Public bodies climate change duties - draft statutory guidance: consultation analysis - final report

4. Taking climate change into account in decision-making

This chapter presents an analysis of responses to Q3 and Q4 of the consultation. These focused on section 4.5 of the draft guidance, which details climate considerations being embedded into decision-making processes, such as through impact assessments. Chapters 5 and 6 of the guidance also provide guidance to support the implementation of the duty. This guidance aims to support public bodies in demonstrating their compliance with the climate change duties. This includes ‘best calculating’ the impact of their mitigating and adaptation actions.

Q3. Does the guidance make it clear how public bodies can fulfil the requirement to ‘best calculate’ the climate impact of their actions?

Of those answering Q3, a third (33%) felt the guidance was clear on how to ‘best calculate’ the climate impact of the actions, while 57% felt it achieved this partially, 8% did not and 2% were unsure. Public bodies were more likely to agree or partially agree that the guidance was clear compared to non-public bodies (92% combined compared to 80%).

Three quarters of all respondents commented to explain their answer to Q3. The most common themes, in order of prevalence, were the positive aspects of the guidance on best calculating climate impacts, the need for greater clarity and comments on methodology.

Best calculation guidance for public bodies is clear

Many respondents, half of all those who commented at Q3, highlighted positive aspects of the guidance on how public bodies can fulfil the requirements to best calculate the climate impact of their actions. Respondents commented that across their sectors and areas of focus, the guidance was helpful, provided useful tools and methodologies, contained good examples and resources (such as the Zero Waste Scotland Commuter Emissions Calculator), and had helpful sections on implementing the duty and understanding of public bodies' climate impacts. These comments were either expressed generally or about specific sections of the guidance, including sections 4.5, 5, 6, 7 and Annex A.

“The guidance clearly sets out that it is vital that public bodies understand the climate impacts of their financial decisions and embed carbon into their business cases, budgetary processes, financial planning and reporting.” – West Lothian Council

Benefits of this section of the guidance were noted by several respondents, particularly how it could ensure that climate change is central to public bodies’ decision-making.

“The guidance outlines the importance of a whole system approach, setting out clearly in a step by step process the importance of providing a leadership function, strong governance and mainstreaming climate action and adaptation, as well as the need for collaboration and partnership working, and community involvement and capacity building to accelerate progress at the scale and pace required to optimise opportunities and benefits.” - Renfrewshire Council

Several respondents felt that the guidance provided clarity, particularly on using standardised emissions factors to calculate climate impact for public bodies. Clarity was also noted for overall aspirations, risks, and implementation of the leader’s checklist.

Need for greater clarity on methodology and implementation support

In contrast, many respondents called for greater detail and clarity on a range of areas in this section of the guidance. Specific requests included providing clearer expectations of public bodies, outlining requirements and benchmarking by sector or type of public body, and details on the tools or standardised methods that could be used to quantify impacts. A few respondents highlighted specific omissions and additions, including collaboration between public bodies and organisations to support calculations, implementing best practices through procurement, and other sector-specific additions. More specifically, many respondents commented on methodology, in particular suggesting using a standard methodology to best calculate the climate impact of public body actions.

Other comments

Resourcing constraints and mitigations were detailed by several respondents, as detailed in Chapter 2.

Comments calling for greater consideration of the wider contextual factors in the requirement to best calculate the climate impact of public body actions were made by some respondents. This included considering:

• Socio-economic and health impacts.
• Embodied carbon.
• The role of public bodies to influence and encourage behaviour change, e.g. through Community Climate Action Hubs.
• How individual settings might best calculate climate impacts, e.g. GP premises or care settings.
• Climate Vulnerability Indexes.
• Information on networks providing advice and support, e.g. the Sustainable Scotland Network and the Scottish Energy Officers’ Network.
• Individual organisational approaches taken regarding climate change.
• Incorporating carbon impact assessments into organisational strategies.

Specific concerns with the proposed approach were raised by a few respondents, such as:

• The challenges of calculating long-term climate impacts, such as ensuring robust measurement.
• Calls for greater consideration of emissions in construction processes.
• The need for regular review to ensure links and documents are up to date.
• Challenges for the ambition of public bodies when targets and deadlines are revised by the Scottish Government.

Some respondents noted issues with emissions targets and measurements, which are covered in Chapter 5 of this report.

“Another issue is that without practical guidance providing a robust and standard methodology for calculating scope 3 emissions, there is a real risk of sub–optimal decision making in respect to carbon emissions resulting in outsourcing or offshoring to less regulated environments. An approach to a standard reporting via a national platform could reduce the risk of additional cost occurred in supply chains.” - Scotland Excel

Q4. Does the guidance make it clear how public bodies should take future climate scenarios into account when making plans and investment decisions?

Of those answering Q4, 23% felt the guidance made it clear how public bodies should consider future climate scenarios when planning and making investment decisions, compared to 63% who felt it was partially clear, 11% who did not, and 3% who were unsure. Public bodies were more likely to agree or partially agree (91% combined) than non-public bodies (69% combined).

Three quarters of all respondents commented on their answer to Q4. The most common themes, in order of prevalence, were the need for more practical tools and clarity and positive aspects of this section of the guidance.

More practical tools and clarity are needed

Many respondents called for greater support with implementation through providing more practical tools and examples (see Chapter 2 for general comments on this). Specific points related to Q4 included the need for scenario planning or toolkits across multiple time frames and different climate change scenarios to assess long-term risks. It was also suggested that more guidance on assessing climate-related financial risks to investment decisions could support financial planning.

The need for greater detail and clarity was emphasised by several respondents, and a few commented on alignment with other goals and policies (see Chapter 2).

Specific suggestions to strengthen aspects of this part of the guidance were made by some respondents, such as greater consideration of resilience, transitionary and physical risks. A few suggested specific additions, such as including more references, e.g. to Met Office Local Authority Climate Report scenarios, addressing the circular economy principles, and prompts to assess location-specific risks and adaptations.

Positive comments

Many respondents highlighted positive aspects of this section of the guidance, making both general comments (see Chapter 2) and comments on the usefulness of specific aspects. This included highlighting the value of illustrative examples, tools, references, and guidance relating to planning and investment.

Several respondents stated that this section of the guidance is clear. Comments included that it clearly outlines expectations of public bodies and the role of climate change scenario analysis and impact assessments for planning and decision-making in public bodies. The clarity and comprehensive nature of the guidance in this area were felt to support implementation effectively. The way in which the guidance highlights important considerations, future climate scenarios, and takes a whole-system approach was felt to be useful for public bodies by some respondents.

“The guidance provides clear examples of ways to comply with the adaptation duty, for future climate scenarios and planning for business continuity, with anticipated outcomes.” – SOLACE Scotland

“In general, the guidance provides a very useful framework for organisations to follow with regard to setting targets and trajectories in line with recognised climate science.” – University of Strathclyde

Other comments

Some respondents commented on methodology, including requests for links to existing climate change pathway methodologies, datasets and tools. A few respondents detailed the need for capacity building and training to support public bodies in making plans and investment decisions (see Q15). Other singular comments were made by organisations, including that the methodology is left to the discretion of public bodies, and that existing work is underway by public bodies towards planning for future climate scenarios.