Appendix 2 - Consultation Feedback

Public Consultation Feedback relevant to the Scope of the SEA (Feb – May 2024)

The analysis report presents an analysis of responses to a public consultation, along with a number of engagement events held by Transport Scotland officials, on the ICP: SAP and VPP. This includes responses to question 14 “what environmental issues do you believe should be captured in the SEA in relation to this plan”, which are summarised in Table 2-1 together with a note on how this has been considered in the draft assessment framework:

Table 2-1 - Public consultation feedback relevant to the scope of the SEA (Feb – May 2024) and how this has been considered in the assessment framework

Comments relevant to the scope of the SEA

Consideration in the Assessment Framework

SEA should capture Scope 3 emissions to allow planning for their reduction

This is considered in SEA topic Air Quality.

SEA should include reference to the importance of reducing carbon emissions and moving to renewable energy sources, including in relation to travel by sea, aviation and construction activities associated with fixed links

This is considered in SEA topics Air Quality and Material Assets.

SEA should consider impacts associated with the whole life of a ferry, including emissions during construction, operation and decommissioning

This is touched on in SEA topic Materials Assets but the whole lifecycle of ferries is beyond the scope of the ICP.

SEA should consider impacts associated with port operations, e.g. in relation to additional recharging / refuelling infrastructure

This is considered across various SEA topics including soils, air quality, and material assets.

SEA should consider vulnerability of port infrastructure to the impacts of climate change

This is considered in SEA topic Material Assets.

SEA should consider impacts on air quality, including with respect to ferry emissions, aviation exhaust and road traffic

This is considered in SEA topic Air Quality.

SEA should consider impacts on water quality in both marine/coastal and freshwater environments

This is considered in SEA topic Water Quality.

SEA should consider impacts of nuisance noise from ferry engines and other port equipment, as well as from aviation activities and from road traffic

Noted, an additional SEA topic has been added to the draft assessment framework.

SEA should consider impacts to marine biodiversity

This is considered in SEA topic Biodiversity

SEA should consider impacts associated with the generation and disposal of waste and debris associated with ferry operations, aviation activities, and construction projects

This is considered in SEA topic Material Assets

SEA should consider impacts on land use patterns and on natural landscapes

This is considered in SEA topic Landscape

SEA should consider impacts on cultural heritage and the historic environment

This is considered in SEA topic Cultural Heritage

SEA should consider potential cumulative impacts, including associated with current and future ferry operations in a given area, and the broader cumulative effects of multiple projects and activities on the environment

Cumulative impacts are assessed as part of the framework, considered as a combination of the SAP / VPP interventions on given SEA topics.

Please note that potential effects associated with site-specific interventions / projects / activities are outside the scope of an SEA, and these should be considered at project level.

SEA should consider impacts of increased connectivity on tourism

This is considered in SEA topic Population and Health.

SEA should consider the needs of disabled people, to avoid inadvertently disadvantaging disabled people who rely on private car travel.

Equality and accessibility are beyond the scope of the SEA and are considered separately in the Equality Impact Assessment of the ICP.

Statutory Consultation Feedback on Draft Assessment Framework (Dec 2024)

Below we have outlined consultation feedback received on the draft assessment framework shared with statutory consultees in December 2024. It should be noted that no feedback was received from Historic Environment Scotland (HES).

Transport Scotland (Outside ICP team) - 11 Dec 2024

Air Quality

Consultation Feedback

Not sure on how the guide questions relate to adaptation

Response

SEA objective has been reworded, reference to climate change adaptation / resilience have been included under SEA topic 8 (material assets).

Water Environment (fresh and marine)

Consultation Feedback

What about the opposite, e.g. Could the proposal affect the condition of the water environment (water quality, physical condition, water resources/ fish?

Response

The guide question would prompt a “yes” or “no” response, so potential effects on water quality would also be capture in the assessment. Wording of guide questions has been revised throughout for consistency.

Biodiversity

Consultation Feedback

Could the plan affect designated sites? International, locally important etc.

Response

Specific reference to designated sites has been added to the first guide question.

Population and Human Health

Consultation Feedback
  • What about consideration of active travel? To existing or proposed.
  • Will it affect links to any paths, cycle or coastal.
  • What about tourism?
Response
  • Specific reference to active travel has been added to the third guide question.
  • Specific reference to tourism has been added to the second and fifth guide questions.

NatureScot – 17 Dec 2024

Soil/sediment

Consultation Feedback

Welcome the inclusion of soils into the assessment process. This should also consider the effects on marine soils where appropriate. 

Response

Although reference to sediment was already included in the framework, this has been specified to be marine sediment for clarity.

Landscape

Consultation Feedback

Not sure what is meant by ‘Does the Plan… seek to protect, enhance visual effects?’ can I suggest the bullets are amended as follows.

  • Seek to protect, enhance or restore landscape character, local distinctiveness and scenic value.
  • Seek to enhance, promote or maintain people’s enjoyment and understanding of the landscape.
  • Seek to protect, enhance or restore and sustainably manage special qualities of designated sites.
Response

A typo is noted, should have read visual “amenity” and not “effects”. Suggestions have been incorporated in the guide questions.

General

Consultation Feedback
  • Appreciate that the marine environment should automatically be considered within the assessment questions, but particularly given reference to the public feedback, I wonder if there would be merit in specific reference to this, for example, ‘Does the Plan……protect, enhance and sustainably manage marine resources and protect coastal features?’
  • The use of the matrix methodology is appropriate but it would be helpful if, within the table, there is a column for providing a narrative to expand on the scoring where necessary. For example, this could also include whether the scoring is the finding of the assessment following any mitigation applied or whether this scoring is pre-mitigation (and what that mitigation might be).
  • There is some inconsistency in the Assessment Guide Questions. Some are worded as outcome focussed while others are worded as impact focussed.
  • Other useful references might include:

For biodiversity –

For landscape -

For Soils –

  • Policy 5 in NPF4 affords specific protection to peatland, carbon rich soils and priority peatland habitat – link as above.
Response
  • The marine environment is covered under all relevant SEA topics, incl. marine soils, marine water environment, marine biodiversity, marine landscapes, marine cultural heritage, etc. The term “marine” has been specified in some guide questions for clarity.
  • A proforma has been used to include commentary as to the reasoning for identified effects, this is presented in Appendix 4. It has also been clarified that the assessment is pre-mitigation. Mitigation measures are then specified in the Findings of the Assessment section.
  • Wording of guide questions has been revised throughout for consistency.
  • References considered relevant for the purposes of the SEA have been consulted.

SEPA – 17 Dec 2024

General

Consultation Feedback
  • It would be useful if the matrix included a commentary column to explain the rationale behind the assessment results.
  • It is also useful to show the link between potential effects and proposed mitigation/enhancement measures.
  • Satisfied that the assessment questions cover the main issues under our remit.
Response
  • A proforma has been used to include commentary as to the reasoning for identified effects, this is presented in Appendix 4.
  • Section Assessment Finings specifies the relationship between potential effects and proposed mitigation/enhancement measures.

Soil/Climatic Factors

Consultation Feedback

We also welcome the inclusion of soil in the assessment and are content for climatic factors to be integrated in other relevant SEA topics

Response

Noted.