Draft Environment Strategy: consultation analysis

6. Questions on the Impact Assessments

Alongside the draft Strategy, the Scottish Government published a series of related assessments. These included:

• Strategic Environmental Assessment (SEA) for the Environment Strategy
• Draft Equalities Impact Assessment (EqIA)
• Draft Island Communities Impact Assessment (ICIA)
• Draft Fairer Scotland Duty Assessment
• Draft Children’s Rights and Wellbeing Impact Assessment (CRWIA)
• Draft Consumer Duty Assessment
• Partial Business and Regulatory Impact Assessment (BRIA)

This chapter presents the analysis of responses to Q13 to Q23, which sought respondents’ views on each of these assessments. Please note that full data tables for each closed question are available in Appendix A.

Strategic Environment Assessment (SEA)

Q13. Do you have any views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the Strategic Environmental Assessment (SEA)?

Among those answering Q13, half (50%) indicated they had views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the Strategic Environmental Assessment (SEA).

Additional comments in response to Q13 were provided by 49 respondents, highlighting the importance of strategy implementation and monitoring, ecosystems and biodiversity, and social impacts and engagement.

Strategy Implementation

The most common theme under this question was policy implementation, with a few respondents highlighting that positive and negative environmental impacts will depend on how this policy is delivered. Some respondents noted a general concern about the SEA's ability to properly identify and prepare for the negative environmental impacts of such a strategy.

A few respondents highlighted specific, unidentified, or unforeseen environmental impacts that they felt could occur due to policy implementation, such as the impacts of solar and wind farms, resource-use impacts, landscape quality, vulnerable communities, and habitat disruption. Unidentified negative environmental impacts from the implementation of solar and wind farms were cited as a concern due to the carbon footprint associated with building these farms relative to their short lifespan, habitat disruption and release of stored carbon due to these large-scale infrastructure projects. Impacts of resource-use were also noted, with a few respondents suggesting negative environmental impacts that had not been considered, including the move to net zero could increase material extraction, leading to the overexploitation of natural resources locally and overseas, and potentially “unintended consequences for soil, water, cultural heritage and landscapes”.

Further unidentified issues that a few respondents felt could potentially arise from policy implementation included the unintentional introduction of non-native species through restoration projects, distributional inequities such as localised pollution, which may unintentionally burden local or vulnerable communities, and a reduction in landscape quality caused by large-scale infrastructure changes.

Monitoring

Several respondents noted that some impacts may develop over time and cannot be foreseen within the Environment Strategy or SEA, making robust and ongoing monitoring an important part of implementation. Some respondents also highlighted specific elements within the SEA where monitoring was perceived as underrepresented, such as surveillance of zoonotic diseases linked to climate change mitigation strategies, such as forestry, or waste-related crime related to changing waste policies.

Ecosystem services

The second most prevalent theme was delivery of multiple outcomes by ecosystems, with some respondents highlighting several additional or underrepresented potential positive ecosystem delivery impacts from the draft Strategy. A few respondents suggested that the role of various ecosystems was underrepresented, highlighting grass-based sheep systems, suggesting they contribute to soil health, biodiversity and carbon sequestration. Another respondent highlighted the positive impacts of managed woodland for renewable fuel supply, promoting biodiversity, carbon capture and rural landscape resilience. Land management was also highlighted as contributing to biodiversity, such as woodland management creating new habitats, which some respondents felt were underrepresented.

Engagement

Engagement was the third most prevalent theme under this question, with one respondent noting that the draft strategy “feels very top down”. Several respondents highlighted that greater community participation could generate additional positive environmental impacts not fully recognised in the SEA. These respondents suggested public education combined with community-led conservation initiatives could empower local communities to engage in environmental stewardship and support behaviour change from connectedness to nature. Another respondent, conversely, highlighted the consequences of failing to engage with local communities, resulting in insufficient support for implementation at the local level. The issue of behaviour change was also highlighted; one respondent called for the SEA to detail research regarding behaviour change to achieve emission reductions, as “people as a whole are resistant to change”.

Land Reform

Several respondents suggested that the SEA fails to identify the environmental significance of land ownership, with one respondent noting that “The Land Reform Acts (Scotland) are not listed in Annex A” despite the pattern of land management being of “fundamental importance [in] restoring the relationship between humans and nature”. Additionally, farm support reform and resulting land use change were highlighted by one respondent as needing to be assessed in further detail in the SEA to ensure farming delivers “biodiversity gains, reduced pollution and healthy soils”.

Social Impacts

Positive social, community and health impacts were also noted, such as “sheep farming supporting open landscapes that enable responsible public access”. Several respondents highlighted the cumulative benefits of landscape-led planning, which integrates nature, climate, and social objectives. These included greater access to green spaces, improved air quality, warmer homes, and the promotion of healthier diets.

Negative impacts

A few respondents noted some potential negative impacts of the draft Strategy that could affect ecosystem delivery, such as the landscape impacts of changes in land use, such as wind farm developments. Several respondents suggested that landscape-scale delivery should be further assessed to ensure clearer delivery mechanisms for ecosystem services and promote biodiversity.

Draft Equality Impact Assessment (EQIA)

Q14. Is there anything in the draft Environment Strategy which should be added or changed to strengthen positive impacts or lessen any negative impacts on people with protected characteristics?

Among those answering Q14, 57% felt that aspects of the draft Strategy should be added or changed to strengthen its positive impacts or mitigate any negative impacts on people with protected characteristics.

Comments in response to Q14 were left by 35 respondents, highlighting potential changes, including targeted actions, co-production, increased accessibility, views on potential policy impact, sustainability, and monitoring.

Targeted actions

Many respondents emphasised the need for more targeted actions to ensure the Strategy delivers equitable benefits across all protected groups. They called for specific measures to remove barriers faced by disabled people, older adults, and minority communities in accessing environmental improvements. Some respondents emphasised the importance of directing investment to disadvantaged areas where access to high-quality green space is limited, as well as designing programmes that address health inequalities, affordability, and resilience to climate risks. Several respondents also suggested that targeted initiatives should support underrepresented groups within green skills and employment programmes, including women, disabled people, and those from low-income or rural backgrounds, to ensure fair participation in the transition to a sustainable economy.

Co-production and inclusion

Several respondents recommended strengthening co-production and inclusive engagement within the draft Strategy. They suggested that people with protected characteristics should be meaningfully involved in planning, design, and delivery processes to ensure policies reflect diverse lived experiences. Community-led design was identified as an effective approach to build local ownership, foster trust, and ensure environmental improvements are culturally relevant and accessible. Some respondents also called for the inclusion of representative organisations in consultation and implementation processes, noting that long-term collaboration with equality, disability, and faith-based groups would improve both policy legitimacy and practical outcomes. Some attendees of the equality consultation workshop suggested that more research was required to build an evidence base on environmental inequalities linked to ethnicity, with current evidence based on experiences in England.

Accessibility

Many respondents highlighted accessibility as a fundamental issue that must be embedded across the Strategy. They urged the Scottish Government to ensure that access to green spaces, sustainable transport, and low-carbon services is equitable and inclusive. This includes step-free infrastructure, accessible signage and pathways, affordable access to services, and the design of inclusive public spaces that consider age, mobility, and sensory needs. Several respondents also noted that digital and financial access must be considered, as reliance on online systems and cost-based participation risks excluding those with limited digital literacy or financial capacity. Some attendees of the equality consultation workshop highlighted similar themes. They suggested that:

• Accessibility for disabled people is not well highlighted.
• Sustainability policies must consider the impacts on disabled people, for example, banning plastic straws.
• Emergency planning for disabled people in Scotland is weak as they are two to four times more liked to be injured in climate disasters.

Policy impact

Some respondents commented on the importance of recognising how broader environmental policies may interact with equality outcomes. Many noted that policies on energy transition, transport, and food systems can have disproportionate effects on low-income or rural households, disabled people, and women with caring responsibilities. A few stressed the need for a more balanced approach that integrates environmental goals with social justice, ensuring that measures such as restrictions on heating methods or vehicle use do not disadvantage vulnerable populations. Some respondents suggested that equality and human rights considerations should be incorporated systematically into policy appraisal, implementation, and impact evaluation.

Sustainability

A few respondents commented that the draft Strategy should take a more explicit position on long-term sustainability and the balance between economic, social, and environmental goals. They argued that subsidies and incentives must prioritise sustainable lifestyles and avoid supporting practices that harm ecosystems or perpetuate inequality. A few raised concerns about technologies such as carbon capture and storage, calling for an assessment of their potential health, environmental, and social implications to ensure that sustainability actions remain just, effective, and community-focused.

Monitoring

Several respondents called for stronger monitoring and enforcement mechanisms to track the impact of the Strategy on individuals with protected characteristics. Some respondents recommended that outcomes related to equality, health, and wellbeing should be systematically measured alongside environmental performance indicators. Some suggested local-level data collection and transparency reporting to identify where progress is uneven or where unintended negative impacts arise. It was also suggested that monitoring frameworks should include mechanisms for continuous feedback from affected communities to ensure adaptive and inclusive implementation. Some attendees of the equality consultation workshop felt the draft Strategy should include more detail on the quality of life indicators, suggesting that the development progress of those indicators has been poor.

Other comments

A few respondents provided other comments outside the above themes. These included calls for more impartial research and greater diversity within the environmental sector workforce. A few respondents also suggested that large-scale environmental projects should undergo equality impact assessments to prevent the displacement or exclusion of communities with protected characteristics. Some noted the need to embed equality and diversity principles within higher education and professional training to ensure that Scotland’s environmental workforce reflects the population it serves. Finally, some attendees of the equality consultation workshop suggested that the communication of the draft Strategy is making it inaccessible, particularly due to the wording of the draft Strategy and the lack of an easy-read format, as well as the digital-first approach to delivery, which may disadvantage a range of groups, including women, migrants, and older people.

Q15. Are there any positive or negative impacts on protected groups (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation) that have not been identified in the draft Equalities Impact Assessment?

Just under half (47%) of those answering Q15 felt there could be additional impacts on protected groups that have not been identified in the draft Equalities Impact Assessment, while 53% felt there were not.

Open comments were provided by 33 respondents, highlighting potential impacts based on protected characteristics.

Age

Some respondents highlighted that older adults may face disproportionate impacts from climate change and the transition to net zero, including greater vulnerability to extreme weather events, air pollution, and rising energy costs. The physical demands of agricultural work and the shift towards digital compliance systems were perceived as potential challenges for older farmers and crofters, who may require additional training and support to adapt. Some attendees of the equality consultation workshop highlighted that green jobs tend to be targeted at those aged 25-49, excluding older workers.

However, some respondents highlighted opportunities for improving health and wellbeing through access to green and blue spaces, which they felt could promote physical activity and reduce social isolation among older people. The importance of accessible design in transport, housing, and community infrastructure was repeatedly raised, with several emphasising that ensuring inclusivity for older people will benefit other protected groups.

Gender

Several respondents highlighted a range of gender-related considerations that they felt were underexplored in the draft Equality Impact Assessment. Several emphasised that women remain underrepresented in key green sectors, particularly in STEM, waste management, and energy, where they account for less than one fifth of the workforce and fewer senior roles. However, some respondents also pointed to positive examples of increasing women’s involvement in rural and conservation sectors, such as Women in Agriculture and Women in Shooting, which were seen as models for encouraging broader gender diversity across environmental programmes.

Several respondents recommended actions to improve gender equality in the transition to a net zero economy, including gender audits of policies, support for flexible training and apprenticeships, and returner programmes to encourage women back into technical roles. A few respondents also noted that safe, inclusive, and well-designed public and natural spaces are essential to encourage women’s participation in community and outdoor activities, with “safety by design” identified as an important principle for strategy delivery. Some attendees of the equality consultation workshop suggested that access to green space was a gendered issue, with women in rural and urban areas feeling unsafe, particularly at night due to a lack of lighting.

A few respondents raised concerns about the framing of gender inclusion policies, arguing that the draft EQIA should ensure clarity between sex-based rights and gender identity protections, and respect for religious or philosophical beliefs.

Disability

Some respondents highlighted a range of disability-related considerations that they felt were underexplored in the draft Equality Impact Assessment. Some emphasised that people with disabilities and older adults may experience disproportionate impacts from climate change and environmental policy, including heightened vulnerability to extreme weather, air pollution, and energy insecurity. A few respondents noted that accessibility barriers persist across green spaces, transport networks, and built environments, and that the shift towards active travel, electric vehicles, and energy-efficient housing must explicitly consider the needs of those with mobility, sensory, or cognitive impairments. A few respondents stressed that inclusive design standards, accessibility audits, and universal design principles should be embedded across all environmental programmes to ensure equitable participation and avoid unintended exclusion.

A few respondents highlighted opportunities for positive outcomes if accessibility and inclusion are prioritised in implementation. Accessible landscapes, well-designed public spaces, and inclusive community projects were seen as ways to improve mental health, physical wellbeing, and social connection for disabled people. Some respondents also noted that improved ferry links, accessible transport, and tailored advisory or funding schemes, particularly in rural and island areas, could help overcome existing inequalities experienced by disabled people. One respondent recommended that the Scottish Government adopt a “health in all policies” approach and develop guiding principles to ensure that sustainability measures do not inadvertently disadvantage people with disabilities, but instead enhance equality of access, resilience, and wellbeing.

Race

A few respondents noted that the draft Equality Impact Assessment could be improved to better reflect the intersection of environmental inequalities with race and socioeconomic status. Some highlighted that minority ethnic communities are more likely to live in areas with higher air pollution and poorer access to green space, meaning they may experience greater exposure to environmental risks. A few respondents recommended that the draft Strategy adopt a stronger environmental justice approach, explicitly recognising and addressing these disparities through targeted interventions and community engagement.

Two respondents pointed to low levels of ethnic diversity in green industries and environmental governance, noting that workers from minority backgrounds are underrepresented in key sectors such as waste management and energy. Strengthening inclusion in recruitment, leadership, and training programmes was identified as a way to ensure that the benefits of the green economy are shared more equally.

Religion or Belief

A few respondents raised the need to consider faith-based or philosophical perspectives in environmental policymaking. Some noted that green and outdoor spaces can hold cultural or spiritual significance for certain communities, and that improvements to access could strengthen cohesion and a sense of belonging.

A few respondents raised concerns about potential conflicts between environmental inclusion policies and religious freedoms. They urged the Scottish Government to ensure that equality measures are implemented in a way that respects all protected beliefs, and that engagement processes include a wide range of perspectives.

LGBTQ+

A few respondents noted that sexual orientation and gender reassignment were not explicitly addressed in the draft Equality Impact Assessment, despite evidence that LGBTQ+ people can be at higher risk from the effects of climate change and social inequality. Citing research such as the akt (2025) report, “there’s no place like home”, a few respondents noted that LGBTQ+ individuals are disproportionately affected by homelessness and housing insecurity, particularly trans and racialised young people. These vulnerabilities can compound exposure to environmental risks such as poor air quality or inadequate housing.

A few respondents suggested that the Environment Strategy should engage directly with LGBTQ+ organisations to better understand these risks and co-design inclusive solutions. Improved access to affordable, safe housing and community-based support was seen to address both environmental and social vulnerabilities. Some also emphasised that inclusive communication and visible representation are key to ensuring that LGBTQ+ people feel included in Scotland’s environmental transition.

Data

Some attendees at the health consultation workshop emphasised the need for data improvement to accurately understand how vulnerable groups may be affected by the draft Environment Strategy. They highlighted that existing data makes it difficult to understand the impacts on children, for example. Air quality and its impact on vulnerable groups were subjects considered to be important.

Q16. Are there any other protected groups, which have not been identified in the draft Equalities Impact Assessment, that will potentially be positively or negatively impacted by the Environment Strategy?

Over two thirds (69%) of those answering Q16 expressed the view that there are no other protected groups which have not been identified in the draft Equalities Impact Assessment, that will potentially be positively or negatively impacted by the draft Environment Strategy. The remaining 31% of those who answered felt other unidentified groups could be affected.

Twenty-two respondents provided an answer to this question, highlighting potential impacts based on caregiver status and age. Some respondents also highlighted rurality and socio-economic status as key factors that may potentially affect whether an individual is impacted by the draft Environment Strategy. These responses have been integrated into the analysis of Q17 and Q18, respectively.

Carers and unpaid support networks

Several respondents identified carers and unpaid family workers as a group that could experience indirect impacts from the draft Environment Strategy. Changes to public transport, service provision, or community infrastructure could affect their ability to provide care efficiently, particularly where travel times or costs increase. A few respondents recommended that accessibility and flexibility be built into local environmental initiatives to prevent added burdens on these groups.

Some respondents also recognised potential positive outcomes if these considerations are embedded early in policy design. Access to local green spaces, community gardens, and nature-based wellbeing projects was cited as an example of initiatives that can improve mental health, reduce isolation, and support carers' wellbeing.

Children and young people

One respondent highlighted that while children's rights are acknowledged elsewhere, their specific needs as a demographic group are not fully addressed in the draft EQIA. Access to outdoor learning, safe green spaces, and affordable participation in environmental programmes were all viewed as important benefits that should be explicitly recognised. A few respondents also noted that youth participation in rural and island areas can be limited by transport costs and availability, reinforcing inequalities in access to environmental education and employment pathways.

A few respondents recommended that the draft Strategy more clearly articulate how actions will enhance opportunities for children and young people, particularly in areas such as outdoor learning, skills development, and engagement in climate action, to ensure Scotland's environmental transition is equitable and future-focused.

Intersectionality

Some attendees of the equality consultation workshop suggested that the draft Strategy should have mapped out intersectionality, the issue of how different inequalities intersect. The example they provided was the issue of fuel poverty in the Highlands and Islands, which may be a result of geography, income, and other factors.

Other and cross-cutting themes

A few respondents suggested that the draft EQIA could be expanded to include other social or cultural groups that are not formally protected by legislation but are relevant to environmental outcomes. These included Gaelic-speaking communities, veterans, migrant workers, and faith-based groups whose collective activities contribute to community resilience and environmental stewardship. In addition, some respondents emphasised that animal welfare and veganism, as protected philosophical beliefs, should be recognised in the draft EQIA. The Vegan Society highlighted that plant-based transitions can yield environmental, health, and justice benefits, aligning with Scotland's sustainability goals. Finally, some attendees of the equality consultation workshop suggested that disability and sensory impairment were missing from the draft EQIA. They suggested that there could be consequences of policies such as sustainable travel policies if partially sighted people or people with other disabilities are not included. This included access to green space and accessible communications.

Draft Island Communities Impact Assessment (ICIA)

Q17. Are there any positive or negative impacts on island communities that are different from the impacts on mainland areas from the draft Environment Strategy, that have not been identified in the draft Islands Communities Impact Assessment (ICIA)?

Just over half (55%) of those answering Q17 felt there could be additional impacts on island communities that are different from the impacts on mainland areas from the draft Environment Strategy, which have not been identified in the draft ICIA.

Additional comments on the draft ICIA were provided by 22 respondents. Many highlighted infrastructure and connectivity, as well as economic resilience and local benefits, as the most prevalent themes. Other recurring themes included exposure to climate impacts, the cost of living and fuel poverty, waste and circular economy logistics, community capacity and participation, biodiversity and heritage, and sector-specific considerations.

Infrastructure and connectivity

The most prevalent theme concerned the transport and infrastructure constraints faced by island communities. Several respondents noted heavy reliance on ferries and air services, higher transport costs, weather-related disruption, and gaps in electric vehicle charging and digital connectivity. It was felt that mainland models for active travel and public transport may be unrealistic in some island settings without tailored approaches.

Economic structure and local benefit

The second most prevalent theme, raised by many respondents, related to the fragility of island economies and the importance of local control and benefits. These respondents were concerned that land reform, large-scale rewilding or decarbonisation could reduce traditional activities without viable alternatives, and that islands risk being used primarily as carbon offset locations or to generate energy that is sent elsewhere. Several respondents cautioned that green energy schemes leasing land to external firms without clear community benefit could disempower islanders, and asked that policies support population retention, local ownership models and economic sovereignty. Several respondents highlighted that community-led energy projects could be an opportunity, provided they retain local value.

Many respondents noted that the prominent economic sectors in rural areas faced specific challenges. Several respondents highlighted the challenges faced by the seafood sector, including cumulative regulatory and spatial pressures, higher logistics costs and the importance of stable year-round employment in coastal and island communities. Some respondents highlighted similar challenges for farming and crofting, recommending support for farmers to adopt nature-friendly practices, diversify, and access local markets. Some respondents highlighted the potential for job creation in marine-based renewables, conservation and nature-based tourism. They highlighted the importance of opportunities for young people to remain in or return to islands, including training and green skills pathways linked to local projects.

Climate impacts and adaptation

Several respondents highlighted disproportionate exposure to sea level rise, coastal erosion and extreme weather on islands. They supported place-based adaptation strategies that protect settlements, heritage and tourism-dependent landscapes. Some respondents raised concerns about perceived trade-offs between large energy or grid projects and valued scenery and nature-based recreation, with implications for wellbeing and tourism.

Cost of living, fuel poverty and energy efficiency

Several respondents described how island homes can be less energy-efficient and face higher energy costs, thereby increasing the risk of fuel poverty. Some respondents highlighted grid fragility and noted that modern stoves can provide resilience when the electricity supply is unreliable. A few respondents requested targeted support for affordable and reliable heating in island settings.

Waste and circular economy infrastructure

Several respondents noted that islands face higher costs and fewer options for waste and recycling, including limited local facilities and a reliance on mainland transport. They reported higher burdens from marine litter, including aquaculture and fishing-related materials, with concerns about volunteer fatigue in small communities, and asked for ring-fenced support for clean-up capacity and practical disposal routes. Some respondents supported investment for on-island consolidation and reprocessing pilots, as well as realistic waste and recycling logistics where anaerobic digestion or energy-from-waste facilities are not available locally. A few respondents noted data gaps and underrepresentation of islands in national marine monitoring, and requested improved island-specific monitoring to inform policy.

Biodiversity and heritage

Some respondents emphasised the unique biodiversity and habitats of Scottish islands, including machair, Celtic rainforest and globally important seabird populations. They cautioned that otherwise positive actions can have unintended effects in sensitive island environments, and asked that the ICIA reflect these potential “green on green” tensions.

Views on the draft ICIA

Several respondents considered the draft Strategy too broad to assess confidently without fuller cumulative analysis for islands. Some respondents disagreed with the view that a full ICIA is not required, citing different costs and delivery realities for island settings. They requested island-tailored scenarios, clearer modelling of transport and logistics, and greater consideration of island-specific data and monitoring. Some respondents suggested that the challenges faced by rural communities merit consideration in equality assessments, with the recommendation that the Scottish Government apply the Rural Assessment Toolkit to the Environment Strategy.

Mitigation

Several respondents suggested measures, including ring-fenced funding for island infrastructure and services, rural and island-specific scheme payment rates, community benefit and local ownership clauses for energy projects, targeted support for farmers, crofters, and seafood SMEs, improved ferry reliability and digital connectivity, and practical solutions for waste and marine litter. Some respondents called for sustained engagement, youth pathways into green skills, and island-specific monitoring to track impacts over time.

Draft Fairer Scotland Duty Assessment (FSDA)

Q18. Are there any positive or negative impacts on groups experiencing socio-economic disadvantage (such as income, low wealth or area deprivation) from the draft Environment Strategy that have not been identified in the draft Fairer Scotland Duty?

Views on the draft Fairer Scotland Duty were evenly split, with nearly half (49%) of those answering indicating that there could be additional impacts on groups experiencing socio-economic disadvantage from the draft Environment Strategy that have not been identified in the draft Fairer Scotland Duty, with the remaining 51% indicating there were not.

Twenty-seven respondents identified both positive and negative impacts on groups experiencing socio-economic disadvantage. These included unequal access to environmental benefits, the costs of climate policy, employment opportunities, and health and rural impacts.

Access

Many respondents highlighted unequal access to environmental benefits across Scotland. It was suggested that people in urban areas may benefit from investment in public transport and green space enhancement, while those in rural and deprived areas risk being left behind. Some respondents also pointed to accessibility barriers for disabled people and older adults, including inadequate infrastructure, digital exclusion, and poor transport connectivity. A few respondents urged the government to adopt an accessibility standard for environmental projects to ensure universal participation and inclusion. Health sector stakeholders at the consultation workshops highlighted the increasing cost of healthy food as an access issue.

Climate policy costs

Many respondents expressed concern that the costs associated with transitioning to net zero could disproportionately impact lower-income households, older people, and those with disabilities. Rising energy and transport costs were seen as particularly challenging for those on fixed or limited incomes. Low-income households are more likely to live in inefficient housing and to experience fuel poverty, and could face higher costs from environmental measures. Some attendees of the equality consultation workshop highlighted difficulties faced by single-parent families who have an increased likelihood of fuel poverty. Some respondents and workshop attendees noted that environmental policies should be accompanied by targeted support measures, such as subsidies for energy-efficient upgrades and affordable transportation alternatives, to prevent the deepening of inequality. One respondent emphasised that as the cost and benefits identified in the draft EQIA may not be evenly distributed the Scottish Government should undertake further research and modelling. Some attendees of the equality consultation workshop suggested that renewable energy plans should address fuel poverty in local communities, citing Harris as an example of a community with fuel poverty while producing a lot of energy that is exported.

Health

Both positive and negative health impacts of environmental change were described by several respondents. Cleaner air, better housing, and increased access to nature were identified as significant public health benefits. Health sector stakeholders at the consultation workshops supported this, emphasising the need for warmer and more sustainable homes that would improve health. Conversely, the physical and mental strain of transition, such as eco-anxiety, disruption from infrastructure projects, or job insecurity, was also highlighted. A couple of respondents suggested embedding Health Impact Assessments more systematically to monitor both immediate and long-term wellbeing outcomes.

Rural areas

Several respondents stressed that rural and island communities face distinct challenges and opportunities. It was felt that geographic isolation, limited infrastructure, and higher living costs can make it harder for residents to benefit from just transition initiatives. Some respondents called for rural-proofing all environmental policies and for targeted investment in transport, housing, and local energy systems. Some also noted that crofting and small-scale farming contribute positively to biodiversity and cultural heritage and should be supported as part of a just transition. This is covered in detail under Q17.

Employment

Several respondents noted that a just transition will reshape Scotland’s labour market, creating both new opportunities and risks. Positive impacts could include growth in renewable energy, land restoration, and circular economy sectors. However, traditional industries such as agriculture, transport, and fossil fuels may face job losses or skill mismatches. A few noted that environmental initiatives can help reduce inequalities when designed inclusively. Investment in green skills, local jobs, and community-led projects was viewed as an opportunity to deliver both social and environmental benefits. A few respondents urged that retraining and workforce support programmes be explicitly linked to equality goals, ensuring access for women, young people, and those in rural or low-income areas. Health sector stakeholders at the consultation workshops emphasised the need to harness the health benefits of potential employment opportunities.

Community

Positive and negative community-level impacts were described by several respondents. On the positive side, local climate and nature initiatives were seen as strengthening community resilience, promoting volunteering, and fostering collective action. However, a few warned of community division arising from controversial projects such as wind farms or low-emission zones. Many respondents stressed the importance of meaningful community engagement and co-design to ensure that environmental actions are locally supported and reflect shared priorities. Some respondents suggested that measures such as community wealth building and devolved governance could strengthen local resilience and help ensure that environmental progress contributes to economic fairness.

Other

Some respondents suggested that people experiencing socio-economic disadvantage, particularly those living in poverty or on low incomes, should be more explicitly recognised in the draft Equality Impact Assessment. Although socio-economic status is not a legally protected characteristic, it was widely noted that financial hardship strongly intersects with environmental vulnerability. Some attendees of the equality consultation workshop suggested that the Scottish Government learn from the lived experience of communities.

Draft Child Rights and Wellbeing Impact Assessment (CRWIA)

Q19. Are there any positive or negative impacts from the draft Environment Strategy that have not been identified in the draft Child Rights and Wellbeing Impact Assessment?

Just under half (46%) of those answering Q19 felt there could be additional impacts that have not been identified in the draft Child Rights and Wellbeing Impact Assessment (CRWIA). The remaining 54% indicated they did not anticipate additional impacts.

Thirty respondents shared their views on the child rights and wellbeing impacts that they felt were not fully identified in the draft CRWIA. The key themes, in order of prevalence, covered healthy environments, education and participation rights, inequalities in access, mental health, household transition effects and sector-specific contexts.

Sustainable environment and education

Some respondents supported the inclusion of children’s rights within the draft Environment Strategy, particularly the recognition of Article 29 of the UN Convention on the Rights of the Child (UNCRC), which emphasises the role of education in fostering respect for the natural environment. Many called for environmental education to be treated not as an optional activity, but as a right for all young people. Embedding this principle across the curriculum and in community initiatives was considered essential to ensuring that all children develop environmental awareness and ecological literacy. Several respondents stressed that children have a right to live in a clean, healthy, and sustainable environment, free from harmful emissions and environmental degradation. They recommended that the CRWIA more explicitly reflect children’s right to a healthy environment, already recognised under Article 24 of the UNCRC (Incorporation) (Scotland) Act 2024.

Approaches to improve implementation

Several respondents proposed ways to strengthen the draft CRWIA’s delivery through participatory, transparent, and accountable processes. They stressed that children and young people must be meaningfully involved in all stages of environmental policymaking and monitoring, not only as beneficiaries, but as active participants and human rights defenders. Some respondents, including children’s rights organisations and youth groups, suggested practical engagement methods such as school-based workshops, surveys, and creative formats (e.g. videos or podcasts) to make consultation accessible and inclusive. They also emphasised the importance of ongoing feedback loops, allowing young people to see how their contributions have impacted decisions.

Participation and access

Some respondents noted that unequal access to outdoor spaces, environmental education, and nature-based learning continues to disadvantage children in rural, island, and low-income communities. While it was noted that the draft CRWIA recognises the general benefits of access to nature, it was seen as insufficiently detailed in addressing barriers such as transport, cost, or the availability of safe green spaces.

Some respondents, particularly those from island and farming communities, highlighted that local infrastructure and economic constraints can limit children’s opportunities for environmental stewardship. Two respondents stressed that learning and play in well-designed outdoor environments, incorporating biodiversity, food growing, and sustainable drainage, can enhance physical and mental wellbeing, foster a sense of responsibility for nature, and strengthen community ties.

Inequality and intergenerational justice

Children from deprived areas were noted to be more exposed to air pollution, flooding risks, and fuel poverty, with associated health and educational impacts. Several respondents urged the Scottish Government to explicitly address these disparities in the CRWIA, linking environmental justice with child wellbeing outcomes.

Mental health and wellbeing

A recurring theme was the need to address the mental health implications of the climate and nature crises. Some respondents noted that while the draft CRWIA acknowledges benefits from green spaces and cleaner air, it does not fully consider the growing evidence of eco-anxiety among children and young people.

Transition and economic impacts

A few respondents identified that some environmental measures could indirectly affect children through their impact on family finances or local economies. Rising costs of heating, food, or transport were cited as potential burdens that could exacerbate household poverty if not mitigated through just transition policies.

Opportunities and future skills

Some respondents viewed the Environment Strategy as an opportunity to enhance children’s future wellbeing by equipping them with green skills, vocational pathways, and civic opportunities. Schools were encouraged to establish stronger links with environmental sectors and green employers, potentially through levy-based funding models similar to those used in the construction sector.

Youth organisations also highlighted that participation in conservation, land stewardship, and nature-based learning builds confidence, responsibility, and a connection to place. Embedding these opportunities across education and community programmes was widely seen as a way to turn environmental responsibility into empowerment.

Draft Consumer Duty Impact Assessment (CDIA)

Q20. Are there any positive or negative impacts from the draft Environment Strategy that have not been identified in the draft Consumer Duty Impact Assessment?

Two thirds (68%) of those answering Q20 expressed the view that there are no additional impacts from the draft Environment Strategy that have not been identified in the draft Consumer Duty Impact Assessment. The remaining 33% indicated there could be additional unidentified impacts.

Twenty-nine respondents provided a range of views on potential consumer impacts that they felt were not fully identified in the draft Consumer Duty Impact Assessment. Many respondents agreed that the Assessment is a helpful starting point, but requires more detailed analysis of affordability, access, communication, and regional differences.

Affordability

The most prevalent theme, raised by many respondents, was the risk that transition costs could be passed on to consumers and widen inequalities. Several respondents noted that upfront costs for low-carbon heating, electric vehicles, and home retrofitting, as well as potential increases in energy and service charges, could disproportionately affect lower-income households and rural and island consumers. Some highlighted concerns about perceived reductions in product choice or a sense of consumers being priced out of sustainable options, describing a risk of elitism if support is not fair and accessible.

Access and inclusion

Several respondents raised a concern about unequal access to any benefits of transition measures. These respondents highlighted barriers for remote and island communities, digital exclusion for older or lower-income households, and uneven availability of public transport and recycling services. Island stakeholders noted higher costs and lower availability of waste and recycling services, with the risk that consumers in these areas may face reduced service levels or higher prices.

Consumer information

Several respondents stated that consumers require clearer, trustworthy information to make sustainable choices. They requested accessible guidance on energy efficiency, waste reduction and reuse, and sustainable travel, along with feedback on outcomes, to build confidence. Sector examples included calls for guidance on correct stove use and credible certification, as well as tailored advice for park home residents on retrofit options and likely bill savings. Several respondents called for sustained consumer engagement during implementation to identify unforeseen issues and ensure equitable benefits. They recommended targeted, plain-language communication and a mix of digital and non-digital channels to reach all consumers. Stakeholders suggested sector partners, such as CIWM Scotland, could help communicate guidance to specific consumer groups.

Consumer choice

Some respondents said the draft CDIA could better consider changes in product availability over time. They suggested that a shift toward more seasonal and plant-based foods may increase some choices and reduce others, which some consumers may welcome, while others may view it negatively. A few respondents cautioned that dietary messaging should be clear and balanced, noting the role of locally produced nutrient-dense foods such as lamb and seafood.

Disruption to services and places

Some respondents noted that delivery of environmental projects could cause temporary disruption to services or access to local spaces, for example, during the construction of flood defences or renewable infrastructure. A few respondents cautioned that poorly planned projects might inadvertently restrict access to valued natural spaces, with unequal effects for communities with lower mobility.

Small businesses as consumers

Some respondents highlighted that small and medium-sized enterprises are also consumers of energy, transport, waste and other services. They suggested that the Assessment could better consider the implications for SME costs, competitiveness, and access to information, especially for rural and family-run businesses.

Sector-specific consumer impacts

A few respondents raised sector-specific consumer issues. In aquaculture, it was believed that stricter measures might increase production costs and seafood prices for lower-income consumers in coastal and island communities. In the stove and wood-fuel market, consumer education and credible standards were viewed as crucial to prevent misuse and promote health and affordability. Island consumers were reported to face higher costs and lower availability of recycling services, which could lead to reduced participation and trust.

Digital opportunities

Some respondents highlighted potential positive impacts not fully emphasised in the Assessment. These included digital tools to support smart energy use and travel planning, lower long-term household costs from energy efficiency and circular practices, and consumer empowerment through reuse, repair and community-led initiatives.

Views on the Consumer Duty Impact Assessment

Some respondents viewed the draft CDIA as relatively slim and requested more detail on distributional impacts, affordability, and access. A few recommended clearer links to monitoring and evaluation, allowing consumer outcomes to be tracked over time. A few respondents requested sectoral case studies, regional analyses for islands and rural areas, and a clearer description of how communications and support will reach digitally excluded consumers.

Partial Business Regulatory Impact Assessment (BRIA)

Q21. Are there any positive or negative impacts from the draft Environment Strategy on businesses that have not been identified in the partial Business and Regulatory Impact Assessment (BRIA)?

Less than half (44%) of those answering Q21 felt there could be additional impacts from the draft Environment Strategy on businesses that have not been identified in the partial BRIA. The remaining 56% indicated they did not anticipate additional impacts.

Thirty-six respondents provided a range of views on the potential impacts of the draft Environment Strategy on Scottish businesses, including both opportunities and challenges. Many respondents agreed that while the draft Strategy could open new markets and promote sustainable innovation, the partial BRIA does not yet capture the full scope of these effects, particularly for SMEs and sector-specific industries.

Positive impacts

Many respondents viewed the draft Strategy as an opportunity for innovation, local economic renewal, and new green markets. Several noted that the transition to a circular economy and sustainable resource management could stimulate job creation, particularly in manufacturing, ecological consultancy, landscape design, and tourism. Some respondents highlighted opportunities for SMEs and local supply chains, particularly in rural and island areas. Renewable energy, restoration services, and community-based initiatives were seen as areas of growth. A few respondents suggested that businesses actively integrating biodiversity restoration or nature-based products could strengthen their brand value, resilience, and competitiveness. A small number pointed to export advantages for early adopters of sustainability standards, particularly where alignment with EU markets could be demonstrated.

Negative impacts

The most prevalent theme, identified by many respondents, was concern over the regulatory burden for SMEs. Several respondents noted that small businesses have limited capacity to manage compliance, reporting, and transition costs, particularly in fishing, aquaculture, farming, and tourism. Several respondents identified cumulative regulatory costs, arguing that overlapping environmental requirements, for example, circular economy and biodiversity measures, could have disproportionate financial and administrative impacts.

Some respondents mentioned sector-specific pressures. Fishing and aquaculture respondents noted potential impacts from marine spatial planning and offshore energy developments; agriculture respondents raised issues around fertiliser scarcity and compliance with environmental standards; and a hospitality and holiday park body noted unique cash-flow and infrastructure constraints. A few respondents highlighted regional disparities, with rural, island, and coastal businesses expected to face higher adaptation costs due to infrastructure and logistics limitations. Two respondents noted uncertainty and transition risks, arguing that ambiguity around policy timelines could discourage investment and job creation in emerging green sectors.

Views on the partial BRIA

Many respondents stated that the partial BRIA did not fully reflect the urgency or breadth of business impacts. These respondents expressed the view that it underestimates challenges faced by smaller enterprises, does not sufficiently assess cumulative effects across overlapping policy areas, and lacks detail on sectoral variation. Several respondents felt that the partial BRIA overemphasised opportunities in ‘green growth’ sectors while failing to analyse negative or transitional effects in existing industries, such as farming, seafood, and rural tourism. A few respondents recommended that future iterations of the BRIA include scenario analysis, sector-specific modelling, and quantitative estimates of compliance costs.

Mitigation and recommendations

Several respondents suggested mechanisms to help businesses manage transition risks, including funded transition plans and proactive risk mapping, multi-year predictable funding support for small rural and island enterprises, clearer policy guidance to reduce uncertainty, and targeted grants, technical assistance, and tax incentives for SMEs adopting low-carbon or circular practices. A few respondents emphasised the need for collaboration between business and government, including co-design of future regulatory frameworks, adaptive management processes, and real-time monitoring of impacts.

Q22. Do you have any further views on the partial BRIA?

Additional comments on the partial BRIA were provided by 34 respondents. These typically reiterated the themes raised in detail in Q21; however, there were additional positive comments, and an additional theme focusing on evidence and modelling.

Positive comments

Some respondents described the BRIA as a ‘solid foundation’ for identifying regulatory and economic impacts, and commended its recognition of opportunities in green innovation, circular economy development, and low-carbon transitions. A few respondents welcomed its potential to support export growth, competitiveness, and job creation through the adoption of sustainable practices and new technologies. However, even these supportive respondents noted that these benefits were expressed at a high level of generality, and requested more detailed examples or case studies to build confidence among businesses and investors.

Evidence and modelling

A few respondents stated that the partial BRIA lacks sufficient quantitative evidence to substantiate its claims about economic benefits or costs. These respondents requested stronger use of modelling, including cost-benefit analyses, scenario testing, and longer-term projections of both risks and savings. A few respondents recommended integrating the BRIA with the Monitoring Framework to ensure that business impacts can be tracked and evaluated over time.

Other considerations

Q23. Are there any other positive or negative impacts on areas such as health in the draft Environment Strategy that should be considered?

Just over half of respondents (53%) indicated there could be additional impacts on areas such as health in the draft Environment Strategy that should be considered.

Comments in response to Q23 were provided by 31 respondents. Most respondents emphasised the significant potential for environmental improvement to deliver public health gains, while several highlighted possible risks, uneven benefits, and mitigation approaches that should be incorporated into delivery.

Positive impacts

Physical health benefits

The most prevalent theme, raised by many respondents, was that the draft Strategy has considerable potential to improve physical health outcomes. Key co-benefits identified included improved air quality, active travel, energy-efficient homes, and healthier diets, all of which are regarded as mutually reinforcing with environmental objectives and essential to reducing the long-term disease burden. Several respondents cited evidence linking walking and wheeling to a reduced incidence of heart disease, diabetes, and cancer, alongside wider wellbeing benefits and cost savings for the NHS. Warmer, more energy-efficient homes were also associated with a reduction in respiratory and cardiovascular illnesses. A few noted that renewable or biomass heating systems could contribute to both physical and mental wellbeing by providing warmth, comfort and resilience in emergencies.

Mental health and wellbeing

Several respondents highlighted the positive link between environmental quality, access to nature and mental health. They praised the draft Strategy’s focus on green and blue spaces, sustainable communities, and clean air, noting that these can reduce stress, promote social cohesion, and strengthen community resilience. Health sector stakeholders at the consultation workshops suggested that social and green prescribing could help tackle loneliness and isolation, while maximising the use of existing green and blue infrastructure; however, they emphasised the need for concrete next steps and funding to support this approach.

Diet and nutrition

Some respondents highlighted diet as a critical determinant of health. Some supported a shift toward plant-rich, sustainable diets, noting the benefits for public health, climate, and biodiversity. A few stressed that the draft Strategy should retain balance by ensuring continued access to nutrient-dense local produce, such as lamb and salmon, especially for groups at risk of dietary deficiency. Stakeholders cited the UK Climate Change Committee’s recommendations for reduced meat consumption and referenced the overlap between dietary change, emissions reduction and disease prevention. Several also called for public campaigns, food-system incentives, and alignment with Good Food Nation plans to normalise sustainable diets across communities. Health sector stakeholders at the consultation workshops suggested that dietary changes could result in NHS savings.

Animal and ecosystem health

A few respondents connected animal welfare and ecosystem health with human wellbeing. They argued that reducing intensive livestock farming could improve biodiversity, regulate disease vectors and yield cleaner, healthier environments. These respondents supported a One-Health approach that links human, animal, and environmental health within the Strategy’s monitoring framework.

Negative or overlooked impacts

Unequal access to benefits

Several respondents cautioned that, without deliberate policy design, the benefits of environmental improvements may not be shared equally. Vulnerable or marginalised groups may face limited access to sustainable food, clean energy, active travel, or safe green spaces, which could exacerbate health inequalities. Several respondents called for targeted investment, local delivery capacity, and inclusive planning to ensure that all communities benefit equally.

Mental health risks

Some respondents noted that the green transition itself could generate mental-health pressures if not managed carefully. They pointed to risks such as climate anxiety, particularly among young people and workers in high-emission or land-based sectors may experience uncertainty, job loss or income insecurity, leading to stress and anxiety. Rising costs of energy or goods were also seen as potential stressors for low-income households. A few respondents recommended embedding mental health support within just transition frameworks, ensuring that rural and island areas receive tailored assistance.

Health and safety at work

A few respondents drew attention to poor health and safety performance in high-risk sectors, such as waste and recycling. They reported fatality and injury rates well above the all-industry average, with thousands of non-fatal injuries and work-related illnesses each year. Improving workforce safety through training, investment, safer materials, and fair work standards was viewed as essential to ensure that environmental progress does not come at the expense of workers’ wellbeing. Examples from aquaculture and waste management demonstrate how improvements in health and safety can also enhance sector resilience and inclusion.

Environmental project impacts

Two respondents highlighted the risk of localised health impacts arising from large-scale environmental or infrastructure projects. Issues such as construction noise, dust and disruption were mentioned, particularly where projects affect vulnerable populations. A few respondents suggested the use of Health Impact Assessments at both national and local levels to ensure that developments deliver net positive health outcomes.

Mitigation

Many respondents proposed practical ways to mitigate health risks and maximise co-benefits. Suggestions included:

• Embed Health Impact Assessments systematically within planning and policy appraisal, and ensure local-level findings inform decision-making.
• Invest in safer, fairer workplaces through training and improved safety standards, especially in waste and resource-management sectors.
• Promote walking and wheeling through long-term infrastructure investment and a minimum of 10 per cent of the transport budget dedicated to active travel, prioritising disadvantaged communities.
• Address mental-health resilience by integrating education, skills and support programmes into just-transition delivery.
• Enhance cross-sector collaboration, linking environmental, health and planning agencies to design landscape-led places that deliver multiple wellbeing benefits.
• Strengthen surveillance and preparedness for climate-related disease risks and pollution impacts, particularly in island and coastal settings.

Other or specific health topics

A few respondents raised additional or sector-specific considerations:

• Concerns about air-pollution impacts from domestic wood-burning and calls for tighter regulation.
• Recognition of public-health benefits from sustainable aquaculture and the need for monitoring to maintain seafood safety.
• Evidence of disproportionate health risks from marine litter and microplastics on islands, with recommendations for island-specific health assessments and producer-responsibility schemes.
• Calls for improved metrics and research on the measurable health outcomes of green spaces and nature-based initiatives, supported through Green Health Partnerships and academic collaboration.
• Health sector stakeholders at the consultation workshops suggested that health impact assessments should be undertaken when considering the development of blue and green infrastructure.