Climate Change Committee's (CCC) annual progress report 2022 recommendations: SG response
Scottish Government's response to the Climate Change Committee’s December 2022 report on Scotland’s progress in reducing greenhouse gas emissions.
2. Response to CCC Recommendations
Cross-Cutting Recommendations
Number
1.
Recommendation
Increase transparency around Government's expected pathways to Net Zero. This should involve publishing more details on the assumptions that underpin these pathways and how the abatement set out in the Scottish Climate Change Plan update will be achieved by planned policies, setting out the quantified abatement expected to be achieved by each policy.
Response
Accept
The next Climate Change Plan, due in draft in November this year, will contain the costs and benefits of policies within the plan.
Our draft Energy Strategy and Just Transition Plan sets out a vision for a future net zero energy system. It has been informed by a programme of independent work and analysis (Project Ninian) to better understand our energy requirements as we transition to Net Zero.
Number
2.
Recommendation
Scale up action to deliver targets across all sectors in line with the ambition set out in the recent Climate Change Plan update.
Response
Accept
The Scottish Government has a legal obligation to deliver on climate change targets, and the law sets out what action is necessary if they are missed. The next Climate Change Plan, due in draft in November this year, will contain policies adequate to meet each target year from 2024 to 2040.
Number
3.
Recommendation
Map out interdependencies between reserved and devolved powers and how they might impact decarbonisation in all economic sectors and use the results to identify significant risks to the delivery of Net Zero and construct a plan to manage them.
Response
Partially accept
The Scottish Government remains determined to work closely and plan with the UK Government on these interdependencies with respect to climate change, but it requires active and sustained cooperation between all parties. As part of the draft Climate Change Plan, due November 2023, the SG will set out what emissions reductions require the exercise of UK Government powers and we will continue to work closely – and press the UK Government – on the exercise of the necessary powers.
Our draft Energy Strategy and Just Transition Plan sets out the actions where the UK Government needs to take action and work with Scottish Government under the current constitutional settlement to deliver Scotland’s full energy potential.
Number
4.
Recommendation
In parallel with the Convention of Scottish Local Authorities (COSLA), address the question of what aspects of Net Zero central and local government are responsible for and how these will be coordinated. As well as sharing local best practice, this should lead to a clearer shared understanding of roles and responsibilities which can be communicated across local government.
Response
Accept
The Scottish Government are bringing forward a draft of the next Climate Change Plan by November 2023 which will set clear asks for all of the main actors on delivering climate policy. In addition, we are working closely with COSLA and Local Authorities on the development of a framework to accelerate and coordinate joint action in support of this agenda, with a view to presenting this before the end of the year.
Number
5.
Recommendation
Ensure that all policies, funding, and delivery mechanisms are properly aligned to the pace of transition required and work together constructively towards Net Zero, for example through introduction of a Net Zero Test.
Response
Accept
The Joint Budget Review between Scottish Government and Scottish Parliament concluded in December 2022. The outcomes from this process included a strand of work to develop a net zero assessment for the policy-making process to assist in better alignment of policy, funding and delivery.
Number
6.
Recommendation
Extend the delivery of climate skills training across the Civil Service and wider public sector. Consider what wider supporting skills (delivery, coordination, legal, financial) will be needed in the public sector to enable effective delivery of the transition to Net Zero.
Response
Accept
The responses to Draft NPF4 called for a resource and skills strategy to be prepared. We will work with Partners in Planning (Home | Partners in Planning) to develop a skills strategy which will identify the specialist skills required to address the requirements of NPF4, and the wider skills required to ensure we have planners with the expertise to deliver on our ambitions for Scotland.
Number
7.
Recommendation
Review how effective existing mechanisms for coordinating delivery with the devolved administrations (including the Inter-Ministerial Group, the Nations Board, and departmental-level engagement) have been at securing input to the design of and buy-in to implementation of recent major strategies relating to Net Zero.
Response
Accept
For our part, the Scottish Government is committed to continuing our participative engagement with the Net Zero IMG and Net Zero Nations Board, and see this as a key vehicle for driving delivery that benefits all four nations. We will bring forward the suggestion of reviewing the existing mechanisms to the group, to secure better engagement in the future, and explore options to improve cooperation with our counterparts in the other governments of the UK. However, agreement would be needed from all governments in order for a review to take place.
Number
8.
Recommendation
Make clear the importance of ensuring that all developments consider how best to minimise lifetime emissions and adapt to climate change as part of the planning process. This should be achieved by embedding Net Zero alignment as a core requirement within the planning reforms in the upcoming Levelling Up and Regeneration Bill and the supporting frameworks and guidance documents.
Response
Partially accept (Complete).
National Planning 4 (NPF4) (now in effect) is applicable to the preparation of local development plans and decision making on individual planning applications across Scotland. NPF4 includes a cross-cutting outcome for reducing greenhouse gas emissions and is clear that the global climate emergency and nature crisis have formed the foundations of the spatial strategy as a whole. NPF4 policies 1 and 2 support spatial strategies and development that reduce greenhouse gas emissions and help places adapt to current and future risks from climate change, with significant weight to be given to the global climate and nature crises when considering all development proposals. Reforms to the planning system identified in the Levelling Up and Regeneration Bill and supporting frameworks and documents do not apply in Scotland as the planning system is fully devolved.
Number
9.
Recommendation
Work closely with the new Electricity Networks Commissioner to ensure that Scotland’s spatial planning regime adequately balances local impacts on natural capital with the need for sufficient electricity network capacity, delivered in a timely fashion, to accommodate expansion of renewable electricity generation capacity in line with UK Government targets and Scottish Government ambition.
Response
Accept
We are engaging with the Electricity Networks Commissioner’s ‘Consult and Review Group’ on the deployment of necessary electricity network infrastructure to support the expansion of renewables.
Decisions relating to electricity networks and generation capacity are taken through the Electricity Act (1989) and the Town and Country Planning (Scotland) Act 1997. Proposals requiring development consent will be made in consideration of Scotland’s plan led system, including the policies of National Planning Framework 4 (NPF4).
NPF4 signals a turning point for planning in Scotland, placing climate and nature at the centre of our planning system. It makes clear our support for all forms of renewable, low-carbon and zero emission technologies, including transmission and distribution infrastructure. Potential impacts on communities, nature and other receptors remain important considerations in the decision-making process. All applications are already, and will continue to be, subject to site-specific assessments.
We continue to work closely with stakeholders across Scotland’s planning system to improve consenting timescales for network infrastructure, and will consider any opportunities for improvements to consenting frameworks where it is possible to do so.
Number
10.
Recommendation
Publicly set targets to end the use of Metered Dose Inhalers (MDIs) for all patients where alternatives can be used, by the mid-2020s, for all NHS and private healthcare services across Scotland. For patients where MDIs are necessary, end the use of MDIs that use propellant gases with 100 year Global Warming Potentials above 200 times that of carbon dioxide. Publish a plan setting out how the Scottish Government will meet these targets.
Response
Partially accept
The NHS Scotland Climate Emergency and Sustainability Strategy states, we “aim to reduce our emissions from inhaler propellant by 70% by 2028. At that point, we will review progress before setting further targets for inhaler propellant emissions on the path to net-zero.” This target has been developed with clinicians, patients and asthma charities.
The Strategy also states that our approach will, “focus on improving patient outcomes, minimising over-use of reliever inhalers and supporting patients to use propellant free options where clinically appropriate. MDIs should only be used where they are clinically necessary.”
The Strategy states that, we will “closely follow progress by pharmaceutical companies in developing low emissions propellant for MDIs”. However, at this time metered dose inhalers with low global warming potentials are not available for clinical use. Their future availability is dependent on factors out with the Scottish Government’s control including regulatory approval by the Medicines and Healthcare products Regulatory Agency.
Buildings
Number
11.
Recommendation
Closely monitor the number of households in fuel poverty and expectations of future energy costs, and revise funding allocated to decarbonising fuel-poor homes to reflect levels of support required.
Response
Accept
The Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 sets out statutory targets in relation to the fuel poverty and extreme fuel poverty rates and the fuel poverty gap. These are monitored annually through the Scottish House Condition Survey (SHCS) and reported in the SHCS key findings report – a National Statistics publication.
Due to the impact of Covid-19 on the SHCS, the latest National Statistics on fuel poverty are for 2019. Given the rise in energy prices since 2019 and the clear policy need and public interest in updated fuel poverty estimates, we have undertaken and published scenario modelling to estimate levels of fuel poverty under various scenarios, and in particular under the Energy Price Guarantee from April 2023.
We also track and quantify the impact of the funded delivery schemes which are covered under Heat in Buildings.
Number
12.
Recommendation
Monitor the use of the £1.8 billion of funding for heat and energy efficiency projects, tracking the amounts spent on heat networks, heat pumps and energy efficiency measures and how these compare to the targets set in the Scotland Heat in Buildings Strategy for low-carbon heating and energy efficiency.
Response
Accept
We have set out allocations for large portions of the £1.8 billion budget and will increase detail on proposed spend in 2023. In 2023 we will also enhance our understanding of progress towards targets by putting in place improved systems for Monitoring and Evaluation.
Number
13.
Recommendation
Develop proposals for long term funding and financing solutions to deploy low-carbon heating in existing buildings, taking into account recommendations made by the Green Heat Finance Task Force
Response
Accept
We will consider the recommendations of the Green Heat Finance Task Force. We continue to call on the UK Government to consider, and work with us on, how funding/financing of energy efficiency, heat pumps and heat networks can be scaled up and put on a more sustainable footing to drive delivery over the longer term.
Number
14.
Recommendation
Ensure that local authorities have the resources required to produce Local Heat and Energy Efficiency Strategies and Delivery Plans, and that these are published by the December 2023 deadline. [Publish guidance on production and content]
Response
Accept
A Scottish Statutory Instrument was passed by the Scottish Parliament requiring all local authorities to publish Local Heat and Energy Efficiency Strategies and Delivery Plans (LHEES) by the end of 2023 and update them on a 5-year basis.The Scottish Government published guidance setting out what is required when developing an LHEES in October 2022.
Local authorities each receive multi-year funding, which has been agreed in partnership with COSLA, to resource the development of their LHEES.
Number
15.
Recommendation
Work with the UK Government to resolve issues around aligning the UK and Scotland’s regulatory frameworks for heat networks, and appointing Ofgem to deal with consumer protection and licensing.
Response
Accept
We continue to work to ensure that heat network regulation in Scotland is developed in a manner which properly considers and is informed by counterpart regulatory frameworks as developed by UK Government and mindful of the role that Ofgem and others will play in our own framework. Consequently, our ability to realise this recommendation will not be limited by our determination to work together, but the willingness of the UK parties to support that joint working.
Number
16.
Recommendation
Work with the UK Government in 2023 to deliver proposals set out in the Scottish Heat in Buildings Strategy to phase out replacement fossil fuel boilers in 2025 for off-gas buildings, and 2030 for on-gas buildings.
Response
Accept
We are committed to phasing out the need to install new or replacement fossil fuel boilers and to requiring improvements in the energy efficiency of Scotland’s building stock from 2025. We are engaging with UK Government to understand all aspects of its approach to zero emission heating. As the UK Government has key powers here, it is vital that active cooperation from the UK Government meets the Scottish Government’s commitment in this area.
Number
17.
Recommendation
Table legislation to prohibit the use of ‘direct emissions heating systems’ from 2024 in new residential and non-residential buildings, building on the 2022 consultation.
Response
Accept:
On 8 June 2023, Scottish Ministers laid the Building (Scotland) Amendment Regulations 2023. If passed, the new regulations will ensure that all new buildings, constructed under a building warrant applied for on or after 1 April 2024, will no longer be able to use highly-polluting direct emissions heating (DEH) systems. Instead, these new buildings will be required to use heating or cooling systems which produce zero or negligible levels of direct greenhouse gas emissions (at the point of use).
Number
18.
Recommendation
Coordinate with the UK Government to develop and implement proposals for a market-based mechanism for heat pump deployment. Evaluate the likely impact of this policy and if needed develop additional plans in to deliver heat pump installations at the rate required by Scotland’s Heat in Buildings Strategy.
Response
Partially accept
We are supportive of the UK Government’s proposed heat pump market mechanism, and look forward to working closely in developing the detail of the scheme before it is implemented.
We are engaging with UK Government to understand all aspects of its approach to zero emission heating and will, as part of this, consider the effects of any UK Government market-based mechanisms on our own programme and targets. As this is an area where the UK Government has significant powers, coordination must be a joint endeavour, with a shared sense of urgency and commitment.
Number
19.
Recommendation
Define clear transitional arrangements which will require any buildings (including individual houses in multiple-unit residential schemes) which have not meaningfully commenced on site within one year of the implementation of new regulations on energy efficiency and low-carbon heat to comply with the new standards.
Response
Partially accept
In Scotland, a building warrant must be applied for and granted before a developer can start construction. Any application made after the date regulations change is subject to those regulations. All work subject to a building warrant must be completed within three years of issue unless an application to extend the duration is made to the local authority. Assurance in Scotland is based upon completion, not commencement, of work on site.
We are devising a compliance and enforcement mechanism for existing buildings, matched to the requirements of forthcoming regulation of existing buildings (both domestic and non-domestic, and mixed use/ownership). These provisions will be phased in over time, and enforcement of them will mirror this.
Number
20.
Recommendation
Consult on and finalise plans for delivering energy efficiency improvements and low-carbon heating in non-residential buildings. These should include clear target dates for meeting standards. Consider the role of targets that look beyond EPCs to more reliable measures of performance and emissions reductions, and clarify whether Scotland will be part of the UK performance-based rating scheme for non-residential buildings.
Response
Accept
We aim to consult during 2023 on a Heat in Buildings Bill, which will include consultation on powers to develop and introduce strengthened regulation for non-domestic buildings, to ensure they reduce demand for heat where feasible and install a zero-direct emissions heating supply.
This follows our previous call for evidence looking at possible different approaches – a specified improvement measures-based approach, a minimum standards approach and an operational ratings approach (based on actual direct emissions).
Number
21.
Recommendation
Publish the delayed monitoring and evaluation framework for the Heat in Buildings Strategy or expand the set of indicators in the annual climate change plan monitoring reports. Include clear indicators for deployment of energy efficiency measures, heat pumps, and low-carbon district heating, across residential and non-residential buildings. Use the development of the framework to identify data gaps and make plans to address them. Track implementation and its costs and use this information in updates to the Strategy.
Response
Accept
We will publish a Monitoring and Evaluation framework in 2023 to help measure progress against our Heat in Buildings Strategy.
Number
22.
Recommendation
Publish more detail on the modelled pathway for low-carbon heat, and planned breakdown of funding announced in the Scotland Heat in Buildings Strategy.
Response
Accept
We have set out allocations for large portions of the £1.8 billion budget and will increase detail on proposed spend in 2023.
We will be reviewing our Heat in Buildings Strategy before end 2023 (and every two years). This process, as well as our wider monitoring and evaluation of the HiB programme will support on-going policy development.
Number
23.
Recommendation
Publish developed plans to deliver energy efficiency improvements and low-carbon heating in residential buildings, aligned with Scotland’s ambitious targets. This will require a combination of incentives and regulation, including using tenancy and ownership changes as trigger points for change. Policies should also factor in the UK Government’s proposals for a market-based mechanism for low-carbon heat.
Response
Accept
We aim to consult during 2023 on our proposed Heat in Buildings Bill from which, once passed, we will then be able to deliver the regulations which will contain and influence/reflect these aspects.
Number
24.
Recommendation
Consult on legislation to set low-carbon heating and energy efficiency targets in privately rented and owner-occupied homes.
Response
Accept
As above.
Number
25.
Recommendation
Complete the review of the Energy Efficiency Standard for Social Housing, assessing progress to date, and aligning with the 2040 target for low-carbon heat in homes.
Response
Accept
The review remains on track to be completed in 2023.
Number
26.
Recommendation
Progress with EPC reform by finalising proposals for improved metrics, and carrying out the planned final consultation within a wider consultation on a regulatory framework for heat and energy efficiency.
Response
Accept
Our Heat in Buildings Strategy set out plans to reform domestic EPCs as advised by the Climate Change Committee. Our proposed EPC reforms introduce a set of new metrics to provide a holistic picture of energy efficiency.
Our domestic EPC reform work also covers wider aspects including ensuring EPC audit and assurance procedures are fit for purpose and modernising the data platform that supports EPCs.
We consulted in Summer 2021 on a new domestic EPC metric based on the dwelling’s energy use. In August 2022 we responded to this consultation, setting out that following feedback received we will bring forward further proposals for EPC metrics alongside finalised plans for EPC reform in 2023.
Number
27.
Recommendation
Develop policies to ensure that the actual performance of new buildings and energy efficiency measures aligns with expectations. These should include improving the accuracy of the models used to assess compliance with standards, expanding performance testing, enhancing monitoring and enforcement of standards (including through providing adequate funding for local authorities), and developing mechanisms for holding contractors to account for quality and performance.
Response
Accept
Work under the Building Standards Futures Board, includes a ‘compliance plan’ approach which seeks to establish improved oversight and a more detailed evidence set from developers to demonstrate compliance within the building standards system. This will support improved outcomes including performance in practice and is a key element in the December 2022 commitment to further review to deliver ‘a Scottish equivalent to the Passivhaus Standard’ including laying of regulations by December 2024. Review will draw on current industry good practice and learning from established very low energy design and certification standards and current and future work on assessment methodologies.
Number
28.
Recommendation
Ensure that skills requirements for decarbonising the building stock are properly quantified, and that delivery can be monitored. Ensure that the required education and skills provisions commence, and that funding and policies are in place .for provision to scale up at the required pace.
Response
Partially accept
Our Heat in Buildings Supply Chains Delivery Plan, backed by a £17.6 million Green Heat Innovation Support Programme, sets out practical steps that we are taking to support the growth of the green heat sector.
The plan also includes our investment in a new mobile training centre for heat pump installation and launch a programme of engagement with installers in the heat and energy efficiency supply chain.
We are in the process of updating our Climate Emergency Skills Action Plan (CESAP), to ensure it remains in line with our economic and climate ambitions as outlined in the National Strategy for Economic Transformation. The Updated CESAP will ensure skills coordination across priority sectors and ensure that skills and education system as whole can adapt throughout the transition to Net Zero.
Work through already ongoing through CESAP includes, for example, a pathfinder project being progressed jointly by Skills Development Scotland (SDS) and the Scottish Funding Council (SFC) is exploring the demand for jobs and skills across decarbonisation of commercial and domestic heat in both Shetland and Glasgow and mapping against provision.
Transport
Number
29.
Recommendation
Consider the environmental impact of airport expansion under the upcoming Scotland National Planning Framework, including a strategy to limit airport expansion in the event that proposals to expand Scottish airports are submitted.
Response
Partially Accept
National Planning Framework 4 (NPF4) is now in effect. It states:
“Airports, ports and rail links will provide vital connections within Scotland and beyond which will be crucial to building on a sustainable recovery whilst helping to decarbonise transport through low and zero emissions technologies.” Spatial planning priorities for the ‘North’ area include that: “The Highlands and Islands are aiming to become the world’s first net zero aviation region by 2040 by pioneering new approaches including electric aircraft. Investment in technology and facilities will be required to achieve this.”
We do not anticipate any proposals being made in the short term that would significantly expand Scottish airports.
Number
30.
Recommendation
Implement the Air Departure Tax (ADT) as soon as possible. Once implemented, use the tax to address price imbalances between aviation and alternative, lower-emissions forms of surface transport (e.g. rail) to encourage modal shift. Also consider other policy levers, such as information provision, to encourage a reduction in the number of flights taken.
Response
Partially accept The Scottish Government remains committed to introducing Air Departure Tax (ADT) once the long-standing issue around the Highlands and Islands exemption has been resolved. The relevance of the new UK subsidy control regime is being carefully considered in this regard. The Scottish Government committed in its Programme for Government 2021-22 to review the UK Passenger Duty (APD) rates prior to the introduction of ADT to reflect our goals on climate change, including the possibility of a higher tax for more polluting aircraft. We will also take account of the Committee’s recommendations as part of that process at the relevant time.
In the meantime, the UK Air Passenger Duty arrangements continue to apply in Scotland.
Number
31.
Recommendation
Go further than the UK Government on information provision to travellers on the environmental cost of air travel. Look at requiring the provision of emission comparisons between different modes of transport (not just alternative flights) for flights operating within and leaving Scotland.
Response
Partially accept The CAA has just launched a Call for Evidence asking “what environmental information should be provided to people when they are looking for and booking flights, and how that information can be presented in a way that is meaningful and enables people to make informed choices about their travel options”.
We will consider the outcomes of the CAA’s review and whether there is a need to provide any further information.
Number
32.
Recommendation
Develop a detailed strategy for the decarbonisation of Public Service Obligation (PSO) routes, including looking at ways to incentivise the use of SAF/zero-emission aircraft for these routes.
Response
Accept Transport Scotland provides subsidy for the PSOs from Glasgow to Barra, Tiree and Campbeltown. We will consider the extent to which these could incentivise decarbonisation, particularly the use of SAF, recognising the balance between the possible costs involved and the possible environmental benefits that would accrue. Incentivising the use of zero-emission aircraft would likely be considered in later service periods, once these aircraft are certified to carry fare-paying passengers.
Local authorities are responsible for most PSOs in Scotland and may wish to consider whether and how they could be used to encourage SAF/zero-emission aircraft.
Number
33.
Recommendation
Continue to provide funding and support for the development of zero emission aircraft for domestic flights in Scotland.
Response
Accept Highlands and Islands Airports Limited (HIAL) is leading on the sustainable aviation test environment (SATE) project in Orkney. This project, in essence, provides a space for low and zero emission aircraft to be tested. The Scottish Government will continue to fund HIAL albeit that the delivery of the SATE project is reliant upon UK government funding. We will continue to encourage the UK Government to maintain this funding stream.
The revised draft National Planning Framework 4 (NPF4) is now in effect and states:“Airports, ports and rail links will provide vital connections within Scotland and beyond which will be crucial to building on a sustainable recovery whilst helping to decarbonise transport through low and zero emissions technologies.”
Spatial planning priorities in NPF4 for the ‘North’ area include that: “The Highlands and Islands are aiming to become the world’s first net zero aviation region by 2040 by pioneering new approaches including electric aircraft. Investment in technology and facilities will be required to achieve this.”
Number
34.
Recommendation
Continue to work with the UK Government and across the ETS Authority to develop a policy on the interaction between the UK ETS and the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) interaction as soon as possible, ensuring it is sufficiently environmentally stringent and that no credits from CORSIA are used for flights currently covered by the UK ETS unless and until they can satisfy strict eligibility criteria (equivalence, additionality, permanence, sustainability). The interaction should avoid double-compliance.
Response
Accept The Scottish Government will continue to work with the UK Government on this issue.
Number
35.
Recommendation
Publish a detailed strategy for decarbonising aviation in Scotland as soon as possible in 2022. Amongst other things, this strategy should set out a roadmap of how the decarbonisation of scheduled flights within Scotland will be achieved by 2040, including which technologies will be prioritised to achieve this and when the capability of these technologies will need to be demonstrated.
Response
Partially accept The Scottish Government intends to publish an aviation strategy. This will consider opportunities for decarbonising aviation in Scotland, building on our commitment to making the Highlands and Islands the world's first emissions free aviation region in the world. At this stage, there is a general consensus in the aviation sector that a variety of technologies will be required to achieve Net Zero. Given this, and that we are reliant on the private sector for the new technologies, it would be unrealistic to identify priority technologies now. In addition, most of Scotland’s internal flights operate on a commercial basis so SG actions would need to complement and support private sector progress.
Number
36.
Recommendation
Reduce the emissions from people travelling to and from Scottish airports. Further encourage the use of public transport for travel to and from Scottish airports to avoid car use and reduce overall emissions from the sector. Encourage Scottish airports to reduce their own on-site emissions (e.g. by adopting low-carbon surface transport and implementing low-carbon energy sources).
Response
Accept
We have set out 45 recommendations for future investment in Scotland’s strategic transport network in the second Strategic Transport Projects Review, published on 8 December 2022. Within these recommendations we have considered airport access in our strategic transport planning considerations. These have been considered in the recommendations for mass or rapid transit systems for the Glasgow, Edinburgh and Aberdeen City Regions, in the form of Clyde Metro, Edinburgh and South East Scotland Mass Transit and Aberdeen Rapid Transit. These recommendations can provide a transformational change in the service provision, focusing on strategic routes and or corridors where bus and rail provide the most effective service. This will improve access to an affordable and reliable public transport system within these City Regions.
The Scottish Government has already committed to the 11 HIAL (Highlands and Islands Airports Limited) airports being net zero by 2040. Edinburgh airport plans to achieve Net Zero by 2040, and AGS (Aberdeen and Glasgow airports) around 2035. Further, the SG statutory 2045 NZ target applies to all industry/businesses in Scotland, including airports.
National Planning Framework 4 (NPF4) is also now in effect. Policy 13 ‘Sustainable Transport’ has a clear intent ‘to encourage, promote and facilitate developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduce the need to travel unsustainably.’ Policy 11 ‘Energy’ has a clear intent ‘to encourage, promote and facilitate all forms of renewable energy development onshore and offshore.’ To support the expansion of renewable, low-carbon and zero emissions technologies.
Number
37.
Recommendation
Do not apply a non-CO2 factor to aviation emissions but commit to stopping warming from non-CO2 effects after 2050.
Response
Accept We will work with UK Government on this recommendation as they have received the same one and joint activity on this is necessary.
Number
38.
Recommendation
Consider how Scotland can incentivise Sustainable Aviation Fuel (SAF) use by Scottish airlines, to meet or go beyond the UK SAF mandate. This should be done in the next year as the UK Government develops its SAF mandate further.
Response
Partially accept The Scottish Government is considering how there could be greater use of sustainable aviation fuel. As well as the SAF mandate noted, the UK government is considering other related actions. The Scottish Government must understand these actions before it commits to doing anything further on SAF, however, the Scottish Government has no power to introduce a SAF mandate.
Number
39.
Recommendation
Use the upcoming Islands Connectivity Plan and Strategic Transport Projects Review to set out a plan for meeting the commitment to 30% of Scottish Government-managed ferries being low-emission by 2032 and for achieving full decarbonisation of Scotland's maritime sector. This should include consideration of zero-carbon fuels, vessel technologies, and the necessary supporting infrastructure.
Response
Accept The upcoming Islands Connectivity Plan to be published in 2023 will set out a plan for meeting the commitment to 30% of Scottish Government-managed ferries being low-emission by 2032.
Number
40.
Recommendation
Support the UK Government in pushing for inclusion of a Net Zero 2050 target in the International Maritime Organisation's 2023 update of its Greenhouse Gas Strategy.
Response
Partially accept TS are working closely with DfT on a range of decarbonisation issues, including aiming to support the IMO to adopt more ambitious proposals to move shipping to a decarbonised future.
Number
41.
Recommendation
Develop a plan for deploying shore power and electric recharging infrastructure at all of Scotland's major ports. This should include identifying roles and responsibilities for delivery and providing support and incentives to drive investment.
Response
Partially accept Transport Scotland is working closely with the Department for Transport on a range of Calls for Evidence and consultations exploring options to help decarbonise the maritime sector. Ports policy is devolved, whereas shipping policy is reserved, so some solutions may require both Scottish Government and UK Government. Some ports in Scotland are already pursuing shore power facilities, while others are looking at solar farms or creating hydrogen hubs to utilise excess offshore wind power nearby, so a one-size-fits-all policy for shore power may not be appropriate.
Number
42.
Recommendation
Publish the Cycling Framework and Delivery Plan for Active Travel in Scotland. This should set out how the increasing funding for active travel will be directed to contribute to reducing car traffic by 20% and delivering 20-minute neighbourhoods.
Response
Accept The Cycling Framework and Delivery Plan was published on 26 April 2023.
Number
43.
Recommendation
Publish a detailed strategy, building on the Route Map consultation of 2022, setting out how the Scottish Government will achieve a 20% reduction in car-kilometres by 2030 and deliver 20-minute neighbourhoods. This should include both investment in more sustainable modes of travel and measures to reduce the attractiveness of driving.
Response
Accept Following a post-publication public consultation on the draft route map, Transport Scotland is currently working with local authority partners to prepare a final version of the route map for publication in the coming months. The route map outlines our investment in more sustainable modes, including our commitment to increase the proportion of Transport Scotland’s budget that is spent on active travel, so that by 2024-25 at least £320 million or 10 percent of the total transport budget will be allocated to active travel, and a commitment to invest over £500 million in bus priority measures. The Scottish Government also recognises the need to reduce the attractiveness of driving, and we have commissioned research exploring equitable options for demand management which we will publish later this year. Using the research findings, we will work with local and regional partners to develop a demand management framework.. It is important to note that the most direct levers on the cost of buying or running a car – fuel duty and vehicle excise duty – are reserved, and the UK Government has yet to give the devolved nations clarity on whether, and if so when, it plans to replace motoring taxes. This must be clarified as soon as possible.
In addition, National Planning Framework (NPF4) is now in effect. On 20 Minute Neighbourhoods, NPF4 sets out a series of spatial principles for Scotland 2045 including ‘local living’; as part of this we are committed to the creation of networks of 20 minute neighbourhoods which will reduce the need to travel unsustainably, improve access to services and build local circular economies. We have published a draft of Local Living and 20 Minute Neighbourhood Guidance to assist those keen to adapt or develop their place as a 20 Minute Neighbourhoods. Delivery is supported through the Place Based Investment Programme, NPF4 and a new generation of local development plans, and can also be influenced by communities’ own local place plans that will capture people’s aspirations and needs for the places where they live.
Number
44.
Recommendation
Embed the 20% car demand-reduction target within key upcoming policy documents, such as the second Strategic Transport Projects Review and the fourth National Planning Framework, to ensure that all transport investment and spatial planning decisions give appropriate consideration to this ambition.
Response
Accept
Our vision is that by 2040, we will have a sustainable, affordable and accessible transport system, helping deliver a healthier, fairer, and more prosperous Scotland.
The 20% car demand-reduction target is embedded within the second Strategic Transport Projects Review, published early December 2022, and the fourth National Planning Framework (NPF4), now in effect.
The draft ESJTP includes the commitment to reduce car kilometres by 20% by 2030.
Number
45.
Recommendation
Work with local authorities to embed sustainable transport changes and deliver the interventions set out in the Route Map, offering support through financial means, resourcing, and with appropriate skills and knowledge-sharing.
Response
Accept
The Route Map was co-authored by CoSLA, reflecting the fact that local interventions will play a key role in supporting the transformation, including measures such as road space reallocation, parking measures, and taking account of the implications for transport when making spatial planning and land use decisions. Alongside the route map the SG will publish a resource guidance to aid local authorities to deliver reduction on car reliance in their area. Our forthcoming Local Transport Strategy guidance will support local authorities to embed sustainable transport changes. To support local authorities to raise revenue to support their local transport ambitions, SG has put regulations and guidance in place to allow local authorities to exercise their discretionary power to implement workplace parking licensing schemes. We will work with all local authorities to support equitable measures which reduce reliance on car use to accompany greater investment in public transport and active travel for a fairer and greener transport system.
Number
46.
Recommendation
Develop an implementation plan to deliver the Scottish Government's vision for the public EV charging network. This should ensure the EV transition works for all road users in Scotland and accelerates in line with EV uptake, delivering 6,000 charge points by 2026 and approximately 24,000 charge points by 2030.
Response
Partially accept Over the past 12 months Scottish Government has engaged with stakeholders to review and refine the Vision for public charging in Scotland and we expect to publish this in 2023. We will also develop implementation actions over the coming year to deliver the Vision. A key action will be delivery of our EV Infrastructure Fund, which aims to grow the public charging network in Scotland to over 6,000 public charge points in the next few years.
Scottish Government has not established a target number of public charge points for 2030 as there are a range factors, including development in technology and mix of charger types and capacity deployed, that will influence the final number of charge points required in Scotland.
Number
47.
Recommendation
Set out clear expectations and targets as to what local authorities should do to develop and implement local charging strategies, along with milestones for the rate at which charge point provision is expected to expand. Ensure that local authorities all have the capacity and capability to develop these strategies and implement the actions required.
Response
Partially accept Over the past 12 months Scottish Government has engaged with stakeholders to review and refine the Vision for public charging in Scotland and we expect to publish this in 2023. We will also develop implementation actions over the coming year to deliver the Vision. A key action will be delivery of our EV Infrastructure Fund, which aims to grow the public charging network in Scotland to over 6,000 public charge points in the next few years.
Scottish Government has not set a target number of public charge points for 2030 as there are a range factors, including development in technology and mix of charger types and capacity deployed, that will influence the final number of charge points required in Scotland. We do not currently anticipate setting targets for charge point provision in each local authority area, but are working in partnership with Local Authorities to support the development of local charging strategies (Strategy and Expansion Plans) which will identify charging requirements in each local authority.
Number
48.
Recommendation
Deliver the public transport fares review outlined in the Route Map. This should consider: prioritising delivery of a new, transparent fare structure that offers more affordable and reliable travel, ensuring fairness in relation to more carbon-intensive choices, and a more interlinked public transport system between operators.
Response
Accept
The draft 20% car km reduction route map includes a commitment to commission the Fair Fares Review. We are progressing the Fair Fares Review to ensure a sustainable and integrated approach to public transport fares that supports the future long term viability of a public transport system that is accessible, available and affordable for people throughout Scotland.
The FFR is considering both the cost and availability of services and the range of discounts and concessionary schemes which are available on all modes including bus, rail and ferry to ensure our public transport system is more accessible, available, and affordable, with the costs of transport more fairly shared across government, business, and society.
The Fair Fares Review advice will report by the end of 2023 and will recommend a package of measures which can be considered for implementation from 2024-25 and onwards. These will provide opportunities to address the wider issues for the cost and availability of public transport services across all modes of public transport.
As part of the Fair Fares Review, a pilot for the removal of ScotRail peak-time rail fares will run for six months starting October 2023.
Number
49.
Recommendation
Continue to support the public transport and shared mobility sectors to recover from the COVID-19 pandemic, including through maintaining recovery funding where required and positive communication and messaging. Work with operators and local transport authorities to avoid detrimental reductions in service provision or increases in fares.
Response
Accept The Scottish Government has been engaging with the industry through our Bus Taskforce to assist in addressing the challenges impacting the reliability of bus services, whilst recognising many of the levers are reserved to the UK Government. We worked jointly with the bus sector to deliver a marketing campaign to promote a return to bus. The campaign concluded on 31 May and we’re currently undertaking a post-campaign evaluation.
We have been clear that the support provided to transport operators needs to evolve to ensure it remains fit for purpose and is sustainable in the long term, and are continuing to invest in bus, including through the Network Support Grant, Community Bus Fund, and for bus priority infrastructure, together with the enhanced suite of options for local transport authorities to improve bus services according to their local needs, including formal partnerships, franchising and running their own bus services.
Number
50.
Recommendation
Continue to support the delivery of Scotland's transition to electric cars and vans. This will require working with the UK Government to ensure that the ZEV mandate will deliver the deployment rates required in Scotland and securing sufficient supply of and demand for vehicles in Scotland to ensure that sales rise throughout the 2020s to meet the 2030 phase-out commitment. The Scottish Government should seek opportunities to influence consumers to choose fully electric vehicles over plug-in hybrids wherever possible.
Response
Accept The ZEV mandate could play a significant role in helping us achieve our ambition to phase out the need for petrol and diesel cars and vans by 2030. The Scottish Government will endeavour to push the UK Government on their proposals for a ZEV mandate but, critically, we must have confidence that the mandate will work for Scotland and support our ambitious 2030 commitment.
Recent research into Plug-in-Vehicle (PiV) uptake in Scotland, undertaken by City Science on behalf of Transport Scotland and the Scottish Futures Trust, indicates that DfT data may be underestimating PiV uptake by 16%. Therefore, we will look to work with the UK Government on how to more accurately report the amount of PiVs, including electric cars and vans, on Scotland’s roads to help us better assess Scotland’s deployment rates than current UK Government reporting allows.
Number
51.
Recommendation
Invest in developing new technologies and support innovation for emerging technologies, for example battery manufacturing and recycling, zero-emission HGVs, and shared mobility solutions.
Response
Accept In June 2022 we established the 4-year £28 million Zero Emission Mobility Innovation Fund, delivered in partnership with Scottish Enterprise to support Scottish companies to innovate and bring zero emission vehicles and their components and systems to market.
Scottish Government has funded organisations like CoMoUK, EST and Connect Community Trust to increase awareness of the benefits of shared transport, including car clubs in Scotland. Some of this funding supports their provision of leadership, expertise and support to organisations and communities across Scotland on shared transport in general and setting up shared transport schemes in particular.
Grants are available through the Scottish Government’s largest travel Behaviour Change Programme, Smarter Choices, Smarter Places, to encourage people to use public transport or other sustainable options such as buses and community car clubs for longer journeys; walking and cycling for short journeys, and home-working to replace daily commutes. These are available to a range of organisations, such as registered charities, education institutions, regional transport trusts, Local Authorities and more.
Agriculture and Land Use, Land Use Change and Forestry (LULUCF)
Number
52.
Recommendation
Maintain and enhance incentives to support agroforestry and hedgerows on Scottish farms. Plant trees on 2% of farmland by 2025 while maintaining its primary use, rising to 5% by 2035, and extend hedgerows by 20% by 2035 and better manage existing hedgerows.
Response
Partially accept
In the Climate Change Plan update (CCPu), we committed to ambitious targets for tree planting, rising to 18,000 hectares per year by 2024/25. Supporting farmers and crofters to integrate trees on their land is a key part of meeting that target. Through support for initiatives such as the Integrating Trees Network, Scottish Government is working to increase the awareness of the benefits of growing trees amongst farming businesses. We are currently working with Scottish Forestry’s Trees on Farm group to develop trial specifications for the Forestry Grant Scheme’s agroforestry option.
The Agri-Environment Climate Scheme (AECS) promotes land management practices which protect and enhance Scotland's magnificent natural heritage, improve water quality, manage flood risk and mitigate and adapt to climate change. The scheme offers support with the planting or replanting of hedgerows. Following the 2022 round awards, the Scottish Government has made hedgerow commitments of around £14.5 million, with over 678,000 metres of hedgerows planted or replanted since 2015.
We published a route map on 10 February 2023 which sets out the timescales for information and interaction with the agricultural industry to deliver the Vision for Agriculture which includes reducing GHG emissions. Through this publication it gives greater clarity and confidence to the agriculture industry on key dates, the various measures being proposed, and the Scottish Government support that will be available for the agriculture industry to implement these changes. The Route Map provides a clear set of programme dates and when more guidance, support and information will become available. This will include new conditions and measures that support farmers and crofters to reduce their emissions and integrate land management practices.
Number
53.
Recommendation
Provide detail on how post-CAP agricultural subsidies and schemes in Scotland will target funding and delivery for climate mitigation alongside wider environmental goals such as climate change adaptation and biodiversity.
Response
Accept
To deliver the ambitions set out the Scottish Government’s Vision for Agriculture, published in March 2022, we will have a support framework that delivers high quality food production, climate mitigation and adaptation, and nature restoration.
We published a route map on 10 February 2023 which sets out the timescales for information and interaction with the agricultural industry to deliver the Vision for Agriculture which includes reducing GHG emissions. Through this publication it gives greater clarity and confidence to the agriculture industry on key dates, the various measures being proposed, and the Scottish Government support that will be available for the agriculture industry to implement these changes. The Route Map provides a clear set of programme dates and when more guidance, support and information will become available. This will include new conditions and measures that support farmers and crofters to reduce their emissions and integrate land management practices.
Recommendation
Put in place robust frameworks for monitoring, reporting and verification of post-CAP farm subsidies and agriculture environment schemes to assess their effectiveness in delivering their environmental objectives, including for climate change mitigation and adaptation.
Response
Accept
This is part of our work to deliver the Vision for Agriculture and a new agricultural support framework.
Number
54.
Recommendation
Deliver on Food Waste Reduction Action Plan to reduce food waste by one-third by 2025. This should be upscaled to reach 50% by 2030.
Response
Accept
Our Food Waste Reduction Action Plan delivers against our target to reduce food waste by one third by 2025. In addition, we are signatories to the Courtauld Commitment 2030, which includes a target to deliver a 50% per capita reduction in food waste by 2030.
Number
55.
Recommendation
Take low-cost, low-regret actions to encourage a 20% shift away from all meat by 2030, rising to 35% by 2050, and a 20% shift from dairy products by 2030, demonstrating leadership in the public sector whilst improving health.
Response
Partially accept
The Scottish Government supports consumers to move their usual diets towards a healthy balanced diet as depicted by the Eatwell Guide and in line with our Scottish Dietary Goals, as a more sustainable way of eating. This means that the average intake of red and processed meat should be no more than around 70g per person per day. The sustainability of the Eatwell Guide was assessed by the Carbon Trust, in 2016, and they concluded that moving towards the Eatwell Guide would provide a 32% lower environmental footprint. Progress towards achieving the Goals has remained largely static for some time. With careful consideration of replacement for reductions in meat intakes, the general population may increase their intakes of fruit, vegetables and fibre.
Number
56.
Recommendation
The Bioenergy Action Plan should set out the role that sustainable domestic production of perennial energy crops and short rotation coppice will play to contribute towards Scotland's emission reduction targets.
Response
Partially Accept
Delivering Negative Emission Technologies (NETs) in Scotland as part of our pathway to Net Zero has the potential to deliver substantial benefits. The Scottish Government has commissioned a detailed feasibility study of opportunities for developing NETs projects in Scotland that will identify specific sites and applications for these emerging technologies. NETs pathways will depend on the use of bioenergy and the availability of sustainable domestic bioresources.
Number
57.
Recommendation
As part of strengthening the regulatory baseline, extend coverage of Nitrate Vulnerable Zones across all of Scotland in order to promote best practice in management of inorganic fertilisers and organic manure and slurry.
Response
Partially Accept
Mandatory farming rules within and out with Nitrate Vulnerable Zones (NVZs) in Scotland for management of inorganic fertilisers and organic manure and slurry are now virtually the same. Therefore we accept the principle and outcome sought of this recommendation but there is not a need to formally amend legislation on NVZs to reach that outcome.
Approximately 10% of Scotland’s land is currently designated as NVZs to protect drinking water sources in the water environment from pollution caused by nitrates from agriculture. The NVZ designations are based on scientific monitoring and assessment of the water environment carried out by the Scottish Environment Protection Agency (SEPA). There are already General Binding Rules under the Water Environment (Controlled Activities) (Scotland) Regulations 2011, most recently updated in 2021, that set mandatory requirements across all of Scotland for management of inorganic fertilisers and organic manure and slurry, which are regulated by SEPA. This means that mandatory farming rules within and out with NVZs in Scotland for management of inorganic fertilisers and organic manure and slurry are now virtually the same. Best practice in the management of inorganic fertilisers and organic manure and slurry is already promoted in Scotland through two Scottish Government funded programmes: the Farming and Water Scotland and Farming for a Better Climate initiatives. The Scottish Government is also encouraging Scottish farmers to improve their nutrient use efficiency through funding for soil analysis under the Preparing for Sustainable Farming Scheme.
Number
58.
Recommendation
Move beyond the voluntary nature of current CAP replacement schemes by setting a strong regulatory baseline that strengthens rules such as those under Basic Payment Scheme and retains them in Scottish legislation.
Response
Accept
A Scottish Agriculture Bill will be introduced in 2023. The Vision for Agriculture commits to integrating enhanced conditionality of at least half of all funding for farming and crofting by 2025.
Number
59.
Recommendation
Put in place action to overcome financial barriers that prevent take-up and innovation in low-carbon farming practices. This should include management incentives under CAP replacement schemes and grants for capital items and infrastructure, and support for research and development.
Response
Accept
We published a route map on 10 February 2023 which sets out the timescales for information and interaction with the agricultural industry to deliver the Vision for Agriculture which includes reducing GHG emissions. Through this publication it gives greater clarity and confidence to the agriculture industry on key dates, the various measures being proposed, and the Scottish Government support that will be available for the agriculture industry to implement these changes. The Route Map provides a clear set of programme dates and when more guidance, support and information will become available. This will include new conditions and measures that support farmers and crofters to reduce their emissions and integrate land management practices.
The Agri-Environment Climate Scheme (AECS) is the Scottish Government’s ongoing and primary funding mechanism for environmental and sustainable land management. It provides targeted support to land managers to undertake specific actions on environmental management, with benefits for biodiversity and climate change mitigation. Support is available for both capital and management options. To date, £285 million has been committed via AECS to over 3,000 businesses to fund a range of activities that help to maintain and enhance the natural environment.
The Agricultural Transformation (Programme) Fund (ATF) is intended to underpin support for the agricultural sector to reduce greenhouse gas emissions, improve efficiency and enhance Scotland’s natural environment through the period of transition. Through Sustainable Agriculture Capital Grant Scheme (SACGS), the ATF has been used to support investment in a wide range of items of agricultural equipment, including £5 million allocated in 2022 to support the purchase of low emission slurry spreading equipment and slurry store covers that are proven to lower ammonia emissions and reduce adverse impacts on water quality. In 2023 the ATF budget of £5 million has been allocated to provide an extension of support for new slurry storage across Scotland (except in Nitrate Vulnerable Zones (NVZ).
Number
60.
Recommendation
Maintain and enhance programmes and initiatives to deliver advice and knowledge exchange on climate change mitigation and adaptation measures for Scotland’s farmers, crofters and land managers.
Response
Accept
Through the Farm Advisory Service (FAS), we are delivering high quality advice and support, largely free of charge, to: improve biodiversity; increase awareness of habitat and carbon sequestration benefits of woodland planting; promote climate change adaptation and mitigation opportunities; improve business management and efficiency; encourage inclusivity by supporting new entrants and women in agriculture; and helping to support the industry and Scottish government to evolve to meet future challenges. This is done through a range of outputs including: events, webinars, advice line support, videos, peer to peer discussion groups and bespoke consultancy/advisor support. Future provision of this service is currently being considered and will ensure that the service is equipped to support the sector with current and future challenges.
We continue to support and invest in existing support mechanisms/initiatives (for example Farming for a Better Climate, the Agriculture, Biodiversity and Climate Change network and The Integrating Tree Network) to ensure they are well placed to adapt, align with future policy, and keep pace with such future challenges. These support mechanisms/initiative will continue to communicate, educate, and demonstrate benefits of climate change mitigation and adaption measures for Scotland’s farmers, crofters and land managers.
Additionally, we continue to offer sector led knowledge transfer and innovation support through the Knowledge Transfer and Innovation Fund (KTIF). This is done by supporting organisations with a range of projects to ensure on-the-ground improvements in resource efficiency, environmental performance and sustainability. We continue to maintain and where possible enhance this programme to ensure its effectiveness.
Number
61.
Recommendation
Continue to support research and development into low-carbon farming practices, including behavioural, innovation and productivity measures. The risk of a high dependency on innovation and technology to meet GHG emission reductions should be assessed, and integrated with demand-side measures such as diet change and waste reduction.
Response
Accept
Scottish Government continues to support research and development on low-carbon farming through ClimateXChange, the Knowledge Transfer and Innovation Fund, the Strategic Research Programme and grant funding of innovative projects.
Recent publications include:
Scenarios for emissions reduction targets in Scottish agriculture
Decarbonisation of mobile agricultural machinery in Scotland
Reducing emissions from agriculture – the role of new farm technologies
Number
62.
Recommendation
Set out how public and private funding for agricultural and land-based measures will be aligned, how opportunities to attract increased private finance for habitat creation and restoration will be developed, and promote the use of existing verifiable standards (such as the Woodland Carbon Code and Peatland Code) whilst also considering the need to develop new ones.
Response
Accept
Our 2022 National Strategy for Economic Transformation commits to developing a high integrity, values-led market for responsible investment in natural capital. This commitment is being taken forward by a public sector partnership programme and is supported by the 2022 Interim Principles for Responsible Investment in Natural Capital. We will be producing a Natural Capital Market Framework for Scotland that will set out in more detail the actions we are taking to support the NSET market vision.
Number
63.
Recommendation
Ensure that funding and incentives are set at the correct level to meet the Scottish Government afforestation target of 18,000 hectares per year by 2025
Response
Accept
Grant schemes in support of woodland creation have been in place for decades and funding towards achieving Net Zero is being prioritised in the Scottish Government. This suggests a positive outcome for funding woodland creation post-2025 although budgets have not been agreed at this stage.
Number
64.
Recommendation
Ensure the forestry sector and government agencies continue to support tree nurseries to increase domestic production of trees to meet the planting ambition and reduce reliance on imports, along with the associated risks of pests and diseases.
Response
Accept
This is in line with plans in the Scotland Climate Change Plan to support a programme of technical innovation to develop and adapt modern horticultural practices to help increase nursery production. Funding to support increased production of young trees is available through the Harvesting and Processing grant which is now open to forest nurseries across GB with support from Defra.
Number
65.
Recommendation
Scottish Government should continue support to develop and promote the Woodland Carbon Code, to attract private finance and additional investment to incentivise woodland creation and diversification of the forest estate in Scotland.
Response
Accept
The Scottish Government is also working to increase private sector investment through mechanisms such as the Woodland Carbon Code which it continues to develop and promote. The target of increasing the scale of the woodland carbon market by 50% in this Parliament has already been exceeded
Number
66.
Recommendation
Develop a comprehensive plan to increase the production and use of UK sourced timber and support the long-term economic viability of domestic woodlands.
Response
Accept
The Scotland Climate Change Plan sets out how, in collaboration with the private forest sector and other public sector bodies, the Scottish Government will implement the Timber Development Programme through an annual programme of projects that support the promotion and development of wood products for use in construction.
Number
67.
Recommendation
Scottish Government should work with private and voluntary sectors, and through agricultural colleges and universities to provide skills training, demonstration and increase capacity to promote delivery of sustainable farming practices and land management.
Response
Accept
The FAS (Farm Advisory Service), work closely with Lantra Scotland (who manage the FBAASS accreditation of advisors). The FAS uses a range of techniques from training events to updated communications to ensure that advisors delivering the programme have the information they need, as well as providing a training programme to support delivery. It should be noted that this is a moderate level of SG support on skills training, demonstrations and increasing capacity.
Future provision of the FAS is currently being considered and it will look to ensure that it is able to increase through knowledge transfer and innovation support the capacity to promote delivery of sustainable farming practices and land management.
The SG plays a role in coordination, cooperation and delivery on skills for all sectors across the rural economy, with the appropriate policy areas liaising with institutions to deliver this. We will continue to seek more ways to continue to engage with partners to deliver ongoing skills training on more sustainable farming practices and land management.
Number
68.
Recommendation
Develop understanding on how the transition to Net Zero in the agriculture and land will affect employment in these sectors, including a timeframe of change and the scale of impact. Set out how the change will be managed to be fair and equitable, ensuring new skills and training are widely available to both support communities, but also to facilitate the meeting of targets in these sectors.
Response
Accept
The Scottish Government is committed to publishing a draft Land Use and Agriculture Just Transition Plan in late 2023. Just Transition planning will be an iterative and evolving process. The first Land Use and Agriculture Plan will set out our approach and policy actions laying the foundations for future plans. It will focus on the livelihoods, skills, health and wellbeing of those who live in and rely on Scotland’s land and agricultural sector as we look to maintain and support thriving rural and island communities.
Recent research for Scottish Forestry shows that each additional 1000 hectares of woodland creation generates an average of 13 full-time equivalent jobs.
Number
69.
Recommendation
Provide support to tenant farmers to overcome contractual issues that restrict the long-term commitment and investment required to reduce emissions and sequester carbon on the land they manage.
Response
Partially accept
This recommendation is partially accepted on the basis of the reference to “overcome”. The use of the word “overcome” in the recommendation suggests that there is an inherent problem with leases at present. There could also be an inference that the intention is to retrospectively deal with existing leases. If so, there would inevitably be A1P1 objections from landlords.
Number
70.
Recommendation
Set in place action to overcome non-financial barriers that prevent adoption of low-carbon farming measures and land-use change to deliver emission reduction and carbon benefits. These include streamlining application processes and providing support for skills, training, and knowledge exchange in order to provide confidence to farmers to take up new measures.
Response
Accept
We continue to support and invest in existing support mechanisms/initiatives (for example Farming for a Better Climate, the Agriculture, Biodiversity and Climate Change network and The Integrating Tree Network) to ensure they are well placed to adapt, align with future policy, and keep pace with such future challenges. These support mechanisms/initiative will continue to communicate, educate, and demonstrate benefits of climate change mitigation and adaption measures for Scotland’s farmers, crofters and land managers.
The new Land Use Tenancy being brought forward through the future Land Reform Bill has the potential to assist in increasing land-use change to deliver emission reduction and carbon benefits.
Number
71.
Recommendation
Ensure incentives are set at the correct level to set a trajectory to achieve 58% of peatland restored by 2035, and 79% under restoration by 2050. All upland peat should be under restoration management by 2045.
Response
Partially accept
In 2020 the Scottish Government set out plans to invest £250 million over ten years to restore 250,000 hectares of degraded peatlands (which represents around 17% of Scotland’s degraded peatlands) by 2030. Restoration targets beyond 2030 will be considered in Scotland’s next Climate Change Plan.
Number
72.
Recommendation
Where peat soils remain under agricultural use, set out how they will be managed in a more sustainable way. This should include raising water levels on 8% of lowland grassland by 2025, reaching 25% by 2035, and 12% of arable crops by 2025, reaching 38% by 2035.
Response
Partially accept
Work towards Scotland’s next Climate Change Plan is looking at the contribution of rewetting peat soils under agricultural use to emissions reductions targets.
Number
73.
Recommendation
Implement a comprehensive delivery mechanism to address degraded peatland and extend current restoration ambition set out by the Scottish government beyond the existing timeframe of 2030. Peat restoration targets include the need to remove all low-productive trees (i.e. less than YC10) from peatland, and restore all peat extraction sites by 2035.
Response
Partially accept
The Scottish Government’s Peatland Programme is driving comprehensive action to remove barriers to upscaling restoration and to build a robust project pipeline to 2030 and beyond. Restoration targets beyond 2030 will be considered in Scotland’s next Climate Change Plan.
Scottish Forestry do not support the planting of trees on deep peat (over 50cm) and all woodland creation cases covering sensitive areas, such as deep peat, require full environmental assessment. Policy on forest restocking on peat soils is following evidence to maximise net GHG removals.
Number
74.
Recommendation
Introduce baseline regulations to ensure lowland peat soils are not left bare by mandating the use of appropriate vegetation cover.
Response
Partially accept
On 7th June it was announced that the protection of peatlands and wetlands will be a condition in Scotland’s future support model for farming and land management, taking forward the new Good Agricultural and Environmental Condition (GAECs 2) covering the protection of wetlands and peatland. This follows the publication of a route map on 10 February 2023 which sets out the timescales for information and interaction with the agricultural industry to deliver the Vision for Agriculture which includes reducing GHG emissions. Through this publication it gives greater clarity and confidence to the agriculture industry on key dates, the various measures being proposed, and the Scottish Government support that will be available for the agriculture industry to implement these changes. The Route Map provides a clear set of programme dates and when more guidance, support and information will become available. This will include new conditions and measures that support farmers and crofters to reduce their emissions and integrate land management practices.
Number
75.
Recommendation
Introduce policy to end rotational burning on peatland before the start of the 2023 burn season.
Response
Partially accept
Measures setting out a prohibition on burning on peatland, except under licence has been included in the Wildlife Management and Muirburn (Scotland) Bill which was introduced in Parliament on 21 March 2023. Muirburn on peatland will only be allowed under licence if no other method of vegetation control is available and it is for one of the following purposes:
(i) restoring the natural environment,
(ii) preventing, or reducing the risk of, wildfires causing damage to habitats,
(iii) preventing, or reducing the risk of, wildfires causing harm to people or damage to property,
(iv) research.
The legislation will not come in to force prior to the start of the 2023 burn season which is 01 October 2023. Therefore this recommendation is partially accepted.
Number
76.
Recommendation
Consult on and introduce the regulations to ban the retail sale of peat in horticulture in Scotland. Government must work with the horticultural industry to end use by the professional sector.
Response
Accept
A consultation on ending the sale of peat in Scotland was launched on 17 February 2023 and ended on 12 May 2023. Outcomes will inform timescales for banning sales of peat in the retail and professional sectors.
Number
77.
Recommendation
Set out clear timeframes to end domestic and industrial peat extraction in Scotland. Provide a mechanism to ensure the peat extraction industries restore extraction sites to protect the peat resource.
Response
Partially accept
National Planning Framework 4 does not support new commercial peat extraction except where this is to support the whisky industry. The framework also seeks to minimise damage from extraction and ensure restoration. Ending domestic cutting would have socio-economic impacts in many rural communities. Ending commercial peat extraction would have significant financial implications. Restoration requirements for commercial peat extraction sites are agreed with the relevant planning authority.
Waste Management
Number
78.
Recommendation
Work with the waste industry to develop a plan to decarbonise waste treatment assets in Scotland in line with emissions and waste reduction objectives, including identifying asks of UK Government in reserved areas.
Response
Accept
The Scottish Government commissioned an independent review of the role of incineration in Scotland’s Waste Hierarchy to ensure that how we treat our unrecyclable and unavoidable waste aligns with Scotland’s carbon reduction ambitions. The Scottish Government responded to the second and final report of the independent incineration review on the 5 May 2023, setting out our approach for decarbonising incineration, including in any areas reserved to UK Government.
Our Circular Economy and Waste Route Map consultation set out proposals to develop a Residual Waste Plan to minimise the environmental impact of waste and to bring this area in-line with Net Zero targets; and a Sector Led Plan to restrict the carbon impacts of incineration. We are considering consultation responses and will refine these proposals in our final Route Map.
Number
79.
Recommendation
Set out further detail on actions and implementation timelines to ensure all recommendations from the incineration review can be delivered. This should include explaining how the projected residual waste capacity gap in 2025 will be managed whilst ensuring commitments to end the landfilling of biodegradable waste are met.
Response
Partially accept
We published our response to Dr Church’s first report on the Review of Incineration in Scotland’s Waste Hierarchy, and accepted all recommendations. Our response can be found here. On 5 May 2023, we published our response to the second and final report of the independent incineration review, which can be found here.
Our consultation on the development of a Circular Economy and Waste Route Map sets out a proposal to develop a Residual Waste Plan to minimise the environmental impact of waste, setting the strategic direction for management of residual waste to 2045 and to bring this area in-line with Net Zero targets. We are considering consultation responses and will refine these proposals in our final Route Map.
Number
80.
Recommendation
Work with the UK Government to develop a policy and funding framework to retrofit existing Energy from Waste plants with CCS from the mid-2020s, and ensure any new Energy from Waste plants are all built ‘CCS-ready’.
Response
Partially accept
The Scottish Government does not hold all the necessary legislative and regulatory levers needed to support decarbonisation of the sector through Carbon Capture, Use or Storage, as they are not devolved. We will continue to work constructively with, and indeed push, the UK Government to ensure the Scottish Cluster has the certainty it needs to continue its development, including the development of a policy and funding framework to retrofit Energy from Waste Plants where feasible.
National Planning Framework 4 (NPF4), now in effect, policy 12 ‘Zero Waste’ only supports energy-from-waste facilities under very limited circumstances. In defined circumstances the policy is clear that proposals will be supported by a heat and power plan which gives consideration to methods to reduce carbon emissions of the facility, for example, through carbon capture and storage.
Number
81.
Recommendation
Start reporting emissions from Energy from Waste as a separate source within the Scottish greenhouse gas inventory.
Response
Accept (completed)
Official statistics on Scottish greenhouse gas emissions are published annually and used to monitor progress towards Scotland’s statutory emissions reduction targets. These statistics are based on a disaggregation of the UK Greenhouse Gas (GHG) Inventory, which is overseen by the UK Government Department for Business, Energy and Industrial Strategy (BEIS) and compiled in line with international scientific guidance. Previously, the UK Inventory did not allow for the isolation of data for emissions from waste incineration plants as opposed to other energy sector emissions at a Scotland level. Decisions around the UK Inventory are a matter for BEIS and are informed by the UK National Inventory Steering Committee, which includes representation from Scottish Government officials. We worked with BEIS and the UK National Inventory Steering Committee and are now able to provide separate Energy from Waste data in our annual Scottish Greenhouse Gas Statistics (as of 20 June 2023).
Number
82.
Recommendation
Review planning policies for waste infrastructure to ensure they enable delivery of recycling targets, support future residual waste needs and consider decarbonisation requirements. This includes clarifying siting requirements for incinerators to enable CCS adoption.
Response
Accept (completed)
Planning policy has been reviewed through the preparation of National Planning Framework 4, now in effect.
National Planning Framework 4 (NPF4) policy 12 ‘Zero Waste’ is clear that local development plans should identify appropriate locations for new waste management infrastructure to support the circular economy and meet identified needs in a way that moves waste as high up the waste hierarchy as possible. The policy for decision making on individual planning applications is clear that ‘Development proposals that are likely to generate waste when operational, including residential, commercial and industrial properties will set out how much waste the proposal is expected to generate and how it will be managed, including to support recycling. Furthermore, the policy is clear that support for waste infrastructure (except landfill and energy from waste facilities – covered separately) will only be supported where any greenhouse gas emissions resulting from the processing and transportation of waste to and from the facility is minimised.
NPF4 policy 12 ‘Zero Waste’ supports energy-from-waste facilities only under very limited circumstances. In defined circumstances the policy is clear that proposals will be supported by a heat and power plan which gives consideration to methods to reduce carbon emissions of the facility, for example through carbon capture and storage.
Number
83.
Recommendation
Implement initial Extended Producer Responsibility, the Deposit Return Scheme and consistent collections of recycling and food waste without further delay. Complete an independent review of the impact of the schemes within 2 years of implementation (i.e. by 2026).
Response
Partially accept (Recycling part of the recommendation)
We are working with other UK governments to deliver Extended Producer Responsibility for packaging.
The launch of Scotland’s Deposit Return Scheme will be delayed until at least October 2025, due to the impact of the Internal Market Act and unacceptable, 11th hour decisions taken by the UK Government, including the requirement to align with other UK DRS schemes, the details of which have not yet been published. Scottish Ministers remain committed to the implementation of a Deposit Return Scheme (DRS) in Scotland and bitterly disappointed that Scotland’s DRS, being years in the making, has been sabotaged.
One of the priorities of the Route Map is to significantly improve recycling from households and businesses. The Recycling Improvement Fund is one important part of our overall efforts to improve recycling, and this £70 million Fund is already making a big impact across Scotland, with 17 councils already benefiting from an award.
The final Circular Economy and Waste Route Map and the Circular Economy Bill will both support and empower local authorities to drive forward the modernisation and improvement of recycling facilities across Scotland, and cut overall amount of waste produced through, for example, incentivising re-use over disposable products.
Number
84.
Recommendation
Legislate the Circular Economy Bill and set targets to reduce waste and improve recycling rates beyond 2025, ensuring these are more ambitious than existing targets. Targets should be set on the basis of separate waste streams (rather than 'All waste') and where possible consider carbon-based metrics.
Response
Partially accept
In 2022 we consulted on both a Circular Economy Bill and Waste Route Map to 2025 and beyond. The Circular Economy Bill was introduced in June 2023 and includes powers to set statutory targets. The Route Map consultation sets out the principles that should underpin new circular economy targets for the period to 2030 and will be published in 2023.
Number
85.
Recommendation
Set out how Scottish Water will be supported to deliver its plan to achieve Net Zero, as well as how emissions from industrial waste water facilities will be reduced.
Response
Accept
Ministers have confirmed that they will lend up to £1.03 billion across the 2021-27 period to support Scottish Water’s investment programme. This includes the implementation of their Net Zero Emissions Routemap together with the prioritisation of investment on water and wastewater services. The Scottish Government intends to align with the EU's recast Urban Waste Water Treatment Directive which covers emissions reductions, decreased energy consumption and the improved circularity of resources through the recovery of energy and critical materials.
Industry
Number
86.
Recommendation
Together with UK Government, review existing – and, if necessary, develop new – schemes that support the sustainable production of biomass feedstocks and conversion of bioenergy in a way consistent with Net Zero. This should include dates beyond which new facilities should be built with CCS, and dates for when CCS will need to be retrofitted to biofuel facilities already in operation.
Response
Partially accept
Scottish Government’s Bioenergy Policy Working Group will consider the role of bioenergy as well as the potential to scale up production of sustainable biomass feedstock.
The Negative Emission Technologies (NETs) feasibility study will help to identify suitable technologies that could facilitate a transition towards Net Zero and potential timeline for development. This will inform policy decisions regarding deployment of carbon capture and storage.
Number
87.
Recommendation
Ensure that key policies to improve resource efficiency, recycling and waste prevention, such as Extended Producer Responsibility, are on track to be in place well before 2025
Response
Partially accept
Development of a Waste Route Map is underway and will be published this year. The Circular Economy Bill was introduced to parliament in June 2023. We are working with other UK governments to deliver Extended Producer Responsibility, with the first scheme being packaging EPR. However Extended Producer Responsibility schemes for other product types are not intended for delivery by 2025.
Number
88.
Recommendation
Renew efforts to improve resource efficiency, recycling and waste prevention by setting new ambitious targets for 2030.
Response
Partially accept
Development of a final Circular Economy and Waste Route Map that will look beyond 2025 and consider future targets underway following 2022 consultation, and will be published this year. Circular Economy Bill has also been published.
Number
89.
Recommendation
Improve the collection and reporting of industrial decarbonisation data to allow for progress to be monitored more effectively, particularly on energy and resource efficiency.
Response
Partially accept
Existing data on point-source emissions underpin monitoring and policy development, however requesting or mandating further disclosure of wider data sources will require a greater level of co-ordination, including with regulators, than at present.
Number
90.
Recommendation
Implement policies to enable substantial improvements in industrial energy efficiency
Response
Accept
Scottish Industrial Energy Transformation Fund (SIETF) will continue to co-fund, until 2026, delivering energy efficiency improvements. A review during 2023 will consider its scope further into the 2020’s.
Number
91.
Recommendation
As part of the planned update to the Energy Strategy, and supported by the proposed new National Public Energy Agency, formalise the planning process, governance framework and timeline for decisions on infrastructure for the conversion to hydrogen of the gas transmission and distribution networks. Alongside this, identify priority candidate areas for hydrogen conversion and areas which are unlikely to be suitable to hydrogen conversion (such that electrification and alternatives can be prioritised), ensuring consistency with least-regret forward views on demand for hydrogen within Scotland and across the rest of the UK.
Response
Partially accept
The future of the gas networks remains uncertain, and will depend substantially on strategic decisions on the future of the gas grid, which only UK Government can make and which it has said it does not expect to make before 2026.
Decisions from the UK Government on the blending of hydrogen into the gas grid are due in 2023 – this decision is key to kick starting the hydrogen market in the UK and would enable the early build out of critical hydrogen production infrastructure.
It should be noted that as the gas grid's future is reliant on UK Government policy decisions as well as the outcome of UK Government/Ofgem funded Project Union activity, the timeframes do not align with the publication of the final ESJTP (Energy Strategy Just Transition Plan). As such, we continue to urge the UK Government to expedite progress on amending regulations and legislation to support hydrogen blending and accelerating decisions on the role of 100% hydrogen in the gas grid.
Number
92.
Recommendation
Continue to support innovation and demonstration of technologies for decarbonising manufacturing and construction; ensure that learning is disseminated as widely as possible within industry.
Response
Accept
We will continue to do this through a range of established structures. As examples, the National Manufacturing Institute Scotland (NMIS) provides businesses with a range of initiatives such as a Digital Factory and a Manufacturing Skills Academy that can help business to become more sustainable. Whilst NMIS has been developed to deliver a pan-Scotland service, it will strengthen its presence significantly by opening a state-of-the-art flagship building this Summer in Renfrew. We also have the Michelin Scotland Innovation Parc (MSIP) which has an aim to help deliver a fair and just transition to a Net Zero economy. MSIP’s location in Dundee offers businesses with access to a range of services such as an Innovation Campus, a skills academy and the option to utilise onsite industrial space. Additionally, through our Advancing Manufacturing Challenge Fund (AMCF), we have funded 12 projects across Scotland which offer free support to SMEs (small and medium enterprises) to help them improve their manufacturing capabilities. The projects deliver a range of initiatives such as: expert advice; technology demonstrators; collaboration/networking space; and training.
We have also established an overarching programme for manufacturing – Making Scotland’s Future. This programme brings together key public sector partners across the support landscape to collaborate, share knowledge and continue to deliver a joined up approach to supporting the manufacturing sector.
For construction this work is underway through our innovation centre BE-ST, to achieve this it is vital that funding of that organisation is maintained. BE-ST's work ranges from development of low carbon materials, to building techniques, technologies and skills development needed to support the just transition of the sector.
Number
93.
Recommendation
Work with business to encourage and enable consumers to share, lease and use products for longer whilst discouraging ‘disposable’ business models.
Response
Accept
We fund Zero Waste Scotland who provide circular business support and advice. A dedicated Circular Textiles Fund has been established to support circular business models.
Number
94.
Recommendation
Develop policies to drive more resource-efficient construction and use of existing low-carbon materials. This should include setting out a plan for phasing in mandatory whole-life reporting followed by minimum whole-life standards for all buildings, roads and infrastructure by 2025, with differentiated targets by function, scale, and public/private construction.
Response
Partially accept
National Planning Framework 4 (NPF4) is now in effect and applicable to decisions on planning applications across Scotland. Policy 2 ‘climate mitigation and adaptation’ is clear that development proposals will be sited and designed to minimise lifecycle greenhouse gas emissions as far as possible.
In December 2021, we published our Response to Scotland’s Climate Assembly: Recommendations for Action, including the commitment to investigate opportunities for whole life emission reporting, through building regulations or by other means. In support of this commitment, officials have engaged with Zero Waste Scotland and some of the UK’s leading experts on the topic and will be considered in development of Scotland’s next Climate Change Plan.
Energy
Number
95.
Recommendation
Set out an updated assessment of how much renewable and low-carbon electricity generation will be required to meet Net Zero in Scotland and contribute cost-effectively to Net Zero in the UK, with a clear trajectory to 2045.
Response
Partially accept
The Scottish Government has assessed potential ranges of energy demand and generation, including electricity, out to 2045 under three future energy scenarios. These scenarios informed the roadmap included in the draft Energy Strategy and Just Transition Plan and further assessments are underway as part of the next Climate Change Plan. We will continue to update our assessments.
Number
96.
Recommendation
In conjunction with the electricity network owners and the electricity system operator, outline what will be required to ensure adequate electricity supply resilience across Scotland in the late 2020s and into the 2030s as thermal generation in Scotland is retired.
Response
Partially accept
This is an entirely reserved issue, and the Scottish Government cannot compel the TOs/DNOs and ESO to undertake this work. However, we are in regular dialogue with the TOs/DNOs and ESO on the issue and it will be considered in our final Energy Strategy and Just Transition Plan.
Negative Emissions Technologies
Number
97.
Recommendation
Carry out a detailed scoping exercise on the potential for engineered removals in Scotland that identifies potential sites for new build and retrofit engineered removals projects and takes into account proximity to biomass stocks, access to future CCS networks and impacts on energy systems.
Response
Accept
The Scottish Government has commissioned a NETs Feasibility Study, which is aligned with the Climate Change Committee recommendations. The research is underway.
The Scottish Government continue to press the UK Government to progress Carbon Capture Utilisation and Storage (CCUS) in Scotland, something which is critical to our Net Zero pathway and which, being reserved, only the UK Government can do.
Number
98.
Recommendation
Work with the Inter-ministerial Group for Net Zero, Energy and Climate Change (IGNZECC) to publish a joint position on the contribution of engineered removals and CCS to meeting UK-wide and DA targets to 2030.
Response
Partially accept
The Scottish Government has requested that the UK Government amend the CCUS clauses within the Energy Bill to reflect divergent national targets. We are considering how best to engage and work with the IGNZECC. We have also invited the UK Government to work with us through establishment of an Energy Transition taskforce, to deliver tangible action to drive the energy transition.
Contact
Email: climate.change@gov.scot
There is a problem
Thanks for your feedback