Public bodies climate change duties: putting them into practice, guidance required by part four of the Climate Change (Scotland) Act 2009

Guidance to support public bodies in exercising their duties under the Climate Change (Scotland) Act 2009.


It is crucial that climate change action is mainstreamed in all public bodies' business processes and functions. To do this effectively, public bodies will need to set targets and milestones and integrate climate change into business practice, through their existing processes and procedures. The Scottish Government has developed this step by step approach to assist public bodies to achieve this.

The outcomes of the step-by-step process will be:

  • Climate change action is mainstreamed into the corporate governance of every public body in Scotland to which the duties apply; and
  • The public sector provides a leadership function to the rest of Scotland (private sector, voluntary sector, individuals and households) in its approach to climate change.

Diagram 1: A step-by-step approach for public bodies to climate change action

Diagram 1: A step-by-step approach for public bodies to climate change action

Mainstreaming climate change into their strategic and corporate processes and actions is the overarching goal for public bodies to work towards. However, it is acknowledged that public bodies will be at different stages of development and understanding of climate change action, and that effective mainstreaming could require more time and effort for some bodies than for others.

Addressing climate change is an ongoing process. To reflect this, the above step-by-step process has been developed into a cyclical diagram (with Step 1 following Step 4 in a new cycle), representing public bodies' continual evaluation of and building upon their climate change action. However, the steps can also be undertaken concurrently as developing knowledge and individual areas of action inform new or revised approaches to embedding climate change action.


Step 1

In order to deliver the climate change duties effectively, public bodies need a good understanding of the legislative and policy context influencing action on climate change in Scotland.

Public bodies should be mindful of key drivers to reduce greenhouse gas emissions, adapt to the changing climate and act sustainably, which are summarised below. The climate change context is continually evolving.

For the latest position please see

A useful glossary of climate change terminology can be found on the United Nations Framework Convention on Climate Change website at:

The outcome of Step 1 will be:

  • public bodies understand the three parts of the public bodies climate change duties: mitigation, adaptation and acting sustainably.


In order to limit future climate change caused by human activity, we need to first stabilise and then reduce levels of greenhouse gases in the atmosphere. The effect of emissions already released to the atmosphere will be felt for some time to come, so reducing emissions now will help to mitigate climate change impacts in the longer term. Activities that help reduce our emissions are referred to as climate change mitigation.

Scotland's framework for reducing greenhouse gas emissions is set out in section 2.3. More information on greenhouse gas emissions can be found at Annex A .


Scotland is already feeling the effects of climate change, with rising temperatures and more frequent extreme weather events impacting on our lives, the environment and the economy. Much of the change to the climate over the next 30 - 40 years is already determined by our past and present emissions. UK Climate Projections ( UKCP09) show the changes that can be expected and, broadly, Scotland will get warmer, wetter winters and hotter, drier summers. These changes will have a variety of impacts, including increased flood risk, longer growing seasons and new pests and diseases. While urgent action to reduce emissions is vital, so is action to reduce Scotland's vulnerability to the impact of our already changing climate.

By planning and preparing for change now, Scotland will be better placed to adapt to the threats and take advantage of the opportunities as we look to build the low-carbon economy of the future.

Assessing the consequences of the changing climate and altering our plans or designs to account for these changes, is referred to as climate change adaptation. In order to adapt we need to understand how the climate is changing. Information on changes in Scotland's climate can be found at Annex B .

While the Act does not require an adaptation programme until after January 2012, the Scottish Government recognises that action is needed now to ensure we are adapting effectively to the unavoidable changes in our climate and, in 2009, published Scotland's Climate Change Adaptation Framework 27 . This Framework is a non-statutory forerunner to the adaptation programme required in 2012/13. Section 44 of the Climate Change (Scotland) Act 2009 requires that public bodies must act in the way best calculated to help deliver any such statutory adaptation programme.

Scotland's Climate Change Adaptation Framework sets out how Scotland should adapt to its changing climate. The framework will help improve understanding of the consequences of these changes, equip stakeholders with the skills and tools they need to adapt as well as help decision takers make the right choices for the future.

Public bodies should familiarise themselves with the Adaptation Framework and the steps it proposes for preparing for climate change.

Box 1 sets out the six principles established by the Adaptation Framework to help ensure that adaptation action is sustainable and coherent.

Box 1: The Six Principles of Scotland's Climate Change Adaptation Framework

Adaptation must be addressed alongside actions to reduce emissions. Actions to adapt for a changing climate must also meet ongoing requirements to reduce emissions. Without mitigation, the scale of adaptation challenges will increase significantly.

Adaptation should build broader resilience, such as through an ecosystem approach. Changes in Scotland's climate will bring both short and long-term challenges. In addressing immediate impacts of climate change, opportunities for developing broader benefits of strong communities, sustainable economic growth and a healthy environment should be considered, as this will make Scotland more resilient to future change.

Climate change gives a new impetus to taking an ecosystem approach that considers the interdependence between species, habitats, and associated natural processes, and the ecosystems services that derive from them.

Adaptation should be informed by a cycle of review and action. Actions to adapt must account for inherent uncertainty of climate projections and related factors through monitoring and reviewing systematically. This improves the knowledge base by identifying those responses which have been successful and allows for the incorporation of new information on risk.

Adaptation should be integrated into existing development and implementation practices. Preparing for a changing climate should be integrated into existing risk management and planning processes and decisions, as an extension of good development practice.

Adaptation should be integrated at an appropriate scale. Adaptation to the impacts of climate change is often most effectively implemented at a local level, as the impacts and consequences may vary considerably by area or community. A local approach will be enhanced through broader support for capacity building, sharing of best practice and supporting policy.

Adaptation should seek to be developed in partnership with interested parties and avoid restricting others from adapting. Climate change will impact on many resources, such as water, that are vital to a number of individuals and organisations from across sectors. In developing adaptation actions, the interests of others and other sectors should be considered. Seeking a more joined-up approach may enhance the effectiveness and sustainability of the planned adaptation.

Public bodies are not formally required, through the climate change duties, to help deliver the Scottish Government's Climate Change Adaptation Framework. However, the Scottish Ministers would strongly advise public bodies to consider the risks and opportunities climate change presents to their business continuity now and how, in delivering their functions, they may build broader resilience to change in Scotland. Many decisions and investments made by public bodies today will have an impact on decades to come.


Sustainable development is development that aims to allow everyone to satisfy their basic needs and enjoy a better quality of life without compromising the quality of life for future generations.

Acting sustainably therefore requires public bodies to routinely balance their decisions and consider the wide range of impacts of their actions.

The widely-used definition which derives from the 1987 report, Our Common Future, by the World Commission on Environment and Development (known as the Brundtland Commission) defines sustainable development as:

"development that meets the needs of the present without compromising the ability of future generations to meet their own needs".

Sustainable development is integral to the Scottish Government's overall Purpose - 'to focus government and public services on creating a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth.' - and underpins the Greener strategic objective.

In developing policy and taking properly-balanced decisions consistent with the goals of sustainable development, five broad principles of sustainability can be followed:

These are to:

live within environmental limits; and
ensure a strong, healthy and just society

and to do so by means of:

a sustainable economy;
promotion of good governance; and
responsible use of sound science

Diagram 2: UK shared framework principles for sustainable development

Diagram 2: UK shared framework principles for sustainable development

Source: Sustainable Development Commission

Acting sustainably is already central to the day to day activities of many public bodies and some bodies already have sustainable development duties, either through the overarching Duty of Best Value, or more specifically; for example, under the Environment Act 1995, SEPA is required to act in line with sustainable development when carrying out its role and have regard to the wider social and economic issues when protecting the environment and human health.

Organisations' influence on sustainability extends beyond their immediate environment through the actions they take forward and how the actions are taken forward.


Step 2

Public bodies are required by the Act, to consider the climate change duties in ' exercising their functions'. Step 2 explores how to assess a public body's impact and influence on greenhouse gas emissions, how to understand the impact of the changing climate upon a public body as an organisation, and a public body's influence in preparing Scotland for a changing climate.

The outcome of Step 2 will be that public bodies can identify:

  • how they impact on and influence greenhouse gas emissions;
  • how they can help prepare Scotland for a future climate and how climate change could affect their organisation; and
  • how they can incorporate the principles of sustainability into their decisions and actions.


Public bodies impact on or influence climate change by having a:

a) Direct impact on greenhouse gas emissions

Public bodies have a direct impact on emissions through management of their staff and estate. Public bodies need to understand this direct impact and what actions they could take to reduce it.

Box 2: Direct and Indirect emissions - definition

The Greenhouse Gas ( GHG) Protocol 28 defines direct and indirect emissions as follows:

  • Direct GHG emissions are emissions from sources that are owned or controlled by the reporting entity.
  • Indirect GHG emissions are emissions that are a consequence of the activities of the reporting entity, but occur at sources owned or controlled by another entity.

Section 5.2 on recording, monitoring and assessing greenhouse gas emissions provides further detail on the definition of direct and indirect emissions in Box 7.

b) Indirect/wider influence on greenhouse gas emissions

The way public bodies carry out their functions, the decisions they make and their general engagement with stakeholders means that they have a much wider sphere of influence on greenhouse gas emissions than just their direct impact on emissions, including how efficiently they use, recycle and dispose of resources of all kinds. It is important that public bodies understand this indirect impact and wider sphere of influence and how they can address greenhouse gas emissions through this influence.


Public bodies are impacted upon by a changing climate and will need to:

a) Be resilient in a changing climate

Impacts of the changing climate will be felt by organisations irrespective of their size, location, activities and services. Public bodies depend on secure supply chains, resource supplies (energy, water, materials) and infrastructure and these could be at risk from the changes in the climate - for example, increased flood risk. It is important that to operate effectively, public bodies are resilient in the face of climate change. Understanding the changes and how these changes could impact on the day to day running of the organisation is a useful starting place. For example, public bodies could put in place Sustainable Drainage Systems ( SUDS) on their own estates.

b) Help Scotland prepare for a changing climate

Through carrying out their functions, some public bodies will play a central role in preparing Scotland for a changing climate. For example, a planning authority taking account of flood risk in decisions on the location of developments. Public bodies can also influence Scotland's resilience by, for example, protecting ecosystem services such as natural flood management.

Another key role for public bodies will be in influencing and supporting the resilience of individuals and communities to the impacts of climate change, for example, by building adaptive capacity through raising awareness of impacts and community consultation as part of the adaptation planning process.

Public bodies' functions vary significantly, and include undertaking statutory roles and providing essential services to people living and working in Scotland. These activities need to be maintained and remain affordable in the face of a move towards a low-carbon future and a changing climate.


All functions of a public body need to be examined in relation to their impact on and influence on greenhouse gas emissions and how a changing climate will influence the functions. For the purpose of this guidance, the wide range of public sector functions have been grouped below into three high-level generic areas: corporate, policy and delivery. Public bodies should also consider how a changing climate might impact on the measures they have in place under each of these areas, and on action to reduce emissions.

a) CORPORATE - Includes business planning, staff management, estate management and procurement.

All public bodies have a direct impact on emissions through the way they carry out their functions, including how they manage their estates and staff. Public bodies can reduce emissions through the way they manage their estate; this includes energy use, water use, waste management and staff travel. Business travel policies can lead to a reduction in emissions.


Procurement (of goods, services, works and utilities) is a key lever through which public bodies can influence a more sustainable economy, greenhouse gas emissions and ensure resilience to a changing climate. The following sections provide more detail on sustainable procurement.

Climate Change (Scotland) Act 2009

The Climate Change (Scotland) Act makes provision for Ministers to call for any public sector organisation covered by the Act to report on its compliance with the Public Bodies Duties contained in the Act. The Act also provides that, by Order, Ministers can require any public body found to be failing to comply with its climate change duties, to prepare a report on the actions it has taken, is taking or intends to take to secure future compliance with those duties. The Act goes on to say that any report must, in particular, contain information relating to how:

(a) procurement policies; and
(b) procurement activity

have contributed to compliance with climate change duties.

Scottish Sustainable Procurement Action Plan

In October 2009 the Scottish Government published the Scottish Sustainable Procurement Action Plan. The Action Plan 29 provides generic guidance for public bodies in Scotland on sustainable procurement. Sustainable procurement is defined in the Plan as " A process whereby organisations meet their needs for goods, services, works and utilities in a way that achieves value for money on a whole life basis and generates benefits not only to the organisation, but also to society, the economy and the environment".

Effectively implementing the Sustainable Procurement Action Plan may well assist individual organisations in demonstrating their compliance with the Public Bodies Duties in the Climate Change (Scotland) Act 2009.

The Action Plan makes clear that the greatest benefits are to be gained by considering sustainability at the outset of the procurement process - when requirements are being identified, specified and advertised. It provides advice on how to specify requirements in a way that will maximise social, economic and environmental benefits.

Building in sustainable outcomes to procurement activity at the beginning of the process ensures that all tenderers are bidding to a set minimum standard. This helps to ensure that tender evaluations and contracts awards meet the obligations of equal treatment and transparency that European legislation requires as part of public sector procurement.

Government Buying Standards

The Sustainable Procurement Action Plan includes a series of specifications (the "Buy Sustainable - Quick Wins", now known as the "Government Buying Standards") for commonly bought goods. The specifications set minimum and enhanced levels of sustainability factors such as energy efficiency and emissions and they can be easily adopted into public sector contract requirements.

Adopting the Government Buying Standards where they are consistent with national and local policies will help to minimise harmful greenhouse gas emissions.

The Action Plan promotes sustainability in public sector contracts in many other ways, including a "Sustainability Test" and the "Flexible Framework".

Sustainability Test

The Sustainable Procurement Action Plan recommends that public sector organisations apply a "Sustainability Test" to their contract requirements. Requirements should be scrutinised before the formal procurement process begins to ensure, for example, that they:

  • Are still required
  • Cannot be delivered by other, more efficient, means
  • Maximise beneficial outcomes
  • Minimise or avoid negative outcomes such as harmful emissions and unnecessary waste.

Flexible Framework

The Action Plan also includes a self-assessment tool, the "Flexible Framework", that enables public (and private) sector organisations to measure - and identify steps to improve - the sustainability of their procurement. It looks at sustainable procurement through various aspects of the organisation's operation and provides a straightforward means of assessing where the strengths and weaknesses lie and what should be done to improve performance.

Emissions arising from transportation

European legislation, including the European Treaty and European Procurement Directives, is designed to promote open trade across Europe. It does not permit discrimination on the basis of where within Europe suppliers are located. It would therefore be illegal to give favourable treatment to any suppliers according to how "local" they are to the public sector organisation concerned. Taking into account during the procurement process the emissions arising from transportation of goods is likely to be seen as indirect discrimination and therefore also illegal.

Many public bodies also deliver services through contractors and/or various other arrangements such as arms length companies. Through the duties, there is an expectation that where public bodies procure or deliver services through others, these services will be designed to support climate change emissions reduction targets.

Food Procurement

The public sector has a significant influence through the goods and services that it procures and one significant example of this is in food supply: over the next few decades, the global food system will come under renewed pressure from the combined effects of climate change and other factors such as population growth and migration. Purchasing food sustainably can not only contribute to emissions reduction targets, but also deliver additional socio-environmental benefits including health improvement, economic development, food security and supporting the agricultural industry in its own response to climate change.

The Scottish Government has published new guidance, Catering for Change, on the sustainable procurement of food and drink in the public sector, which includes information on: developing a sustainable food procurement policy, sustainable development principles in relation to sustainable food procurement and building sustainability into the procurement process. The guidance can be accessed via the Scottish Government website 30 .


The public bodies duties should similarly be considered in relation to disposal of public assets, and public bodies may wish to consider the implementation of a 'climate change burden' in relation to property, as detailed in Section 68 of the Climate Change (Scotland) Act 2009. Section 68 inserts a new section (46A) into the Title Conditions (Scotland) Act 2003 to create a new kind of real burden - a 'climate change burden' - that can be added to a property's title deeds to specify the mitigation or adaptation standards that must be met when the burdened property is developed.

Staff engagement

Public bodies can also influence emissions through engaging with their workforce, working to achieve buy-in to action on climate change at all levels of the organisation, and ensuring that staff feel empowered to play their part in cultural change. This could include raising awareness of the imperative to reduce emissions, addressing this in future workforce skills requirements and training, and creating a sense of shared ownership by asking staff to identify contributions they can make such as switching off office equipment at night. The public sector employs a large number of people in Scotland and the workplace is a key environment in which people can not only learn the skills they need to address climate change but also, through making informed choices in their everyday work environment, promote significant cultural change both there and beyond at home and in their communities.

b) POLICY - Includes policy making, decision making, influencing and consultation functions of public bodies.

Policy making functions influence greenhouse gas emissions and adaptation through the decisions that are made and policies that are put in place. These decisions impact on how services are delivered. For example, spatial planning policies may impact on greenhouse gas emissions associated with waste, transport and energy in a particular local area. Spatial planning policies may also affect the resilience of natural systems to the changing climate and the vital resources they provide, such as food and water. Education policies will influence how climate change is addressed in the education sector. Energy policy can also influence greenhouse gas emissions and the resilience of energy infrastructure to the impacts of the changing climate.

c) DELIVERY - Includes regulatory, spatial planning, education, advice, awareness, engagement, grants, funding, subsidies, licensing, research, monitoring, science and other service delivery such as waste collection, healthcare and recreation.

Public bodies influence greenhouse gas emissions through the decisions they make in the process of delivering services. For example, a planning authority giving permission to a particular development may be able to influence the greenhouse gas emissions associated with that development.

Public bodies that administer grants, funding, subsidies and licences can also impact on or influence greenhouse gas emissions from those that are receiving the grant, funding, licence or subsidy and may opt to address this through imposing relevant conditions on the contract.

A significant number of public bodies have education, advisory, informing and awareness raising roles and it is important that these bodies understand the impact and links of their actions to climate change. The public sector engages and informs various stakeholders, including the public, everyday and has a responsibility to address climate change through this role. Awareness campaigns run by the public sector should seek to address climate change where appropriate.

Universities and colleges have a key role to play in addressing climate change. They have much to contribute to understanding of climate change and sustainable development through their primary role as educators, skills trainers and researchers. This extends to their role as the focus of many local communities, positioning them to influence and lead on wider community and social initiatives.

Public bodies also need to ensure that their services, and decisions they make to deliver these, are resilient to changes in the climate and help Scotland prepare for the future.

Public bodies with research, science and monitoring roles have much to contribute to our understanding of climate change. As a cross cutting issue, climate change touches on a wide range of issues and it is important that these links are understood across the public sector.


The questions in Box 3 are suggested as a good starting point to identify potential impacts and influences of a public body on climate change and climate change impact on a public body, which can then be used as a starting point to explore action to be taken in response. For example, answering 'Yes' to any of the questions should prompt further inquiry into the nature of the impact (mitigation or adaptation) and the means by which this is best understood and managed.

Box 3: Impact and influence of public bodies on climate change and the changing climate

Greenhouse gas emissions (climate change mitigation)

  • Does your public body use offices, buildings or other facilities that require energy use?
  • Does your public body procure goods and services?
  • Does your public body have employees who travel for business?
  • Does your public body influence greenhouse gas emissions in the key sectors of: energy, transport, business and industry, land management, residential or waste management?
  • Does your public body influence travel patterns including number and length of journeys made and the mode of travel?
  • Does your public body have a role in protecting or impacting on use/disturbance of soils?
  • Does your public body influence energy generation?
  • Does your public body influence energy efficiency?
  • Does your public body affect energy consumption in people's homes or in offices/workplaces?
  • Does your public body influence opportunities for the development of low-carbon economy and low-carbon technologies?
  • Does your public body influence waste arising or the amount of biodegradable waste going to landfill?
  • Does your public body influence agricultural practices and production?
  • Does your public body influence the construction/reconstruction of any infrastructure?
  • Does your public body influence any changes to the way land is used or will it influence forest planting/forest management?
  • Does your public body influence planning and/or land use strategies?
  • Does your public body engage with the public and wider communities?

Adapting to the changing climate

  • Does your public body use offices, buildings or other facilities that could be affected by the changing climate?
  • Does your public body rely on energy and water supplies and/or telecommunication and transport networks which could be disrupted by the changing climate?
  • Does your public body have employees who travel for business?
  • Could the services your public body delivers be affected by changes in the climate, e.g. flooding?
  • Does your public body influence the location or design of new developments, critical infrastructure and public services?
  • Does your public body influence the protection of existing infrastructure, including essential services, from risks such as flooding, erosion and storm damage?
  • Does your public body influence the use of water or water supply?
  • Does your public body influence the management of water systems including drainage?
  • Does your public body influence ecosystem services such as natural flood management and maintaining soil carbon?
  • Does your public body influence habitat networks and corridors for movement of species?
  • Does your public body engage with the public and wider communities?


Public bodies must also ensure they are acting sustainably through their actions and through the decisions they make.

Box 4 provides an example of a 'sustainability checklist' which may assist organisations to identify the extent to which they impact on a range of social, environmental and economic factors. All of these factors need to be appropriately balanced by bodies in making decisions in the exercise of their functions.

The checklist does not cover responsible use of sound science or promotion of good governance; however, if relevant, these should be considered alongside the three other principles.

Box 4: An example of a sustainability checklist for considering social, environmental and economic impacts

Social - To what extent, in exercising its functions, does your public body:

  • impact on health and wellbeing?
  • contribute to the protection and enhancement of Scotland's cultural and historic heritage?
  • ensure that all areas have access to good quality public services?
  • affect numbers of people gaining education and skills?
  • ensure that all areas have access to good quality housing that is both affordable and safe?
  • tackle poverty and reduce economic inactivity in our most deprived communities?

Environmental - To what extent, in exercising its functions, does your public body:

  • lead to change in the emission of greenhouse gases?
  • get impacted upon by changes in our climate?
  • have an impact on air quality?
  • protect our inland and coastal waters?
  • disturb or enhance habitat and wildlife?
  • encourage resource efficiency and help minimise waste?
  • take opportunities to enhance the environment?
  • otherwise impact on the natural environment?

Economic - To what extent, in exercising its functions, does your public body:

  • promote the spread of prosperity to all parts of Scotland?
  • help bring long-term jobs and skills to communities?
  • engage and work with small businesses?
  • encourage the use of new and innovative technologies and/or provide 'green' advice to businesses?
  • impact on costs and availability of goods and services?
  • bring savings to government and wider public sector?
  • have an influence on opportunities in the green economy and the low-carbon economy?


Step 3

Mainstreaming means integrating climate change into the everyday work of a public body at all levels including senior management, policy makers, service delivery and external partners and requires:

  • Strong leadership and shared ownership of climate change action: By ensuring that responsibility for leadership on climate change is clear within the organisation, both at management level and cascaded throughout, accountability for climate change action will be increased.
  • A declared commitment to action on climate change: Making a public body's commitment to deliver against the climate change duties visible and transparent, both to those who work within the organisation and to stakeholders, suppliers and service users, will increase the level of scrutiny of climate change actions, and public bodies will begin to exert positive influence over the behaviours of their stakeholders, supplier and service users.
  • Integration of climate change within business planning, e.g. through policy appraisal, impact assessment, SEA: Building a process whereby the 'climate change question' and 'sustainability question' is routinely asked as part of the decision making process around new and existing policies, plans and proposals, will ensure the impact of that decision on climate change is considered and public bodies are seeking to act sustainably.
  • Partnership working with external bodies and interests: Working cooperatively with other public bodies, e.g. bodies in the same geographic area, or bodies working in the same sector, will maximise efficiency and increase the impact of climate change action.

The outcomes of Step 3 will be:

  • Public bodies start to take action to help them implement the climate change duties;
  • Public bodies' governance supports climate change action;
  • Public bodies have strategies/action plans to address climate change as appropriate;
  • Public bodies set outcomes and targets for emissions (direct/indirect);
  • Public bodies integrate greenhouse gases into decision making through carbon impact assessments;
  • Public bodies are prepared for a changing climate;
  • Public bodies supporting climate change awareness and engagement work; and
  • Public bodies in Scotland are acting sustainably.


Taking action to strengthen a public body's governance, leadership and commitment in regard to climate change will significantly contribute to the successful implementation of the climate change duties. The public sector has a central role in helping Scotland to reduce greenhouse gas emissions, move towards a low-carbon economy and prepare for the future climate. Strong governance, leadership and commitment within the public sector is vital.

Suggested actions: Governance, leadership and commitment

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Develop commitment to climate change within the senior management of the organisation to ensure that climate change is visible in management processes and decisions and to promote increased awareness of climate change and appropriate action at all levels of the organisation.
  • Promote this climate change commitment to staff, service users, stakeholders, delivery partners and suppliers, e.g. by referring to it in other published material (such as a medical practice handbook), website, displaying within the public body's premises etc.
  • Be able to demonstrate commitment and leadership in addressing climate change and consider where appropriate a formal governance system for addressing climate change within the organisation with a nominated lead or champion from senior management.
  • Consider demonstrating visible leadership by making a public commitment to address climate change through the actions of the organisation. This could be part of an organisation mission statement or stated priorities. Joint action in association with partners is also encouraged and there are already good examples of these (the local authorities' Climate Change Declaration and the Universities and Colleges Climate Change Commitment for Scotland).


As part of public bodies' planning processes, public bodies may wish to consider developing a strategy to embed mitigation and adaptation across the organisation which sets clear climate change outcomes, indicators and targets. These could be brought together through a detailed work programme based on how a public body impacts on and influences climate change. It is likely that Major Players, based on their impact and influence, would have more detailed strategies.

Suggested actions: Developing a strategy or action plan

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Develop a set of climate change objectives and commitments.
  • Build climate change into business planning processes by ensuring a climate change test/check is applied to all new and existing plans, policies and proposals. The appropriate form of this 'test' will depend upon the type of plan, policy or proposal - examples include conducting a Strategic Environmental Assessment ( SEA) when required, using a sustainability/climate change checklist, and the application of a sustainability test to procurement specifications, as set out in the Scottish Sustainable Procurement Action Plan.
  • Develop a detailed strategy or action plan. The programme of work should include actions and commitments to contribute to the delivery of Scotland's targets and to help prepare for a changing climate. Strategies could be part of existing corporate plans or in a separate document depending on the nature of the organisation. It is likely that Major Players will have more detailed strategies.


Setting clear and publicly-available targets drives improved performance, hence the ambitious national targets that have been set for Scotland (at least 42% reduction in GHG emissions by 2020, 80% by 2050), as well as annual targets for the period 2010-2022. As stated earlier, these are economy-wide, rather than sector-specific targets. It is not for this guidance or for the Scottish Government to set specific targets for individual public bodies, however the trajectory set out in the Climate Change (Annual Targets) (Scotland) Order 2010 provides an indication of the reductions required on an annual basis to meet the longer terms targets of the Act.

What may constitute an 'appropriate' target will depend on the nature of the public body itself. The extent of activities and influence an organisation may have on emissions varies widely across the public sector. In addition, the progress that an organisation has already made in reducing emissions will affect how much further they can progress in the near future. In view of this, public bodies are expected to identify their own ambitious targets. Whilst the guidance is non-prescriptive in terms of targets, there is a presumption, in the case of bodies which may have a major influence on their own or others emissions, and the Scottish Government, that targets should echo the ambition of the national targets. Where this is not the case, the reasons for this should be explained.

In setting targets in respect of direct emissions reductions, account should be taken of the intended trajectory of emissions reductions. Indirect emissions reductions should also be considered in supporting delivery of the targets.

There is greater potential for complexity when accounting for indirect emissions, and it may also be difficult to estimate how effective efforts have been to reduce them.

There are best practice principles which can be applied to carbon accounting for indirect emissions and the Scottish Government in conjunction with partners in Scottish Enterprise and SEPA are developing this understanding going forward, with the aim of creating a best practice user community. Achieving a greater degree of consistency in the reporting of indirect emissions is desirable and will form part of the work programme going forward.

Public bodies need to collectively identify methods which work best for them. Public bodies should therefore actively seek to engage with each other for the purposes of improving their understanding of their influence over emissions, and how best to capture that information.

Recording associated direct and indirect greenhouse gas emissions will allow public bodies to set targets and monitor progress in achieving these targets. In order to reduce emissions and work towards a target, bodies need to understand how their emissions arise, through a combination of environmental/carbon management processes and environmental reporting. Based on an understanding of the pattern of associated emissions, public bodies can begin to set out the actions they will take to manage and reduce emissions.

In general, it is anticipated that the information on indirect emissions would be used only by the public body in question to develop an understanding of its influence over the direct emissions of other entities - that is, to inform decisions. There is inevitably the potential for "double counting" of emissions in such instances, and to avoid that possibility, reported indirect emissions data will not be totalled at a national level.

Estimates and assumptions may be compared when learning about which methodologies are most successful but, in general, it is expected that the information be used only by the public body in question to aid in understanding the ways in which they might influence the direct emissions of other entities - that is, to inform decisions.

Major Players with significant influence on emissions are encouraged to set annual targets for direct emissions and, where possible, indirect emissions and to show these at least for the five years ahead (and preferably through to 2022). This dovetails with the requirements of the Act that Scottish targets are set for each year. They are also encouraged to strive to meet or exceed annual targets, wherever possible, without rollover.

Major Players with less influence on emissions and other public bodies could set targets more flexibly to fit with their planning processes, perhaps over a three- or five-year period. It is recognised that these bodies may also require more flexibility around rollover and smoothing between year ends.

Public bodies with limited influence on emissions and small estates and/or staff numbers are encouraged to consider how they plan to deliver emissions reductions in the medium term, in recognition of the fact that, with much less of an impact on emissions, they may have less scope and it might be appropriate that they simply seek to ensure they reduce emissions as they go forward, rather than setting specific targets.

Actions and commitments to reduce emissions will help public bodies work towards their targets and support Scotland in moving towards a low-carbon economy.

Chapter 5 on practical support and tools provides more information on how to approach measuring and monitoring greenhouse gas emissions and actions that can be taken to reduce these emissions. Within this chapter, Box 7 provides an explanation of direct and indirect emissions.

Suggested actions: Setting targets for direct and indirect emissions

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Major Players with a significant influence on emissions are encouraged to set baselines and annual targets for emissions and to show these at least for the five years ahead (and preferably through to 2022). They are also encouraged to strive to meet or exceed annual targets, wherever possible, without rollover.
  • Major Players with less influence on emissions and other public bodies could set baselines and targets more flexibly to fit with their planning processes, perhaps over a three- or five-year period. It is recognised that these bodies may also require more flexibility around rollover and smoothing between year ends.
  • Where possible, baselines and targets should include both direct and indirect emissions (see Box 2). The boundaries of emissions included in baselines and targets should be clearly defined. Where baselines and targets do not already exist, appropriate baselines and targets based on the most recent information available should be established, by 2012 where possible.
  • Public bodies with limited influence on emissions and small estates and/or staff numbers are encouraged to consider how they plan to deliver emissions reductions in the medium term, in recognition of the fact that it may be appropriate they simply seek to ensure they reduce emissions as they go forward, rather than setting specific targets.
  • Actions to reduce emissions should be identified. Public bodies should understand principles of good carbon management and put these into practice in the way they run their operations in order to achieve high standards and continuous improvement in their operational environmental performance.
  • Any targets set for direct and indirect emissions and the actions to reduce these emissions should be published in a plan or delivery statement. This plan could be part of an existing corporate plan, or a separate document, depending on the nature of the organisation.
  • Public bodies should work to improve energy efficiency: for example, switching off lights and office equipment at night and following the principles and programme set out in the Energy Efficiency Action Plan 31 .
  • Public bodies should seek to put in place a travel plan for business travel, travel by staff to and from work, and travel by visitors to and from the service provided and to reduce emissions associated with staff travel by using more sustainable modes of transport and travelling less frequently.
  • Public bodies should work to promote sustainable workplaces through identifying areas for action within the office which would tackle emissions and identify opportunities to promote and influence sustainable thinking among staff.


Assessing carbon can also be used to compare options and assist in the identification of ways of reducing/minimising the carbon impact of proposed activities/interventions. Carbon impact assessments are a useful tool to ensure that the decisions being made, and the way a public body is delivering its services and using resources, are contributing to Scotland's move towards a low-carbon economy. Decisions on the ground should take account of the carbon impact to help achieve the national targets.

NB. Emissions falling within the wider sphere of influence can be much more difficult to quantify and in some instances it might not be appropriate to quantify or measure these emissions.

Suggested actions: Carbon Impact Assessments

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Consider using carbon impact assessments to ensure that carbon is factored into all decision making. Internal procedures and processes should be put in place using qualitative or quantitative assessments.


It is both important and good business practice to ensure that the services being delivered to the public are resilient to the changing climate. In the face of a changing climate, a public body must ensure that the services it delivers are resilient.

Suggested actions: Prepare your organisation for the changing climate

  • Public bodies should ensure that their operations and service delivery have planned for changes in the climate, for example through resilience planning, risk assessment and delivery of locally-appropriate adaptation measures.


Public bodies influence and make decisions which affect Scotland's society, economy and environment and which will help Scotland adapt to the changing climate. When bodies make decisions, these decisions need to consider the risks and opportunities associated with a changing climate and ensure that projected changes in the climate are taken into account.

Where an SEA is applied to a particular plan, programme or strategy, it will serve as a useful tool to help take adaptation into account.

Diagram 3: Model for adapting to the changing climate in Scotland

Diagram 3: Model for adapting to the changing climate in Scotland

Suggested actions: Helping Scotland adapt to the changing climate

  • Public bodies which are responsible for local and national plans and policies should analyse whether the plans and policies are resilient to the impacts of the changing climate.
  • Public bodies should identify how these local and national plans and policies can help Scotland adapt to a changing climate.
  • Public bodies should take into account how their plans and policies can help Scotland's natural environment adapt to climate change.
  • Public bodies should consider and support Scotland's Climate Change Adaptation Framework.


In making decisions about priorities, public bodies should be mindful of the third duty and act in a way which is most sustainable.

Acting sustainably will mean building in sustainability principles across a public body's functions and decision-making processes and considering the principles of sustainable development in setting out plans and priorities.

Best Value

Over the past decade or so, under the existing duty of Best Value, a number of organisations 32 , 33 have already been required to demonstrate (amongst other characteristics) how the individual organisation is making a contribution to sustainable development through their actions, processes and the outcomes they deliver (individually and, increasingly, across multiple partnerships or through contracts).

Sustainable development is a core part of Best Value and an organisation subject to the Best Value duty is already required to demonstrate an organisational culture which recognises the value of working with wider stakeholders and partners to achieve more effective and sustainable policy development, better services and customer-focused outcomes.

The Audit Scotland Sustainability Toolkit 34 is a tool to support local authorities in delivering this duty on sustainable development and more information can be found in Chapter 5.

Suggested actions: Acting sustainably

  • Public bodies should work to understand the impact of their corporate operations, policies and service delivery on the environment, society and the economy and explore ways to reduce this, in accordance with the principles of sustainable development.
  • Public bodies should, where necessary, assess the sustainability of their business activities and decisions to ensure they are acting sustainably by taking into account their impact on society, economy and the environment, in line with the principles and requirements of SEA (see section 5.3)


The Scottish Government encourages public bodies to work together through existing mechanisms - for example, through Community Planning Partnerships ( CPPs), and Single Outcome Agreements - or through devising new partnerships. Although CPPs as a single entity are not covered by the climate change duties (as 'Community Planning Partnership' does not appear as an entity on Schedule 1 of FOISA), some of their constituent organisations such as councils, health boards and other public bodies will be covered in their own right.

Co-ordinated action on climate change could deliver real benefits for those across the public sector and in conjunction with the third sector and private sector, as well as building capacity and providing opportunities to share best practice. Public bodies are therefore encouraged to think about the potential for joined-up action both within or between Community Planning Partnerships, and through other mechanisms or existing networks.

Suggested actions: Partnership working

  • Public bodies should seek opportunities to work in partnership to help address climate change and should consider how this commitment could be demonstrated through examples which provided positive outcomes.


Public bodies should raise awareness internally and externally on climate change and work towards buy-in from staff at all levels of the organisation, supporting and enabling them in understanding the contribution they can make in addressing climate change. Public bodies in Scotland employ large numbers of staff and each employee has the potential to carry the message regarding taking action on climate change beyond the immediate workplace, to their wider sphere of influence (home, community groups, etc). Workplace engagement strategies should assist in ensuring that all employees in the organisation have an understanding of the impacts of climate change, in order to generate a sense that they collectively 'own' a public body's response to this and feel empowered to contribute to its actions. Public bodies are encouraged, where possible, to also embrace wider action throughout the community.

In addition to identifying the actions we as individuals can all take to help meet Scotland's targets, the Scottish Government's Public Engagement Strategy contains a delivery plan for the year ahead which gives examples of actions being taken by private, public and voluntary bodies to engage with the public on this agenda through a range of networks. Public bodies should consider the information provided in the strategy; support the Public Engagement Strategy and create their own plans for communicating with their partners, stakeholders and staff to take forward climate change action as appropriate. This recognises that public bodies have a wide range of stakeholders and constituents who are affected by and have an interest in climate change, and they have long experience in engaging with their local communities.

Suggested actions: Raising awareness and engagement

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Public bodies should work to raise awareness of and achieve buy-in to action on climate change at all levels of their organisation.
  • Public bodies should support the climate change Public Engagement Strategy to involve the whole of Scottish society in helping to deliver climate change objectives.
  • Public bodies should develop their leadership capacity in relation to the low-carbon economy through their work to reduce carbon.
  • Public bodies should put an internal sustainable development/climate change awareness training programme in place (e.g. through induction/continuing professional development) to help employees understand their role in addressing climate change.


Step 4

It is important that public bodies monitor how they are doing in respect of their climate change duties in order to gauge progress and to make adjustments if necessary.

They also need to be accountable for this to stakeholders, the Scottish Ministers, the Scottish Parliament and their communities. Transparent and open reporting is a crucial element of maintaining public confidence in the performance of a public body. It will also assist a public body in demonstrating that it has complied with its climate change duties.

We know that reporting increases the level of scrutiny and drives improvement.

The outcome of Step 4 - 'Reporting' - will be:

  • Transparent and open reporting on the delivery of the public bodies climate change duties, which generates public confidence in the performance of public bodies, drives improvement and assists public bodies in demonstrating compliance with their climate change duties.


Public bodies are used to reporting their performance across many aspects of their functions. Public bodies are expected to ensure that their reporting addresses the progress they are making in relation to climate change action. It is important that climate change reporting is linked to the outcomes, indicators and targets for climate change action set through the public body's business planning process (see Step 3: Take Action). This will enable public bodies to review when and where adjustments in policy and practice might be required over time.

This guidance is not prescriptive on how to report (in line with its advisory purpose). Public bodies can decide whether to use existing reporting mechanisms or whether a standalone report might be appropriate. Public bodies which either have a very small number of staff or do not have property are encouraged to consider possible alternative ways of communicating their action in respect of the public bodies duties, which could be through related/parent organisations or an alternative report.

When considering the issue of reporting, public bodies (particularly Major Players) may find it helpful to consider their climate change duties alongside other reporting activity; namely; the obligation under section 76 of the Climate Change (Scotland) Act for the Scottish Ministers to prepare a report on the efficiency and contribution to sustainability of the civil estate and the sustainability reporting requirements within the Government Financial Reporting Manual ( FReM). A summary of activity in these and detail of other relevant areas of reporting has been included in Box 5 below.

Box 5: Other reporting requirements

Climate Change (Scotland) Act 2009 - Section 76 reporting:

Public bodies will be aware of the requirement under section 76 of the Climate Change (Scotland) Act 2009 on Scottish Ministers to prepare a report on efficiency and contribution to sustainability of buildings which are part of the civil estate and used for the purposes of Scottish central government administration. The scope of the civil estate has been defined in relation to the provisions which apply to the UK Government as: ' workspace, offices and other property (land and buildings) used to deliver departments' activities that is owned, leased, or occupied by a government body including non-ministerial departments, agencies, executive NDPBs and Special Health Authorities... It does not include the operational NHS Estate, the Prisons Operational Estate, the Foreign Office Overseas Estate, the DEFRA Rural Estate, the privatised rail entities, public corporations or the defence estate (except for certain civil elements) 35 . An analogous definition will apply in Scotland and the scope of elements statutorily required, covering information on the size and cost of estate (incl. space efficiency), waste, water, and energy will be broadly similar. The Scottish Government is currently considering whether, and how, the information to be reported under s76 could be enhanced to cover other elements of sustainability and environmental performance, and any inherent implications for our own annual environment reporting arrangements. The Scottish Government wrote to Chief Executives of affected bodies in August 2009 about data handling issues related to the preparation of reports and will bring forward further advice as appropriate in due course, which may be of interest to public bodies.

Scottish Ministers Accounts Directions: Sustainability Reporting requirements in accordance with Government Financial Reporting Manual ( FReM):

Spending bodies accountable to the Scottish Parliament funded from the Scottish Consolidated Fund will also wish to be aware of a requirement for the mandatory inclusion of sustainability reports within the Annual Reports and Accounts of affected bodies from the 2011/12 financial year. These reports are to cover performance against sustainability targets for greenhouse gas emissions, waste minimisation and management and the use of finite resources, and their related expenditure. Guidance will be prepared in due course on the reporting methodology and model to be adopted in preparing the sustainability report, based upon targets to be outlined by the Scottish Government.

Guidance prepared by HMT for central government bodies in England participating in a dry-run exercise in the (2010-11) financial year requires as a minimum all public bodies reporting in accordance with FReM to include a section in their Annual Report covering their performance on sustainability during the year including a simple commentary overview; a 'sustainability report' comprising a table of financial and non-financial information covering the organisation's emissions, waste and finite resource consumption and includes guidance on populating a suggested format for a table containing the data and associated narrative. The key principles of such reporting are that it should provide transparency, in terms of clarity and openness, consistency for comparative purposes, and that it links financial with non-financial information in each area reported on. In practice this approach allows for the preparation of a three or four-page report, concise in nature and which can signpost the reader to other sources of information and the arrangements which will apply to bodies in Scotland are expected to be broadly similar. For further information, the Sustainability and Environmental section of the FReM website offers more detail

The requirement in Scotland is expected to cover the core Scottish Government, Executive Agencies, Non-Departmental Public Bodies, Non-Ministerial Departments, Crown Office, Health Boards (including Special Health Boards), but not Public Corporations or local authorities. However, local authorities should be aware of related work by The Chartered Institute of Public Finance and Accountancy ( CIPFA) which is currently undertaking a consultation on local authority annual reporting ('telling the whole story') including consideration of sustainability reporting and the approach adopted in the HMT draft guidance. CIPFA is also currently developing a publication on public sector sustainability reporting, drawing on the Accounting for Sustainability Connected Reporting Framework (a model that informed the HMT draft guidance).

Best Value

An organisation subject to the existing Best Value duty is already required to demonstrate, amongst other characteristics, that robust arrangements are in place to monitor the achievement of outcomes (possibly delivered across multiple partnerships or through contracts) as well as reporting on specific activities and projects. The measures used to manage and report on performance will also enable the organisation to provide assurances on quality and link this to continuous improvement and the delivery of efficient and effective outcomes.

Scotland's Climate Change Declaration

Scotland's Climate Change Declaration ( SCCD) represents the commitment and leadership of Scottish local authorities to take action, in partnership with the Scottish Government, on climate change. All 32 Councils are signatories to the Declaration. It is an acknowledgement of the reality and importance of climate change to elected members and the key role of local authorities, and forms a public demonstration of commitment to this agenda. Signatories are committed to:

  • mitigating their impact on climate change through reducing greenhouse gas emissions
  • taking steps to adapt to the unavoidable impacts of a changing climate
  • working in partnership with their communities to respond to climate change

The Sustainable Scotland Network produced a template and guidance note to assist with reporting, which COSLA encourages all councils to use.

Further information about SCCD is available via the Sustainable Scotland Network's Climate Change Declaration web pages 36 .


Part 4 of the Act also gives the Scottish Ministers the power, by Order, to:

  • impose additional climate change duties on individual or categories of public bodies;
  • require reports on compliance with climate change duties; and
  • designate one or more bodies or persons to monitor and to carry out investigations into public bodies' compliance with the duties.

As no decision has yet been taken on the potential use of these Order-making powers, reporting is at this stage undertaken on a voluntary basis. There is as yet no statutory obligation on public bodies to report their progress and, until such time as this may come into effect, it is a matter for each public body to decide what is appropriate to ensure they are able to demonstrate compliance with their duties.

However, the Scottish Ministers would encourage public bodies, particularly Major Players, to be mindful of their position of influence in tackling climate change, of the fact that their action will in turn contribute to the achievement of Scotland's national climate change programme and targets, and of the benefits which open and transparent reporting could bring in helping a public body demonstrate its compliance.

The principle of proportionality is important to reporting and it is therefore suggested that those bodies with a larger influence on climate change should report in more detail and possibly more frequently than other public bodies. Major Players should consider reporting annually, whilst for public bodies with less influence on climate change this could be less frequently (particularly if their climate change targets are set over a longer time period): perhaps on a three-year basis.

Major Players should, wherever possible, seek to use a consistent approach to reporting in terms of what they report. They are also encouraged to publicly state, for example through their website, how they will report, as soon as is reasonably possible. This will assist in articulating how public bodies are contributing to achievement of Scotland's climate change ambitions.


Both quantitative and qualitative reporting are important. Public bodies should think about how their reporting would encompass action on fulfilling their three duties. The following suggestions may provide a steer:

  • MITIGATION: Reductions in emissions over the period and against baselines could be accompanied by a narrative and link the information, where appropriate, to the outcomes, indicators and targets for climate change action as set out in corporate planning processes. Information in relation to direct and indirect emissions could include procurement policies, energy efficiency measures in relation to management of estates, policies in relation to staff (for example, travel policies) as well as action in relation to delivering policies, programmes and plans in conjunction with stakeholders in the wider community.
  • ADAPTATION: Reporting in relation to adaptation could include information from public bodies' risk registers, if appropriate, and progress made in taking forward climate change resilience planning in line with the Climate Change Adaptation Framework. Information on any action to assess vulnerability to current and past climate impacts, and the impacts associated with future climate change predictions/scenarios could be included. Action to prepare for climate change impacts, to build adaptive capacity and climate change resilience, could be reported.
  • SUSTAINABILITY: Sustainability reporting could include examples of how the public body is seeking to act sustainably through its actions and decision-making processes. The 'sustainability checklist' may help in articulating the social, environmental and economic issues which have been considered in sustainable decision-making and in identifying areas where progress has been made.

As a guide, Major Players' reports might summarise the various aspects of the relationship between public body corporate planning and climate change action, namely:

  • Governance, leadership and management arrangements for climate change action and confirmation of the nominated senior management champion.
  • Reductions in relation to public bodies' direct greenhouse gas emissions.
  • Emissions arising from exercising public bodies' broader functions and the action being taken to address these.
  • Action taken to assess risks of climate change impacts and work undertaken with others on adapting to the impacts of climate change.
  • Examples of partnership working and climate change communications.
  • Other activities and achievements: both highlights and areas for improvement.

This structure is broadly in line with current reporting carried out under Scotland's Climate Change Declaration.

Public bodies would also be expected to build in a process of evaluation and review both to determine the success of their climate change policy and as part of consideration of how the information generated by reporting processes is best used to promote staff engagement and drive continuous improvement. Assessment of the value and format of reporting will be part of the ongoing cycle and adjustments should be made if necessary to ensure the reporting process remains efficient and effective.

Suggested actions: Reporting

Actions in bold are considered to have particular reference to Major Players, other actions can apply to all public bodies.

  • Public bodies undertake regular reporting of their climate change actions under the public bodies duties, either through dedicated reporting process or through an existing reporting mechanism.
  • In the case of Major Players, it is recommended that reporting should be on an annual basis; for other public bodies reporting less frequently (for example, on a three year cycle) may be more appropriate.
  • Public bodies' reporting should cover action taken against each of their three duties: mitigation, adaptation and sustainability.


Audit Scotland performs independent financial and performance audits across the whole of the public sector on behalf of the Auditor General for Scotland and the Accounts Commission. Its work covers the Scottish Government, councils, NHS bodies, other public bodies and colleges. Audit Scotland have identified addressing climate change as a key theme for their future work.

The Scottish Government intends to keep this guidance under review to ensure it remains an effective tool for assisting public bodies in their action on climate change and to consider whether adjustments need to be made in future. These could include future use of the Order-making powers in Part 4 of the Act in relation to categories of public bodies for reporting and monitoring arrangements. However, the central role in monitoring must be taken forward by public bodies themselves in relation to evaluating their performance, commissioning research when required and learning from the practices of others. Public bodies should embed this monitoring role as a continuing process within the normal policy and review cycle to evaluate and ensure their own climate change action remains in line with that required to deliver the longer-term national targets.


Email: Central Enquiries Unit,

The Scottish Government
St Andrew’s House

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