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1 Introduction
1.1 Purpose of Report
The Scottish Executive Freshwater Fisheries and Aquaculture Division is carrying out a strategic environmental assessment ( SEA) of the Fish Farm Location/relocation Programme. SEA is a systematic method for considering the likely environmental effects of certain plans and programmes. SEA aims to:-
- integrate environmental decision making into plan/programme development;
- improve plans and programmes to enhance environmental protection; and
- increase public participation in environmental decision making.
SEA is required under the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004 1.
The key SEA stages provided for in the Regulations are:-
Screening: To determine whether the plan/programme is likely to have significant environmental effects and whether an SEA is required
Scoping: To determine level of detail of the environmental report, and the consultation period for the report - this is done in consultation with Scottish Natural Heritage, the Scottish Ministers (Historic Scotland) and the Scottish Environment Protection Agency
Environmental Report: publishing an environmental report on the plan or programme and its environmental effects, and consulting on that report
Adoption: providing information on:- the adopted plan/programme; how consultation comments have been taken into account and; methods for monitoring the significant environmental effects of the implementation of the plan/programme
Monitoring: To monitor significant environmental effects with appropriate remedial action for any unforeseen significant environmental effects.
This document fulfils the SEA requirement for an environmental report and is intended to:-
- provide information on the SEA process
- provide information on Fish Farm Location/relocation Programme;
- identify, describe and evaluate the likely significant effects of the programme and reasonable alternatives;
- provide an early and effective opportunity for the Consultation Authorities and the public to offer views on any aspect of this environmental report.
* SEA Activities to Date and Key Facts are appended in the Annex of this report
1.2 The need and scope of assessment
The main rationale for strategic environmental assessment ( SEA) is to ensure that environmental considerations are integrated into the preparation and adoption of plans and programmes with a view to promoting sustainable development 2. More specifically it addresses the weakness of project level EIA in dealing with higher level policy/programme pressures and cumulative impacts.
The relocation programme is specifically designed to deliver net environmental benefits without compromising commercial viability, and does not undermine existing project level EIA and consent arrangements. In this sense, the need for an SEA, irrespective of legal minutiae, is questionable. Furthermore, because it has been introduced to the process at such a late stage 3, the ideal process - whereby the SEA informs plan or programme development - cannot be realised.
In practice this should not matter. The Location/Relocation Working Group ( LRWG) was charged specifically to explore alternative mechanisms to promote relocation of fish farms to generate a net environmental benefit, with particular emphasis on minimising the risks to wild salmonid fisheries. This document is to a large degree a recap and summary of the deliberations of that group, which examines programme suitability to maximise environmental benefit.
The relocation process envisaged in the "preferred option" is stakeholder driven. The programme does not define specific areas for removal or relocation, although this is one option which was considered. This environmental report cannot therefore assess the environmental effects of specific relocation projects. It can only assess in the broadest terms the likely consequences of relocation arising from the programme - typically from smaller sites closer to river mouths at the head of sea lochs, to larger sites towards the entrances of sea lochs or further off-shore. Equally mitigation can only be addressed in very general terms. Site related EIA will therefore still be required 4 to address local issues and identify practical mitigation measures.
In practice this leaves something of a gap in terms of genuinely "strategic" EA which might inform the overall location and scale of fish farming by addressing cumulative impacts, overall environmental capacity issues and the interests of other users. Such assessments might also reduce the duplication and detail of farm level EIAs in "developed" locations thereby reducing the regulatory burden. There are existing pilot projects to test out such an approach in relation to particular aquatic systems, and it is to be hoped that these will become more widespread as local authorities take on their enhanced role with respect to aquaculture development planning.
A scoping report was prepared and circulated to statutory consultees to solicit guidance on the nature and content of this report. The responses from the Agencies has been taken into account as far as possible in the preparation of this report.
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