1 Introduction
1.1 Background
1.1.1 The Scottish Executive Energy Efficiency Unit (the Responsible Authority) has prepared a draft Energy Efficiency and Microgeneration Strategy for Scotland (the Draft Strategy). The Draft Strategy sets out the Executive's aims for improving energy efficiency and encouraging a greater uptake on microgeneration across the domestic, business and public sectors. This consultative draft highlights work underway, sets out progress being made, and outlines work that is currently planned for the future. The Scottish Executive has determined that, on a voluntary basis, it would be prudent to undertake a Strategic Environmental Assessment ( SEA) of the Strategy.
1.1.2 WSP Environmental Ltd, in association with Estrata, was appointed by the Scottish Executive Energy Efficiency Unit to undertake the SEA of the Draft Strategy. The results of the SEA are presented in this Environmental Report ( ER).
1.2 Statutory Context for the SEA
1.2.1 The Responsible Authority does not consider that the Draft Strategy requires mandatory SEA within the terms of the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004 (the Regulations), but has chosen to volunteer an SEA because the Draft Strategy can be defined as a "plan or programme" under the Regulations and partly meets the relevant criteria under Regulation 9a. Although the Environmental Assessment (Scotland) Act 2005 (the Act) has now come into force, the first preparatory act of the Draft Strategy was undertaken prior to commencement of the Act, and therefore the SEA has been undertaken in accordance with the Regulations and not the Act.
1.3 Purpose of this Environmental Report
1.3.1 The purpose of this ER is to set out the findings of an environmental assessment of the Draft Strategy. In accordance with Part 3 of The Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004, the Environmental Report identifies, describes and evaluates the likely significant effects on the environment of implementing the Draft Strategy and the reasonable alternatives to this which have been assessed.
1.3.2 The report is intended to provide this information for the Consultation Authorities (Scottish Natural Heritage, Scottish Environment Protection Agency and Historic Scotland) and the general public during public consultation on the Draft Strategy. Further information on consultation activities and approach for the Draft Strategy and the SEA is presented in Section 1.6 of this report.
1.4 Context of the Energy Efficiency and Microgeneration Strategy
1.4.1 The Draft Strategy has been produced as a response to various commitments made by the Scottish Executive in relation to an overarching and coordinated approach to energy efficiency and microgeneration in Scotland, not least through the Scottish Climate Change Programme, which states that it "…will encompass a more joined-up approach to energy efficiency interventions in the residential, business, transport and public sectors."1
1.4.2 Recent publications have refocused and highlighted the potential impacts of climate change on human society, and indeed the significance of the human influence on our changing climate. The recent Intergovernmental Panel on Climate Change ( IPCC) Fourth Assessment Report 2 and the Stern Review 3 have respectively focused attention on the generally accepted principle that the main causes of climate change are, indeed, human influenced, and that there is a compelling economic case for urgent action on climate change.
1.4.3 The SCCP recognises the important role that energy efficiency and microgeneration could play in reducing carbon emissions and achieving the targets set within the Programme. The Draft Strategy has been organised to tackle the domestic, business and public sectors, identifying the main programmes, initiatives and funding streams which relate to each. As a result, the current Draft Strategy does not introduce any new measures or initiatives that would not exist in some form or another regardless of the existence of the Draft Strategy. That is not to detract in any way from the value of the Draft Strategy, but rather recognition of the fact that the purpose of this is to draw together all of the work being undertaken by various organisations and agencies into a single, connected and comprehensive strategy. Once the consultation on the Draft Strategy has concluded, the Executive will consider all responses and take these into account when preparing the Final Strategy. All of the existing and new targets and commitments in the Final Strategy will be compiled into a single Action Plan which will be published during 2007.
1.4.4 In addition to measures in the Draft Strategy for Scotland, there are a range of initiatives and actions that fall within a UK-wide remit and are reserved to Westminster. These are addressed in an Annex to the Draft Strategy and are not incorporated into the main body of the document as these would not contribute to the Scottish Share or Scottish Target identified in the Scottish Climate Change Programme. These measures are therefore not assessed specifically in this ER.
1.5 Key Facts about the Draft Strategy
1.5.1 The key facts relating to the Draft Strategy are set out below.
Name of Responsible Authority
- The Scottish Executive Energy Efficiency Unit
Title of Strategy
- Draft Energy Efficiency and Microgeneration: Achieving a low carbon future: A Strategy for Scotland:
Requirement for the Strategy
- Commitment to producing the Strategy identified in Scotland's Sustainable Development Strategy and Climate Change Programme.
Strategy Subject
- Energy efficiency and microgeneration
Period Covered by the Strategy
- Specifics of the Draft Strategy cover a variety of time-periods dependant upon the individual measures or initiatives. The Final Strategy may include future commitments announced under the forthcoming Spending Review 2007.
Frequency of Updates
- The Draft Strategy will be updated prior to publication of the Final Strategy and Action Plan. The Action Plan will be reported on annually.
Strategy Area
- The Draft Strategy extends to the whole of Scotland.
Plan Purpose and Objectives
- The Scottish Executive recognises the critical role which energy efficiency and micro-generation plays in responding to the challenges of climate change and moving Scotland towards a sustainable, low carbon economy. The Draft Strategy is intended to help join up action and promote partnership working in these areas across all sectors.
- The Draft Strategy sets clear policy objectives across the Executive consistent with UK policy measures on what energy efficiency and micro-generation should deliver in assisting Scotland to make its equitable contribution to UK domestic and international obligations on carbon reduction.
Contact Points
- Queries on the Strategy should be addressed to:
- The Energy Efficiency Unit, Scottish Executive Energy Efficiency Unit, 2 nd Floor, Meridian Court, 5 Cadogan Street, Glasgow, G2 6AT. Tel 0141 242 5522, Email: eemstrategy@scotland.gsi.gov.uk
- Queries on the SEA of the Strategy should be addressed to:
- Andrew Mitchell, WSP Environmental Ltd, 4/5 Lochside View, Edinburgh Park, Edinburgh, EH12 9DH. Tel 0131 344 2300, Email: Andrew.Mitchell@wspgroup.com
1.6 SEA Activities and Consultation
1.6.1 The following activities have been undertaken in completing this SEA:
- Preparation of a Scoping Report setting out the proposed approach to the SEA and the proposed period for public consultation. It also presented the view of the Responsible Authority on:
- The environmental topics to be scoped out of the SEA.
- Relationships with other plans, programmes and environmental objectives.
- The environmental baseline.
- Environmental problems and issues.
- Likely evolution of the baseline without the Draft Strategy.
- Submission of the Scoping Report to the Consultation Authorities, via the Scottish Executive SEA Gateway.
- Review of Consultation Authorities responses to the Scoping Report.
- Designing and undertaking the detailed environmental assessment.
- Reporting the environmental assessment in this ER together with proposals for mitigation measures and future monitoring of Strategy implementation.
1.6.2 The Draft Strategy has developed as a result of a commitment to draw together information on the broad range of initiatives and programmes which seek to increase awareness and take up of energy efficiency and microgeneration in Scotland. As a result, in addition to the current formal consultation on the Draft Strategy, consultation activities have taken place across all of these linked initiatives, as well as the more strategic national level agenda areas such as climate change, transport and sustainable design, and all of this activity has fed into development of the strategy. The key areas of consultation activity to date include:
1.6.3 In addition to these formal consultations, the Scottish Executive Energy Efficiency Unit has undertaken extensive consultation across other Executive Departments, and has consulted informally with a number of organisations with an interest in the content of the Draft Strategy, including:
- Scottish Building Standards Agency ( SBSA).
- The Carbon Trust.
- Energy Saving Trust.
- Communities Scotland.
- Scottish Renewables Forum.
- Friends of the Earth Scotland.
- Scottish Enterprise Energy Technology Centre.
- Scottish Further and Higher Education Funding Council.
- The Wise Group.
- The Eco-schools Programme Managers.
- Local Authorities.
- BRE Scotland.
1.6.4 Feedback from these consultation activities has been taken into account in developing the Draft Strategy and undertaking the SEA.
1.6.5 In addition, there is a formal SEA consultation process which is being undertaken. The main elements of this are as follows:
- Scoping Report sent to Consultation Authorities in October 2006.
- Draft Strategy and ER for consultation (this document).
- Final Strategy and Post adoption SEA Statement, detailing the way in which responses to the Draft Strategy and ER have been taken into account in the final version of the Strategy.
1.6.6 The Responsible Authority is currently at the second of these stages, as the Draft Strategy and this ER are published for consultation. The responses to this will be reviewed and reflected, where appropriate, in the final version of the Strategy accompanied by a post-adoption SEA Statement.
1.7 Overall Approach to the SEA
1.7.1 This ER has been prepared with reference to the following SEA guidance:
- Scottish Executive (2006) Strategic Environmental Assessment Toolkit, Version 1 (Sep 2006);
- Scottish Executive (2003) Environmental Assessment of Development Plans, Interim Planning Advice;
- Scottish Executive Circular 2004/2 (2004) Strategic Environmental Assessment for Development Planning; the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004;
- Office of the Deputy Prime Minister (2005) A Practical Guide to the Strategic Environmental Assessment Directive;
- European Commission DG Environment (2004) Implementation of Directive 2001/42 on the Assessment of the Effects of Certain Plans and Programmes on the Environment.
1.7.2 Guidance on the SEA Directive produced by the (then) Office of the Deputy Prime Minister ( ODPM) identifies a series of requirements, which have been followed in completing this SEA. These are summarised in Table 1.1 along with a comment on where each has been addressed.
Table 1.1: SEA Directive Guidance
Requirements | Response within SEA of the Strategy |
|---|
a) | Outline of the contents, main objectives of the plan and relationship with other relevant plans | Addressed initially within the Scoping Report and presented in this Environmental Report |
b) | Relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan |
c) | Environmental characteristics of areas likely to be significantly affected |
d) | Existing environmental problems which are relevant to the plan |
e) | Environmental protection objectives established at international, community or national level, which are relevant to the plan and the way those objectives and any environmental considerations have been taken into account during its preparation |
f) | Likely significant effects on the environment | Addressed within this Environmental Report |
g) | Measures envisaged to prevent, reduce and as fully as possible offset significant adverse effects on the environment of implementing the plan |
h) | Outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties |
i) | Description of measures envisaged concerning monitoring in accordance with Article 10 |
j) | Non-technical summary of the information provided under the above headings |
1.8 Scoping of Likely Significant Environmental Effects
1.8.1 Due to the nature and subject matter of the Draft Strategy, the SEA team considered that there were a limited number of relevant SEA topics which needed to be addressed in detail, and these are identified early in this ER in order to justify the exclusion of more detailed information relating to those topics which have been scoped out of the assessment. In coming to this view, in accordance with Schedules 1 and 2 of the Regulations, the Responsible Authority has considered whether the environmental effects (positive and negative) of the Draft Strategy are likely to be significant, and has focused the assessment work on identifying and assessing those topic areas upon which it considers the likelihood of significant environmental effects to exist.
1.8.2 This process involved identification of environmental topics upon which to structure the SEA appraisal framework. The scope and content of this report has been guided by the relevant criteria for Environmental Reports set out in Schedule 2 of the SEA Regulations as identified in Table 1.2, which also presents the view of the Responsible Authority as to which topic areas should be scoped out of the assessment and a justification for this view.
1.8.3 This was presented to the consultation authorities in the Scoping Report and their detailed responses are presented in Appendix A, together with the response of the Responsible Authority in relation to each point raised. Table 1.2 also identifies, by topic area, the views of the consultation authorities in relation to the scope of the SEA. In particular, dialogue was held with SNH due to a number of differing points of view on the scope of the assessment. Their original scoping response of 10 th November 2006 notes a number of areas of disagreement with the proposed scope. As a result, WSPE, on behalf of the Responsible Authority, wrote to SNH on 27 th November 2006 providing further justification and responding to the points raised by SNH. This was followed by a final response from SNH on 15 th December 2006. WSPE has considered in detail all of the points raised by the consultation authorities and has, where considered appropriate, amended the ER to reflect these points. However, there remain some areas where the scope of the SEA has not been agreed, and where relevant these are referenced directly in Table 1.2.
1.8.4 In most cases, the current Draft Strategy itself will not introduce any new significant environmental effects as it essentially collates a series of initiatives which are already in place or would be implemented regardless of their inclusion in the Draft Strategy. Nonetheless, the potential exists for increased pressure on some aspects of the environment as a result of the aim of the Draft Strategy to increase the extent to which particular initiatives and funding streams are taken up. In this regard then it must be noted that each individual project that comes forward as a result or otherwise of the Draft Strategy will be subject to the normal consenting procedures, principally the town and country planning system for microgeneration installations, and the appropriate consideration of environmental effects prior to being implemented. This issue is discussed in more detail in Section 3.7.
Table 1.2: Scoping of Likely Significant Environmental Effects
SEA Issues | Scoped In | Scoped Out | Justification |
|---|
Biodiversity, flora, fauna | | Yes | Due to the nature of the initiatives in the Draft Strategy and the scale of any physical interventions which could result from its adoption, it is not predicted that any elements of the Draft Strategy will result in significant effects upon biodiversity, flora or fauna. SNH is of the view that biodiversity should be included within the scope of the assessment due to the potential for impacts upon bats where they roost in lofts. However, it is the view of the Responsible Authority that the Draft Strategy does not set the framework for consent of any such works, and that the existing legal framework to protect bats is the most appropriate. In addition, it is not considered likely that implementation of the Draft Strategy will significantly increase disturbance to bats as a result of the measures therein. In SNH's letter dated 15 th December 2006 they note that "any targets set by the strategy will have a direct bearing on the scale of development at a national level/". However, the Draft Strategy in its current form does not set individual local authority targets. SNH also expressed the view that baseline data should include numbers of bat roosts by local authority. This information is not available, and the Responsible Authority does not consider that such data would serve a useful purpose in the SEA given the above points relating to potential for significant effects. In summary, it is the view of the Responsible Authority that as this is a national level Strategy which does not introduce any new measures or a related increase in pressure for development affecting bats, such assessment is not necessary. However, a section has been included in this ER dealing specifically with the existing legal framework for the protection of species, including bats (Section 3.7) which recognises the potential for such indirect, secondary, local level impacts which, although not directly related to the Strategy, should be acknowledged nonetheless. This topic has therefore been scoped out of the SEA. |
Population | | Yes | Due to the nature of the initiatives in the Draft Strategy and the scale of any physical interventions which could result from its adoption, it is not predicted that any elements of the Draft Strategy will result in significant effects upon population. This topic has therefore been scoped out of the SEA. |
Human health | Yes | | The potential exists for improvements to human health through a reduction in emissions associated with traditional forms of electricity generation. In addition, there is the potential for positive impacts on human health as a result of successfully implementing domestic energy efficiency measures such as improved insulation. This topic has therefore been scoped in to the SEA. |
Soil | | Yes | It is not predicted that any elements of the Draft Strategy will result in significant effects upon soils. It is possible that the Draft Strategy could encourage an increase in the installation of ground source heat pumps, which may in turn increase the potential for impacts to soils and geology at a local level. However, it will be for the consenting process in place at the time to determine the acceptability of such impacts and the SEA process cannot accurately predict the future take-up of different forms of Microgeneration technology. SNH's original scoping response recommended including soils within the assessment, due to the potential for impacts from ground source heat pumps. However, it is the view of the Responsible Authority that this is not appropriate as any impacts would be minimal and that existing planning controls are sufficient to protect sensitive areas. SNH, in its follow up letter date 15 th December 2006, accepted this argument. Relating to soils, SEPA's scoping response noted that "…the strategy could encourage an increase in microgeneration technologies such as ground source heat pumps which in turn could have effects on soil. While SEPA would agree that it is unlikely that these will result in significant effects, it would nevertheless be useful for the Environmental Report to refer to the potential for this to occur and to highlight to other plans and consenting processes the need to fully consider such issues." Overall, SEPA expressed the view that "…it is considered unlikely that effects upon [soils] will be significant." This ER acknowledges, in Section 3.7, the potential for such indirect, secondary local level impacts which, although are not directly related to the Draft Strategy, should be acknowledged nonetheless. This topic has therefore been scoped out of the SEA. |
Water | | Yes | It is not predicted that any elements of the Draft Strategy will result in significant effects upon water. Again, it is possible that the Draft Strategy could encourage an increase in the installation of microgeneration plant that makes use of water to generate electricity, and this may in turn increase the potential for impacts to watercourses. However, it will be for the consenting process in place at the time to determine the acceptability of such impacts. SNH's original scoping response recommended including water due to the potential cumulative impacts from small scale hydro schemes on freshwater ecosystems and hydrology. SEPA's scoping response noted that "…significant effects are unlikely in the timescale of the strategy." Overall, SEPA expressed the view that "…it is considered unlikely that effects upon [water] will be significant." The Responsible Authority is in agreement with these conclusions, and that any such issue would be local in nature, and is not appropriately considered by the SEA of a national level strategy. However, this ER does acknowledge, in Section 3.7, the potential for such indirect, secondary, local level impacts which, although are not directly related to the Draft Strategy, should be acknowledged nonetheless. This topic has therefore been scoped out of the SEA. |
Air | Yes | | The potential exists for improvements to local air quality through a reduction in emissions of local air pollutants associated with traditional forms of energy generation, and a reduction in energy consumption as a result of reduced energy demand in all sectors. SEPA expressed agreement with the proposal to scope air into the assessment. This topic has therefore been scoped in to the SEA. |
Climatic factors | Yes | | Whilst the Draft Strategy itself will not have a measurable impact upon global climatic factors, the potential exists for contribution to Scottish and UK targets for reducing CO2 emissions with a view to assisting the effort to tackle global climate change. SEPA expressed agreement with the proposal to scope climate change into the assessment. This topic has therefore been scoped in to the SEA. |
Material assets | | Yes | Due to the nature of the initiatives in the Draft Strategy and the scale of any physical interventions which could result from its adoption, it is not predicted that any elements of the Draft Strategy will result in significant effects upon material assets. This topic has therefore been scoped out of the SEA. |
Cultural heritage | | Yes | The Scoping Report considered that, due to the nature of the initiatives in the Draft Strategy and the scale of any physical interventions which could result from its adoption, it was not predicted that any elements of the Draft Strategy will result in significant effects upon cultural heritage. However, the scoping response from Historic Scotland presented the view that the strategy does have the potential to adversely affect the cultural heritage, albeit that they "…would not expect a detailed assessment of impacts on the historic environment to be undertaken, rather…that the potential for significant impacts should be highlighted in the Environmental Report, along with a statement identifying (i) the most appropriate stage in the planning hierarchy at which you consider this could be addressed; and (ii) who would be responsible for undertaking this assessment. Assessment should not be left to the project level" The Responsible Authority agrees with this approach, and has consequently included a section in this ER (Section 3.7) which identifies the potential for such indirect, secondary, local level impacts which, although not directly related to the Draft Strategy, should be acknowledged nonetheless. This topic has therefore been scoped out of the SEA. |
Landscape and visual | Yes | | The potential exists for effects at a local level in relation to the visual impacts of microgeneration infrastructure, and possible associated pressures on sensitive landscapes and townscapes. It will be for the consenting process in place at the time to determine the acceptability of such impacts, but the issue was retained within the scope of the SEA following Scoping given the specific issues arising from visible microgeneration technologies such as domestic wind generators. Again, whilst it is not considered that the Draft Strategy itself will introduce any new significant environmental effects as it does not set the framework for consenting such works, in recognition of the particular issues for visual amenity an assessment on this topic has been included. This topic has therefore been scoped in to the SEA. |
1.8.5 In recognition of the nature, level and scope of the Draft Strategy and the likelihood of significant environmental effects, the following four environmental topics were taken forward for inclusion in this assessment:
- Air quality
- Climate Change
- Human health
- Visual amenity
1.8.6 In addition, the potential for secondary local level impacts to arise indirectly on the following topic areas has been considered and is discussed in more detail in Section 3.7:
- Soils
- Water
- Cultural heritage
1.8.7 The relationship between the four SEA topics and the criteria identified in Schedule 2 of the Regulations, along with consideration of the key environmental issues for each, is presented in Table 1.3.
Table 1.3: Relationship between Proposed SEA Topics and Schedule 2 Criteria
Environmental Topics | SEA Regulations Criteria | Key Environmental Issues |
|---|
Air Quality | Air, Climatic Factors, Human Health | - Air Quality (concentrations of nitrogen dioxide ( NO2), particulate matter ( PM10) and other pollutants)
- Air Quality Management Areas ( AQMA) and Smoke Control Areas ( SCA)
|
Climate Change | Climatic Factors | - Carbon dioxide ( CO2) emissions (and Scottish targets)
- International and trans-boundary climate issues
|
Human Health | Air, Human Health | - Key health indicators
- Relationship between air quality and housing quality with respiratory health
- Fuel poverty
|
Visual Amenity | Landscape | - Designated landscape and townscape areas
- Landscape character and quality
- Integrating new technology into the fabric of buildings - aesthetic quality, concealment
|