Climate Change Bill: consultation summary report
A independent summary report analysing responses to the public consultation on Scottish Government proposals for a Climate Change Bill.
Chapter 2: Proposals on updating target ambition
2.1. A more ambitious 2050 target and a complete set of interim targets – questions 1 and 3
This section addresses responses to question 1 about setting a more ambitious 2050 greenhouse gas ( GHG) emission reduction target, and question 3 about setting interim targets for 2020, 2030, and 2040; as well as relevant comments in response to other questions and responses from letters or emails.
Responses to questions 1 and 3a-c are summarised together below, as respondents address targets in a general manner and raise the same points across the 2050 and interim targets.
The Scottish Government proposes to increase the ambition of the 2050 target to 90% GHG emission reduction from the baseline, in line with the CCC’s advice that a 90% reduction in GHG emissions by 2050 would be more consistent with limiting temperature rise to 1.5°C than the current 80% target. The Scottish Government recognises that meeting the target will be challenging, but feels that increasing targets will strengthen their position as international leaders in tackling climate change.
The Scottish Government proposes, in line with the CCC’s advice, to update the interim target for 2020 to at least 56%, and to set new interim targets for at least 66% in 2030 and at least 78% in 2040. The CCC advise that the interim 2020 target should reflect actual Scottish GHG emissions (see Chapter 3), and should be updated for a reduction of at least 56% from baseline levels.
There were 206 responses to the closed section and 215 responses to the open section of question 1,  which asks:
Q1. Do you agree that the 2050 target should be made more ambitious by increasing it to 90% greenhouse gas emission reduction from baseline levels? Yes/No (Please explain your answer)
There were 198 responses to the closed section and 185 responses to the open section of question 3a,  which asks:
Q3a. Do you agree that the 2020 target should be for greenhouse gas emissions to be at least 56% lower than baseline levels? Yes/No (Please explain your answer)
There were 192 responses to the closed section and 186 responses to the open section of question 3b,  which asks: (Please explain your answer)
Q3b. Do you agree that a target should be set for greenhouse gas emissions to be at least 66% lower than baseline levels by 2030? Yes/No
There were 195 responses to the closed section and 189 responses to the open section of question 3c,  which asks: (Please explain your answer)
Q3c. Do you agree that a target should be set for greenhouse gas emissions to be at least 78% lower than baseline levels by 2040? Yes/No (Please explain your answer)
2.1.1. Closed questions about the targets
Chart 2: Responses to the closed questions 1, 3a, 3b, and 3c 
The majority of respondents who answered closed questions 1, 3a, 3b, and 3c, support the proposals:
- to set the 2020 target for GHG emissions to be at least 56% lower than baseline levels (n=198):
− 159 respondents selected Yes (82 individuals and 77 organisations),
− 39 respondents selected No (29 individuals and 10 organisations);
- to set the 2030 target for GHG emissions to be at least 66% lower than baseline levels (n=192):
− 117 respondents selected Yes (63 individuals and 54 organisations),
− 75 respondents selected No (44 individuals and 31 organisations);
- to set the 2040 target for GHG emissions to be at least 78% lower than baseline levels (n=195):
− 117 respondents selected Yes (63 individuals and 54 organisations),
− 78 respondents selected No (46 individuals and 32 organisations); and
- to make the 2050 target more ambitious by increasing it to 90% GHG emission reduction from baseline levels (n=206):
− 139 respondents selected Yes (80 individuals and 59 organisations),
− 67 respondents selected No (33 individuals and 34 organisations).
Some respondents who ticked ‘No’ however explained in the open question below that they want higher targets and the proposed targets are seen as a minimum requirement. 
2.1.2. Comments about the 2050 and interim targets
Higher 2050 and interim targets
Most respondents, including all campaigns (see section 7.2.1 for further detail), agree the need for ambitious targets but believe that the proposed targets are not ambitious enough. Many respondents would rather have the proposed targets than no targets or lower targets.
‘Yes, at least, but the target may need to be more ambitious to reach carbon neutrality by mid-century’ Private sector organisation
Many respondents provide various reasons as to why they think the proposed targets should be higher. These reasons include:
- net-zero GHG emissions should be achieved as soon as possible, by 2030, 2040, or 2050 at the latest;
- it is necessary to align with the Paris Agreement, United Nations Sustainable Development Goals ( UN SDGs), Global Carbon Budget, and other global climate commitments (see Chapter 6);
- it is essential to contribute to limiting the average global temperature increase to 1.5°C or 2°C;
- Scotland’s historic production of GHG emissions increases its current responsibility for emission reductions and higher targets are perceived as appropriate to align with the Climate Fairshares Model (see Chapter 6);
- to set an example and remain a global leader in climate legislation (see Chapter 6);
- the means to achieve greater reductions are believed to exist already and significant GHG emission reductions have already been achieved;
- further technological advances are expected to occur;
- scientific evidence is believed to show it is achievable and required;
- to drive innovation, policy, and investment;
- the severity, longevity, and onset of climate change impacts warrant greater ambition and urgent action (see Chapter 6);
- the updated 2020 target is not increasing ambition, as it is the same target according to a different accounting system;
- to avoid using up the carbon budget; and
- to cater for additional GHG emissions that are excluded (such as that of imported goods).
‘However, it is not ambitious enough to prevent the 1.5 degrees C as advised by the Paris Climate deal agreement, so more drastic action is required’ Academic or research organisation
Support for the proposed 2050 and interim targets
Many respondents who support the proposed 2050 and interim targets note agreement with the rationale in the consultation document and the CCC’s advice:
- to be ambitious while considering feasibility;
- to support the Paris Agreement and a limit of 1.5°C rise in global temperature;
- to show leadership; and
- to signal the direction of business and the Scottish economy.
Some respondents support the proposed targets in light of the need for action and ambition in response to climate change, and see them as an important step in reaching net-zero GHG emissions. Some respondents see ambitious targets as building on Scotland’s success to date and important motivators for continuing momentum. A few respondents feel the proposed targets will strengthen and support Scottish climate change policy and strategy nationally and at a local level, and see it as important for transitioning to a sustainable energy economy.
‘My views on allowing the interim and 2050 emissions reduction targets to be updated is that I agree with the CCC that a 2040 target should be set now as if we don't do something soon emissions can and will continue to damage and harm our planet’ Individual
Some respondents perceive interim targets as useful tools to monitor Scotland’s progress towards the 2050 target, that provide opportunities to see what areas need attention to meet the long-term target.
Opposition to the proposed 2050 and interim targets
A few respondents would prefer lower targets, for example the alternative option provided by the CCC to keep the 2050 target at 80% GHG emission reduction from baseline levels, with the provision to increase it later.
Respondents who oppose the proposed 2050 and interim targets provide reasons including the following:
- targets are not ambitious enough;
- zero-emissions need to be reached before 2040 or 2050;
- Scottish GHG emissions are not significant enough on a global scale to affect climate change;
- targets are not achievable;
- targets should be set according to a non-linear pathway (refer to Feasibility, below);
- it is unnecessary and too short a timeframe to change the 2020 target;
- the later targets are too far ahead to be relevant, as evidence changes; and
- impacts on the environment and Scottish population of the measures implemented to achieve targets (see Chapter 5).
‘…our output of any harm full emissions compared to the rest of the world is tiny and makes no difference at all’ Individual
Some respondents believe the targets are too ambitious and raise several concerns about feasibility including:
- financial restraints, limited capacity, and lack of technology would limit the ability to meet the targets;
- GHG emission reductions are not equally possible across all sectors, with some sectors being better placed to make significant contributions;
- GHG emission reductions to date are evidence that the targets are infeasible;
- GHG emission reduction can only be achieved if there is sufficient political motivation (see Chapter 6);
- the short timescale poses additional challenges to achieving the 2020 target; and
- targets rely on renewable energy and carbon sequestration.
‘At present, we consider that current spending constraints limit our ability, as a local authority, to meet more stringent targets’ Public body
A few respondents seek further evidence and information about how the targets will be achieved.
Some respondents believe that GHG emission reductions get progressively harder and more costly as greater reductions are achieved.
Some respondents describe a ‘curved trajectory graph’ (see section 2.3.5), in which the size of the area underneath the line represents the cumulative GHG emissions that will be emitted while meeting the interim and 2050 targets. They believe that with faster progress earlier and slower progress later, far less GHG emissions are released over all, even though the final target doesn’t change. For this reason, they call for a non-linear approach to setting targets.
A few respondents feel that more ambitious targets will be more viable towards 2040 or 2050, due to progress in technology, and suggest a non-linear approach with larger efforts to reduce GHG emissions later on.
‘…the rate of technological development in decarbonisation technology means it would be appropriate to weight reduction targets towards 2040 and 2050’ Private sector organisation
A few respondents suggest setting a range for allowable shortfall for targets. Some respondents make suggestions as to how the targets can be achieved, such as targeting specific sectors or implementing policy measures and financial incentives, an extensive list is provided in Appendix B.
2.2. A future target for net-zero emissions – question 2
This section addresses responses to question 2 about including provisions for a net-zero GHG emission target to be set at a later date in the new Climate Change Bill, as well as relevant comments in response to other questions and responses from letters or emails.
As part of this consultation the Scottish Government proposes, in line with advice from the CCC, to include provisions in the new Climate Change Bill to allow Ministers to set a net-zero emissions target for the second half of the century, subject to regular reviews of the evidence. The UNFCCC Paris Agreement sets a goal of reaching net-zero global GHG emissions during the latter half of the century, and the Scottish Government supports this aspiration. Highly ambitious, stretching targets are important to drive action, but equally it is important for targets to be credible and achievable. The CCC advise that the evidence is not available to set a domestic net-zero emissions target now.
As described in the consultation document the Scottish GHG inventory reflects emissions that are positive (where GHGs are emitted into the atmosphere) or negative (where GHGs are taken out of the atmosphere); negative emissions are subtracted from positive emissions to provide an overall net emissions figure. It is not clearly stated in the consultation document that targets are for net emissions, and set against a baseline that is a net emissions figure. When net emissions figures are used as a baseline, a 100% reduction would achieve net-zero emissions. This was not clear to some respondents, and as there was no definition of net-zero GHG emissions in the consultation document, there were some inconsistencies in responses.
The Scottish GHG inventory reflects emissions that are positive (where GHGs are emitted into the atmosphere) or negative (where GHGs are taken out of the atmosphere); negative emissions are subtracted from positive emissions to provide an overall net emissions figure. Net-zero emissions are achieved when the same amount of GHGs are emitted into the atmosphere as what is taken out of the atmosphere. When using net emissions figures, as in the proposals in this consultation, a 100% reduction in net emissions from baseline would achieve net-zero emissions. This was not clear to some respondents and has led to some inconsistencies in responses, with different interpretations of net-zero and 100% emission reduction.
There were 207 responses to the closed section and 210 responses to the open section of question 2,  which asks:
Q2. Do you agree that the Climate Change Bill should contain provisions that allow for a net-zero greenhouse gas emission target to be set at a later date? Yes/No (Please explain your answer)
2.2.1. Closed question 2
Chart 3: Responses to the closed question 2 
The majority of respondents (120 respondents – 67 individuals and 53 organisations) who answered the closed question 2 (n=207) support the proposal to include provisions in the new Climate Change Bill that allow for a net-zero GHG emission target to be set at a later date. 87 respondents selected no to this question (48 individuals and 39 organisations).
2.2.2. Comments about a future target for net-zero emissions
Some respondents provide reasons for supporting the proposal to include provisions that allow for a net-zero GHG target to be set at a later date. These reasons include:
- the required evidence is not currently available, it does not appear feasible at present, and it is too early to set a target (as per the rationale in the consultation document);
- the proposal provides flexibility as the net-zero target can be brought forward or pushed later as required, in line with future progress and evidence;
- including provisions in the Bill that allow for a net-zero target to be set at a later date is valuable to reflect intention, ambition, and long-term expectations, particularly in terms of global leadership (see section 6.2.3);
- showing commitment to net-zero GHG emissions by including provisions to set a target is important to maintain momentum in GHG emission reductions;
- reaching net-zero GHG emission is important;
- a premature push for net-zero could work against the credibility of GHG emission reduction targets; and
- including provisions in the Bill that allow for a net-zero target will support investment and development in technology and research.
‘We agree that allowing for future provision is reasonable given that current reduction paths cannot comfortably attain full carbon neutrality.’ Public body
Some respondents, including several campaigns, feel that achieving net-zero GHG emission is feasible and the target should be set now, showing opposition to the proposal to set it at a later date. A few respondents are concerned that with the current proposal, the net-zero target may never be set. Many respondents suggest a net-zero target, generally feeling that it should be reached before 2050. Some respondents feel that setting a net-zero emissions target now is important because they say:
- ambition is needed (see section 2.1) and it shows commitment;
- the extent and severity of climate change warrants it (see Chapter 6);
- it is necessary to limit the increase in average global temperatures to 1.5°C, in line with the Paris Agreement (see Chapter 6);
- it is valuable to show global leadership (see section 6.2.3);
- it is important to allow policy-makers, businesses, organisations, and individuals to plan for implementation; and
- it would lead to a shift in education, which would equip people for future jobs.
Suggested provisions for a net-zero target
Some respondents suggest considerations and approaches for provisions for a net-zero GHG emission target, including the following:
- a net-zero target should only be set when evidence shows that it is possible to achieve it;
- stagger the introduction of net-zero emissions targets per sector, initially piloting policy in sectors that are more likely to achieve it;
- on setting a net-zero target, the mechanisms to achieve it should be outlined;
- the target should be sooner rather than later, and the flexibility provided in this proposal should only allow for the target to be brought forward;
- the Bill should include a date by which the target should be set;
- the setting of a net-zero target should go to the Scottish Parliament as a formal amendment or revision of the Climate Change Bill; and
- the target should be given the appropriate legal status.
Some respondents refer to the feasibility of achieving net-zero emissions as discussed in the consultation document, where the CCC note that with current evidence it does not appear to be feasible. A few respondents feel that current perceived infeasibility shouldn’t prevent Scottish Government from setting a net-zero target, as advances in GHG emission reduction measures will make it achievable. A few respondents believe net-zero emissions will never be feasible.
‘With present technology, this is unattainable and unrealistic. Even in countries with massive renewables deployment it has not been achieved. In fact, Germany's CO2 emissions have not even reduced, let alone become zero’ Individual
A few respondents comment on the need for a clear definition of the term ‘net-zero’, that factors in carbon sequestration, import and export, and all sources of GHG emissions.
Some respondents did not directly answer the question, and highlight the importance of a net-zero or net-negative emissions target. Some respondents feel it is important to achieve net-zero emissions as soon as possible, without commenting specifically on the proposal. However, these respondents often indicated in the closed question that they support the proposal to include provisions in the Bill for a net-zero emission target to be set at a later date, which appears to contradict their views that net-zero should be achieved as soon as possible.
Some respondents provide suggestions as to how to achieve net-zero emissions ( Appendix B).
2.3. Consistent annual targets – question 4 and 5
This section addresses responses to questions 4 and 5, which both focus on how annual targets should be set.
Question 4 asks whether annual emission reduction targets should be presented as percentages, and Question 5 asks about automatically setting annual targets according to the 2050 target.
The 2009 Act makes provision for annual emission reduction targets to be set every year up to 2050. These annual targets are currently specified as fixed amounts of GHG emissions, measured in tonnes of carbon dioxide equivalent, and are set in five year batches through secondary legislation.
The situation in which long-term emission reduction targets are given in the form of percentage reductions from the baseline, and annual targets are given in the form of amounts of GHG emissions (in tonnes) has created confusion. Setting all targets in the Bill in the same form, but not both, would help ensure that targets remain consistent. Whilst the fixed amount form provides links to global and domestic carbon budgets, the percentage reduction form is much less sensitive to changes in the GHG inventory and is easier to understand. The Scottish Government proposes, in line with the CCC’s advice, to specify the annual targets in the Bill in the form of percentage reductions from baseline levels.
The 2009 Act requires annual targets to be set through secondary legislation. Annual targets are set in five year batches at least 12 years in advance. The Scottish Government proposes to set additional interim targets for 2030 and 2040 which raises the possibility that the annual targets could be set as a direct consequence of these long-term targets, rather than through separate secondary legislation. The annual targets from 2021 to 2050 would be calculated as a simple linear path between the 2020, 2030, 2040 and 2050 targets. These annual targets would be updated automatically if the interim and/or 2050 targets were updated.
There were 196 responses to the closed section and 180 responses to the open section of question 4,  which asks:
Q4. Do you agree that annual emission reduction targets should be in the form of percentage reductions from baseline levels? Yes/No (Please explain your answer)
There were 196 responses to the closed section and 176 responses to the open section of question 5,  which asks:
Q5. Do you agree that annual targets should be set as a direct consequence of interim and 2050 targets? Yes/No (Please explain your answer)
2.3.1. General comments about annual targets
Whilst question 4 and 5 ask about the way that annual targets should be set rather than whether annual targets are a good proposal, respondents share their views on the role of annual targets altogether.
Respondents who express support for annual targets feel that they are important to maintain focus on long term goals, keep momentum, and to highlight where progress is not on track to meet overall goals.
Some respondents oppose having annual targets, saying that the time frame between them is too short, making them vulnerable to fluctuations in progress that may be caused by economic, technical, and environmental changes. Some say that the annual targets will frequently be missed because of this and therefore will be undermined in their importance.
Some respondents suggest that the Scottish Government should communicate that annual targets are likely to be missed, and that there is an acceptable margin around them for achievement, but that the 2020, 2030, 2040, and 2050 targets are obligatory and must be achieved and enforced (see section 6.2).
On the other hand, some respondents say that all targets should be compulsory with repercussions for organisations that miss them, but to make them more achievable they should be every five years rather than every year, and set as a direct consequence of the 2050 targets.
2.3.2. Closed question 4
Chart 4: Responses to the closed question 4 
The majority of respondents (172 respondents – 87 individuals and 85 organisations) who answered the closed question 4 (n=196) support the proposal to present annual emission reduction targets in the form of percentage reductions from baseline levels. 24 respondents selected no to this question (20 individuals and 4 organisations).
2.3.3. Comments about annual emission reduction targets in the form of percentage reductions from baseline levels – question 4
Many respondents who discuss this proposed change feel that percentages are the best way to present the annual GHG emission reduction targets, giving various reasons such as:
- percentages are easily and universally understood across different levels of expertise;
- easier to visualise progress against overall targets than with absolute units;
- if the baseline is updated to reflect new evidence, targets will still stay the same; and
- because of the above reasons, percentages are easy to compare between countries, organisations, sectors and local authorities.
‘It is an easy way to visualise the relative change in consumption. GWh or similar units would be lost on the general public’ Individual
Some respondents feel that a wide understanding of percentages will be useful when communicating progress to the general public, whilst demonstrating the scale of the progress required by 2050. Some respondents comment that it is important as they feel that the Scottish Government needs to get the general public ‘on board’ if they are to meet targets.
Some respondents feel that the ability to easily compare targets, coupled with the clarity of progress presented by percentages, holds the Scottish Government accountable for their performance against annual targets.
Respondents frequently argue that, while they feel that percentages are a useful way of showing targets and progress, the Scottish Government must also publish absolute figures annually alongside them. These respondents give different reasons for this, including:
- to avoid losing sight of the total carbon budget;
- the absolute figures are helpful for breaking down carbon budgets further to a sector level, organisation level or even an individual level; and
- they bring transparency about changes made to the baseline and the impact of changes to progress.
A few respondents oppose the proposal citing various concerns as discussed below, such as the need to consider global emissions budgets (see section 6.1.4).
Some respondents, including some who support the proposal and some who oppose it, raise various concerns about the proposal. Some respondents have concerns about the use of percentages as annual targets. Most of these people say that a percentage format moves too far away from planning around global and national carbon budgets. They argue that whilst percentages are a clear way of demonstrating how far Scotland has come, they do not clearly demonstrate that there is an ultimate limit to the cumulative emissions that can occur before irreversible damage is caused to the climate, and how much more Scotland can emit before reaching this limit. These respondents feel that targets should be set by working backwards from carbon budgets, rather than looking forward from past performance.
‘The climate responds to the forcing effect of the cumulative absolute emission, not the emission relative to an arbitrary baseline. We encourage SG not to lose sight of this fact and to still give information on how percentage targets translate to absolute emissions when appropriate to the context’ Organisation
Many respondents refer to the Climate Fairshares Model (see section 6.1.6), arguing that the government must also focus on GHG emissions budgets in terms of absolute figures in order to fulfil the responsibilities that the Climate Fairshares Model sets out.
Several respondents make clear that the Scottish Government should evaluate whether percentage targets work as intended, and that they should be open to changing the method of measurement if it is not fit for purpose in practice.
Some respondents ask that the government provide clear guidance on how the actual figures and the percentages are calculated so that there is consistency of use between local authorities and organisations.
2.3.4. Closed question 5
Chart 5: Responses to the closed question 5 
The majority of respondents (159 respondents – 78 individuals and 81 organisations) who answered the closed question 5 (n=196) support the proposal to set annual targets as a direct consequence of interim and 2050 targets. 37 respondents selected no this question (29 individuals and 8 organisations).
2.3.5. Comments about setting annual targets as a direct consequence of interim and 2050 targets – question 5
Respondents who express support for annual targets being set automatically according to the 2050 targets, give reasons such as:
- it is common sense to derive short term targets from the overall targets;
- it will be clear if Scottish Government is falling behind targets, therefore holding them accountable for their performance against the agreed targets; and
- it aids public understanding and interest as the overall GHG emission reduction target is broken down into more digestible or comprehendible ones, and the short-term targets encourage consistent focus.
Some respondents support the method of setting annual targets automatically, according to overall targets, but reiterate their view that the overall targets are too low (see section 2.1). Some of these respondents specifically refer to the Global Emissions Budget and say annual targets should be derived from this in order to fulfil our targets set by the Climate Fairshares Model (see section 6.1.6).
‘Yes, so long as the interim and 2050 targets are set to take account of the need for rapid, early reductions and of the need to stay within our ‘fair’ carbon budget’ Community group or organisation
A few respondents oppose the proposal expressing various concerns, such as target trajectories and the need to consider a Scottish fair share of global emissions budgets (see section 6.1.4).
Some respondents support the concept of having annual targets working towards the 2050 target, but raise some concerns about the way they will be calculated and set. They echo concerns raised in section 2.1.2, Feasibility, arguing that year-on-year progress will not be consistent, as GHG emission reductions will be easier and cheaper at the beginning and become harder as time goes on, with a possible lull in the middle as the easiest reductions have already been achieved, but the technology for the tougher solutions is still being developed. Their thoughts are illustrated with the hypothetical scenario indicated with the dark blue line in Chart 6 below.
Some respondents say that if the annual targets are automatically set with a straight-line trajectory between current GHG emissions and the 2050 targets (light blue line in Chart 6 below), it could disincentivise early action as target reductions would be set lower than what is already achievable. They feel this would create a false perception that meeting the targets will always be easy and that there is little urgency on the matter, but in later years the targets would be too high and regular shortfall would undermine them.
Respondents often suggest that for this reason, annual targets should be tougher at the beginning and easier towards each decadal interim target (2020, 2030, 2040, 2050), as demonstrated with the hypothetical scenario indicated with the green line in Chart 6. The chart has been created only for illustration purposes.
Chart 6: Illustrative example  of cumulative GHG emissions with different approaches to long-term and annual targets
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