Blog by Lloyd Austin, Policy Advisor to Stop Climate Chaos Scotland
The Scottish Government has rightly called this time – the 2020s – the ‘decade of delivery’ on climate change. Yet, to date, delivery has been lacking, with a recent series of damaging missed climate targets – so we must find ways to confront the scale, complexity and ubiquitous nature of the challenge. Stop Climate Chaos Scotland has published a Climate Manifesto in an attempt to rise to that challenge and set out the full range of policy measures that are necessary, ahead of the Scottish Government publishing a new Climate Change Plan (CCP). Following on from the blog by SCCS’s Chair, Mike Robinson, introducing the Climate Manifesto, this blog seeks to explain what the CCP is, why it is important, the timetable for its review/publication, how SCCS has been contributing to its development, and how we will judge its content.
The Climate Change Plan
The Climate Change Plan (CCP), previously known as the Report on Proposals and Policies (RPP), is a statutory document required in the Climate Change (Scotland) Act 2009. The Scottish Government describes the plan as the “strategic delivery plan for meeting our emissions reduction targets”. The plan is required to include proposed measures related to issues devolved to the Scottish Parliament, and is organised by sector: for instance, electricity, transport, agriculture, etc.
The current version of the plan is the third Report on Proposals and Policies, published in 2018, taken together with the Climate Change Plan update, published in 2020 (the latter to take account of the new targets and requirements introduced by the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. This plan and its update covers the period 2018-2032, the next plan will ‘roll forward’ to cover the period from 2024/5 to, at least, 2040 – but also with an eye on the 2045 net zero target. As part of this ‘rolling forward’, the new plan will need to carry forward an/or revitalise/update, existing policies in the current CCP/CCPu that need to be continued or are, as yet, not completed or fully implemented.
Why is it important?
Government policies – whether regulation, fiscal (grants, subsidies or taxes) or advice – are crucial for the changes necessary to deliver emissions’ reductions. The 2009 Act sets a comprehensive framework for how such policies, insofar as devolved matters are concerned, should be developed, set out and implemented. A similar framework for UK/reserved matters has been established under the Climate Change Act 2008.
The framework for Scotland’s actions on climate change, as set out in the 2009 Act, as amended, includes the requirement to seek advice from the Committee on Climate Change (as well as annual progress reports from that body), but also the requirement to report annually to Parliament on progress towards the targets. These annual reports usually happen around June of each year when emissions’ statistics are published. Recently, while considerable progress has been made, it is notable that, in eight of the past twelve years, annual targets have not been met – and those that have were a result of travel being limited during the pandemic. This has led the Committee on Climate Change to advise that “the integrity of the Scottish climate framework is now at risk”.
Thus, the next CCP is really of huge significance – it is the opportunity for the Scottish Government to reassert its climate leadership – to set out a new framework that will meet future targets but also to demonstrate how that will happen, by clearly setting out the emissions’ reductions that each of its actions will deliver. The CCP must be credible – both for its own sake and the meeting of future targets, but also for the credibility of the Scottish Government. Often, the First Minister (and others) have made very welcome and positive statements about the need for action on climate change – especially in contrast with those from the UK Government, and the CCP would help to turn that rhetoric into reality.
If, however, the plan is not adequate, this will be a huge missed opportunity and potentially an example of what the First Minister has called “catastrophic negligence”. It would also make meeting targets more difficult and undermine the credibility of the Scottish Government (especially when speaking on the international stage about the need to address climate change). Such an inadequate plan also risks, because of the need to comply with the framework set by the 2009 Act, being challenged – and potentially the Government being ordered to re-do it. Such a challenge, related to the similar Net Zero Strategy and the framework of the 2008 Act, was recently successful. This led to the UK Government having to produce a new strategy – although the revised strategy is also, now, potentially subject to a renewed challenge. Likewise, ad hoc changes to policies, previously set under the planning frameworks (as the UK Government has recently proposed) may be subject to challenge.
The timetable for its review/publication
On the basis of the statutory five year cycle, the existing CCP/CCPu would need updating in the mid-2020s. However, when the current Scottish Government was formed, the ‘Bute House Agreement’ promised “to deliver a draft of the next Climate Change Plan, that demonstrates a credible pathway to achieving the 2030 target, for consideration in the first half of this parliamentary session”.
This commitment is reiterated in the 2023-24 Programme for Government states out that the Scottish Government will “set out how we will continue to drive down emissions in a draft Climate Change Plan, with bold action across transport, heat, our natural environment, and other areas, demonstrating how our ambition will be realised while maximising opportunities for the economy, job creation, and health”. It is then further underlined, including reference to the 2040 target, in the ‘mandate letter’ to the Cabinet Secretary, which indicates that a priority is to “publish our new draft Climate Change Plan which will extend Scotland’s emissions reduction planning pathway for our statutory targets out to 2040 and include estimates of the costs and benefits of the policies to achieve this”.
Originally, the expected date for the publication of the draft CCP was around ‘late November 2023’. Publication then would provide, if it was genuinely ambitious, setting out a clear and credible path to meeting targets (as a minimum), the Scottish Government with a proposal to be proud of at COP28 in December. November 2023 would also (just) be around the halfway point of this Parliamentary session – and thus meet the Bute House Agreement commitment.
However, publication has been delayed – with the Cabinet Secretary citing the need to analyse and take account of recent changes to UK Government policies and the economic situation as causes.The new plan is now expected to be in the new year. SCCS has responded to news of the delay here.
Early 2024 is already the likely publication date for the (closely linked) Energy Strategy and Just Transition Plans. The CCP will also need to cross-reference (and provide further detail) on the implementation and timings of actions under the Agriculture Bill and Circular Economy Bill (both framework bills currently before Parliament), and the forthcoming Heat in Buildings Bill.
Whenever the draft is published, the process that follows will be the same. The draft is laid before Parliament, and there follows a period of 120 days (of which no fewer than 60 must be outwith of recesses), for Parliamentary scrutiny. At the conclusion of this scrutiny, Parliament will publish its recommendations – which the Government has to consider before finalising and adopting a final version of the plan.
This 120 day scrutiny period will be a crucial opportunity for stakeholders and the public to comment on the draft plan. It is likely that various Parliamentary Committees will issue ‘calls for evidence’ to which SCCS, its members and others will respond. There may also be parallel public engagement opportunities co-ordinated by the Parliament and/or Government.
A final CCP (incorporating Government responses to Parliamentary recommendations and any public engagement) is, therefore, likely to be adopted in late 2024 or early 2025.
How has SCCS already been contributing to its development?
SCCS has, of course, been aware that work to develop a new CCP has been underway for some time. The commitments in the Bute House Agreement and Programme for Government made this clear, and it was confirmed by our regular meeting with Scottish Government Ministers and officials. Building on these discussions, we have taken part in a series of meetings with relevant officials, starting in early 2022, when for instance we discussed and made a submission on the scope of the plan. It appears that parts, at least, of this proposal have been accepted that the new CCP will address international climate justice and the issue of blue carbon.
More recently, during the summer of 2023, and as part of the Scottish Government’s public engagement programme, SCCS has chaired and its members have participated in a series of “NGO roundtables” on a range of sectors. These roundtables, involving NGOs from within and beyond the SCCS coalition, have considered, transport, marine, international, agriculture & land use, waste & circular economy, Negative Emission Technologies & hydrogen, and buildings & heating. For each of these roundtables, the NGOs provided a brief outline of the policies and proposals that members and others thought could (and should) be included in the CCP. The roundtables provided an opportunity for a brief, initial discussion of these ideas, while some were subject to subsequent bilateral discussion. The Scottish Government officials have undertaken to give the ideas appropriate consideration, and to provide feedback on if and how they are included in the CCP and, if they aren’t or aren’t in full, to provide some explanation.
The policies and proposals suggested by SCCS members at these roundtables were based on work that was already underway, in summer 2023, to develop SCCS’ Climate Manifesto. As set out in the summary of the published form of the manifesto, it is a collection of proposals that could help us get back on track to meeting our targets, and it is “a wealth of content for those revising Scotland climate plans”. Of course, in relation to matters addressed by the NGO roundtables, relevant officials were aware of the proposals ahead of the manifesto’s launch.
In the introduction to SCCS’ Climate Manifesto, we say that:
“Adopting the policies in this document would put Scotland on track to deliver the real reductions in climate change that the planet needs and to make our fair contribution to helping other countries deal with climate change in their own ways”.
The ideas in the manifesto can be adopted in a range of ways – by the UK Government (on, for instance, oil and gas, corporate taxation or international negotiations) or by local authorities (on for instance, local active travel schemes). There are many policies proposed, however, for the Scottish Government. On international climate justice, including funding for Loss and Damage, these are policies that Ministers can announce, include in budgets and implement as/when possible. However, in relation to policies for emissions’ reduction, the key mechanism for the Scottish Government to implement these ideas is the Climate Change Plan (CCP), and we hope the new CCP will adopt many of them.
As set out above, the CCP has to describe the Scottish Ministers’ policies and proposals “for meeting the emissions reduction targets” (that is, net zero by 20245, and a 75% reduction by 2030, as set in the legislation). These relate, however, to all emissions from Scotland – whether or not the policies that influence them are reserved or devolved or, in many cases, a mix of both. This means that the plan, which focuses on devolved policies within the control of Scottish Ministers, has to take account of whatever international and UK context – and still meet the targets. There is, therefore, an understandable dilemma and the need to fully understand that context – especially at a time when recent changes in UK policy have been disappointing and subject to challenge by UK NGOs. However, it remains clear that there is considerable scope for more ambitious action in devolved areas (see the gap between actions in the current CCP/CCPu and those in SCCS’s Climate manifesto). SCCS is clear that both the UK and Scottish Governments can, and should, be more ambitious – and that both governments (and/or the CCC) should be more transparent as to what each of their policies mean for emissions, and how they interact – rather than seeking to ‘blame’ each other if/when targets are not met.
How will SCCS judge its content?
SCCS will assess the draft CCP. This assessment (and any recommendations we make for its improvement) will take two forms:
- An overall assessment of its ambition and credibility – using the MATCH criteria (see box); and
- An assessment of individual policies, sector by sector, based on a comparison with the policy proposals set out in SCCS’ Climate Manifesto, previously shared with officials at the roundtables, described above.
The MATCH criteria
In order for Scotland to meet its world-leading climate ambitions and to realise the benefits of a low carbon transition, we believe that the Scottish Government’s new Climate Action Plan must MATCH all of the following criteria:
Every policy in the Climate Action Plan should have specific, measurable outputs, expected climate outcomes and a timeframe for implementation.
The Plan should front load ambitious new policies to secure the biggest possible impact, particularly for transport, land use, heat and energy efficiency
The Climate Action Plan should provide clarity on how each expected policy outcome has been calculated and which body is responsible for implementing each policy.
The Plan must show how all annual targets between now and 2032 will be met and should prioritise policies over proposals and regulation over voluntary action.
The Plan should take account of the wider benefits of policies (e.g, social, economic and health), as well as detailing their climate and financial impacts.
Of course, a similar approach will also be used to assess the final version – and, if in the view of experts, it is substandard and/or appears not to meet the requirements of the 2008 Act in setting out a route to meet the 2030 or 2045 targets, we will need to consider what, if any, action we might take.