Chapter 6: Other issues regarding the new Climate Change Bill
This chapter addresses responses to question 13 that were not specific to any proposals referred in previous chapters; as well as overarching themes raised across multiple sections of the consultation, in response to other questions and responses from letters or emails. Responses to question 13 that are specific to the proposals of this consultation, are addressed in the relevant chapter.
There were 197  responses to question 13 which asks:
Q13. Please use this space to tell us any other thoughts you have about the proposed Climate Change Bill not covered in your earlier answers.
6.1. Climate change – targets and framework
6.1.1. Climate change and the new Climate Change Bill
Many respondents feel that the proposals in general are not ambitious enough. They often express concern about both the present and possible future impacts of climate change (such as sea level rise, poverty, and biodiversity loss) and express a strong desire for urgent action, above and beyond what is proposed in the Bill. Some respondents praise the Scottish Government for what they view as better than expected recent progress against current climate change targets.
‘The coming decades are crucial to halt catastrophic global warming but the proposals set out in the consultation paper do not contain the ambition or action required to deliver the Paris Agreement or to keep temperature increases below 1.5ºC.’ Individual
Some respondents draw attention to the Paris Agreement, and ask that action taken by the Scottish Government be in line with the intention of the Agreement to limit global temperature rise to 1.5°C. Some respondents believe that Scotland, as an early industrialised country, has a historic responsibility for GHG emissions and has benefitted from the industries which produce them. They say that Scotland consequently has a responsibility to contribute as much as it can to GHG emission reduction.
‘Whilst the Paris Agreement sets a goal of reaching net-zero greenhouse gas emissions in the second half of this century, industrialised countries such as Scotland, with a historical responsibility of contributing to climate change by burning fossil fuels, should cut emissions faster and reach net-zero well before that date.’ Organisation
A few respondents discuss climate change science, commenting that GHG emission reduction alone may be insufficient, given the existing greenhouse gasses present in the atmosphere from past human activity. They comment that effective GHG emission reduction may be complicated by poor understanding of natural carbon sinks.
Some respondents comment that the proposals are unlikely to have any effect on climate change globally, given Scotland’s relatively small contribution to international GHG emissions. A few respondents feel that the proposals are simply unnecessary. They feel the focus should be on adaptation to the effects of climate change instead of mitigation of Scottish GHG emissions. All comments related to specific proposals are described in the relevant chapters.
6.1.2. Interaction between the new Climate Change Bill and future Climate Change Plans
Many respondents criticise the proposed Climate Change Bill for not containing plans or specific measures for how climate change targets are to be met. They provide suggestions for measures to include in Climate Change Plans, these are summarised in Appendix B.
‘The new Climate Change Bill should not be restricted solely to targets and accounting measures, but should include policies to cut our emissions.’ Organisation
Some respondents comment more specifically on the interaction of the proposed Climate Change Bill with future Climate Change Plans. Comments on the timing of Climate Change Plans and possible alignment with the Paris Stocktakes are described in Chapter 4. Some respondents suggest that the new Climate Change Bill introduce requirements related to the production of future Climate Change Plans. They suggest that the new Climate Change Bill:
- introduce a requirement for Ministers to seek and publish advice from the CCC when forming Climate Change Plans; and
- require the Climate Change Plans to include metrics for measuring the progress of policies and groups of policies.
6.1.3. Definition and calculation of targets
Many respondents query the territorial basis used for calculating Scotland’s GHG emissions, referring to the carbon footprint of both importing and exporting, goods and services. Some respondents suggest that consumption-based GHG emissions should be measured, reported, and reduced. They express concerns that the rate of Scottish consumption GHG emissions may increase as territorial emissions are reduced. Others add that GHG emissions from exporting goods should also be accounted for, as well as emissions from the exporting process itself, such as shipping emissions.
‘The Climate Change Bill should require Ministers to measure and report annually not only on Scotland's production emissions but also its consumption-based emissions. There should also be targets in the Bill for reducing consumption emissions, and strategic actions to meet these targets should be incorporated into the policy making process.’ Organisation
Some respondents say that if consumption and shipping GHG emissions were included in reduction targets, then Scotland would bear more of its responsibility for increased GHG emissions elsewhere, such as in poorer countries that may themselves be disproportionally affected by climate change. Some respondents feel that the Scottish Government should consider the impacts of its proposals on people outside Scotland, particularly in light of the UK Government’s commitment to UN Sustainable Development Goals.
A few respondents query whether military operations, both domestically and internationally, are or should be included in GHG emission reduction targets.
6.1.4. Global emissions budget
Some respondents encourage the Scottish Government to adopt a different approach to setting targets. Instead of basing targets on a Scottish emissions budget, they say they should be based on allocating Scotland a portion of a global emissions budget instead (see Chapter 4). They say that if this approach was used, targets would be set to reduce Scotland’s GHG emissions sooner, limiting the Scottish share of global GHG emissions. These respondents feel that a reduced emissions budget is important as there is a threshold of global GHG emissions beyond which changes in climate may be irreversible and have catastrophic consequences.
6.1.5. ‘Fair’ and ‘safe’ principles
Some respondents emphasise the importance of the Scottish Government taking a ‘fair and safe’ approach to setting and updating GHG emission reduction targets. These respondents generally see ‘fair’ as Scotland’s share of the global emissions budget being in line with the principle of ‘common but differentiated responsibilities and respective capabilities’. They consider ‘safe’ to be a global emissions budget that will limit global warming to 1.5°C.
‘We therefore believe the Climate Change Bill should include clear definitions for, and mechanisms to achieve a ‘fair and safe’ budget for Scotland. The Paris Climate Agreement recognises that nations have common but differentiated responsibility and respective capabilities ( CDRRC) to tackle climate change. In practice, this means that historically high polluters and wealthier economies like Scotland will have to contribute more to the efforts to mitigate climate change.’ Third sector organisation
6.1.6. Climate Fairshares Model
The Climate Fairshares Model is a model based on the principles of ‘fair’ and ‘safe’ as described above, to set specific targets for all countries. It is a measurement of what is a fair share for each country and is advocated for by many international organisations. Respondents who cite this model value the principles on which this model is based.
A conservative global emissions budget is divided between all countries, and then adjusted according to:
- Responsibility: the cumulative GHG emissions of each country since 1850 which directly reflects a nation’s contribution to climate change;
- Capacities: the wealth and resources at a country’s command; and
- Sustainable development: allowances and thresholds to give room for developing countries to make progress.
Some respondents see this model as essential to consider in setting, updating, and delivering on targets. The model sets a target for the UK, and respondents suggest that these figures be extrapolated for Scotland to use as the basis for proposals in the new Climate Change Bill. They are concerned that various proposals for the new Climate Change Bill are not aligned with the Climate Fairshares Model, and in some cases even work against it.
A few respondents believe the Scottish Government is not taking an objective approach to climate change. They say the planet’s climate has always varied and that the dangers of climate change are exaggerated.
6.2. Broader political issues
6.2.1. UK withdrawal from the EU
Some respondents express concern about the possible effects of UK withdrawal from the European Union on implementation of the proposals, and seek more clarity on its possible impact. They express a sense of uncertainty about the future while negotiations are ongoing.
A few respondents refer to the possible effects of UK withdrawal on the EU ETS, and say that withdrawal could impact on UK policy and the balance of devolved and reserved matters. They say that the resourcing of sectors such as organic farming could be affected, and suggest that there may be a lack of workers with the skills required to implement the proposals. Further comments on the EU ETS are given in Chapter 3.
6.2.2. Political context and consistency of policies
Some respondents suggest that the Climate Change Bill be used to ensure that Scottish Ministers take consideration of Scotland’s climate change ambitions in all other areas of policy and budgeting. Some respondents give suggestions about how Scotland’s climate change ambitions could be more consistent with its policies and budgeting:
- Use the Climate Change Bill to create new legislative duties requiring the Scottish Government to align its budget with its climate change targets and plans.
- Close the perceived loophole in Section 94 of the Climate Change (Scotland) Act 2009, which respondents argue will force the publishing of more information about the long-term effect of each part of the budget on GHG emissions.
- Establish a low-carbon infrastructure commission to advise the Scottish Government on aligning major infrastructure projects with climate change targets and plans.
‘We believe the upcoming Climate Act could be used to ensure that Scottish Ministers have to consider the climate implications of Scotland’s spending plans.’ Organisation
Some respondents comment on the need for political will and a consistent national policy framework to ensure that targets are met. They say that wider collaboration is necessary, with allocation of responsibilities across sectors and localities. Some respondents call for strict legislation, including taxes and fines, to be put in place to ensure compliance with targets. Some of these respondents give different specific examples of where they feel Scottish Government policies are currently inconsistent with its climate change ambitions, and which therefore need to be altered:
- heating and waste management;
- road infrastructure projects;
- Air Departure Tax; and
- extraction of fossil fuels from the North Sea.
Some respondents say that future reductions in GHG emission will be more difficult than the reductions achieved to date, and as such feel that political action is important for meeting the proposed targets.
‘It will be necessary for the Scottish Government to ensure consistent application and consideration of this target, ensuring emissions reduction is embedded throughout all aspects of decision making, including but not limited to policy development, planning, regulation review and controls around manufacturing.’ Public body
6.2.3. Global leadership
Many respondents say that Scotland proved itself with the Climate Change (Scotland) Act 2009 to be a leading nation in addressing climate change. Some feel that Scotland is continuing to maintain a leading position, while others say that the Scottish Government’s proposals should be more ambitious to keep showing leadership.
Some respondents refer to the importance of setting an example for other nations, and often claim that it is appropriate to do so since Scotland has benefitted from the use of fossil fuels. Some respondents identify potential economic benefits from demonstrating leadership in transitioning to a low-carbon economy.
‘The legacy of our responsibility for historic emissions places an obligation on Scotland to take a lead in decarbonising our economy. Fortunately we are blessed with abundant renewable resources so are well placed to develop radically ambitious plans for climate action and re-establish Scotland as a true climate leader.’ Community group or organisation
6.3. Consultation process
Some respondents praise the Scottish Government for providing the opportunity for them to share their views on the new Climate Change Bill, saying that they appreciate that the government is trying to engage people in a decision that will affect them.
Some respondents are pleased with the consultation process itself, and comment that it was well organised, comprehensive, and that the provision of workshops was valuable for engagement. However, other respondents criticise the consultation process for various reasons.
The most frequent criticism that respondents give regarding the consultation process is that it was not sufficiently publicised, with several saying that they found out about it less than one day before the deadline.
A few say that the full consultation period was too short for members of the public to understand such a complex topic and digest the technical documentation, and that this meant they did not have sufficient time to understand the materials and properly compile their response.
Some respondents raise their doubt in the intentions of the Scottish Government, questioning whether the consultation process was meant to discourage engagement from the general public or from young people.
Several respondents, mostly organisations, suggest further consultation either on the Bill itself or on any plans drawn up in the future to achieve the targets set in the Bill and to integrate other policies.
Suggestions to improve the accessibility of the consultation include:
- offline methods such as a mailshot for those that are not online or do not watch television;
- more support for community groups to reply; and
- more public engagement such as social science surveys, deliberative public events, and use of social media.
Consultation materials and events
A few respondents comment that the consultation paper is well put together, saying that it is reasonably easy to follow, contains the appropriate level of technical information, and asks relevant questions.
However, other respondents say they struggled with the consultation materials, and say that they are too long, technical, assume too much existing knowledge, and are intimidating to the general public rather than user friendly.
Other respondents feel that the materials do not link to each other or relevant resources in a helpful way, and that it is difficult to navigate to reports and documentation referred to or to find the online resources from the hard copy materials. They suggest using hyperlinks in the text to address this issue.
A few respondents raise concerns that some charts are presented in a misleading way.
Several respondents feel that there is not enough detail, evidence or background in some of the sections of the consultation document. Some specifically mention the Environmental Assessment, suggesting that it should have been made available alongside the consultation, or that it should be hyperlinked to where relevant.
Other suggestions include:
- the document could have non-technical input to make it more user friendly; and
- a short summary of the relevant sections displayed alongside the questions.
A few respondents praise the questions asked in the consultation, saying they are clear and that the open questions allow for further comments.
However, the majority of respondents who comment on the questions criticise the wording of the question text and/or the options available.
They complain that they are leading questions, or that the yes or no options where not suitable as they can be ambiguous given the wording of the question:
Other respondents say that the questions are too narrow, restrictive or may lead to answers being miss-interpreted.
Several respondents say that they do not understand the question that they are answering, most commonly regarding question 7a (What are your views on allowing the interim and 2050 emission reduction targets to be updated, with due regard to advice from the CCC, through secondary legislation?). Some other respondents feel that the questions and the consultation document itself is not focused enough on how the targets will be achieved, and suggest more of a focus on plans and policy to move forward.