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

4 Views on the Overarching Framework

4.1 This chapter presents an analysis of respondents' views on the overarching framework for the Programme. The consultation included two questions about the framework:

Question 1a: To what extent does the overarching framework of the Programme set an appropriate long term direction for climate change adaptation in Scotland?

Question 1b: Does the overarching framework address the current and predicted impacts to Scotland identified in the UK Climate Change Risk Assessment?

Appropriateness of the overarching framework

4.2 Fifty-four (54) respondents answered Question 1a. Of these, 43 (80%) thought that the overarching framework either "fully" or "mostly" set an appropriate long term direction for climate change adaptation in Scotland, while 11 (21%) thought it only "partially" or "poorly" did so. (Table 4.1.) The latter group included four of the 10 non-governmental organisations (NGOs).

Table 4.1: Question 1a - To what extent does the overarching framework of the Programme set an appropriate long term direction for climate change adaptation in Scotland?

* Percentages do not total 100% due to rounding.

4.3 Fifty-seven (57) respondents (81% of all respondents) provided comments in relation to Question 1a.^[4] Those who thought the programme was generally appropriate described it as "comprehensive", "balanced" and "flexible enough to cover a wide range of eventualities" as additional risks are identified over time. The thematic approach set out in the Programme was seen to be preferable to the sectoral approach previously used, and the "shift from being responsive to being anticipatory and pre-emptive" was also welcomed.

Those who thought the framework was less well equipped to meet the Programme's objectives described certain objectives (and policies) in the Programme as "vague" and asked for details about priorities and timescales. This group commented that the Programme appeared in some cases to be more "reactive than proactive", and to be "applying remedial approaches to current practices", rather than adopting a long term, principled approach required for adaptation. These respondents also wanted the Programme to communicate a greater sense of urgency and a call for action.

Specific suggested improvements

4.4 There were a range of suggestions about how the framework could be improved. Most of these concerned requests for clarification in relation to: the responsibility for delivery of the Programme; the role of local authorities in particular; the links between themes; and the arrangements for monitoring. All of these issues have been discussed in Chapter 3 and so will not be repeated here.

4.5 Additional points raised by a range of respondents included:

• Economic impacts: Respondents commented that the Programme did not sufficiently address the potential impacts of climate change on businesses and services.
• The role of the private sector: Respondents thought that in order for the Programme to set an appropriate long term direction, it should indicate how the private sector would be influenced to act in relation to adaptation. This was perceived to be a gap.

Extent to which the overarching framework addresses the impacts in the UK CCRA

4.6 Forty-nine (49) respondents answered Question 1b. Of these, 34 (69%) thought that the overarching framework either "fully" or "mostly" addressed the impacts to Scotland identified in the UK CCRA, while 15 (31%) thought they only "partially" or "poorly" did so. (Table 4.2.) A substantial proportion of the local authority respondents (8 out of 21) thought the framework only "partially" addressed the current and predicted impacts set out in the UK CCRA.

Table 4.2: Question 1b - Does the overarching framework address the current and predicted impacts to Scotland identified in the UK Climate Change Risk Assessment?

4.7 Forty-three (43) respondents (64% of all respondents) made comments in relation to Question 1b. The most common point made by respondents was that it would be helpful for the Programme to clarify which aspects of the UK CCRA fell under each of the three themes in the Programme.

4.8 Respondents also noted that the UK CCRA does not cover all climate change risks for Scotland. For example, it does not include risks to all of Scotland's species. In addition, the risks to Scottish society were poorly specified in the UK CCRA because of a lack of data. Therefore, it was suggested that the Programme would be limited if it only focused on the risks and threats set out in the UK CCRA.

4.9 The point was also made that some risks appeared to be more comprehensively covered than others, but that the Programme had provided no explanation of why this was the case.

4.10 Respondents identified additional risks which they thought were not adequately addressed in the Programme. Many of these issues were also raised in comments made on each of the Programme's three themes, and so they are not discussed in detail here. Additional areas at risk identified by a range of respondents included:

• Energy supply
• Peatland degradation
• Coastal erosion and flooding
• Overheating and drought
• Economy (as noted in paragraph 4.5 above)