Climate Change Bill: consultation summary report

Chapter 5: Assessing the wider impacts of the proposals

This chapter addresses responses to questions 10, 11 and 12 about the new Climate Change Bill’s potential impacts on Scotland’s people, businesses and environment.

5.1. Assessing impacts on people – question 10

There were 202 ^[27] responses to this question which asks:

Q10. What are your views on these initial considerations of the impact of the Bill proposals on Scotland’s people, both now and in future generations?

5.1.1. Potential impacts of the Bill proposals on Scotland’s people

Some respondents explicitly express support for the Scottish Government’s initial considerations regarding the impact of the Bill proposals on Scotland’s people, both now and in future generations. Most of these comments simply highlight the considerations’ importance before describing the more specific benefits which are described below.

Conversely, some respondents criticise the initial considerations. They believe that they lack sufficient detail to provide meaningful insight into the potential impacts on Scotland’s people.

‘We agree that it is hard to quantify the indirect impacts (and multiple co-benefits) of the Bill’s proposals on Scotland’s people, the international community and future generations but more should be done to assess and communicate these.’ Third sector organisation

Many respondents, including several campaigns (see section 7.2.6), agree with the statement in the consultation document that the bill improve the quality of life. Some of these respondents do not elaborate on how quality of life would improve. However, others highlight specific improvements including warmer homes, equality and improved health. These points are described in more detail below.

Many respondents, including several campaigns (see section 7.2.6), argue that the Bill proposals will improve income equality in Scotland. They often cite the potential for a low carbon economy to reduce fuel poverty and increase people’s disposable income.

‘There are significant benefits to Scotland’s people of acting on climate change – improved energy efficiency reducing fuel poverty…’ Individual

Some respondents agree that Scotland’s transition to a low carbon economy must be focused on equality and justice, ensuring that vulnerable and/or protected groups are not disproportionately affected by the Bill proposals. In contrast, a few respondents express different concerns regarding the Bill proposals’ impact on equality:

• geographically remote areas such as the Highlands and islands that are more dependent on carbon-based energy and fuel; and
• those on lower incomes who may be charged with perceived ‘Green taxes’ or tariffs.

Some respondents also highlight the Bill proposals’ potential for positive health impacts. Most of these, including several campaigns (see section 7.2.6), refer to these health impacts without elaboration.

‘It will also have positive effects and influences on the environment and on the health and wellbeing of the Scottish people now and create a lasting legacy for future generations…’ Public body

Some respondents go into more detail about positive health impacts of the proposed Bill, such as:

• reduced risk of respiratory conditions, winter deaths and mental health conditions as a result of reduced fuel poverty;
• improved health due to improved air quality; and
• improved fitness resulting from increased walking and cycling.

In contrast, a few respondents identify potential negative health impacts of the Bill proposals. This includes increased exposure to emissions due to increased walking and cycling, as well as poor health due to perceived ‘green taxes’ or tariffs.

5.1.2. Future generations

Some respondents focus on the second part of question 10 which asks about the impact on Scotland’s people of future generations. Many of these respondents refer to the impacts described above and go onto describe the potential injustice that would be inflicted upon future generations.

‘The decisions made today will impact future generations significantly, and thus we should be as ambitious as possible if we are to respect their rights.’ Individual

A few respondents suggest different solutions to this issue:

• reference to intergenerational equity in legislation;
• remove discounting methods from the modelling of climate policy to give equal weight to future generations;
• include youth representation in the development of climate policy, such as a future generation’s commissioner or guardian; and
• refer to the Welsh Wellbeing Future Generations Act as a possible model for the Scottish Government.

5.1.3. Behaviour change

Some respondents suggest that the Scottish Government considers people’s differing levels of acceptance of transitioning to a low carbon economy. While these respondents do not refer to targets explicitly, they describe the potential challenges of people transitioning on achieving the aims of the Bill proposals. Some examples of potential barriers to behaviour change include:

• modal shift away from cars to public transport, walking and cycling;
• perceived ‘green taxes’ and tariffs;
• changes in diet; and
• reduced flying.

A few respondents also believe that people can struggle to see the link between their own energy consumption and the impact this has on climate change.

Some respondents also suggest potential mitigation for these barriers to behaviour change. A few respondents suggest a hard-line or regulatory approach of telling people that they must make sacrifices.

‘I think that us people need to be made aware that we need to change. Things we take for granted might not be possible in the near future.’ Individual

Other respondents prefer a softer method of education and communication. This includes reducing the bureaucracy of grants, loans and funds that facilitate transition, in addition to projecting the positive impacts of the Bill proposals. Some more specific suggestions can be found in Appendix B.

5.1.4. Suggestions for the initial considerations

A few respondents provide a variety of specific suggestions for how the Scottish Government could provide more detail to assess the impact of the Bill proposals on Scotland’s people:

• assess impacts against UN Sustainable Development Goals;
• assess impacts against the Scottish Government’s National Performance Framework;
• include a detailed Health Impact Assessment; and
• include a new document broadly explaining the delivery measures intended and their impacts for all groups.

5.2. Assessing impacts on businesses and regulation – question 11

There were 197 ^[28] responses to this question which asks:

Q11. What are your views on the opportunities and challenges that the Bill proposals could present for businesses?

5.2.1. Opportunities for businesses and the wider economy

Respondents often state that Scotland’s economy will improve and jobs will increase as a result of the Bill proposals. Some of these respondents do not elaborate on how the economy would improve, including several campaigns (see Chapter 7). Some respondents also relate the potential economic benefits to global leadership and setting an example for other nations (see section 6.2.3).

Some respondents also highlight different potential opportunities for businesses and the economy. These include:

• research and development (R&D), manufacturing and sales jobs for electric and fuel cell-powered transport;
• R&D, construction and distribution jobs for the renewable energy sector; and
• increased energy efficiency reducing business overhead costs.

5.2.2. Challenges for businesses and the wider economy

Some respondents believe that the Bill proposals pose a challenge to Scotland’s businesses and economy. While some use this as a means to criticise the Bill proposals, others see these challenges as inevitable or able to be mitigated.

‘Certain businesses like oil, gas etc. will undoubtedly have to make way for the green businesses…The end of the industrial revolution had its casualties. Our society will have too.’ Individual

In addition to more general observations of potential economic challenges, some respondents identify specific potential negative impacts to Scotland’s businesses and economy. This includes the hydrocarbon industry, both for those who work directly for such businesses or those who have invested in this industry. Some respondents also express concerns around potentially increased transport or energy costs for businesses and employees. They believe these increases may come about as a result of tax increases or new and expensive technologies.

5.2.3. Transitioning to a low-carbon economy

Many respondents, including several campaigns (see section 7.2.7), request a “Just Transition Commission” that includes representatives from different stakeholders, including work unions, community representatives and environmental organisations. They believe that these stakeholders would be able to advise the government on how best to transition high-carbon industries and jobs to a low-carbon economy.

‘The Scottish Gov should set up a Just Transition Commission to advise on moving businesses to a co-operative low carbon economy where costs and rewards are shared fairly.’ Individual

In addition, a few respondents support the concept of a “just transition” without explicitly suggesting a Commission.

Some respondents believe that supporting businesses is the most effective way to successfully transition Scotland to a low carbon economy. Some respondents make different suggestions of how to do this:

• create industry strategy and policy that can ensure the long-term sustainability of Scotland’s businesses;
• provide training and support for businesses and their employees; and
• provide incentives, including funding and tax breaks, especially for small and medium enterprises ( SMEs) who may be most at risk of being impacted by potential taxes or tariffs.

A few respondents also suggest that the process of transitioning to a low carbon economy must involve a wide range of stakeholders, both large corporations and SMEs, in order to build trust and encourage a positive attitude to transformation.

‘Small and local businesses have higher relative/percentage costs of compliance and managing change; and so measures need to be in place to enable and encourage smaller - and community - businesses to be part of the solution; rather than it being only larger corporations who can afford to adapt to new standards.’ Individual

A few respondents are sceptical about the success of the Bill proposals’ ability to transition to a low-carbon economy. They comment that businesses may be unwilling to change, or that measuring the financial success of companies may not be an effective way to gauge the success of the Bill proposals. Some respondents suggest a more hard-line regulatory approach to businesses who are unwilling to transition to a low carbon economy.

5.2.4. Comments on the partial Business and Regulatory Impact Assessment ( BRIA)

Some respondents make comments on the partial BRIA which is an accompanying document to the main consultation document. A few of these respondents are supportive of the document. They agree with the document’s conclusions that the Bill proposals create both opportunities and challenges to businesses. A few respondents also support ‘Option 3’ which intends to turn the threat of climate change into a competitive advantage.

In contrast, a few respondents are critical of the partial BRIA. These criticisms include a perceived lack of detail and a failure to account for the potential significant economic cost of choosing the ‘Do Nothing’ option which does not include more ambitious targets.

5.3. Assessing impacts on the environment – question 12

This section addresses responses to question 12 about the Strategic Environmental Assessment ( SEA) carried out by the Scottish Government to assess the impacts of the proposed Bill, as well as relevant comments in response to other questions and responses from letters or emails.

The Scottish Government published an Environmental Report and requested respondents’ feedback on the evidence used to inform the report, the environmental effects of the proposals, and the conclusions and recommendations reached.

Responses to questions 12a-e are summarised together below, as respondents address the issues in a cross-cutting manner.

There were 149 ^[29] responses to question 12a which asks:

Q12a. What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process? (Please give details of additional relevant sources).

There were 142 ^[30] responses to question 12b which asks:

Q12b. What are your views on the predicted environmental effects as set out in the Environmental Report?

There were 133 ^[31] responses to question 12c which asks:

Q12c. Are there any other environmental effects that have not been considered?

There were 141 ^[32] responses to question 12d which asks:

Q12d. Do you agree with the conclusions and recommendations set out in the Environmental Report?

There were 127 ^[33] responses to question 12e which asks:

Q12e. Please provide any other comments you have on the Environmental Report.

5.3.1. General comments

Across these questions, most respondents who express a view on the Environmental Report support its use of evidence, and agree with the predicted environmental effects the Report sets out, as well as its conclusions and recommendations. Across all questions, some respondents comment on the potential positive environmental effects of the proposals, primarily referring to the effects of reduced emissions on air quality.

Of those respondents who criticise the Report in general terms, many respondents claim that the Environmental Report should consider the GHG emissions from production of goods and services elsewhere that are consumed in Scotland. Some respondents claim that the Environmental Report does not adequately address the urgency of climate change because the proposals are not ambitious enough. A few respondents say that the Report is unclear or biased, while others doubt the feasibility of the proposals it outlines. Specific criticisms or suggestions are summarised below.

‘The Environmental Report quantifies Scotland's contribution to climate change in terms of territorial emissions but does not include any recognition of the greenhouse gas emissions induced by Scottish consumption of good and services produced in other territories.’ Individual

Many respondents do not comment in detail on the Report, stating that they do not have an opinion, or that the document is too complex for them to understand.

5.3.2. Evidence and assessment process

Respondents who do give more feedback, describe the evidence used to inform the assessment process and set out in the Report as comprehensive, well-summarised and clear. They say that the approach taken, which includes a review of previous relevant assessments, is appropriate. Respondents welcome the inclusion of references to transport and planning strategies and evidence on the potential health impacts of the proposals (see section 5.1.1 for more details on health impacts).

‘The two stage process for gathering evidence for the Environmental Report was a suitable option to providing the overview of potential environmental effects associated with the Climate Change Bill.’ Public body

Some respondents say that aspects of the Report require further consideration or that parts of it rely on assumptions or narrow evidence bases, limiting the scope for accurate predictions to be made. Some respondents offer additional relevant sources to address perceived gaps in the evidence to inform the assessment process, including articles, Scottish and UK government publications and research from organisations like the Centre for Alternative Technology. A full table of suggested additional sources is included in Appendix C.

Some respondents suggest topics that they feel could be included in greater detail in the evidence set out in the Report. These topics include:

• management planning for river basins and flooding;
• agriculture and land use;
• pollution and air quality;
• ocean acidification;
• the spread of human and animal diseases;
• the impacts of fossil fuel extraction; and
• emerging energy sources, such as hydrogen and bioenergy.

‘We are broadly satisfied with the evidence used to inform the assessment process… However, the Report could also have made reference to River Basin Management Planning and Flood Risk Management Planning.’ Public body

5.3.3. Predicted environmental effects

Respondents who comment on the predicted environmental effects set out in the Report accept that the proposals will impact positively on global climate, and often specify positive secondary impacts that could result from decreased GHG emissions, such as improved health and air quality, and increased biodiversity.

Some respondents welcome the inclusion of potential negative effects in the Report as well, specifically the impacts of new energy infrastructure. They often request the mitigation of these impacts through monitoring and project planning, for example through reuse of existing infrastructure. A few respondents claim that there are likely to be other environmental effects that have not been considered in the Report, but which cannot yet be predicted.

‘I agree that potential negative effects as a result of low carbon infrastructure should be avoided or reduced where possible through careful planning, reuse of existing assets and appropriate mitigation measures.’ Multiple respondents

While some respondents say that the predicted environmental effects are presented clearly in the Report, and are consistent with recent research on climate change, others identify gaps in the effects provided. Some respondents say that the environmental effects of renewable energy sources, Carbon Capturing and Sequestration ( CCS) technologies and any other infrastructure required to meet the targets, will need to be considered further. They consider the possibility that negative environmental effects currently generated by traffic in one location could be replaced by negative effects from energy generation elsewhere, suggesting that a strategic approach may be required to monitor and address cumulative negative effects.

‘It may be helpful to identify triggers for when strategic rather than project level assessment will be required. For example proposals for a number of bioenergy facilities in one area would benefit from strategic consideration rather than on a project-by-project basis.’ Public body

Several respondents refer to the inclusion of references to CCS in the Report, with both opposition to and support for its proposed use. Respondents who favour this approach see a role for such technology in addressing air quality, and discuss ‘blue carbon habitats’; they say that the impact of marine activities upon the carbon sequestration capacity of the sea needs to be understood, and ask why CCS applicability to coal has not been mentioned in the Report. Those who oppose CCS say that it would not end Scotland’s use of fossil fuels and has not yet been proven economically viable or replicable.

‘We note and support, in particular, two conclusions that have resonance with our views on the need for deployment of CCS as a CO2 management and storage system, and the means by which this may be achieved.’ Academic or research organisation

5.3.4. Other comments on the Environmental Report

Some respondents comment on features of the Report that they support, including the emphasis on adaptation, the use of renewable energy technologies and the need for planning and policy alignment across sectors. Respondents often emphasise the importance of additional assessments as proposals are put in place, requesting that the principle for the development of a monitoring scheme should be embedded in the Bill. They say that this monitoring must consider the achievement of national policy objectives alongside the proposed targets, with sector-specific accounting and policies, and consultation on strategic issues.

Other comments that some respondents offer on the structure and context of the Report include:

• provide the views of statutory consultees in an appendix;
• make links with relevant UN Sustainable Development Goals;
• examine reasonable alternatives to the proposed targets, such as tighter interim targets;
• assess the environmental effects of a range of scenarios for interim targets; and
• consider food production as its own category.

5.3.5. Effects of climate change

Question 12 was about the Environmental Report, but some respondents express views on predicted environmental effects of climate change more generally. Most of these respondents say that climate change will be more severe sooner than the Report sets out, emphasising the uncertainty in modelling any future climate change. They encourage the Scottish Government to prepare for worse outcomes than they say the Report demonstrates. A few of the respondents providing a view on this question however agree that the Report gives an accurate assessment of these effects. Some respondents provide suggestions to reduce emissions, to address the effects of climate change, these are provided in Appendix B.