ENVIRONMENTAL REPORT - NON TECHNICAL SUMMARY
Outline of the Energy Efficiency Action Plan
(i) The Scottish Government is undertaking a strategic environmental assessment ( SEA) of the Energy Efficiency Action Plan ( EEAP) for Scotland. The EEAP represents one part of a wider ongoing process of energy policy development and delivery that is being progressed by the Scottish Government through the ten pledges on energy policy.
(ii) The consultation on the EEAP for Scotland sets out:
- options for setting indicative energy savings needed from different sectors to contribute to overall greenhouse gas reductions;
- the key activities in each sector under the direct control of The Scottish Government and its associated bodies and agencies. This includes, where known, economically attractive investments in energy productivity that are expected to be feasible for consumers, businesses and government; and
- the key gaps in current activity that need to be closed in order to increase energy efficiency and contribute to greenhouse gas emission targets.
(iii) The consultation on the EEAP for Scotland and its SEA build on previous work which was undertaken to prepare an Energy Efficiency and Microgeneration Strategy for Scotland. The SEA has also been informed by recent assessments of a number of other Scottish Government plans and policies relating to renewable energy and heat, and climate change.
Environmental Context
(iv) Several relevant plans and strategies set out strategic aims and objectives for Scotland's environment. These provide a framework within which the SEA has been undertaken. This includes:
- National targets for climate change mitigation and adaptation. Mitigation focuses on reducing harmful greenhouse gas emissions by 80% at 2050, with an interim 2020 target of 42% .
- The Climate Change (Scotland) Act 2009 emphasises the importance of the contribution of energy efficiency and renewable heat towards these ambitious targets.
- Ongoing aims of reducing health problems associated with air pollution, the condition of housing and fuel poverty.
- Targets for reducing specific air pollutants, particularly those arising from the transport and energy sectors set at a European level and in the Air Quality Strategy for the UK.
- In terms of improving air quality, priority is given to areas where there are concentrations of air pollution at present (Air Quality Management Areas). Most of these areas have been declared as a result of transport sector emissions.
- The Scottish Historic Environment Policy sets objectives that require energy efficiency measures to be appropriate to historic and traditional buildings, complemented by more general objectives which aim to conserve and enhance (where appropriate) the historic built environment.
Environmental Baseline
(iv) The SEA has taken into account the current state of the environment in Scotland. There are several existing environmental problems that could be directly or indirectly influenced by the energy efficiency measures outlined in the action plan. Many relate to the aforementioned environmental objectives.
(v) Human activity has resulted in the release of greenhouse gases that have led to current and future climatic change. Annual emissions of these gases has reduced in Scotland in the last few years. The EEAP has the potential to improve energy efficiency and reduce overall energy consumption, therefore contributing to a decrease in harmful greenhouse gas emissions. In addition, Scotland's air quality objectives have been met over much of the country, but there are some hotspots of poor air quality where Local Air Quality Management Areas ( AQMAs) have been declared. Although the energy sector contributes to air pollution from large combustion plants, emissions have fallen overall as use of coal has reduced.
(vi) Air pollution and poor housing conditions are linked to poor health. The EEAP for Scotland will contain measures that will improve housing conditions and reduce energy use. Fuel poverty is used to describe the situation where 10% or more of household income is spent on fuel, as a result households may not be adequately heated which particularly impacts on the health of vulnerable members of the population. This is a significant and growing problem in Scotland: in 2006/2007, there were 586,000 households (25.3% of all households) living in fuel poverty.
(vii) Improvements to the existing housing stock are central to the proposals within the consultation on the EEAP for Scotland. Although a significant proportion of the historic environment benefits from some form of designation, through listed building status or location within a conservation area not all older buildings are afforded statutory protection. There are more than 2.3 million dwellings in Scotland of which 438,000 date from before 1919 and a further 299,000 were built between 1919 and 1944.
Likely significant effects of key elements of the Energy Efficiency Action Plan and proposed mitigation measures
(viii) The consultation on the EEAP for Scotland discusses a range of energy efficiency related information. It explores the potential content of the finalised EEAP, and invites consultees to comment on a range of options. For the purposes of this assessment the consultation document was reviewed to identify the content that would have significant environmental effects. The assessment focused on strategic actions and the broad options for target setting that have been proposed. The assessment has not included those activities that are referenced but are promoted through other policies and plans.
(ix) The SEA focused on four topic areas (climatic factors, air quality, population and human health, and cultural heritage) that could experience significant environmental effects as a result of the EEAP for Scotland. The environmental issues within these topic areas were used to develop a series of questions, against which the consultation on the EEAP for Scotland was assessed.
(x) Initial analysis of the consultation on the EEAP for Scotland suggested that there was some potential for positive significant (and more minor) effects on climate change mitigation and air quality. The EEAP has a positive, and potentially significant, role to play in ensuring that Scotland reaches national targets for the reduction of emissions of greenhouse gases. In particular the more ambitious options for targets and activities have the potential to ensure that these positive effects are significant. The relationship between reducing emissions and air pollution was also explored in the assessment, although it was concluded at this stage that the EEAP is unlikely to significantly reduce air pollution specifically in areas where pollutants are already concentrated.
(xi) As well as reducing greenhouse gas emissions, the SEA explored the role which the EEAP might play in helping people and businesses to adapt to the impacts of climate change. It was noted that predicted climate change impacts could alter patterns of energy demand and that, as changes in temperatures progress, there may be a need to reconsider whether energy efficiency measures are still appropriate. The SEA recommended that this should be considered further within the finalised version of the EEAP for Scotland.
(xii) The assessment considered whether the EEAP could contribute positively or negatively to the ongoing issue of fuel poverty. Whilst energy efficiency measures should reduce fuel consumption and therefore costs over the long term, in the shorter term the SEA noted that costs to householders could also arise. Although it is difficult to define this fully at this stage, it was concluded that the consultation document includes sufficient measures to ensure that the finalised EEAP does not inadvertently have adverse effects on those members of the population who are already fuel poor.
(xiii) No significant adverse effects on historic and valued buildings were predicted, as it is expected that adequate protection will be provided by existing legislation on the historic environment. The EEAP consultation document also makes reference to the need for measures to be sensitive and appropriate to the fabric and character of historic buildings.
Monitoring
(xiv) The progress of the implemented EEAP for Scotland and its potential significant effects will be monitored. The commitment to review the EEAP for Scotland every three years provides opportunities for updates in light of this monitoring. Most of the proposals for environmental monitoring will be undertaken to track the progress of the EEAP in delivering the aims of the Climate Change (Scotland) Act 2009. The SEA noted the importance of using monitoring to ensure that the EEAP has maximised its contribution to reducing greenhouse gases and household and commercial energy use. Possible tensions between energy efficiency measures and the need to anticipate and adapt to climate change impacts will require further consideration. The SEA has also suggested that further consideration is given to linking data on the number of individuals experiencing fuel poverty with the distribution of grants and incentive schemes for the installation of efficiency measures.