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Scottish Region Policy Group response on The Scottish Executive Consultation on Scotland's National Transport Strategy Strategic Environmental Assessment - Environmental Report

The responses below are those of members of The Chartered Institute of Logistics and Transport(UK) Scottish Policy Group who have contributed to the discussion on The Scottish Executive Consultation on Scotland's National Transport Strategy Strategic Environmental Assessment - Environmental Report.

The Institute is the professional body for the full range of people who are engaged in logistics and transport. This includes freight and passenger transport operators, government and local government employees, consultants and academics.

We welcome the decision to apply the Strategic Environmental Assessment process to the National Transport Strategy consultation paper despite this not being a legal requirement. We have replied separately to the NTS Consultation Paper referring to the fact that the breadth of content inevitably means the narrative therein is somewhat simplistic. The SEA process compensates for this on environmental matters.

The detailed content of the report is excellent and this is assisted by the tabular presentations, including the appendices. Our observations relate in the main to the non-technical summary.

The criteria included within the assessment are wide ranging and sensible and it is noted that noise and visual amenity were also scoped. These latter aspects are often considered most important by the general public even though adverse impacts are generally of less real environmental significance than the other criteria used. This dichotomy reflects the fact that public perceptions of adverse effect are often contrary to real long lasting impact.

The key points arising from the assessment of the NTS Consultation Paper are presented subjectively with no attempt to identify the relative impact of different environmental effects. This approach reduces the extent of potential criticism and is useful in terms of general assessment but has limited value when considering specific initiatives, or public perceptions and addressing the action needed, with justifiable costs to ameliorate adverse factors.

We suggest that consideration is given to re-examination of the STAG project appraisal with a view to incorporating amendments to reflect the above points.

With regard to the summary of key points arising from the assessment of the NTS Consultation Paper, we have a number of points :

Biodiversity - points accepted although the potential negative impact is perhaps overstated.
Population - even with the most optimistic assumptions it is difficult to envisage a 'critical' mass of pedestrians and cyclists being reached to achieve the effect indicated.
Human Health - agree.
Soil - it is agreed impacts are largely site specific and therefore difficult to reach broad conclusions.
Water - the positive effect of increasing waterborne traffic in reducing road traffic and associated adverse effects should be highlighted.
Air Quality - agree.
Climate factors - in addition to biofuels there should be reference to potential benefits of increased electric traction.
Material assets - similar comment as for 'Soil'.
Cultural heritage - the need for good transport to facilitate access to the heritage deserves mention.
Landscape, Noise, Visual Amenity - agree, but the general lower level impact than other criteria should be highlighted as referred to above.

It is hoped these comments are helpful. We look forward to the SEA post-adoption statement when it is published in conjunction with the final NTS later in 2006.

 

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