Consideration of the Environmental Report

Assessment Process

The assessment of the SAP and VPP was undertaken using a bespoke assessment framework, developed by Ramboll in consultation with statutory consultees, that interrogated the SAP and VPP components to target potential effects on agreed SEA objectives, assessed in a qualitative manner. The objectives comprised the following:

  • SEA Objective 1 – Air Quality
  • SEA Objective 2 – Noise
  • SEA Objective 3 – Soil/Sediment
  • SEA Objective 4 – Water environment
  • SEA Objective 5 – Biodiversity
  • SEA Objective 6 – Cultural Heritage
  • SEA Objective 7 – Landscape
  • SEA Objective 8 – Material assets
  • SEA Objective 9 – Population and Human Health

The assessment process also included the assessment of cumulative effects, evaluating the significance of potentially overlapping effects on each SEA objective. The assessment also identified mitigation and enhancement measures aimed at avoiding/minimising negative environmental effects and/or enhancing positive effects. 

Findings of the Assessment and Consideration

SAP – ICP Vision

Regarding the ICP Vision, the SEA findings concluded that whilst the primary drivers of the ICP directly/indirectly contributed to long-term benefits associated with SEA objectives 8 (material assets) and 9 (population and human health), it was not clear whether the ICP Vision would lead, in practice, to positive or negative effects on the natural and/ or historic environment (SEA objectives 1 – 7), and accordingly these were rated as unknown. Although no mitigation was considered necessary, proposed enhancement included to consider rewording the overall Vision and/or accompanying text, or adding new text elsewhere in the document, to include specific reference to the protection and enhancement of Scotland’s unique natural and historic environment when designing and implementing policies and actions that support the Vision, and to clarify how the term ‘sustainability’ applied explicitly to the ICP Vision.

Although the wording of the ICP vision has remained unchanged, accompanying text in the SAP does now highlight environmental benefits that the ICP supports, particularly in relation to improved public transport connectivity that could reduce reliability on private vehicles. There is also further clarity on how the term ‘sustainability’ applies, i.e. through the support of greener travel, and specific reference to the protection of the natural and historic environment is now made under the fourth priority ‘Low Carbon and Environmental Impact’ described in the SAP.

SAP Outcomes

Individually, the Outcomes were identified to potentially have positive, neutral and unknown effects on SEA objectives 1 – 7, as the number of services and associated vessel/vehicle/people movements could increase or decrease as a result of the ICP, in combination, a clear intent to reduce the overall dependency on private vehicles to access ferry services by facilitating a better integration with public transport and encouraging active travel was perceived; and, for any new vessels/services to be more efficient and less polluting.

The SAP Outcomes were considered to have overall positive effects on SEA objectives 1 (air quality) and 8 (material assets), and positive significant effects on SEA objective 9 (population and human health), as multiple and complementary benefits to ferry-dependent communities were identified. Potential cumulative effects on other SEA objectives were rated as unknown.

The following mitigation and enhancement measures were proposed, noting to what extent these have been considered in the adopted SAP:

  • The Priorities/Outcomes mainly cover ferry services, active travel and public transportation, and although aviation and potential new fixed links of bridges, tunnels and causeways, are described in the SAP, these modes of transport/infrastructure elements are not specifically referred to in any of the four Priorities and associated Outcomes, the assessment stated that it is unclear how the ICP supports these – Priorities and associated Outcomes continue to exclude specific reference to how the ICP will support these transport modes, which shows that integration of ferry services with these transport modes remains the focus of the ICP. At the same time, the SAP notes that CNAs will further consider specific proposals associated with these transport modes where relevant.
  • A recommendation was made to consider rewording the description of Outcomes to ensure these are Specific, Measurable, Achievable, Relevant, and Time-Bound (SMART) or to set out how progress towards the Outcomes will be monitored in a SMART way – the description of Outcomes has remained largely unchanged, the Monitoring and Evaluation Plan will set SMART targets that will help understanding and evaluating progress of the SAP over the short, medium and long-term, which is considered to have similar benefits.
  • A recommendation was made to consider rewording the Outcomes (or their description in the SAP) to include/emphasise the benefits anticipated on the natural and historic environment, protection requirements and/or enhancement opportunities, which are relevant to ferry services, port developments, as well as other interventions associated with transport modes that are intended to support these – the adopted SAP further highlights the sustainable character of travel choices promoted across its four Priorities and associated Outcomes; extends the scope of outcome 4.2 to support the adaptation of infrastructure to climate change; and clearly commits to support the achievement of net zero targets. In addition, environmental criteria are now noted to be considered in the future Monitoring and Evaluation Plan. It should be noted that although Outcome 4.1 makes specific reference to the design and implementation of policies and actions that support the protection of the natural and historic environment, the only reference to these appears in the Commitments made under the theme “Environmental impact and low carbon”, which now includes an overall intention to “minimise the environmental impact of the next generation of vessels, harbours and ports and ensure they are resilient to the impacts of climate change” and lists an increased number of Commitments (or actions), but not policies.

VPP Objectives

The VPP Objectives were individually considered likely to have both negative and positive effects on SEA objectives 1 - 7 for various reasons. In combination, these were rated positive for SEA objectives 1 (air quality) and 2 (noise), as the long-term benefits from the gradual decarbonisation of the vessel fleet and port infrastructure were considered to outweigh the potential short-term (not significant) negative effects that could arise during port construction, or the small-scale (not significant) negative effects that could arise in relation to potential vessel fleet growth. None of the negative effects identified were considered significant. Significant positive cumulative effects were identified on SEA objectives 8 (material assets) and 9 (population and human health), as individual positive effects were considered complementary and beneficial to strengthen port infrastructure and connectivity.

The following mitigation and enhancement measures were proposed, noting to what extent these have been considered in the adopted VPP:

  • It was recommended to consider rewording the description of Objectives to ensure these are SMART or to set out how progress towards the Objectives will be monitored in a SMART way – this recommendation has not been taken forward, but as noted above, the Monitoring and Evaluation Plan for the wider ICP will set SMART targets that will help understanding and evaluating progress.
  • It was recommended to consider rewording the Objectives or developing a separate set of principles or policies underpinning these to include reference to natural and historic environmental protection requirements and/or enhancement opportunities – the adopted VPP includes reworded Objectives 1 and 8 that now make specific reference to natural and historic environmental protection.

In addition, the section “Decarbonisation” has been replaced by the section “Environmental Impact and Low Carbon”, which places environmental protection requirements and opportunities for environmental mitigation / enhancement at the core of the business case process that informs decision-making.

VPP Project Categories

Similarly, the assessment of VPP Project Categories found that the long-term benefits achieved through the increased adoption of modern and less polluting vessels and overall decarbonisation of the vessel fleet and port operations, would overall have positive effects on SEA objectives 1 (air quality) and 2 (noise), and significant positive cumulative effects on SEA objectives 8 (material assets) and 9 (population and human health). Cumulative effects on SEA objectives 3 – 7 were overall rated as unknown for both VPP Objectives and Project Categories.

The following mitigation and enhancement measures were proposed, noting to what extent these have been considered in the adopted VPP:

  • It was recommended that consideration be given to including reference in the VPP to the principles by which new vessels should be designed and built and how environmental/heritage protection requirements are to be considered through existing project appraisal, development and business case approval processes – although design/building principles have not specifically been listed, as noted above, the VPP makes reference to environmental protection and opportunities for enhancement/mitigation to be integrated into business case processes.
  • It was recommended that consideration be given to considering the development of policies/principles to follow during the planning of port upgrades, so environmental protection can be considered from the outset, and increase opportunities for enhancement measures to be considered at an early stage - although port upgrade planning principles/policies have not specifically been listed, as noted above, the VPP Objectives now include specific reference to natural and historic environmental protection.
  • It was recommended that consideration be given to considering the addition of a specific reference to the requirement to adhere to circular economy/waste hierarchy principles as part of “principles for fleet renewal” or similar to further strengthen benefits to SEA objective 8 – this recommendation has not been taken forward.