Justice Sustainable Development Strategy 2020 to 2023

Executive Summary

The 2019 to 2022 Federal Sustainable Development Strategy (FSDS) presents the Government of Canada’s sustainable development goals and targets, as required by the Federal Sustainable Development Act. In keeping with the purpose of this Act to provide the legal framework for developing and implementing a Federal Sustainable Development Strategy (FSDS) that will make environmental decision-making more transparent and accountable to Parliament, the Department of Justice supports the goals laid out in the FSDS through the activities described in the Justice Sustainable Development Strategy (JSDS).

The Department recognises that sustainable development – social and economic sustainability, as well as environmental sustainability – contributes to the Department’s ability to achieve its strategic outcomes. To this end, Justice Canada’s vision for sustainable development is the integration of sustainable development – in its broadest terms – with departmental objectives, needs and practices. The JSDS 2020 to 2023 plays an integral role in achieving Justice Canada’s vision for sustainable development.

In the JSDS 2020 to 2023, Justice Canada sets out ten departmental actions that support the FSDS 2019 to 2022 goal of “Greening Government: The Government of Canada will transition to low-carbon, climate resilient, and green operations.” These actions – which involve measures to enhance Justice facilities, ensure sustainable development is reflected in security and procurement activities, and improve sustainability of Justice operations – directly contribute to four FSDS targets:

• Divert at least 75% (by weight) of non-hazardous operational waste from landfills by 2030;
• Divert at least 75% (by weight) of plastic waste from landfills by 2030;
• By 2022, departments have developed measures to reduce climate change risks to assets, services and operations; and
• Actions supporting the Goal: Greening Government.

In addition, this strategy describes a number of initiatives Justice Canada is undertaking that contribute to the Government’s broader sustainable development objectives. These measures include support for the United Nations Sustainable Development Goals through Justice Canada’s Access to Justice Secretariat (see Section 2), as well as initiatives to: promote broader adoption and integration of flexible work arrangements; build a culture of sustainable practices in meetings, events and operations; and expand the successful Ottawa public transit card pilot project to regions. (see Section 4)

The Department’s Sustainable Development Steering Committee (SDSC) is mandated to oversee Justice Canada’s sustainable development program. In this role, it will monitor the progress of all of the initiatives identified in this strategy, and provide advice, guidance and direction as needed to ensure issues are addressed. Additional information on SDSC’s role and responsibilities, as well as those of other Justice Canada stakeholders, are set out in Section 4.

In addition to the work undertaken under the framework of the sustainable development program, Justice Canada will continue to ensure that its decision making process includes consideration of FSDS goals and targets through its Strategic Environment Assessment (SEA) process.

Once approved by the Minister of Justice, the JSDS 2020 to 2023 is tabled in Parliament. During subsequent years, the Department reports on its sustainable development targets through annual planning and reporting documents tabled in Parliament.

Section 1: Introduction to the Justice Sustainable Development Strategy

The 2019 to 2022 Federal Sustainable Development Strategy (FSDS) presents the Government of Canada’s sustainable development goals and targets, as required by the Federal Sustainable Development Act. In keeping with the purpose of this Act to provide the legal framework for developing and implementing a Federal Sustainable Development Strategy that will make environmental decision-making more transparent and accountable to Parliament, the Department of Justice supports the goals laid out in the FSDS through the activities described in the Justice Sustainable Development Strategy (JSDS).

This strategy was prepared under the 2008 Federal Sustainable Development Act. However, amendments to the Act received Royal Assent in February 2019 – including an expanded focus on the social and economic aspects of sustainable development – and will come into force on December 1, 2020. Once the amendments are in force, future strategies will be guided by an Act that supports greater accountability, a truly whole-of-government approach, and more effective engagement with Canadians.

Section 2: Sustainable Development Vision and Context in the Department of Justice

Department of Justice’s Approach to Sustainable Development

The Department of Justice (Justice Canada) strives to ensure that Canada has a fair, relevant and accessible justice system that reflects Canadian values, and that the federal government is supported by high quality legal services. To achieve these strategic outcomes, Justice Canada strives to enable an environment of legal and business excellence based on principles of innovation and collaboration, as well as open, transparent and accountable operations.

Sustainable development is embedded in these principles of business excellence. It is factored into decision making as the Department seeks to determine which approaches, initiatives, strategies and investments will put Justice Canada in the best position to deliver its programs and services, and meet the expectations for both its clients and Canadians.

Department of Justice’s Vision for Sustainable Development

The Department recognises that sustainable development – social and economic sustainability, as well as environmental sustainability – contributes to the Department’s ability to achieve its strategic outcomes.

To this end, Justice Canada’s vision for sustainable development is the integration of sustainable development – in its broadest terms – with departmental objectives, needs and practices. In order to bring this vision into effect, the Department is taking a multi-pronged approach that involves:

• ensuring the Department is able to bring a broad sustainable development perspective to discussion and decision making;
• exploring opportunities to introduce sustainable practices through corporate and program-based initiatives; and,
• encouraging responsible management of resources, sustainable economic practices and healthy communities through education and awareness building.

The JSDS 2020 to 2023 plays an integral role in achieving Justice Canada’s vision for sustainable development. This strategy sets out the Department’s required commitments in support of the FSDS Greening Government Goal, as well as describing additional activities that contribute to the Government’s broader sustainable development objectives.

The initiatives described this Sustainable Development Strategy build on the efforts launched in Justice Canada’s previous strategy, most notably in the Department’s full roll out of two pilot projects: the eSignature project, aimed at determining the demand for and effectiveness of this innovative technology (see Section 3); and the Public Transit Card project (see Section 4), which encourages staff to opt for less carbon-intensive modes of transport for work-related travel. In addition, the Department supports the United Nations Sustainable Development Goals. Although strictly speaking beyond the scope for this strategy, the Goals clearly align with its overall purpose – see, “UN Sustainable Development Goals and Justice Canada.” Collectively, the actions set out in the JSDS 2020 to 2023 are moving Justice Canada closer to realizing its vision for sustainable development.

UN Sustainable Development Goals and Justice Canada

Peaceful, Just and Inclusive Societies and Strong Institutions

As a signatory to the United Nations 2030 Agenda and the 17 Sustainable Development Goals (SDGs), the Government of Canada is committed to the overarching vision To Leave No One Behind. Of particular relevance is SDG 16, which calls for peaceful, just and inclusive societies that provide access to justice for all and build effective, accountable and inclusive institutions at all levels. Justice Canada is the Government of Canada lead for advancing SDG 16.

The Department’s new Access to Justice Secretariat provides a focal point for the Government’s efforts to realize SDG 16 and promote access to justice for all, domestically and internationally.

Commitment to Open Justice

Among the activities being undertaken to advance SDG 16, Justice Canada has committed to work with partners and stakeholders to develop an Open Justice commitment in support of a people-centered approach to justice that aims to address legal needs across Canada. This initiative concurrently supports the Government of Canada’s commitment to Open Government.

Reporting on this commitment would take place through Canada’s upcoming National Action Plan on Open Government.

Other Sustainable Development Goals

In addition to SDG 16 which is foundational to all the goals, Justice Canada also contributes to four other SDGs in various ways:

• SDG 5 – Gender Equality;
• SDG 8 – Decent Work and Economic Growth;
• SDG 10 – Reduced Inequalities; and
• SDG 17 – Partnerships for the Goals.

Section 3: Commitments for Department of Justice

Greening Government: The Government of Canada will transition to low-carbon, climate resilient, and green operations

Responsible Minister: All ministers

This goal captures commitments from the Greening Government Strategy, as well as reporting requirements under the Policy on Green Procurement.

FSDS Goal and target(s) Greening Government	FSDS contributing action(s)	Corresponding departmental action(s)	Contribution to the FSDS goal and target by each departmental action	Starting point(s) Performance indicator(s) Target(s)	Program(s) in which the departmental actions will occur
Divert at least 75% (by weight) of non-hazardous operational waste from landfills by 2030	Other	Partner with Building Property Managers, Brookfield Global Integrated Solutions (BGIS), in collaboration with Public Services and Procurement Canada (PSPC) on measures that will enable Justice Canada to improve waste diversion rates by 2022, notably on an initiative to expand central recycling stations in the National Capital Region (NCR) – specifically St. Andrews Tower (SAT) and the East Memorial Building (EMB) – to include composting and better signage allowing employees to easily recognize the correct bins and what items can be recycled.	Collaborating with BGIS and PSPC to set up mechanisms on properties leased to Justice Canada to facilitate waste diversion will help to reduce landfill gas and transport hauling emissions, as well as emissions for the extraction and production of virgin materials. UN SDG 12: Target 12.5	Starting Point: Establish agreement with BGIS, in collaboration with PSPC, to expand and enhance central recycling stations on properties occupied by Justice Canada in the NCR, specifically SAT and EMB. Performance Indicators: By March 31, 2022, enhanced central recycling stations are in place at Justice Canada facilities in accordance with agreed-upon locations and timelines. Target: An agreement has been reached between BGIS and Justice Canada, in collaboration with PSPC, to install 13 enhanced recycling stations in SAT and 16 in EMB by March 31, 2022.	Internal Services
Divert at least 75% (by weight) of plastic waste from landfills by 2030	Other	Partner with BGIS and PSPC, on measures that will enable Justice Canada to improve plastic waste diversion rates by 2023, notably on an initiative to install bottle refilling stations where feasible in facilities leased to Justice Canada.	Actions that reduce the generation of plastic waste will help to reduce indirect emissions (i.e. Scope 3 emissions) for the production, transport and disposal of material. This includes reducing landfill gas and transport waste hauling emissions by diverting plastic waste from landfill sites, and reducing emissions for the extraction and production of virgin materials by recovering material through recycling plastics. UN SDG 12: Target 12.5	Starting Point: Agreement with BGIS, in collaboration with PSPC, to install bottle-refilling stations in specified locations in facilities leased to Justice Canada. Performance Indicators: Bottle-refilling stations are installed in accordance with agreed-upon locations and timelines. Target: An agreement has been reached between BGIS and Justice Canada, in collaboration with PSPC, to install two bottle-filling stations per building in both EMB and SAT by March 31, 2023.	Internal Services
		Partner with BGIS and PSPC, on measures that will enable Justice Canada to track and disclose plastic waste diversion rates by 2023, notably on an initiative to conduct annual plastic waste diversion audits in the National Capital Region (NCR), specifically St. Andrews Tower (SAT) and the East Memorial Building (EMB).	Actions that track and disclose plastic waste diversion rates on a regular basis provide information needed to reduce the generation of plastic waste and to help reduce indirect emissions (i.e. Scope 3 emissions) for the production, transport and disposal of material. This includes reducing landfill gas and transport waste hauling emissions by diverting plastic waste from landfill sites, and reducing emissions for the extraction and production of virgin materials by recovering material through recycling plastics. UN SDG 12: Target 12.5	Starting Point: Establish agreement with BGIS, in collaboration with PSPC, to conduct annual plastic waste diversion audits in the NCR, specifically at SAT and EMB. Performance Indicators: Annual plastic waste diversion audits will be conducted at Justice Canada facilities in the NCR, specifically SAT and EMB, illustrating historic and current waste generation and diversion rates. Target: Annual plastic waste diversion audits are conducted at SAT and EMB In collaboration with BGIS and PSPC, Justice Canada will establish a target diversion rate for plastic waste at SAT and EMB by March 31, 2023.	Internal Services
By 2022, departments have developed measures to reduce climate change risks to assets, services and operations	Increase training and support on assessing climate change impacts, undertaking climate change risk assessments and developing adaptation actions to public service employees, and facilitate sharing of best practices and lessons learned	Review emergency management and business continuity planning material and processes annually to ensure climate change risks and impacts are appropriately addressed.	Factoring climate variability and change into emergency management and business continuity planning is one of the most important ways Justice Canada can ensure it remains well-prepared to address the impact of a changing climate on its capacity to operate and deliver on its critical services, among which is the provision of legal services to all clients. UN SDG 13: Target 13.2, 13.3	Starting Point: The Department’s Strategic Emergency Management Plan (SEMP) and Business Continuity Plan (BCP) already incorporate responses for emergencies generated by environmental conditions. Performance Indicators: Annual reviews and updates of the SEMP and BCP take place, with consideration of climate change impacts and risks. Business Continuity Management (BCM) and/or Emergency Management (EM) exercises include specific injects prompting discussions on climate change impacts and risks. Targets: 50% of Business Continuity Management exercises conducted annually include specific injects prompting discussions on climate change impacts and risks 33% of Emergency Management exercises conducted annually include specific injects prompting discussions on climate change impacts and risks.	Internal Services
Actions supporting the Goal: Greening Government	Minimize embodied carbon and the use of harmful materials in construction and renovation	Partner with PSPC to implement a LEED-certified pilot fit-up project. Such projects require the use of low embodied carbon materials.	Partnering with PSPC on a LEED-certified pilot fit-up project helps Justice Canada to encourage industry to adopt low carbon extraction, production and disposal practices. This will reduce indirect emissions (i.e. Scope 3 emissions) and other harmful environmental impacts. UN SDG 9: Target 9.4	Starting Point: LEED-certified pilot fit-up project proposal will be developed. Performance Indicator: Progress towards a LEED Certified project. Target: By March 31, 2022, LEED project has been selected and meets all mandated prerequisites to achieve certification level (40–49 points).	Internal Services
	Departments will use environmental criteria to reduce the environmental impact and ensure best value in government procurement decisions	Explore measures to increase awareness and uptake of environmental considerations in procurement activities	Exploring measures to increase green procurement allows Justice Canada to establish the tools and processes that will successfully encourage clients to incorporate environmental considerations into purchasing decisions and motivate suppliers to reduce the environmental impact of the goods and services they deliver, and their supply chains. UN SDG 12: Target 12.7	Starting Point: Obtain approval to incorporate modest environmental criteria in procurement evaluation as a pilot project. Performance Indicator Incorporating a green procurement rating criterion in procurement evaluation pilot projects. Target Three pilot projects to incorporate green procurement rating criteria.	Internal Services
	Departments will adopt clean technology and undertake clean technology demonstration projects	Expand the use of Justice Canada’s eSignature pilot project to address specific departmental needs and increase operational efficiency	Actions by individual departments that incent, support, or procure state-of-the-art innovative clean technologies help to lower the environmental footprint of government operations. Justice Canada’s eSignature pilot project, which was part of the 2017-2020 Justice Sustainable Development Strategy, has demonstrated the contribution this technology has made to sustainable operations – including paper reduction, energy efficiency and reduced carbon footprint. By replacing physical signatures with secure electronic signatures, eSignature reduces the need to print and store documents requiring official signatures. In the short term, eSignature decreases paper usage and the energy needed to run printers. Over the longer term, widespread use of eSignature could decrease storage requirements for paper documents, reducing the Department’s overall carbon footprint. UN SDG 12: Target 12.7	Starting Point: The eSignature Pilot has been completed in the National Capital Region, and structures are in place to expand eSignature to regions and new business lines and/or processes. Performance Indicators: Number of business lines and processes adopting eSignature Percentage of digitized transactions as a result of the adoption of eSignature. Percentage completed of regional roll out Target: eSignature is successfully implemented by at least 10 business lines or processes. 80% of transactions requiring signatures for business lines or processes which have implemented eSignature are completed electronically. eSignature is implemented in at least one unique business line or process in each region.	Internal Services
		Add to Mobile Electronic Courtroom (MEC) capacity	A Mobile Electronic Courtroom is a moveable suite of electronic devices (monitors, switch boxes, cabling) that equips a courtroom to run an electronic trial. This eliminates the need for producing documentary evidence on paper. The goal of this initiative is to achieve savings in costs and time as well as reducing impact on the environment by using electronic means to display documentary evidence. For example, for the 300-day Cowichan trial in BC Supreme Court that will run for at least 3 years, equipping the court room eliminated the need to print 14,000 evidentiary documents - over 200,000 pieces of paper. UN SDG 12: Target 12.5	Starting Point: Justice Canada has three MECs, the first of which was deployed in a courtroom in late 2016. Performance Indicator: Number of days the 3 MECs are used each year. Target: 200 days per year (i.e. the combined use of all 3 MECs).	Litigation Services
	Support for green procurement will be strengthened, including guidance, tools and training for public service employees	Continue to ensure decision makers, material management and specialists in procurement have the necessary training and awareness to support green procurement.	Green procurement incorporates environmental considerations into purchasing decisions and is expected to motivate suppliers to green their goods, services and supply chain. Ensuring that procurement and materiel management specialists have the necessary training to provide effective guidance and direction to clients and suppliers. UN SDG 12: Target 12.7	Starting Point: 100% of specialists in procurement and materiel management have completed training on green procurement within one year of appointment. Performance Indicator: Percentage of specialists in procurement and materiel management who have completed training on green procurement. Target: 100% of specialists in procurement and materiel management have completed training on green procurement within one year of appointment to Justice Canada.	Internal Services
	Other	Explore options for implementing procedures and technologies to decrease the environmental impact of printer usage at Justice Canada.* [*Note:  This action is consistent with Statistics Canada’s “Measurement, Controls and Monitoring” (Table 2e) listing of clean technologies in its detailed taxonomy].	Procedures and technologies to manage printers and printing efficiently and in accordance with environmental best practices are expected to raise awareness about environmental considerations and costs; and decrease usage and waste of resources (ink, paper, etc.) and electricity. UN SDG 12: Target 12.5	Starting point: A pilot project involving the lease of approximately 100 printers (including paper, ink and service) was launched in Q3 2018-19. Trend and usage data are being generated as part of this project. Best practices and tools to provide guidance and direction on printing will be explored for further opportunities. Performance Indicator: Pilot project generates sufficient data to determine whether to expand model or pursue an alternate approach to decreasing the environmental impact of printer usage. Additional strategies, actions and/or tools are identified to promote sustainable and efficient printer use. Target: A recommended model for managing Justice Canada’s printers is on hold pending further information on return to work and the impact of remote work on the paper culture A recommended model for managing Justice Canada’s printers will be submitted to senior management by Q3 2021-22. Specific targets to be confirmed pending identification of strategies, actions and tools.	Internal Services

Section 4: Integrating Sustainable Development

Framework for Sustainable Development

In October 2019, Justice Canada brought together all work done in the Department related to sustainable development under a single framework, known as the sustainable development program. (see Annex A)

This framework was designed with the explicit mandate to embed an integrated approach to sustainable development at Justice Canada. Based on this approach, initiatives and activities are categorized, irrespective of their operational or public policy origins, as:

• Green Workplace – Activities and initiatives related to greening government operations and practices;
• Education and Outreach – Events, training and activities aimed at individual awareness and capacity building (includes Green Teams); and
• Sustainable Development Public Policy – Activities and initiatives aimed at advancing public policy and program objectives (including the United Nations Sustainable Development Goals).

Achieving Justice Canada’s Sustainable Development Vision

Justice Canada’s sustainable development program enables the Department to connect activities across functional and business lines to support broader sustainable development objectives, in addition to meeting its obligations toward the Federal Sustainable Development Strategy and the United Nations 2030 Sustainable Development Goals.

In fact, a number of initiatives beyond those outlined in section 3 will make an important contribution to the Department’s vision for sustainable development over the next three years. The Sustainable Development Steering Committee (SDSC) will be regularly advised on the progress of these initiatives as part of Justice Canada’s sustainable development program.

Alternative and Flexible Working Arrangements

This initiative to promote broader adoption and integration of alternative and flexible work arrangements across Justice Canada contributes to both the Federal Sustainable Development Strategy (FSDS) and the UN 2030 Sustainable Development Goals (SDGs).

The pandemic has caused or accelerated changes in public administration in Canada and around the world as many global corporations are transitioning to flexible work locations, telework models and adopting hybrid versions. To respond to the changing reality, Justice Canada will explore future ways of working, where a hybrid workplace approach with both on- and off-site work models co-exist.

Why does it matter?

In appropriate circumstances, flexible work arrangements enable employees to work safely and effectively in remote locations and/or on non-standard schedules. Work flexibility may contribute to the reduction of the quantity of pollutants released into the air as a result of employees commuting to a physical office each day, one of the goals of the FSDS as well as a contribution to SDG 11 (Sustainable Cities and Communities). On a broader scale, it can also facilitate efforts to create decent work and economic growth (SDG 8) and reduce inequalities (SDG 10) by opening new opportunities to those situated outside of urban centres.

What will it look like?

In practical terms, advancing work flexibility depends on shaping workplace conditions and culture in ways that promote take up and successful engagement across the Department. This means that the right physical, technological, operational and professional conditions need to be in place in order for sustainable development benefits to be fully realized.

With this in mind, as part of its efforts to integrate sustainable development into its policies, operations, programs and culture, over the next three years Justice Canada will:

• Identify activities and initiatives that will be pursued to promote adoption and integration of flexible work arrangements; and
• Monitor the status of activities and initiatives supporting flexible work arrangements with respect to their approved plans.

Building a Culture of Sustainable Practices

This initiative involves changing long-standing behaviours around the use of plastics – particularly single-use plastics and packaging waste – in meetings, events and operations. While this initiative is expected to support the FSDS action to “Eliminate the unnecessary use of single-use plastics in government operations, events and meetings and promote the procurement of sustainable plastic products and reduction of plastic packaging waste”, its initial focus is on creating the environmental conditions for success.

Why does it matter?

Everyday activities and operations – printing documents, purchasing office supplies, and other ordinary decisions – have direct environmental consequences. However, these choices also create and reinforce the habits, assumptions and expectations that shape workplace culture. To achieve its sustainable development vision, Justice Canada must invest in creating a culture of sustainable practices: one in which the physical, operational and social environment all work together to encourage employees at all levels to make sustainable choices.

What will it look like?

Culture change is a long-term initiative, and there are no short-cuts to success. At the same time, Justice Canada recognizes the significance of culture in achieving its sustainable development vision.

Over the next three years, the Department will:

• Seek senior management commitment to engage in sustainable practices in their sectors/portfolios, with a focus on eliminating use of single-use plastics in their operations, events and meetings;
• Provide concrete guidance to sectors/portfolios on holding green events and meetings; and
• Explore other measures that could make it more practical for Justice employees and decision makers to make sustainable choices.

Public Transit Card Initiative

This initiative explores the potential to expand Justice Canada’s successful “Presto Card” pilot project to its regional offices. The initiative provided participating units with public transit passes for work-related travel in the Ottawa area. Not only was the pilot project well-received by employees, it has proven to be of interest to other departments.

Why does it matter?

Actions that incent green travel help to lower the environmental footprint of government operations, and can help to improve the air quality of the areas in which government operates. Justice Canada’s public transit card project has already proven successful in Ottawa, and expanding this initiative to other urban areas across the country is expected to enhance the environmental benefits accordingly.

What will it look like?

At this point in time, the Ottawa-based “Presto Card” (Public Transit) Pilot Project has been completed, and opportunities are being examined to extend the initiative to regional offices.

Over the next three years, a national strategy will be put in place and implemented to roll out the public transit card to regions. The details and timing will be determined in consultation with regional offices.

Modernizing the Way We Work with the Courts

This initiative explores options for the Department to work with the Courts, Law Societies and the private bar to implement procedures and technologies in a more environmentally-conscious manner.

Why does it matter?

Working with the Courts and opposing parties to leverage clean virtual conferencing platforms and to digitize court documents will help to lower the environmental impact of government operations. The contribution this initiative provides to sustainable operations includes paper reduction, energy efficiency and reduction in travel; lowering our carbon footprint.

What will it look like?

The limitations imposed by the need for physical distancing as a result of the COVID-19 pandemic have forced the Courts to adapt and modernize by conducting hearings remotely and experimenting with video conferencing technologies.

Over the next three years, the Department, in collaboration with the Courts, will work to extend its use of these technologies. For example:

• E-commissioning affidavits on consent and with permission from the courts;
• Filing and serving materials electronically instead of by paper;
• Reducing in-person attendances where counsel can appear by video or telephone (e.g. case management conferences and largely procedural hearings; uncontested motions)

Strategic Environmental Assessment (SEA)

In addition to the work undertaken under the framework of the sustainable development program, the Department of Justice will continue to ensure that its decision making process includes consideration of FSDS goals and targets through its SEA process. An SEA for a policy, plan or program proposal includes an analysis of the impacts of the given proposal on the environment, including on relevant FSDS goals and targets.

Public statements on the results of Justice Canada’s assessments are made public when an initiative that has undergone a detailed SEA. The purpose of the public statement is to demonstrate that the environmental effects, including the impacts on achieving the FSDS goals and targets, of the approved policy, plan or program have been considered during proposal development and decision making. (Note: due to the nature of Justice Canada’s policies and programs, no initiatives have required a detailed SEA to date; however here is the link to the Department’s general SEA site.)

Justice has established a single-window hub for SEA guidance and tools to facilitate early reflection on environmental considerations in the development of advice for Ministers and/or Cabinet. The SEA questionnaire and guidelines provide a customized, step-by-step procedure that enables Justice Canada employees not only to complete the SEA preliminary scan and detailed SEA (if required), but understand the context and rationale underpinning this activity.