Consideration of Consultation Feedback
Appendix 2 of the Environmental Report outlines public consultation feedback, on the draft SAP and VPP undertaken between February and May 2024, of relevance to the scope of the SEA, and indicates how this was considered in the development of the assessment framework. Feedback received was related to a number of topics that have also been covered in the adopted SAP and VPP, such as reduction of carbon emissions, uptake of renewable energy sources, consideration of environmental impacts, consideration of vulnerability of port infrastructure to climate change impacts, etc.
The section outlines consultation feedback received on the Environmental Report published for public consultation between February and March 2025, and how this has been considered in the adopted version of the ICP. In summary, feedback from five organisations was received, mostly including general comments, as well as specific points that have been considered in the adopted versions of the SAP and VPP.
NatureScot
Date received: 25 February 2025
Theme: General
Consultation feedback
I have reviewed the documents on behalf of NatureScot in relation to our natural heritage remit. We had the opportunity to make comment on the Draft Bespoke Assessment Framework in December 2024 and I am pleased to note that the comments we made within our response to the SEA Draft Bespoke Assessment Framework have been taken on board. I have no further comments to make on the SEA Environmental Report.
Consideration in the ICP
Noted.
SEPA
Date received: 10 March 2025
Theme: General
Consultation feedback
In line with the procedures previously agreed between SEPA and SG we will not be submitting comments on this ER.
Consideration in the ICP
Noted.
CalMac
Date received: 10 March 2025
Theme: Electric Ferries
Consultation feedback
Low Carbon & Env. Impact – Although electricity is being promoted as the low carbon alternative, there seems to be no mention of the lifecycle of these batteries and the impact of recycling - Strategic Approach Paper page 30
Consideration in the ICP
The Environmental Report recommends including, in the VPP, specific reference to adherence to circular economy / waste hierarchy principles as part of “principles for fleet renewal”, and to include the principles by which new vessels, engaged in the provision of lifeline services, should be designed and built. Although this recommendation has not been taken forward in the adopted VPP, the section “Environmental Impact and Low Carbon” requires investment planning to consider the frequency and cost of replacement batteries, and the recycling of these.
CalMac
Date received: 10 March 2025
Theme: Shore Power Infrastructure
Consultation feedback
There is no mention of supporting infrastructure for the all-electric vessels. A lot of the shore power and infrastructure works will be captured under the SVRP programme umbrella and assumed to be part of the new vessels. Currently, the final business case for the SVRP sets out what shore power and infrastructure works will be required to accept the new vessels and how much it is likely to cost (An infrastructure review carried out by Mott McDonald). There is currently detailed design work being carried out for CMAL owned ports, which will go out to tender once funding is approved. 3rd party ports are responsible for their own upgrades. There is also a CMAL led, tripartite shore power group that looks at the shore power for not only SVRP but other new vessel projects such as New Islay Vessels. The shore power will be the same for all new vessels - Strategic Approach Paper.
Consideration in the ICP
Noted. Appendix 3 (Baseline) of the Environmental Report, section 'Material Assets' describes some of the existing and planned shore power infrastructure available in Scotland. The section “Small Vessel Replacement Programme (SVRP)” in the adopted VPP indicates that port works, including shore power requirements are developed and shared through this programme.
Historic Environment Scotland
Date received: 11 March 2025
Theme: General
Consultation feedback
SEA Requirements and Process: We understand that the consultation on this environmental report is accompanied by the consultation draft Strategic Approach Paper and Vessels and Ports Plan. In light of this the post-adoption statement will need to make clear how consultation responses on both the ER and its relevant documents have been taken into account from this consultation.
Consideration in the ICP
This Post-Adoption SEA Statement documents how environmental considerations and SEA findings have been incorporated into the ICP, including feedback during the consultation of the draft SAP and VPP in 2024 (further detailed in the Environmental Report) and of the Environmental Report in February and March 2025.
Historic Environment Scotland
Date received: 11 March 2025
Theme: General
Consultation feedback
What are your views on the accuracy of the information used to describe the SEA environmental baseline? We are content with the high-level summary presented for the historic environment. However, the report would have benefited from setting out more specific commentary on the elements of the historic environment most likely to interact with the proposals of the plan.
Consideration in the ICP
Noted.
Historic Environment Scotland
Date received: 11 March 2025
Theme: General
Consultation feedback
What are your views on the predicted environmental effects and mitigation measures? We note that a number of negative effects on cultural heritage have been identified through the assessment. We are generally content to agree with these findings and in particular note the potential interactions between the plan options and the historic environment through physical works associated with port upgrades.
Consideration in the ICP
Noted.
Historic Environment Scotland
Date received: 11 March 2025
Theme: General
Consultation feedback
Statutory Consultation Feedback on Draft Assessment Framework (Dec 2024): This section states that no feedback was received from Historic Environment Scotland. Our response to the request for feedback on the SEA draft assessment methodology was issued to the SG SEA Gateway on 20 December 2024. However, it would appear from this section that this response did not reach you. We have therefore included it with this response for information.
Consideration in the ICP
Noted. We have indicated in this document that all three statutory consultation authorities provided feedback to the Draft Assessment Framework. We note that HES only had a minor comment on one of the assessment framework questions and request to extend SEA consultation period to 6 weeks, so it is not considered to have implications to the SEA findings.
Historic Environment Scotland
Date received: 11 March 2025
Theme: General
Consultation feedback
Baseline Evolution and Trends: We note the reference here to Climate Ready HES. This document relates solely to HES as an organisation and the steps it is taking in managing and adapting the sites in its care. While the approaches taken will be of interest to others with stewardship responsibilities for historic environment assets it will not reflect the baseline relevant to the Islands Connectivity Plan.
Consideration in the ICP
Appendix 3 (Baseline) of the Environmental Report, section 'Cultural Heritage' includes a description of climate change and trends relevant to cultural heritage, which are noted in the Climate Ready HES and are considered relevant to Scotland's cultural heritage assets.
Mobility and Access Committee
Date received: 12 March 2025
Theme: Impact Assessment
Consultation feedback
"Unknown Impact" on Marginalised Groups (Page 34, Outcome 2.1): The environmental assessment marks the impact of fair and safe access as 'unknown', which is unacceptable given the legal obligations under the Equality Act 2010. Why has this been marked as unknown? Has feedback from disabled individuals been actively sought and incorporated into the planning process? If data is lacking, the consultation should extend its outreach to disability advocacy groups.
Consideration in the ICP
The assessment of SAP outcome 2.1 is rated as positive for SEA objective 9 (population and human health). As further described in Appendix 4 of the Environmental Report, potential effects on SEA objectives 1 - 7 are rated as uncertain due to the uncertainty on whether this outcome would result in an increased number of vessel and vehicle movements across services / routes.
Mobility and Access Committee
Date received: 12 March 2025
Theme: 12 March 2025
Consultation feedback
Potentially Ableist Assumptions (Page 80, Outcome 1.2): There is no explicit mention of disabled passengers or the specific accommodations required for them, which raises concerns that the assessment assumes an able-bodied perspective. Outcome 1.2 discusses people getting to where they need to go but does not explicitly consider disabled passengers who may need additional support, step-free access, or mobility accommodations. Does Outcome 1.2 assume an able-bodied perspective? How has the assessment ensured that disabled passengers' unique needs are considered?
Consideration in the ICP
As described in the SAP and Appendix 4 of the Environmental Report, outcome 1.2 focuses on the effective integration between ferry services and other transport modes, which would benefit all ferry users. SAP outcome 2.2 "will be easy to use for all" focuses on ensuring accessibility for all, reducing barriers where possible. Equality and accessibility are beyond the scope of the SEA and are considered separately in the Equality Impact Assessment of the ICP.