Official Report 225KB pdf
Good morning. I welcome members, members of the public who are with us this morning and representatives of the press. I remind everyone to turn off their mobile phones. We have received apologies from Alex Johnstone.
What features should the strategic environmental assessment gateway have if the bill is to be successful?
The gateway could have a range of roles, but the bill would require to be amended to allow for some of them. At the moment, the gateway is largely administrative. As you will have seen from my submission, I believe that that administrative role is crucial. The gateway is an efficient way of dealing with the link between the responsible authorities and the consultation authorities and I understand that it is working well. I commend the Executive for putting it in place. There is no equivalent in England, where the system does not work nearly as efficiently. The administrative role is important.
Who should undertake the formal analysis of the process?
We have had 15 years or so of environmental impact assessments for projects and nobody is carrying out enforcement, so the first question is whether that is essential for SEA or whether the system is self-policing, as it is for the EIA projects. There is an important role for the gateway—or another body—to play not in carrying out an official audit of every environmental report that comes through, but in monitoring and disseminating good practice in the decisions taken by responsible authorities and consultation authorities. That is the role that the gateway can play. The idea of auditing and enforcing is completely different and we have not had it for projects with EIA.
I agree with most of what David Tyldesley has said. It is great that the gateway exists, but its role could be improved and widened. There should be a transparent register, which could be set up easily on a web page and which could set out the plans that were coming through screening and scoping and the answers that were being given.
So you mean that self-policing is harder with SEA than with EIA.
Exactly. For project EIA, consultants undertake the EIA reports and they compete for tenders, so the quality issue is important. How will that apply when, most of the time, responsible authorities alone will undertake SEA? Someone must perform that important role.
I support what my colleagues said. The gateway could fulfil several roles, which include the supportive role—the advice and guidance role, the simple administrative role of co-ordination and the role of monitoring and auditing. Does the auditing role sit easily in the same body—the same place—as the supportive role? Problems with relationships could arise.
The discussion on the gateway has led us to talk about monitoring and auditing. Will the bill provide a tool for better decision making? If so, should the decision rather than the tool be monitored and audited?
The bill should deal with both. The tool must work well, but you are right: we want better decision making. That is what is special about SEA. It provides a way in which to make policies, plans and programmes better. It should be closely integrated with the decision-making process. SEA will affect processes that are being undertaken by—I hope—making them better. We want to ensure that we get things right. Many times, we predict that, if a mitigation measure is taken, human health will improve, for example. We want to monitor that and to say whether the mitigation measure is doing what it is supposed to do. Two years down the line, we might find that it is not working and that people still have poor health, so we will have to ask what we can do.
Problems may also arise with determining what constitutes better decisions, given that the environmental component is just one aspect of the decision making by bodies for which political accountability is often meant to provide the way of making better decisions. Issues arise with what is monitored and how that is done. It can be argued that monitoring at the environmental assessment stage is more objective—it will never be completely objective—and provides quality control, as it is easier to apply without going into complicated political decisions and trade-offs between environmental and other benefits.
I presume that we want monitoring at two levels. Individual monitoring of decisions should be undertaken by the authority that produced a plan, which should have a robust monitoring mechanism. Then there is your point about whether the bill will make a difference and how the SEA gateway or the Executive will monitor its impact throughout Scotland. We are almost trying to do two things—we are trying to get an overview of what SEA has achieved, but we also want to ensure that there is an incentive for the authorities that carry out the SEA to check their own process. That cannot all be done centrally. Presumably there has to be a mix.
Experience tells us that the legislation will need to be reviewed and perhaps amended in future, just as all environmental legislation has had to be amended over long periods. The bill is a great step forward, but it is not the be-all and end-all. I am sure that it is not the final word on SEA in Scotland.
I would like to tease out the relationship between SEA and existing attempts to place sustainable development at the core of Government policy. Professor Reid, how do you see the bill more fully integrating environmental considerations in the decision-making process?
The bill is a big improvement, because it will ensure that the environmental component is properly considered. The difficulty that I foresee is that the final weighing up of the various elements of sustainability will inevitably involve different considerations that have been developed by different processes. That may lead to the same problem arising as there is in the planning system, in which the reporter's conclusions can be overturned by Scottish ministers.
It is an interesting point that, thanks to SEA, we may need to raise the quality of economic and social evaluations. On the link between SEA and sustainability appraisal, the English approach integrates the two systems. My instinct tells me that that might not be such a good idea, because the environment might lose out. I like the idea that Scotland is pursuing at present, which is to keep SEA as a separate process and to make the process more transparent.
The question is absolutely critical in the context of the bill. If you are going to go down the route of sustainability appraisal, you will have to do it now and not at some point down the line. In my view, the wider sustainability appraisals tend to tell responsible authorities what they already know. They are already promoting the plans for social and economic reasons—that is often their role—and they understand those factors well. Experience shows that it is perhaps the environmental implications of the plans and programmes that are less well understood. That is where SEA plays an absolutely vital role in sustainable development. Although the social and economic aspects are obviously important, they are better understood and the plans often promote them in the first place.
You are saying that SEA is a catalyst to make the whole range of environmental regulation work in an integrated way.
Yes, it is a part of that.
That is an interesting point, which brings us back to the purpose or the benefits of the bill as a whole—why we need it and what it will do in practice. It will effectively ensure a much more rigorous, coherent environmental assessment and a tiered approach, but with the SEA report and the consultation it will push up the bar on decision making more generally.
As a practitioner in the field for many years, I have my views on that question. I believe, as I said in my written submission, that the cost estimate in the papers that I have read underestimates the resources that will be required to service what the bill will provide for. There is no doubt in my mind that the bill will cost responsible authorities more than is being anticipated. However, I still say that that is worth while as an environmental insurance policy for the future and that the costs are justified. The costs are not unjustified, but they will be higher than anticipated.
That is very interesting. I accept that there will be a resource issue; the question is how large it will be. While David Tyldesley has more experience than I have on the issue, my instinct is that local authorities sometimes get in a bit of a panic and feel that the problem is much bigger than it actually is. One of the problems for local authorities is that they think that they will need a lot of data. The reality is that one can carry out SEA without data. Data must not be a stumbling block to undertaking SEA.
As the introduction of project-based EIA showed, there were transitional problems in those areas that had not had a structured plan-making process. We must encourage organisations to consider which of the documents they produce are plans, programmes or strategies and then think back to how they produced them or at what stage they would put in the appropriate assessment or consultation period. In areas such as planning, it was easy to slot in the EIA, because procedures already existed. However, for other areas, such as forestry, slotting in the EIA was a huge problem and we were many years late—we had several false starts—in coming up with a process that fitted the European Community requirements.
I should point out that not all local authorities think alike. An interesting case study is provided by the SEA that was carried out by Falkirk Council in, I think, July 2004. When I asked the council whether resources had been an issue, I was told that no extra resources were required for carrying out the SEA. It was simply part of best practice and the council did not view SEA as an extra burden.
However, the bill will clearly mean a change from business as usual. It will require people to do things differently and to think about them differently. The accounting process will also require people to be transparent about what they do. We can perhaps ask the Convention of Scottish Local Authorities about the transitional process for going from where we are now to where the bill will require us to be. The regulations have been in place for a year, but the bill will up things substantially. How we manage that process is a subject that we will come to.
The tension between environmental and socioeconomic matters is an issue that has been raised not only by local authorities. The business community believes that the bill tips the balance too far in favour of the environment and is anxious about the bill going beyond the directive's requirements. What is the value of going further than is required by the directive and further than the rest of the United Kingdom has gone? What are the implications of that? Will we be faced with two sets of regulations, one of which will cover the whole of the UK and the other of which will cover only Scotland?
I have heard, and I understand, the argument that the bill will tip the balance too far in favour of the environment. However, we can look at the experience of what happened in the first 10 to 15 years of project environmental impact assessments—which are a slightly different process—between the mid-1980s and the point at which the range of projects that were required to be assessed was increased by the amendment to the directive. The research that we carried out in the early 1990s showed that almost a third of all environmental statements that were submitted to planning authorities were unnecessary in terms of the law. In other words, various sectors of industry saw the EIA process as beneficial to their projects: it was seen as beneficial to the decision maker because it helped to show that a project was environmentally benign or acceptable. Therefore, I do not hold to the idea that the bill will tip the balance. There is no evidence to show that the weight given to socioeconomic aspects by decision makers has diminished in any way because of environmental assessment of any kind.
I agree with David Tyldesley, in that I disagree with the idea that the bill will tip the balance, for the simple reason that the SEA process does not make decisions but simply informs them. Ultimately, decisions will still be made by the decision maker; SEA just puts the facts on the table. As Colin Reid suggested, perhaps we need the quality of our economic and social assessments to match up to that of environmental assessments.
I would add only that many of the plans and programmes that have been covered will ultimately lead on to individual projects. If the plan and programme are dealt with, that should make the later stages a lot easier—you will not have to consider some of the more radical alternatives because the framework will be set up already. That means that you will be able to be much more focused at a later stage and that there will be savings later on. When a number of assessments have been done, there should be some cross-fertilisation, some data and some arguments that can be used to tie things together and to ease the process, rather than ignoring the process and then hitting the buffers when you come across something that is caught by a project EIA. If authorities and the people who are making proposals to authorities are thinking along those lines, that should help you towards a more integrated approach that will ease decision making later on when proposals come up against other controls.
What are your views on pre-screening? Pre-screening is intended to take everything out that need not be included and to cut down on bureaucracy, but I think that David Tyldesley was suggesting the need for a register. It seems to me that that might pre-empt a lot of work on freedom of information requests to local authorities that were pursuing information—they would see that the information was benign, if you like, if they had a register. Could you expand on why you thought that a register was a good idea?
Quite simply, I have indicated that I cannot think of a better pre-screening system than the one that is proposed in the bill. Therefore, I am not suggesting that there should be a different pre-screening procedure. However, what I am saying is that, when the bill is passed, all over Scotland there will be responsible authorities taking possibly dozens and dozens of decisions—hundreds over the years—screening out strategies, plans and programmes that they honestly believe will not have an environmental effect. I am suggesting that we will never have a record of those decisions. Nobody will ever know what is being screened out, because the responsible authorities will just make a decision and that will be the end of the matter.
Do the other witnesses agree?
Yes. It is crucial to have a register. Indeed, such a transparent system will save resources, because it is all about learning from one another and finding out what people are doing.
Do members have any other comments? I think that we have already covered quite a lot.
I want to ask about exemptions to the bill, which defines responsible authorities as
There are additional problems with the MOD because of the question of devolved and reserved matters and the extent to which any cross-border policy can be classed as reserved. What the MOD does clearly has an environmental impact. Indeed, the relationship involving national security, the MOD, the Crown and environmental protection has been a long-running element in a wide range of environmental issues. The general trend has been towards including those matters more and more as part of the planning system, but essentially it all comes down to a political decision about where the boundary lies.
I agree that financial plans and budgets are crucial in determining what comes next. If there is no SEA at that level and if how things should be is imposed, when people get to the next stage, they will be constrained and their hands will be tied as far as considering alternatives is concerned—they cannot think about them because they have to take a certain approach. As soon as the alternatives that can be considered as a means of achieving objectives are determined at a higher level, people will be constrained in their innovation. They should be thinking of innovative ways of achieving the objectives of the plan, while at the same time minimising environmental impacts and maximising improvements in human health and so on. That is what an SEA should do. It is not a good idea when the alternatives are constrained because the decisions have been made earlier. It seems obvious that an SEA should be done of budgets and financial plans.
How can the role of the MOD be captured?
The same point applies. Why should the MOD be excluded? The activities that it undertakes will obviously have environmental implications, and perhaps those should also be considered. The matter of defence is excluded from the SEA directive; I reckon that that is why defence has also been excluded from the bill. When the countries involved sat round the table, they could not come to an agreement, so it was easier just to decide to exclude certain areas. All the different countries that came up with the SEA directive agreed to exclude those matters, but in terms of the principle the area should be included.
I agree with what both Colin Reid and Elsa João have said.
Perhaps my thinking on the finance and budget issue is a bit simplistic but my view is that by doing strategic assessment the assessment is being done at a level at which the strategy will inform the budget. The budget is not a separate entity; surely it is tied to a policy or strategy. We do not say, "This is the budget" and then make the policy. Surely the sensible approach is to assess the policy or strategy, rather than try to make a strategic assessment of the budget. I cannot get my head round how you would assess the budget in that way.
The process is multi-layered. If you decided, for example, that Scottish Natural Heritage's budget next year would be £1 million, your financial decision would clearly affect all the organisation's plans, projects and strategies. However, if you said, "We won't give any money to schools next year because we are giving all the money to SNH so that it can make the environment perfect," your financial decision would have a huge impact on the organisation's strategies. However, as you said, in reality the two areas feed off each other all the time. Throughout the process there is an issue, particularly for areas in which there are no formal decision-making processes and where plans and strategies have emerged from a mixture of evolving elements, with different elements coming and going. Now that there must be a more formal process in some areas, there is a degree of thinking to be done about how we integrate the formal elements with those that are less structured.
I do not see any member who is desperate to ask a question, so I thank the witnesses not just for being prepared to answer many questions, not all of which might have been anticipated, but for the extremely useful written evidence that you supplied before the meeting, which helped us to think about the issues that we would follow up with you today. Thank you for taking the time to come and make your contribution. You are welcome to stay on in the public seats to hear what the next witnesses say.
Meeting suspended.
On resuming—
I thank our second panel of witnesses for coming and for their written submissions, which were extremely useful to us as we thought about the issues and what we might want to ask. I welcome Councillor Alison Hay, who is the Convention of Scottish Local Authorities' spokesperson on the environment, sustainability and community safety; John Rennilson, who is the director of planning and development at Highland Council; Kathy Cameron, who is the policy manager at COSLA; and Iain Sherriff, who is the head of transportation at Dundee City Council, but who is here to represent the Society of Chief Officers of Transportation in Scotland. We will not take opening statements, given that we have read your submissions. The witnesses bring a range of expertise and experience to the meeting and I invite members to kick off with questions.
I had better not ask the witnesses whether they are panicking, as a previous witness suggested.
The Executive has underestimated the number of SEAs that councils will have to undertake. Like the Highlands, Argyll and Bute is a devolved area and most of our policies and programmes will have to be scrutinised. The process of scrutinising all the documents and deciding whether to proceed to a full SEA will take time and will be resource intensive. I know that Argyll and Bute Council is undertaking an SEA for its local plan, which will take us quite some time and will cost us a considerable amount of money. Different councils have different views on the number of SEAs that they will have to undertake, but Highland Council has done some detailed work in that area.
It is my understanding that it has for many years been standard practice for some level of EIA to be done for structure plans and local plans. John Rennilson might want to comment on that. Is there, as I presume there is, such expertise in local authorities?
There is some expertise, especially in the planning service, but that is not necessarily true of all council departments and services. A whole range of plans, policies and strategies, including local housing strategies, renewable energy strategies and schools estate strategies will be caught by the bill. We believe that the Executive underestimates the number of SEAs that will have to be produced.
I want to add something about the capacity of local authorities to undertake such work. Local authorities vary in size. Some local authorities, such as Highland Council, have done the work in-house, which is fine; Highland Council has built up that knowledge in-house. Other councils that are pretty lean as far as staffing is concerned have found that they just do not have the staff to do the work in-house and have therefore had to use consultants. The ability of councils to build up expertise varies widely.
I wonder whether either of the other two witnesses want to respond to my question. You mentioned that there would be resource implications, but you were vague about what it takes to do such an assessment. Can you give us figures on the resource implications?
The resource implications would depend on what sort of SEA you are talking about. The costs will not just be confined to our planning department, but will be cross-departmental at strategic level across the council. Education, social work and the other big departments—transportation particularly—will all be involved. The problem that some councils experience is that it is difficult to convince departments—other than planning departments—that this will affect them. Once they have become convinced of that, we face a problem in getting staff to understand the process that they have to go through. Planners are fairly familiar with the processes, but other staff are not.
Will there have to be a culture change in local authorities before the change can be delivered? Will such a change be difficult to achieve?
That is what I am saying, to some extent. One of the previous speakers mentioned sustainability: councils are now particularly aware of the need to consider sustainability when they assess their plans and projects. We are aware that we have to consider the implications for the environment of our policies and plans and, for example, whether we will use up a resource that we should not use. However, for the rest of the council, there will have to be a culture change.
I would like to say something in relation to transportation. I emphasise that I speak on behalf of the Society of Chief Officers of Transportation in Scotland, not on behalf of Dundee City Council. I say that because my elected-member colleague cannot reach me to hit me if I say something that is contrary to our basic statements.
Maureen Macmillan asked about resources and about the need for a culture change. I would like to pursue those issues.
When we spoke to the minister nearly a year ago, we suggested that there should be pilot projects. At that point, we thought that it would be wise to examine the possible problems and benefits of the proposal in a structured way. We thought that if we ran a small number of pilots—we suggested two, but three councils have offered to run them—we could work with those councils in a way that would ensure that we could examine the process, the pre-screening and the gamut of activities that the bill asks us to do. Both sides would gain experience from the process and we could have rolled out the proposal across Scotland in a more measured and structured way. We felt that that would that be of benefit to us and to you.
Are you working with the local authorities that have submitted plans under SEA?
We are working with some. Orkney is one but I cannot remember the other two.
Orkney Islands Council, West Dunbartonshire Council and West Lothian Council have offered their assistance. In some cases that assistance is through their existing work on SEAs and in some cases it is through work that is about to start on specific strategies that the councils will promote.
How is that experience being rolled out to other local authorities?
It is not being rolled out to other authorities because the pilots have not started yet. We have had only one meeting with the Executive to discuss the matter and we are starting to move forward.
The committee should be aware of how stretched the planning service already is. Planning applications in Scotland are at a record high across the board. At the moment, we are working with the 2004 regulations on delivery in relation to planning transport. Recruitment is exceedingly difficult right across the planning service. With a planning bill coming before the Parliament shortly, there is significant difficulty in meeting our requirements to fulfil the 2004 regulations without spreading that expertise across colleague services such as housing, waste, the education estate, school-catchment planning and so on. This will be a new field for such staff to consider from an environmental, rather than social or financial, point of view.
What kind of practical assistance would you require?
There are not enough planners coming out of planning schools to fill the vacant posts. There is an argument for going step by step: let us have complete competence in delivering on the requirements of the 2004 regulations and direction, and let us roll that out stage by stage. The approach that is suggested by the bill seems to be a scattergun approach—everything will be covered and we will then look back and remove whatever is deemed to be unnecessary. That means that SEA is in danger of having to go ahead in an unsatisfactory way, and none of us wants that.
What would you take out of the bill to encourage a more transitional approach? Previous witnesses talked about an incremental approach that starts off at a base point; we would learn from experience. If there is too much in the bill as it stands, which sections would you delete?
It is not a question of there being too much in the bill; it is about our being able to work through what is in the bill with one or two authorities in order to find out what we need to exclude or to add. Once we have been through that process, we can see where we are and we can consider rolling the legislation out while taking the necessary action to address the problems that we come up against during the pilot period.
Can you clarify what you mean? Should we consider the experience of three authorities, say, but not implement the rest of the bill—
We should work through the bill with two or three authorities and tease out what might be problems for them, in conjunction with the consulting authorities.
Would you therefore put the bill on ice for one or two years?
We cannot put the bill on ice; we are where we are. That said, we have been making the point to the minister for the best part of a year and a half to two years that there needs to be some structure to the bill and that local authorities need to know where they are going. If the minister wants to get the best out of local authorities and the public sector, we will all have to work through the process bit by bit. We have to consider what local authorities need by way of training, resources and so forth.
I suppose that the follow-up question to that is this: if you have been working through this with the minister for a year and a half, why have you not been considering those matters?
What do you mean?
If you have, with the minister, been working through the content of the bill and where you think the bill should go, and given that you knew the bill was coming, why has work on training needs and gaps not been done by now?
We met the minister a year and a half ago, when we offered the pilots, but we have not got much further forward.
To be honest, if you offered the pilots to the Executive a year and a half ago and, as you said earlier, you are enthusiastic about SEAs, surely it is slightly contradictory that we do not have the pilots by now?
It is not contradictory; that is how long such things take.
If the Executive wanted to go for the pilots, surely it would have included them in the bill? Surely the Executive would have written into the bill that there would be a pilot for a year and that that would be followed by different implementation dates for the other authorities?
The pilots are written into the documents.
I am not saying that COSLA is not talking about the pilots. However, if the minister had been enthusiastic about them, surely the pilots would have been part of the process that he put in place?
The pilots are part of the process.
The pilots are referred to in the explanatory notes. Our difficulty was in engaging with staff in the Executive to initiate discussions on them.
Perhaps we can clarify with the Executive where it is with those discussions and whether the pilots form part of the minister's plans.
We have had the best part of a year's practical experience of the regulations. Has COSLA undertaken any monitoring of its members in respect of the impact of the regulations on different local authorities? Is not the basis of our new expertise the fact that local authorities have been undertaking the process for a year?
I might be speaking out of turn, but local authorities have been doing that for the past year only as far as the planning authorities are concerned. The bill is meant to have a great impact not only on the planning process but on other parts of council policies and strategies, but that has not been happening.
It is also fair to say that, in the absence of a response from the minister, other environmental legislation has appeared in the intervening period. I am thinking of natural heritage legislation and the access provisions of the Land Reform (Scotland) Act 2003, both of which have placed on local authorities new duties that relate to environmental issues. New duties are coming into effect on the preparation of core path network plans and so forth, and we have also had to keep our eye on this statutory ball. While this bill has been working its way through the system, we have had to move forward on other areas.
On education, most authorities have embarked on a fairly radical programme—at least, such is the case in the local authority area that I represent—of school building. Has environmental assessment taken place as part of that process? If so, could it not be assessed as part of this process or have people just said, "It doesn't really matter."
We have received no reports of any such exercise.
That does not mean that it has not happened; only that it has not been reported to COSLA.
We discussed with the previous panel how sustainable development as a concept from Government feeds into strategic environmental assessment processes. Highland Council is concerned that an opportunity has been missed because the bill fails to take socioeconomic factors into account in environmental reports. I presume that you would be more at ease if the Government had done more work on SEA policy before you were presented with work about which you complain that you do not have the staff to deal with. Will you expand on your idea that sustainable development, which is becoming a cornerstone of public sector policies and planning, is only a part of the process? If SEA is a catalyst for the process, should it be properly funded from the top and its impact on councils properly estimated?
There is an argument for the social element to be better specified. To put the matter in a planning context, the environmental considerations suggest that we should cut car travel and that we concentrate population and communities but, in a place such as Wester Ross, the counterargument to that is that we want to keep smaller communities alive. To do so, we need housing and we need to keep small schools, but that might involve greater travel. There is a conflict between the two objectives. If we were to take environmental considerations in isolation, we would concentrate as much of the population as possible in larger communities, which would be cost effective. There is a dichotomy in that situation, and we face that dichotomy in responses from the Scottish Executive: its planning division tells us one thing in "Scottish Planning Policy 15: Planning for Rural Development", but the response on individual planning applications and environmental impact assessments that accompany planning applications for roads is different and seeks concentration. That tension will not be resolved simply by introducing an SEA into the policy, because it needs to take account of the social dimension and overall sustainability.
Yesterday, I was at a meeting in London on future technologies in transportation. Like all transportation professionals, I get excited about the thought of new urban traffic-control systems. The discussion at that meeting kept coming back to the environment, carbon emissions and how to stop them. One speaker got an extremely hard time—which was a shame—because he used the phrase "a sustainable car journey" because the vehicle to which he was referring did something like 82 miles per gallon. Two or three years ago, nobody would have picked him up on that, but transportation professionals are now picking people up on such comments.
That, I presume, is what the bill is about.
SCOTS fully supports the bill. I agree with my colleagues from COSLA to an extent but, in transportation, we start from a different level because, by default, environmental considerations are embedded in the process, although not in the structured way in which they are in the bill. In some areas, SEA is embedded and understood; in other areas, there will be nervousness, because it is not only about transportation or land-use planning, but about education, housing and joining everything up. That is where the problems arise. One of the earlier speakers said that they hoped that such legislation would not be required in 10 years because SEA would be a natural process that people would go through. That was a profound comment.
You say that different documents suggest contradictory aims and approaches—John Rennilson spoke about SPP15 and the roads issue. Has COSLA raised such concerns in its discussions with the Executive?
Time and again.
What has the response been?
We keep hearing, "Yes, we understand."
This is a period of development for environmental legislation, so there could not be a definitive statement at the moment. We all live with that.
Yes.
However, you know of specific examples of the Government making things very difficult by being contradictory in what it is asking you to do.
Yes.
I would like to reinforce what John Rennilson said. The driving force behind the current review of planning legislation is to make the process faster, thus satisfying the public's need for applications to be dealt with quickly, notwithstanding any other considerations. However, there is a potential—I emphasise that it is only a potential—for the review to contradict the need to speed up the process. That has to be acknowledged.
I want to ask Iain Sherriff whether the Scottish transport appraisal guidance is somehow at odds with SEA. Is more guidance needed?
Not particularly. Assumed weightings tend to be used. I am from an engineering background and I always like two and two to make four. It should be as simple as that, but once we get into the abstract territory of using weightings, we have to consider different effects. For example, is it worth having an impact on the environment just to allow someone's journey time to their work or leisure to be two or three minutes less? A lot of value judgments have to be made.
So you believe that clear weightings should be established through the STAG process, so that if trade-offs are required, we can make the right decisions. Ideally, however, we should be looking for win-wins.
Win-wins are obviously utopia. That is what we all want. Articulating the guidelines would be a very difficult political process. An example would be the Edinburgh congestion charge. I am not calling Edinburgh people turkeys, but turkeys were not going to vote for Christmas, were they? The effects have to be quantified and articulated, but the decisions thereafter have to be political.
I want to ask about the SEA gateway, which is the process round which the bill hinges. How useful will the gateway be to you, in terms of guidance, training and the overall implementation of the bill's provisions?
I have agreed with some of what previous speakers have said. The gateway could give local authorities a lot of support. It is always helpful to have a single point of contact. The dissemination of good practice is vital, because we tend to live in little shells. We talk to one another quite a lot, but when it comes to the nitty-gritty of policies, it would be useful to exchange information and find out what others are doing because that might help us to improve what we do. The previous panel talked about quality and monitoring, and I think that that would be a good role for the gateway—that would be helpful to both councils and other public authorities that have to do SEA. The previous panel also mentioned auditing, but I have a slightly different view of the auditing process. All councils are subject to a best-value process, and I think that SEA should perhaps be subject to such a process too, but that is a matter for discussion.
To me, the issue that stood out from your submissions was the staff implications. Someone mentioned capacity building. Setting aside all the practicalities, will you comment on the desirability of doing the work in-house rather than putting it out to consultants? What is the value of embedding it rather than handing it over?
In an ideal world, we would want to do the work in-house. I agree that we want to build up in-house capacity. As Kathy Cameron said, it needs to become part of what we do without even thinking about it, and that will happen only if we can build up staff to do the work in-house. However—and it is a big however—councils vary in size, they cover different geographical areas and they have different staffing levels. To be slightly parochial for a moment, my council is pretty tight as far as staffing is concerned and we have had to go out to consultancies. That is useful in itself, because they are experts in their field and they can provide the support that our staff need. They can teach our staff and give them an insight into how our staff should be doing SEA. Ideally, we would like it to be done in-house, but sometimes that is not possible because of the nature of councils, so consultants have a role to play.
We try to keep SEA in-house wherever possible so that we develop our staff. For some time, we have had a sustainable development officers group, which is trying to drive forward the council's overall sustainability agenda.
That position is reflected in the views that we have had from individual authorities. In managing the resources that they have, they would prefer to operate SEA in-house, but given the lack of experience in departments other than planning and development, they may be forced to go outside. However, I hope, and they hope, that they will eventually achieve their own expertise so that they can manage the process in-house.
SCOTS agrees with that. You will recall that in my written evidence I gave an example of what Dundee City Council is doing to try to embed the process. Earlier, the committee heard about culture change, and it is only by engaging and developing our own staff and addressing their training needs that we can get that culture change so that it is instinctive for staff to think environmentally as well as financially, technically and professionally.
We talked about the cost of implementing SEA. I presume that in the long run money can be saved. For example, if you make the correct decisions to reduce congestion, that will save you money and improve health. What cost savings will you make from SEA? Do you believe that they could be substantial?
Analysis will be done of that, but it cannot be done until we have a clearer idea of what action has to be taken by authorities, and the jury is still out on that. Until we get that information, it will be difficult to identify the longer-term savings that can be made. I agree that, in principle, that should be possible. However—we have been making this point for some time—it is difficult from a standing start for those departments and services other than development and planning to have an idea of what actions they will have to take, what impact that will have on strategies and programmes and, as you have said, what the longer-term savings might be.
You will not know that until councils start to implement SEA. Each council is different, and it would be difficult for you to take one example of a pilot project and say that it applied to another council. You are not really going to know what the savings are until you bite the bullet and start implementing the bill at a local level.
I would not use the phrase "bite the bullet". As I keep repeating, we are happy to enter into this process and we have already started to do that. However, until we are further down the line and have a few years under our belts, we will be unable to measure definitively how much we are saving. We are signed up to the policy—there is no doubt about that. We just need to think out how we do it properly.
The term "savings" is being used in a financial sense, but everybody in the transportation profession knows that we cannot afford not to have full environmental assessments and costs taken into account when we are doing things. It is not a saving; we cannot afford not to be doing things.
That is a good point on which to finish. In the context of the committee's climate change inquiry, which we are pursuing with our other hats on, we know about the target to reduce carbon emissions by 60 per cent by 2050. At some point, that will have to start to be addressed, and I presume that the bill provides a framework for that. I thank you for giving your evidence this morning.
Meeting suspended.
On resuming—