Scotland's Climate Change Plan 2026-2040: strategic environmental assessment

5. How the Opinions Expressed Have Been Taken into Account

5.1.1 On 6 November 2025, the Scottish Government laid the draft CCP in Parliament, beginning 120 days of parliamentary scrutiny and a 12 week public consultation. The public consultation on the draft Plan from November 2025 to January 2026 to: (i) receive feedback on the policies and proposals set out in the draft Plan; (ii) gather insights across key policy areas, associated impact assessments, and just transition indicators; and (iii) ensure inclusive public participation. Throughout the scrutiny period the Scottish Government undertook a number of representative and public engagement events to seek views on the draft Plan. Alongside this, Parliamentary scrutiny sessions were held via the Net Zero Energy and Transport (NZET) Committee and relevant sectoral committees who produced reports^{[20], [21]} containing their feedback on the draft Plan. In addition, public engagement events across the country gave us a range of different viewpoints on the impact of climate damage, and the importance of a just transition.

5.1.2 A report analysing consultation responses on draft CCP was published on 27 February 2026.^[22] This set out the findings from responses submitted to the consultation. The consultation received a total of 489 responses from the Citizens Space platform and from direct emails. In addition, there were 112 consultation events organised by the Scottish Government and delivered in collaboration with ‘trusted messenger’ third-sector organisations. The events were both in-person and online, carried out across Scotland, and reached over 1,800 people.

5.1.3 Overall, respondents were supportive of the Plan and welcomed it as a step in the right direction. However, respondents highlighted room for improvement, particularly around clarity of actions, community ownership arrangements, and public transport infrastructure. The need for better-connected, affordable, and accessible public transport was particularly prominent, alongside the importance of a behavioural shift driven by government-provided incentives.

5.1.4 Section 4 of the public consultation focused on the Strategic Environmental Assessment. Five key themes identified in the responses are detailed below.

5.1.5 The published consultation responses can be found here: Published responses for Draft Climate Change Plan - Scottish Government consultations - Citizen Space. The consultation analysis report can be found here: Scotland's draft Climate Change Plan 2026-2040: consultation analysis - gov.scot.

5.2. Theme 1: Broad support with calls for greater specificity

5.2.1 Respondents were generally supportive of the draft Plan’s environmental intent and direction. However, this support was often qualified by concerns that proposals remain too high level. Many felt that aspirations were not consistently translated into clear, actionable measures, raising doubts about financial viability, practical delivery, and enforceability. This applied both to predicted effects and to mitigation, enhancement, and monitoring proposals.

5.2.2 The CCP includes an updated monitoring and evaluation framework to review of the progress against the Plan’s policies. The updated monitoring framework for the CCP is built around four complementary elements that, together, provide a comprehensive view of progress in delivering emissions reductions and supporting a just transition:

• Greenhouse gas inventory emissions statistics,
• Emissions-reduction indicators,
• Just transition indicators, and
• The policy tracker.

5.2.3 Further detail on the CCP monitoring and evaluation framework is set out in Section 7.

5.3. Theme 2: Level of detail in environmental evidence

5.3.1 Consultation respondents broadly agreed that the environmental baseline and predicted effects are comprehensive at a national level, but repeatedly highlighted gaps in detail. Particular weaknesses were identified in relation to agricultural soils, crofting and grazing systems, on‑farm biodiversity, and high nature value farmland. There was some consensus that finer spatial resolution and better use of regional and local data are essential, especially for sensitive environments such as peatlands, islands, coastal and marine areas.

5.3.2 NatureScot’s response to the Monitoring aspect of the SEA Environmental Report highlights a lack of detailed targets and timelines in the Agricultural Sectoral Annex, making it hard to assess environmental outcomes. Current indicators are seen as too narrow: most focus on emissions reduction, with only minimal attention to carbon storage and sequestration in agricultural habitats. NatureScot advise that while efficiency measures are important, they are insufficient alone, and that equal emphasis is needed on protecting nature, supporting nature-based solutions, safeguarding carbon stores, and increasing sequestration. The recommendation is to broaden the set of agricultural indicators to better capture both positive and negative environmental effects.

5.3.3 The Scottish Government has committed to designing and implementing a Monitoring and Evaluation plan for the Rural Support Plan and the ongoing monitoring of the impacts of future agricultural support. This is due to be published in the new parliamentary term once finalised with Ministers. This will include a sub-outcome to maintain or increase in carbon stores on agricultural land, including below and above ground stores and those on peaty soils, against which a series of monitoring indicators have been developed.

5.4. Theme 3: Place-based and context-sensitive approaches

5.4.1 Respondents warned against uniform, one-size-fits-all approaches and stressed that Scotland’s environmental diversity requires flexible, place-based mitigation, enhancement, monitoring, and assessment. This included calls for regionally specific baselines, local indicators for monitoring, and tailored implementation that accounts for cumulative impacts from renewable energy, grid infrastructure, land‑use change, and industrial activity, particularly in rural and island contexts.

5.4.2 The Scottish Government undertook a number of workshops in partnership with the Convention of Scottish Local Authorities (COSLA), Sustainable Scotland Network (SSN) and Solace to engage with Local Authorities across Scotland, focused on improving place-based delivery in the actions in the Plan.

5.4.3 Many of the recommendations and feedback that we received have called for delivery to be accelerated, or for already-committed action to be undertaken. We have accepted these recommendations, and reconsidered policy positions based on the importance stakeholders place upon them. For example, the Rural Affairs and Islands Committee called on the final Plan to more clearly specify how peatland restoration will be prioritised to maximise emissions reductions and deliver co-benefits. The Scottish Government understands the importance of working with communities and land managers to deliver the multiple benefits and ecosystem services that peatland restoration can provide for climate, nature and people, and how this can help deliver against other strategic frameworks including the Biodiversity Strategy, the National Planning Framework and the Land Use Strategy. We, therefore, adjusted text in the LULUCF chapter to clarify this, for example to refer to work we are progressing with our peatland delivery partners through our first Peatland ACTION Partnership Plan.

5.4.4 The Scottish Government undertook an Island Communities Impact Assessment which considered how CCP policies may impact upon Scotland’s Island communities.

5.4.5 It should be noted that individual policies or sectoral delivery plans may be subject to an Environmental Impact Assessment or SEA in which finer detail on the specific policy context may be provided.

5.5. Theme 4: Nature-based solutions with integrated design and co-benefits

5.5.1 Respondents widely welcomed the Plan’s emphasis on nature‑based approaches and saw significant potential for positive environmental outcomes if implemented well. However, many argued these measures must be better integrated and designed to deliver multiple co‑benefits. Examples included combining biodiversity enhancement with carbon reduction, flood management, climate resilience, healthier estates, and tenant wellbeing, while avoiding unintended harms such as displacement of productive grazing land or habitat fragmentation.

5.5.2 During the draft CCP consultation and scrutiny period the Scottish Government ran a Nature and Environmental Sustainability workshop to better understand how the CCP can interact and ensure a joined-up approach with other nature and environment plans such as the Environment Strategy for Scotland, the Scottish biodiversity strategy to 2045 and a Circular Economy Strategy for Scotland.

5.5.3 In the final Plan we have significantly increased the prominence of the benefits to our health and wellbeing that can result from action on climate change and nature loss within the Plan. This includes significant benefits from cleaner air, warmer homes, health promoting natural and built environments, high quality public services and fair work in a thriving economy. The final Plan makes stronger connections between delivery of our ambitions for climate and nature, and our priorities for health, wellbeing and social care in Scotland. We have also worked with the Edinburgh Climate Change Institute (ECCI) at the University of Edinburgh to quantify and describe the co-benefits of climate action, including for our health and wellbeing, with positive outputs for individuals and public finances from reduced strain on our public services.

5.6. Theme 5: Risk, Uncertainty, and Climate Acceleration

5.6.1 A notable group of responses highlighted concerns included reliance on historical or incremental indicators, underplaying non‑linear climate impacts, and insufficient attention to biodiversity thresholds, carbon limits, and extreme weather risks. Some respondents also highlighted tensions between biodiversity protection and poorly sited renewable development, warning that environmental damage and social impacts could be greater than predicted without stronger safeguards and adaptive management.

5.7. Consultation Authorities – Key Feedback

5.7.1 The following sub-section section sets out key and overarching feedback the from consultation authorities. Sectoral comments are included in sub-section 5.8: Consultation Authorities – sectoral feedback.

Historic Environment Scotland

5.7.2 Historic Environment Scotland (HES) advise that they are broadly content to agree with the findings of the Environmental Report. However, HES advise that neither the CCP nor the Citizen Space Hub included a link or reference to the Environmental Report, which was published separately on the gov.scot website. To improve awareness and accessibility we have included links in the CCP to the Environmental Report where it is mentioned.

5.7.3 HES agree with our findings on secondary, cumulative and synergistic effects on the historic environment, however, they do not agree that the effects of the deployment of renewable energy infrastructure and upgrades to support carbon capture and storage (CCS) can be offset, at least partially, by Waste sector measures around improved circular economy practices in the construction and demolition sector. HES state that this is because the effects will largely be on differing elements of the historic environment, and are not likely to interact in a way which would mitigate negative effects. The Scottish Government accepts this feedback, noting that the way this section was worded could be clearer. The relevant potential effects set out in the environmental report remain valid, but should be considered as distinct rather than linked, while recognising that local circumstances will vary.

NatureScot

5.7.4 As NatureScot set out in their response to the draft Climate Change Plan SEA Environmental Report, the delivery of CCP policies and proposals are intrinsically linked with the delivery of the Scottish Biodiversity Strategy (and vice versa). Nature and biodiversity are both vulnerable to climate risks in a warming and increasingly unpredictable climate, and nature and biodiversity underpin much of the content of the SEA. During the scrutiny period of the draft CCP the Scottish Government undertook a cross-government workshop in collaboration with NatureScot which focused on ensuring that the CCP and other environment and nature-related strategies positively interacted with each other to achieve mutually beneficial outcomes.

5.7.5 In their response to the Environmental Report, NatureScot note that the current greenhouse gas (GHG) inventory is structured around 6 land-use types, reflecting the dominant land uses when the inventory was developed. NatureScot have argued that this does not currently accommodate what they have described as more complex varieties of habitat in all settings that might afford greater opportunities for sequestration and resilience to climate risks. The Scottish Government has incorporated peatland degradation and restoration in the greenhouse gas inventory for a number of years. Some other land and marine uses fall under the “blue carbon” arena and are not currently included, however, studies are underway to scope their potential inclusion in future. This primarily because of current international guidelines on inventories.

5.7.6 Further, NatureScot say that it is unclear whether the multiple positive environmental effects stated in the SEA Environmental Report will be sufficient or timely. For example, NatureScot refer to the slow uptake of regenerative practices in agriculture combined with the sector’s increased risk to climate risks could undermine some of the anticipated benefits. The Scottish Government recognises that agriculture is exposed to the impacts of climate change which is why climate adaptation is an important outcome of the Agricultural Reform Programme, alongside mitigation and biodiversity.

SEPA

5.7.7 In line with the procedures previously agreed between SEPA and the Scottish Government SEA Gateway, SEPA Planning did not submit comments on the CCP Environmental Report.

5.8. Consultation Authorities – sectoral feedback

Buildings (Residential and Public)

5.8.1 NatureScot note that there is a significant work being done by the Scottish Government in relation to heat and water management and use in residential and public properties, advising that: “as well as having high embodied carbon, these also have high impacts on nature (in terms of their air, soil and water pollution) and on human health (in terms of offgasing during manufacture, installation, use and disposal)”. NatureScot feedback goes on to state that multiple “natural ‘new insulation materials’ already exist on the market that are suitable for retrofit of all construction types. As well as having lower embodied carbon, they also have lower nature and human health impacts”. NatureScot note that these alternative materials are readily available and have lower climate, nature and health impacts in multiple policy areas. Scottish Government delivery programmes currently allow for the installation of such materials, where considered appropriate. However, these materials can be more expensive, and we must ensure that funds are directed where there is the most value for money. Existing mechanisms, such as the planning system and environmental guidance, are likely to mitigate any potential adverse impacts.

5.8.2 NatureScot also note that delivery of Outcome 1 will involve the replacement of ‘old’ heating and hot water systems with which building occupants and users are relatively familiar. New systems may bring perceived (or actual) complexity which may result in higher energy use, higher associated running costs, higher emissions and the perception that the replacement systems are not fit for purpose. NatureScot recommend highlighting the risk of teething problems and inefficient use of new low carbon heating and hot water systems, and the need for support and guidance to be in place to mitigate this risk

5.8.3 We currently provide advice to home owners on clean heating systems through our Home Energy Scotland Advice Service – a domestic advice service that acts as a single point of access for free, bespoke, impartial advice on energy efficiency, renewable heating and fuel poverty support in Scotland. We are continually working to improve the process that customers go through to install clean heating and/or energy efficiency upgrades in their homes. We are currently working to explore existing customer journeys and how these may be improved, with a focus on Home Energy Scotland. This will help us to shape and evolve future advice and support services and to ensure that they continue to meet the expectations of a growing customer base.

5.8.4 HES highlight that negative effects are found for the historic environment in the draft CCP Environmental Report, however, HES consider that the Buildings proposals have the potential for both positive and negative effects, noting that the assessment identifies the potential for negative effects through works which may affect the character of historic or traditional buildings, it does not recognise the potential for positive effects through the application of appropriate energy efficient measures which will help to secure the ongoing sustainable use of those buildings. The findings for effects on the historic environment are not reflected in the key findings or mitigation and enhancement sections for this theme. Given that our historic and traditional buildings are a significant proportion of the national building stock, we agree that this is an important omission. We also agree with HES that improved capacity in appropriate skills and materials, and policy measures which can flex to accommodate approaches to differing building types will be key to mitigating effects and enhancing outcomes.

Waste

5.8.5 NatureScot advise that the benefits of a circular economy could be extended by adopting regenerative practices for all types of land use over and above material flows and waste streams. NatureScot also provided feedback to strengthen existing elements of the Environmental Report related to the Waste sector, including the issue of ‘Source-to Sea’ and the potential for land-based management of emissions to reduce impacts to the marine environment. The Scottish Government accepts these points, and would note that A Circular Economy Strategy for Scotland^[23] and its accompanying environmental report^[24] look at these issues in more depth – for example, embedding circularity across different sectors (influencing land use practices), and the link between better management across all stages of product lifecycles and reducing marine pollution and protecting aquatic ecosystems.

5.8.6 Further, NatureScot recommend that additional pressures should consider the loss of non-renewable natural assets, i.e. soil waste lost to landfill. They note that localised negative effect on soil arising from the footprint of construction and operation of new waste facilities is a minor issue when compared with the volume of soil lost to landfill. The Scottish Government notes this point, and that several measures contained within the Circular Economy and Waste Route Map will provide an opportunity to consider this in the round, including the development of a residual waste plan, and the further action to investigate and promote ways to reduce soil and stones disturbance, movement and volumes going to landfill.

Energy Supply

5.8.7 Consultation authorities recommend a recognition that there may be less wind in a warming and chaotic climate than in a stable and predictable one, potentially leading to significant disruption and operational constraints.

5.8.8 Consultation authority responses note that in paragraph 4.4.5 of the CCP Environmental Report the reference to alternative energy sources such as ‘vegetable oils’ should acknowledge that there may be potential biodiversity and other impacts depending on sources and production. It is acknowledged that the environmental implications of all energy sources can vary depending on how and where the energy is produced, including potential effects on biodiversity. This consideration is noted in reflecting the wider context of sustainable sourcing.

5.8.9 Consultation authorities also highlight the potential for the growth of the energy sector with extension of land-based renewable energy schemes and associated storage and transmission infrastructure to create negative effects on the environment if the full impacts of the development construction, operation, restoration and decommissioning are not properly assessed. This is particularly relevant for assessing how soil carbon balance and land stability may be impacted during and post construction. The Scottish Government recognises these concerns, and notes that where new development proposals come forward, our Fourth National Planning Framework (NPF4) ensures the impacts of proposals on communities and nature, including cumulative impacts, are important considerations in the decision-making process. All applications are subject to site specific assessments.

Agriculture

5.8.10 NatureScot agree in principle that measures that promote efficiency, thus reducing fertiliser and pesticide usage, and nature-friendly farming practices that boost soil health should be beneficial for both climate and nature. However, they note that there are some caveats, in particular, the scale of adoption may ultimately determine whether there is transformational land use change and the implications for nature. NatureScot also advise for greater need for consideration of the pace at which changes occur.

5.8.11 NatureScot note the stated positive effects from agriculture but note that, depending on specific practices, the potential negative effects are understated such as shifts in land use affecting wildlife habitats and advise stronger assessment of the potentially more extensive negative effects on Scotland’s biodiversity. The Scottish Government notes these concerns and that delivering the Vision for Agriculture quickly, which includes improving biodiversity, will not come at the expense of delivering it well. We recognise that protecting our natural environment and restoring biodiversity are essential to sustainable and regenerative agriculture and careful consideration is being given to making sure our Agricultural Reform Programme can deliver food production and supporting our climate and biodiversity goals.

Land Use, Land Use Change and Forestry (LULUCF)

5.8.12 HES note that the draft CCP Environmental Report identified positive effects for cultural heritage as a result of the LULUCF proposals and agree that there is potential for positive effects. However, they advise that the assessment does not recognise that peatland restoration also has the potential for significant negative effects on the historic environment, predominantly through damage to archaeological sites as a result of peatland restoration activities.

5.8.13 Historic Environment Scotland recognise that woodland creation may have positive effects on the historic environment through the enhancement or reinstatement of historic landscapes and the setting of historic environment assets. HES also note the potential for negative effects through the disturbance of historic assets, including buried and unknown archaeology, however. In response, the Scottish Government highlight that the UK Forestry Standard (UKFS) is the technical standard for sustainable forestry practice, which underpins delivery of the forestry policies of Scotland, England, Wales and Northern Ireland. It supports Scottish Government priorities and the Forestry Strategy, and Chapter 5 of the UKFS sets out legal and good practice requirements, supported by explanatory guidelines, relating to Forests and Historic Environment. These include the protection of identified archaeological sites, as well as the need for those working on new and existing forest sites to be aware of the importance of the historic environment, to recognise evidence and to assist in gathering information when reporting new records.

5.9. Consultation Authorities – Assessment of effects

5.9.1 NatureScot have broadly agreed with the assessment of these combined effects but have reiterated that they are based on assumptions around pace and scale of implementation versus the pace, scale and impacts of climate risks.

5.10. Parliamentary Scrutiny

5.10.1 The NZET Committee led parliamentary scrutiny of the draft plan, supported by evidence sessions across nine further committees.

5.11. Further scrutiny

5.11.1 Ministers requested the Climate Change Committee’s views on the draft plan as the Scottish Government’s independent statutory advisers, which were published as part of their Progress Report for Scotland in February 2026.

5.11.2 The plan has also benefited from expert input, including through the Climate Change Plan Advisory Group, covering individuals and groups with technical and scientific knowledge of climate change, representatives from business and finance, as well as those with knowledge of international law and policy related to climate change. The draft Climate Change Plan was also reviewed by the Scottish Science Advisory Council which includes membership from a wide range of scientific disciplines within Scotland’s science base.