3 Taking Account of Consultation Responses

3.1 Consultation Background

Consultation was undertaken between 10th December 2008 and the 13th February 2009. Public notices were placed in the Herald, Scotsman, Press and Journal and Inverness Courier newspapers in addition to the Edinburgh Gazette.

The consultation information was also placed on the Scottish Government and Transport Scotland websites. The volume of published material was such that the documents were primarily web enabled. It was neither practical nor desirable to publish large volumes of the STPR documents, which totalled over 3,700 pages. A summary leaflet was available and a dedicated mailbox and phone service were established to address queries.

This allowed the public and the Consultation Authorities (SNH, SEPA, Historic Scotland and Health Scotland) an opportunity to comment and inform the development and finalisation of the STPR. Comments were received from the Consultation Authorities, the general public, regional transport partnerships, local authorities and other agencies. In total, 55 consultation responses were received. These are summarised later in this section. Annex 2 summarises the consultees.

3.2 Consultation Requirements

The SEA Act places the following requirements on the conduct of the SEA and content and process of adoption. The Post-Adoption SEA Statement must, consequently highlight:

  • How the opinions expressed in response to the invitations mentioned in section 16 of the SEA Act have been taken into account; and
  • How the results of any relevant consultation under regulation 14 of the Environmental Assessment of Plans and Programmes Regulations 2004 (S.I.2004/1633) have been taken into account. It should be noted that no transboundary consultation was necessary as part of STPR.

3.3 Summary of Consultation Responses

Responses received comprised comments that can be addressed within this Post-Adoption Statement, observations regarding the contents of the Environmental Report and comments impacting on the content and presentation of the recommendations of the STPR itself.

There were 55 responses in all, including one from each of the three general statutory consultation authorities (SEPA, SNH and Historic Scotland) and the additional statutory consultee, Health Scotland.

Whilst each raised a number of points which require responses, the consultation authorities felt that the SEA was comprehensive and generally fit for the purpose of informing the STPR. Concerns were raised over the role it plays, however, in supporting greenhouse gas emissions.

Other respondents, conversely, expressed concerns that the SEA process had not adequately influenced the STPR, either in terms of its role in selecting interventions, or in terms of the outcome of the assessment for individual interventions.

Some felt that the inclusion of interventions in the STPR recommendations that had been appraised as having negative environmental impacts illustrated a failing in the process. This was raised particularly in terms of some of the roads proposals emerging from STPR. Others highlighted concern that it had not been practicable to assess all of the likely impacts of proposals and, consequently, the individual and cumulative appraisals were inadequate to properly inform the assessment process.

A number of comments were received about climate change and greenhouse gas emissions. Typically, these expressed concern about the stated impact of the STPR proposals, either individually or in combination, on greenhouse gas emissions. In detail, some responses felt that the emissions outcomes highlighted did not support the Government’s wider targets for climate change.

Approximately half of the consultation responses received were made in relation to the STPR intervention highlighting a proposal for a northern bypass of Dundee. All of these responses expressed a high degree of concern over this proposal and the vast majority specifically requested that it be removed from the STPR recommendations. A response to these comments is presented at the end of table 3.1.

3.4 Addressing Consultation Responses

The consultation responses are summarised in Tables 3.1 and 3.2. Table 3.1 offers responses to those comments which were received from a number of respondees and which might be grouped and responded to collectively without diminishing the relevance of the response to the comment. The table summarises the key consultees who expressed comments combined into the themes shown.

Table 3.2 shows how the remaining comments have been addressed. Typically, these are comments on specific topics that cannot be grouped. Table 3.2 also identifies the originating correspondent. It should be noted that responses have been summarised, although the key points raised have been retained.

The responses reflected in Tables 3.1 and 3.2 do not include general queries or points of clarification that did not originate directly from the consultation process. Many queries have been received as part of general correspondence or through meetings, conferences and other engagements. These have been answered separately and will continue to be so.

Table 3.1 Taking Account of Themed Consultation Responses

Theme of Consultation Response

How Consultation Response has been Addressed

Consultees making point include

Climate Change

A number of correspondents felt that the STPR did not adequately support the wider reduction in Greenhouse gas emissions set out in the Climate Change Bill.

Comments typically fell into the following categories;

Modest performance overall in contributing to climate change goals; concern expressed that the carbon impacts of the STPR are not clearly defined and may have been underestimated and an expectation of clear statements about the expected carbon impacts of the [roads] proposals in the STPR and clarification about how these will be addressed. Concern that the cumulative effects of CO2 increases are ignored in the case of climate change.

Lack of effective interlink between SEA process, its recommendations and the STPR outcomes; Concern that the SEA process appears to have had no overall impact on the content of STPR. Concern that the STPR does not propose interventions which will contribute to a reduction in Greenhouse gasses.

Resilience of interventions in terms of future climate change impacts. Increased flooding, coastal erosion and landslides are all predicted under the climate change scenarios for Scotland and these could all affect Scotland’s transport networks. Projects that are going forward should be tested in terms of their resilience to climate change.

Assumptions underlying the impact of interventions on climate change outcomes; Concern that the SEA fails to include the implications of road improvements for traffic volumes and subsequent air pollution impacts, whilst timesaving or economic benefits which may arise from net capacity increases and consequent traffic volume increases, are assumed to occur.

The method for estimating climate change impacts is described on page 69 of the environmental report.

Assumptions used in estimating CO2 output employed a worse case scenario in each case. For instance, rail interventions are assumed to use diesel rolling stock unless the intervention specifically proposes electrification and no allowance is made for the generation and use of electrical power using renewable sources.

As the network is progressively electrified, therefore, the local or regional impacts arising from diesel emissions on specific routes would typically reduce.

The use of renewable generation sources would, in addition, lock in benefits at a national level. This would further reduce carbon emissions markedly from that suggested in STPR.

The approach to the SEA followed follows guidance within Volume 11 of DMRB. These assessments produced logical results and have been grouped into bands. The banding system presented in Table 3.5 of the ER was applied when estimating significance of transport interventions in terms of increasing CO2e outputs. In practice no significance ratings greater than minor benefits were recorded.

The SEA and STPR have been closely linked, as shown in Chapter 2 of the Post Adoption Statement. The ability the STPR to address climate change in its own right is very much limited and the emissions figure produced illustrate this. This is reflected in the STPR reports, with specific reference to the additional measures that could be implemented in the areas of technological enhancements and behavioural change.

The need to demonstrate and deliver resilience to climate change impacts is acknowledged. The recently launched Landslides study will be included in the maintenance of the network and the design and delivery of interventions. Similarly, flooding and sea level changes will be considered in the development of proposals. This will be acknowledged in the mitigation and monitoring strategies.

The framework in which the STPR and SEA sits acknowledges the objectives of managing the demand for travel and reduction of transport emissions in the future. This is reflected in corridor specific objectives, particularly for those corridors where increases in emissions or existing high emission levels are noted, for instance the Edinburgh to Glasgow corridor.

Most of the roads proposals do not create additional capacity, or do so in a marginal way, for instance by widening or straightening a rural road. They are less likely, in their own right to encourage traffic growth. They do however seek to improve reliability and therefore reduce stop-start conditions and carbon emissions. Other proposals, such as the A9 upgrade, for instance, need not encourage significant additional traffic as the characteristics of the route are such that strategic trips may be more likely to grow in response to land use changes, not capacity changes on the connecting routes.

It is recognised that the potential impacts of road improvements must be considered on a case by case basis and we recognise the potential for some capacity increases to be associated with increases in scheme specific emissions.

However as outlined in the reports there is forecast to be a reduction in road based transport carbon emissions of between 100,000 and 150,000 tonnes of CO2e per year. These forecasts have been derived using the most appropriately available modelling and analytical tools.

SNH, SEPA, Friends of the Earth (Scotland), City of Edinburgh Council.

Sustainability

There is reference in the main report about it being good practice to undertake sustainability appraisal alongside SEA.

We strongly support the undertaking of sustainability appraisal, but only if it is done as an add-on to the SEA.

Also, concern expressed about sustainability of recommendations in terms of such matters as sea level change, flooding, landsides etc.

The Sustainability Appraisal is only applied to the STPR objectives and is separated from the rest of the SEA by being included within its own specific section (section 2.5 of the Environmental Report). It is intended as an informative add on to the SEA of the STPR and is clearly identified as such 2.5.1 Objectives: Methodology.

The inclusion of a sustainability appraisal allows greater transparency surrounding the decision making process and clearly illustrates how issues of sustainability have been integrated into the STPR decision making process at a very early stage. As noted in the comment on climate change, mitigation and monitoring will include reference to climate change resilience.

SNH, SEPA, SAPT, CILT.

Impact of SEA on STPR

A number of correspondents expressed concern over the impact of the SEA process and findings on the recommendations of the STPR.

The SEA Statement should make clear how the assessment process has influenced the contents of the STPR during its finalisation. In spite of giving certain interventions an ‘adverse’ rating, the SEA does not appear to have had an influence on STPR, in terms of excluding them.

Chapter 2 of this Post Adoption Statement illustrates how the development of STPR and its SEA have run in parallel.

Chapters 5 and 6 of the Post Adoption Statement illustrate the ongoing proposals to ensure that the development of interventions arising from the STPR is done to the best environmental standards.

The SEA is not the sole determinant in an interventions inclusion or exclusion at the strategic level at which the STPR has been undertaken.

Further environmental assessment will take place to determine how the recommendations may be carried forward, or how the objectives of STPR may be otherwise met.

Of particular issue raised in this response is the opportunity that has been afforded to the SEA process to affect the decision as to which implementation should be progressed and which should not.

Through the use of the ANSEA approach it was identified that sifting of transport interventions was a significant decision window and the close integration of the environmental assessment process and the sifting of options was conducted at this stage. Hence rather than the SEA reactively affecting the decisions as to which interventions are implemented. It has taken the approach of pro-actively influencing this decision.

Project Environmental Appraisals of Route Options (at the Project STAG 1 stage) and detailed Environmental Impact Assessments (at the STAG II stage). The Environmental Statement will identify for each intervention, specific issues that should be considered and suggest at what stage in the decision making the assessment should be.

SNH, SEPA, SEStran, Transform Scotland.

Monitoring and Reporting

The mitigation proposals in the Environmental Report address the issues that are required in order to meet statutory obligations. Comments that wider demonstrable consideration of environmental effects is needed.

We would expect mitigation action to be associated with transport infrastructure projects, both online and offline.

Recommendations that the Adoption Statement emphasise the need for subsequent project assessments to consider mitigation for all natural heritage impacts and for the ensuing proposals to set out who will be responsible for undertaking and managing mitigation works, and to give a commitment to it being done.

Chapter 6 of this statement sets out how the development and delivery of the STPR will be monitored.

The Environmental Assessment (Scotland) Act 2005 is clear on the requirement to monitor and the role monitoring plays in the ongoing implementation and refinement of the STPR.

Transport Scotland will work with key stakeholders in ensuring that this takes place.

In addition, the development of more project specific monitoring and mitigation will be undertaken as the interventions arising from STPR are taken forward.

SNH, SEPA, Historic Scotland

Scope of STPR

Some correspondents expressed concern that the STPR was not wider ranging enough to encompass all the modes it needed to consider.

Concern that walking and cycling should are excluded from STPR; Schemes to improve provision for walking and cycling are regarded as being "outside the scope of the review" and as "not strategic in their scope or funding requirements". STPR does nothing specifically to encourage walking and cycling, and so makes no contribution to improving public health

The STPR requires to be extended to include aviation issues with more being put on the acceptance by the UK and Scottish governments of a substantial shift of Anglo-Scottish travel from air to rail.

The STPR is one of the mechanisms for delivering the National Transport Strategy (NTS), published in 2006. This strategy outlined the vision for the country’s transport network and the context for transport policy in the next 20 years.

The STPR is not the only mechanism for delivering the NTS and modes such as walking and cycling are better addressed in the NTS delivery plan, and through regional and local transport strategies.

Similarly, the STPR does not include air, because air policy is determined at a UK level and the STPR is not a policy document.

Transform Scotland, Friends of the Earth Scotland, CILT, SEStran, Railfuture Scotland, CRAIC

Queries about the consistency of the STPR assessment with that of the National Planning Framework 2, which also considered a number of the STPR interventions.

Concern that there doesn’t appear to be the appropriate level of synergy between the STPR and other policy documents such as the National Planning Framework.

Also queries in respect of findings of NPF2 SEA and STPR SEA in terms of overall assessment of environmental impacts of interventions.

The National Transport Strategy recognises the critical importance of providing efficient links between our cities, stating that "our strategic networks are particularly important for connecting our cities, connecting our towns with cities and bringing people and goods to those cities".

The Strategy recognises, however, that strategic networks "are also critical for providing key routes into our wider regions, including the Highlands and Islands, to our regeneration areas, to England and to global markets to contribute to the accessibility of Scotland as a whole through road, rail and port connections. This means the strategic networks have a particular role in providing for the longer intercity and inter-region journeys."

These themes are inherent in the development and conduct of the STPR. In addition the high level objectives of STPR are drawn directly from the objectives of the NTS and linked to the themes of the Scottish Government’s Economic Strategy. Concerns about inconsistencies between the assessment of the emissions arising from road improvements in the STPR and NPF are acknowledged.

This arose because the assessment of candidate national developments in NPF2 was undertaken prior to the STPR being finalised and was therefore based on a set of assumptions as defined within Appendix 2 of the NPF ER. Different methods of assessment were used in the SEAs: whilst the STPR was based on quantitative modelling of projected emissions, the NPF assessment used a more qualitative approach that was based on professional interpretation of available relevant, but also generic evidence.

Such inconsistencies are almost inevitable within the SEA process and are considered to be acceptable when both assessments are attempting to define the downstream effects of very high level plans. The apparently more negative conclusions of the NPF SEA should not therefore be interpreted as undermining those of the STPR SEA.

SEPA, SEStran, Fife Council, Tactran.

Consultation process

There are concerns that there has been no public consultation on the STPR and limited consultation on the SEA prior to the release of the STPR. It is currently unclear how comments to this consultation will be incorporated in the already published STPR.

The STPR is drawn from the national Transport Strategy for which there was extensive consultation. The STPR was subject to consultation by reference group interaction throughout the development of its baseline, underlying issues and both its high level and more specific objectives.

The consultation undertaken under SEA legislation presented the recommendations emerging from this to further consultation, which has been augmented by individual meetings and presentations. All of the comments received in the course of the consultation will be considered and addressed appropriately.

SESplan, Fife Council, West Lothian Council.

Assessment of environmental and non environmental issues

Balancing out environmental effects against safety issues in this way is misleading as to the environmental impact of the proposals. We think it would clearer to conclude that such a proposal has a range of adverse environmental effects (some certain, some of which could be mitigated), but it would also deliver major improvements in road user safety.

The SEA includes assessments of non-environmental effects such as "benefits to commuters" which are then included in a qualitative aggregation of scheme benefits and disbenefits with the result that environmental disbenefits are down-weighted.

This report fails as an environmental assessment because it confuses environmental impacts and other factors such as cost-effectiveness and efficiency, While these are factors to be taken into account, they are not key in assessing environmental impact and contribution to the level of climate change emissions.

The EU directive that implements SEA specifically requires a consideration of the total, i.e. human and natural environment. Therefore it is a legislative requirement that the SEA approaches issues such as human health and issues that impact upon the population in general.

Within extant guidance for producing an SEA for transport policies both accessibility and human health are cited as applicable issues against which transport interventions should be addressed.

The difficulties in addressing these factors and balancing off one aspect of the environment against another are recognised within the environmental report.

Sustainable access is promoted through STPR in a number of ways. The promotion of a rail dominated programme supports mode shift, while the spread of electrified rail lines offers the potential to use renewable energy for rolling stock propulsion.

The design, including mitigation and monitoring, of STPR interventions will also include consideration of the maintenance and promotion of active travel routes where appropriate.

SNH, Friends of the Earth (Tayside), Friends of the Earth (Scotland), Transform Scotland.

Dundee Bypass comments

   

A considerable number of commentators wrote highlighting concerns Intervention 29 (Dundee Northern Relief Road). These concerns focused on impacts on the countryside, environment and communities to the north of Dundee.

Friends of the Earth Tayside is very concerned to see that the proposal for a Dundee by-pass is given support in this document and is viewed as a preferred option rather than an upgrade of the Kingsway to improve traffic flow along the A 90 corridor bordering Dundee.

The environmental assessment of this proposal is surprisingly favourable to the by-pass option, much more so than Strategic Environmental Assessment associated with the same proposal when it initially appeared in the draft TACTRAN document.

The Bypass proposal illustrated in STPR is one of two strategic options, the other being upgrade and improvement to the existing A90 through Dundee.

No firm proposals exist to develop and Dundee bypass. Alternatives for addressing strategic traffic issues around Dundee will be taken forward in line with the STPR’s published hierarchy of

  • Investment aimed at maintaining and safely operating existing assets (ensuring the connections between where people live and work are of a suitable standard and safe);
  • Investment promoting a range of measures, including innovative solutions, to make better use of existing capacity, ensuring the existing road and rail networks are fully optimised (these may include technology based, fiscal and ‘soft measures’ in addition to engineering solutions); and,
  • Investment involving targeted infrastructure improvements.

Consequently, it might be expected that a new route would be developed only after consideration to other alternatives had been explored.

Any such consideration will comprise consultation and engagement with relevant parties, including the local community.

Auchterhouse Community Council, Lundie, Muirhead and Birkhill Community Council, Carbon Reduction Action and Information Centre, Dundee Green Party, Friends of the Earth (Tayside), Teal Community Council, individuals.

Table 3.2 Taking Account of Specific Consultation Responses

Summary of Consultation Response

How Consultation Response has been Addressed

Historic Scotland

We confirmed at scoping that we were content with the SEA Objective for the historic environment and welcome that the techniques for assessing effects section (page 70) provides further clarification on how this objective has been applied.

We would have expected all categories of listed buildings to be included in this baseline, as well as unscheduled archaeology from the relevant Local Authority Sites and Monument Record.

There is a general principal in SEA that the baseline should be of sufficient detail to inform the assessment, this issue was raised as recently as February’s edition of the Scottish Planner in an Article from the Scottish Government’s advisor on SEA.

The assessment, as agreed within this response, understandably focuses at the national level and the existing baseline, in order to avoid unnecessary expenditure of resources has concentrated on nationally important cultural heritage resources.

It is accepted that an assessment of all historic resources needs to be considered within the tiered environmental assessment approach that most interventions will be subject to. The level of assessment that interventions will require during their permitting process will be identified as stated above, which will include as assessment on all listed buildings.

Please note that Scottish Historic Environmental Policy (SHEP) supersedes the policy elements of Passed to the Future.

Text to be included in an addendum to the Environmental Report.

(Addendum comment 1.1)

I note that the number of listed buildings, scheduled monuments and conservation areas potentially lost or affected by proposals will be monitored.

The monitoring strategy should monitor significant effects of the interventions upon the historic environment as a whole and therefore should not be restricted to designated sites and buildings and conservation areas. The monitoring strategy should also consider effects upon archaeological sites, gardens and designed landscapes.

Text to be included in an addendum to the Environmental Report.

(Addendum comment 1.2)

The monitoring strategy will reflect the sites outlined where practicable.

It may be useful to split the proposed monitoring item into separate categories, which address both direct impacts (loss/partial loss) and significant impacts upon setting as follows:

SEA objective: to safeguard cultural heritage features and their settings

  • indicator: number of scheduled monuments lost or significantly affected by proposals
  • indicator: number of listed buildings lost or significantly affected by proposals
  • indicator: number of archaeological sites lost or significantly affected by proposals

It would be useful for the SEA Statement to indicate who will be responsible for both carrying mitigation through and monitoring the effects of the transport interventions.

All points will be considered within the monitoring strategy presented in this document.

Health Scotland

 

It is very comprehensive. Good to see the link between air pollution and health being made although the issue of people at risk as a result of  existing conditions (as well as the undesirability of pollution for all the population) could always be emphasised more. 

The only other remark would be about measuring health impacts in terms of active transport/physical activity 

The measurement of physical activity has been highlighted by some other respondents. The mitigation and monitoring strategies will consider the maintenance or promotion of active travel routes where appropriate.

Walking, cycling and other active travel modes are more properly considered under other aspects of the National Transport Strategy.

SNH

Although this is a strategic environmental assessment and not a sustainability appraisal, the SEA Indicator Questions as set out on pp 70-78 include some which are more about societal benefits than environmental impacts:

Population — would the intervention provide sustainable access?

Human health — does the intervention have the potential to promote healthier and safer lifestyles?

In arriving at an overall assessment, the uncertain impacts (which will only become known at a more detailed planning stage) on several criteria have been balanced out by positive impacts on population or health to conclude that the project will be beneficial overall.

The SEA is compliant with the regulations set out for its completion. The difficulties in addressing these factors are, however, recognised.

Sustainable access is promoted through STPR in a number of ways. The promotion of a rail dominated programme supports mode shift, while the spread of electrified rail lines offers the potential to use renewable energy for rolling stock propulsion.

The design, including mitigation and monitoring, of STPR interventions will also include consideration of the maintenance and promotion of active travel routes where appropriate.

Finally, under the heading of ‘population’, it is not clear that consideration of sustainable access has included consideration of the potential to improve facilities for active travel.

STPR sets out the strategic concept of interventions. Issues of access are important but are more effectively dealt with at design stage and addressed by mitigation and monitoring.

We suggest that it will be important for the STPR to flag up the need for impacts on resources of regional or local importance to be assessed in working up the detail of any of the component projects.

It would be helpful if the Adoption Statement could place a marker on the need for such issues to be addressed at the project level.

Agree and this issue is flagged up in this post adoption statement, noting that STPR sets out the strategic concept of interventions.

Issues of access are important but are more effectively dealt with at design stage.

Consideration should be given to the risk that transport infrastructure projects will lead to further fragmentation of habitats and disruption of ecological networks, effectively putting in place barriers to species movement

Assessing significant effects arising in such cases will be included in the monitoring strategy.

The assessment of transport projects — both infrastructure works and softer policy measures — should include consideration of the impacts on people’s ability to use outdoor access resources.

Negative impacts could result from temporary or permanent disruptions to Long Distance Routes, regional routes and local routes.

These impacts should be avoided by careful planning of both the infrastructure works and the temporary or permanent diversion of active travel routes.

The design of projects will include a consideration of these factors. Mitigation and monitoring strategies will similarly reflect the potential to impact on walking, cycling and other outdoor access resources.

Project environmental appraisals should consider the impact on all landscapes.

Impacts on Scotland’s areas of wild land should also be taken into account.

Agreed a marker is included within Environmental addendum and monitoring strategy.

We have identified two projects where we would recommend a further level of strategic appraisal of environmental effects, to assess different options at an individual project level:

D14 A9 Upgrading together with D15 Rail Enhancements on the Highland Mainline.

These projects are planned for the same transport corridor, and there is potential for cumulative impact, eg on the flood storage capacity of the land traversed. Consideration should also be given to whether any works can be integrated with works proposed for the Beauly-Denny interconnector.

D21 Grangemouth Road and Rail Access Upgrades.

Concern that increase in shipping to post may impact designated areas along Forth estuary.

As a normal part of the appraisal process, a suitable assessment of the environmental affects would be undertaken, reflecting the status of the various projects noted.

This will be undertaken as far as practicable for the A9 corridor, noting the uncertainties over the longer term detail of some aspects of the development proposals, particularly the A9 upgrade.

We do not accept that the D21 intervention increases shipping, as it focuses on potential road and rail interventions accessing the landward side of the port.

Any change in shipping patters will be independent of the access improvements and beyond the control and scope of STPR. Any further work undertaken will reflect this.

We do not expect to undertake any work on this intervention in the short term.

There are references to the use of SNH’s Site Condition Monitoring (SCM) programme as a basis for monitoring impacts on SSSIs and Natura sites.

If as a result of implementation of the STPR there is a need to monitor potential impacts on SSSIs, this would have to be done outwith or as an enhancement to the SCM programme.

Assessing significant effects arising in such cases will be included in development of proposals and their monitoring strategy.

There is also an important body of information on biodiversity gathered through project-level Environmental Impact Assessments.

Ask that when habitat and species data are collected, such as through survey, they should be put into the public domain through the National Biodiversity Network.

Comment generally agreed — a recommendation to be included in the Environmental Statement addendum to supply this information in a format that allows it to be so placed.

(see addendum comment 2.1)

There is a duty on Member States under Article 12.4 of the Habitats and Species Directive to establish monitoring of incidental or accidental capture and killing of those species listed on Annex 4 of the Directive (European Protected Species).

Transport Scotland's trunk road operating companies are responsible under existing contractual arrangements for the removal of animals killed on the road network and procedures are being developed to monitor the incidence of kills of EPS.

Transport Scotland is working towards development of a more comprehensive monitoring system for this to be implemented in the next round of operating company contracts which will be awarded from 2011.

We recommend that monitoring should include the effect on people’s use of outdoor recreation and active travel routes.

This might include direct monitoring of active travel facilities.

The potential effect of delivering STPR interventions on people’s ability to use outdoor recreation and active travel will be considered at an appropriate level within more detailed scheme appraisal, for example core path networks.

We note that an emphasis is placed on the role of Landscape Character Assessments (LCA) in monitoring effects of STPR projects on the landscape.

The existing LCA assessment for the area may provide a helpful baseline, although it is likely that further baseline analysis should be undertaken as part of the associated Environmental Impact Assessment.

Changes in landscape character would be recorded in the EIA of any major development, and this could be recorded within a monitoring programme. Significant effects will be monitored as part of project level EIA.

The section on page 8 on soils and geology should summarise the potential impacts on geodiversity

Proposals within the STPR should be tested as to whether they are compatible with the objectives of this Scottish Soil Framework.

This was not published in time to be incorporated in the SEA. Therefore, it was not included. Never the less it will form part of ongoing scheme development, mitigation and monitoring.

(see addendum 2.2)

The section on climatic factors should identify rising sea-levels as an effect of climate change. There should also be mention of increased risks of landslides and instability.

A comment to this effect will be included in the addendum to the Environmental Report. (see addendum 2.3).

Under ‘Treatment of adverse effects’ on page 16, we recommend an additional bullet point to take account of impacts of climate change: ‘Ensuring that developments in dynamic environments (such as river floodplains and at the coast) are based on a sound understanding of natural processes.’

A comment to this effect will be included in the addendum to the Environmental Report. (see addendum 2.4).

We are not clear, in the ‘Soils and Geology’ section, whether impacts on environments such as river corridors, floodplains and coastal areas were considered.

This will form part of ongoing scheme development

The section on future trends should recognise potential changes in geomorphological processes — changes in magnitude and frequency of flood events, coastal erosion and landslides, particularly in the light of climate change.

This was not published in time to be incorporated in the SEA. Therefore, it was not included. Never the less it will form part of ongoing scheme development. (see addendum comment 2.5).

D1: Delivery of the Strategic Road Safety Plan

There could be impacts on local environments, for example as a result of the removal of trees for safety reasons and the impacts of these should be considered carefully.

Assessing significant effects arising in such cases will be included in the monitoring strategy.

D3: Targeted Programme of Measures to Reduce Accident Severity

It is important to bear in mind that if works are needed near accident black spots that might impact on Natura sites, then further assessment is required.

Assessing significant effects arising in such cases will be included in the monitoring strategy.

D3c: Targeted Programme of Measures to Reduce Accident Severity between Inverness, Fort William, Mallaig and Skye

Improvements to the A82 in this area could impact on a highly valued, but not nationally designated, landscape. It is also important to take into account the proposals for the establishment of a National Cycle Route along this section.

Assessing significant effects arising in such cases will be included in the monitoring strategy. The comment on National Cycle Route provision is noted and will be considered in light of other published strategies.

D3d: Targeted Programme of Measures to Reduce Accident Severity between Aberdeen and Inverness

As with the improvements to the A82, work on the A96 could lead to localised landscape impacts. Any work is, however, unlikely to impact on Bin Quarry SSSI.

A comment to this effect will be included in the addendum to the Environmental Report. (see addendum 2.6)

D3e: Route management

There is a reference to no works taking place within 2km of Natura or Ramsar sites. However, in subsequent planning and assessment it will be important to take into account potential impacts on other sites, such as SSSIs and landscapes.

Assessing significant effects arising in such cases will be included in the mitigation and monitoring strategies.

D4: Targeted Programme of Measures to improve the Trans European Network linkage to Loch Ryan port facilities

Given how close the road (A75) goes to Natura sites and other designations, it is not clear that adverse effects can be avoided. The assessment needs to recognise the range of sites that could be impacted by these works.

Improvements are considered to be on-line. The assessment reflects this. Assessing significant effects arising from more detailed proposals will be included in the more project focused assessment.

D5: Targeted Programme of Measures to Improve road standards between Glasgow and Oban/Fort William (A82)

The potential impacts have been identified, but as there is little detail on the proposals it is difficult to assess the magnitude of the impacts. Given the sensitivity of the area (especially around the north end of Loch Lomond in the National Park), we feel that the impacts have been underplayed. The suggested mitigation may not adequately address the impacts on the landscape.

Improvements are considered to be primarily on-line.

Acknowledge need for more detailed investigation as project is given more definition. Assessing the significant effects arising will be included in the monitoring strategy.

D7: Further electrification of the strategic rail network

This intervention could have significant landscape impacts if overhead lines are used through sensitive areas of the countryside.

Acknowledge that overhead lines could have a visual impact on some specific locations. Also needs to look to next level of project definition. Assessing significant effects arising in such cases will be included in the monitoring strategy.

D10: Reconfiguration of the National Rail Timetable

We welcome the encouragement of people to use public transport, but there may be a risk of an adverse effect on local train travel in favour of inter-city journeys.

Subsequent evaluation and monitoring should be sensitive enough to pick up any negative effects on travel options for local communities.

The National Transport Strategy, and its supporting document "Scotland’s Railways", highlight the role of rail in providing;

  • Fast, long distance passenger services between our major urban centres;
  • High quality commuter services into major areas of employment, education and leisure activities; and,
  • Rail freight services for regular high volume and generally long distance flows.

The service patterns that may be delivered in future to utilise any new rail infrastructure will be designed to support these objectives.

D11: Park-&-Ride/Park-&-Choose Strategy

These developments could have adverse landscape impacts if they are not sited carefully.

Acknowledge that P&R could have a visual impact on some specific locations. Also needs to look to next level of project definition.

Assessing significant effects arising in such cases will be included in the monitoring strategy This will be based on the strategy published in July 2009 for Park and Ride sites.

D14: A9 upgrading from Dunblane to Inverness (parts 1 and 2)

The impact on habitats may be significant in terms of the Natura tests, and this is likely to need further consideration at the more detailed planning stage.

There are multiple crossings of the River Tay SAC, including several crossings of tributaries which form part of the SAC. The documentation is not clear that all these have been identified, although the conclusions reached remain the same: that effects can be mitigated. This is likely to be an appropriate conclusion for the construction phase.

We are concerned that the environmental report downplays the potential impacts on landscape and visual amenity.

In terms of landscape, one of the most critical is the River Tay (Dunkeld) NSA due to the narrowness of the pass. The visual impacts are likely to be significant.

There are quite a number of SSSIs along the route of the A9 and the impact on these needs to be taken into account in subsequent assessments — with effective mitigation designed if impacts can not be avoided.

The Adoption Statement, at least, needs to make reference to maintaining existing access/recreation routes that currently pass under the A9 and providing new underpasses where necessary.

As highlighted earlier in our response, it is important to look carefully at the cumulative impacts of the proposed work on the A9.

Acknowledge need for further assessment when more detail of proposal is available.

Assessing significant effects arising in such cases will be included in consideration of scheme design and carried through the mitigation and monitoring strategies.

Through the Cycling Action Plan for Scotland we will be recommending that more effective monitoring should be undertaken at both national and local levels.

The design stage of interventions is the most appropriate point to consider likely significant effects on active travel routes and it will be undertaken at that stage.

The form and scale of any cumulative impacts associated with this intervention will depend greatly when the intervention is progressed and when other projects such as the highland mainline and Beauly - Denny grid connection are understood in their final form. It is recognised that these effects need to be taken on board during the design phase of this intervention.

D15: Rail Enhancements on the Highland Mainline between Perth and Inverness

Especially important is that Auldclune and Invervack Meadows SSSI has been omitted from the list, and it may be impacted through harm or loss of extent.

A comment to this effect will be included in the addendum to the Environmental Report. (see addendum 2.7)

D 16: Upgrade A 96 to Duel Carriage way between Nairn and Inverness

There are references in section 6.3.3 to Calvine and Blaire Atholl in relation to this intervention, but these places are not relevant to this project

(see addendum comment 2.8)

D18: Rail Enhancements between Aberdeen and the Central Belt

The River South Esk SAC should be added in as it also discharges to the North Sea via Montrose Basin. Construction of a new bridge would have to consider any impacts on migratory salmonids.

The statement 'which is also graded at international level for its biodiversity' should perhaps be changed to 'graded at international level for being a wetland supporting over-wintering wildfowl'.

A comment to this effect will be included in the addendum to the Environmental Report. (see addendum comment 2.9).

D19 — Dundee Northern Relief Road

The Den of Fowlis SSSI should be mentioned.

There may be impacts on red squirrels, especially near Camperdown. It is a notable species in and around Dundee, with significant population. The likely impacts on the population include fragmentation of habitat and roads presenting barriers to movement of animals and causing road kills. There is likely to be land-take so we would expect some impacts on soils and geology.

A comment to this effect will be included in the addendum to the Environmental Report ((see addendum comment 2.10).

It was not possible to assess the specific impacts on the red squirrel populations due to the lack of detail concerning the routes and location of the relief road.

However the issue is noted and impacts on notable species will be recognised in the design of interventions and carried into mitigation and monitoring.

D21: Grangemouth Road and Rail access Upgrades

If more commercial shipping is to be encouraged, then this may increase the risk of oil spills. This intervention is likely to warrant a strategic environmental assessment of project options to look at the cumulative impacts from it and other projects in the vicinity.

Given the works required, there are likely to be impacts on geodiversity — and this should be acknowledged in the environmental report.

This intervention does not encourage shipping as it relates solely to road and rail access to a port which already has plans for various forms of development.

We do not accept that a further assessment of the STPR recommendation is necessary to assess shipping impacts.

D24: Targeted Road Congestion/Environmental Relief Schemes

This project includes the building of new infrastructure, and careful design of this and integration with the active travel networks, will help cater for active travellers and the routes that they currently use.

There will also be opportunities to improve connections between active travel routes and communities that have been bypassed and to encourage the use of roads which have been relieved of traffic.

The final design of such schemes should include provision for new infrastructure that mitigates the physical effects on communities. Although this intervention is mentioned at all the appropriate places throughout the main environmental report, it is not listed in the summary tables in the non-technical summary

This is more appropriately dealt with as individual projects come forward for more detailed consideration.

D25: West of Scotland Strategic Rail Enhancements

Aspects of this intervention affect Glasgow and have the potential to disrupt the public realm movement corridor comprising Buchanan Street and St. Enoch Square and also the riverside National Cycle Route 75

Diversions and closures of existing routes are commonly used to manage changes in infrastructure, but the quality of the temporary arrangements needs to be considered as early as possible to reflect the volume and type of existing users and the effect of each phase of the works.

Given the works required, there are likely to be impacts on geodiversity — and this should be acknowledged in the environmental report.

This is more appropriately dealt with as individual projects come forward for more detailed consideration.

D27: Rail Enhancements between Inverclyde/Ayrshire and Glasgow

This intervention includes a possible new rail link between Paisley Canal and Elderslie. National Cycle Route 7 (Paisley to Irvine section) currently occupies the old railway corridor.

So, the design of any new rail link should, from an early stage, fully consider active travel routes in the area.

The re-use of old transport corridors could have effects on habitats and/or protected species that have re-established. This should be considered in subsequent assessments and suitable mitigation included in project plans.

This is more appropriately dealt with as individual projects come forward for more detailed consideration.

D29: Enhancements to Rail Freight between Glasgow and the Border via West Coast Mainline

Although impacts are less likely than with other interventions, it is important to take active travel interests into account in subsequent assessments of this intervention as project plans develop.

This is more appropriately dealt with as individual projects come forward for more detailed consideration.

City of Edinburgh Council

The intervention which would have the greatest environmental benefit, reducing travel or the need to travel, does not feature in the STPR.

Neither the Forth (replacement) Crossing nor the Edinburgh-Glasgow (rail) Improvement Programme is included in the SEA. This appears to be because they were addressed as national developments in NPF2.

However, to facilitate an overview of the environmental impact of the STPR, they should perhaps have been included in this document; not least as they are the programmes which will probably have the greatest environmental impact.

The STPR is one aspect of the overall delivery of the National Transport Strategy. The NTS, in its entirety, more fully addresses the need to travel.

The Forth Replacement Crossing has already been subject to SEA, which was published in November 2007. EGIP is subject to its own SEA. NPF2 has also been subject to SEA.

The environmental impacts of the Forth Replacement Crossing are clearly understood and the impacts of EGIP are likely to be beneficial, both in its promotion of mode choice and potential for using sustainable electricity generation when electrified.

The SEA identifies Work Package 9 (Intelligent Transport Systems) as having major regional and local environmental benefits.

It is difficult to see how this can be accurate when one its main components (using hard shoulders for general traffic rather than buses/HOVs) significantly increases the capacity of the road network in congested areas.

The overall Scotland-wide Cumulative Effects with regard to Climatic Factors, Air Quality and Human Health are assessed to result in minor benefits. This is difficult to agree as there is no overall reduction in travel; and growth in travel will almost inevitably increase climate and air quality-related emissions.

The STPR identifies reduction in CO2e of between 100,000 and 150,000 tonnes. In part this is achieved by more efficient use of the network, though reduced congestion, arising from ITS.

Environmental Effect of these interventions (as is required under the SEA Act) are assessed against the existing baseline which in this case involves heavy traffic use and a large degree of congestion.

It is the congestion relief resulting that links to the minor benefits on regional air quality. The assumption used is that the traffic management measures will change the way the capacity is used, not that it will result in an increase in road usage.

Using Intelligent Transport Systems on Parts of the Road Network to Enhance Capacity and Operations.

Major long term Regional benefits

Neither the summary nor the full environmental report indicate why this should be the case.

ITS used in the manner proposed would generate traffic (by effectively creating new capacity), with environmental disbenefits

Point of ITS is to better manage capacity at times of peak demand to reduce congestion.

This congestion reduction resulting reduces emissions associated with the traffic involved. The detail of individual proposals will be developed to address their particular operating requirements.

Further Electrification of the Strategic Rail Network - Moderate long term Regional benefits

This would have national not just regional benefits; priority routes likely to be national routes

The proposed electrification of the rail network is phased, and the most immediate benefits would accrue regionally from the use of electric powered rolling stock.

National benefits would be affected by the generation source for the electricity used, which cannot be specified at this time.

Rail Enhancements in the East of Scotland - Moderate Local long term benefits

Has regional, not just local benefits. Compare and contrast with D27 ‘Rail Enhancements Inverclyde/Ayrshire —Glasgow’ which are assessed as ‘Moderate long term Regional benefits’

This intervention primarily benefits Fife and so may be categorised as local.

The D27 enhancements are more geographically extensive and generate benefits for a wider area.

West of Scotland Strategic Rail Enhancements: Glasgow Tunnel proposals -

Moderate long term Local benefits

Depending on the scheme, potentially national

Note the comment raised. It does not affect the overall assessment and continued refinement of the emerging proposal will be accompanied by further environmental consideration.

Upgrade Edinburgh Haymarket Public Transport Interchange - Moderate long term Local benefits

Has regional, not just local benefits. Haymarket is a regionally significant location

The impact of Haymarket is primarily local. The consequent rail service changes which may arise are addressed in other interventions.

The appraisal is reported as local to avoid double counting.

Light Rapid Transit connections between Fife and Edinburgh - Minor or Moderate long term Local benefits

Has regional, not just local benefits; is a regional project

Note the comment raised.

New Rail Line between Perth and Inverkeithing - Moderate long term Regional benefits

This would have national not just regional benefits; would be used by nationally strategic services

This proposal would not affect rail service environmental impacts across the country as the operating impact of services on connecting lines would be unaffected. The changes would be felt in the area affected by route change as so are more properly described as regional.

New LRT Line to SE Edinburgh - Minor or Moderate long term Local benefits

Has regional (perhaps national), not just local benefits. Compare and contrast with E14 ‘Augment far north rail line…with express coach’ which is assessed as ‘Minor…local and regional benefits’

The LRT proposal has no national benefits as it does not materially affect Public Transport patterns outwith the local/ regional context.

Scottish Association for Public Transport

Another factor neglected in the Environmental Report is the impact of changes in policy and in fossil fuel prices on future forecasts of movement and modal share both within Scotland and on external links.

The STPR as adopted needs to give more attention to this issue with explicit recognition that a continuation of the near stabilisation of road vehicle kilometres (already evident for car use as shown in Scottish Transport Statistics, December 2008) and a substantial slowing of aviation growth offers joint benefits for the economy, the environment and society.

The Environmental Report also needs to take account of the advocacy in the National Planning Framework of land use and pricing policies which can reduce the need for movement and encourage both shorter trips and working and shopping from home.

The STPR has considered a number of scenarios. These are summarised in Report 4.

The overall conclusion from this suggests that any changes arising from increases in fuel costs etc are likely to be in terms of timing rather than pattern.

Note, also that assumption on fuel prices etc is not within the scope of an SEA.

The need for more investigation of this area is admitted with the Climate Change Committee urging faster moves towards the use of electric power in transport if steepened 2020 targets are to be met. What also requires examination in the STPR (and in SEA) are the increasing prospects that overall road vehicle kilometres can be stabilised (reduced in some areas) and domestic air travel in Britain (and to the nearer continent) reduced over the period to 2022 with joint benefits for the economy, the environment and society. Environmental assessment must be revised to take account of these probabilities.

The STPR has been undertaken using currently available modelling tools. Sensitively testing was undertaken and concluded that patterns of vehicular use are relatively impervious to changes in factors such as fuel process etc.

Also, may of the issues STPR addresses are current, and as such, are not significantly affected by future trends.

Stages of Assessment p 4 Environmental assessment should be integrated with economic assessment, including the opportunity costs and benefits of using funding for proposed major projects in other ways.

Changes in the level and structure of funding from that proposed in STPR could offer better outcomes for the economy and the environment

The SEA Act prescribes the following themes for consideration;

  • Biodiversity, Flora and Fauna;
  • Noise
  • Population;
  • Human Health;
  • Soils and Geology;
  • Water;
  • Air;
  • Climatic Factors;
  • Material Assets;
  • Cultural Heritage;
  • Landscape and Visual; and
  • Interactions and Overall Effect.

It does not, therefore, include any provision for combining economic and environmental assessment.

The STAG appraisal underlying STPR does include an economic theme and this is reflected in the appraisal.

The SEA, to be compliant with both the SEA Act and Scottish Guidelines, has taken the form of a assessment under the requirements of the Environmental Assessment Scotland Act 2005 and the SEA directive.

Assessment Methods p 9 & p10-13 Pages 10 to 13 deal only with broad findings of positive or adverse environmental impacts.

The weighting given to the different factors in environmental assessment is unclear and, since no information is given on economic assessments, it is not possible to evaluate the reasoning behind the 29 projects favoured in STPR.

The factors are considered equally and the economic benefits for the 29 interventions are not all available. Some are not clearly enough defined yet, for instance "Strategic Road Safety Plan" or "Reconfiguration of national rail timetable".

The recommendations arising from the STPR reflect those assessed as being best able to support the Government’s Purpose on the basis of the information and evidence available.

D14 Part 1 p12 Should this not read as A9 upgrade Dunblane to Blair Atholl?

Check and revise as necessary in addendum to ER. (see addendum comment 3.1)

E2 p12 Co-locate Bus and Rail Station in Dundee — query basis for view that this would have adverse environmental impact

The construction works associated with this process would have an adverse impact, while the operation of the co-located stations would have implications for bus routeing and no demonstrable environmental benefits.

E8 & D31 Query view that E8 (new railway Inverkeithing-Perth) would have positive regional environmental impacts while D31 (new railway Inverkeithing-Halbeath) would have neutral impact.

In view of higher cost of Perth line (and ability to use these funds in other ways), it is likely that Inverkeithing-Perth would be neutral and Inverkeithing-Halbeath positive.

This response potentially confuses economics and environmental impact.

Issues are kept separate in appraisal. The relative costs of two proposals do not directly relate to their respective environmental performances.

D25 p13 West of Scotland Strategic Rail Enhancement— query conclusion of an uncertain environmental impact.

Would expect strong environmental benefits (as well as economic gains), if decisions are taken to give priority to electrification of the Shields Rd- Bellgrove Glasgow Crossrail link and related early conversion of inner south side suburban lines to higher frequency light rail penetrating the city centre.

Scope of project is not fully defined and, given potential options, so only conclusion available for SEA is ‘uncertain’.

As project definition improves, so the uncertainty would reduce and a more definitive assessment would be made.

Why was the Forth replacement Crossing omitted from the ER?

Given the engineering evidence that the existing bridge can handle present levels of traffic for the foreseeable future and the commitment to encourage both peak car-sharing and shifts to rail, bus and ferry, early priority for a £2.3bn additional crossing would have large economic and environmental disbenefits.

It is expected that the present road bridge will be able to handle HGVs at least until 2020 but, if this is not feasible, the disbenefits involved in HGV diversions would be low compared to the economic and environmental benefits of allocating £2.3bn for other purposes in the years to 2016. This suggests that any final decision on an additional Forth crossing should be delayed until 2014.

Such a delay would also permit evaluation of the integration of any future crossing in a tidal barrage (also able to generate electricity) cutting flood risks from rising sea levels on the Forth west from Rosyth.

The Forth Replacement Crossing was subject to Strategic Environmental Assessment in 2007. Its inclusion in the recommendations of the STPR reflects the work completed to date and the commitments made in respect of the proposal.

The Scottish Government is committed to progressing the Forth Replacement Crossing.

A barrage was dismissed during the Forth Replacement Crossing study, primarily in its adverse impact on designated environmental sites around the Forth.

National Transport Strategy (NTS)

This is referred to on p17 but there should be an indication that the NTS retained the aim of stabilising road vehicle kilometres over the years to 2021.

Substantial progress on this aim is evident in recent traffic data, showing stable or falling car use despite a rise in car ownership (principally in the number of households with 2 or more cars).

The STPR is based on the outcomes of the National Transport Strategy, and focused on strategic transport interventions, not the full spectrum of measures that might be used to address travel patterns. The STPR recommendations address issues which currently exist, or are forecast to exist.

The STPR reflects underlying land use assumptions and travel arising from them and is consistent with the approach used in other studies.

Cumulative Effects Assessment (p17-19)

Environmental Impacts in Inverness, Perth, Aberdeen, Edinburgh, Fife, Dundee & Glasgow

The Association suggests that there should be a direct indication of the expected scale of modal shift from cars (the greater the shift, the greater are environmental and economic benefits) with added mention of the benefits of the NPF objectives of encouraging shorter trips, better interchange planning and higher densities promoting greater use of public transport and of walking and cycling.

However, there is a puzzling reference to greater use of public transport encouraging walking and cycling. This is true as people have to walk to and from public transport but it is less evident that plans for integrating cycling with public transport are well developed.

The statement needs to be altered to reflect the importance of greater use of both walking and cycling for the full length of shorter trips made in urban areas — a topic neglected in STPR as it is a local authority and RTP issue.

It is correct that walking and cycling have limited comment within STPR as they are more properly addressed through the NTS support for non-motorised travel and local intervention schemes. At a strategic level, the STPR recognises the importance of integrating modes and, in particular where it will provide a step change in public transport provision, doing this in a way that allows more localised cycle and pedestrian access to be maximised.

In terms of modal shift, we approached this from an emissions perspective, consistent with the key strategic outcomes of the NTS. Section 2 of the summary report provides an overview of this. Modal shift is one aspect along with addressing congestion hotspots, more efficient use of the network and land-use/transport integration.

Transform Scotland

Environmental Assessment of Interventions

It is notable that of the interventions which are assessed as having an adverse effect, the only ones which are being pursued through STPR are the A96 upgrade between Inverness and Nairn and (more particularly) the A9 upgrade to dual-carriageway as far as Inverness, of which all phases are judged to be "Moderate to Major, short and long term, Local and Regional, Adverse".

The document considers alternatives which focus on improvements to public transport, modal shift from road to rail and use of speed cameras, but only the improvements to the Highland Mainline between Perth and Inverness is pursued.

The A9 upgrade is only seen as being acceptable in conjunction with the parallel rail upgrade: "any increase in CO2e through decreased journey time would be offset through a modal shift to rail as result of rail service enhancements". This scheme is pushed through despite its adverse environmental effects and once again, the SEA demonstrates that it has no teeth.

The alternative options described did not meet the objectives defined for the corridor. They were rejected as a result. This is discussed in Chapter 4 of this Post adoption Statement.

The highland mainline proposals are one of the 4 immediate priorities in STPR and as such are expected to be delivered before the recommended upgrade of the A9 itself.

Any development of the A9 will involve significant environmental assessment and any consequent changes in traffic volumes are more closely linked to changes in land use at either end of the route than the capacity offered by the route itself.

South East Scotland Transport partnership (SEStran)

It should be noted that Cross Forth Ferry Facilities project was identified as needing an Appropriate Assessment as it potentially impacts upon Natura 2000 (habitat) sites, although it was not rejected on that basis. An Appropriate Assessment has been carried out on this project. It does not affect the SSSI since all associated infrastructure is within an active harbour.

It is noted that an appropriate assessment has been completed.

The Cross Forth Ferry proposals have been sifted into Appendix C of the STPR.

There are projects in the SEStran area that were dismissed on mainly environmental grounds which should be questioned.

The following were rejected after assessment in the STPR;

Railfreight connections to Rosyth

The SEA states that this project ".. has minor to moderate adverse effects and over the long term potentially substantial adverse effects".

This is difficult to understand as any improved rail connection would substantially use existing track bed and remove a significant number of HGVs from the roads reducing environmental and noise pollution, how the above statement could be justified.

This intervention was dismissed on a number of grounds including its potential impact on designated sites around the Forth estuary.

The provision of a rail link from Halbeath to Inverkeithing offers a more effective link to Rosyth Port from the south, helping to support future development there.

It also reduces journey times between Edinburgh and Perth, and Inverness, Aberdeen and the central belt, and provides the ability to run more direct services to Edinburgh in conjunction with a strategic Park-&-Ride facility at Halbeath.

It would also enable the segregation of local and intercity services and provide more efficient freight access to the port of Rosyth.

New LRT line to South East Edinburgh

Although accepting that there are environmental benefits to tram extensions, it states that "..it was not though that there would be any substantial environmental issues resulting from project rejection."

This area of Edinburgh will become increasingly more congested as development progresses. Therefore a project that addresses this issue and access to the Royal Infirmary in an environmentally friendly manner should be welcomed.

This intervention was dismissed for a number of reasons, primarily its lack of any significant national benefits.

The assumptions outlined are of a local and regional nature and the benefits assigned to addressing them cannot be made within SEA.

New Rail connections in Fife

This project lumped several rail proposals together and it was accepted that there were modest environmental benefits in implementing these projects but they were dismissed on mainly implementability grounds.

The Levenmouth project, as developed by SEStran and its partners, will use existing track and therefore should not have been rejected on that basis.

The Levenmouth rail project was not included in STPR because it has local/ regional impacts.

In developing the next High Level Output Specification (HLOS) and future franchises Transport Scotland will give consideration to other rail interventions that would contribute to the objectives for this Government.

Improved Road Links to Edinburgh Airport

This project was recognised as having only minor adverse effects on the environment.

Although this project was not rejected on this basis there appears to be inconsistency in the approach to assessment.

The proposed link is relatively confined in its geographical impact and sits in an area already trafficked by several routes.

Its environmental effects should be seen in this context.

It was rejected as public transport options better met the objectives.

3.5 Conclusions

The tables set out in this Chapter summarise the consultation responses received for the SEA and offer responses. Further consultation responses are presented in Annex 1, under a similar format. This annex focuses on those comments received on the underlying recommendations of the STPR.

The comments presented above highlight a number of common themes and, where appropriate, a commitment is being carried forward into the further refinement of STPR interventions. This will be delivered at various stages of the development process. The addendum to the Environmental Report, and Mitigation and monitoring strategies set out in Chapters 5 and 6 of this Post Adoption Statement set out these commitments in more detail.