Climate Action Hubs funding, recycling targets and tidal power: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004


Information requested

1. “The Scottish Government ring-fenced £5.5m for Climate Action Hubs, could you supply a full breakdown of where this money went?

2. Could you supply all documentation held by the Scottish Government, including correspondence sent and received (including internal), minutes/notes from meetings, briefings, analysis about the Scottish Government's 70% recycling target for 2025, from the last month? - Can you include the latest risks register/assessment on this target?

3. Could you supply all documentation held by the Scottish Government, including correspondence sent and received (including internal), minutes/notes from meetings, briefings, analysis about Scotland's tidal power, from the last month?”

Response

As the information you have requested is ‘environmental information’ for the Purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Question 1

Under Regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. Where information is already publicly available, I have provided you with the links to the relevant websites. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.

In 2024/2025, the Scottish Government committed to funding up to £5.5m for the Climate Action Hub Programme alongside a wider support package. A detailed breakdown of the grants awarded to the organisations leading Climate Action Hubs since their inception (including 2024/2025) can be found at:

Introduction - Climate Action Hub Programme: Funding Awards

In addition to the above, the following additional amounts were awarded for work to support effective delivery of the programme in 2024/25.

  • £80,000 to the Scottish Communities Climate Action Network
  • £4,139 to cover costs linked to the national gathering events and publication of documents

The figures for the 2025/2026 award will be published in due course and once available can also be found via the above link.

Question 2

While our aim is to provide information whenever possible, in this instance the Scottish Government does not hold the specific information you have requested, namely documentation in relation to the Scottish Government's 70% recycling target for 2025. Therefore, with respect to your request this is a formal notice under Regulation 10(4)(a) of the EIRs confirming that the Scottish Government does not hold this information.

It may help if I explain that as part of the response to your request we have conducted a search of the Scottish Government’s main records filing system and have been unable to locate the information requested. I would also note that a search request was submitted to Scottish Government Officials which also resulted in no information being identified that would be within the scope of your request.

Please note that for the purposes of your request we have conducted searches for information held between the dates of 29 November 2025 and 29 December 2025 in this instance.

This exception is subject to the ‘public interest test’. It is important to note that although we do not hold the information and have applied Regulation 10(4)(a) – information not held, it is a requirement that we have to apply the public interest test.

Wider guidance on the Environmental Information regime can be found in the Key Concepts section under ‘Information Not Held’ and ‘The Public Interest Test’ in the attached Scottish Information Commissioner Briefings and Guidance document. Further guidance on the public interest test can also be found on page 8 of the Scottish Information Commissioner guidance.

Question 3

While our aim is to provide information whenever possible, under the exception at Regulation 10(4)(b) of the EIRs a public authority may refuse a request for information if it is ‘manifestly unreasonable’. The Scottish Information Commissioner’s guidance on the Regulation 10(4)(b) exception here says that there may “be instances where it is appropriate for the Commissioner to consider the proportionality of the burden on the public authority in terms of the costs and resources involved in dealing with a request when considering the application of this exception”.

In this case, carrying out Question 3 of your request under the EIRs would impose a significant resource and cost burden on the Scottish Government due to the volume of materials that would be considered as a part of said request. For these reasons, we consider that your request is manifestly unreasonable and so we are refusing it under Regulation 10(4)(b).

As the exception is conditional we have applied the ‘public interest test’. This means we have, in all the circumstances of this case, considered if the public interest in disclosing information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception.

While we recognise that there may be some public interest in information regarding tidal power/energy in Scotland, this is outweighed by the public interest in ensuring the efficient and effective use of public resources by not incurring excessive costs when complying with information requests.

You may however wish to consider reducing the scope of your request in order to make it more manageable due to the number of items identified that would be potentially within the scope of your request based on the criteria you have provided. For example this could be by reducing the date range required and/or requesting information relating to a particular tidal power/energy project.

You may also find it helpful to look at the Scottish Information Commissioner’s ‘Tips for requesting information under FOI and the EIRs’ on his website here.

Please note that for the purposes of your request we have conducted searches for information held between the dates of 29 November 2025 and 29 December 2025 in this instance.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

Contact

Please quote the FOI reference
Central Correspondence Unit
Email: contactus@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrew's House
Regent Road
Edinburgh
EH1 3DG

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