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 3: Targets based on actual Scottish emissions

This chapter addresses responses to question 6 about setting emission reduction targets on the basis of actual GHG emissions, removing the accounting adjustment for the EU emissions trading system ( EU ETS) as well as relevant comments in response to other questions and responses from letters or emails.

The Scottish Government proposes, in line with the CCC advice, to set all targets on the basis of actual GHG emissions, by removing the EU ETS adjustment. It is anticipated that statistics will continue to report GHG emissions on both actual and adjusted bases.

There are 190 responses to the closed section and 173 responses to the open section of question 6, [16] which asks:

Q6. Do you agree that all emission reduction targets should be set on the basis of actual emissions, removing the accounting adjustment for the EU emissions trading system ( EU ETS)? Yes/No (Please explain your answer)

3.1. Closed question

Chart 7: Responses to the closed question 6 [17]

Chart 7: Responses to the closed question 6

A large majority of respondents (177 respondents – 92 individuals and 85 organisations) who answered the closed question 6 (n=190) support the proposal to set emission reduction targets based on actual emissions, removing the accounting adjustment for the EU ETS. 13 respondents selected no to this question (11 individuals and 2 organisations).

3.2. Comments about setting targets based on actual Scottish emissions – question 6


Respondents who support the proposal believe that setting emission reduction targets based on actual emissions, removing the accounting adjustment for the EU ETS, will improve accuracy, consistency, or transparency of the current system. Some respondents feel that using actual emissions will be simpler, making communication and information about targets easier to understand. A few respondents think that it would make GHG emissions data collection easier.

‘Using actual as opposed to adjusted emissions will give a more clear and transparent measure.’ Public body

Some respondents say that setting and reporting on targets using actual emissions would better reflect progress and the impact of investment in reducing Scottish GHG emissions. Some respondents emphasise other benefits they believe this approach would provide, such as it would:

  • encourage decarbonisation across the Scottish economy;
  • increase accountability across sectors and businesses;
  • improve the likelihood of achieving targets;
  • allow for uncertainty, such as that of the withdrawal of the UK from the EU (see section 6.2.1); and
  • better achieve the desired outcome of mitigating climate change.

A few respondents emphasise that a tailored approach of setting targets based on actual Scottish GHG emissions considers progress to date and what is still achievable, making the targets more realistic, with an ability to measure achievability.


A few respondents are opposed to removing the accounting adjustment for the EU ETS for various reasons, including:

  • reliable measurement of actual emissions can be a challenge;
  • the EU ETS is an important tool and incentive for driving action;
  • by retaining the EU ETS adjustment it would maintain consistency in accounting and reporting across the UK and internationally; and
  • it will be inconsistent with previous targets and reporting thereby not representing Scottish progress.

Other comments on this proposal

Some respondents feel strongly that the EU ETS adjusted figures should be reported in parallel with the actual emissions. They believe that this would allow for comparison with international data and Scottish GHG emissions history; provide context; incentivise businesses; and assist the public in understanding the approach at the European level.

A few respondents raise various concerns that they believe need to be considered:

  • how the change in approach will impact Scotland’s progress to date;
  • how this decision will affect the ways companies reduce their GHG emissions; and
  • a risk of contradictory legislation and policy impacting on the targets.

A few respondents express a need for more information to state a position, such as:

  • detailed impacts of this proposal;
  • explanations of how measurements are made; and
  • the difference in the GHG emissions figures to understand if more ambitious targets could be set.

3.2.1. EU ETS and carbon trading

Some respondents support the proposed approach to set the emission targets based on actual emissions, removing the accounting adjustment for the EU ETS, due to various perceived problems with the EU ETS and carbon trading, such as the perceived inability of the EU ETS to encourage reducing emissions.

‘It should be noted that EU ETS does not account for all emissions from some EU ETS installations.’ Private sector organisation

Some respondents comment generally on carbon trading and the EU ETS, which is outside of the scope of this consultation. Some respondents are opposed to GHG emissions trading as they feel it is not an appropriate approach to mitigate climate change, as internationally, countries will be struggling to meet targets and as such won’t sell carbon credits. Some respondents feel that policies for industrial decarbonisation need to go beyond the EU ETS, and that provisions must be in place to prevent displacement of GHG emissions to other countries.

‘We also support the proposal to ensure policies for industrial decarbonisation, but these policies must go beyond EU ETS cap levels and include provision for mitigating displacement of emissions to other countries.’ Third sector organisation

Those respondents who value the EU ETS programme, believe it would prevent distortions in high energy industries (particularly in terms of industrial production export). They feel that Scotland should be advocating for greater GHG emission reductions, in the EU and internationally, and see involvement in the EU ETS as a platform for doing this.

A few respondents seek transparency in reporting and the publication of more information about EU ETS and use of international carbon credits.

3.2.2. Aviation and shipping emissions

Accounting for aviation and shipping emissions is addressed in this section of the consultation document. A few respondents specifically support the continued inclusion of Scotland’s share of International Aviation and Shipping emissions. They say it would support transparency, continuity, and ambition; and aid communication and understanding with the public.

‘Retaining in the new bill the current practice of including our share of international aviation and shipping emissions (ideally separately) will also help communication and understanding of the bigger picture with the general public.’ Individual

3.2.3. Suggestions

Some respondents provide suggestions for the data used in setting and reporting on targets:

  • include import and export GHG emissions data;
  • include consumption GHG emissions data;
  • include sector targets;
  • include other trading schemes data;
  • take account of local authority data;
  • provide baseline 1990 GHG emissions data to local authorities to enable more accurate reporting;
  • consider fugitive methane emissions;
  • identify polluters and sources of GHG emissions; and
  • incorporate flexibility to be guided by the best available carbon accounting practice and climate science.


Back to top