This response was submitted by the ClimateXChange Directorate to the Scottish Government consultation on the Climate Change Bill in September 2017. Read a summary of all the consultation responses.
Proposals on updating target ambition
- Do you agree that the 2050 target should be made more ambitious by increasing it to 90% greenhouse gas emission reduction from baseline levels?
Yes. We welcome the increased ambition. We note the advice of the UK Committee on Climate Change stating that a pathway to net-zero by 2050 cannot be reliably drawn from the evidence we have on technologies and costs today. It is vital that Scotland continues to be in the vanguard on ambition globally. We believe that net-zero is an ambition that must be kept in play with active efforts required to design a pathway to net-zero for Scotland. It is important that the 2050 target is described as ‘at least 90%’ in the Bill.
- Do you agree that the Climate Change Bill should contain provisions that allow for a net-zero greenhouse gas emission target to be set at a later date?
Yes. However, the provision needs to clearly spell out the mechanism by which this new target would be set and that it must be put on a statutory footing and replace the 2050 90% target.
3a. Do you agree that the 2020 target should be for greenhouse gas emissions to be at least 56% lower than baseline levels?
Yes. We are effectively locked in to the savings we will get from policies already in place, so the 2020 target needs to be consistent with the level of reductions we anticipate those policies delivering.
3b. Do you agree that a target should be set for greenhouse gas emissions to be at least 66% lower than baseline levels by 2030?
Yes, this is consistent with a target of at least 90% by 2050.
3c. Do you agree that a target should be set for greenhouse gas emissions to be at least 78% lower than baseline levels by 2040?
Yes, this is consistent with a target of at least 90% by 2050.
- Do you agree that annual emission reduction targets should be in the form of percentage reductions from baseline levels?
Yes
- Do you agree that annual targets should be set as a direct consequence of interim and 2050 targets?
Yes. This is the logical consequence of moving to fixed percentage interim targets.
Actual Emissions
- Do you agree that all emission reduction targets should be set on the basis of actual emissions, removing the accounting adjustment for the EU ETS?
Yes. This was one of the most confusing aspects of reporting under the 2009 Act. It also meant that the strides in decarbonisation made in those industries covered by the ETS were not duly recognised in communication about progress against the targets.
Reviewing Targets and Reporting on Policies and Proposals
7a. What are your views on allowing the interim and 2050 emission reduction targets to be updated, with due regard to advice from the CCC, through secondary legislation?
Secondary legislation may be best applied to the interim targets, whilst the 2050 target should only be altered after getting over the higher hurdle of the primary legislation process. Regarding the use of secondary legislation for amending the interim targets, the Bill should require additional public consultation and engagement so that opportunities for public debate outside parliament are not missed.
7b. What do you think are the most important criteria to be considered when setting or updating emission reduction targets?
The criteria currently in the 2009 Act seem appropriate, although if the first criterion is amended, it should retain reference to Scotland’s cumulative emissions budget and to the moral case for action.
8a. What are your views on the frequency of future Climate Change Plans?
A 5-yearly cycle fits with parliamentary and UNFCCC cycles. It is also consistent with other legislative 5-yearly cycles (for example the Climate Change Risk Assessment and Adaptation Programme) and the Paris stock-take cycle. Further, it is appropriate when considering the pace of technological, economic and social change – a higher frequency (say 2-years) would be too short to allow policies to mature and take effect in order to be robustly evaluated for effectiveness, whilst a longer cycle (say 10-years) would greatly reduce flexibility for policies to respond to technological, economic and social change.
8b. What are your views on the length of time each Climate Change Plan should cover?
Based upon our experience of working closely with and providing expert advice into policy processes around climate change planning, the current 16 years seems about right. If plans and interim targets are set 5-yearly and 10-yearly, the right period for future Climate Change Plans might arguably be 15 years.
8c. What are your views on how development of future Climate Change Plans could be aligned with Paris Stocktake Processes?
It would be useful to have national values that could feed into the Paris Stocktake Process – so providing national values the year before each Paris Stocktake Deadline (every 5 years) would allow Scotland to feed in to that process.
- What are your views on the proposal that any shortfall against previous targets should be made up through subsequent Climate Change Plans?
This appears to be sensible: there needs to be some means of adjusting ambition and delivery in light of underperformance and this needs to be anchored to the national planning process. However, there is a risk that a time lag is introduced if the shortfall were discovered soon after a Plan was agreed.
Accessing the wider impacts of the proposals
- What are your views on these initial considerations of the impact of the Bill proposals on Scotland’s people, both now and in future generations?
It is good to see that Scotland is considering fully the rights and needs of future generations as well as current generations. More emphasis is being placed on the rights and needs of future generations in the scientific discourse about climate change (see Hansen et al., 2013; Hansen et al. 2017).
Refs: Hansen, J., Kharecha, P., Sato, M., Masson-Delmotte, V., Ackerman, F., Beerling, D., Hearty, P.J., Hoegh-Guldberg, O., Hsu, S.L., Parmesan, C., Rockstrom, J., Rohling, E.J., Sachs, J., Smith, P., Steffen, K., Susteren, L.V., von Schuckmann, K. & Zachos, J.C. 2013. Assessing ‘‘dangerous climate change’’: required reduction of carbon emissions to protect young people, future generations and nature. PLoS ONE 8 (12), e81648. doi:10.1371/journal.pone.0081648. Hansen, J., Sato, M., Kharecha, P., von Schuckmann, K., Beerling, D. J., Cao, J., Marcott, S., Masson-Delmotte, V., Prather, M. J., Rohling, E. J., Shakun, J., Smith, P., Lacis, A., Russell, G. & Ruedy, R. 2017. Young people’s burden: requirement of negative CO2 emissions. Earth Systems Dynamics, 8, 577-616, https://doi.org/10.5194/esd-8-577-2017
12b. What are your views on the predicted environmental effects as set out in the Environmental Report?
We welcome the fact that potential conflicts between mitigation and other key policy objectives (e.g. biodiversity conservation) were visible throughout the report. These potential indirect impacts of climate change mitigation should be managed to ensure that Scotland’s other international obligations, e.g. on biodiversity, water quality and ecosystem health, are also promoted.
Other issues
- Please use this space to tell us any other thoughts you have about the proposed Climate Change Bill not covered in your earlier answers.
Although there is now a compelling climate science evidence base (and significant momentum in international climate policy efforts) for the shift to a 90% emissions reduction target (and raised interim targets), there is as yet little established evidence or shared appreciation (in Scotland or internationally) of the economic and social implications involved. It is vital that such evidence be generated, and interrogated by the scientific community and wider publics.
Inevitably, there will be considerable uncertainties associated with any ‘90% by 2050 pathway’ for Scotland’s decarbonisation efforts, but it is only by exploring a range of assumptions and outputs that the feasibility and implications of such a shift can be properly considered across all parts of the economy. We therefore encourage the Scottish Government, working with independent expertise available in the Committee on Climate Change, ClimateXChange and elsewhere, to support the development of the evidence base.