The role of public sector bodies in tackling climate change: consultation analysis

Appendix B: Additional Comments

Question 1

Wider Comments on Guidance

A number of other areas were identified where public sector bodies might require further guidance and support, including:

• How to determine key emission intensive areas, how to baseline and prioritise, and how to identify and tackle barriers to achieving targets.
• Enabling public sector bodies to work with each other and with communities.
• Guidance should support approaches that enable the collection and use of data to deliver the net zero target, and set out procedures for data sharing between public bodies.
• Any update to the guidance should be "island proofed".
• How to deal with environmental issues relating to out-sourced contractors (e.g. to ensure contracts cover sustainability and environmentally-friendly practices).
• Best waste management practice in the workplace.
• Support and guidance could be re-established similar to previous services provided by Resource Efficient Scotland (RES) and The Carbon Trust (e.g. support for feasibility studies and staff training).
• The recommended skill requirement for different staff roles, and scope to share resources or specialist skills where these might not be needed for every public sector body.
• Guidance should be developed for major public sector investments and projects to scale up investment opportunities.
• Guidance should look at opportunities to minimise the overall cost of delivering the 2045 target.
• Emissions data at Scottish and UK-wide levels indicate that the transport, agriculture and related land uses, business/industry, residential and energy supply sectors continue to be the largest sources of carbon emissions. While it was reported that Government programmes will address some or all of these sectors in some way, it would be helpful to have further guidance/advice. This includes: on the type of actions across each sector which would reduce emissions; how these can be delivered; by whom; and level of investment required and/or subsidy available to assist.

• Potential for carbon management through changing land use on the public sector estate was said to be rapidly increasing in prominence. Guidelines would be welcomed on how to weigh this up against other requirements from policy and legislation.
• Guidance on a consistent approach for how public sector bodies engage with current levels of activism (e.g. Climate Strikes).
• For major public sector investments and projects, including public events (sporting, cultural and civil events), and major national infrastructure developments.

Question 3

More specific comments provided on the proposal that public sector bodies should be required to set targets for when they will achieve zero direct emissions, and for reduced indirect emissions:

• Further clarity would be required on what is expected of public sector bodies and clear definitions/explanations provided on terminology to avoid any confusion and ensure a consistent methodology for target setting. Specific reference was made to the terms: 'direct emissions', 'indirect emissions', 'net-zero', 'absolute zero' 'off-setting', 'sequestration', 'carbon neutrality'.
• A set of meaningful and consistent metrics would need to be developed and guidance provided in terms of what should be included and excluded in the targets to ensure consistency and validity of approach (e.g. type and source of emissions, off-setting and sequestration were specifically mentioned).
• Clear advice should be given on target scope (e.g. scopes 1, 2 and 3) and support given on how these should be assessed and reported on.
• Clarification on the relationship and interdependencies involved in net-zero organisational targets and net-zero national targets, and when using a targets-based approach factors that need to be considered include plans for such targets being well-informed and based on agreed international professional reporting standards.
• Net-zero would provide a consistent target for all organisations to work towards - boundaries of what should to be included by each organisation (direct and indirect emissions) should be made clear from the outset. It was further reported that technology, collaboration and resources would influence when timescales could be met, and support to facilitate and encourage these functions would be welcomed.
• Organisational target setting should continue to be supported by national/international sector-based guidance that ensures a clear understanding of how to set (and monitor) meaningful targets using an agreed indicator set. Guidance should build on existing approaches that have been used by public sector bodies to allow for national monitoring of progress towards achieving the national net zero target.
• Support to create carbon management plans, including methods for including off-setting and sequestration.
• Clarity on the monitoring and reporting requirements, and provisions for the independent verification of emissions data against targets.
• That an appropriate auditing regime would need to be put in place to ensure that emissions have been calculated correctly and accurately.
• Some respondents identified that additional training would be required to help public sector bodies accurately calculate emissions, particularly indirect emissions, and for setting informed/realistic dates for achieving targets (e.g. carbon accountancy training).
• Examples of best and innovative practice, as well as opportunities to learn from other organisations (e.g. online forums, documenting best practice, sharing of experiences and innovative solutions) could be provided. Plus signposting to national programmes and initiatives that could support the transition.
• Further work would be required to look at interdependent issues such as the climate emergency, ecological emergency, conserving and enhancing biodiversity, and climate adaptation - providing guidance, tools and techniques to enable effective action at a local level that contributes to national and global targets.

Question 8

The following largely individual points were raised by respondents to Question 8 within the consultation document. The main themes were presented in the main report:

• Public bodies should also be reporting action to maintain carbon storage and improve potential for carbon sequestration on their landholdings or if they have invested in offsetting schemes. There should also be space to highlight climate change action/innovation.
• Information about how Public Sector Bodies plan to implement an Environmental Management System or if they have one already, how that operates (could be incorporated in to 4f). Information on the (at least one) designated individual who is solely responsible for sustainability in the workplace.
• How many sustainability/environmental staff employed expressed as a % of turnover, utility spend and per Full Time Equivalent (FTE) student number.
• Carbon capture targets could be reported.
• In view of the importance, for other departments, of the work of one department, departments should be required to report on liaisons they have had with others, to achieve more climate change benefit. I have mentioned transport in relation to health and to land use and planning.
• All emission sources should be identified and each public body should have to report on these.
• Sign off on all reports should be taken at the Chief Executive level in all organisations to reflect the importance of this issue and to ensure that Chief Executives are aware of the climate change work of the organisations they lead.
• There could be an opportunity to reflect the importance of the civic leadership role local authorities have within communities and the opportunities to work with other key stakeholders.
• With regards to travel this currently only allows you to put in miles rather than the amount of fuel used, which is a better proxy.
• A section where the public sector body can include additional information they feel is relevant to the achievement of net zero emissions but not captured elsewhere within the report, such as the number of electric vehicles within the fleet and use of technologies such as heat pumps.
• Additional reporting requirement on staff training, Reports should therefore identify what training is being done, targets for this, and the number and percentage of staff participating.
• We welcome the proposed changes to the Adaptation section, to introduce a structure that will focus responses. The weakness of this section currently is that it is anecdotal and does not give a clear indication of progress from year to year. We therefore also welcome Adaptation Scotland's Benchmarking Tool, which is a companion to the Adaptation Capability Framework, for which HES and other public bodies supported through an the Expert Working Group. The tool allows organisations to measure progress and compare theirs to that of other bodies.
• Changes in practice or improvements to infrastructure. To this end, the report will need to capture information about how individual organisations are addressing this, and section 3 of the report would be the most appropriate area to include this.
• A consideration of Island proofing, and where legislation may effect Islands differently. For example, reliance on ferries (currently diesel) and air travel means there are some restrictions to change for islanders.
• A report of grant funding received or investment made for certain projects and initiatives to help demonstrate the value and return on investment (in terms of sustainability benefits and finance).
• Infrastructure risk from climate change, such as the effect of sea level rise on coastal and road flooding, should be considered under a standard approach.
• A supported peer review process. This would include training (which could be part of the "Climate Solutions" qualification.
• Reporting of indicators is needed.
• Reporting does not consider how to deal with structural and organizational changes in PBs. What happens with divestment and outsourcing? E.g. if a school becomes an academy? Is this still considered part of the carbon neutral regime or is it carbon leakage?
• Consideration should be given to requesting that Public Sector Bodies authorise their utility suppliers and meter operators to issue their data directly to Scottish Government's reporting scheme administrator / contractor.
• There needs to be a greater focus on indirect emissions throughout the reporting.
• Consideration could be given to 'softer' climate related outputs/actions that are aimed at reducing emissions. This could include communication campaigns, behaviour change, educational work and stakeholder engagement.
• There are some major areas where urgent changes are needed, particularly in ensuring that infrastructural projects such as schools, hospitals, offices and housing intended to be operational through to 2045 and beyond are designed and constructed to utilise the best available (affordable with life cycle analysis) technology for energy efficiency and renewable energy generation. There should be specific reporting on the progress achieved in this direction.
• We find the general approach taken rather vague and intangible. We would prefer an approach which set out rather more concrete items on which Public Bodies should report. In the area of transport, this would include:
  • Travel Planning. Whether Public Bodies have adopted Travel Plans, and whether they have effective monitoring in place. Public Bodies should as part of their Travel Plans quantify business travel emissions and should estimate emissions generated by commuter travel.
  • Low Emission Vehicles: Whether Public Bodies are making progress in decarbonising their vehicle fleets.
  • Travel to London: Whether Public Bodies are using rail rather than air for travel from Scotland to London (in particular Edinburgh-London and Glasgow-London).
• We recommend that these items be included in the Statutory Guidance.
• It may be useful to revise the procurement section to gather more useful data to better understand how it might contribute to decarbonisation.