The Environment Strategy for Scotland: Consumer Duty Impact Assessment (CDIA)

Stage 2 – Evidence Gathering:

3. What is the proposal trying to achieve?

The Environment Strategy sets out a holistic framework for delivering Scotland’s role in tackling the global crises of nature loss, climate change and pollution. The final version of the Strategy can be found here. The Strategy brings together the Scottish Government’s existing policy response to tackling nature loss, climate change and pollution, highlighting the importance of carefully managing synergies and trade-offs across these goals.

It builds on these existing policies by outlining new priorities and proposals. These focus, in particular, on opportunities for supporting the economic and societal changes needed to help tackle these global crises in ways that create wider benefits for Scotland – supporting green jobs and industries, improving people’s health, tackling poverty and promoting social justice.

Vision and outcomes

The 2045 vision for the Strategy begins by describing our ambitions for fulfilling Scotland’s role in tackling the global crises of nature loss, climate change and pollution, helping to safeguard our shared planet for all life on Earth. The vision also sets out how we will harness the enormous opportunities this creates for Scotland to flourish as a fairer, greener and more prosperous nation.

The vision recognises that tackling these crises relies will depend on changes in Scotland’s economy and society. This, in turn, can help to transform Scotland for the better – for example by supporting green jobs and enabling people and communities in Scotland to live sustainably – in ways that also tackle inequalities and poverty and create wider benefits for people’s health and wellbeing.

The Strategy identifies a set of outcomes to support the delivery of this vision. Four outcomes describe our goals for tackling climate change and restoring the health of our natural environment, in Scotland and overseas:

• Scotland’s nature is protected and restored
• We have ended Scotland’s contribution to climate change
• We minimise pollution and waste in our environment
• Scotland’s global environmental impact is sustainable.

Two outcomes describe the positive transformations in our society and economy that will support these goals, while creating wider benefits for Scotland’s wellbeing and prosperity:

• Scotland’s society is transformed for the better by living sustainably, in harmony with nature
• Scotland’s net zero, nature positive and circular economy thrives within the planet’s sustainable limits.

Two cross-cutting outcomes explain how we will build Scotland’s resilience to the impacts of these global crises and support wider goals for social justice in Scotland and overseas:

• We build Scotland’s resilience to climate change and other global environmental risks
• These transformations are achieved through a just transition, supporting climate and environmental justice and intergenerational equity.

The Environment Strategy presents high-level pathways for driving progress towards the outcomes. These pathways summarise key existing policies while also identifying proposals and priorities to guide future policy development across the breadth of government. The Strategy sets out arrangements for monitoring and reporting progress towards the outcomes, in order to guide improvements to our approach.

4. What are the impacts on consumers?

The Environment Strategy is likely to result in a positive impact for consumers in Scotland, including vulnerable consumers, by improving the services provided by public authorities. These include reducing flood risk, increasing green and blue spaces and tackling air pollution.

One of the key impacts on consumers as a result of the Environment Strategy is from promoting environmental quality and providing access to nature. These impacts will give greater benefits to consumers, especially those living in more deprived areas, who will benefit from better health and wellbeing outcomes. These impacts can help transform towns and cities into more enjoyable, attractive and safer places to live, and reduce the level of demand that is placed on the National Health Service. The consultation responses also highlighted the importance of the Strategy in supporting mental health, social cohesion, and educational outcomes, and reducing air pollution.

In addition to increasing health opportunities and equalities, the Environment Strategy can also maximise the wider opportunities to create green jobs and businesses, and for achieving Scotland’s ambitions for a wellbeing economy. It will help ensure Scotland’s net zero, nature positive economy positive and circular economy thrives within the planet’s sustainable limits, and harnessing the opportunities this creates for good, green jobs.

However, some consultation responses warned of the potential unintended consequences from infrastructure projects, which could temporarily reduce access to local spaces and services. In addition, island stakeholders during the consultation highlighted 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. Other consultation responses also argued that reducing Scotland’s environmental impact could potentially increase costs on public authorities through transition costs, which could then be passed on to the consumer.

The actions that follow the publication of the Environment Strategy will be assessed for their impact on consumers, and further impact assessments, including the Consumer Duty Impact Assessment, will be carried out where appropriate.

5. Is it likely that harm will be experienced by consumers as a result of this proposal?

The Scottish Government believes it is highly unlikely that there will be harm to consumers caused by the implementation of the Environment Strategy. However, there is an argument that reducing Scotland’s environmental impact could potentially increase costs on public authorities through transition costs, which could then be passed on to the consumer. This is also something that was flagged in the consultation.

It is possible that some individual policy measures considered in support of the priorities set out in the Strategy could have differential impacts on consumers, which should be considered. It is important that that the potential impacts on consumers highlighted in the responses to the consultation are considered and mitigated against during the implementation of the priorities and proposals. The appropriate level of Consumer Duty Impact Assessment should be carried when considering policy measures.

6. What alternative proposals are there that can improve outcomes for consumers and/or reduce harm to consumers?

In preparing the Environment Strategy, we considered the possibility of “doing more and sooner”, where the Environment Strategy would be more ambitious and reach its aims much sooner than those set out in the Strategy. We have not considered a ‘do nothing’ scenario, as the Strategy was placed on a statutory basis by the Continuity Act 2021, with Section 47 requiring Scottish Ministers to prepare and publish an environmental policy strategy.

7. How do these alternative proposals compare to the original proposal?

It was decided that the “doing more and sooner” option would be discounted as our net zero target of 2045 is one of the most ambitious in the world and means reaching net zero five years ahead of the rest of the UK. The UK’s Committee on Climate Change also said that the 2045 target was set as it was the earliest achievable date for net zero without major disruption or unrealistic expectations. The option taken forward in the Environment Strategy will also ensure consistency with other Scottish Government net zero commitments.