Environment Strategy for Scotland: equality impact assessment

Annex – summary of the responses to the consultation

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.