A Consultation on "The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015": Analysis of Responses

2. Introduction

Background

2.1. On 20 February 2015 the Scottish Government (SG) published a consultation on its proposals to introduce a requirement for climate change reporting under the climate change public bodies duties. The overall aim of the proposal is to improve the quality and consistency of climate change information reported across the public sector in Scotland.

2.2. General purpose: The main reasons for using the powers in the Climate Change (Scotland) Act 2009 ('the Act') to introduce a statutory reporting requirement are to: support compliance with the public bodies duties; consolidate climate change information from the public sector; introduce standard methodology to improve data consistency; encourage continuous improvement and transparency; improve board engagement and leadership action; and inform Scottish Government strategic reporting and future policy/support.

2.3. Consultation aim: To consult on the Scottish Government proposals to make an order under section 46 of the Climate Change (Scotland) Act 2009 requiring specified public bodies, described as 'major players', to prepare annual reports on compliance with climate change duties. The order will set out the public bodies involved, the form of these reports and the information to be included.

Consultation Process

2.4. The consultation ran for a period of 14 weeks from 20 February to 29 May 2015.

2.5. The key proposals upon which views were sought relate to the following areas:

• The draft statutory instrument outlining the policy proposals.
• The public sector major players list. (Schedule 1).
• The public bodies duties climate change reporting form. (Schedule 2).

2.6. The Scottish Government sought views on the proposed introduction of a statutory requirement on specified public bodies to report compliance on the climate change public bodies duties. Views were also sought on the impact of the changes in reporting climate change progress and activity, including any concerns. The consultation also invited views on how the climate change reports should be validated, analysed and monitored in the future.

2.7. The consultation was launched on the Scottish Government "Citizen Space" (CS) on-line portal. A dedicated consultation questionnaire asked fourteen relevant questions about the policy proposals, with a fifteenth question inviting any other comments. The consultation questionnaire was optional for respondents to complete. Several respondents did not use the portal to record their views, however to enable these views to be taken into account during the analysis process, these responses were uploaded onto the CS platform by officials for completeness.

2.8. The consultation was promoted directly to stakeholders and more generally through the following media options:

• SG Citizen Space portal and SG consultation webpage.
• SG consultation update service.
• SG News Release.
• Public Bodies weekly bulletin.
• All 150 major players notified via practitioner contacts or sector associations.
• SSN newsletter article and update.
• Ministerial speeches at public sector events.
• Climate Change Director / Executive strategy meetings.
• SSN and Resource Efficient Scotland (RES) Conference and training events.

2.9. SSN also organised a stakeholder event, held in March 2015, which informed its response to this consultation.

Profile of Respondents

2.10. A total of 73 responses were received: 51 were from organisations and 22 were from individual members of the public. For the purposes of the analysis, the organisation respondents have been classified in 6 categories: public sector organisations including NHS organisations (19 responses); Local Government including the Convention of Scottish Local Authorities (COSLA) (17 responses); education and research bodies (6 responses); third sector and environmental NGOs (6 responses); and other miscellaneous groups (3 responses) comprising a community planning monitoring group, an environmental consultancy and a trade union. This breakdown is shown below.

Table 1: Breakdown of Consultation Respondents

Respondent Type	Number of Responses	% of Total
Organisations	51	70%
Public Bodies (see below)	19	26%
Local government	17	23%
Education / research institution	6	8%
Third sector / NGO	6	8%
Other - misc	3	4%
Organisations sub-total	51	70%
Individuals	22	30%
Total Responses	73	100%

Public Bodies includes Executive Agencies, Non-Departmental Public Bodies, NHS, etc

all percentages are rounded

2.11. For the purpose of the analysis, organisation respondents were also categorised according to whether or not they were 'major players', which would be required to report under the proposed statutory requirements. A breakdown of this categorisation is shown below.

Table 2: Breakdown of Consultation Respondents by Major Player Status

Respondent Type	Major Player?
	yes	no	Total
Organisations	34	17	51
Public Bodies (see below)	16	3	19
Local government	16	1	17
Education / research institution	3	3	6
Third sector / NGO	0	6	6
Other - misc	0	3	3
Organisations sub-total	35	16	51
Individuals	0	22	22
Total Responses	34	39	73
Organisations - % breakdown	67%	33%	100%
Individuals - % breakdown	0%	100%	100%
Total - % breakdown	47%	53%	100%

Public Bodies includes Executive Agencies, Non-Departmental Public Bodies, NHS, etc

all percentages are rounded

2.12. It is important to note that, while a number of responding organisations are not themselves major players, they represent or speak on behalf of organisations which are. For example:

• Local Government: COSLA is not itself a major player, but acts as the national voice for the majority of Local Authorities in Scotland, which are major players. 14 Local Authorities submitted separate responses.
• NHS: the NHS Scotland Sustainability Steering Group (NSSG) is not itself a major player, but it represents all 22 NHS Scotland Boards across all areas of sustainability, including climate change and associated public sector duties. Its response was discussed and ratified by an NSSG meeting and none of the NHS Boards submitted separate responses.
• Education and research sector: 3 out of the 6 responses from this sector were from sectoral organisations which are not themselves major players but which represent education institutions, or staff working in them, which are. These 3 sectoral organisations are the Environmental Association for Universities and Colleges (EAUC), Advanced Procurement for Universities & Colleges (APUC) and Scottish Association of University Directors of Estate (SAUDE).

2.13. This issue was taken into account during the analysis of responses.

2.14. A full list of respondents, including their major player status, is shown in Annex A.

Data Analysis

2.15. 7 out of the 15 questions included a 'closed' element, asking 'Yes/No' questions or inviting respondents to select from one of a limited range of options. Results from responses to these closed questions are presented in tables.

2.16. 8 out of the 15 questions were 'open', inviting free text narrative responses. These responses have been analysed qualitatively to identify common themes and issues, a number of which featured in response to more than one question. In these cases they are discussed in detail under the most directly relevant consultation question, and other questions featuring the same theme cross-refer to those questions. The 7 'closed' questions also invited additional narrative responses, and these have also been analysed qualitatively.

2.17. For some of the open questions it was possible to code the qualitative analysis of free text responses in order to develop a quantitative breakdown of responses. These analyses are also presented in tables.

2.18. A small number of respondents did not make their submission in the consultation questionnaire, but submitted comments in a free-text or statement-style format. This content was analysed qualitatively under the most directly relevant consultation question.

2.19. Several respondents made points about religion, marriage, health, banking, world debt and defence policy. While such views were considered in the analysis, only views relevant to the specific policy proposal or to the wider climate change context were taken into account for this report.

Presentation of the Findings

2.20. The consultation findings are presented for each question, according to the order in which the questions were asked in the consultation.