The team from ASH Design + Assessment reflects on why EIA will be so important in the Scottish government's efforts to reach net zero
On 28 April of this year, Scottish First Minister Nicola Sturgeon declared a climate emergency at an SNP party conference. This was followed the next day by the Welsh government's similar announcement, and the UK government made an official declaration on 1 May 2019, becoming the first country in the world to do so. Since then, a number of others, including Canada, France and Austria, have followed suit. These declarations follow numerous campaigns and protests to raise awareness of the effects of climate change and the need to take action, as well as the warning issued by the Intergovernmental Panel on Climate Change (IPCC) 2018 Special Report.
Climate change statement
On 26 August 2019, the Climate Emergency Response Group of civic and business leaders published its Climate Emergency Statement. This contains a 12-point action plan setting out recommendations and actions for immediate implementation over a 12-month period, designed to help Scotland achieve its net zero goals. The plan relates to the key industries with the greatest potential to reduce greenhouse gas emissions, including agriculture, transport and construction.
The statement does not make any specific mention of environmental impact assessment (EIA); its focus is on actions and goals rather than processes, setting out milestone actions for the Scottish government to carry out and dates by which these milestones should have been achieved. For instance, Action 1 places an onus on the Scottish public sector to redirect its annual £11bn procurement spending towards zero-emission building and vehicles and purchase only electricity generated from renewable sources, with a target of fully zero-emissions fleets by 2030.
These actions, while ambitious, do not relax the need for appropriate EIA for developments going forward. Indeed, the need for robust EIA is likely to become more significant – particularly in relation to the housing and energy sectors, as the statement pushes for greater uptake of zero-carbon buildings and homes and deployment of renewable electricity generation of all scales and technologies.
Industry implications
Building standards for both domestic and non-domestic properties are currently under review in Scotland. This review is principally in relation to fire safety, prompted by the Grenfell Tower disaster of June 2017; however, the statement recommends that building standards should also ensure that on-site renewable generation takes place at all appropriate locations. As the EIA process is a key tool in determining whether a development is 'appropriate', this may prompt greater communication between the construction and environmental sectors, and result in a more integrated approach between developers and environmental consultants.
Scottish planning policy includes a principal policy of 'presumption in favour of development that contributes to sustainable development', and this often forms the needs case for large-scale renewable energy developments when seeking consent. From previous experience, smaller scale renewable developments such as single wind turbines or biomass heating units often rely more heavily on site-specific justification due to their smaller contribution to climate change targets. It would be beneficial, from a development standpoint, for the recommendation that all developments have appropriate on-site renewable generation to be a material consideration within the planning system. This could give property owners the confidence to pursue renewable energy development, and lead to a faster and more widespread deployment of such technologies.
Naturally, all on-site generation would need to be appropriate in EIA terms (where it is deemed to be 'EIA development'), and there will be a greater need for competent experts to facilitate this. Such a need would be prompted by a number of the recommendations put forward within the statement and, based on many of the statements made within the Scottish government's 2019 Programme for Government, published on 3 September 2019, and the forthcoming Climate Change (Emissions Reductions Targets) (Scotland) Bill, the environmental sector is likely to see greater growth than anticipated during the coming years. This in itself would assist Scotland's goal to become a globally recognised leader within the environment industry.
The Climate Emergency Statement is set against a backdrop of stark warnings about the worsening state of our climate and the need for action, but delivers a set of achievable targets with myriad benefits. The environmental industry will play a key role in delivery of these targets, engaging with several other industry sectors, and both the level and method of adoption of the statement's recommendations by the Scottish government will shape this engagement and determine its success.
ASH Design + Assessment provides professional landscape design and environmental assessment services.
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