Royal Commission on Environmental Pollution

Thank you for consulting SNH on the above study, and for allowing us to stray a little beyond the consultation deadline. We welcome the study as likely to shed light onto areas which are central to issues of environmental quality and sustainable development.

'Environmental planning' is a broad topic. Alongside the procedures for land use planning, public policy for the environment is implemented through a multiplicity of regulatory frameworks, strategies, designations and incentive regimes. Some of these are overtly environmental: others have social or economic objectives but have effects upon the environment. We welcome the attempt to seek an overview of planning to meet environmental objectives, difficult though this may be.

I attach, as an annex, responses to your questions. Each could be addressed at much greater length, but we have tried to highlight those areas where we feel SNH's experience is most likely to be valuable.

If we can help by further expanding upon points raised here, either through further correspondence or through verbal evidence, we would be very pleased to do so.

a.       Has the pursuit of sustainable development as the broad objective of policy had favourable or unfavourable consequences for protection of the environment? To the extent that consequences have been unfavourable, how could that best be remedied?
We see the effects of the sustainable development approach so far as having been subtle and strategic, rather than as having already brought about great environmental change. It has been successful in raising the profile of environmental issues in areas of policy where they have not traditionally been to the fore; and it has encouraged policy-makers across social, economic and environmental fields to move towards a common agenda. We see that strategic influence as of great significance, offering the potential for enormous environmental changes in the future.

By the same token, however, the greater the weight accorded to sustainable development as an objective of public policy, the greater will be the temptation to re-interpret the concept to suit the interests of particular sectors. In the past economic interests have attempted to subvert it in this way; in the current political climate there are signs that those pursuing a social agenda may be trying to do so. And of course both these groups would (sometimes with some justice) accuse protagonists of the environment of taking a similarly blinkered view.

To guard against this danger it is vital to cling to and re-emphasise the key principle that sustainable development is about integrating social, economic and environmental objectives and recognising that they have equal legitimacy. Moreover, there has to be an understanding of mankind's fundamental dependence on a soundly functioning ecosystem, so that due weight is accorded to long-term stewardship of the environment in cases where there is a perceived conflict between environmental and other objectives. Without this, there will always be a high risk that long-term interests (social and economic as well as environmental) will be sacrificed for short-term economic gain. This underlines the importance of the principle of inter-generational equity, as well as matters of intra-generational equity which tend to figure strongly in the thinking of those who approach the sustainable development agenda predominantly from a social angle.

b       Can environmental objectives always be balanced against other issues or are there environmental imperatives? If so, how are they (or how should they be) determined?
Sustainable development should not attach a precedence to social, environmental, or economic perspectives; rather it seeks integration between these objectives, combining peoples' needs with those of environmental protection. However it is important to recognise mankind's fundamental dependence on the environment, as referred to above. Moreover, there should be due recognition of the irreplaceability of many environmental assets - be these species, which clearly cannot be re-created, or other less tangible aspects of environmental quality (for example wildness or local character) which once lost are never likely to be recaptured. Expressing even the first of these concerns as an "environmental imperative" may not be helpful presentationally but it is important to underline how seriously these must be taken if mankind's relationship with the rest of the universe is to be put on a sounder footing.

c      What regulatory approaches are likely to be the most effective and practicable to protect the environment, in both measurable terms, e.g. water, soil and air quality, and less tangible aspects, e.g. landscape and amenity?
For air, soil and water quality, existing regulatory approaches are broadly successful for tackling point-source pollution, or impacts of localised development. However these approaches do not adequately tackle issues such as diffuse pollution, resource consumption (including energy and transport), and waste. They also have difficulty in handling problems arising from cumulative impacts. Such issues are often more effectively addressed through economic instruments, awareness-raising, incentive schemes and cross-compliance requirements which should aim to integrate environmental considerations into all other frameworks for land and resource use. Fiscal signals have a particular role in influencing patterns of personal consumption.

For the natural heritage, we support a whole-countryside approach which recognises that these values are found to different degrees in all places, and which recognises that bundle of values within all land use and land management planning and regulatory frameworks. Within such an approach, there will continue to be a need for the identification and designation of special areas where natural heritage values are particularly high, and for frameworks of policy and practice which safeguard and enhance these special qualities.

d      In practice, to what extent does land use planning still embody a presumption in favour of development? Has the legislative change to a plan-led system given land use planning the potential to become a more effective instrument for achieving environmental sustainability? Is any further change necessary, and if so, what?
Land use planning is indeed theoretically a plan-led system. But for the plans to be effective in helping to deliver overall sustainable development ambitions:

• there needs to be stronger leadership in the direction of sustainable development;
• they need to be better supported by a public commitment to sustainability objectives;
• there needs to be more co-ordination between development plan policies and the plans and programmes of Government bodies which have the power to help to deliver (or indeed frustrate) these policies.

• encourage new development which uses natural resources wisely and is likely to maximise economic, social and environmental benefits;
• where there is uncertainty over impacts, encourage a precautionary approach to new development which, through the operation of conditions and agreements, allows for the operation or use of the facility created to be modified in response to emerging understanding of environmental impacts;
• develop the role of planning in integrated management initiatives (through statutory and non-statutory planning tools such as Indicative Forestry Strategies (IFS) or integrated catchment and coastal management (ICZM));
• develop the links between the Local Agenda 21 process and the planning system (to put the development plan in a broader and longer term context);
• increase the use of strategic appraisal tools such as Strategic Environmental Assessment (SEA), Environmental Appraisal of Development Plans (EADP), and Environmental Audit;
• ensure close links between the Community Planning initiative now established in Scotland and the planning system;
• encourage greater public participation in development planning.

There is an urgent need for a planned approach in relation to the development of renewable energy resources. Government so far has largely adopted a market-led approach in the interests of securing new renewable energy sources at least cost. Instead, we need a planned approach which encourages renewable energy developments of a type and in locations which have least environmental impact. There should also be a link to success in reducing energy consumption. Targets for the generation of a proportion of UK or Scottish electricity from renewable sources are currently advocated against a background of steadily rising overall energy consumption. Unless economic growth and energy consumption can be decoupled, the environmental costs of large-scale adoption of renewables (notably though accumulated landscape and visual impacts) could be increased without securing decrease in carbon dioxide emission from fossil fuel sources.

f      Do current arrangements for environmental planning sufficiently take into account the cumulative impacts of developments?
Incremental change in land use for agriculture and forestry has been the major cause of change in UK biodiversity, and has had other environmental consequences for water quality. In our view this reflects past frameworks of policy and management which have lacked effective long-term planning, and which have been insufficiently integrated with environmental policy objectives.

In this respect forestry has made great strides during the last ten years, although the issue remains that while there is local impact regulation and good practice guidance, it has not (until this year) been seen in national overview terms. The proposed Scottish Forestry Strategy now offers the prospect of a national framework which can help deliver multiple benefits.

As far as agriculture is concerned problems still remain in integrating food production and environmental stewardship objectives, although the commitment now being made towards enhanced agri-environment spending will help.

In development planning cumulative impact remains a difficult issue, both in terms of individual developments which grow by accretion and of separate developments which, taken together, can fundamentally alter (for example) the landscape character and quality of a particular area. It is important that decisions on individual development proposals are taken with a view to the longer term consequences and wider context. This underlines the importance of the development plan which can anticipate such pressures and lay down policies designed to counter them. There may also be a case for strengthening the hand of planning authorities in declaring classes of development on which planning decisions can be deferred to consider several developments at once; or of strengthening the provisions within EIA which require comparative assessment of different possible sites, or of requiring SEA for selected classes of development.

In more general terms, all change is incremental. A key role for strategic land use plans should be to identify where cumulative incremental changes might approach social or environmental limits. This highlights the importance of such plan-led approaches being informed by a vision of overall development objectives.

g      To what extent is effective environmental planning hindered by a lack of resources within central government and local government, statutory agencies and advisory bodies? Have the procedures become to complex for any institution to cope adequately?
We do not see lack of resources being a critical limiting factor in environmental planning. We would see the main hindrance being in a culture which has historically given priority to economic benefit over social or environmental well-being. Many institutions, including some local authorities and economic development players, still need to adjust to objectives which include social and environmental well-being alongside economic development. We see a need in Scotland for Government and its agencies to monitor progress in this direction, to issue guidance to push it forward and to publicise good practice.

h      What are the implications of long-term risks, such as those posed by climate change or persistent waste, for environmental planning? Can planning systems become drivers for limiting the extent of damage from unavoidable climate change?
As outlined above in our answer to para f, we see the need to address incremental change as one of the primary justifications for environmental planning. Plan-led systems informed by shared visions and objectives are a means of delivering socio-economic well-being in a way which is consistent with long-term environmental quality. 'Plan-led' shouldn't imply top-down, but such plans require to strike a balance between local and national interests which gives sufficient priority to national as well as local needs. Strong and agreed guidance and targets at a national level are needed to identify national priorities and regional responsibilities - for example in relation to renewables, flood risks, and sea level rise.

i      To what extent does the achievement of environmental sustainability depend on permitted uses being time limited?
Where new technology is deployed and there is a degree of uncertainty over likely environmental impacts, a precautionary approach requires the ability to adapt a development in the event that it proves more environmentally damaging than anticipated. Time-limiting is one of the simplest forms of adaptation and is easily accommodated within the land use planning system. More sophisticated forms of adaptation may be preferable but can raise complex issues which are not easily handled by the land use planning system.

2.      Boundaries

a      To what extent does a mismatch between administrative areas and environmental processes contribute to environmentally unsustainable planning, for instance in river catchments or along coastlines? What should be done about it?
There is a multiplicity of natural boundaries at different spatial scales which will never overlap with political and administrative boundaries. Ensuring that strategic planning frameworks are integrated with these natural processes is often complex but need not be a barrier to environmentally sustainable planning. Thus, for example, local authorities are well used to considering coastal protection issues within a framework of large scale coastal processes. Implementation of the EU Water Framework Directive will require an integrated view of water catchments.

Biozonal approaches, such as SNH's Natural Heritage Zones programme, aim to integrate different elements of the natural heritage, and bring together local and national aspirations for the natural heritage. The boundaries of these zones do not coincide with administrative boundaries, but they should providing a framework for considering the natural heritage in-the-round, rather than as a series of independent elements.

b      What problems arise from different plans being produced and implemented for overlapping geographical areas?
Different plans produced and implemented for overlapping geographical areas need to be integrated in relation to the areas of overlap (geography and policy). A failure of integration raises problems of distribution (eg where the area preferred for forestry in an Indicative Forestry Strategy is not where the market makes land available for planting and inadequate public incentives are available to overcome this problem), prioritisation (eg where land which is important for biodiversity has been zoned for housing in a Local Plan), and accountability (who decides a proper mix of social, economic and environmental benefits where there is conflict of interest?).

One timely example of how these integrative difficulties may be resolved are Scotland's proposed new National Parks. These Parks are likely to be given statutory purposes relating not only to safeguarding the natural and cultural heritage and providing for its enjoyment and understanding, but also promoting sustainable use of its natural resources, and promoting the socio-economic well-being of its local communities. The Parks should create a new planning tier, representing a balance of local and national interests, which brings together existing regulatory frameworks for both land-use and development planning through the Park Plan.

Community Plans in Scotland also aim to integrate council and agencies' strategies and funding programmes for individual local authority areas. These plans are at an early stage of development but present a key opportunity for integration at a local level. This is in line with the McIntosh Commission's proposals for a power of general competence for local authorities including powers to oblige local public bodies to work in partnership with councils in developing a Community Plan. This local horizontal integration will have implications for policies and programmes within individual agencies.

c      Should the land use planning system be responsible for helping to deliver policy targets in other areas such as transport, energy, water provision, flood protection, climate change and nature conservation?
Yes. Several features of the planning system make it a key instrument for delivering policy targets in other areas, including:

• it constitutes the main instrument for regulating in the public interest those types of change statutorily defined as development;
• it makes an explicit effort through the development plan process to look some 10-20 years ahead;
• it has through the development plan process the capacity to co-ordinate different land-uses, thereby reconciling potential policy conflicts before they reach the project stage;
• it is a sophisticated, workable and largely well-understood system which operates across a wide range of defined activities;
• it is a system which operates at all scales from the national to the local; and
• it currently provides the main single opportunity for the public to get involved in decision-making about the future of their area.

e       Does the lack of control over certain activities, such as forestry and agriculture, prejudice the achievement of environmental goals? If so, what would be the effect of introducing such controls?
It is not true to say that agriculture and forestry lack controls. Both of these activities are very highly controlled - for example through CAP incentives, animal welfare, health and safety, pollution regulations, and WGS controls. However the objectives for both these sectors have historically been seen in terms of producing food and timber, and not in terms of multiple benefits including biodiversity, landscape character, and amenity.

During the last decade, forestry has made great strides towards a multiple-benefit approach, soon to be supported by a national Forestry Strategy and revised Indicative Forestry Strategies at regional level. Recognition of environmental goals as an essential component of forests has had a huge impact on forestry design. Agriculture has still some way to go, though the recent publication by the Scottish Executive of a discussion document on 'A Forward Strategy for Scottish Agriculture' could herald a step in this direction.

3.      Integration or co-ordination?

a      Does the current system need "fixing"? What gaps, unnecessary duplication and conflicts exist in present arrangements for environmental planning?
As far as ensuring effective integration of regulatory frameworks is concerned, we would commend three approaches all of which are being developed to some extent:

• increasing the scope of the land use planning system
• creating a new tier of integrated plan
• strategic environmental assessment

SNH has always been cautious about extending the scope of the current land use planning system to embrace land management activities because of the dangers of overloading responsibilities on a system which is already stretched, and which has limited land management expertise to draw on. We do not see the land use planning system as the best way to regulate the on-going management of land and water. There is however scope for extending planning control to a relatively small number of associated developments which have a significant impact on rural areas: the buildings, mineral extraction, roads and tracks associated with agricultural and forestry operations; river works affecting the structure of the river; and built developments below the low water mark. We also consider that land use planning should be extended to include a wider range of telecommunications development.

There may also be a case for extending planning control to extensive afforestation schemes; although this issue needs to be considered further in the context of the Scottish Parliament's general approach to the promotion and regulation of forestry. This is a land-use change with very long lasting effects; and any future consideration of how forestry is best promoted, guided and regulated should not automatically dismiss the option of bringing it within the planning system. However, at present we do not see a similar case for the widening the scope of the planning system more generally to agriculture, as any advantages that might accrue in terms of public accountability and environmental protection would be significantly outweighed by the increased complexity of the planning system it would require, as well as the additional bureaucratic and financial costs placed on the industry and the planning authorities themselves. The further 'greening' of the agricultural support system through the Rural Development Regulation and the effective implementation of the environmental assessment regulations may offer better means to secure the necessary safeguards.

Many of the mechanisms for the planning and encouragement of forestry already exist and are relatively well-tried and tested, although their ability to deliver in practice is yet to be proven. Indicative Forestry Strategies have yet to guide forestry to sites which optimise the full range of benefits and which by virtue of that fact should be relatively uncontroversial and the development of Forest Framework Plans to guide afforestation and achieve a satisfactory balance of land cover and uses in areas which already contain a high level of forest cover is still in its infancy. There is a need to target the Woodland Grant scheme in Scotland in order to maximise the public benefits that forestry delivers, as well as to ensure a complementarity between the public incentives for forestry and agriculture to help to deliver an agreed local vision. Until now, the mechanisms for guiding the geographical location of new afforestation at the regional and local scales have lacked a clear steer at the national level about which areas should be targeted for forestry expansion in the future, and of what type. This gap is now being filled by the Scottish Forestry Strategy.

However, while the overall land use planning framework may be sound, its capacity to work effectively has been hindered by:

• A lack of clear direction in national legislation or national policy guidance on the role of the planning system in achieving more sustainable development.
• Changes to planning policy and the structures of government have over time, and not always consistently, tended to weaken the strategic planning function as well as the power of planners to facilitate positive change. As a result, the planning process has become more reactive, ad hoc and incremental, better geared to accommodating change rather than to shaping it.
• Planning has become an ever more adversarial, legalistic and technical process in which the simplistic 'environment verses development' argument has effectively become enshrined.
• Planning has not fully recognised its potential for involving the public: it accommodates to some extent but does not go out of its way to stimulate their active participation.

It has been recognised that the land use planning system needs to be well integrated with the plans and programmes of Government agencies, and the other regulatory frameworks provided by pollution control, buildings standards and environmental assessment.

Community Planning in Scotland has established a new process for local authorities and partners to jointly plan, provide for and promote the well-being of the communities they serve. SNH supports the development of Community Planning which offers the potential to develop overarching policies and strategies for sustainable development and social inclusion in a more co-ordinated and consistent manner than previously and with the close involvement of local communities.

In future the proposed National Park Plans should also perform this function for areas designated as national parks.

Strategic Environmental Assessment

The Scottish Executive is committed to introducing strategic environmental assessment for government programmes. Given our experience in this area through EADP and EC structural fund programmes, we see the value of developing different SEA methodologies for different tasks, rather than develop one single definition or methodology for SEA. To ensure natural heritage interests are given proper consideration alongside social, economic and other environmental factors, we would like SNH to be given a formal role in SEA in Scotland which would mirror our statutory role in respect to Environmental Assessment. As we have argued in responses to the various consultations on the European Spatial development Framework, in addition to the national, regional and local policy level, SEA could also be usefully applied to EC policies.

b      Is there in practice a hierarchy in the formulation of different types of environmental plans? Would there be advantages in establishing a clearer hierarchy?
Some activities are planned for at the national, regional and local scales. In forestry for example there will shortly be a national Scottish Forestry Strategy, there are regional Indicative Forestry Strategies, and some areas have Local Forestry Frameworks. For development planning, the NPPG series forms the equivalent national framework and there is the regional Structure Plan, and the Local Plan. However, for biodiversity there is a national plan and local plans but no regional tier. Agriculture can barely be said to have a plan at all, although there is now as indicated above a move to develop a national strategy, which will we hope recognise the need for differentiated approaches across Scotland. In general terms the structure of national, regional and local plans would seem to be a sensible one, with the proviso that all of these elements may not be necessary everywhere.

However, we would tend to see these as complementary and interdependent nested plans, rather than as a hierarchy.

As outlined in our answer to 3(a) above, we can imagine Community Plans - embodying the work of Local Agenda 21 - becoming important as a new overarching framework. Their capacity to set a vision for an area which enables the integration of development planning with broader local aspirations for land-use and socio-economic objectives will effectively place the Community Plan above other plans.

c      Should the process of environmental planning be further integrated or rationalised, e.g. as in New Zealand? Or would better co-ordination be sufficient to ensure an efficient and effective system?
It will be clear from the foregoing that we are strongly in favour of the need for the environment to be integrated with all other policy sectors and support mechanisms. We do see a need for complementarity and consistency in the planning of and public support for different land using activities (eg. forestry and agriculture) across Scotland and indeed at the regional and local scales. Some form of indicative land use planning (going well beyond the current development planning system) is therefore attractive in principle although we would see it as providing a context for, rather than replacing, some of the existing planning systems. However, we are insufficiently familiar with the situation in New Zealand to offer a view on the detail of the question.

d      Are present arrangements for environmental planning efficient and cost-effective? Can the wish to speed up the land use planning processes be reconciled with effective environmental protection?
The development planning system works to tight timescales in a majority of cases. Where it is slow, it is often because it is trying to arbitrate over important and sometimes contentious issues with implications for the long term. We are content that this is appropriate: time taken in the short term to get the right decision is efficient in the longer term.

e      Are the mandates and procedures of the pollution control bodies appropriate to their environmental planning responsibilities? Are these responsibilities appropriate? Is it practical to have parallel decisions on land use planning and pollution control?
We offer no view.

f      Has a satisfactory integration of transport planning and land use planning been achieved? If not, what more needs to be done?
No, but it is better now than it was five years ago, with transport objectives included within national planning guidance. We still need:

• a clearer political commitment to integration;
• more resources to achieve it;
• development of techniques for multimodal studies of the future transport needs of areas;
• wider public (and elected member) awareness of the contribution made by transport to greenhouse gas emissions, and the lack of effective control over increases;

Some types of environmental impact have not been adequately taken account of in development control decisions because the significance of the impact lies in cumulative effects rather than individual impacts. The incremental loss of biodiversity or amenity, or of water storage in the soils of a catchment, or of carbon stored, often goes unnoticed. There is therefore a need to explore techniques such as the environmental capital approach which address this kind of environmental service. The quality of planning decisions could be improved by ensuring that a more comprehensive range of environmental issues is considered.

h      One possible economic instrument could be a "betterment tax" aiming to increase public ownership of development gain. Is such a tax feasible and desirable? Might there be some way of linking the rate of tax to environmental impact?
No comments offered.

i      Does the adoption of sustainability as the focus of policy intensify disagreements about the boundary between public and private development rights and obligations? To what extent does the current system enable such issues to be resolved?
Yes. By highlighting the wider social and environmental implications of activities which may be undertaken primarily for private economic objectives, the adoption of sustainable development as the focus of policy raises new questions about the appropriate balance between public and private interest.

4.      Subsidiarity and democracy

a      Is the current balance between elected leadership, expert assessment and public participation in environmental planning decisions appropriate?
We offer no comments on this, in the light of the range and variety of frameworks covered by the heading of 'environmental planning', although we see all three elements as essential to a successfully functioning system.

b      How do we ensure that all levels of decision-making processes are sufficiently open, transparent and accountable to gain public acceptance? What are the best ways to reflect the range of public opinion whilst maintaining an appropriate procedural timetable? When should local public opinion be overridden in the interest of a broader common goal?
We offer no view on the first two questions.

On the third, the key is national planning guidance or designations which reflected national democratic support. In the current debate about National Parks in Scotland, the Park bodies will need representation from national interests, as well as local. In a plan-led system, plans will reflect national planning guidance. Ultimately, as national policy is likely to succeed in the face of sustained and widespread local opposition something has to give, be it the policy itself or an acceptance that a transfer of resources will be needed to make the policy acceptable locally. As well as such "compensation", however, there is a need to explain the justification for the policy and to outline the other benefits that it is likely to bring locally. This requires pro-active "selling" of the policy and a willingness to engage in debate at local level.

c      What should be the relationship between international, national, regional and local goals? Should environmental planning take place at the lowest level consistent with the common good (the principle of subsidiary)? How far do current arrangement depart from that principle?
Strategies and goals need to be integrated and nested with others at different scales. Environmental planning needs to take place at all levels, in each case to influence only those decisions which are most effectively taken at that level. We thus support the principle of subsidiarity, which we would see implying a greater requirement for local involvement in many decisions. However local decision-making can only be sound if well informed by national and regional perspectives; hence the importance of these wider strategies and guidance.

d      Are new regional planning arrangements, or other measures such as strengthening the strategic planning role of local government, needed to ensure greater coherence between national and local planning regimes? If so, what should these be and how should they be made accountable?
See our answer to 3(a)

e      To what extent do the principles of the environmental planning regimes in England, Scotland, Wales and Northern Ireland need to differ from each other? What are the specific drivers for these differences?
We do not believe that the principles need to differ. However, the translation of these principles into practice should reflect local "cultural" traditions and should be designed to ensure that the outcomes properly reflect local circumstances as well as underlying environmental objectives.

f      Does the present form of planning inquiry offer the best way of resolving disputes? Should it be extended to permit a third party right of appeal? If so, should such rights be restricted to prevent abuse?
In general, we would like to see a move away from adversarial procedures towards those more geared to building consensus, although we recognise that some form of conflict resolution mechanism will always be needed where agreement proves impossible to achieve. A third party right of appeal might be justified where a development had been permitted that was apparently continuing to development plan policy. As in the courts, this could be the subject of an independent assessment as to whether a "prima facia" case had been established.

g      Would environmental tribunals or courts enhance public confidence in the land use planning appeals process? If so, would they impose significant extra costs and delays?
We would have serious reservations about any procedures which made environmental planning more legalistic. On the contrary we would, as stated above, like to see a move towards a more consensus-building approach.

5.      Assessment approaches

a      What are the most appropriate appraisal methodologies for use in drawing up environmental plans and assessing the environmental impact of plans prepared for other purposes? Do appraisal methodologies applied to individual cases provide sufficient information about their implications for wider environmental goals?
Assessment methodologies are tools to improve the quality of decision making by taking into account environmental and sustainability considerations (i.e. they inform decisions, they do not make decisions). Assessment or appraisal should also improve the quality of the 'product' being appraised (be it a policy, programme, plan or project). There is a need for a range of methodologies, each suited to a different purpose and for these different scales of application.

We see there being a significant omission at present for strategic-level assessment of environmental effects, either by themselves or alongside economic and social effects. This kind of assessment/appraisal needs to be incorporated into policies, spending plans, subsidy regimes, and development plans at all levels of government, local authorities, agencies, as well as the larger private organisations. It is difficult for individual project level appraisals (where the bulk of assessment is currently undertaken) to address meaningfully the contribution made to wider environmental goals. There is still some work necessary to explore and broaden understanding of different SEA techniques, but the implementation of the forthcoming EC Directive should raise the profile of SEA as a technique over the next few years.

b.      Could increased use of such methodologies dovetail effectively with efficient operation of environmental planning systems? How widely applicable should environmental appraisal be? What level of detail is appropriate for the various plan types? Who should be responsible for i) undertaking environmental appraisal, and ii) judging its quality?
A common criticism made of many appraisals is that they are being applied at the wrong level, after higher level decisions have been taken without a similar assessment of environmental factors. So a form of appraisal should be required of the environmental impact of all significant actions. Higher level plans should stick to broad indicators of sustainability and whether these are being furthered or hindered. Lower levels of plan should indicate whether they are helping to achieve or detracting from the sustainability aims identified in the plans above them, but majoring on the more site specific impacts that can be identified at this level.

We believe the proponent of the action (policy, programme, plan, project) should undertake the appraisal, since the appraisal should feedback and inform the action taken. Questions about the impartiality of such a situation are inevitable. There may be scope to provide for independent auditing of the standards of such appraisals, building on existing BS or ISO standards such as those for Environmental Management.

c      What would be the value of increased use of other assessment tools e.g. sustainability appraisal, environmental capital, environmental footprint, environmental space, and health impact assessment?
Many activities have consequences for the environment which are not accounted for in the decision-making process. The relatively new tools listed here reflect attempts to make visible these (hidden) environmental implications. Once made explicit, this information may raise the quality of decisions made. An overly complex system of appraisal should be avoided, but new tools need to be tested to see whether they do indeed have a place. In general, there is a lack of effective tools which look beyond a 'single' environmental focus towards integration of social, economic and environmental priorities.

• environmental capital draws attention to environmental 'services' such as natural regulation of water supply, or the development of soils, for example. Interruption of these services has led to flooding in developed catchments, and soil loss.
• environmental footprints make explicit the environmental implications (usually at a distance) of consumer purchasing decisions and lifestyle choices;
• sustainability appraisal could draw out the social, economic and environmental implications of policies and plans.

e      How adequate is the knowledge base, including the location and availability of expertise, provision of training for practitioners, and the accessibility and quality data? How far are any of these elements in the knowledge base constrained by the lack of resources or suitable institutions, and, if appropriate, how could that be remedied?
Extensive habitats, such as forest and woodland, peatlands and sand dune systems, as well as landscape character, have become better documented in recent years. Nevertheless, many gaps remain in the state of knowledge about Scotland's natural heritage, and environmental impact assessments often depend on acquiring new local data. Overview information is also limited, though the 'National Countryside Monitoring Scheme' offers data on land cover change from c1947, c1973 and c1988, and the Countryside Survey 2000 will soon provide more up-to-date information on aspects of land cover, plant species, soils and fresh water.

Linkages between human activities and environmental consequences are often poorly underpinned by data. Examples of this include an inadequate knowledge of urban greenspace, about the peri-urban environment, and development pressures in the countryside. For these, data have generally not been assembled in consistent or accessible forms. Statistical data on farm production tends to be collected and utilised in isolation from studies concerned with determining environmental benefits and impacts of farming.

Improved mechanisms are required for matching information collection, analysis and interpretation to information needs for policy formulation, evaluation and advice. Environmental and sustainability 'indicators' development calls for relevant and robust time-series data. Data integration commonly requires a consistent approach to the management and utilisation of spatial data. Increasingly, web portals or gateways, such as the National Biodiversity Network gateway, are becoming essential elements of data access and dissemination.

Aimed at addressing such concerns, SNH is improving the ways in which it manages and provides information. In working with others, SNH is providing input into a Scottish Executive sponsored project which seeks to define 'an improved rural data infrastructure for Scotland'. The May 2000 consultation report from the 'Digital Scotland Task Force' indicates the need for more effective and more integrated ways of managing and supplying public sector information. The development of 'National Statistics' may provide one means for better harmonisation of data. Notwithstanding inevitable resource constraints, opportunities exist for doing things better. In general, more collaborative priority setting and more open attitudes to information provision should be fostered and encouraged.

SNH has long been concerned at the paucity of relevant environmental expertise in some key decision-making bodies, especially local authorities. We would like to see many more staff with ecological and landscape expertise employed in these bodies. This should help significantly to improve the quality of decision-making and to increase "ownership" of environmental objectives; it would also reduce the pressure on SNH to make good the shortage of such skills through its own advice. Unfortunately recent times have seen, if anything, a reduction in the number of local authority staff with relevant skills: this is entirely contrary to the key role that they should be playing in promoting the sustainable development agenda.

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