Climate change duties: statutory guidance for public bodies

5. Implementing the first duty: reducing emissions

The first of the climate change duties set out in section 44 of the Climate Change (Scotland) Act 2009 requires public bodies, in exercising their functions, to act in the way best calculated to contribute to the delivery of national emission reduction targets, i.e. to reduce greenhouse gas (GHG) emissions, also known as climate change mitigation. In the context of the duties, ‘targets’ means both the national five-yearly carbon budgets and the final 2045 target.

To help demonstrate compliance with this duty, public bodies should:

• develop a climate change strategy that includes net zero and other relevant targets and has regard to just transition principles
• develop and implement a carbon management plan or equivalent
• develop action plans to deliver key elements of the carbon management plan, detailing interim steps, costs, timescales and dependencies
• set up a process of monitoring and reporting, to report on performance against their targets and action plans
• ensure that mitigation actions maximise co-benefits, such as improved public health, reduced inequalities and enhanced biodiversity, and minimise unintended consequences such as maladaptation and negative environmental impacts
• undertake the above in a manner proportionate to their size and emissions impact, giving due consideration to their physical assets including buildings, land and fleet; their staff and service users; the services they deliver; the investments they manage; and the functions they exercise.

Key outcomes will be that public bodies:

• focus efforts on the material decarbonisation opportunities in each of their areas of wider influence, scopes 1 and 2, and scope 3
• work with urgency to reduce GHG emissions as quickly as possible in order to get under and stay under 1.5 °C aligned decarbonisation pathways, i.e. to go as far as possible as fast as possible, and minimise cumulative emissions
• put governance processes, systems and senior level accountability in place that ensure policy and project development is aligned to national emission reduction targets
• measure, monitor and report on annual progress against their targets and decarbonisation pathway.

5.1 Introduction to the first duty

To support the duty to reduce emissions, this chapter sets out how to reduce emissions in practice through the development of strategies, targets, carbon management plans, and monitoring and reporting. Detailed guidance on reporting is provided in Chapter 8 and Annexes F and H.

Net zero (or net zero carbon), in relation to organisational or corporate emissions, describes an approach which reduces an organisation’s GHG emissions as far as possible, with only the remaining unavoidable residual emissions offset through a credible and robust offsetting mechanism. Public bodies are expected to achieve net zero for scopes 1 and 2.

In this context, ‘unavoidable residual emissions’ are those emissions which remain after a body has taken all reasonable steps to reduce or remove them. They may include emissions related to specific processes or technologies for which no viable alternative currently exists, for example anaesthetic gases used in healthcare settings or refrigerant gases used in heat pumps.

Some sectors, such as aviation and maritime transport, face greater challenges and technological solutions may not currently be available on the market. In these cases, emissions should be reduced as far as possible, for example by seeking greater efficiencies and using alternatives where feasible. New technologies and solutions are continually being developed, and bodies should ensure that opportunities to further reduce or remove emissions are maximised when they become available.

Bodies should be cautious of using cost and complexity as reasons to delay mitigation action, particularly for situations where existing and robust alternative technologies are available. There may be a point beyond which costs become excessive, e.g. to remove the final residual 5-10% of emissions associated with a particular source. However, bodies should bear in mind the future costs that will be imposed on society should mitigation targets fail to be reached. Whole life analysis, incorporating the financial cost of carbon into business cases and appropriate use of impact assessments, as noted in section 4.2 above, can assist bodies to make robust and equitable decisions.

Many public body functions are key to supporting wider society’s transition to net zero, building climate resilience and achieving sustainable outcomes. Annex E addresses the area wide emissions that public bodies have a critical role in tackling as part of Scotland’s just transition net zero.

5.1.1 Direct and indirect emissions

Public bodies are responsible for generating GHGs through the operation of their built estate and other assets, and as they deliver services and perform their functions.

Emissions are defined as direct and indirect:

• direct emissions - primarily come from fossil fuels used in assets owned or controlled by the body, such as gas used to heat buildings, or petrol and diesel used in fleet vehicles. For carbon accounting and reporting purposes, direct emissions are classed as scope 1 emissions. The sources of scope 1 emissions are within the control of the body, e.g. the body could choose to replace a gas boiler with an air source heat pump, or a diesel fleet car with an electric car
• indirect emissions - come from the generation of acquired electricity, heat, steam or cooling (scope 2 emissions), or from the wider value chain (scope 3) – wider activities including business travel, staff commuting and the purchase of goods and services. Indirect emissions fall outside the direct control of a body, but within its influence, e.g. a body cannot directly control a supplier, but it can work with them through a contract to influence how a service is delivered. Further information on emission scopes and reporting is provided in Chapter 8.

For most public bodies the majority of direct scope 1 emissions are likely to come from heating buildings. For some, direct emissions from fleet, process emissions and fugitive emissions may be significant. Landholding bodies may have direct land-based emissions, for example from degraded peatland. Bodies are also likely to have substantial indirect scope 2 emissions associated with acquired electricity, and potentially heat, steam and cooling.

However, for many bodies, the majority of total emissions will likely be indirect scope 3 emissions from the wider value chain. Each body’s size, operations, budget and functions will determine the make-up and significance of its scope 3 emissions. For bodies with larger budgets, the emissions associated with purchasing - all of the things a public body buys in order to deliver its functions, from buildings to vehicles, furniture to IT equipment, cleaning services and external consultancy – are likely to make a significant contribution to its overall emissions.

Bodies may also influence emissions in a wider context, that sit outside of their value chain and are not easily quantifiable. For example, schools can include climate change and sustainability on their curriculum and reflect them in their values and priorities, influencing the knowledge and behaviour of their learners both at the time, and potentially for the rest of their lives. Bodies should consider this influence carefully, particular in relation to the exercise of their functions.

5.1.2 Key actions for public bodies

Key emissions reduction actions for most public bodies may include:

• The decarbonisation of heating systems and fleet e.g. replacing gas boilers or combined heat and power plants with air, water or ground source heat pumps, or connecting to a district heating network powered by the same.

Public bodies should focus investment in reducing emissions in those buildings that are planned to remain part of the estate in the longer term. Investment in energy efficiency and clean heat should be focused on those buildings for which there is confidence on future need. Where a public body expects to vacate a building, improvements should be limited to those required as part of planned maintenance requirements and to meet other statutory obligations.

• Public bodies having clear long-term strategies for their assets and the sustainable management of those assets. Public bodies should consider the size and location of their estate, whether it matches service requirements and future needs and opportunities for co-location of services – to maximise use and minimise waste (including emissions). This includes modifying the assets to net zero standards and making assets resilient to a changing climate.
• It is essential that public bodies decarbonise their vehicle fleets. Public bodies should work to reduce their fleet emissions by maximising the utilisation of existing zero emissions vehicles, and by replacing existing petrol and diesel vehicles with new zero emission vehicles, prioritising high mileage vehicles for replacement soonest. Further advice will be provided through a public sector fleet decarbonisation action plan being developed by Transport Scotland, due to be published early in 2026.
• The reduction of electricity use wherever possible via, for example, improved building fabric to reduce heating demand, installation of renewables, LED lighting, and replacement of inefficient equipment with energy efficient alternatives.
• Achieving net zero will, generally, see public bodies using more electricity for heat in their buildings – particularly if they are moving to electrical heating. At the time of writing, electricity costs more than other heating fuels, notwithstanding the efficiencies of electrically-powered heating systems like heat pumps. Public sector organisations may therefore consider on-site electricity generation technologies. This should always be supported by an investable business case that does not expose the body to excessive risk. Public bodies could consider investing any savings made in energy costs into improvements to the fabric of their buildings and or the additional costs of clean heating systems.
• The move to a circular economy approach to procurement and resource management by:
  • thinking early about whether, what, how much and how to buy
  • extending the life of equipment and other assets wherever possible (including by enhancing their resilience to climate impacts such as flooding)
  • considering leasing and shared ownership models where practical and economical
  • reusing and repurposing equipment wherever possible; including the approach taken to buildings, e.g. considering deep retrofit options rather than demolition and rebuild
  • where a purchase is required, procuring products that have been used (including refurbished products) or remanufactured, or are designed to be repaired, reused, refurbished, remanufactured or recycled.
• Where bodies own or manage landholdings, actions should include reducing direct emissions, such as those from degraded peatland, and enhancing and increasing nature-based carbon sinks. These actions can also contribute to a body’s adaptation planning by increasing flood resilience, improving biodiversity and contributing to nature networks.

Sector-wide approaches to climate change are being taken by key parts of the public sector. Bodies should refer to the annexes below for sector-specific guidance and information:

• local authorities – Annex I
• Planning authorities and place makers – Annex J
• health and social care bodies (NHS Boards and IJBs) – Annex K
• higher and further education bodies – Annex L.

5.2 Reducing emissions in practice: key principles

To achieve the national net zero target of 2045, a step change in ambition and action is required.

Before outlining some principles that will help guide this step change in ambition, it is important to recognise that the approach bodies will take to developing their plans will differ due to their size, nature and purpose. This guidance is organised by the three duties (mitigation, adaptation and acting in the most sustainable way) for clarity. However, bodies should consider the duties together in an integrated way and may choose to develop plans or strategies that include all aspects.

To help focus action in those areas likely to have the greatest emission reduction impact, following a number of broad principles will be helpful.

Materiality

It will be necessary to focus efforts on those actions which achieve the most material impacts first.

Typically, actions such as recycling, moving to electric vehicles or installing on-roof solar PV may have been the focus of mitigation action, as they likely to be more easily achieved and require lower levels of investment. While they bring benefit these are often not the most impactful actions.

In the future, there may be a greater focus on procurement policy and purchasing behaviour across the organisation’s buying community. In relation to scope 2, exploring major renewables installations with direct wire connections or sleeved power purchase agreements with explicit additionality in the contract may be of most impact. Where bodies are responsible for commissioning construction and infrastructure projects, this is highly likely to be an area of material impact and also one where significant carbon reductions can be achieved through intervention early in the design and specification process.

It is worth noting that a significant proportion of Scotland’s GHG emissions come from the land and land management activities. It is important that landholding bodies work to understand and address GHG emissions from their land, such as from degraded peatland, to maximise nature-based opportunities to reduce emissions and to capture and store carbon, and to ensure that their lands are resilient in the face of the changing climate.

Wider influence

Closely related to materiality, is ensuring consideration of an organisation’s wider impacts. For example, a local authority may achieve greater emission reductions by introducing a Workplace Parking Levy than by installing PV on the roofs of its own buildings (noting that the former will contribute to area wide targets that may be in place, and the latter primarily to corporate targets). Ultimately both direct and indirect area wide emissions will need tackled, but prioritising those areas of influence with the largest impact will be critical to achieving a science aligned pathway.

Below are some prompts to help public bodies consider where their own potential wider impacts and influences on climate change might be. These 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 and materiality of the impact and the means by which this is best understood and managed.

Does your public body influence:

• the construction or reconstruction of any infrastructure?
• the construction methods and energy standards of homes, offices or other developments?
• existing buildings, either in terms of ongoing performance and maintenance, or re-use?
• energy generation, energy efficiency or energy consumption?
• planning and or land use strategies including development, farming, forest planting, forest management, nature-based solutions or soil management?
• agricultural practices and production?
• travel patterns including number and length of journeys and the mode of travel?
• individual behaviour such as dietary choice, physical activity levels, or time in nature?
• knowledge and behaviour through education and training?
• waste arising or the amount of biodegradable waste going to landfill?
• pension schemes or other significant investments?

Urgency

Due to the risk of triggering climate tipping points, and the fact climate change is driven by absolute and cumulative carbon emissions, the importance of the pathway to the net zero carbon target is equally important to arriving at net zero on the target date.

Spending effort on actions that result in immediate reductions is important, whilst working on actions for the largest carbon reductions that might take longer to put in place. For example, replacing a large combined heat and power (CHP) plant with an air source heat pump might take over four years from concept to finish. Switching off that CHP (assuming there are back-up gas boilers) now would immediately offer significant carbon savings based on the difference between the emissions from the CHP and grid electricity emissions. This may result in increased revenue spend as electricity is more expensive than gas, but may be a rapid way to make significant carbon reductions whilst larger changes are worked on.

Public bodies should focus on urgent action to reduce emissions as far as possible as fast as possible over the next decade to minimise cumulative emissions, whilst still ensuring the goal of achieving net zero by 2045.

Supply chain

Most effort has, historically, gone into addressing scope 1 and 2 emissions, primarily generated by heating and powering buildings and fleet. For most public bodies indirect scope 3 emissions from the wider supply chain will make up the majority of emissions, and can be influenced or controlled by the public body to some degree. Categories of scope 3 emissions likely to be significant hotspots for public bodies include the emissions associated with purchased goods, works and services, business travel, capital assets and investments.

For example, whilst the scope 3 emissions from the construction of a new building are the scope 1 and 2 emissions of the construction company procured to undertake the project, ultimately the public body’s decision to commission that building creates those emissions. An alternative, particularly in a hybrid working environment, of better utilising existing space via hot desk policies, refurbishment, repurposing buildings, or purchasing and refurbishing existing buildings rather than building new, would significantly reduce scope 3 emissions in this example.

Bodies wield considerable influence over their supply chain through their procurement practices and activities; influence that can cascade down through the tiers of a contract or supply chain. Climate and sustainability action can be built into the procurement process, from the initial identification of need and specification, through to the end of contact or the useful life of the asset.

Mainstreaming

Ultimately, in regards to each of the principles above, it is crucial that climate change action is mainstreamed in all public bodies’ business processes and functions, as laid out in Chapter 4 above. 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. Embedding decarbonisation into core day-to-day business will be essential to achieve corporate and national net zero and other targets.

Demand management

When considering any source of emissions, whether energy or purchased goods or services, demand management is key – the lowest carbon option is always not to buy or consume at all. It is therefore important that approaches begin from a demand reduction perspective.

This will be of particular importance as buildings and fleet are electrified, placing higher demands on grid infrastructure. Bodies should work to ensure that such demands are minimised, for example by reducing heat demand by insulating buildings and by undertaking behaviour change programmes with staff and building users.

Demand management in the wider community can also be influenced by public bodies. For example, local authorities can support car clubs, bike hire schemes and community transport providers, improve walking and cycling infrastructure, and can set parking charges and implement local road user charging schemes to help reduce the demand for personal car use and ownership. Such initiatives can also contribute to wider outcomes such as reduced transport poverty, enhanced connectivity and improved air quality and public health.

Worked example: materiality.

Taking a large higher education institution as an example, there are several areas of materiality in each of the main themes below.

Direct and indirect emissions

Indirect scope 3 emissions will make up a significant proportion of emissions, with most institutions having between 65% and 85% of their emissions within scope 3. Within scope 3, the material sources of emissions are typically, in order of size: the things the organisation buys including, in this example, laboratory equipment, IT equipment, vehicles and furniture; then international student flights; followed by the construction of new buildings, as illustrated in figure 3.

Within scopes 1 and 2, building heating will be the largest source of emissions, with electricity usage typically the next material source of emissions. Fleet emissions will usually be relatively small.

In this example the priority actions would be in engaging with procurement and the procurement community to reduce purchasing wherever possible.

Wider influence

The key purpose of the institution in this example is to provide undergraduate and post-graduate level education and to carry out research, and its functions reflect this. Arguably, its largest impact is through the education of its students, and through research into sustainable solutions such as renewable technology and energy storage. Whilst this does not directly impact on the higher education institution’s corporate emissions, embedding climate change meaningfully across degree programmes, and incentivising and supporting research into climate solutions, is arguably the largest impact that the institution can have, whilst working to reduce its own direct and indirect measurable emissions.

5.2.1 Maximising co-benefits and minimising unintended consequences

Co-benefits

Many of the actions to reduce emissions can deliver benefits for other policy areas such as health and wellbeing, equity, economic development, and nature and biodiversity. Bringing these benefits to the fore can help drive more ambitious climate action and provide an additional narrative across stakeholders. Research has indicated that every £1 spent in the UK on climate change mitigation can provide social benefits including increased productivity, and improvements to public health and urban connectivity valued at £14.^[6]

The Lancet Pathways to a healthy net-zero future noted:

“a focus on the opportunities for transformative change to an economy that supports health and equity within planetary boundaries can provide hope and a compelling vision of an inclusive and sustainable future, engage more diverse audiences and build support for change” ^[7]

There is increasing evidence that many actions to reduce emissions can deliver near-term health co-benefits.^[8] Several programmes of work are underway in the UK and internationally to understand the scale of these benefits and how we can maximise them. Health co-benefits can be achieved when climate action addresses the building blocks of good health, for example through:

• promotion of active and sustainable transport which can increase physical activity, reduce air and noise pollution, and increase footfall in local areas with positive impacts on the local economy
• replacing fossil fuels with clean renewable energy which reduces air pollution
• consumption of sustainable and healthy diets
• warmer, better insulated, healthier homes improving the health and wellbeing of residents and helping to tackle fuel poverty
• creating local economic opportunities that support community wealth building
• inclusive participatory place based approaches to designing, delivering, evaluating and monitoring climate actions which can empower people and communities and build social capital
• promotion of accessible, high quality open, blue and greenspace with benefits for mental and physical health; and other co-benefits such as enhanced biodiversity, and improved flood resilience and nature connectivity.

Key to a just and equitable transition will be to ensure that benefits delivered by climate mitigation in relation to emissions, health, equity, social and environmental outcomes are fully accessible to all.

Resources:

• UK Co-benefits Atlas can be used to illustrate and quantify the estimated value of 11 co-benefits, by region and per capita
• NatureScot’s Natural Capital Tool can support decision making in land management, ensuring that benefits and services provided by nature are taken into account
• Climate Just information tool, designed to help with the delivery of equitable responses to climate change at the local level.

Unintended consequences

Implementation of mitigation actions can have both positive and negative, planned and unintended impacts on other policy areas and inequalities. For example, urban planting, both a mitigation and adaptation measure, can have benefits for health and wellbeing thereby supporting just transition outcomes, as well as supporting biodiversity and helping create nature corridors. However, there is some evidence urban trees can increase property values and if unevenly distributed to lead to gentrification, making land inaccessible to low income residents.^[9],^[10] Similarly, retrofit housing schemes to increase energy efficiency are associated with improved health and social outcomes. However, increasing the airtightness of buildings without sufficient ventilation can contribute to poor indoor air quality or health risks during hot weather. For some residents the cost of housing retrofit can be passed on in increased rental values, particularly for low income residents in the private rental sector. Where mitigation actions are not considered in relation to adaptation this can contribute to policy fragmentation and increase the risk of unintended consequences, such as properties overheating in a warming climate.

Whilst trade-offs across policy areas may be necessary, if the unintended impact on different population groups and different policy areas are not explicitly considered, these trade-offs can be unacceptable.

Working with stakeholders across policy areas, staff and the wider community, in particular the most affected population, using systems approaches to co-design and implement mitigation actions, and integrating mitigation and adaptation, can help support the delivery of multiple policy objectives, avoid maladaptation, reduce the risk of unintended consequences and prevent increased inequalities.

5.3 Taking corporate mitigation action

This section outlines the key actions that all public bodies are expected to take, in a proportionate manner, to reduce their corporate (organisational) emissions. Many public bodies will already be at a more mature stage, and have some or all of these elements already in place. These may be stand-alone elements as outlined below, or integrated into wider strategies and plans.

• Climate change statement or policy – a clear statement or policy that outlines the body’s approach to climate change and sustainability. For example, many local authorities will have a high-level statement that recognises the climate and nature emergencies, and makes a commitment to reach net zero.
• Climate change strategy – a strategy that outlines the body’s headline mitigation targets, key milestones and actions. Bodies may choose to integrate climate change into their strategic plan to aid with mainstreaming.
• Route maps – alongside the strategy, the body should develop route maps laying out, at a high level, steps illustrating how targets and milestones will be achieved. It may be appropriate for larger or more complex bodies to develop separate route maps for different areas of activity, e.g. for building and fleet decarbonisation.
• Targets – alongside an overarching net zero target, public bodies should set individual targets, such as a date for achieving clean heating in all of their buildings, and a date for electrifying their fleet. Targets should be ambitious but achievable, evidence-based, and appropriate to the body.
• Carbon management plans – carbon management plans (CMPs) are more detailed than the strategy, and lay out how the strategy will be implemented over a given time period. Smaller bodies may find, taking a proportionate approach, that a separate strategy is not required, and developing a CMP is adequate. The term ‘carbon management plan’ is used in this guidance as it is well known. However, bodies may choose to use a broader term such as ‘emissions reduction plan’ to better reflect their actions to reduce all relevant GHGs. They may also choose to integrate this work into existing delivery plans.
• Action plans – action plans sit below the carbon management plan and lay out in detail interim steps that need to be taken. They should include critical milestones, decisions, dependencies, costs, key people and lead times.
• Monitoring and reporting – bodies should monitor progress and report on this through their corporate reporting processes.

5.3.1 Climate change statement or policy

It is essential that public bodies have a statement or policy in place that clearly states their approach to climate change and sustainability. For example, many local authorities have a climate statement which recognises the interlinked climate and nature emergencies and makes a commitment to reaching net zero and building climate resilience. Bodies should ensure that their statement and or policies cover all three climate change duties and are signed off at senior level.

Bodies should ensure that other pertinent policies, for example those relating to procurement and business travel, properly reflect the climate change duties. In particular the third duty, to act in the most sustainable way, is highly likely to be relevant to most other corporate policies.

All policies should be easily available to staff and stakeholders. As best practice bodies should make them publicly available, for example through their website.

5.3.2 Climate change strategy

Climate change statements can be a useful starting point when it comes to developing a climate change strategy. While actions on mitigation, adaption and acting sustainably have, for clarity, been laid out in separate chapters in this guidance, bodies may find that developing a strategy which encompasses all three areas is the most effective approach.

A climate change mitigation strategy should include, where relevant:

• scopes 1 and 2, and detail the elements of scope 3 included
• land-based emission sources and natural carbon sinks, opportunities to increase these, and a narrative of how landholdings can support wider outcomes and co-benefits
• a description of the wider material influences the organisation has on carbon emissions
• what the final decarbonisation targets are for the organisation, including any targets or action regarding its wider influence
• a visual breakdown of the organisation’s carbon footprint
• a high level timeline of key actions that will achieve the targets (i.e. a route map)
• a narrative of where the material impacts are, including an explanation of why certain actions are being prioritised over others chronologically or by effort
• a narrative summarising the key potential risks and wider benefits associated with the actions, and how these are being mitigated and delivered fairly, taking into account just transition principles, as defined in the 2009 Act and the upcoming refresh of the Just Transition Planning Framework, which will include a monitoring and evaluation framework for the first time
• a narrative of where and how the body can best use its influence to contribute to wider emission reductions in the community, region and or sector
• where applicable, the approach that will be taken to insetting and offsetting, which residual emissions these will cover, and what proportion the residual emissions represent of the baseline carbon footprint
• a high level overview of risks.

As a minimum, and as detailed in Chapter 8 (Reporting), bodies are recommended to include within their boundary scope 3 emissions from water, waste and waste water, business travel, student travel where relevant, staff commuting and homeworking, and indirect fuel and energy related emissions.

When developing or updating their climate strategy, public bodies should be aware of the wider policy context.

Scottish Government is committed to decarbonising heat in buildings by 2045. On 18 November 2025, Scottish Government published a Draft Buildings (Heating and Energy Performance) and Heat Networks (Scotland) Bill to provide clarity to industry and stakeholders. Draft explanatory notes were published alongside. The intention is to introduce the Bill early in the next Parliamentary session, subject to the outcome of the 2026 Scottish Parliament election.

Local authorities will have developed Local Heat and Energy Efficiency Strategies (LHEES) which includes the development of Heat Network Zones (HNZs) which should influence their corporate climate strategy and related plans, and certainly their area wide planning. Publicly owned buildings should be an early focus to allow exploration of opportunities for coordinated area-based action to decarbonise heat, including the identification of public buildings that could act as anchor loads in any future heat network.

The strategy should include how the body can use its influence – with customers, service users, stakeholders, suppliers and the sector – to contribute to wider emission reductions, for example as a regulator, a buyer, a planning authority, as a trusted messenger or as an anchor organisation.

The strategy should also consider the contribution the body can make to wider net zero, just transition and wellbeing economy aims, for example:

• a body may generate significant waste heat which could be made available to other bodies or to a local district heating network
• using locally sourced materials and consumables will contribute to the local or regional economy and wider sustainability outcomes
• choosing recycled or reused materials will contribute to the circular economy
• purchasing energy from a community energy group, for example via a power purchase agreement, could secure the group a long-term income source that will benefit the local community
• landholding bodies could consider wider opportunities for public land to contribute to climate action and sustainable development. For example, land could be made available to community groups who may wish to develop and operate sources of renewable energy.

Considering these wider outcomes as the strategy is developed and at reviews will help ensure that these strategic opportunities to assist the wider public sector or community are maximised.

5.3.3 Route maps

Net zero carbon targets are typically longer-term targets ranging from 5 to 25 years into the future. Science aligned decarbonisation pathways require significant carbon emission reductions well before typical net zero target dates such as 2040 or 2045.

Each public body will work within a specific context and many will face challenges to decarbonisation including electricity grid limitations, geographically dispersed assets, and remote rural and island locations. It is also likely that sequencing of particular actions will be important, for example insulating buildings to reduce heat demand before moving to clean heating systems.

Land and nature-based projects typically have a long time lag between initial implementation and active sequestration or emission reductions. For example, where woodland creation is a key part of achieving a net zero target, the time lag between planting and active sequestration (typically 15 to 25 years) means that such activities require urgent action if aligning to 2045 net zero targets.

The route map should recognise such challenges and constraints, and can aid in breaking down the journey to net zero, helping to ensure that the pathway is context-appropriate and that sufficient action is planned for delivery.

Route maps should also, where known, include future activities such as major retrofit or construction projects that are likely to cause a short term but significant upturn in emissions. Work to ensure that impact is minimised can then be planned in.

Route maps can take a variety of visual forms. A high level visual giving key dates and top line actions can be useful for overview presentations.

A more detailed quantification of emissions reductions delivered by each intervention can be useful in delivering a granular analysis of how the decarbonisation pathway is going to be achieved, and to clearly identify any gaps between planned action and the pathway.

High level route maps can include actions on scopes 1, 2 and 3, as well as insetting and, where relevant, offsetting, as a helpful overview of the full mitigation programme, and could also include adaptation.

A public body route map will typically include the following specific mitigation actions as a minimum, where relevant:

• heat in buildings
• fleet
• business travel
• staff commuting
• waste
• reduction in electricity consumption (excluding increases caused by the electrification of heating and the transition to electric vehicles).

As best practice bodies should also include, where relevant:

• supply chain action
• construction and major retrofit projects
• insetting and offsetting action
• land and land use
• investments.

Table 1 below is an example of the kind of high level actions that might be used to populate a decarbonisation route map for a public body.

Table 1: Example timeline of actions that might be placed along a route map for a public body*

2025:

Decarbonising heat: -

Decarbonising fleet: All new (purchased or leased) cars and vans to be EVs from this date

Electricity: Achieve 50% LED lighting across the estate

Supply chain: Develop circular economy policy. Publish supply chain route map

2026:

Decarbonising heat: Deep retrofit of most carbon intensive buildings

Decarbonising fleet: Introduce cargo bikes for appropriate journeys

Electricity: Upgrade most carbon intensive equipment

Supply chain: Analyse supply chain impacts

2027:

Decarbonising heat: Deep retrofit of less carbon intensive buildings

Decarbonising fleet: 50% of planned onsite EV charging infrastructure to be complete

Electricity: Achieve 75% LED lighting across the estate

Supply chain: Begin supplier engagement to reduce largest emissions

2028:

Decarbonising heat: First major CHP replaced

Decarbonising fleet: 85% of cars to be EV, 70% of LCV (vans) EV, 7% of HGV fleet to be low emission vehicles

Electricity: -

Supply chain: 33% supply chain emissions 1.5°C aligned

2029:

Decarbonising heat: Retrofit of least carbon intensive buildings

Decarbonising fleet: 100% of planned onsite EV charging infrastructure to be complete

Electricity: Achieve 100% LED lighting across the estate

Supply chain: -

2030:

Decarbonising heat: Second major CHP replaced

Decarbonising fleet: 20% of HGV fleet to be low emissions vehicles

Electricity: 25% of electricity consumed to be self-generated using renewable technologies

Supply chain: 66% supply chain emissions 1.5°C aligned

2031:

Decarbonising heat: District Heating Network for social housing commenced

Decarbonising fleet: 35% of HGV fleet to be low emissions vehicles

Electricity: -

Supply chain: -

2032:

Decarbonising heat: District Heating Network for social housing completed

Decarbonising fleet: 45% of HGV fleet to be low emissions vehicles

Electricity: 33% of electricity consumed to be self-generated using renewable technologies

Supply chain: 80% supply chain emissions 1.5°C aligned

*Note: the examples provided in the table above are illustrative only. It is for each public body themselves to determine the most appropriate range of actions and measures in their journey to net zero.

Route maps should typically cover at least a five-year period (e.g. to align with the body’s carbon management plan), and could cover the full journey to net zero carbon if appropriate, and where actions and timelines are understood (i.e. to illustrate the full strategy). It is likely that most public bodies will have a clearer picture of the next five years, with decreasing certainty with time. For that reason public bodies in most cases should develop route maps five to ten years in duration, noting any material action that will be required beyond the end of the route map horizon, and noting that this will be updated at least one year in advance of the end of the current route map timeline.

It is likely, especially for larger public bodies, that achieving net zero will be reliant to some extent on the activities of others, such as for the development of heat networks. Bodies intending to electrify the heat in their buildings and fleet may be dependent on upgrades to grid infrastructure taking place in advance of work commencing on their sites. A vital part of developing the route map will be identifying the key partners and stakeholders associated with each element or project, establishing contact and building relationships. This process can be lengthy, and bodies are encouraged to establish these relationships early, especially with their Distribution Network Operator (DNO) in relation to grid upgrades, as these can take many months or even years to come to fruition.

5.3.4 Emissions reduction targets

The approach to setting targets

Targets often form the most visible and public part of an organisation’s strategy for taking climate action. It is important that these are well considered, evidence-based and appropriate to the body. When setting targets, bodies should consider the nature and functions of their organisation, their resources and the actions that will be needed to deliver on the targets.

It can be helpful to approach target setting using the SMART criteria.

• Specific – be clear on what is included and excluded in your target or targets, and avoid general ‘catch-all’ targets. For example, if setting a target related to car kilometres travelled per year, be clear as to whether that applies to pool cars, hire cars, grey fleet, etc. Aim to develop specific targets relating to the body’s significant sources of emissions, such as heat in buildings or road fleet.
• Measurable – to enable realistic targets to be set, and for performance to be monitored and reported on, the target must be measurable. Consider the data sources available, data quality, where improvements can be made to enhance accuracy and reliability of data, and to streamline or automate data collection and verification processes.
• Ambitious (but achievable) – it is important that targets are stretching and drive action, but it is also important that they are evidence-based and are felt, with due effort, to be achievable. Unachievable targets may, in effect, set a body up to fail and may work against delivery by facilitating delays and the prioritisation of other work or spend, and by demotivating staff. There are also significant reputational risks associated with missing targets, or with having to alter them in the future.
• Relevant – targets should be relevant to the organisation and to the body’s overall footprint. Efforts should be focused where they will have the most impact, or where targets support other priority outcomes or policies.
• Timebound – effective targets should be timebound. They should include a target date plus, where relevant, a baseline year which progress is measured against. Where a target lies in the more distant future, such as 2045, consider milestones and how to maintain focus and help ensure that progress stays on track.

Corporate emission reduction targets

Corporate emission reduction targets should include, as best practice and where relevant:

• an overall net zero target for scopes 1 and 2 of no later than 2045, earlier where possible
• individual targets for zero direct emissions from heating of buildings, zero direct emissions from road fleet vehicles (some public bodies may find it appropriate to have separate targets for cars, LCVs and HGVs) and zero direct emissions from any ferry fleet being operated
• targets related to land use and land use change, in particular where land-based emissions, such as those from degraded peatland, are a source of direct emissions
• targets covering other direct emissions, e.g. from use of machinery, fugitive gases or process emissions
• targets covering waste, e.g. waste to landfill, recycling rates, circular economy
• targets related to procurement
• targets related to other sources of indirect emissions, such as business travel, car kilometres travelled, etc.

The organisational net zero strategy should map out any intended use of nature-based carbon removals on the body’s landholdings (insetting) or carbon offsetting required to achieve net zero targets. The residual unavoidable emissions that will be sequestered should be estimated as part of net zero planning. Residual emissions should be as small as possible, and any assumptions and uncertainties clearly explained. Further information is provided in Annex F.

In addition to net zero targets and those related to decarbonisation of buildings and fleet, bodies are strongly encouraged to set wider additional targets that reflect or go further than national policy.

In all cases, targets should include:

• specific information around what is, or is not, covered by the target
• a target date
• where relevant, baseline information.

It is important that the way targets are framed avoids unintended consequences. For example, if a reduction in car use target included only travel in vehicles owned by the body, this could encourage a shift to using grey fleet vehicles for business travel instead.

Targets may relate to carbon (e.g. absolute or relative reductions in emissions) or may take alternative forms, such as demand reduction. For example, a body may decide that the most effective way for them to tackle the emissions associated with procurement would be to carry out an emissions reduction programme based on prioritisation of procurement of goods, works and services with a high climate impact. Public bodies may use early market engagement and the contract management process to identify key performance indicators (KPIs) that can be used to seek and measure improvements against a baseline during the lifetime of the contract. KPIs should be relevant and proportionate to the contract in question. This may start with qualitative data, moving to quantitative date over time as data available improves.

Other measures of progress on procurement and climate maturity may include, for example, indicators from the Procurement and Commercial Improvement Programme (PCIP) such as numbers of staff having completed climate literacy training or evidence that climate has been consistently addressed in relevant procurements.

5.3.5 Carbon management plan

A carbon management plan (CMP) is a more detailed document than a climate change strategy, and lays out how the strategy will be implemented over a given time period, typically three to five years.

The CMP should include the boundary and governance arrangements, the baseline and targets set by the organisation and a visualisation of the decarbonisation pathway. It should reflect the principles outlined at the beginning of this section, i.e. an approach created through the lens of materiality, wider influence, supply chains, urgency and demand reduction, and which embeds approaches reflecting all of the above in the core business governance systems and processes.

An important element of developing the CMP will be the identification of key stakeholders and partner organisations, who will be critical to successful implementation of the plan. Such stakeholders may be internal or external and are likely to include the Distribution Network Operator (DNO), other public bodies, local Planners and district heat network developers or providers. Internal stakeholders are likely to include Finance, Estates, Fleet, Facilities Management and Procurement colleagues.

It is important that an organisation’s CMP and other key strategies and plans are aligned with, where relevant, the estate strategy, planned maintenance and plant replacement schedules, fleet strategies and fleet replacement plans, and the procurement and investment strategies. There are likely to be many dependencies between these strategies and plans, particularly in relation to budgets and implementation.

Public bodies should make decisions about the heating systems in their buildings in line with the Local Heat and Energy Efficiency Strategy (LHEES) for their area. When installing or replacing heating systems, due consideration should be given to individual clean heating systems and the future potential for heat networks, as suggested by their LHEES. These set out zones where different heat decarbonisation technologies may be appropriate including heat networks.

Taking an estates strategy-led approach to building decarbonisation

Public bodies are most likely to achieve best value for money by installing clean heating systems when existing plant has reached (or is nearing) the end of its useful or economic life, and in addition where works can be combined with wider building improvements and refurbishment projects. Aligning works across buildings and estates as part of strategic planned maintenance has the potential to deliver further cost benefits as well as wider economic and environmental outcomes.

An estates strategy-led approach to building decarbonisation should also take into account an organisation’s wider estates strategy, including which buildings will be retained, how these will be used to meet future operational needs and the location of assets. Consideration should be given to how remote or geographically dispersed buildings of mixed or similar types might be grouped in terms of planned lifecycle and maintenance, to offer the most cost-effective solutions.

The Net Zero Public Sector Buildings Standard (the Standard) encourages public bodies to take an estates strategy-led approach to decarbonisation and thereby transition their existing buildings to net zero. A key principle of the Standard is to set out all the business drivers for buildings improvement works along with lifecycle requirements over the years to 2045, and beyond. The Standard also provides guidance to determine the most pragmatic, opportunistic and cost-effective targets and milestones to implement decarbonisation measures as part of a ‘Construction Intervention Strategy’ that sets out a credible path to net zero operational energy, as well as enabling wider outcomes around objectives of place, carbon and the environment.

When bodies are investing in replacement heating systems and other plant and assets, they should ensure that they consider future climate scenarios, and whether the asset will be fit for purpose in the future. For example, whether a cooling system with an expected life span of 25 years is sized correctly for warmer average temperatures and increased frequency of heatwaves that may be predicted.

Alongside the climate change duties, there is a policy commitment for publicly-owned buildings to replace polluting heating systems with clean heating systems by 2045. To support this transition, and the work required of the CMP, the Scottish Government is, at time of writing, preparing non-statutory guidance that will clarify expectations around decarbonisation and clean heating, and signpost public bodies to the most relevant tools and resources.

Interim solutions

Expensive or technically complex interventions can take longer to develop or gain approval for, so that emissions reductions are not realised in the short or medium term. In such cases, public bodies could explore interim solutions that can mitigate emissions in the meantime whilst long term interventions are developed. It may be possible to utilise hybrid technology that helps reduce emissions until a full transition to a zero emissions system can be realised.

Leasing assets whilst awaiting capital budget, maturation of technology or approval for long term purchases is another bridging mechanism that allows for short term emissions reductions whilst working on long term solutions. For example, a body may have an asset, such as specialised machinery or plant equipment, at end of useful life. While a zero emissions alternative may not currently be available, the body may be confident that an option will be brought to the market within a few years. In this case, leasing a replacement asset as an interim stage could be an appropriate approach and avoid the lock-in that a purchase now would result in.

Flexible approaches

Approaching budgets flexibly may be necessary in reflecting short, medium and long term decarbonisation opportunities, and bodies are encouraged to consider their investment budgets holistically. It may be helpful to temporarily move budget from, for example, estates to fleet whilst estates plans are further developed but immediate spend is not required; and then move fleet budget to estates later when major capital works are required. Similar policy-related budget flexibility may be wise in maximising area wide impacts.

5.3.5.1 Template plans

Annex C contains a carbon management plan template and associated guidance. It is intended to assist smaller public bodies that may have limited capacity and has been designed to align with the mandatory public bodies’ climate change reporting duties. Public bodies should use the template as a starting point and develop it to reflect their own needs and circumstances.

It may be appropriate for small bodies that are not classed as ‘major players’ to condense the template to reflect their more limited emissions and influence. For example, such bodies could focus on scope 1 and 2 emissions initially.

Annex D contains a template climate change plan for local authorities. This is a more extensive document and covers mitigation, adaptation and acting sustainably from both an organisational and an area-based perspective. It is intended to act as a guide to what local authorities’ plans are expected to include.

5.3.6 Land and nature-based projects: carbon insetting and offsetting

Definitions of carbon insetting, offsetting and carbon credits, including types of credits (emission reductions, removals and avoidance), as used in this guidance, are provided in the glossary.

The main focus of climate change mitigation action for Scottish public bodies should be action within Scotland to reduce GHG emissions and increase nature-based carbon sinks. Public bodies should maximise opportunities to restore, enhance and increase nature-based carbon sinks on their landholdings. As well as contributing to emissions reduction targets, such actions are likely to have many wider benefits including increased flood and wildfire resilience, enhanced biodiversity and improved nature networks – helping bodies to meet the second climate change duty and, where applicable, the biodiversity duty.

Quantifying the emission reductions or carbon sequestered by nature-based projects is complex. Bodies should be aware of this and cautious with how such claims are communicated, particularly for insetting projects which are not externally verified.

Refer to Annex F for further details.

5.3.7 Action plans

Below the CMP will sit an action plan, or series of action plans. These will take the headline actions outlined in the CMP, and clearly lay out the interim steps that need to be taken in order to achieve the end results. The action plans should include critical milestones, decisions, dependencies, costs, key people and lead times. They can form the basis of a project plan to deliver that element of the work.

For example, the CMP may include a target to replace any remaining fossil fuelled fleet vehicles with electric vehicles by 2030. The action plan would break this down into a series of steps, likely arranged by financial year, required to meet this target. Typical steps might include: getting senior management sign off for the target; confirming vehicle costs and lead times with suppliers; developing a five-year budget; getting sign-off on the budget; updating the fleet replacement plan; and developing a plan to schedule in the placing of orders, delivery of new vehicles, disposal of old vehicles, etc.

Developing action plans will be vital to ensure the CMP is delivered. Many projects will have dependencies, for example gaining planning permission or being contingent upon electrical grid upgrades, and it is important that these are identified early and allowed for. They can assist in the identification and management of risks, and facilitate resource planning. Progress should be monitored and reported on through existing project management processes and KPIs.

5.3.8 Monitoring and reporting

Public bodies with statutory reporting duties under the Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended, must report all scope 1 and 2 emissions, along with relevant scope 3 emissions, as outlined in chapter 8 (Reporting). They are also encouraged to report on the progress of key land-based projects.

Bodies outwith the mandatory reporting duty are encouraged to follow the guidance provided in the Reporting chapter, as best practice, and to include the information within their annual corporate reports. Climate action and sustainability should be integrated into existing monitoring and reporting processes and documents, such as the annual corporate report and organisational KPIs.

Public bodies should monitor and report emissions annually, tracking progress against their decarbonisation pathways and or carbon budgets. Detailing any emissions over or under budget, and tracking a cumulative figure, is key to staying within the organisation’s carbon budget, where applicable.

As well as reporting on overall progress toward targets, bodies should ensure that progress on action plans is monitored and reported on, to ensure that barriers and potential delays to delivery are identified early, and solutions can be developed.