Environment Impact Assessment - Frequently Asked Questions
What is Historic Environment Scotland’s role in Environmental Impact Assessment?
Historic Environment Scotland is a consultee on all qualifying Environmental Impact Assessment (EIA) developments in Scotland. This includes some project types which are not typically considered 'development' e.g. forestry. We have a specific remit in relation to EIA which means that we focus on providing advice and comments on impacts on scheduled monuments and their setting, category A listed buildings and their setting and Inventory gardens and designed landscapes. We will also provide advice where an EIA development proposal appears likely to have an impact on an Inventory battlefield.
It is important to note that where an Environmental Statement (ES) is submitted with an application for consent it is not necessarily determinative of the decision on the application. However, it should report the conclusions of the assessment without justification so that the decision maker can decide its outcome in full light of the potential impacts on the environment. In addition to providing information for the decision maker and the statutory consultees EIA is also intended as a means for the developer to share information with the public. The ES is one part of the information that the decision maker will take into account once the consultation period on the application and the ES has ended. Other information includes the comments of the local authority, the statutory consultees and the public.
Where requested, our comments are returned to the decision-making authority. Our advice on the historic environment will be one of a range of factors that the decision maker will take into account in reaching a view on the application. Historic environment matters are also subject to the comments of the local authority historic environment service for a range of historic environment issues.
Can I contact Historic Environment Scotland directly to discuss a development proposal in its early stages?
Yes. We welcome pre-application consultation. However, it is helpful if the following information is provided with your enquiry
- A map showing the location and extent of the proposed development site
- Indicative details of the proposal. For example, for a windfarm we find that however preliminary, an indication of the number of turbines, maximum height to blade tip, initial site layout and Zone of Theoretical Visibility (ZTV) model helps us to identify the sites to be considered as in the Environmental Impact Assessment (EIA) of the project
Without this information, we may be unable to provide specific comments.
We would be happy to discuss any issues we have raised with you as the design of your development progresses, particularly where the significant impacts are predicted. Further discussion of appropriate mitigation measures may be necessary in these cases and our preference is to address these issues in advance of the submission of any application and accompanying Environmental Statement (ES). Further information of this nature can be submitted to: the Strategic Heritage Management team
. Our response time for such consultations is 21 days.
More information on pre-application engagement can be found in the Key Agencies statement on pre-application engagement for national and major developments
How far should the area of search extend to?
We would advise caution with this approach since there may be monuments likely to experience a significant impact beyond this distance. The application of a Zone of Theoretical Visibility model may help to identify such sites as part of an initial assessment. We would be happy to discuss the findings of this search with you once you have produced such a model. The ES should make clear the extent of the area within which impacts on setting have been assessed and the reasons for that cut-off point.
Data on scheduled monuments, listed buildings, Inventory Gardens and Designed Landscapes and Historic Battlefields is available from our data services website
. Please contact the relevant local authority archaeology service for information on unscheduled archaeology. The relevant local authority’s conservation advisors will be able to provide information on listed buildings, conservation areas and non-Inventory gardens and designed landscapes.
How should I assess impacts on the historic environment?
Historic Environment Scotland recommend that you engage a suitably qualified archaeological/historic environment consultant to advise on and undertake the detailed assessment of impacts on the historic environment and advise on appropriate mitigation strategies. Baseline
The starting point for any assessment will be to develop an understanding of the historic environment baseline. Information on the location of all archaeological/historic sites held in the National Monuments Record of Scotland, including the locations and, where appropriate, the extent of scheduled monuments, listed buildings and gardens and designed landscapes can be obtained from www.pastmap.org.uk
. Data on scheduled monuments, Inventory gardens and designed landscapes and Inventory battlefields can be found on our data services website. For any further information on those datasets please contact firstname.lastname@example.org
. Historic Environment Scotland would also be happy to provide any further information on all such sites and on impacts on the setting of category A listed buildings.
Information and advice on unscheduled archaeological sites, listed buildings and conservation areas should be sought from the relevant local authority archaeological and conservation services.
Additional baseline information can be obtained from other relevant documentary and cartographic sources and should be augmented by a non-invasive walk-over survey and field evaluation. It should also assess the area’s potential for the discovery of further, as yet unrecorded archaeological sites. It should identify and describe the site and setting of the historic environment assets both within the boundary of the development area and within a wider area within which significant impacts on setting may be expected to occur.Potential Impacts
Impacts on historic environment features can depend upon the land-take associated with infrastructure and supporting activities and may be avoided through appropriate locational measures. Impacts on the historic environment should be considered in the following terms:
- direct i.e. loss of and/or damage to a feature of the historic environment
- indirect, including amongst other things, effects on the setting of historic environment assets; changes to surface drainage patterns, removal of peat etc.
Any development should be designed to avoid direct impacts on scheduled monuments. This includes any associated ancillary development. For example, for a windfarm, in addition to turbines, this could include access roads, cable routes, work compounds and laydown areas and other site infrastructure. Where it is considered that direct effects on scheduled monuments cannot be avoided, developers are advised to contact Historic Environment Scotland as early as possible to avoid delays later in the planning process.
Developments should also be designed to ensure that impacts on the setting of heritage assets are avoided or reduced, in line with Scottish Ministers’ policies for the protection of the historic environment as expressed in Scottish Planning Policy. This is only likely to be implemented effectively if these issues are taken into account from the early stages of the design process.
Assessment of impacts on setting should be supported by appropriate visualisations such as wirelines or photomontages. Historic Environment Scotland would be happy to discuss and agree such details.Mitigation
In applying mitigation, the starting point should be the avoidance of impacts, if this is not possible such measures should reduce impacts as far as possible. Offsetting methods, including prior archaeological excavation of threatened features may be appropriate in some cases but as Planning Advice Note (PAN), Environmental Impact Assessment indicates, it is at the lower end of the mitigation hierarchy. We would welcome further discussion of appropriate mitigation measures. Your Environmental Statement should provide information on the mitigation measures considered in the design of your development.
What should I include in the cultural heritage chapter?
Since the purpose of EIA is to make environmental information accessible to both specialist and non-specialist readers, the assessment contained in the cultural heritage chapter should clearly state the level of impacts predicted for the sites assessed without justification. The chapter should address issues such as direct effects, setting and cumulative impacts. Further information and advice on setting and the assessment of impacts on setting can be found in our Managing Change guidance note
on the topic.
The sites included the assessment and level of detail for each can be agreed as part of any pre-application discussions. Analysis should be clear and assumptions underpinning the assessment explained in the ES. It is helpful if any chapters containing information relating to the historic environment are cross referenced. For example if Inventory gardens and designed landscapes are to be assessed in the Landscape and Visual Assessment chapter rather than the cultural heritage chapter, this should be stated. However, our preference is that the cultural heritage chapter should also contain the assessment of impacts on any Inventory Gardens and Designed Landscapes. This is because these assets are designated primarily for their historic environment interest. The inclusion of visualisations (see below) to support the conclusions reached is also helpful.
The cultural heritage chapter should explain how mitigation measures have been applied to any predicted significant impacts and how those measures have avoided, reduced or offset impacts. We would welcome discussion of the application of appropriate mitigation measures as during the process of the design of your development where significant impacts on scheduled monuments, listed buildings and Inventory gardens and designed landscapes are likely. We also recommend that you seek advice from Historic Environment Scotland where an EIA development affects a battlefield.
The cultural heritage chapter should also contain an assessment of any cumulative impacts.
Should visualisations be included in the ES for the historic environment?
The inclusion of visualisations to support the conclusions reached in the ES is helpful. We would be happy to agree suitable locations for visualisations as part of any pre-application consultations being undertaken although it is generally more helpful to do this once an initial assessment of impacts has been made by your historic environment advisor. The visualisations should demonstrate the likely impact of the development on the setting of the heritage asset.
Further information on setting can be found in our setting guidance
. Images should contain viewing information so that it replicates what will be seen if the proposal if the proposal is constructed. Information on the viewpoint location and horizontal field of view should also be included.
Where can I find information on policy and guidance?
Further information on Environmental Impact Assessment can be found on the Scottish Government’s Environmental Assessment web pages
The Scottish Minister’s policies for the historic environment are set out in the following documents:
Our website contains further information on the historic environment as does the Scottish Government’s website
The following guidance is also relevant for offshore and marine EIA projects
Further information about marine archaeology can be found on our Historic Marine Protected Areas page.