Scottish Government

Non-Technical Summary

Introduction

This document is the Non Technical Summary of the Environmental Report which has been prepared by the Scottish Executive Energy Efficiency Unit following the Strategic Environmental Assessment ( SEA) of the draft Energy Efficiency and Microgeneration Strategy for Scotland (referred to in this report as the Draft Strategy).

The Scottish Executive 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 Section 2 of the Regulations and since it meets the relevant criteria under Section 9(a) of the Regulations.

Background to the Draft Strategy

The Draft Strategy has been produced as a response to various commitments made by the Scottish Executive in relation to the need for an overarching and coordinated approach to energy efficiency and microgeneration in Scotland, not least through the Scottish Climate Change Programme ( SCCP). Various recent publications by international bodies and government have focused attention on the generally accepted principle that the main causes of climate change are, indeed, human influenced.

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 each area of influence upon which the main programmes, initiatives and funding streams can exert influence. As a result, the Draft Strategy does not introduce any new measures or initiatives that are not programmed or already in existence. That is not to detract from the value of the Draft Strategy, but rather recognition of the fact that the purpose of the Draft Strategy is to draw together all of the work being undertaken by various organisations and agencies into a single, connected and comprehensive strategy.

Approach to the SEA

A structured approach to the SEA has been adopted based on all relevant best practice guidance including the recently published Scottish Executive SEA Toolkit and its predecessor draft guidance.

The environmental baseline for the assessment was established drawing on relevant published information and consultation for a series of environmental topics which have been used to structure the assessment. Current environmental issues and problems were also drawn from the analysis of the baseline and with reference to other plans and programmes.

Based on a review of other relevant plans, policies and strategies, the review of baseline environmental data and consultation feedback, a series of environmental objectives and sub-objectives were then determined for each relevant environmental topic in the SEA. The high level objectives are presented in the table below.

Table 1 SEA Objectives

A set of more detailed sub objectives was then defined by the SEA team for use in the appraisal. These objectives and sub-objectives were presented as part of a Scoping Report, which was submitted to the SEA Consultation Authorities in October 2006, and the finalised list of objectives was prepared taking account of comments made by the Authorities in their formal response to the Scoping Report.

A framework approach has been used to evaluate the environmental effects of the content of the Draft Strategy and this was evolved from the set of objectives and supporting appraisal criteria. The SEA framework was then used to appraise each "area of influence" in the Draft Strategy as follows:

• Changing our behaviour (Draft Strategy Chapter 3)
• Knowing what we use (Draft Strategy Chapter 4)
• Changing our buildings (Draft Strategy Chapter 5)
• Improving our homes (Draft Strategy Chapter 6)
• The public sector leading by example (Draft Strategy Chapter 7)

The appraisal of each area of influence has been based on mainly qualitative appraisal, drawing on the assessment team's knowledge of the likely effects of national level strategies of this nature and an understanding of the baseline environment. However, quantitative data in the form of predicted carbon emissions savings have been used where these have been made available from evaluations of relevant initiatives and programmes. The level of appraisal undertaken is a reflection of the fact that the Draft Strategy is at a national level, and does not introduce any new measures or initiatives that would not exist in some form or another already.

The nature of the Draft Strategy is such that detailed mitigation specific to each measure or initiative would not be appropriate or easily implemented. Mitigation in the form of guidance for applicants on the potential local level environmental effects (which are considered to be secondary and indirect in relation to the Draft Strategy) is proposed. Again, this is commensurate with the scope of the Draft Strategy itself and related directly to the significant environmental effects predicted to arise.

SEA requires a description and evaluation of "the likely significant environmental effects of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme".

The Draft Strategy presents a coherent national-level view of energy efficiency and microgeneration in Scotland, collating all of the information relating to financial assistance and existing programmes to increase awareness and encourage take up by stakeholders and scheme applicants. Since the Draft Strategy collates programmes and measures already in progress, rather than a new approach to energy efficiency and microgeneration, there are no strategic "alternatives" to it. The SEA has therefore concentrated on an analysis of different groups or "themes" of programmes for energy efficiency and microgeneration and each theme has been appraised separately, as well as in combination.

Findings of the Environmental Assessment

The findings of the SEA are summarised in this section for each area of influence, as well as for the Draft Strategy's predicted cumulative effects.

Changing Our Behaviour (Draft Strategy Chapter 3)

Many of the measures presented have the potential to make a clear and quantifiable contribution to the carbon and other emissions reductions objectives of the Draft Strategy and the Scottish Climate Change Programme. In addition, it is possible that local air quality improvements and associated health benefits from reduced air pollutants will result. However, it is difficult to assess the local level effect of pollutant emissions reductions on the basis of the information available in published evaluations and reports.

Knowing What We Use (Draft Strategy Chapter 4)

Measures in this area of influence relate to raising awareness of what energy we use and how, and supporting other initiatives. As a result, any significant environmental effects that may arise from the measures identified are likely to be positive, although unquantifiable and therefore uncertain.

Changing Our Buildings (Draft Strategy Chapter 5)

Measures in this area of influence have the potential to make a clear and quantifiable contribution to the carbon and other greenhouse gas emissions reductions objectives of the Draft Strategy. In addition, it is likely that there will be associated health benefits from reduced air pollutants. However, it is difficult to assess the local level effect of local pollutant emissions reductions given the information available in published evaluations and reports. In relation to visual amenity, the predicted effect of the Draft Strategy is neutral. This relates to the fact that the existing mechanisms in place to protect local visual amenity are considered to be sufficient to determine the acceptability of individual projects. As a result, the overall effects of the Draft Strategy at a national level are not predicted to be significant.

Improving Our Homes (Draft Strategy Chapter 6)

Measures in this area of influence have the potential to make a clear and quantifiable contribution to the carbon and other emissions reductions objectives of the Draft Strategy. In addition, it is possible that local air quality improvements and associated health benefits from reduced air pollutants will result. However, it is difficult to assess the local level effect of local pollutant emissions reductions given the information available in published evaluations and reports.

The Public Sector Leading by Example (Draft Strategy Chapter 7)

Measures in the public sector have the potential to make a contribution to the carbon and other emissions reductions objectives of the Draft Strategy. In addition, it is possible that local air quality improvements and associated health benefits from reduced air pollutants will result. However, it is difficult to assess the local level effect of local pollutant emissions reductions given the information available in published evaluations and reports.

Synergistic Effects

Whilst most of the areas of influence assessed in the Draft Strategy are predicted to result in slight beneficial effects in relation to carbon emissions savings, the effects which arise as a result of the combination of all of these measures can be greater or more significant than those that would arise if each individual measure were implemented in isolation ("…greater than the sum of its parts"). This is referred to as "synergy". In this case the synergistic effects likely to arise will be as a result of increased knowledge, awareness and understanding of the various energy efficiency and microgeneration initiatives and funding mechanisms available in Scotland through their inclusion in the Draft Strategy than would have been likely were they simply promoted as standalone initiatives. Their direct environmental effects are unlikely to increase synergistically, but the potential benefit of carbon savings through education and awareness may do so.

When considered in combination, each of the slight positive impacts identified in relation to carbon reductions from the areas of influence accumulates to form a greater impact. Therefore in combination, the environmental effect of all measures in the Draft Strategy in relation to carbon reductions (ie the 'Climate Change' topic for the SEA) is predicted to have a significant beneficial (Moderate Positive) effect, and to be greater than each of the initiatives and areas of influence when assessed in isolation. The assessment relating to each of the other SEA topics is not predicted to alter as a result of cumulative effects. These remain Slight Positive for air quality and human health, and neutral for visual amenity.

Indirect Secondary Effects

There are a number of environmental topic areas that were not assessed in detail in the SEA as it was not considered the Draft Strategy itself will give rise to significant environmental effects. However, it is recognised that there may be particular, mostly local-level implications of some of the activities and projects which could be implemented in order to fully realise the potential of a number of the programmes mentioned in the Draft Strategy. The Scottish Executive believes that these may represent secondary indirect effects and that, at a national level, it is neither appropriate nor possible to assess these in detail, not least given the fact that the Draft Strategy itself simply collates mainly existing programmes and initiatives. In most of these cases it is the role of the planning system to identify these areas if a specific proposal is brought forward and to prevent inappropriate development. This issue is covered in detail in the full Environmental Report and is related to effects on biodiversity, soils, water and cultural heritage.

Mitigation and Monitoring

Notwithstanding the fact that detailed mitigation measures specific to the initiatives in the Draft Strategy are not considered to be appropriate, the potential for indirect secondary effects at a local level gives rise to an opportunity to raise awareness of the potential wider environmental effects of energy efficiency and microgeneration measures. The Scottish Executive is committed to this, and therefore proposes to devise and circulate to all prospective funding applicants a short and easily accessible briefing note outlining the main environmental considerations to be taken into account when making a funding application and those agencies who can provide further information and advice if a particular issue, such as cultural heritage, geology and soils or visual amenity, is likely to arise. In this way, it will be possible to raise awareness of (and mitigate) any potential local level environmental effects of these measures. This briefing note would supplement, but in no way replace, the information provided in the Annex to the Executive's existing guidance contained in Planning Advice Note PAN 45 on Planning for Microrenewables.

The success of the Final Strategy itself will be tracked through implementation of an accompanying Action Plan, which will be reviewed annually. Annual reports relating to progress delivered by the Action Plan will be published. Given that the environmental effects reported in this Environmental Report are all positive, the Scottish Executive proposes that this process also be used to monitor carbon savings in relation to the SEA, incorporated into the monitoring to be undertaken in assessing the effectiveness of the Final Strategy through the Action Plan.

In addition, it is likely that each of the key programmes identified in the Final Strategy will be subject to individual independent evaluation, which will be the responsibility of the relevant lead department within the Scottish Executive to tender and commission. In order to facilitate assessment of the relative contribution of different measures and initiatives, it is recommended that where appropriate a standard methodology for the collection and presentation of data is developed, and this is distributed to all agencies involved in the commissioning of these evaluations.

Through ongoing refinement and reiterations of the Action Plan, the monitoring indicators that are developed will form the basis of further discussions, development and refinement. This will reflect their relevance, practicability and ease of measurement based on the data available, or the data that will be required in order to undertake such monitoring.

Next Steps

This document has been prepared to support the Draft Strategy which was published for consultation in March 2007. The Environmental Report will be issued to the SEA Consultation Authorities for comment. The responses provided by the Consultation Authorities will then be taken into account in the finalisation of the Strategy and Action Plan and in the future reviews of it.

Comments on the Environmental Report may be addressed to:

Sarah Hart