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									                                                                                                         July 2010

          Assessing the carbon impact – what does it mean for SEPA?

The purpose of this paper is to provide an update on how SEPA is involved in carbon
assessment. In turn, this will support the ongoing work to establish SEPA’s remit in
regard to carbon impact assessment.

1.        Introduction
Carbon assessment is a fast evolving agenda. In October 2009, SEPA published a
measuring carbon think piece which was the first step in scoping out SEPA’s role and remit in
relation to measuring and assessing greenhouse gas emissions. Since then, there have been
a number of developments. This paper sets out the carbon assessment framework in
Scotland and explores SEPA’s role in measuring and assessing greenhouse gas emissions.

Key messages
 Carbon assessment is a fast evolving area and SEPA’s role is closely linked to
   measuring, monitoring and assessing carbon in a number of areas.

     Under the Carbon Accounting Scheme (Scotland) Regulations 2010, SEPA is named as
      the delegated authority to administer the net Scottish emissions account.

     The Public Bodies Duties relating to climate change will drive transparency and
      accountability in considering carbon in decision making. SEPA recognises its leadership
      role in demonstrating compliance with the duties and will strive to be an exemplar.

     SEPA is working with Scottish Government to clarify and formalise its role in relation to
      carbon assessment of developments on peatlands.

     SEPA is working with key agencies to produce a joint statement setting out roles in
      relation to climate change and planning

     SEPA is continuing to carry out work to development its use and understanding of carbon
      monitoring and assessment within its regulatory role.

2.        The carbon assessment legislative and strategic framework in Scotland

2.1       The Climate Change (Scotland) Act 2009
The Climate Change (Scotland) Act sets challenging and ambitious greenhouse gas emission
reduction targets (42% by 2020 and 80% by 2050 using 1990 baseline). In order to calculate
the annual emission reductions achieved in Scotland, a net Scottish Emissions Account has
been introduced in the Climate Change Scotland Act and set out in detail in the draft Carbon
Accounting Scheme (Scotland) Regulations 2010. There are also reporting requirements in
the Act on Scottish Ministers to show that policy decisions are helping Scotland to reduce
greenhouse gas emissions and move towards a low carbon economy.

Decisions on the ground will need to take account of the carbon impact to help achieve these
national targets. Where these quantifications are not necessarily used in the national account,
they are an important part of aiding decisions to help us reach the national targets. We need
to measure and assess carbon in order to understand the impact of decisions that are made.

  The use of the term carbon is often interpreted to mean carbon dioxide equivalent and includes all six greenhouse
gases. However, in some instances it is only accounting for carbon dioxide or actual carbon. It is important to
understand which gases have been included in the calculation of total emissions in the carbon assessment. Please
refer to the measuring carbon think piece for further information.

                                                                                                          July 2010

Ex-ante and ex-post evaluation
It is important to differentiate ex-ante from ex-post evaluations. Ex-ante evaluations involve
assessing emissions which will arise from a future development whereas ex-post evaluations
involve assessing emissions which have already occurred. Ex ante can be used to inform and
influence decisions whereas ex post, in principle, will measure actual emissions. This
highlights the importance of the aim of the carbon assessment. For example, is it to measure
and monitor emissions? Or is it to inform a low carbon decision?

2.2       Public Bodies Duties relating to climate change

Further to this, Part 4 of the Climate Change (Scotland) Act places duties on public bodies
relating to climate change. The duties on the face of the Act (section 44) require that a public
body must, in exercising its functions, act:
 in the way best calculated to contribute to delivery of the Act's emissions reduction
 in the way best calculated to deliver any statutory adaptation programme; and
 in a way that it considers most sustainable.
The duties come into force on the 1 January 2011 and apply to all 'public bodies '.
Carbon assessments and other appraisal methods will form an important part of complying
with the duties. The duties are likely to drive transparency and accountability. In particular,
“exercising the functions in a way best calculated to contribute to the delivery of the emission
reduction targets”, implies that carbon impact will need to be brought into functions of a public
body and therefore all decision making processes.

2.3       Carbon assessment of the Scottish Budget

The carbon assessment of the Draft Budget will become a statutory requirement under the
Climate Change (Scotland) Act 2009 and the Government has already provided this
assessment for the 2010-11 Draft Budget. It is a high-level estimate of how much carbon is
created in the production of the goods and services the Government demands, including
those associated with imported goods.

2.4       Scottish Carbon Impact Assessment (SCIA)

The Scottish Government is developing guidance to assess the impact of policies on
greenhouse gas emissions. This Scottish Carbon Impact Assessment guidance seeks to
provide a consistent approach across Government to quantifying carbon impacts over time,
which will assist in managing compliance with the statutory targets in the Climate Change
(Scotland) Act. This guidance is initially being rolled out across Scottish Government and
could potentially be followed by other Public Bodies. This methodology could potentially be
useful in its entirety, or in part, to use within SEPA.

3.        SEPA’s role relating to measuring carbon and assessing carbon

SEPA can impact on and influence greenhouse gas emissions in its regulatory role,as a
statutory consultee for land use planning, and in its role as a consultation authority for
Strategic Environmental Assessment (SEA). SEPA is also committed to minimising its own
carbon impact and monitors and reports on progress. Further to this, SEPA works towards
integrating climate change across the organisation. It is therefore important for SEPA to
understand when a quantitative or qualitative carbon impact assessment/carbon appraisal
methodology is appropriate. The following sections present in detail these different areas of
SEPA’s role relating to measuring and assessing carbon.

 defined as a Scottish public authority within the meaning of section 3(1)(a) of the Freedom of Information (Scotland)
Act 2002 (as amended).

                                                                                                  July 2010

3.1       Regulatory regimes where SEPA administers information on carbon emissions

a) EU Emissions Trading Scheme (ETS): SEPA administers and implements the EU ETS in
   Scotland. SEPA issues a GHG permit with a wide range of conditions that the qualifying
   installations must comply with (including a monitoring plan) and carries out site
   inspections. However, SEPA does not verify emissions; the operator is required to use an
   accredited verification body to do so. SEPA also reviews new entrant reserve

b) The CRC Energy Efficiency Scheme : (formerly known as the Carbon Reduction
   Commitment): SEPA will be the administrator of the scheme for Scotland. Once the
   participants have successfully registered, SEPA will have a compliance and enforcement
   role when CRC comes into force in April 2010.

c)     Carbon Accounting Scheme (Scotland) Regulations 2010: SEPA is specifically
      mentioned in The Carbon Accounting Scheme (Scotland) Regulations 2010 and is likely
      to undertake administrative role of operating the carbon account, similar to aspects of its
      role in the EU ETS. These regulations aim to put in place the administration and
      management of the carbon units in order to track the emissions reduction set-up in the
      Climate Change (Scotland) Act.

3.2 Regulatory regimes where SEPA specifically impacts on or influences carbon
a) Under the Controlled Activities Regulations (Scotland)-CAR , SEPA is required to protect
   the water environment from damage, but derogations from this requirement are allowed if
   a new activity provides overall benefits to sustainable development that outweigh the
   adverse impacts on the water environment. New hydro electricity generating schemes
   cause adverse impacts on the water environment, but the benefits that they provide to
   climate change by generating renewable energy have to be considered in deciding
   whether a new scheme can be licensed. SEPA has developed a regulatory method and
   supporting guidance (WAT RM 34 and WAT SG 67) to guide these assessments.
   Essentially this requires all significant impacts of a new development, from a
   comprehensive range, including those on climate change, to be described and a
   balancing judgement made.

b) Through other regulatory functions, SEPA impacts on and influences greenhouse gas
   emissions e.g. Pollution Prevention and Control (PPC) regime and the energy efficiency
   of processes, and landfill gas capture. SEPA also advises businesses on resource

3.3       Planning – Statutory Consultee

An “Interim Position Statement on Planning, Energy and Climate Change” highlighting the
need for a partnership approach to reduce greenhouse gas emissions through planning and
the potential application of carbon impact assessments on development plans and
development management applications has been approved by the SEPA Board in April 2010.
This statement insists, in particular, on the need to define roles and responsibilities in
quantifying the carbon impacts of individual planning applications. SEPA is developing
internal operational guidance on climate change for development plans and development

3.4       SEA Consultation Authority

  “Provision is made for the Scottish Ministers to delegate the functions placed on
them in this instrument to the Scottish Environment Protection Agency (SEPA)”
  The European Water Framework Directive (WFD) was transposed into Scottish law by the Water Environment and
Water Services (Scotland) Act (WEWS). The regulations coming from WEWS are the Controlled Activities
Regulations (CAR).

                                                                                                              July 2010

SEPA has developed guidance, Consideration of Climatic Factors within Strategic
Environmental Assessment, on behalf of Scottish Government. This guidance explores the
qualitative carbon impact of plans, programmes and strategies. The next phase, to look at the
quantitative carbon impact of plans, programmes and strategies has been combined with a
Scottish Government project on carbon impacts assessment and spatial planning. SEPA is
contributing to this project financially and through technical support on the project team and
steering group. The first part of the project will look at existing tools with the second focusing
on developing a bespoke tool for spatial planning.

3.5        Measuring and assessing SEPA’s own impact

a) The Greening SEPA program aims to improve the organisation’s green credentials. This
   includes assessment and reporting against SEPA’s direct emissions (business transport
   in particular) but also electricity use. SEPA has a reduction target for carbon dioxide of
   25% by March 2012 and a reduction target for internal travel and transport emissions by
   10% by March 2011, both from a 2006/2007 baseline.

b) SEPA has committed to carry out a full carbon footprint in 2010/2011 of its direct and
   indirect emissions to identify other areas where SEPA can positively influence the
   reduction of greenhouse gas emissions e.g. through its procurement activities.

c) SEPA is assessing the carbon impact of organisational changes, for example, the
   implications of the Step Change in Science programme on business travel and energy
   use in buildings.

3.6       Developing areas

a) Carbon Assessment and peat
   Scotland’s bogs, wetland and upland systems act as a vital “carbon bank”. Scotland's
   organic soils hold 10,028 Mt CO2e, this compares with a total of 418 Mt CO2e in UK
   surface vegetation . To put this into context, Scotland’s net 2007 greenhouse gas
   emissions equate to around 0.6% of Scotland’s total soil carbon bank.
   This means that developments leading to peat disturbance could therefore generate a
   rise in emissions need to be carefully considered. SEPA is working alongside other
   partners (mainly SNH and the Scottish Government) to improve the understanding of this
   issue (most developments on peat are currently windfarms but this is likely to diversify in
   the medium-term) and to identify respective responsibilities. Planning has a key role to
   play in development but it is not, as yet, framed by a strong legal framework.

      In 2008, Scottish Government developed and released a tool for assessing carbon
      emissions from windfarms. SEPA continues to work with the Scottish Government and
      SNH to improve its use and effectiveness in delivering lower carbon renewable energy for
      Scotland. Minimising the amount of peat excavated and disturbed is likely to reduce the
      overall environmental impact, including greenhouse gas emissions. This is why SEPA
      has been working closely with Scottish Natural Heritage (SNH) to develop a good practice
      guide that considers all aspects of windfarm development.

b) Life Cycle Assessment/environmental decision making
   Life Cycle Assessment is the consideration of environmental impacts of a service or a
   product. This is obviously highly relevant for carrying out carbon assessment. SEPA is
   currently reviewing its internal resources in this area and more information will be
   available shortly on the extent to which SEPA integrates life-cycle assessment in its

c) Role of carbon pricing compared with qualitative descriptions of carbon emissions

  Bradley, R. I., Milne, R., Bell, J., Lilly, A., Jordan, C. and Higgins, A. (2005) A soil carbon and land use database for
the United Kingdom. Soil Use and Management 21, 363-369.

                                                                                         July 2010

      SEPA commissioned a project to compare the outcomes of hypothetical licence review
      decisions for the Controlled Activities Regulations (CAR) made using carbon pricing with
      decisions made using qualitative descriptions of carbon emissions. The UKWIR (UK
      Water Industry Research) carbon accounting methodologies were used and provided a
      useful way of determining the carbon impacts associated with regulatory decisions in the
      water sector. The conclusions of the project were that, in the case studies used, neither
      qualitative descriptions of carbon nor monetised values for carbon had an impact on the
      outcome of the final regulatory decision. It has to be noted however that, if carbon prices
      increase, as is likely in future years, their impact on regulatory decisions might increase.

d) Carbon accounting tools and methodologies- the oil and gas industry
      SEPA commissioned a report looking at the carbon accounting methodologies, tools and
      assessment available in the oil and gas industry and how their principles could be applied
      to other sectors. The report highlighted in particular the key difference between tools and
      methodologies: methodologies define the framework and principles behind the carbon
      assessment whereas the tools actually implement the process and come up with figures.
      Life Cycle Assessment is a methodology and the figures can be obtained by using the
      relevant tools. The full report will be available soon on SEPA’s website. In the meantime,
      please contact Jean Le Roux if you wish to get a copy of the summary or full report.

3.7       Further stakeholder engagement

a) SEPA organised, in 2008, a series of GRIP (Greenhouse Gas Regional Inventory
   Protocol) workshops with a range of stakeholders to raise awareness about the
   challenges to achieve an 80% emissions reductions by 2050 in five cases for the whole of
   Scotland and one case for the Highlands and Islands. This process, based on discussion
   on how the energy sector might look like in 2050, has proven very beneficial and also led
   to a session for the TICC (Transport Infrastructure and Climate Change Committee) while
   the Climate Change Scotland Act was passing through parliament. A brochure presenting
   the key results of each session is available here. The Glasgow Clyde Valley Structure
   Plan Joint Committee recently ran additional sessions and Scottish Enterprise considered
   the potential organisation of sessions.

b) The Local Footprints Project, run by the Sustainable Scotland Network (SSN), aims to
   help local authorities and schools make an effective contribution to reducing Scotland's
   footprint through the use of footprint analysis to inform policy and practice, to raise
   awareness, and to change behaviour. The Local Footprints Working Group, which SEPA
   sits on, has been set up to build on past project experience, ensuring that councils and
   community planning partnerships are at the heart of delivery, whilst capitalising on the
   knowledge and expertise of key partners.

This paper has provided an update on how SEPA is involved in carbon assessment. Please
contact Jean Le Roux or Rebecca Walker for further details in relation to this work. As
SEPA’s carbon assessment activities continue to move forward we will provide updates.

Jean Le Roux and Rebecca Walker, July 2010.


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