Consultation on the Draft Scottish Climate Change Adaption Programme: Analysis of Responses

Executive Summary

Introduction

Section 56 of the Climate Change Act 2008 requires the UK Government to publish a Climate Change Risk Assessment (CCRA) every five years. Following these assessments, the Climate Change (Scotland) Act 2009 requires Scottish Ministers to lay before the Scottish Parliament a programme for adaptation to climate change setting out Scottish Ministers' adaptation objectives, and their policies and proposals to meet those objectives. The first UK CCRA was published in January 2012 and a draft Scottish Climate Change Adaptation Programme (the Programme) was developed in partnership with stakeholders, addressing the risks identified in the report for Scotland. This first Programme is part of an iterative process and subsequent Programmes are required to address the risks identified for Scotland in successive CCRAs.

The Programme is structured around an overarching aim to increase the resilience of Scotland's people, environment and economy to the impacts of a changing climate. It comprises three themes - (i) Climate Ready Natural Environment (the N theme); (ii) Climate Ready Buildings and Infrastructure Networks (the B theme); and (iii) Climate Ready Society (the S theme). Each theme has an outcome that the Programme is seeking to deliver in the long term (up to 2050). Within each theme there are three objectives, each with policies and proposals that provide a focus for the lifetime of the Programme in order to progress towards the long term objective. Altogether there are 124 policies and proposals included in the Programme.

Between June and September 2013, the Scottish Government undertook a public consultation to invite views on the Programme and the Strategic Environmental Assessment (SEA) which accompanied it.

The consultation questionnaire included a combination of closed and open questions. In the closed questions, respondents were asked to tick a box to indicate their level of support for particular aspects of the Programme. In the open questions, respondents were invited to provide further comments.

The consultation received 67 responses. All but three of these were from organisational respondents. Just over half of the organisational respondents were public bodies with defined duties under the Climate Change (Scotland) Act 2009.^[1] A summary of the main findings from the consultation responses follows.

Key issues from the consultation

There was broad support for the Programme's overarching framework, and its objectives, policies and proposals. Respondents also generally thought that the Programme and its objectives, policies and proposals addressed the impacts to Scotland identified in the UK CCRA.

Respondents welcomed the Programme and acknowledged the efforts of the Scottish Government in creating a "comprehensive", "balanced" and "flexible" framework to focus the work of adaptation. However, at the same time, it was common for respondents to request more detail about certain aspects of the Programme and to suggest that there should be a greater emphasis on "taking action".

Across all questions, respondents repeatedly raised a number of key issues as areas for improvement in the Programme. In particular, there were requests for clarification about how it would be delivered, who was responsible / accountable for delivery, priorities and timescales, funding, and arrangements for reporting and monitoring. Local authorities, in particular, thought that their role in the delivery of the Programme was missing or understated. This was thought to be a significant omission because of the considerable influence that local authorities have at a local level over a wide range of issues.

Other key issues repeatedly raised by respondents in their comments included the need to highlight areas where there were links between the Programme's three main themes. One such area was in relation to green space and green infrastructure, which was perceived to have benefits for the natural environment, built environment and society.

Respondents also thought it was important for the Programme to clarify the relevance to adaptation of certain policies listed under the three themes.

Views on the overarching framework

The majority of respondents thought that the overarching framework for the Programme set an appropriate long term direction for climate change adaptation in Scotland, and that it addressed the impacts to Scotland identified in the UK CCRA.^[2]

Those who thought the Programme was generally appropriate described it as "comprehensive", "balanced" and "flexible enough to cover a wide range of eventualities" as additional risks are identified over time. The thematic approach set out in the Programme was seen to be preferable to the sectoral approach previously used, and the "shift from being responsive to being anticipatory and pre-emptive" was also welcomed.

Those who thought the framework was less well equipped to meet the Programme's objectives commented that the Programme appeared in some cases to be more "reactive than proactive". This group wanted the Programme to communicate a greater sense of urgency.

Respondents made a range of suggestions about how the overarching framework could be improved. In particular, respondents thought that the risks of climate change to the Scottish economy were not sufficiently addressed, and that information should be included which explained how the private sector would be influenced to act in relation to adaptation.

Respondents pointed out that the UK CCRA does not cover all climate change risks for Scotland, and it was suggested that the Programme would be limited if it only focused on the risks and threats set out in the UK CCRA.

Climate Ready Natural Environment - the N theme

The three objectives in the N theme were:

• N1 - Understand the effects resulting from climate change and their impacts on the natural environment
• N2 - Support a healthy and diverse natural environment with the capacity to adapt
• N3 - Sustain and enhance the benefits, goods and services that the natural environment provides

A majority of respondents thought the three N objectives and the policies and proposals listed under them set an appropriate long term direction for natural environment adaptation - describing them as "suitable", "sensible" and "logical".

At the same time, respondents wanted to see a greater emphasis in the N objectives on taking action. They also highlighted the need for a holistic approach to adaptation of the natural environment. Respondents thought the natural environment can play a crucial role in helping Scotland's infrastructure and society to adapt to climate change impacts. Therefore, if action is taken to help the natural environment adapt, this will add value to other adaptation efforts.

The policies and proposals under the N objectives were generally described as "appropriate" and "comprehensive". Respondents thought the N theme could be strengthened by focusing more on positive measures such as restoring and sustaining ecosystems and local habitat networks, and not just on understanding the risks or avoiding the impacts of climate change.

Areas for development under the three N objectives included:

• Objective N1: the need for policies that cover a full range of habitats; a need for research into the effects of climate change on coasts and peatlands, and on the use of green space; and a concern that "citizen science" activities (although valuable), should not be seen as a substitute for professional monitoring.
• Objective N2: a need for a greater emphasis on the role of green infrastructure in supporting a healthy and diverse natural environment; and a need for more policies and / or proposals related to habitat creation and protection.
• Objective N3: a need to emphasise the importance of an ecosystems approach to guide adaptation for the natural environment.

Climate Ready Buildings and Infrastructure Networks - the B theme

The three objectives in the B theme were:

• B1 - Understand the effects of climate change and their impacts on buildings and infrastructure networks
• B2 - Provide the knowledge, skills and tools to manage climate change impacts on buildings and infrastructure
• B3 - Increase the resilience of buildings and infrastructure networks to sustain and enhance the benefits and services provided

A majority of respondents thought the three B objectives and their policies and proposals set an appropriate long term direction for adaptation of Scotland's buildings and infrastructure networks. The B theme was described as "the most coherent of the three themes" in the Programme, and was seen to provide "a strong foundation" for improving the resilience of Scotland's infrastructure.

Those who were less satisfied with the objectives thought they were "too narrowly defined" and wanted to see more specific objectives, incorporating a wider range of measures, with both short and long term actions. Respondents perceived gaps in the B theme in relation to: information and communications technology infrastructure; energy infrastructure; coastal and inland water infrastructure; and water supplies.

Respondents thought that the definition of "infrastructure" in the B theme should be broadened to include green infrastructure. They also emphasised the importance of avoiding unintended consequences from actions taken to address the B objectives - for example, action taken to improve the resilience of the road infrastructure could result in greater carbon emissions.

Areas for development under the three B objectives included:

• Objective B1: the need to incorporate policies aimed at supporting walking and cycling and reducing reliance on cars; the need to improve the resilience of a wide range of existing buildings, including housing, workplaces, care homes - as well as historic buildings, monuments and sites; and the need to include a wider range of policies and proposals to support a resilient energy sector.
• Objective B2: the need for a greater emphasis on providing training and tools to a wide range of professionals in the public and private sectors.
• Objective B3: the need to address the challenges of developing resilience in older buildings; and the availability of flood insurance for small businesses as well as householders.

Climate Ready Society - the S theme

The three objectives in the S theme were:

• S1 - Understand the effects of climate change and their impacts on people, homes and communities
• S2 - Increase the awareness of the impacts of climate change to enable people to adapt to future extreme weather events
• S3 - Support our health service and emergency responders to enable them to respond effectively to the increased pressures associated with a changing climate

A majority of respondents thought the three S objectives and their policies and proposals set an appropriate long term direction for adaptation of Scottish society - describing them as "comprehensive" and addressing "a good range of important issues". Respondents considered the "climate justice work" identified under objective S1 to be especially welcome and valuable.

Those who were less satisfied commented that the S theme was "the least developed" of the Programme's three themes. This group perceived gaps in relation to the adaptation of businesses and the economy and of food security. They also wanted to see a greater emphasis on building capacity in communities.

Areas for development under the three S objectives included (among others):

• Objective S1: the need to include a wider range of measures under S1; respondents suggested additional areas for research to better understand the effect of climate change on communities, and how communities can become more resilient.
• Objective S2: the need for resources to support capacity building in communities; and the need to consider the wider effects of climate change (i.e. other than flooding) on communities.
• Objective S3: the need to broaden the policies and proposals to reflect the contributions of other agencies (not just health and emergency services) to the increased pressures associated with a changing climate.

Role of others in delivering the Programme

In terms of the support required by public bodies with duties to help deliver the Programme, respondents highlighted a need for guidance, tools and training; leadership at a senior level in national and local government; financial models to support investment in adaptation activities; and strengthened planning policy. Support was voiced for organisations like Adaptation Scotland and the Sustainable Scotland Network which play an important role in capacity building, sharing knowledge and producing guidance for public bodies.

Respondents were divided in their views about whether the Programme set out adequate arrangements for public engagement and for involving a range of other stakeholders in delivery. Respondents wanted to see the Programme include a "clear statement of ambition" to engage more inclusively with all relevant stakeholders, including businesses, communities, the media and the general public. There was also a request for clarification about who would be responsible for the delivery of engagement activities, and the timescales and resources available for this work.

Strategic Environmental Assessment (SEA)

In relation to the SEA, a majority of respondents thought the SEA set out an accurate description of the current environmental baseline; and agreed with the predicted environmental effects, the recommendations and the proposals for monitoring the environmental effects of the Programme. They were also not aware of additional environmental information that would help inform the environmental assessment findings, nor were they aware of other 'reasonable' alternatives to the Programme and its content that should be considered as part of the SEA process.

Conclusion

In general, respondents supported the Scottish Government's draft Scottish Climate Change Adaptation Programme and voiced their willingness to play a part in helping Scotland to become more resilient to the processes of climate change. Some respondents made positive comments about the Programme overall, describing it as "comprehensive" and "welcome", and recognising the effort taken by the Scottish Government in developing a strategic approach to adaptation. At the same time, they wanted to see the Programme communicate a greater sense of urgency and put a greater emphasis on action.

Respondents emphasised the importance of adaptation becoming embedded in the policy, processes and language of the planning system. They also thought that partnership working is key to the success of the Programme.