This report provides a summary of the responses to the consultation by the Scottish Government on its proposals for a new Climate Change Bill. The consultation began on 30 June 2017 and closed on 22 September 2017.
The Scottish Government announced that it would bring forward a Climate Change Bill to increase the ambition of the targets in the Climate Change (Scotland) Act 2009 in response to the Paris Agreement. The purpose of this consultation was to allow members of the public, organisations, and any interested parties to respond to the proposals to inform the development of the final Climate Change Bill.
A total of 19,365 responses were received, of which 19,092 were campaign responses with or without variation, coordinated by several organisations.
This report summarises respondents’ views by considering comments made in relation to each of the nine questions included in the Consultation Document. This executive summary provides an overview of some of the main themes and issues that arise in response to the consultation, and which are presented in greater detail in subsequent chapters of this report.
Updating target ambition
Respondents generally support the proposal of raising the ambition of the 2050 and interim greenhouse gas ( GHG) emission reduction targets; however, many perceive them as a minimum requirement and feel that they should be more ambitious. Some respondents are opposed to the proposed targets, and a few would prefer the 2050 target to remain at 80% GHG reduction from baseline levels, with the provision to increase it later. Some respondents feel that ambitious targets are important to achieve net-zero GHG emissions and to motivate continuing action.
Some respondents see interim targets as useful tools for monitoring progress towards the 2050 target. A few respondents express concerns about the feasibility of the 2050 and interim targets. Some respondents suggest that considering the feasibility of the various targets, that they should be set according to a non-linear approach.
Many respondents feel that a net-zero GHG emissions target should be set now, and should be reached before 2050. Other respondents support the proposal to include provisions in the new Climate Change Bill that allow for a net-zero target to be set at a later date, they value the flexibility this provides, particularly considering a current lack of feasibility evidence. Some respondents feel that the proposal reflects intention and ambition, and is important for global leadership and maintaining momentum in emission reduction. A few respondents provide suggestions for provisions around the setting of a net-zero target that should be included in the new Climate Change Bill.
Many respondents support the proposal to present annual emission reduction targets in the form of percentage reductions from baseline levels. They provide reasons such as percentages are easier to understand, negate the need to update targets to reflect new evidence, and enable comparison across countries and sectors. Those respondents who raise concerns note that a percentage format moves away from the format of global and national carbon budgets, and suggest publishing absolute figures alongside percentages.
Many respondents support the proposal to set annual targets as a direct consequence of interim and 2050 targets. They see this approach as sensible, and believe it will be clear if targets are not being achieved. Other respondents suggest a non-linear approach to setting annual and long-term targets.
Actual Scottish emissions
Many respondents support the proposal to set targets on the basis of actual emissions, removing the accounting adjustment for the EU ETS. They feel the proposal will improve accuracy, consistency, and transparency of the current system; and make communication about targets easier to understand. Some respondents believe that using actual emissions will better reflect progress and motivate further action. Other respondents suggest that both figures be reported in parallel, and a few oppose the proposal referring to perceived benefits of the accounting adjustment for the EU ETS.
Many respondents support the ability to update interim and 2050 targets through secondary legislation, but feel that this should only be allowed for increasing targets. Other respondents believe that decreasing targets should be allowed, but via primary legislation or the super affirmative procedure. Respondents who oppose the proposal feel that any changes require primary legislation, or that updating targets is wasteful and misrepresents performance.
Some respondents feel that scientific knowledge, technology, environmental considerations, and European and international law and policy are important criteria for setting or updating targets. Some respondents provide more detailed comments on the Scottish emissions budget, social circumstances, economic circumstances, and impact on remote rural and island communities. They highlight the importance of equality, intergenerational and international equity, and human rights and suggest additional criteria which they feel should be considered when setting or updating targets.
Reporting and future plans
Respondents generally prefer the current frequency (every five years) and duration (of 16 years) for future Climate Change Plans, but some provide alternative suggestions. Respondents who agree with the current frequency feel that setting plans every five years provides a suitable balance of flexibility and long-term stability. Some respondents feel that short-terms plans allow for urgent action and quicker adaptation to change; while others feel that long-term plans provide certainty and stability for long-term planning and investment for implementation.
Some respondents support the suggestion to create Climate Change Plans after the Paris Stocktakes, to avoid the need to update them. Respondents who are opposed to this proposal see it as an unnecessary delay to Scottish climate change efforts. Some suggestions include making provisional plans prior to the stocktakes, and updating them afterwards.
Respondents generally feel that the period for parliamentary consideration of Climate Change Plans should be 90 or 120 days as they believe a period of more than 60 days would allow for proper scrutiny and consensus-building.
Some respondents support the proposal to make up for any shortfall against targets in future Climate Change Plans, seeing it as essential to avoid missing future targets. Respondents who object to the proposal are concerned about a potential time lag between shortfalls occurring and remedial action being implemented. They suggest alternative approaches to deal with shortfalls.
Assessing the wider impacts of the proposals
Some respondents feel that the proposals would impact positively on people, improving quality of life and health, and an increase in income equality. Others say that details are lacking to be able to identify potential impacts. Respondents sometimes say that the Scottish Government has a responsibility to future generations to address climate change. They often reflect on the need for people to change their behaviour as Scotland transitions to a low-carbon economy, along with the barriers to behaviour change.
Many respondents say that the proposals will be beneficial to the Scottish economy, with increased employment in sectors such as renewable energy or electric transport, as well as research and development opportunities. They say that increased energy efficiency will reduce business costs. Other respondents say that the proposals represent a challenge to Scotland’s economy and businesses, and fear that there may be higher transport and energy costs, or increased taxation. Respondents often refer to the need for a just transition to a low-carbon economy, with input from a range of stakeholders and support available for businesses.
Respondents who comment on potential positive environmental effects of the proposals, say that the predicted effects set out in the Environmental Report are accurate. They support the use of evidence in the Report, and agree with its conclusions and recommendations. Often respondents say that additional assessments of the impacts of the proposals will be needed when they have been put in place. Some respondents suggest topics that they feel could be examined in greater detail in the Report, providing additional sources of evidence to be considered. Some respondents discuss the negative environmental effects of the proposals, as outlined in the Report, which are principally due to the need for new energy infrastructure. They request mitigation of these impacts through monitoring and project planning.
Other issues regarding the new Climate Change Bill
Respondents emphasise various broader issues relating to the proposals put forward in this consultation, including climate change impacts, the need for urgent action, and the Paris Agreement. Some respondents highlight the importance of global approaches in setting targets; such as global emissions budgets and the Climate Fairshares Model. They praise the Scottish Government for what they view as better than expected recent progress against current climate change targets, and feel that it is important for Scotland to maintain its position as a global leader in climate change mitigation. Many respondents provide various suggestions for the proposals and methods to achieve the proposed targets.