About you
3. What is your name?
Name
(Required)
Elizabeth Leighton
4. Are you responding as an individual or on behalf of an organisation?
Organisation
Climate Emergency Response Group
Your Views
1. What is your assessment of the progress to date in cutting emissions within the sector/sectors of interest and the implementation of the proposals and policies set out in previous Climate Change Plans (RPP1-3)?
Please provide your response in the box provided.
The Climate Emergency Response Group (CERG) is a collection of like-minded leaders spanning Scotland’s private, public and third sectors, delivery organisations and membership bodies.
The group aims to inform and influence the Scottish Government's response to the climate emergency by providing practical, workable solutions that can be implemented – not in the future, but now. The group’s sense is that there is no time to lose and like the global pandemic, this emergency also requires and emergency response.
Using its diverse experience, the group drafted proposals for immediate actions for Scotland’s climate emergency response. This 12-point plan for action was adopted by the Scottish Government as part of its 2019 Programme for Government to support its target of achieving net zero carbon emissions by
CERG was formed in summer 2019 out of a concern that Scottish Government policies and programmes were not changing to reflect its recognition of the climate emergency (April 2019 – the first nation in the world to declare a state of climate emergency). Since then, we have seen the Scottish Government give priority to the climate emergency in the Programme for Government 2019, the Scottish Budget 20/21, the draft Infrastructure Investment Plan, and most recently in its emphasis on the green recovery, as seen in the Programme for Government 2020. The CCPU brings together and reflects this significant progress in placing net zero at the heart of its policies and frameworks.
While CERG has not undertaken a detailed assessment of the entire CCPu, we do believe the Scottish Government has stepped up to the challenging task of setting out a vision and trajectory for meeting the 2030 and 2045 climate change targets. We also welcome the new additional investment decisions and policy commitments where these have been made, particularly in the challenging context of responding to a global pandemic. For example, the ambition for a million homes to be zero carbon emissions from heating by 2030, a target to reduce car kilometres by 20%, the shift in language and intention around land use, and the significant investment in green jobs and skills.
However, some sectors continue to lag in ambition – notably agriculture – and the ‘how to’ achieve the ambition is too often lacking. In some cases, processes are set out (working groups, research) though timescales do not reflect the urgent nature of the climate emergency and green recovery. And without the firm policies to give certainty to investors – from homeowners to developers – demand will falter, the supply chain will not have the confidence to grow, and the targets won’t be achieved. We are aware that further policy announcements are expected in the coming months, but we are not able to assess the ambition until we have seen the details.
In summary, the CCPu ambitions and high level statements are welcomed, but CERG needs to see more firm targets accompanied by a credible policy framework which give confidence the targets will be achieved (e.g. regulation, incentives, resource, delivery programmes, enabling policy).
CERG Interim Progress Report
Our interim progress report (dated November 2020 so did not include assessment of the CCPu) concluded there has been good progress against our 20 recommendations, though few have been met in full, and more is required to match the scale and urgency of the climate emergency. While it is fair to expect some delay due to the global pandemic, at the same time CERG believes we must seize the opportunity to accelerate action as part of the green recovery to the economic impacts of COVID-19. The report gave the Scottish Government a green rating (met in full) for its response to 33% of our recommendations, an amber rating (met in part and/or more scale and urgency needed) for 57%, and a red rating (not met in a meaningful way) for 10%.
Our interim progress report highlighted the following positive commitments, which are included in the CCPu:
• Support for green jobs, apprenticeships, and skills.
• Increased and multi-year funding to give buses more space on roads, to cut emissions from homes and buildings and build more cycling and walking infrastructure.
• Scottish National Investment Bank given a primary mission to tackle climate change.
The report also identified the following gaps which need to be filled through the CCPu and associated policy statements:
• Set out flagship policy and funding for zero emission mobility in our cities by 2030 – with an ambition for four city or town transformation plans in place by 2022.
• Double both the funding and scale of Scottish Government energy efficiency and fuel poverty programmes and set a target that all homes must reach Energy Performance Certificate Band C by 2030.
• Plan to build a pipeline of projects to double the number of buildings connected to heat networks by 2025.
• Help farmers plan and invest by saying now that from 2024 rural subsidies will encourage climate friendly practices.
• Ensure that the climate emergency is a material consideration in planning decisions.
The two CERG proposals where the Scottish Government response received a ‘red’ rating were on mobilising public procurement for the climate emergency response and developing guidance on sustainable, climate-friendly diets. The CCPu and other government statements indicates the government remains committed to both and we believe progress can be made with:
• Strong targets with timescales for procurement – for renewable energy and energy storage, food, reused/recycled content and zero emission estates
• Guidance on sustainable, climate-friendly, healthy diets and linking this to the Local Food Strategy and procurement.
This written evidence makes recommendations on how the CCPu could be amended to improve these ratings through strong policy action which matches the world-class climate change targets.
A full response has been provided to the ECCLR Committee and this response provides extracts relevant to this committee.
The group aims to inform and influence the Scottish Government's response to the climate emergency by providing practical, workable solutions that can be implemented – not in the future, but now. The group’s sense is that there is no time to lose and like the global pandemic, this emergency also requires and emergency response.
Using its diverse experience, the group drafted proposals for immediate actions for Scotland’s climate emergency response. This 12-point plan for action was adopted by the Scottish Government as part of its 2019 Programme for Government to support its target of achieving net zero carbon emissions by
CERG was formed in summer 2019 out of a concern that Scottish Government policies and programmes were not changing to reflect its recognition of the climate emergency (April 2019 – the first nation in the world to declare a state of climate emergency). Since then, we have seen the Scottish Government give priority to the climate emergency in the Programme for Government 2019, the Scottish Budget 20/21, the draft Infrastructure Investment Plan, and most recently in its emphasis on the green recovery, as seen in the Programme for Government 2020. The CCPU brings together and reflects this significant progress in placing net zero at the heart of its policies and frameworks.
While CERG has not undertaken a detailed assessment of the entire CCPu, we do believe the Scottish Government has stepped up to the challenging task of setting out a vision and trajectory for meeting the 2030 and 2045 climate change targets. We also welcome the new additional investment decisions and policy commitments where these have been made, particularly in the challenging context of responding to a global pandemic. For example, the ambition for a million homes to be zero carbon emissions from heating by 2030, a target to reduce car kilometres by 20%, the shift in language and intention around land use, and the significant investment in green jobs and skills.
However, some sectors continue to lag in ambition – notably agriculture – and the ‘how to’ achieve the ambition is too often lacking. In some cases, processes are set out (working groups, research) though timescales do not reflect the urgent nature of the climate emergency and green recovery. And without the firm policies to give certainty to investors – from homeowners to developers – demand will falter, the supply chain will not have the confidence to grow, and the targets won’t be achieved. We are aware that further policy announcements are expected in the coming months, but we are not able to assess the ambition until we have seen the details.
In summary, the CCPu ambitions and high level statements are welcomed, but CERG needs to see more firm targets accompanied by a credible policy framework which give confidence the targets will be achieved (e.g. regulation, incentives, resource, delivery programmes, enabling policy).
CERG Interim Progress Report
Our interim progress report (dated November 2020 so did not include assessment of the CCPu) concluded there has been good progress against our 20 recommendations, though few have been met in full, and more is required to match the scale and urgency of the climate emergency. While it is fair to expect some delay due to the global pandemic, at the same time CERG believes we must seize the opportunity to accelerate action as part of the green recovery to the economic impacts of COVID-19. The report gave the Scottish Government a green rating (met in full) for its response to 33% of our recommendations, an amber rating (met in part and/or more scale and urgency needed) for 57%, and a red rating (not met in a meaningful way) for 10%.
Our interim progress report highlighted the following positive commitments, which are included in the CCPu:
• Support for green jobs, apprenticeships, and skills.
• Increased and multi-year funding to give buses more space on roads, to cut emissions from homes and buildings and build more cycling and walking infrastructure.
• Scottish National Investment Bank given a primary mission to tackle climate change.
The report also identified the following gaps which need to be filled through the CCPu and associated policy statements:
• Set out flagship policy and funding for zero emission mobility in our cities by 2030 – with an ambition for four city or town transformation plans in place by 2022.
• Double both the funding and scale of Scottish Government energy efficiency and fuel poverty programmes and set a target that all homes must reach Energy Performance Certificate Band C by 2030.
• Plan to build a pipeline of projects to double the number of buildings connected to heat networks by 2025.
• Help farmers plan and invest by saying now that from 2024 rural subsidies will encourage climate friendly practices.
• Ensure that the climate emergency is a material consideration in planning decisions.
The two CERG proposals where the Scottish Government response received a ‘red’ rating were on mobilising public procurement for the climate emergency response and developing guidance on sustainable, climate-friendly diets. The CCPu and other government statements indicates the government remains committed to both and we believe progress can be made with:
• Strong targets with timescales for procurement – for renewable energy and energy storage, food, reused/recycled content and zero emission estates
• Guidance on sustainable, climate-friendly, healthy diets and linking this to the Local Food Strategy and procurement.
This written evidence makes recommendations on how the CCPu could be amended to improve these ratings through strong policy action which matches the world-class climate change targets.
A full response has been provided to the ECCLR Committee and this response provides extracts relevant to this committee.
2. Do you think the scale of reductions proposed within the sector(s) are appropriate and are the proposals and policies within the CCPu effective for meeting the annual emissions targets and contributing towards the 75% reduction in GHG emissions by 2030 and net-zero by 2045 targets?
Please provide your response in the text box provided.
The CERG interim progress report recognised achievements and positive commitments (which are brought together in the CCPu) and made both cross-cutting and sector specific recommendations for the CCPu. These are set out below with commentary in italics on how we think the CCPu responds to these recommendations.
Achievements and positive commitments – based on CERG interim assessment
• Green Recovery - The Scottish Government has shown a strong commitment in words and actions to a green recovery in its response to the economic crisis caused by the global pandemic
The CCPu is framed in terms of how the transition to net-zero can be accelerated through a green recovery – targeting green jobs and skills, locking in positive behaviours, pursuing a place-based approach, investing in low carbon solutions, whilst building resilience.
• Multi-year funding commitments - Multi-year capital funding commitments will facilitate much needed long-term planning and private investment. Over the period of the next parliament, the Government will invest nearly £1.6 billion in eliminating emissions from heat and improving energy efficiency in buildings, and £1 billion in active travel and bus priority measures. However, investments should be front-loaded wherever possible to maximise impact for jobs, early emissions reduction and to reduce lock-in of high carbon behaviours. Capital spend will also need to be accompanied by resource funding for quality planning, delivery, and maintenance.
The CCPu presents the next tranche of the multi-year Low Carbon Fund, with investments focusing on NETS, transport, active travel, and green infrastructure. CERG hopes our recommendations around front-loading investments and resource investment are taken up in the Scottish Budget 21/22.
• Investment Frameworks and Market Signals - New investment frameworks are being developed to help piece together the necessary finance for the transition to net zero. As part of its ‘Green New Deal’, the Scottish Government has committed £2 billion to capitalise the Scottish National Investment Bank with net zero central to its mission, launched the Green Investment Portfolio and is also continuing to develop the Green Growth Accelerators to attract green finance into Scotland. A heat pump sector deal will generate clear long-term market signals for the accelerated installation of heat pumps.
The heat pump sector deal is a good example of working in partnership with the private sector to achieve targets, although it is important that the PfG20 timetable is maintained and the Scottish Government responds quickly in order to make rapid progress on heat pump deployment. There remains a worrying lack of detail within the CCPu on the use of new financial models such as the Green Growth Accelerator to support large-scale city transformations blending private finance with public investment and borrowing.
Policy signals (regulation, fiscal incentives, targets) - Some important policy signals have been provided to set the direction of travel to net-zero, however significant gaps remain (see recommendations below). An example of good progress includes a proposed revision of standards for new buildings requiring them to use renewable or zero emission heating, (though we believe the timescale here can and should be accelerated). CERG would like to see similarly strong signals for existing buildings and for zero emission (vehicles) cities.
The CCPu includes some welcome additional policy signals (e.g. 50% of homes converted to low carbon heating by 2030, £120m for bus decarbonisation, 20% reduction in car kilometres by 2030, commitment to accelerate action to phase out peat extraction). Notable gaps where policy signals are inadequate include agriculture and enabling zero-emission cities, agriculture.
Priority for low carbon infrastructure - The draft Infrastructure Investment Plan shows a welcome actual and percentage increase of low carbon capital spending in 2020/21 from 31% to 35%. However, spending on high carbon activities remains approximately constant (road and airport infrastructure).
The CCPu should provide an indication of how investment will increasingly shift to low carbon and circular economy practices by encouraging more integrated alignment of transport, planning and active travel. There is also a need for immediate action to review and minimise all planned high carbon infrastructure investment which could undermine progressive targets and policies within the CCPu.
Cross-cutting recommendations – based on CERG interim progress report
One of the key challenges for the CCPu is that solutions to delivering a net zero future are increasingly systemic, while the Plan reporting takes a sectoral approach. We understand the rationale for sectoral targets and reporting but recommend that cross-sectoral solutions and delivery plans are flagged clearly in the Plan (noting which sectors are involved). In this context, we were very pleased to see the implicit acknowledgment of this collective approach with the sign off of the CCPu by the entire cabinet.
Below we set out a brief analysis of the extent to which the cross-cutting recommendations presented in our interim assessment have been met in the CCPu (with our comments in italics):
1. CERG Recommendation – Strong Policy Signals: The welcomed increase in public investment must be matched by strong policy signals across the board to provide a certain and attractive environment for private investment in retrofitting buildings for greater energy efficiency, renewable energy, district heating, and e-mobility.
Some progress in the CCPu with standards signalled for buildings and cars, though detail is lacking. Gaps remain e.g. for agriculture, zero-emission cities, and industrial decarbonisation.
2. CERG Recommendation – Urgency and ambition: Policies, regulations, and programmes need to be developed with urgency, working to ambitious timescales so the public and private sector know what they need to do and when.
CCPu sets out ambitious emissions reductions targets for most sectors (with agriculture notably slower). To achieve this, CCPu should commit to a new way of working which is less risk averse (learning by doing) with less reliance on lengthy policy development processes. This is beginning to happen but not in all areas. We identify agriculture and the holistic transformation of urban areas as examples where rapid and sufficient investment could deliver changes on the ground and shift public attitudes.
3. CERG Recommendation – front-loaded spending: Multi-year investments need to be front-loaded to maximise impact for jobs and achieve early emissions reduction. The Comprehensive Spending Review Framework spending profile for low carbon indicates a slow increase which will fail to deliver on these aims.
Useful new funding commitments in CCPu on buses but otherwise spending trajectory does not appear to ‘front load’ spending.
4. CERG Recommendation – Resource investment: Capital spend must be accompanied by adequate funding for capacity and expertise to ensure rapid and effective development and delivery of programmes throughout Scotland. We estimate that resource spend should be at least 10% of capital spend (additional)and is necessary to secure jobs and investment.
Capacity and expertise for the delivery of big programmes remains a significant problem which must be addressed urgently. This resource ‘gap’ threatens Scotland’s ability to meet its climate change targets and win a green recovery from the pandemic.
Sector recommendations for CCPu – based on CERG interim progress report
The following table sets out CERG’s recommendations for the CCPu from our interim progress report, alongside commentary on how we think the CCPu responds to these recommendations. As there is a considerable amount of detail in the table, we have chosen 10 priority recommendations we believe need urgent attention through the scrutiny process.
10 Priority Sector Recommendations for the final CCPu
1. Firm policy and funding commitments to support holistic city and town centre transformations, focusing initially on four city and town transformation plans as pilots, financed through Green Growth Accelerators.
2. Double funding and scale of current energy efficiency and fuel poverty programmes to support acceleration of Energy Efficient Scotland Route map to EPC band C for the vast majority of buildings by 2030 (accompanied by solutions to the methodology which underpins EPC’s so it is aligned with net-zero).
3. Introduce mandatory energy performance standards for owner/occupied housing at point of sale and major refurbishment with a significant foreshadow period, implementation from 2025 and accompanied by well-resourced programme of support.
4. Emissions targets for the agriculture sector should be equally challenging to those for other sectors.
5. Set clear intention for mandatory environmental conditionality with agriculture payments.
6. Agriculture Transformation Fund must incorporate robust capacity building strategy for adoption and use of new equipment and practices, and clearly align to net zero transformation.
7. Set expectation for progress in industrial sector on resource efficiency and decarbonisation.
8. Resources (capacity and funding), accountability and clear expectation for the public sector, in particular local authorities, to lead on delivering the net-zero agenda - particularly around planning, transport, and heat.
9. Public procurement targets for net-zero products and services to lead by example and build the market – e.g. new buildings, retrofit standards, upcycled products, climate-friendly food, renewable energy.
10. Make joining up of skills and public engagement programmes (as per buildings and heat) explicit as part of CCPu decarbonisation plans.
Transport:
• Welcome references to place-making and 20 minute neighbourhood approaches - but no detailed initiatives.
• Welcome announcement to bring forward target on petrol / diesel cars and vans to be in line with UK target.
• Welcome ongoing commitment and new funding for zero emission buses (alongside Bus Decarbonisation Taskforce / Bus Partnership Fund) and promoting bus transport for a green recovery.
• Welcome target on reduction in car travel – the route-map on how to achieve this is critical and will need to include strong demand management measures as well as incentives for modal shift. Would also like to see target on increased mobility space for active travel and bus priority.
• Missed opportunity to set out holistic policies and targets to send the clear signal that city centres will be largely emission free (vehicles) by 2030.
• No mention of city centre transformations, investing in public realm, and financing models. – this should be linked with policy on 20 minute neighbourhoods to maximise opportunities for innovation and collaboration. There needs to be a holistic approach to decarbonisation across sectors in the urban area.
• Consolidation centres / last minute mile initiatives for freight (also recommended by CCC) presented as for consideration and opportunities only – more policy direction and support for private sector required.
• Planning - need for more connection between transport, planning and design / regeneration of neighbourhoods and communities.
• Ongoing concerns about local government capacity / resources to deliver on their key role in local transport policy and delivering locally-relevant solutions.
• Concern that achievement of ambitions to transform transport choices is dependent not only on the forthcoming NPF4 and Strategic Transport Projects Review but also immediate action is required to review and minimise all planned high carbon infrastructure investment. Ongoing investment in high carbon infrastructure road enhancement projects could undermine achievement of progressive targets within the CCPU such as the ambitious 20% reduction in kilometres by car by 2030.
Land Use:
• Welcome the new agriculture outcome, environmental conditionality and desire to scale up action, draw in private investment and overcome barriers. Specifics lacking, which is worrying given this is an area of huge importance for Scotland and we need to see more rapid progress. CCPu mainly announces process / proposals rather than targets and details.
• The current emissions envelope for agriculture is the weakest of all sectors, with only a 24% reduction envisaged by 2032 (compared to 43% for industry, 50% for waste and 40% for transport for example). This is in the context of very limited emission reductions in the agriculture sector over the past 10 years. On this trajectory the agriculture sector will become the biggest emitting sector in Scotland by the 2040s (being around 4.3 MTCO2e by 2040) and so require a huge amount of NETs in order to meet the 2045 net zero target for Scotland. We do not think this is justified in terms of requiring more action in other sectors, nor is it the best use of public money (i.e. direct payments with conditions that only deliver a relatively small emissions reduction) in a climate emergency.
• There is a significant risk that Scottish Food & Drink loses market advantage in terms of low emissions intensity production (e.g., vs more ambitious changes in England) and so ultimately industry suffers through protection of ‘business as usual’ practice.
• The expansion of the agricultural transformation fund is welcome but, again, it is focused on capital spend. Very doubtful how much the current scheme will actually reduce emissions (seems more focused on productivity) and still needs robust capacity building strategy for adoption and use of new equipment and practices. Cost/benefit analysis should be used to score applications rather than a simple menu of options.
• Environmental conditionality is positive but lacking in detail – scope, measures and scale. Must move from voluntary best practice guides to clear mandatory conditionality and prioritise / resource rapid roll out.
• Increase in annual tree planting targets welcomed but must be done in a transparent and consultative way. The RLUPs represent an important mechanism to avoid push backs and delays, and to ensure communities and stakeholders are involved in woodland expansion that affects their own areas.
• Welcome commitment to climate friendly diet guidance. Awaiting Statement of Policy on Food and Local Food Strategy. We understand the sensitivities around dietary advice, but changing diets are a core part of the net zero transition and can deliver improved human health outcomes too. Opportunity for greater leadership by public and private sectors. An emphasis on local food is important in terms of sustainability and local economies, and it avoids food miles and ‘off-shoring’ emissions for products like red meat which is produced at a lower emissions intensity in Scotland. However, in most cases it does not actually deliver significant emissions reductions compared to an emphasis on increasing the proportion of plant-based food in diets. The UK CCC 6th carbon budget report includes targets on reduced meat / dairy intake.
• We need an integrated, whole system approach to food policy, that secures meaningful emissions reductions - a framework Good Food Nation Bill could help do this.
• in most cases it does not actually deliver significant emissions reductions compared to an emphasis on increasing the proportion of plant-based food in diets. The UK CCC 6th carbon budget report includes targets on reduced meat / dairy intake.
• No ban on peat extraction – but desire to accelerate action to phase out, though missed opportunity to set the timescale in the CCPu. Stronger use of planning system in Scotland (not support new commercial and facilitate restoration) to come in through NPF4. Acknowledge need to do much more to restore degraded peatlands. (note CCC has targets for 60% restoration and a ban on extraction).
• Welcome commitment to RLUPs and emphasis should be on rolling out to all parts of Scotland working with all land uses/types from the outset. They will be crucial in delivering the net zero transition in the LULUCF and agriculture sectors so the post-CAP rural support regime should be fully integrated into RLUP development. Local governments must be resourced to take part as they will be key to success.
Achievements and positive commitments – based on CERG interim assessment
• Green Recovery - The Scottish Government has shown a strong commitment in words and actions to a green recovery in its response to the economic crisis caused by the global pandemic
The CCPu is framed in terms of how the transition to net-zero can be accelerated through a green recovery – targeting green jobs and skills, locking in positive behaviours, pursuing a place-based approach, investing in low carbon solutions, whilst building resilience.
• Multi-year funding commitments - Multi-year capital funding commitments will facilitate much needed long-term planning and private investment. Over the period of the next parliament, the Government will invest nearly £1.6 billion in eliminating emissions from heat and improving energy efficiency in buildings, and £1 billion in active travel and bus priority measures. However, investments should be front-loaded wherever possible to maximise impact for jobs, early emissions reduction and to reduce lock-in of high carbon behaviours. Capital spend will also need to be accompanied by resource funding for quality planning, delivery, and maintenance.
The CCPu presents the next tranche of the multi-year Low Carbon Fund, with investments focusing on NETS, transport, active travel, and green infrastructure. CERG hopes our recommendations around front-loading investments and resource investment are taken up in the Scottish Budget 21/22.
• Investment Frameworks and Market Signals - New investment frameworks are being developed to help piece together the necessary finance for the transition to net zero. As part of its ‘Green New Deal’, the Scottish Government has committed £2 billion to capitalise the Scottish National Investment Bank with net zero central to its mission, launched the Green Investment Portfolio and is also continuing to develop the Green Growth Accelerators to attract green finance into Scotland. A heat pump sector deal will generate clear long-term market signals for the accelerated installation of heat pumps.
The heat pump sector deal is a good example of working in partnership with the private sector to achieve targets, although it is important that the PfG20 timetable is maintained and the Scottish Government responds quickly in order to make rapid progress on heat pump deployment. There remains a worrying lack of detail within the CCPu on the use of new financial models such as the Green Growth Accelerator to support large-scale city transformations blending private finance with public investment and borrowing.
Policy signals (regulation, fiscal incentives, targets) - Some important policy signals have been provided to set the direction of travel to net-zero, however significant gaps remain (see recommendations below). An example of good progress includes a proposed revision of standards for new buildings requiring them to use renewable or zero emission heating, (though we believe the timescale here can and should be accelerated). CERG would like to see similarly strong signals for existing buildings and for zero emission (vehicles) cities.
The CCPu includes some welcome additional policy signals (e.g. 50% of homes converted to low carbon heating by 2030, £120m for bus decarbonisation, 20% reduction in car kilometres by 2030, commitment to accelerate action to phase out peat extraction). Notable gaps where policy signals are inadequate include agriculture and enabling zero-emission cities, agriculture.
Priority for low carbon infrastructure - The draft Infrastructure Investment Plan shows a welcome actual and percentage increase of low carbon capital spending in 2020/21 from 31% to 35%. However, spending on high carbon activities remains approximately constant (road and airport infrastructure).
The CCPu should provide an indication of how investment will increasingly shift to low carbon and circular economy practices by encouraging more integrated alignment of transport, planning and active travel. There is also a need for immediate action to review and minimise all planned high carbon infrastructure investment which could undermine progressive targets and policies within the CCPu.
Cross-cutting recommendations – based on CERG interim progress report
One of the key challenges for the CCPu is that solutions to delivering a net zero future are increasingly systemic, while the Plan reporting takes a sectoral approach. We understand the rationale for sectoral targets and reporting but recommend that cross-sectoral solutions and delivery plans are flagged clearly in the Plan (noting which sectors are involved). In this context, we were very pleased to see the implicit acknowledgment of this collective approach with the sign off of the CCPu by the entire cabinet.
Below we set out a brief analysis of the extent to which the cross-cutting recommendations presented in our interim assessment have been met in the CCPu (with our comments in italics):
1. CERG Recommendation – Strong Policy Signals: The welcomed increase in public investment must be matched by strong policy signals across the board to provide a certain and attractive environment for private investment in retrofitting buildings for greater energy efficiency, renewable energy, district heating, and e-mobility.
Some progress in the CCPu with standards signalled for buildings and cars, though detail is lacking. Gaps remain e.g. for agriculture, zero-emission cities, and industrial decarbonisation.
2. CERG Recommendation – Urgency and ambition: Policies, regulations, and programmes need to be developed with urgency, working to ambitious timescales so the public and private sector know what they need to do and when.
CCPu sets out ambitious emissions reductions targets for most sectors (with agriculture notably slower). To achieve this, CCPu should commit to a new way of working which is less risk averse (learning by doing) with less reliance on lengthy policy development processes. This is beginning to happen but not in all areas. We identify agriculture and the holistic transformation of urban areas as examples where rapid and sufficient investment could deliver changes on the ground and shift public attitudes.
3. CERG Recommendation – front-loaded spending: Multi-year investments need to be front-loaded to maximise impact for jobs and achieve early emissions reduction. The Comprehensive Spending Review Framework spending profile for low carbon indicates a slow increase which will fail to deliver on these aims.
Useful new funding commitments in CCPu on buses but otherwise spending trajectory does not appear to ‘front load’ spending.
4. CERG Recommendation – Resource investment: Capital spend must be accompanied by adequate funding for capacity and expertise to ensure rapid and effective development and delivery of programmes throughout Scotland. We estimate that resource spend should be at least 10% of capital spend (additional)and is necessary to secure jobs and investment.
Capacity and expertise for the delivery of big programmes remains a significant problem which must be addressed urgently. This resource ‘gap’ threatens Scotland’s ability to meet its climate change targets and win a green recovery from the pandemic.
Sector recommendations for CCPu – based on CERG interim progress report
The following table sets out CERG’s recommendations for the CCPu from our interim progress report, alongside commentary on how we think the CCPu responds to these recommendations. As there is a considerable amount of detail in the table, we have chosen 10 priority recommendations we believe need urgent attention through the scrutiny process.
10 Priority Sector Recommendations for the final CCPu
1. Firm policy and funding commitments to support holistic city and town centre transformations, focusing initially on four city and town transformation plans as pilots, financed through Green Growth Accelerators.
2. Double funding and scale of current energy efficiency and fuel poverty programmes to support acceleration of Energy Efficient Scotland Route map to EPC band C for the vast majority of buildings by 2030 (accompanied by solutions to the methodology which underpins EPC’s so it is aligned with net-zero).
3. Introduce mandatory energy performance standards for owner/occupied housing at point of sale and major refurbishment with a significant foreshadow period, implementation from 2025 and accompanied by well-resourced programme of support.
4. Emissions targets for the agriculture sector should be equally challenging to those for other sectors.
5. Set clear intention for mandatory environmental conditionality with agriculture payments.
6. Agriculture Transformation Fund must incorporate robust capacity building strategy for adoption and use of new equipment and practices, and clearly align to net zero transformation.
7. Set expectation for progress in industrial sector on resource efficiency and decarbonisation.
8. Resources (capacity and funding), accountability and clear expectation for the public sector, in particular local authorities, to lead on delivering the net-zero agenda - particularly around planning, transport, and heat.
9. Public procurement targets for net-zero products and services to lead by example and build the market – e.g. new buildings, retrofit standards, upcycled products, climate-friendly food, renewable energy.
10. Make joining up of skills and public engagement programmes (as per buildings and heat) explicit as part of CCPu decarbonisation plans.
Transport:
• Welcome references to place-making and 20 minute neighbourhood approaches - but no detailed initiatives.
• Welcome announcement to bring forward target on petrol / diesel cars and vans to be in line with UK target.
• Welcome ongoing commitment and new funding for zero emission buses (alongside Bus Decarbonisation Taskforce / Bus Partnership Fund) and promoting bus transport for a green recovery.
• Welcome target on reduction in car travel – the route-map on how to achieve this is critical and will need to include strong demand management measures as well as incentives for modal shift. Would also like to see target on increased mobility space for active travel and bus priority.
• Missed opportunity to set out holistic policies and targets to send the clear signal that city centres will be largely emission free (vehicles) by 2030.
• No mention of city centre transformations, investing in public realm, and financing models. – this should be linked with policy on 20 minute neighbourhoods to maximise opportunities for innovation and collaboration. There needs to be a holistic approach to decarbonisation across sectors in the urban area.
• Consolidation centres / last minute mile initiatives for freight (also recommended by CCC) presented as for consideration and opportunities only – more policy direction and support for private sector required.
• Planning - need for more connection between transport, planning and design / regeneration of neighbourhoods and communities.
• Ongoing concerns about local government capacity / resources to deliver on their key role in local transport policy and delivering locally-relevant solutions.
• Concern that achievement of ambitions to transform transport choices is dependent not only on the forthcoming NPF4 and Strategic Transport Projects Review but also immediate action is required to review and minimise all planned high carbon infrastructure investment. Ongoing investment in high carbon infrastructure road enhancement projects could undermine achievement of progressive targets within the CCPU such as the ambitious 20% reduction in kilometres by car by 2030.
Land Use:
• Welcome the new agriculture outcome, environmental conditionality and desire to scale up action, draw in private investment and overcome barriers. Specifics lacking, which is worrying given this is an area of huge importance for Scotland and we need to see more rapid progress. CCPu mainly announces process / proposals rather than targets and details.
• The current emissions envelope for agriculture is the weakest of all sectors, with only a 24% reduction envisaged by 2032 (compared to 43% for industry, 50% for waste and 40% for transport for example). This is in the context of very limited emission reductions in the agriculture sector over the past 10 years. On this trajectory the agriculture sector will become the biggest emitting sector in Scotland by the 2040s (being around 4.3 MTCO2e by 2040) and so require a huge amount of NETs in order to meet the 2045 net zero target for Scotland. We do not think this is justified in terms of requiring more action in other sectors, nor is it the best use of public money (i.e. direct payments with conditions that only deliver a relatively small emissions reduction) in a climate emergency.
• There is a significant risk that Scottish Food & Drink loses market advantage in terms of low emissions intensity production (e.g., vs more ambitious changes in England) and so ultimately industry suffers through protection of ‘business as usual’ practice.
• The expansion of the agricultural transformation fund is welcome but, again, it is focused on capital spend. Very doubtful how much the current scheme will actually reduce emissions (seems more focused on productivity) and still needs robust capacity building strategy for adoption and use of new equipment and practices. Cost/benefit analysis should be used to score applications rather than a simple menu of options.
• Environmental conditionality is positive but lacking in detail – scope, measures and scale. Must move from voluntary best practice guides to clear mandatory conditionality and prioritise / resource rapid roll out.
• Increase in annual tree planting targets welcomed but must be done in a transparent and consultative way. The RLUPs represent an important mechanism to avoid push backs and delays, and to ensure communities and stakeholders are involved in woodland expansion that affects their own areas.
• Welcome commitment to climate friendly diet guidance. Awaiting Statement of Policy on Food and Local Food Strategy. We understand the sensitivities around dietary advice, but changing diets are a core part of the net zero transition and can deliver improved human health outcomes too. Opportunity for greater leadership by public and private sectors. An emphasis on local food is important in terms of sustainability and local economies, and it avoids food miles and ‘off-shoring’ emissions for products like red meat which is produced at a lower emissions intensity in Scotland. However, in most cases it does not actually deliver significant emissions reductions compared to an emphasis on increasing the proportion of plant-based food in diets. The UK CCC 6th carbon budget report includes targets on reduced meat / dairy intake.
• We need an integrated, whole system approach to food policy, that secures meaningful emissions reductions - a framework Good Food Nation Bill could help do this.
• in most cases it does not actually deliver significant emissions reductions compared to an emphasis on increasing the proportion of plant-based food in diets. The UK CCC 6th carbon budget report includes targets on reduced meat / dairy intake.
• No ban on peat extraction – but desire to accelerate action to phase out, though missed opportunity to set the timescale in the CCPu. Stronger use of planning system in Scotland (not support new commercial and facilitate restoration) to come in through NPF4. Acknowledge need to do much more to restore degraded peatlands. (note CCC has targets for 60% restoration and a ban on extraction).
• Welcome commitment to RLUPs and emphasis should be on rolling out to all parts of Scotland working with all land uses/types from the outset. They will be crucial in delivering the net zero transition in the LULUCF and agriculture sectors so the post-CAP rural support regime should be fully integrated into RLUP development. Local governments must be resourced to take part as they will be key to success.
4. To what extent do you think the proposals and policies reflect considerations about behaviour change and opportunities to secure wider benefits (e.g. environmental, financial and health) from specific interventions in particular sectors?
Please enter your response in the text box provided.
Behaviour change
The CCC states that reaching net-zero will require more involvement from people in changing to less energy intensive ways of eating, getting around and heating their homes. The CCC estimates that more than half of the emissions reductions for net-zero will involve some element of behaviour change (UK CCC, 6th Carbon Budget report). 40% involves adopting a new technology (e.g. heat pump, EV) and 15% involves making different choices, such as a healthier diet or traveling by foot, bike, or public transport instead of the car.
The Scottish Government’s publication of the draft public engagement strategy is welcome. Public understanding and awareness of the climate crisis has placed the climate emergency at the top of the political agenda. The public want to see changes to their economy and society to cut emissions, but gaps do exist in individuals’ understanding of the speed and breadth of the changes needed. We are encouraged by the draft strategy which puts an emphasis on engagement with the public on the net-zero agenda, co-creating policies and their delivery, and framing new action as an opportunity rather than a burden.
With the UN COP conference on climate change on our doorstep in November, 2021, Scotland has a unique opportunity to involve the public, private and public sector with showcasing ‘net zero in action’ – by communities, businesses, the public sector – and how it can be achieved in a fair and inclusive way – leaving no one behind. We have two recommendations relating to public engagement:
1) It is vital that public engagement is a key component of the many policies and programmes in the CCPu. For example, there are commitments for public engagement plan on heat decarbonisation in buildings and on food and food waste. Similar efforts are required, working on a cross-sectoral basis where needed, for other flagship policies such as 20 minute neighbourhoods, regional land use plans, and reducing car usage. This upfront investment in engagement will lead to positive change in attitudes to the low carbon transformation, greater uptake of new technologies, and less need for enforcement of low carbon behaviours in the future.
2) It is critical that the public sector demonstrates best practice, for example through the procurement of low carbon goods and services, with specific targets and timelines to achieve them, and by enabling and encouraging behaviour change by their employees – for example travel, food waste, and heating. The public may be unwilling to make their own changes if they see public sector bodies and their schools, hospitals and local authorities continue with ‘business as usual’. This is why CERG have prioritised the mobilisation of public procurement for net-zero with the setting of clear targets for products and services – essentially ‘choice editing’ so the low carbon product is the norm.
Just Transition, Green Recovery and wider benefits:
We welcome the CCPu’s framing in terms of the green recovery and the just transition to net-zero. Indeed, given the current economic crisis and climate emergency, there is an imperative to invest public money and incentivise private investment to deliver a fairer, greener and more resilient Scotland as part of our recovery from COVID-19. Therefore, the CCPu should include the public spending, fiscal stimulus measures and policy levers which will achieve the most in accelerating Scotland’s response to the climate emergency, while improving public health and well-being, equalities, and economic outcomes.
CERG identified the following priority areas in its Green Recovery report which have been addressed to varying degrees in the CCPu (see also answer to question 2). We supply commentary below in italics.
• City and Town Infrastructure Transformation Programme
Infrastructure improvements for active travel, public transport, green spaces and community hubs are ‘shovel ready’ projects (or could rapidly reach this point) which would provide immediate construction jobs. Making our cites more attractive and liveable, will boost local jobs, businesses and retail. The COVID-19 crisis has taught us about the importance of good air quality, green spaces for physical and mental health, and community resilience. It can be combined with other decarbonisation projects such as district heating and EV charging networks.
The CCPu does not include commitments to city and town transformations but does set out a vision of more integrated transport, planning and active travel. The CCPu mentions the concept of ’20 minute neighbourhoods’ but does not commit to a process or funding to develop these with local authorities. There is concern that the ambitious reduction in car kilometres driven will not be reached without further policies and programmes to support this change through incentives and regulation (see SPICe briefing).
• Retrofit buildings for a net-zero Scotland
Energy efficiency is a rapidly expandable and scalable infrastructure investment, with extensive co-benefits and multipliers giving a good return on government investment. Delivered alongside a rapid uptake in low carbon heat, the jobs and manufacturing potential is even greater.
The CCPu confirms this is a major priority for the Scottish Government receiving significant multi-year investment. CERG recommends that existing fuel poverty and energy efficiency programmes should be doubled in scale and budget starting in 2021/22 to maximise job creation and locking in emissions reduction as soon as possible.
• Rural jobs creation programme
With rural areas particularly hard hit by the economic effects of the global pandemic, and with large amounts of climate emergency work that needs to take place on the land, there are good opportunities for rural job creation
The CCPu confirms increased targets for tree planting, commits to produce guidance on sustainable food, and to accelerate action on peatlands. In addition, CERG recommends more emphasis is placed on the skills development alongside these carbon reduction measures to ensure maximum impact. CERG is also concerned that Scottish producers could lose market advantage if they fall behind in low emissions intensity production.
• Green Enterprise support
Learning from the COVID-19 response, there are opportunities for new business models which contribute to community wealth building, shorten value chains, and transfer assets to local communities. For example – local food systems, community work hubs, and circular economy business practices.
The CCPu gives a commitment to a ‘work local programme’ and developing a local food strategy. We look forward to learning more about the details and timescales of these commitments. There are also commitments to use public procurement to support the circular economy.
The CCC states that reaching net-zero will require more involvement from people in changing to less energy intensive ways of eating, getting around and heating their homes. The CCC estimates that more than half of the emissions reductions for net-zero will involve some element of behaviour change (UK CCC, 6th Carbon Budget report). 40% involves adopting a new technology (e.g. heat pump, EV) and 15% involves making different choices, such as a healthier diet or traveling by foot, bike, or public transport instead of the car.
The Scottish Government’s publication of the draft public engagement strategy is welcome. Public understanding and awareness of the climate crisis has placed the climate emergency at the top of the political agenda. The public want to see changes to their economy and society to cut emissions, but gaps do exist in individuals’ understanding of the speed and breadth of the changes needed. We are encouraged by the draft strategy which puts an emphasis on engagement with the public on the net-zero agenda, co-creating policies and their delivery, and framing new action as an opportunity rather than a burden.
With the UN COP conference on climate change on our doorstep in November, 2021, Scotland has a unique opportunity to involve the public, private and public sector with showcasing ‘net zero in action’ – by communities, businesses, the public sector – and how it can be achieved in a fair and inclusive way – leaving no one behind. We have two recommendations relating to public engagement:
1) It is vital that public engagement is a key component of the many policies and programmes in the CCPu. For example, there are commitments for public engagement plan on heat decarbonisation in buildings and on food and food waste. Similar efforts are required, working on a cross-sectoral basis where needed, for other flagship policies such as 20 minute neighbourhoods, regional land use plans, and reducing car usage. This upfront investment in engagement will lead to positive change in attitudes to the low carbon transformation, greater uptake of new technologies, and less need for enforcement of low carbon behaviours in the future.
2) It is critical that the public sector demonstrates best practice, for example through the procurement of low carbon goods and services, with specific targets and timelines to achieve them, and by enabling and encouraging behaviour change by their employees – for example travel, food waste, and heating. The public may be unwilling to make their own changes if they see public sector bodies and their schools, hospitals and local authorities continue with ‘business as usual’. This is why CERG have prioritised the mobilisation of public procurement for net-zero with the setting of clear targets for products and services – essentially ‘choice editing’ so the low carbon product is the norm.
Just Transition, Green Recovery and wider benefits:
We welcome the CCPu’s framing in terms of the green recovery and the just transition to net-zero. Indeed, given the current economic crisis and climate emergency, there is an imperative to invest public money and incentivise private investment to deliver a fairer, greener and more resilient Scotland as part of our recovery from COVID-19. Therefore, the CCPu should include the public spending, fiscal stimulus measures and policy levers which will achieve the most in accelerating Scotland’s response to the climate emergency, while improving public health and well-being, equalities, and economic outcomes.
CERG identified the following priority areas in its Green Recovery report which have been addressed to varying degrees in the CCPu (see also answer to question 2). We supply commentary below in italics.
• City and Town Infrastructure Transformation Programme
Infrastructure improvements for active travel, public transport, green spaces and community hubs are ‘shovel ready’ projects (or could rapidly reach this point) which would provide immediate construction jobs. Making our cites more attractive and liveable, will boost local jobs, businesses and retail. The COVID-19 crisis has taught us about the importance of good air quality, green spaces for physical and mental health, and community resilience. It can be combined with other decarbonisation projects such as district heating and EV charging networks.
The CCPu does not include commitments to city and town transformations but does set out a vision of more integrated transport, planning and active travel. The CCPu mentions the concept of ’20 minute neighbourhoods’ but does not commit to a process or funding to develop these with local authorities. There is concern that the ambitious reduction in car kilometres driven will not be reached without further policies and programmes to support this change through incentives and regulation (see SPICe briefing).
• Retrofit buildings for a net-zero Scotland
Energy efficiency is a rapidly expandable and scalable infrastructure investment, with extensive co-benefits and multipliers giving a good return on government investment. Delivered alongside a rapid uptake in low carbon heat, the jobs and manufacturing potential is even greater.
The CCPu confirms this is a major priority for the Scottish Government receiving significant multi-year investment. CERG recommends that existing fuel poverty and energy efficiency programmes should be doubled in scale and budget starting in 2021/22 to maximise job creation and locking in emissions reduction as soon as possible.
• Rural jobs creation programme
With rural areas particularly hard hit by the economic effects of the global pandemic, and with large amounts of climate emergency work that needs to take place on the land, there are good opportunities for rural job creation
The CCPu confirms increased targets for tree planting, commits to produce guidance on sustainable food, and to accelerate action on peatlands. In addition, CERG recommends more emphasis is placed on the skills development alongside these carbon reduction measures to ensure maximum impact. CERG is also concerned that Scottish producers could lose market advantage if they fall behind in low emissions intensity production.
• Green Enterprise support
Learning from the COVID-19 response, there are opportunities for new business models which contribute to community wealth building, shorten value chains, and transfer assets to local communities. For example – local food systems, community work hubs, and circular economy business practices.
The CCPu gives a commitment to a ‘work local programme’ and developing a local food strategy. We look forward to learning more about the details and timescales of these commitments. There are also commitments to use public procurement to support the circular economy.
5. To what extent do you think the CCPu delivers a green recovery?
Please enter your response in the text box provided.
Please refer to our answer to question 4.
We believe the CCPu demonstrates how action to address the climate emergency is also a good way to recover our economy from the impacts of COVID-19 and make Scotland more resilient and able to respond to further emergencies in the future – such as adapting to climate impacts of flooding or more stormy weather.
In particular, we welcome the initiatives in the PFG 20 and CESAP around jobs and skills for a green recovery e.g. National Transition Training Fund / Green Jobs Workforce Academy / Green Jobs Skills hub (but unclear what resources, scope and scale for the latter two initiatives).
We believe that there is a need to do more in terms of front-loading low carbon investments and reviewing high carbon infrastructure plans to prevent a post-COVID return to business as usual.
As a final comment on the green recovery, we know it cannot be funded solely through public funding. The Scottish Government can secure additional investment by creating an attractive policy environment for investors, resulting in stronger business cases and channelling investment in the right direction. The securing of private investment through greater policy certainty is at least as important as the role of public sector investment. It is essential that the CCPu policies and programmes provide that policy certainty through supportive programmes, fiscal measures and regulation (generally to level the playing field) so that viable economic cases for investment can be made.
We believe the CCPu demonstrates how action to address the climate emergency is also a good way to recover our economy from the impacts of COVID-19 and make Scotland more resilient and able to respond to further emergencies in the future – such as adapting to climate impacts of flooding or more stormy weather.
In particular, we welcome the initiatives in the PFG 20 and CESAP around jobs and skills for a green recovery e.g. National Transition Training Fund / Green Jobs Workforce Academy / Green Jobs Skills hub (but unclear what resources, scope and scale for the latter two initiatives).
We believe that there is a need to do more in terms of front-loading low carbon investments and reviewing high carbon infrastructure plans to prevent a post-COVID return to business as usual.
As a final comment on the green recovery, we know it cannot be funded solely through public funding. The Scottish Government can secure additional investment by creating an attractive policy environment for investors, resulting in stronger business cases and channelling investment in the right direction. The securing of private investment through greater policy certainty is at least as important as the role of public sector investment. It is essential that the CCPu policies and programmes provide that policy certainty through supportive programmes, fiscal measures and regulation (generally to level the playing field) so that viable economic cases for investment can be made.