3.0 APPROACH TO THE ASSESSMENT

Background: The Scottish Ferries Review

3.1 As noted in Chapter 2 (paragraph 2.5), a strategic environmental assessment was carried out of the Ferries Review consultation, focussing on climate change issues, and an Environmental Report was published for consultation. The Draft Ferries Plan builds on the responses to the Ferries Review (as well as other information). In the same way, this SEA builds on the original SEA of the Ferries Review. Accordingly, the results of the SEA are being reported as an addendum to the original Environmental Report.

3.2 The Scottish Ferries Review consultation sought to elicit views on environmental issues, with a focus on the mitigation of climate change through reduction of greenhouse gas emissions. Two key approaches to achieving reductions in greenhouse gas emissions from ferries have been identified by the Scottish Government: technological measures; and demand and fleet management.³ The consultation sought views on how emissions from ferries could be reduced, and in particular sought views from operators and passengers as to whether they would support reductions in vessel speeds as a means of reducing emissions.

3.3 A range of suggestions was offered on how to reduce emissions from ferries. In general the consultees did not support reductions in vessel speeds. Overall the emphasis was on technical solutions, particularly for inclusion in new vessels, but service changes were also mentioned.⁴

The Draft Ferries Plan

Scope of the Draft Ferries Plan to be Assessed

3.4 The subjects covered by the Draft Ferries Plan were reviewed to ascertain whether they would be likely to give rise to significant environmental effects, as a result of changes to the existing ferry network. The results are set out in Table 2.

3.5 The funding and procurement of ferry services, and responsibility for their provision, are considered to be the kinds of strategic action that would result in no or minimal environmental effects. The same applies to issues of accessibility. The SEA has therefore focused on the potential environmental effects of changes to fares, provision of new vessels and proposals for new and/or changed routes and services.

3.6 The Draft Ferries Plan includes proposals to improve port/harbour infrastructure at Brodick, Iona, Gigha, Stornoway and Ullapool. At this stage no details of proposed improvements are available. Port/harbour improvements have the potential to result in environmental effects; depending on the characteristics of the local environment and the type of improvements, such effects could include loss of and/or damage to habitat; disturbance of species; disturbance of local residents during construction and/or operation; landscape and visual effects; effects on water quality, e.g. from dredging; and changes to local coastal processes. A review of the potential for environmental effects of such proposals has been undertaken to ascertain whether a high-level assessment should be undertaken. At this time, no national-level biodiversity, landscape or cultural heritage interests have been identified at these locations. We anticipate that effects (if any) would therefore be local in nature. Accordingly, environmental assessment has been deferred to the STAG-type appraisal that will be undertaken for each improvement project prior to the publication of the final Ferries Plan.

Table 2. Scope of the Draft Ferries Plan to be Assessed
Draft Ferries Plan Subject	Environmental Effect?	Scope In/Out
Funding and procurement of ferry services, vessels, and ports and harbours	No. Procurement and funding mechanisms will not in themselves result in environmental effects.	Out
Provision of new vessels	Yes. As vessels age, engines become less efficient and emissions would be expected to increase. New vessels will be designed to be fuel-efficient overall, and emissions of greenhouse gases would therefore be expected to decrease.	In
Funding and procurement of harbour infrastructure	No. It is the design and construction of harbour infrastructure that would exert the environmental effect and this is controlled by planning and consenting procedures.	Out
Fares	Yes. Fares may affect passenger numbers, which could result in more people travelling. This issue has been assessed at a high level, in terms of effects on atmospheric emissions.	In
Proposals for routes and services	Yes. New and/or changed routes and levels of service may have environmental effects.	In
Who should be responsible for providing ferry services	No. It is the operation of ferries, rather than who is responsible for their provision, that has potential for environmental effects.	Out
Accessibility	No. Accessibility is an issue for a wide range of passengers with disabilities. However, this is a social issue and therefore outwith the scope of this SEA.	Out

Scope of the environmental topics to be Assessed

3.7 The proposals in the Draft Ferries Plan have been reviewed against the environmental issues identified in Schedule 3 of the Environmental Assessment (Scotland) Act 2005. Table 3 sets out the resulting scope of the environmental topics that have been addressed in the SEA.

Table 3. Scope of Environmental Topics to be Assessed
SEA Topic	Proposal	Potential Effect?	Scope In/Out
Biodiversity, flora and fauna	increased vessel movements	potential for increased cetacean collisions and increased acoustic disturbance potential increase in the introduction of invasive species	In: focus on cetaceans, marine noise and non-native invasive species
Population and human health		decreased air quality at ports	In
Water quality / ecological status	increased vessel movements	increased risk of collisions between vessels, with adverse effects on water quality (and indirect effects on biodiversity) increases in marine litter	In: focus on collisions and marine litter
Climatic factors	increased vessel movements	increased GHG emissions	In
	new vessels	increased GHG emissions from aging vessels decreased GHG emissions from new, fuel-efficient vessels	In
	fares	passenger numbers may increase, which could increase emissions	In
	Note: after discussion with the Consultation Authorities, it has been agreed that the adaptation aspect of climatic factors should be scoped out of the assessment, as this topic is outwith the remit of the Draft Ferries Plan		Out
Air quality	increased vessel movements	decreased air quality at ports increases in vehicle emissions	In
Soil, geology and coastal processes	increased vessel movements	increased vessel wake/wash, with potential adverse effects on coastal processes (exacerbation of coastal erosion) potential for indirect effects on biodiversity, cultural heritage, and landscape	In: focus on coastal erosion
Cultural heritage		no direct effects identified	Out: indirect effects will be addressed under "coastal processes"
Landscape		no direct effects identified

Environmental Protection Objectives

3.8 The Environmental Assessment (Scotland) Act 2005 requires that the SEA should identify the environmental protection objectives (established at international, European, UK or Scottish level) relevant to the Draft Ferries Plan. Environmental legislation and policy has been reviewed and details of the environmental protection objectives are provided in Appendix 2. The principles underlying these environmental protection objectives have been incorporated into the SEA objectives (Table 4).

Methods

3.9 The proposals have been assessed against the SEA objectives set out in Table 4. The results are set out in Chapters 4-11, and a summary is provided in Chapter 12.

3.10 Given the nature of the proposals, this SEA has been undertaken as a high-level assessment. Where appropriate, spatial information has been used, e.g. in the assessment of erosion effects.

Table 4. SEA Objectives
SEA Topic	Objectives
Biodiversity, flora and fauna	To protect and where appropriate enhance protected habitats To avoid generating disturbance of key species from construction and operational activities To safeguard marine and coastal ecosystems, including unprotected and unknown resources To avoid adverse effects on coastal processes
Population and human health	To avoid secondary adverse effects on health arising from air pollution and other nuisance effects
Water	To reduce pollution of the coastal and marine water environment To reduce marine litter
Climatic factors	To minimise greenhouse gas emissions from the marine transport sector, focusing on Scottish ferries operations
Climatic factors	No objective has been provided for adaptation, as this has been scoped out of the assessment.
Air	To reduce air pollution from the Scottish ferries sector and thereby avoid secondary effects on health
Soil, geology and coastal processes	To avoid exacerbating coastal and/or seabed erosion
Cultural heritage	To avoid damaging known and unknown coastal and marine archaeology To avoid adversely affecting the historic built environment on the coast, including the character and setting of listed buildings and conservation areas
Landscape	To avoid adversely affecting the key qualities landscape and/or seascape

Reasonable Alternatives

3.11 The Environmental Assessment (Scotland) Act 2005 requires that reasonable alternatives to the preferred options set out in the Draft Ferries Plan be assessed. At the time of the scoping report, undertaken at an early stage of the Ferries Review, a wide range of reasonable alternatives was envisaged. However, the financial context in which we are operating has changed since the Ferries Review was initiated. In consequence, the alternatives to the proposals identified in the draft Ferries Plan have been rejected on the grounds of cost or unacceptable effects on the local community. In consequence, this SEA has not assessed alternatives to the proposals set out in the Draft Ferries Plan.