Climate change duties - draft statutory guidance for public bodies: consultation

Annex B: Climate Change Plan template for local authorities

The purpose of this template and guidance

Who is this template for?

This template is for use by Scottish local authorities (LAs) only. It is intended to help LAs demonstrate their compliance with the three climate change duties, across their corporate and area wide boundaries.

What is the purpose of the Climate Change Plan template?

This document provides a template of how local authorities should present the action being taken in respect of their climate change duties in the form of Climate Change Plans (CCPs). The content of the template is not exhaustive, however it does contain the areas LAs CCPs should cover in order to demonstrate that they are meeting their climate change duties.

LAs are free to develop and structure their CCP, or equivalent, as best suits their own organisation, for example as a single overarching plan or a series of linked plans covering different areas. This document is intended to provide an overview of what LAs' plan or plans should include, as a minimum, to demonstrate how they are acting in the way best calculated to contribute to the national mitigation targets and to help deliver the national adaptation programme, and in the most sustainable way, i.e. how they are meeting the public bodies climate change duties.

What should a Climate Change Plan include?

In developing their CCP, LAs should consider corporate and area wide activities in terms of mitigation (reducing emissions), adaptation and acting in the most sustainable way, i.e. they should cover the full scope of the climate change duties.

LA Climate Change Plans (CCPs) should cover:

• corporate (organisational) assets and activities and the emissions generated by these, including relevant scope 3 emissions
• area wide activities and emissions, many of which will lie outside the control of the LA but within their sphere of influence.

The climate change duties require to be met as the body 'exercises its functions' – for LAs, these functions should be taken to include:

• corporate operational functions
• delivery of public services within the authority area
• policy making functions or influence
• discharging of other mandatory duties
• exercise of regulatory powers.

The CCP therefore needs to be a much more comprehensive plan that one which, say, considers building and fleet decarbonisation alone. LAs may find, in operational terms, that the CCP is supported and implemented by a series of targeted policies, route maps and action plans which lay out the more granular detail for relevant assets, functions and activities.

Given the interlinked nature of the climate and biodiversity crises, LAs may wish to develop strategies or plans that tackle these together. The content of this template focuses on climate action and sustainability. LAs should follow the available guidance in relation to biodiversity and nature recovery. Further relevant guidance may be developed in the future in relation to the proposed Natural Environment Bill and the proposed statutory targets for nature restoration.

Climate Change Plan template for local authorities

1. Introductory information about the LA

i. Background information about the LA area (high level)

Including, for example: location, geography, population, socio-economic status and influencing factors, key industries and land use, nationally or regionally important assets or infrastructure, e.g. regional NHS sites, large Scottish Water assets, HE/FE institutions, key transport infrastructure. Key climate vulnerabilities and impacts, such as coastal erosion, drought risk or flooding, specific to the LA area.

ii. Background information about the council (high level)

Overview of the council, including numbers of staff; overview of assets such as buildings, fleet and social housing; services and delivery (e.g. waste, social care – procured as contracts or delivered inhouse); other mandatory duties; and regulatory powers, e.g. planning. Key delivery partners and stakeholders.

iii. Climate policy and implementation (high level)

Brief statement around the climate emergency, action taken to date, key policies and related strategies (including links to where these can be found). This could include identifying key relevant national targets, strategies and policies, and outlining how the council has delivered or plans to deliver on those, with gaps and exemplar action noted.

Brief statement about mainstreaming or embedding climate action into the council’s activities and decisions; note key responsible roles (governance to be covered in more detail in further sections).

2. Developing the Climate Change Plan

i. Assessment of the current situation – where we are now

The LA’s and the LA area’s impact on climate change; and how climate change is, and will, affect the organisation and region (refer to chapters 5 and 6 of the guidance).

Emissions:

Refer to section 5.5 of the guidance and the table below.

Table: Relationships of scopes across the organisational (corporate) and area-wide protocols (adapted from the GHG Protocol)

Scope	Definition in relation to organisational emissions	Definition in relation to area-wide emissions
1	Direct GHG emissions from sources that are owned or controlled by the organisation	GHG emissions from sources located within the local authority boundary
2	Indirect GHG emissions from acquired electricity, heat, steam or colling consumed by the organisation	GHG emissions occurring as a consequence of using grid-supplied electricity, heat, steam and or cooling within the local authority boundary
3	All other indirect emissions that are a consequence of the activities of the organisation	All other GHG emissions that occur outside the local authority boundary as a result of activities taking place within the local authority boundary

• Corporate (organisational) emissions – main sources of emissions both direct and indirect (i.e. including relevant scope 3 and, where applicable, land based emissions) and explanatory narrative
• Area wide emissions – main sectoral sources of emissions (e.g. heating, energy, transport, industry, land use) and explanatory narrative. Further guidance will be developed by the Scottish Climate Intelligence Service (SCIS) in the coming months to assist LAs with this.
• Where the LA and LA area is now, and the gap to net zero, i.e. areas where action needs to be focused.

Adaptation:

Refer to chapter 6 of the guidance.

• Corporate adaptation – main hazards, vulnerabilities and exposure; key risks and opportunities in relation to assets, service delivery and fulfilment of LA functions; key partners and stakeholders. Where relevant, how corporate adaptation relates to and links with the regional adaptation approach and plan.
• Area-wide adaptation – main hazards, vulnerabilities and exposure; key risks and opportunities for the LA area (or wider region if appropriate) and wider priorities (e.g. economic development); key partners and stakeholders. Regional approaches that are already in place or in development.
• Where the LA and LA area is now; the gap to being a well-adapted and resilient organisation or region; and the gap in relation to SNAP3 outcomes.

Acting in the most sustainable way:

Refer to chapter 7 of the guidance.

• Corporate sustainability – consideration of wider environmental, social and economic issues, beyond GHGs and net zero, e.g. waste, pollution, use of plastics, the circular economy, equalities and just transition in service delivery and procurement. Contribution to and alignment with the National Performance Framework and UN SDGs.
• Area wide sustainability - wider environmental, social and economic issues; LA area or regional issues such as air and water pollution, contaminated or abandoned land or property, health, areas of deprivation, inequalities. Any specific issues, challenges and opportunities. How the LA fits into the national picture, contribution to and alignment with the National Performance Framework and UN SDGs. Where the LA or LA area is now, and the gap to being a sustainable and equitable organisation or region.

ii. Drivers, goals and objectives – where we want to get to

This section is about recognising a problem and the causes, and the costs and benefit of inaction versus cost and benefit of action. This section needs to enable understanding of why change is needed, and can include a vision for the future and the local benefits and costs that accrue from this. It should include consideration of co-benefits and show how climate action can be used to further wider outcomes and objectives including improved biodiversity, access to green space, reduced inequalities and improved health and wellbeing, etc.

• Drivers for developing the plan (corporate and area-wide aspects)
• Goals and objectives (corporate and area-wide, high level, outlining what success looks like), covering:
  • mitigation – key goals and objectives, including wider linked objectives, e.g. improved air quality, improved health and wellbeing, etc.
  • adaptation – key goals and objectives, contribution to delivering the Scottish National Adaptation Plan (SNAP), wider linked objectives
  • acting sustainably – key goals, objectives and outcomes, links to national priorities, National Performance Framework outcomes and UN SDGs.

iii. Impact assessments

Note the impact assessments, such as EQIA and FSDA, that have been carried out in relation to the this plan or plans, and explain how feedback from the assessments was taken into account as the plans developed. Where copies of the impact assessments or related information are available publicly, provide links.

• iv. Planned reviews and updates

Briefly note how often this plan will be reviewed and by whom, and note the frequency of any official update cycle. The review and update frequency is likely to vary depending on how the LA structures its plan or plans. For example, if the overarching CCP contains a net zero target of 2045 this is unlikely to require regular review, however the supporting route maps and action plans on how to achieve this target will need to be reviewed on at least an annual basis, potentially more frequently.

Note where the CCP will be published or made available. It is recommended that, as best practice, LAs should make their high level plans publicly available. The supporting detailed action plans and risk assessments, etc., may contain more sensitive information, and it is for individual LAs to decide whether and how they wish to share these. LAs are encouraged, in the interests of transparency, to make information publicly available where it is appropriate to do so.

3. Boundaries

In this section, LAs should describe which assets and activities are included in their CCP in a transparent way. Any exclusions should be noted, along with a reason for this. Refer to section 8.3.2 in the guidance.
This section of the template will be updated as the Improvement Plan related to the Environmental Standards Scotland investigation progresses through the Parliamentary process. The template will be updated to align with the agreed actions, specifically in relation to the reporting of scope 3 emissions.

• Corporate boundaries – the LA should describe how their boundary has been set, the approach taken and why; list which assets, infrastructure and activities have been included; and note and explain any exclusions. The boundary (assets, land and activities) is reasonably expected to include the built estate including street lighting, landholdings, fleet and business travel, corporate waste, staff commuting and homeworking, and procurement. Section 8.3.5.1 of the guidance outlines the ‘baseline’ emission categories LAs are, as best practice, expected to include in their boundary and reporting on mitigation.
• Area wide boundaries – the geographical boundary (land and sea), and within that the sectors, sources and activities that are included. Content should follow the guidance that will be developed by SCIS. Over the coming 12-18 months, a standard approach to area-wide boundary and target setting, planning and reporting for mitigation will be developed in partnership with SCIS. Boundaries for adaptation may be different from those for mitigation and may be at a regional level.

LAs typically own other assets, such as social housing, and provide services such as municipal waste treatment. Given that these are not under the direct control of the council (for example in terms of how much energy a household uses, or how much waste it produces) it is suggested that these be included within the boundary for the area-wide plan rather than the corporate plan – noting that the approach to these wider assets and services is to be developed in partnership with the SCIS, to ensure a consistent approach is taken by all LAs.

4. Targets

In this section, LAs should detail out their climate change targets and how these align with and support other strategic priorities. While such targets should include those related to emissions reduction, adaptation and acting sustainably, they could also include broader targets related to, for example, skills and capacity building. Refer to section 5.4.4 and section 6.4.6 of the guidance.

i. Corporate targets

Corporate emission reduction targets

There are various national policy targets and ambitions in place, for example around heat in buildings, fleet decarbonisation and the circular economy. When setting their corporate targets LAs should, as best practice, align to these; and could show greater ambition where this is felt to be achievable.

Corporate emission reduction targets should include, as best practice and where relevant:

• an overall net zero target for scopes 1 and 2 (or separate targets covering both scopes) of no later than 2045, earlier where possible. Where a target lies far off (such as 2045), bodies are encouraged to consider ways to help ensure they stay on track such as setting milestones
• individual targets covering zero direct emissions from cooking and heating, zero direct emissions from road fleet vehicles (LAs may find it appropriate to have separate targets for cars, LCVs, HGVs, etc.) and zero direct emissions from the ferry fleet
• targets related to land use and land use change, in particular where land based emissions, such as those from degraded peatland, are a source of direct scope 1 emissions
• targets covering other direct emissions, e.g. from use of machinery
• targets covering waste, e.g. waste to landfill, recycling rates, circular economy
• targets related to procurement
• targets related to other sources of indirect emissions, such as business travel, car kilometres travelled, etc.

Further guidance can be found in section 5.4.4.

Corporate adaptation targets

LAs have a statutory duty to help deliver the Scottish National Adaptation Plan. SNAP3 has five long-term outcomes and 23 objectives. SNAP3 objectives relating directly to LAs’ corporate adaptation include:

• Objective PS1: “Providers of public services have the governance, culture, skills and resources for and are collaborating in effective and inclusive adaptation action.”
• Objective PS2: “People can access the public services they need; and critical assets, systems and networks are resilient to the impacts of the changing climate.”

LAs may consider it appropriate to report on progress against a mix of outcomes and quantitative targets. These could relate to both hard measures or softer measures such as community resilience building. Further guidance and resources are provided by Adaptation Scotland.

Corporate sustainability targets

To act in the most sustainable way, LAs should ensure that sustainable development principles are built into their decision-making process (refer to section 7.4 of the guidance). LAs may consider it appropriate to report on progress towards sustainability outcomes, similar to the approach to adaptation outlined above.

ii. Area wide targets

Area wide emission reduction targets

Content should follow the guidance that will be developed by SCIS and shared over the coming months.

As best practice, LAs are encouraged to aim for net zero on an area wide basis by 2045, in line with the Scottish national target. LAs are encouraged to consider milestones, where the overall date lies far off, to help ensure that they stay on track.

Area wide adaptation targets

LAs need to consider carefully what adaptation outcomes, targets and metrics are appropriate to their region, communities and the climate-related risks and opportunities that they face.

LAs have a statutory duty to act in the way best calculated to help deliver the Scottish National Adaptation Plan. SNAP3 has five long-term outcomes and 23 objectives. Depending on context, all of the SNAP3 objectives could relate directly to area wide adaptation. LAs must consider the SNAP3 objectives they can help to deliver, including though place-based action and participation in regional collaborations.

LAs may consider it appropriate to report on progress against a mix of outcomes and quantitative targets.

Area wide sustainability targets

LAs need to consider carefully what sustainability outcomes, targets and metrics are appropriate to their region and communities. They may consider it appropriate to report on progress against a mix of outcomes and quantitative targets.

5. Leadership and Governance

i. Roles and responsibilities

In this section, LAs should clearly lay out the roles and responsibilities in relation to delivering their CCP. This should include detailing the responsibilities assigned to individual roles and teams, and include an overview of the governance structure and risk management, including relevant Boards. LAs may find it helpful to illustrate this section with an organogram. Refer to section 4.3 of the guidance.

ii. Mainstreaming

It is essential that climate change and sustainability is embedded throughout the work of the LA. This section should include consideration of the climate change duties when exercising functions; integration of climate change and sustainability into development, planning and decision-making processes; and reporting on progress. LAs should outline the processes and structures which ensure climate and sustainability are embedded across all business areas.

The LA could also describe organisational culture, and related aspects such as leadership, training, performance management and objectives, and staff engagement and communications.

Refer to section 4.4 in the guidance above.

iii. Climate considerations in decision making

In this section, LAs should provide more detail around how climate and sustainability are taken into account in the decision-making process. They should note specific tools, impact assessments and or methodologies that are used, and for what types of decisions.

In particular in relation to major financial and policy decisions, LAs should outline the methodology they employ, for example SEA, other impact assessments, carbon budgets, assessment of whole life carbon and carbon costs in business cases or options appraisal, and so on. Refer to section 2.2 and section 4.5 of the guidance.

6. Functions and wider influence

Through their varied functions and influence, LAs can have a wide and significant influence on emissions and climate action far beyond their organisational boundaries. This section should identify these functions and influence, and briefly describe how the LA is, and will, help drive climate and sustainability action more broadly.

Such functions and influence for LAs will typically include: spatial and transport planning, service delivery, place-making, investment, infrastructure development, economic development, funding, regulation, communications, education, community development, and partnership development and facilitation.

Refer to section 4.6 and section 5.5 of the guidance.

7. Quality assurance and audit

It is important that LAs’ climate action is subject to the same robust scrutiny as, for example, their financial management. LAs should briefly describe their quality assurance processes and internal audit mechanisms. They could also consider external verification or audit in relation to their climate action. It is likely that different processes will be required in relation to corporate and area-wide climate actions. Refer to section 4.7 of the guidance.

8. Monitoring and reporting

In line with the necessity to mainstream climate and sustainability action within the organisation, reporting on these should be embedded in the standard corporate reporting structure (noting that reporting on corporate and area wide climate actions should be kept separate).

This section should briefly describe how performance towards agreed mitigation, adaptation and sustainability targets and outcomes is reviewed and assessed, for example via regular Board meetings and use of KPIs, interim targets and short-term indicators. It should include the processes or actions that will be taken forward if progress falls off track and detail where the information can be found, e.g. in corporate reports, and include links to the webpages.

Any related statutory reporting, including the public bodies climate change duties reporting, biodiversity duty reporting and social housing reporting (EESSH or its successor), should be briefly described and links provided.
Refer to chapter 8 of the guidance.

Reducing emissions (mitigation)

9. Corporate emission reductions

In sections 3 and 4.1 above, LAs will have defined their corporate boundary and laid out their emission reductions targets. Here, further detail should be provided around how the targets will be achieved. LAs should develop route maps and action plans as laid out in chapter 5 of the guidance. The route maps and plans should demonstrate, clearly and quantifiably, how actions and measures have been assessed in terms of their contribution to meeting targets. The action plans in particular are likely to be separate documents, and should detail out interim steps, costs, timescales and dependencies.

Where the route maps and action plans are separate to this document and are publicly available, links should be provided.

Where the information is contained within another strategy or plan, such as LHEES or heat network plans, LAs should summarise the information briefly here, and provide links to these separate documents or webpages.

More detailed guidance on the measures that LAs can take, for example to decarbonise the heating in buildings or to develop a sustainable travel plan, is provided in the topic supplements which will accompany this guidance. These supplements, listed in section 1.4 of the guidance, will be available to view and download from the Scottish Government website.

10. Area wide emission reductions

In sections 3 and 4.2 above, LAs will have defined their area wide boundary and laid out their area wide emission reductions targets. Here, they should outline as a high level summary only, how these targets will be achieved. The route maps and plans should demonstrate, clearly and quantifiably, how actions and measures have been assessed in terms of their contribution to meeting targets. Refer to section 5.4.3 and section 5.5 of the guidance.

Where route maps and action plans are separate documents and are publicly available, links should be provided.

LAs should note where detail is provided in other strategies and plans, such as LHEES, heat networks and local housing plans, and provide links to these separate documents or webpages.

Content should follow the guidance that will be developed by SCIS.

It is the intention that, through the SCIS, area wide emissions information will be publicly available via the data platform, ClimateView. The ClimateView platform provides public-facing dashboards that illustrate policies, planned actions and expected emission reductions, and will in effect become ‘live’ area wide net zero plans.

Adaptation

11. Corporate adaptation

In sections 3 and 4.1 above, LAs will have defined their corporate boundary and laid out their adaptation targets and or outcomes. Here, further detail should be provided around how those targets and or outcomes will be achieved. It is expected that LAs will undertake climate risk assessments and develop and implement an adaptation plan in line with the SNAP, as outlined in chapter 6. of the guidance. These plans should show a clear pathway towards meeting organisational outcomes and targets.

Where these are separate to this document and are publicly available, links should be provided.

More detailed guidance on the measures that LAs can take, for example to develop nature-based solutions or adapt buildings to the changing climate, is provided in the topic supplements which will accompany this guidance.

These supplements, listed in section 1.4 of the guidance, will be available to view and download from the Scottish Government website in due course
Resources and support in relation to adaptation planning and action are provided by Adaptation Scotland.

12. Area wide adaptation

In sections 3 and 4.2 above, LAs will have defined their area wide or regional boundary and laid out their adaptation targets and or outcomes. Here, they should lay out in more detail how those targets and outcomes will be achieved. These plans should show a clear pathway towards meeting area wide outcomes and targets.

SNAP3 objective C1 is that: “Regional collaborations are driving inclusive, effective and place-based adaptation action across all of Scotland”. SNAP3 proposes that action at a regional scale includes collaborating on regional risk and opportunity assessment, adaptation priority setting, and long-term planning and investment; taking a place-based approach and including diverse communities as part of action to reduce inequalities.

Resources and support in relation to adaptation planning and action are provided by Adaptation Scotland.

The SCIS will focus on emission reductions. While it is possible that, in the long term, the remit of the SCIS may extend to include adaptation, there are currently no plans for it to do so. LAs should not delay area wide adaptation planning and action based on this expectation.

Acting in the most sustainable way

13. Corporate sustainability

In sections 3 and 4.1 above, LAs will have defined their corporate boundary and laid out their corporate sustainability targets and or outcomes. Here, they should lay out in more detail how those targets and or outcomes will be achieved. These plans should show a clear pathway towards meeting organisational outcomes and targets.

LAs are likely to have some sustainability plans already in place, for example in relation to food, procurement and learning settings. There is no need to duplicate details here: such plans can be briefly referenced in this section, and links to the individual documents or webpages provided.

More detailed guidance on the measures that LAs can take is provided in the topic supplements which will accompany this guidance. These supplements, listed in section 1.4, will be available to view and download from the Scottish Government website in due course.

14. Area wide sustainability

In sections 3 and 4.2 above, LAs will have defined their area-wide boundary and laid out their area-wide sustainability targets and or outcomes. Here, they should lay out in more detail how those targets and or outcomes will be achieved. These plans should show a clear pathway towards meeting area wide outcomes and targets.