Summary of Key Issues
This section provides a summary of the key issues and comments raised by respondents to the SEA Screening and Scoping Report. A summary of the views received via responses to the policy consultation, where these were of an environmental nature, has also been included.
12. In relation to the Scottish Government's plans to reduce the APD replacement tax by 50% by the end of the current session of the Scottish Parliament, and abolish it when resources allow, common views raised by respondents included concerns about increased greenhouse gas ( GHG) emissions through a rise in aviation activity, and the impact on Scottish Government commitments and ambitions with regard to climate change targets. Other common issues included the potential impacts of a modal transport shift arising and its more localised environmental impacts e.g. potential changes to noise levels. Existing mitigation measures and the need to consider the wider context of aviation activity, for example, globally or the ability of current capacity to deliver increased flights, was also raised.
13. These views, either raised within responses submitted to both consultations, or to those submitted to the SEA Screening and Scoping Report only, have been summarised below.
- The majority of the 161 respondents to both consultations raised some form of environmental concern or objection to the Scottish Government's plans to reduce an APD replacement tax by 50% by the end of the current session of the Scottish Parliament and to abolish it entirely when resources allow.
- Climate change was the main reason given by the majority of respondents who did not support the policy proposals.
- In addition, a few respondents felt that the policy proposals were inconsistent with wider Scottish Government policies, such as support for active travel and policies related to transitioning to a low carbon economy. This was mirrored by respondents who felt that air connectivity should not be considered in isolation but alongside wider objectives, such as those related to tackling climate change and improving public health and the quality of life.
- Many of the respondents felt that the APD replacement tax should reflect the environmental or social impacts of aviation or be increased to reduce growth in the aviation sector, thus reducing the associated environmental impacts. Some argued that aviation should be actively discouraged or restricted due to the associated environmental effects.
- A few respondents, however, expressed a view that the introduction of a replacement tax was not an appropriate or cost effective measure when considered in a purely environmental context. The role of existing mitigation measures, such as the EU Emissions Trading System ( ETS), and past and current work undertaken to improve efficiencies was also noted. It was considered important that the SEA process notes this wider context when considering the impacts of the policy proposals.
- Views on the effectiveness of existing mitigation differed. Some respondents felt that existing mechanisms are not sufficient, when considered in isolation, to address climate change emissions from the industry.
- Potential modal transport shifts brought about by a reduction or abolition of APD, and the environmental implications of this, was another common issue raised. Many respondents were of the view that this had not been considered effectively within the consultation. Requests were made that this issue be given greater consideration, including within the SEA work, to ensure that the implications of GHG emissions arising from any modal shift are considered effectively.
- Local level environmental implications that arise from aviation activity were noted by a few respondents. Examples included increased noise and traffic around airports, both of which have health implications. It was felt that these issues would increase if an APD replacement tax was reduced or abolished, compounding existing impacts on communities.
- The proposal that the SEA will consider the environmental implications of the policy proposals at both national and local level was supported. However, it was noted that national priorities should not take precedence over those which had local significance.
- There were mixed views on the section of the SEA Screening and Scoping Report which set out the proposed evidence base for the assessment process. Views ranged from it being reasonably comprehensive to overly complex. Additional sources of information and amendments or corrections were provided on a range of issues.
- The majority of respondents agreed or broadly agreed with the key assumptions and questions and initial findings of the early assessment work set out in the SEA Screening and Scoping Report. Those who broadly agreed with the initial findings reiterated a view that the assessment needed to consider more current and future environmental measures, policies, improvements and mitigation.
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