Draft Infrastructure Investment Plan – 2021-22 to 2025-26

The indicative dashboard is a well-designed tool which could ensure future infrastructure investment decisions can be made under the guidance of meeting the indicators included. While there are many indicators, this reflects the wide definition and remit of infrastructure in Scotland.

However, it is not currently clear how the indicators will be used to appraise infrastructure projects or what weight will be given to each indicator or overall IIP theme. There may be practical issues in using the dashboard due to the number of indicators included. It would be helpful for the dashboard to sit alongside an appraisal methodology that identifies how the assessment of infrastructure projects is calculated and weighted against the indicators. For example, how many of the indicators will projects need to contribute to positively for it to be considered good enough to be progressed into the IIP pipeline? Given the importance of reducing emissions and related indicators in the Environmental Sustainability theme it is important that this theme is given considerable weight to ensure long term investment decisions contribute to the net-zero emissions targets. This is a similar approach the Council has suggested through the process in reviewing the STAG methodology. It is therefore welcomed that, like the STAG review, the IIP is also considering how best to measure the implications of investment decisions on carbon and overall emissions.

Sustainable Places and Inclusive Growth – The factors and overall assessments included within the Scottish Index of Multiple Deprivation may be very helpful in assessing how successful, resilient and sustainable places are. It may be particularly useful for looking at reducing inequalities for places which have historically recorded poor levels in the individual factors and overall SIMD.

Sustainable Places and Environmental Sustainability – Greenhouse gas emissions are included within the Environmental Sustainability theme, however, it is also important to consider the local implications of infrastructure investment decisions on local air quality. Improving local air quality has many benefits including improved health, improved environment and – due to the disproportionate effect of poor air quality on the very young, the elderly and those with existing health conditions – help to reduce inequalities. The Council would therefore recommend this section of the final IIP is closely linked to Cleaner Air for Scotland 2, which is also currently out for consultation in draft format.

Resilient and Sustainable Places – it is important to assess how new infrastructure can contribute to resilience to the effects of climate change. Intervention 8 in the Climate Ready Clyde Adaptation Strategy currently out to consultation addresses this issue, focusing on the need for new infrastructure to be located and designed in such a way that risk of future climate impacts is minimised - https://online.flippingbook.com/view/139900/18/

An outcome which will benefit both of these themes is also access to active travel infrastructure. This should be an important outcome and will hopefully be a key consideration in STPR2 and the final IIP. Improved access to active travel infrastructure has many benefits for local people and place including; reducing emissions by replacing short journeys by car with walking and cycling trips; improving physical health by encouraging more people to be active in their daily lives while also delivering benefits for overall wellbeing; and reducing inequalities by providing enhanced access to local services, facilities and jobs – promoting social inclusion.

There are similarities with the process underway to refresh the STAG methodology – with transport being a key component of infrastructure and therefore similar priorities and criteria being linked between the two pieces of work - it would be beneficial if the two processes and methodology were closely aligned.

With the climate emergency and the net-zero emissions target by 2045 being agreed in legislation, it is now more important than ever that the implications for emissions are robustly considered when making infrastructure investment decisions. The current taxonomy method does not provide this robust analysis as it is too blunt a tool to provide specific enough data and evidence to improve decision making. While it is noted in Annex C that the other three method options will all require individual assessments to be made for each potential intervention, this is now an urgent requirement in the project appraisal and planning process. Improved methodology providing more accurate results in the early stages of project and infrastructure planning can result in better decision making and the correct infrastructure being maintained or prioritised in order to contribute to achieving the net-zero target rather than contribute to its failure.

The Council agree there is benefits to further exploring the Baseline and Intervention and Gap Analysis approaches. The IIP mentions that a combination of approaches could be the most beneficial in terms of delivering improved results for calculating emissions – which seems a reasonable approach to take. With that in mind, it may also be beneficial to understand if elements of the Absolute Emissions method could be used in this combination. It appears that this could provide the most accurate calculation of emissions for individual infrastructure assets out of the three methods, which could provide benefits for improved decision making as noted above. It is also noted that this may be the most resource intensive method – however it would be worth exploring further if this method could be combined in the overall appraisal process. For example, it may be worth including an assessment of Absolute Emissions as a final calculation method for a shorter list of potential infrastructure decisions once the less resource intensive methods have been used to appraise a long list of options prior to sifting and refinement. The results of the combined methods could then help to look at cumulative effects, addressing the other concern regarding the Absolute Emissions method.

As noted earlier in the Council response – aligning this approach with the STAG review as much as possible will help both approaches by learning from each other, reducing duplication of work and helping user and public understanding by having common approaches and methodology.

The environmental baseline set out in the Environmental Report is robust and covers all relevant issues. The Evolution of the Baseline – Pressures, Trends and Key Points is particularly useful in seeing how environmental baseline data will change as environmental pressures are more prevalent. Whilst the SEPA Flood Maps are referenced, the flood maps now include climate change outputs which will be relevant to the Plan and assessments going forward.

The environmental effects of the IIP assess and identify the key effects of the themes and opportunities including clearly highlighting the significant effects. Identifying opportunities for enhancement and mitigation for each theme assessed and assumptions/links to other SEA are also a welcome addition to the assessments.

Including proposals for mitigating, enhancing and monitoring environmental effects as part of the assessments is welcome. Whilst the inclusion of this offers opportunities to further enhance positive effects and maximise the benefits of the Plan, it would also be good to see opportunities to mitigate against the negatives impacts identified in the assessments.