Infrastructure investment plan 2021-2022 to 2025-2026 - draft: consultation analysis
Independent analysis of consultation responses to the Scottish Government's Draft Infrastructure Investment Plan 2021-22 to 2025-26. The consultation ran from 24 September 2020 to 19 November 2020.
6. Assessing Greenhouse Gas Emissions Impact
6.1 The Scottish Government has used broad categories of low, neutral and high carbon (known as a taxonomy approach) to explain the climate impact of its infrastructure investment.
6.2 When considering the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, Parliament agreed that a new methodology should be developed to improve assessment of the contribution made by infrastructure investment to Scotland's emissions targets.
6.3 This was informed by some research the Scottish Government undertook (Greenhouse gas emissions and infrastructure investment decisions), which concluded that a new approach will take time to develop. In order to inform the best way forward, the research presents four options that should be considered (and the strengths and weaknesses of each has been considered):
1. Updated Taxonomy.
2. Absolute Emissions.
3. Baseline and Intervention.
4. Gap Analysis.
6.4 The Scottish Government is minded to further explore the use of Baseline and Intervention and Gap Analysis approaches which we believe will provide a more useful and meaningful assessment than the current taxonomy approach. The development of the new approach using one of the methods (or a combination of them) is likely to be an iterative process and will require substantial work to establish the new framework and collect the necessary data.
Do you support the planned approach to developing a new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets?
6.5 Almost three-quarters of respondents support plans to develop a new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets (54, 72%), Table 6. Relatively equal proportions of individuals and organisations agree, albeit organisations within the Travel and Transport sub-group are more likely to have mixed views.
6.6 One-fifth of respondents are unsure about the planned approach (15, 20%), and relatively few respondents do not support the proposed approach (six, 8%).
|Construction and Built Environment||12||80%||1||7%||2||13%|
|Natural Environment and Climate Change||6||67%||1||11%||2||22%|
|Travel and Transport||4||40%||3||30%||3||30%|
|Energy, Telecoms, Water and Waste||5||100%||0||0%||0||0%|
|Business and Enterprise||5||100%||0||0%||0||0%|
|Health, Education and Public Services||2||100%||0||0%||0||0%|
N=75. Percentages do not add up to 100 due to rounding.
Please explain and support your response with evidence?
6.7 In the main, the vast majority of respondents welcome action being taken by the Scottish Government to develop a new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets.
6.8 Many respondents acknowledge the limitations of the current taxonomy approach. The most common feedback notes that the current approach is too "simplistic", "basic", that it is "out of date" and/or fails to gather sufficient quantitative data.
6.9 The general view provided is that the current taxonomy approach does not capture and assess the full impact of emissions made by infrastructure investment. In the context of ambitious national emissions targets to be met by 2030 (75% reduction in greenhouse gases) and 2045 (net zero), the consensus among respondents is that the current approach is not fit for purpose, and that developing a new approach is both crucial and urgent.
6.10 Regardless of how consultation respondents answered Question 4a, the main point raised is that the new approach should include consideration and assessment of the emissions throughout the whole lifecycle of infrastructure investment. This reflects similar points raised to previous consultation questions. Strong support is expressed that any new approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets should consider both "embodied emissions" and "whole life emissions".
6.11 For example, a carbon lifecycle assessment would "reflect embodied carbon from demolition, materials, transport and maintenance, as well as the operational carbon associated with heat and power". Some respondents went on to highlight how the whole lifecycle approach is particularly crucial given how infrastructure is "long-lived" and "locks in emissions and resilience patterns for decades".
6.12 The main rationale proposed for assessing whole lifecycle impacts is that this would allow more informed decisions on infrastructure investment to be made, and for a more meaningful assessment and accurate reflection of their contribution to national emissions targets to be established.
6.13 Following on from this logic, some respondents also state that the approach to assessing the contribution made by infrastructure investment to Scotland's emissions targets should be "holistic" and consider the wider "knock-on effects" of infrastructure investment, such as impact across range of sectors or impact on behavioural change and lifestyles (e.g. increased car usage). For some respondents, a whole lifecycle approach would have the benefit of avoiding "longer-term, potentially marginal, operational benefits at the expense of significant upfront carbon impacts within the most critical short-term timescales" which will be significant to avoid locking in emissions related to infrastructure investment.
6.14 In terms of explicit reference made in the consultation responses to the four options set out in the Draft IIP (Updated Taxonomy, Absolute Emissions, Baseline and Intervention, and Gap Analysis), most respondents note points that highlight and/or reinforce the strengths and weaknesses presented in Annex C of the Draft IIP.
6.15 Firstly, there is broad consensus that the most appropriate approach would comprise a combination of the different options.
6.16 There is also broad support for the proposal to explore further the use of Baseline and Intervention and Gap Analysis approaches. It is noted that this would provide a more useful and meaningful assessment than the current taxonomy approach. Specific comments about these approaches are noted below.
6.17 Benefits of the Baseline and Intervention approach noted by respondents in their consultation responses are that it can be used to:
- Quantify and assess trends and changes to a greater degree of accuracy (e.g. methodology is used within HM Treasury's Green Book and is internationally recognised as best practice).
- Set targets.
- Undertake comparative analysis between different types/scale of infrastructure projects.
- Could accommodate/utilise the proposed dashboard style reporting.
6.18 Further, respondents (across most organisation sub-groups but primarily Natural Environment and Climate Change) note that also adopting the Gap Analysis approach could be significant in helping to "identify the additional investment required to meet the emissions reductions targets" and thus anticipate investment needs.
6.19 Support for the Absolute Emissions option was expressed by relatively few respondents within the Other, Local Government, and Construction and Built Environment sub groups (with the absolute highest numbers in Other). Where comments are provided, it is considered "cumbersome" and/or "impractical". While challenges with this approach are noted, a few respondents report that, if a combination of approaches are to be adopted, then there may be merit in exploring whether some elements of Absolute Emissions can be incorporated as part of any new approach.
6.20 Even fewer respondents note explicit support for the Updated Taxonomy approach. These respondents were all single respondents from the Construction and Built Environment, Business and Enterprise, and Other organisation sub-groups. As above, the current taxonomy approach is largely viewed as not fit for purpose. However, a handful of respondents highlight benefits of the current approach - it is considered easy to understand and communicate to a non-technical audience. In addition, given the urgency of action required and potentially significant time and resources required to develop a new approach, these respondents also suggest that there may be value in using the Updated Taxonomy approach in the interim period until a new approach is developed, and to build capacity within organisations to implement any new approach.
6.21 Several respondents suggest that the development of a new approach could be standardised across different types of infrastructure investment and that there could be an aspiration for it to be "internationally recognised as best practice". These respondents are from a few organisation sub-groups including Local Government, Health, Education and Public Services, Construction and Built Environment, and Natural Environment and Climate Change (with the absolute highest number for Local Government). The main benefits of a standardised approach highlighted by respondents include:
- Comparable methodology and data and international benchmarking.
- Consistency of approach.
- Encouraging collaboration across organisations, sectors, governments, countries.
- Avoiding duplication of reporting.
- Greater shared understanding among stakeholders and users.
6.22 As noted in Annex C of the Draft IIP, some respondents reinforce how the development of a new approach would require substantial work to establish the framework and collect the necessary data. As such, the interim period is considered crucial in terms of ensuring that emissions from infrastructure are not locked in and progress is still made towards meeting emissions targets during this period, particularly the 75% reduction in greenhouse gases by 2030.
6.23 The main concern raised is that the development of a new approach might delay the shift to investment in projects that reduce carbon emissions. It is noted that such an approach does not align with, or support, the pressing need that "urgent" action is considered on all fronts to reduce carbon emissions.
6.24 It is further noted that this urgency, combined with the need to increase the pace of change to bring about the scale of change required to meet targets, could be reflected more fully throughout the Draft IIP. These points are reflected in the respondent quote below.
"CERG appreciate the complexity of the task and the time taken to establish new frameworks and assessment tools. However, we have significant concerns that there will be no change to the assessment of climate impact of infrastructure until the development of the next IIP. The urgent nature of the climate emergency and the long-lasting impact of infrastructure decisions which could lock in high carbon travel and energy use, means that action needs to be taken now particularly if we are to hit the 2030 target of 75% reduce in GHG emissions."
Climate Emergency Response Group
6.25 Another reason provided for not supporting the planned approach outlined in the Draft IIP to assessing the contribution made by infrastructure investment to Scotland's emissions targets is that it is not considered clear how the new approach would lead to changes in how decisions on investment infrastructure are made.
6.26 Finally, a couple of respondents raise concerns around the new approach in terms of it being overly burdensome or that it may pose additional barriers, particularly for smaller organisations with less resources and capacity to deal with new and changing requirements.
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