Scottish climate change adaptation programme 2019-2024: analysis of responses to consultation

Stakeholders' responses to consultation draft on Scotland's second statutory five-year climate change adaptation programme. The programme is due to be launched in autumn 2019.

5. Additional policies to include within the Adaptation Programme

Question 7: Are there any additional policies that should be included in the outcomes set out in the following pages?

5.1 There were 66 responses to Question 7. Of those 66 responses: 50 respondents answered 'yes' indicating that they thought additional policies should be included in the outcomes, six answered 'no' and ten were unsure. Fifty-nine respondents made additional detailed comments, including two who did not answer the 'yes/no/unsure' question. The summary of these detailed comments below is organised by the frequency with which views were identified from most to least prevalent.

Overall nature of responses

5.2 Of the 59 substantive comments, 45 made at least one specific suggested change or addition, 18 making suggestions specific to at least one particular outcome. The remainder (and many of those suggesting specific policies) made general comments including:

  • Calls to improve linkages between policy areas and adaptation.
  • Comments on broad policy areas such as planning, farming, food insecurity, waste management, soil health, oil and gas subsidies, culture, air traffic, deer management, freshwater catchment management, planning, fair trade, peatland management, air quality policies and legislation and Low Emission Zones.
  • For inclusion of climate change in the national curriculum.
  • Taking account of equality issues rather than merely physical impacts when identifying people 'vulnerable to climate change'.
  • An increased focus on cycling and active travel.
  • Consideration of the specific implications for island communities.
  • For a greater emphasis on culture and tourism.
  • One suggested that a number of the policies named relate to work during the first Scottish Climate Change Adaptation Programme (SCCAP 1). They felt these, therefore, would not be fit for purpose for the named visions and goals. This respondent suggested that it may be better to simplify this section given the significant difference between SCCAP1 and SCCAP2.
  • A small number suggested some of the policies cover climate change mitigation rather than adaptation e.g., Cleaner Air for Scotland Strategy.

5.3 Three respondents noted that many of the policies listed are already in place and that the document is drawing together other policy areas/instruments/drivers rather than influencing or directing change across government policy. For example, one describing it as a 'brochure of work already being undertaken with very little in the way of new proposals.' The point was made again that adaptation behaviours are predominantly focussed on individuals rather than organisations or sectors.

Key themes

Additional policies to include

5.4 Two thirds of the substantive responses (comments from 42 out of 59 participants) mentioned at least one additional specific policy, policy suggestion or programme/initiative to include or reference. Some of these included calls for new policy creation; others for reference to existing policies that participants felt to be of relevance, within the discussion. There were 17 specific mentions of outcome 1, 15 of outcome 2, 14 of outcome 3, 9 of outcome 4, 11 of outcome 5, 4 of outcome 6 and 4 of outcome 7. The additions suggested are grouped under headings below (note many were mentioned in relation to more than one outcome):


  • Access Strategies / Greenspace / Core Path Plans.
  • City Region Deals.
  • Core Paths Strategy.
  • Community Planning.
  • Designing Places.
  • Designing Streets.
  • Design Manual for Roads and Bridges.
  • Development plans.
  • Extending the Place Standard and the Place Principle.
  • Green Infrastructure Strategic Intervention.
  • Infrastructure Investment Plan.
  • Infrastructure Commission for Scotland.
  • National Park Plans.
  • National Planning Framework.
  • National Planning Framework 3.
  • National policy to mandate the use of green roofs, particularly for larger buildings in urban settings within flood risk Potentially Vulnerable Areas.
  • Open Space Strategy.
  • Reference to the Central Scotland Green Network (as a National Development in the National Planning Framework).
  • Regional Economic Partnerships.
  • Scottish Planning Policy.
  • Scottish Government Infrastructure Investment Plan.
  • Strategic planning through emerging regional strategies.


  • Active Travel Strategies & Long-term Vision for Active Travel in Scotland.
  • Additional place tools, such as those developed by the Scottish Wildlife Trust (SWT) or the Natural Capital Standard (NCS).
  • Learning for Sustainability 2030+ vision and outcomes.
  • Carbon Literacy for Communities.
  • Climate Ready Classrooms programme.
  • Climate Challenge Fund.
  • Climate Justice Fund.
  • Community Empowerment Act and associated policy.
  • Education for Sustainable Development.
  • Health and social care and the impacts of temperature, extreme weather.
  • Health and Social Care Strategic Plan and Locality Plans concerning developing and strengthening communities.
  • Inequalities Action Frameworks.
  • National Walking Strategy.
  • Physical Activity Plans / Strategies.
  • Place Standard Tool, The Place Principle and the Local Flood Risk Management Plan.
  • Regional resilience plans.
  • Resilient Communities Strategic Framework and Delivery Plan 2017-2021.


  • Blue Carbon Forum.
  • Climate Change Plan.
  • Flood Risk Management Act and policies on Natural Flood Management.
  • National Coastal Change Assessment super sites.
  • National Flood Risk Assessment & Rivertrack.
  • Policies which encourage businesses to reduce flood risk by increasing green space (de-paving) and retrofitting surface water measures, with appropriate incentives to do so.
  • Regional Marine Planning.
  • Reform drainage charges.
  • River Basin Management Planning.
  • Scottish Government-sponsored work to review drainage policy and guidance, and the Flood Risk Management Act (FRMA).
  • Scottish Water's Water Resource Plan.
  • SEPA's Sector Plan.


  • Fuel Poverty Strategy.
  • National Energy Strategy.
  • RIIO-GD2 and RIIO-ED2 – led by Ofgem.

Land use and biosecurity/diversity:

  • Agriculture Bill (post-Brexit) or implementation of CAP reform.
  • Biosecurity policies.
  • Land Use Strategy.
  • Historic Environment Scotland's Conservation Area Regeneration Scheme (CARS).
  • Invasive Non-Native Species (INNS) policies related to forestry.
  • Local Biodiversity Action Plans.
  • Muirburn Code.
  • National Ecological Network, as set out by Scotland's Biodiversity 2020 Route Map.
  • Plant health policies.
  • Policy for internationally designated sites for biodiversity.
  • Policy for Invasive Non-Native Species.
  • Route Map Big Step 3 Quality Greenspace.
  • Route Map Big Step 2 Investment in Natural Capital.
  • Scottish Forestry Strategy.
  • Scottish Biodiversity Information Forum Review outcomes.
  • UK Minerals Strategy.


  • Scottish Government Strategy on a Circular Economy.
  • Scottish Economic Strategy with consideration of adaptation being embedded within it
  • Leverage funding and financing mechanisms, such as Scottish National Investment Bank, the review of the Climate Challenge Fund, the UK Government's response to the Green Finance Taskforce, the UK Municipal Bonds agency and any UK government replacement to financing currently provided by the European Investment Bank.


  • Adaptation Scotland programme.
  • The British Standards Institute and International Standards Organisation (ISO) are developing a range of international and UK standards (ISO14090, ISO14091, and ISO14092 and a UK standard on adaptation pathways).
  • City Region Deals.
  • Civil Contingencies policies – Resilience Partnerships/Integrated Emergency Management.
  • Climate Week.
  • Emergency protocols that involve invoking a state of emergency and nation-wide mobilisation of emergency and military personnel which could arise under a number of eventualities. For example, social unrest due to food or fuel price spikes, a sudden influx of numerous climate refugees, food and water distribution and breakdown of supplies.
  • The British Standards Institute and International Standards Organisation (ISO) are developing a range of international and UK standards (ISO14090, ISO14091, and ISO14092 and a UK standard on adaptation pathways).
  • Hyogo and Sendai Framework for Disaster Risk Reduction.
  • Housing Beyond 2021.
  • Mainstreaming the approaches of UNFCCC and the Paris Agreement to climate change, UNISDR's Sendai Framework for Disaster Risk Reduction as well as the Sustainable Development Goals (SDGs) together.
  • National Waste Management Plan.
  • Our Place in Time: the historic environment strategy for Scotland.
  • Other standards have roles to play, such as BREEAM for the Built Environment (which includes an adaptation credit).
  • Strategic Transport Projects Review (STPR2).
  • Sub-National Partnerships – Partnership approaches such as Climate Ready Clyde, Edinburgh Adapts and Aberdeen Adapts are important mechanisms to accelerate adaptation at a sub-national level.
  • Recommendations of the Committee on Climate Change's Report on the Final Assessment of the First Climate Change Adaptation Programme for Scotland.

Comments on presentation/wording

5.5 Eight respondents commented on the presentation or wording of the policies discussed within the document.

  • Some of these commented on the complex and cross-cutting nature of the information and the difficulty of assigning policies to specific outcomes without creating repetition or omission. One felt that policies relating to the natural environment could be better-integrated across all outcomes. One commented that while the layout is useful to keep the consultation simple, some cross-referencing or coding of policy against the outcomes that it delivers would be helpful.
  • It was suggested that existing policies had been grouped under outcomes without the necessary detail to explain how the policies will together achieve specific progress related to the sub outcome[6]. An additional level of detail on existing policies was called for, spelling out how each policy will increase resilience or capacity for adaptation (the activities planned in the programme timeframe, their intended aims, responsible owners, timelines, and allocated investment for adaptation).
  • Another highlighted that although the document mentions that proposals are included alongside policies, proposals are not listed under all outcomes and it is not clear if this is because listed policies are considered sufficient for achieving particular outcomes.
  • A small number felt that an acknowledgement of any gaps, for example where the policies in place will not meet required outcomes, and an outline of any additional policies required during the lifetime of the plan to complement existing and planned policies listed in the consultation document would be helpful.
  • Two participants suggested this section could be simplified, asking for the removal of policies in this part of the document.
  • One pointed out that some of the measures listed as policies are not policies, noting, by way of example:
    • the Scottish Flood Forum is an independent organisation, not a policy.
    • The Place Standard Tool is a tool and not a policy.
  • One respondent made a few specific wording suggestions about how historic environment policy for Scotland has been described. These have been signposted to the Scottish Government for consideration:
  • Another noted that 'there is an assumption that climate change will stimulate outdoor pursuits; it should be noted that the opposite may happen in the event of extreme weather events, which may result in areas being waterlogged for extended period, for example.'

Ways the SG can support implementation

5.6 Six participants reflected on ways the Scottish Government could help to support adaptation. In their comments they called for:

  • Greater recognition of the negative impact of subsidising the oil and gas sector.
  • Supporting disadvantaged people to engage in climate change adaptation
  • Making climate change part of the Health and Wellbeing curriculum
  • Having a policy commitment to 'climate literacy' for all parts of society.
  • To ban all plastics unless recycled into new road surfaces.
  • To support the rollout of Smart Village Scotland, to help with communication.

5.7 Participants also shared a range of specific examples and evidence to inform policy development in the future. These have been signposted to the Scottish Government for consideration.



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