some evidence of a 'joined up' approach to climate change, however so far, no national strategies have produced clear GHG emissions reduction targets. Many include phrases that commit to work to achieve the 'Scottish Share', but in the context of a statutory reductions target much more ambitious language and commitment is required. The PPS review in Appendix B helps highlight the following issues:

• Within the energy generation sector renewable energy developments will be central to delivering reductions (targets for total energy from renewables have recently been increased), but again, there is little indication of which "sectors within the sector" will be supported and developed, and what the expected contributions of each will be.
• There is potential divergence between the Scottish and UK administrations on the future role of nuclear power. 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. Significant gains will be required in renewables development.
• The current planning system may not facilitate the required rapid development of Scotland's renewable capacity; this may be an area that the SCCB target wields significant influence.
• There is also the issue of grid infrastructure development (which is a reserved matter) in terms of developing capacity for distributed generation and, long-term, energy feed in from micro-renewables. The SCCB target may help focus attention on long-term grid investment.
• A multitude of initiatives and advice bodies face both the domestic and business sectors, which could be confusing. A one-stop shop for all energy issues would be helpful.
• Agriculture and forestry are often promoted as offering significant contributions to emissions targets, but it is unclear how this will be realised. Carbon sequestrations may be outweighed by methane and nitrous oxide emissions from agriculture and as such, effective quantification is required. Appropriate biomass production and use may offer significant diversification opportunities to the land use industries, but this must be balanced by effective investment in distributed processing and CHP systems, to minimise downstream emissions and improve overall energy efficiencies.
• It will be difficult to ensure transport makes appropriate contributions, as the fiscal side of transport is a reserved area (fiscal measures will likely be major levers in reducing transport emissions). Difficult decisions will be required to address transportation issues, for example on major road building schemes, and potentially strengthening the planning regime to limit developments which generate further car usage.
• Direct environmental impacts at a project level can be evaluated/ controlled by existing methods ( EIA, planning, etc.), however strengthened regulations and guidance should be provided on climate considerations to minimise overall emissions and account for embodied carbon costs.