Scotland's Climate Change Plan: 2026–2040

Implementing Climate Action

The consultation on the draft plan highlighted the importance of setting out detail on how implementation of actions will be undertaken, and how delivery will be tracked. As a composite plan, consisting of bundles of policy action across different sectors, geographies and delivery bodies, delivery is complex, and we need to tailor oversight of implementation.

Delivery does not just lie with the Scottish Government or, indeed, the wider public sector alone. We have a critical role in making the transition envisaged here as seamless as possible and to make this transformation a reality and realise the benefits that come with it. All parts of Scottish society will have a role – from businesses in different sectors to communities and individual households.

Our role will be maintaining the pace of delivery. Implementation of sector-based actions will be through the delivery mechanisms already in place for those actions. Our oversight of progress will build on an existing foundation of strong delivery, including the Scottish Government’s overarching Global Climate Emergency Programme Board and supporting governance structure. This approach was considered in detail by Audit Scotland in its 2023 report, who outlined that organisation to support delivery of climate change goals had “improved” since the declaration of a climate emergency in 2019.^[31] Scottish Government action is across all portfolios. The approach has supported some significant achievements in climate action, not least the rollout of public electric vehicle (EV) chargers now totalling over 12,000, enabled by significant private sector investment.

That said, given the increasing pace and complexity of climate action set out in the plan, these arrangements will evolve over the 15-year lifetime of this document. This will ensure that delivery on climate mitigation complements and supports the delivery of Scotland’s just transition and adaptation ambitions, alongside action to support environmental and biodiversity priorities.

As part of reviewing the governance structure for climate delivery, we will ensure the approach supports the principles of place-based delivery, and that we respond to real-time evidence of progress. The aim of these changes is to ensure flexibility in the delivery of national outcomes, both locally and across the programme, should there be updated evidence.

Place-based Delivery

The success of this plan rests on working with individual communities and businesses – both in terms of demonstrating and realising the benefits of climate action as well as ensuring that local delivery is embedded in the plan’s implementation. We will do this by co-developing our delivery with key partners as appropriate, working with Local Authorities through the Climate Delivery Framework and with the support of the Scottish Climate Intelligence Service and the Sustainable Scotland Network, to better plan the respective and joint contributions of local government. We will continue to work through the network of Climate Action Hubs to better understand the challenges and opportunities of climate action for different local communities.

We will also continue to engage and work closely with businesses, particularly small business, to understand any potential impacts they may face in whilst implementing the actions set out in this plan and design workable approaches to meeting desired outcomes.

To drive accountability in delivering the actions set out in this plan, we have broadened the policy list in Annex 3 to outline when the policies and proposals are expected to be delivered, when they will begin contributing to emissions reduction and, crucially, who is responsible for delivery. These ‘accountability tables’ help clarify roles and responsibilities, while providing detail on implementation timing to deliver emissions reduction within this plan. Each sector chapter also contains a delivery routemap which outlines the key actions to be taken up until 2040 to implement the policy package. These graphics provide detail on the proposed timing of key interventions further to the policy detail provided elsewhere within the chapters. Taken together, sectoral detail in this plan provides greater information on how and when policies will be implemented.

We will supplement this approach through collaboration with partners on developing delivery planning across each sector. This will include working with partners on more detail on deliverables and milestones, benefits realisation, consideration of behaviour change required within society, plans for public engagement and awareness raising, delivery responsibilities, key risks and interdependencies, and more detail on monitoring and oversight arrangements. The exact form and pacing of the more detailed delivery plans will be tailored to the nature and needs of different sectors.

Sectoral delivery of the CCP will be underpinned by the principle of place-based delivery. This approach understands that implementation of national outcomes and goals in local areas should ensure that the plans work “with local communities, to improve the lives of people, support inclusive and sustainable economic growth and create more successful places”,^[32] and is in line with the principles set out in National Planning Framework 4 (NPF4).

For climate action this will mean reflecting a people-centred approach to policy and delivery, which considers the local impacts of the transition to net zero. In doing so, the policies will be supported by engagement, community action and behavioural insights delivered in alignment with the Climate Change Public Engagement Strategy (PES). Co-development of policy implementation will also be undertaken with key delivery partners wherever possible, with a view to have a stronger, place-based dimension to delivery.

Monitoring Delivery

The CCP is underpinned by 159 policies and proposals, within 7 sectors of the economy, and spans a 15-year timeframe. The Scottish Government recognises the complexity of the delivery challenge over this period, not least due to a number of unknowns – particularly those outwith our control such as technological advance and market development, private sector investment and wider uncertainties at all levels of government including, given the constraints of devolution and the amount of key levers that are reserved to the UK Government, future UK Government action. In order to provide a robust understanding of delivery progress, this plan sets out a new, bolstered, monitoring and evaluation section (Annex 3) with key indicators and monitoring of policy action across all sectors to track delivery. This will be added to and augmented as required over the lifetime of the plan.

To support this, we will also work with business to:

• promote sustainability to be embedded throughout supply chains,
• understand the climate-related impacts and potential costs they may face in the short-term,
• understand and navigate the risks and costs for business, including where those may impact consumer prices, business competitiveness or investment, and
• understand, support and promote the benefits for business innovation, business resilience, attractiveness to customers, and future investment opportunities.

We will maintain annual progress reporting, while the Climate Change Plan Advisory Group will continue to observe progress and provide critical advice on the plan’s actions. Annual progress reports from the CCC will continue to provide an assessment of whether Scotland remains on track to meet our carbon budgets and net zero target.

This augmented approach will provide early warning indications of progress across all key outputs, supporting contemporaneous evaluation of whether progress is on track compared to waiting for official statistics on Greenhouse Gas Emissions outturns, which are typically published 18 months after the end of the year they refer to. For example, the annual monitoring will provide progress on indicators such as the proportion of new car registrations which are EV, significantly in advance of the emissions impact being reported.

This will allow us to be agile by reacting more quickly to any potential delivery challenges, and to make assessments of where further action is needed to correct any shortfall (either within a sector, or across the whole CCP). Alongside this, we will consistently review UK Government action or inaction in reserved areas and wider market forces and assess whether action in the plan should be accelerated or reprioritised to ensure carbon budgets are met.

In this way, delivery of the plan will be more flexible and reactive to the pace and complexity of climate change action. These arrangements will evolve where necessary to ensure they remain appropriate for implementing the action set out in this document. Overall, the CCP will adapt to the changing environment and evolve iteratively to meet Scotland’s carbon budgets.

Delivering under Devolution

The Scottish and UK Governments’ ambitions to tackle climate change and biodiversity loss are highly interdependent: many of the critical levers required to deliver emissions reduction that will take us to net zero by 2045 in Scotland are held at the UK level. Meanwhile, delivering UK-wide climate targets by 2050 is also reliant on Scotland achieving our net zero aim five years earlier. Scotland’s vast natural resources, from our renewable energy potential to our extensive area of peatland and forestry, are critical to climate goals for the whole of the UK.

The CCC, in their advice to the UK Government on the level of the UK 7^th Carbon Budget (2038 to 2042), highlighted that over “10% of the UK-wide emissions reduction required to meet the recommended 7^th Carbon Budget will come in devolved or partially devolved policy areas within the devolved nations”.^[33]

Moreover, the CCC emphasises the necessity for shared delivery and collaboration between national governments as between 30-60% of the emissions reduction required in Scotland, Wales and Northern Ireland will be in areas of policy that are mostly reserved.

As such, action from the UK Government in key areas of reserved policy will be crucial to achieving Scotland’s climate ambitions, including (but not exclusively):

• the rebalancing of prices in the electricity market to make electricity prices more affordable,
• incentivisation for renewable electricity generators to provide private wire over constraining generation,
• partial decarbonisation of the gas grid,
• a comprehensive four nations approach to vehicle and road taxation,
• appropriate, long term, specific financial support for land-based measures including tree-planting and peatland restoration, reflecting the larger share of these resources in Scotland,
• fair funding distribution for agriculture, and
• further certainty on critical investment decisions, including a full funding package and timeline for the Acorn Transport and Storage Project.

However, this plan only assumes action from the UK Government where they have presented a clear policy to deliver this action. Where this is the case, the projected emissions reductions are included in the analytical baseline. However, in cases where there is no clear policy for UK Government delivery, this CCP cannot assume action as part of the baseline or delivery routemap. We continue to call on the UK Government to accelerate efforts on climate action, including in the areas outlined above, as this will create further options for climate delivery and, in the case of reduced electricity prices, lower costs for people and businesses.

Were the UK Government to take further action on this, or other areas of climate delivery over the lifetime of this plan, delivery of climate mitigation action could be amended or accelerated to account for the change in circumstances. To this end, this plan sets out our key requests of the UK Government in each sectoral annex, highlighting the need for further collaboration, action and ambition, in line with CCC recommendations.