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Chapter Eight: Comments on the Strategic Environmental Assessment - Environmental Report
Introduction
8.1 In addition to the Draft SPP, the Scottish Executive also published, in parallel, a Strategic Environmental Assessment ( SEA) Environmental Report, on which separate comments were invited. The SEA Environmental Report was required under the Environmental Assessment (Scotland) Act 2005 which enacted EU Directive 2001/42/ EC into Scots Law. Its main purpose was to set out the significant environmental effects (positive and negative) of implementing draft SPP6.
8.2 There were four main elements to the SEA on which respondents may have wished to comment. These were:
- The SEA Approach and Methodology
- Baseline and SEA Objectives
- Development of Options
- Assessment of Environmental Effects
In practice, there was only one separate submission relating to the SEA and two other comments which were included in the main SPP submission. These covered only 3 of the 4 parts of the SEA and have been summarised below.
The SEA Approach and Methodology
8.3 An NDPB was disappointed that their recommendation for a two-tier approach (set out on page A6 of the SEA Report) had not been followed. They indicated that only the first tier of this assessment - examination of the broad policy options - had so far been carried out but that the second tier was equally vital to the effective planning of renewable energy in Scotland. They were disappointed that Section 3.3.4 of the SEA indicated that it was not the Executive's intention, in developing the draft SPP6, to predict the impacts that could arise from different combinations of renewable technologies across Scotland. The NDPB had expected that the SEA would assess the environmental impact of various technology mixes, and as a result would illuminate how the Executive's 2020 target could be met with least environmental impact. They felt that while such an approach might then have had to be tempered with realities surrounding costs and the state of development of the various technologies, it would have enabled SPP6 to offer national guidance designed to encourage, in different parts of Scotland the pursuit and uptake of the technological option(s) most suited to their environmental conditions and constraints.
Baseline Data
8.4 The NDPB respondent was concerned by the implication in section 4.2.3 of the SEA Report that because SPP6 was national guidance, it needed only to take account of designated areas of national and international importance. They felt that the issue which was of greatest importance and of prime public interest, was the extent to which renewable energy development should be allowed to impact upon non-designated resources and that an opportunity would be lost if SPP6 did not offer guidance on this issue. The submission recognised that information on some areas of local value had been taken into account in the SEA, (from the acknowledgement of the relevance of resources of regional or local significance, from the mapping of some of these resources in Figs 4.4 - 4.8, and from the inclusion of non-national designations in Appendix C), but it was felt to be unclear whether these had contributed towards the assessment conclusions in Table 5.1.
8.5 The respondent was also disappointed that in section 4.2.6 of the SEA, the baseline data did not include information on Scotland's wild land resource. They considered that, in a Western European context, these resources were unusual; distinctive and increasingly valued both for the recreational experience they offered and for their very existence. There was concern that any type of large-scale renewable energy development would be likely to adversely affect wild land qualities which were considered to be highly susceptible to development impacts. It was suggested that ' Wildness in the Scottish Countryside' published by SNH, provided a useful indication of where the major areas of wild land were to be found.
Policy Options
8.6 The NDPB respondent found questionable the assumptions set out in Section 5.3 of the SEA, regarding Options D and E and hence questioned the conclusion, at the bottom of p44, that locally-determined contributions allied to broad areas of search would provide the greatest benefit against the SEA objectives. They noted, in relation to paragraph 5.3.5 (Option D - national locational framework), and agreed that if areas of search were defined and mapped nationally, they would be likely to be based on less detailed knowledge than if they were defined by local authorities and that this could result in undue pressure on environmental resources or under-exploitation of potential renewables resources.
8.7 However, concern was expressed that in paragraph 5.3.6 (Option E - targets), the SEA report arrived at the same conclusion regarding a national level statement of regional targets, as the NDPB felt that sufficient information was readily available to enable broad conclusions to be drawn about the relative potential capacity of different areas to accommodate renewables. It was considered that these conclusions would be informed by all of the main factors listed in draft SPP6; that data need not be 'detailed and localised' for this purpose and the proposed five-year review would provide an appropriate opportunity to update and adjust targets in the light of any mismatches encountered.
8.8 In the view of the NDPB, it would be possible, helpful and desirable to offer planning authorities some level of national guidance on the capacity of different parts of Scotland to accommodate renewable energy, as envisaged under Option E - regional targets. They considered that any such guidance should be founded upon a national-level assessment of the environmental impacts likely to arise from different scales and types of renewables development in each of these areas.
8.9 A submission from another respondent was concerned that the SPP was silent and hence rather dismissive of the potential environmental impact of hydro schemes. They felt that this was also reflected in the SEA Report, where the assumption was that only small scale schemes would be taken forward in the future and hence there was no issue. They considered on the basis of their experience in providing advice to Scottish Ministers and developers, that there was potential for adverse impacts on fish and fisheries of both large and small schemes if they were located at an inappropriate site or designed and / or operated in an inadequate way.
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