Consultation on the Draft Scottish Climate Change Adaption Programme: Analysis of Responses

3 Key Issues from the Consultation

3.1 This section summarises a number of key issues that were repeatedly raised by respondents across all questions in the consultation. The key issues were identified by respondents as areas for improvement in the Programme. These issues are discussed here, and are not repeated in Chapters 4, 5, 6 and 7.

General perceptions

3.2 Respondents generally welcomed the Programme and acknowledged the efforts of the Scottish Government in creating a "comprehensive" and "coherent" framework to focus the work of adaptation. However, it was also common for respondents to describe particular aspects of the Programme as "vague".

3.3 Respondents also thought that the focus on existing policies gave the impression that "there is not much new" in the Programme and that it did not add value to what was already happening. Respondents wanted to see a greater sense of urgency in the Programme and called for increased emphasis on "taking action" to balance the perceived over-emphasis in the Programme on improving knowledge and understanding.

Need for clarity about delivery mechanisms

3.4 Respondents repeatedly made the point that there is little information in the Programme about:

• How it will be delivered
• Who is responsible / accountable for delivery
• What the priorities and timescales will be
• What monitoring and reporting arrangements will be put in place
• What resources will be available

3.5 These issues were of particular concern to local authorities, NHS organisations and other organisations that have public body duties under Section 44 of the Climate Change (Scotland) Act 2009, but they were raised more generally by other respondents across all sectors too.

3.6 Respondents were not clear for whom the Programme was written. While it was recognised that the Scottish Government had a legal obligation to produce the Programme, they were not certain what action was required from stakeholders in response to it, and whether there would be any reporting requirements. Local authorities, in particular, wanted guidance about the implications for Single Outcome Agreements. Moreover, local authorities and NHS respondents were concerned that without more detail in the Programme, it would be difficult to secure support for investment from within their own organisations. There were also concerns about the lack of policies or proposals aimed at developing skills and capacity within public sector bodies.

3.7 These issues will be discussed in further detail in Chapter 8 of this report.

The role of local authorities

3.8 Local authorities generally thought that their role in the Programme was missing or understated. This was considered to be a significant omission, given the very wide range of issues at a local level that local authorities can influence.

Links between themes

3.9 Respondents commented that the Programme should adopt a holistic approach, and therefore it was important to make explicit the links that exist between the Programme's three themes in relation to issues such as:

• Green infrastructure, including urban drainage, shading of buildings and areas of natural flood management
• Integrated catchment management, including planning, flooding and water quality
• "Working with nature"- the role that the natural environment can play in supporting adaptation
• Improving community resilience through improved building standards and resilient energy, IT, water and transport infrastructures

3.10 Respondents' comments on these issues will be discussed in further detail in Chapters 4-6.

Clarify the links to other (external) policy areas and with adaptation

3.11 Respondents suggested that the Programme should also make links with other (external) policy areas. The two areas mentioned by a range of respondents were in relation to community empowerment and mitigation.

3.12 There were differing views about how the links to mitigation should be demonstrated in the Programme. Some respondents thought the Programme should highlight its links with the mitigation agenda - drawing out how certain policies were appropriate for both an adaptation framework and a mitigation framework. Others pointed out that some policies appeared to be more related to mitigation than adaptation, and these policies should either be removed or the link to adaptation made more explicit. Examples included, among others, the policies on:

• Farming for a Better Climate Programme (N3-21)
• Water Use Efficiency (B2-3)
• Energy efficiency (B2-6, B3-7, S2-3)
• Extend the requirement for sustainability labelling beyond schools to other non-domestic buildings (B2-23)
• Eradicate fuel poverty (S2-1)

3.13 This latter point was expressed in a more general way by other respondents, who thought that the Programme should clarify the relevance of certain policies to adaptation. Examples included, among others, the policies on:

• Land Use Strategy (N2-8)
• Scottish Biodiversity Strategy (N2-9)
• Marine planning (N2-13 and N2-14; B2-9, B2-10)
• Common Agricultural Policy (N3-1)
• Fishing and aquaculture (N3-14 and N3-15)
• Developing a greater understanding of food-borne disease related pathogens (S1-1)