Stop Climate Chaos Scotland policy adviser Lloyd Austin and a team of eagle-eyed coalition members unpick the details in the Scottish Government’s draft Climate Change Plan, which was published on 6 November and is open for consultation until 29 January.
Publication of the new Climate Change Plan (CCP), in draft form, is welcome, setting out how the country will meet its legally binding target to reach net zero, or neutral emissions, by 2045.
It comes after a new accounting system using five-yearly carbon budgets was introduced to replace the annual and interim goals leading up to 2045, which were scrapped after a series of failures to hit them. It also reflects some recommendations from government advisers at the UK Climate Change Committee (CCC).
The contents of the CCP will be “critical” in setting out a clear pathway to a fairer, greener future, according to Stop Climate Chaos Scotland policy adviser Lloyd Austin.
The coalition, with it’s 70+ members, is calling for a strong and ambitious CCP that will bring about the necessary carbon reductions to reach net zero while providing multiple benefits to people, the economy and the environment. The plan and methods used to achieve decarbonisation must also be measurable, achievable, transparent, credible and holistic.
Here SCCS assesses the draft plan and how it can be improved:
Emissions reduction goals
The new CCP covers the first three of four carbon budgets on the road to net zero emissions by 2045: 2026-2030, 2031-2035 and 2036-2040. These will require emissions to be reduced by 57%, 69% and 80% respectively, compared to 1990 levels, in order to stay within the limits of each allowance.
The figures do add up arithmetically, confirming that greenhouse gas emissions will be within budget if the policies are implemented and work as predicted. However, ministers must demonstrate more clearly how they arrived at the final figures and more clearly that this pathway is realistic and deliverable.
As drafted and published, the policy-specific origins of the emissions reductions are unclear, with data broken down only to sector or policy-package level. Given the delays and lack of clear further action in many areas, the way in which these sectors and packages will deliver the forecasted emissions reductions needs clarification.
There is also a worrying over-reliance on unproven emissions-removal technology such as carbon capture, utilisation and storage (CCUS) to achieve emissions cuts for some of the biggest polluters. This provides a ‘get out of jail free’ card for the likes of gas-fired power stations and simultaneously leaves progress subject to a high degree of chance. The draft CCP proposes that, by 2040, these technologies will capture significantly more greenhouse gases than the CCC ‘balanced pathway to 2045’ suggested. This is necessary as the Scottish Government has chosen to delay or not implement CCC proposals in relation to buildings, agriculture and other sectors.
The costs and benefits of targeted decarbonisation measures have been set out well, with price tags given at sectoral and overall level as well as predicted economic uplift – a tenfold return on every pound spent.
Is it measurable?
Every policy in the CCP should have specific, measurable outputs, expected climate outcomes and a timeframe for implementation.
But analysis shows most policies are either vague or ‘enabling’. In a few cases there are specific, quantifiable outputs, but these are rare. Some timescales are included, but these are mostly absent. Generally it is also not obvious or stated whether existing measures are to continue, even when highlighted as a ‘success’.
Is it achievable?
The plan should front-load ambitious new policies as early in the plan period as possible to secure the biggest impact. However, there is no sign of any front-loading. In some cases, such as buildings, there appears to be further delays, leaving the most significant action until the late 2030s or early 2040s.
Meanwhile, there is a significant lack of new policies – few, if any. Most measures depend on implementation or ramping-up of existing ideas, and are subject to appropriate funding being allocated in future budgets.
Funding to be allocated for each carbon budget period should also be set out, or the plan is at serious risk of failure.
Is it transparent?
There must be clarity on how each expected policy outcome has been calculated and which body is responsible for implementing them.
The CCP clearly purports to provide monitoring and analysis, but the detail is limited – broken down only to outcome or policy package level. And there is buck-passing in most sections, relying on ‘asks’ from the UK government, local authorities and non-government partners such as businesses.
There are also very few actual timelines included, and where given are generally delayed.
Is it credible?
It is crucial to demonstrate how carbon budgets will be met, and how the actions proposed will result in a viable pathway to net zero by 2045. It should prioritise policies over proposals and regulation over voluntary action.
Although the numbers do add up, ministers have provided little evidence of how the component policies each contribute to the stated emissions reductions or the confidence about the degree to which the reductions proposed on paper can be delivered in practice. Overall, with few new policies, actions or regulations, credibility is shaky.
Credibility is also undermined by the increased dependence on the (probably) unreliable technological solutions of negative-emissions technologies (NETs), including CCUS. Evidence suggests these will be expensive, unlikely to work and never delivered in time. Yet, the plan only ‘adds up’ because even more emissions will, apparently, be removed by these methods. At the very least, the plan should propose contingencies or alternatives (a so-called ‘Plan B’) as to how budgets will be met if these solutions do not materialise.
Is it holistic?
The CCP should take account of the wider benefits of policies (eg: social, economic and health), as well as detailing their climate and financial impacts.
The Scottish Government has done good work in this section, with considerable presentation of economic data, including costs and benefits, as well as associated improvements in health and well-being.
Round-up by policy area
Buildings
No new measures are proposed. There is no Heat in Buildings Bill, and this won’t be coming any time soon after being put on hold until after the 2026 Scottish election. Also, the pathway laid out in the draft CCP postpones significant emissions cuts until after 2040, creating a cliff-edge scenario.
Transport
The plan contains positive action on electrification of cars, vans and HGVs, which will deliver most of the emissions reductions set out, but is weak on both modal shift and increasing and improving public and active travel options. And there is no action to cut emissions from aviation or shipping.
Waste
Aspirations here are very dependent on Scotland’s circular economy and waste routemap and targets to be set in 2027 – all of which have not met expectations, and do not go far enough to transform how we use materials.
Energy supply
Positions on supporting renewables and opposing onshore oil and gas (including fracking) and coal are welcome. However, there is a notable silence on offshore oil and gas, beyond noting historical decline in reserves. Although this is an issue reserved to the UK government, this is a missed opportunity to show leadership and drive the just transition needed by workers and communities. The CCP appears supportive of Peterhead gas power station if “CCUS-ready”, relying on carbon-removal tech to cut pollution.
Business and industry
Policies on electrification and energy-efficiency are positive, while some hydrogen measures may be supportable, depending on application. However, once again there is a significant gamble on CCUS and other NETs for delivering the necessary reductions.
Agriculture
No new policies have been set out and this sector has largely got a free pass, with emissions planned to be higher than advised by the CCC. There is no proposal relating to the need to shift to lower-carbon diets, which would also help improve our health. While the CCC recommended a proactive policy to reduce livestock numbers, the government has taken a political choice to diverge from this advice. This means emissions from this sector will be higher and need to be balanced by higher removals in other sectors.
Land use, land use change and forestry
Ambition for this sector is disappointingly low, despite it playing a crucial role in reaching net zero because of its importance in delivering removals to balance out residual emissions from the other sectors. Planting targets for new forests and woodlands are to increase, but not in the order of magnitude needed. A higher end-target for peatland restoration is also proposed, but this actually represents a lower annual improvement rate than the government had been seeking to achieve in recent years.
Marine
Nothing new to see here – while it’s welcome that marine issues are included, the CCP simply reiterates existing research ideas.
International
It is welcome that the plan includes a section on how Scotland has supported lower-income countries that did least to cause the climate crisis to reduce emissions and adapt to climate impacts. SCCS specifically asked that the new plan include such an international perspective, and this is required in legislation.
However, the draft is, in effect, simply a review of actions to date and no new measures are proposed. Indeed, it is not even explicit that current actions will be maintained. The finalised plan should make clear the Scottish Government’s continued commitment to this work and demonstrate more ambition for the plan to deliver climate justice.
Conclusion
The draft plan does purport to meet the carbon budgets and covers the required sectors/topics, with the predicted emissions reductions from each sector adding up to the budgets.
However, the lack of new meaningful measures and over-reliance on NETs are a weakness, meaning that it fails to provide an inspiring vision of a better, climate-friendly future. Alongside this, the lack of detail about how policies will be funded and delivered means we have serious concerns about its credibility.
The plan will now be scrutinised by MSPs, and the public can also have their say.
The routemap must be strengthened to realise its full potential to not only meet national and international climate targets but to deliver meaningful benefits to people’s lives.
A strong CCP would help Scotland reclaim its reputation as a climate leader while also creating a cleaner, safer, healthier and more prosperous future for Scots.
