Appendix I – Specific Comments on the SEA Scoping Report
Scope of the SEA The Strategy should clearly set out the scope, remit and implementation related elements of the Strategy. These will have implications for the SEA, in terms of guiding the level of assessment applicable at the appropriate level for the Strategy. Where it is envisaged that measures proposed in the Strategy will be implemented via other plans, which themselves have been or will be subject to SEA, this should be explained in the Environmental Report and taken into account in the assessment. Where specific measures will be implemented directly, further detail should be provided in the Environmental Report and Strategy on the relevant environmental assessments to be carried out at the project stage and relevant mitigation measures to be applied, as appropriate. There may be merit in exploring this issue further with the relevant Environmental Authorities during the Strategy preparation and SEA processes. There may be merit in including a matrix in the SEA environmental report to show the interrelationships between the various topics. This should be accompanied by relevant explanatory text. Data & Knowledge Gaps The Strategy should identify any significant data and knowledge gaps, including commitments to address these on a priority basis and where relevant, in association with other government departments/ organisations, during the implementation phase of the Strategy. This is with a view to strengthening the evidence base for future reviews and iterations of the Strategy. Range of Effects The SEA Environmental Report should refer to the full range of effects and of the area likely to be affected. This assessment should consider the duration and frequency of effects as well as short, medium and long-term, cumulative and synergistic effects of the Strategy. The EPA’s Good Practice Guidance on Cumulative Effects Assessment in Strategic Environmental Assessment (EPA, 2020). Consultation There is merit also in pointing to Article 13 of the SEA regulations (S.I. 435 of 2004, as amended) which relates to the consultations. The SEA regulations require that the draft Strategy is sent to the statutory environmental authorities inviting written submissions. Additionally, Cork City Council is required to publish a newspaper notice inviting submissions/observations from the public on both the Strategy and the SEA environmental report. The SEA regulations refer to a public consultation period of not less than 4 weeks and submissions and observations received should be taken into consideration in finalising the Strategy.
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