Cleaner Air for Scotland 2: consultation

Consultation on a draft new air quality strategy for Scotland, taking into account the recommendations arising from the independent review of the Cleaner Air for Scotland strategy.

2. Integrated Policy

35. The public health effects of indoor air quality and noise pollution correlate strongly with those of outdoor air pollution. Similarly, there is significant overlap between the measures needed to address climate change and improve air quality in areas such as transport, agriculture and industrial emissions.  Effort to address these issues in a more co-ordinated way offers additional likely co-benefits.  Improving air quality makes an important contribution to the United Nations Sustainable Development Goals[26] and the Scottish Government’s National Outcomes[27].  In a wider context, further progress in embedding placemaking principles across all policy areas will deliver benefits for both physical and mental health through creating better urban spaces that are more attractive to spend time and easier to move around in.

36. CAFS 2 must work in tandem with other key Scottish Government strategies, notably the National Transport Strategy 2, Climate Change Plan[28], National Planning Framework and Infrastructure Investment Plan, in order to achieve the vision for Scotland to have the cleanest air quality in Europe. Clear synergies exist between these strategies.

37. It is crucial that our transport and placemaking agendas interact in a way that drives tangible and measurable emissions reduction, whilst enabling great places where people live, work and play to become even more connected, accessible, affordable and efficient.  

Air pollution and climate change

38. Greenhouse gases and air pollutants share common sources, notably transport, energy generation and land use practices, and will thus benefit from many of the same policy interventions.  Some air pollutants can also act as greenhouse gases (e.g. ozone) or contribute to their formation (e.g. nitrogen oxides).  Conversely, changes in the climate will impact on air quality; increases in temperature may affect ozone formation, increasing the frequency and severity of summer smogs, and increase emission rates of ammonia. At the same time, air pollution and climate change generally act at different scales, both spatially and temporally.  Greenhouse gases are most active high up in the atmosphere, whereas the most important factors for air quality are the location and level of concentration of pollutants nearer the earth’s surface, with increased impacts near emission hotspots.  There are also complex relationships and trade-offs between the various pollutants that need to be managed.  For example black carbon makes a significant warming contribution, besides being an important component of PM.  Reducing such emissions therefore has a clear benefit for both climate change and air quality.  On the other hand, whilst reducing sulphur dioxide emissions has been positive for both public health and the environment, atmospheric cooling from sulphate or “white” aerosols (secondary PM) it helps to form is also reduced.

39. With transport being Scotland's largest greenhouse gas (GHG) emitting sector[29], the NTS climate action and health/wellbeing priorities highlight the crucial role of transport in delivering improvements to both climate and air quality emissions.  Actions on climate change and air quality can present policy interlinkages and offer tangible co-benefits[30]in a way that supports delivery of our air quality vision[31]

40. Employers across all sectors are adapting Carbon Management Plans (CMPS) to formulate GHG strategies that support the net-zero agenda[32] and circular economy.  In doing so, many CMPs are broadening their reach beyond traditional aspects such as estate energy management and travel planning, but we should not lose sight of these core tenets, particularly given the thinking and lessons learnt around homeworking and estate management prompted by the COVID-19 pandemic.  

41. In 2016, the CAFS Governance Group commissioned a report ‘Synergies and tensions between climate change and air quality actions’[33]. The report, including 50 key recommendations, was intended to help inform the 2018 Scottish Climate Change Plan. The report also contributed to the work of a UK cross-department group that has been set up to explore the requirements and opportunities for cross disciplinary research to provide a stronger evidence base for analysing the synergies and tensions of policy and regulation of air quality and climate change.  Of the 50 recommendations made in the report, 38 presented strong evidence of synergies between tackling climate change and improving air quality simultaneously. 

42. By 2018, Scotland’s source greenhouse gas emissions had declined by over 45% since 1990.  The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019[34] sets a target of net zero emissions of all greenhouse gases by 2045.  The Act also sets a 75% emissions reduction target for 2030, and 90% by 2040, from a 1990/95 baseline.  The Scottish Government is updating its current Climate Change Plan[35] to account for the new targets in the 2019 Act.  The Climate Change Plan update will be published later this year and will set out plans for a green recovery from COVID-19, alongside a strategy to meet future emissions reduction targets.  Building on the initial policies set out in the Scottish Government’s Programme for Scotland 2019-20[36] to end Scotland’s contribution to climate change, the updated Climate Change Plan will contain a wide range of measures that will provide air quality benefits and aligns closely with the aims of this strategy.  

43. A key part of the Scottish Government’s approach on climate change is ensuring a just transition. This means reducing emissions in a way which is fair for all and leaves no-one behind. The Climate Change (Emission Reduction Targets) (Scotland) Act 2019 contains a set of just transition principles, that Ministers must have regard to when setting out plans to reduce emissions. 

44. To further support the application of just transition principles, the Scottish Government established the Just Transition Commission to advise Ministers on how we can maximise the economic and social opportunities of meeting our climate change targets, while managing the challenges.[37] The Commission published its interim report in February 2020, and is due to deliver its final report to Ministers in early 2021.

45. The Scottish Government’s approach on just transition is in line with the desired outcome of better air quality. Embedding just transition principles in Government policy will therefore help deliver a win-win in the form of reduced greenhouse gas emissions and improved air quality for people all over Scotland, in turn ensuring the benefits of climate action are shared widely.

Air pollution and noise

46. As yet there are no fixed noise level targets in Scotland or the rest of the UK.  In 2002 the EU adopted the Environmental Noise Directive which stipulates that measurements must be taken of ambient noise, with the results being made publicly available and action plans for noise reduction must be agreed.  The World Health Organisation (WHO) published guidance in 2018 on environmental noise levels taking account of existing health effects evidence[38].

47. In Scotland’s four biggest cities, it has been estimated that over one million people are exposed to noise levels in excess of the WHO guidelines during the daytime and over 0.8 million during the night, with evidence indicating that deprived communities suffer more[39].  The health impact costs have not been directly estimated in Scotland but, based on WHO estimates elsewhere, may be considerable.  

48. As with urban air pollution, the major source of ambient noise is road traffic.  The adverse impacts of air pollution are closely correlated with those of noise, making it difficult to assess the impact of traffic noise on health separately.  However, this does mean that many interventions aimed at reducing traffic sourced air pollution are also likely to help reduce excess traffic sourced noise.  These interventions range from traffic reduction in urban areas to physical solutions such as green barriers along roads. 


We will:

  • Work with local authorities to ensure that noise action plans are closely aligned with air quality action plans to deliver co-benefits.  Guidance will be produced to facilitate this.
  • Ensure that all actions taken by the Scottish Government to address air quality maximise the potential for co-benefits with climate change mitigation and adaptation. The 50 recommendations for maximising co-benefits set out in the CAFS Governance Group climate change report will be used to guide this process.  We will work with local authorities to ensure that a similar approach is taken at local level.
  • Ensure that actions in the Scottish Government’s Climate Change Plan maximise co-benefits for air quality.

Questions on integrated policy

2. Do you agree with the package of actions put forward in the integrated policy chapter? 

A) Yes

B) No

C) Neither agree nor disagree

Additional comments in support of your answer

3. What in your opinion and/or experience are the barriers to cross departmental working within local authorities or other organisations on air quality and how can these barriers be overcome?



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