Scottish Government Improvement Plan – Response to Environmental Standards Scotland Investigation – Climate Change Delivery Improvement Report

Consultation

In preparation of our response to the Improvement Report for the mandatory reporting of scope 3 emissions for LAs, consultation has been carried out with various stakeholders in line with subsection 30(4)^[8] of the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021.

Details of the consultation

During May 2024 representatives from all 32 LAs were invited to participate in online discussions through two workshops. Out of 32 local authorities, representatives from 15 attended the first workshop, and 17 attended the second. All LAs were presented with the final draft Improvement Plan for comments through the SSN LA Forum held in June 2024. A list of organisations represented at each of these events can be found at Annex A.

Workshop 1

Prior to workshop 1 each LA was asked to indicate for each scope 3 emission categories whether data was:

• readily available and if so how accurate it was;
• potentially available and the quality of such data; and
• if they currently reported on each category, and if so what tools and methodologies they used.

The workshop was delivered online via MS Teams, and break-out rooms were used to provide LA representatives with the opportunity to input more granular information. Each break-out room took a selection of the scope 3 emission categories, covering: reasonably straightforward; would need further research to develop tools; uncertain methodologies; and not applicable to LAs.

Questions covered during these break-out rooms were:

• Data availability/quality challenges under each scope 3 category;
• Practical barriers to overcome that would need resolved to allow full scope 3 reporting; and
• Indication of possible timeline for action towards.

Views expressed during this workshop included:

• Essential to ensure any additional reporting adds value to existing frameworks and is carried out in an efficient way.
• Ensure baselines for each of the different emission scopes are set and reviewed when necessary. This would require some training of how to set baselines.
• Adequate resource is required to report effectively.
• Linking reporting to actions to ensure delivery of climate ambitions.
• Suggestion that the UK Government approach to companies reporting could be adopted: “comply or explain”.
• Reporting should focus on the most significant emissions, those most material to the organisation.

The views expressed during the first workshop were considered and reflected in the discussions held during the second workshop, and helped to inform proposals for creating three groups and the actions that would be taken forward.

Workshop 2

Prior to the second workshop the LA representatives were provided with a document that summarised the position following Workshop 1 and outlined SG’s draft proposals for the Improvement Plan. This included the division of scope 3 emissions categories into 3 distinct groups, and how SG planned on addressing each group.

The workshop was again delivered virtually, with a presentation from SG on the proposed way forward, followed by an open discussion about the paper provided.

Views expressed during this workshop included:

1. Practical and feasible

• Indicative methodologies would need to be provided to ensure consistency and to ensure they are commensurate with the value of the data being collected and reported.
• Consideration of measuring v estimating emissions as some will be based on averages.
• Those included in this group are feasible to report on.
• Need to avoid double-counting – for example, waste in Shetland and Orkney uses joint disposal process.

2. Collaboration and resource

• Working group approach is welcome.
• Should include LAs, academics, climate change professionals and a mix of experience in delivering reporting.
• Clear methodologies would be needed and a clear indication of what data needs to be collected.
• Work on drawing boundaries would be required.
• Procurement reporting needs to link into the SG Procurement Team reporting requirements, and the Improvement Plan should acknowledge the procurement reporting challenges.

3. Further research needed

• These are the categories that SG isn’t looking at mandating reporting of, however LAs could still report on these if they were applicable.
• Further research is definitely required to establish the value of reporting on these categories by LAs.
• De-minimis levels are set out in the GHG Protocol.
• Estimates to be used where primary data are not available.

Following the second workshop changes were made to wording, and suggestions for implementation captured to help with delivery, including the proposal to establish a focus group to share best practice, identify opportunities to report and agree a standardised methodology for reporting on categories.

To further explore the findings from the two workshops SG officials presented the outputs from each of the workshops – alongside the recommended actions to be included in this Improvement Plan – to the SSN LA Forum (12^th June 2024). This discussion was chaired by the SSN, and attended by 63 representatives from across 28 LAs. An opportunity for further input was provided and feedback was positive. No further representations from LA representatives was received.

In addition to the two workshops and SSN LA Forum, the SG consulted with COSLA and SOLACE on the development of the Improvement Plan and to ensure that LAs had sufficient opportunity to input to the development of the Plan.

Advice from climate change and carbon accounting experts at the Edinburgh Climate Change Institute and the Jame Hutton Institute was also sought in finalising the groupings and the proposed actions.