Download Response to consultation on Climate Change Bill Scotland

Consultation Response
Climate Change: a consultation on
proposals for a Scottish Climate Change
Bill
Jonathan Hughes
Head of Policy
June 2008
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
About the Scottish Wildlife Trust (SWT)
The Scottish Wildlife Trust (SWT) was founded in 1964 to take all appropriate
measures to conserve the fauna, flora, and all objects of natural history in trust
throughout Scotland. With 30,000 members, several hundred of whom are actively
involved in conservation activities locally, we are proud to say we are now the largest
voluntary body working for all the wildlife of Scotland. The Trust owns or manages
124 wildlife reserves and campaigns at local and national levels to ensure wildlife is
protected and enhanced for future generations to enjoy.
Introduction
SWT welcomes this opportunity to contribute to the development of the Scottish
Climate Change Bill. SWT believes that quite apart from the direct impact on
humanity, climate change is also one of the biggest threats that Scotland’s natural
environment has ever faced. In relation specifically to biodiversity threats, a recent
report by the UK Biodiversity Partnership1 identified a number of direct key impacts of
climate change upon ecosystems as evidenced from observational data and models
of future trends. These include:
• changes to habitats and ecosystems, such as altered water regimes
increased rates of decomposition in bogs and higher growth rates in forests
• changes to the composition of plant and animal communities
• changes in the timings of seasonal events, leading to loss of synchrony
between species and the availability of food, and other resources upon which
they depend
• shifts in suitable climate conditions for individual species leading to change in
abundance and range changes in the habitats which species occupy
SWT urges the Scottish Government to ensure not only that GHG emissions targets
are achieved rapidly to limit the impact of climate change on the natural environment,
but also urgently implements a package of adaptation measures under the Scottish
Climate Change Adaptation Strategy.
Summary of SWT recommendations
In addition to the detailed comments under the questions posed in the consultation
document, we have provided a summary of some of our key recommendations
below.
SWT recommends the Bill:
• Sets long and medium term greenhouse gas reduction (GHG) targets.
The Bill should require Government to keep within a fair share of global
greenhouse gas emissions, at a level that restricts temperature rise to 2°C.
Based on current scientific evidence this requires an overarching target to
reduce greenhouse gases by at least 80% by 2050, based on 1990 levels. An
interim target of 50% by 2020 should also be included as this is consistent
with preventing an above 2°C rise.
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UK BAP Partnership (2007) Conserving biodiversity in a changing climate. Defra.
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
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Sets statutory annual GHG reductions of at least 3%. Year on year cuts of
at least 3% will be required to ensure that overall targets are met. Lower rates
of annual progress will mean a higher level of cumulative emissions.
Includes a duty on all public bodies to deliver their climate change
responsibilities in a manner that furthers the delivery of sustainable
development and the conservation of biological diversity.
Ensures climate change is tackled sustainable way which does not lead
to irreversible damage to the natural environment and biodiversity. The
Bill should require future policies for mitigation and adaptation to be
developed in accordance with the principles of sustainable development,
including the conservation and enhancement of biodiversity (see also above
regarding ‘sustainability duty’).
Introduces a requirement on Scottish Ministers to adapt to climate
change. The Bill must include a requirement on Ministers to produce an
adaptation strategy that includes environmental measures as well as a
statutory requirement to regularly report on progress with adaptation
measures.
Includes international aviation and shipping in targets. International
aviation and shipping emissions should be accounted for in targets, based on
traffic through Scottish ports and airports.
Sets up an independent Scottish Climate Change Commission to advise
Government and monitor and report on the implementation of the Bill.
Revises targets as necessary using sound science. Climate Change
policy is complex and constantly developing; therefore the Bill should
establish an independent climate change Commission to advise Government.
Ensures transparency and accountability. Ministers must be required to
report annually to Parliament on the previous year’s progress towards
meeting allocated budgets and their future plans for doing so. As well as
reporting on the impact of climate change and Government’s progress on
adaptation work.
Consultation questions
1. Should a Scottish target be based on carbon dioxide only or the basket of
six greenhouse gases?
SWT urges the Government to base the reduction target of 80% on the basket of
six greenhouse gases (GHGs). A target which takes the basket approach is
consistent with both the Kyoto Protocol and Scotland’s Climate Change Programme.
The UK Government already collects and reports emissions of all six key greenhouse
gases for Scotland and reports them as carbon equivalent so this approach would
not mean any additional costs.
It should be noted that non-CO2 emissions in Scotland make a significant contribution
to Scotland’s climate emissions with around 16% coming from N2O and CH4 from
land use, soils and agricultural activity. Another important source is aviation, a sector
responsible for many non CO2 emissions. The IPCC has estimated that the climate
change impact of aircraft emissions is between two and four times greater than CO2
emissions alone. It is therefore essential that Scotland’s share of GHGs arising from
aviation (and shipping) is included in the Bill.
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
2. Should the Bill contain provisions to alter which gases are included, for
example if the reliability of data for a particular gas improves or if science
changes in the future about which gases cause climate change?
Yes, we think it makes sense to include this provision in the Bill. However, gases
should not be removed without thorough independent research and on the
agreement of an independent Scottish Climate Change Commission.
3. The Scottish Government wishes to ensure that the Bill gives sufficient
incentives to invest in energy efficiency and renewable electricity. Should the
targets be based on source emissions; an end-user inventory; or on individual
targets for energy efficiency and renewable electricity? Do you have any other
suggestions?
SWT welcomes the emphasis in the Bill on incentivising energy efficiency and
renewable electricity which is very much in line with SWT’s Policy on Energy
(Appendix 1). The Bill should place a requirement on Scottish Ministers to produce
and regularly report on an Emissions Reduction Implementation Plan (ERIP).
Such a plan must include details of initiatives to reduce energy demand, improve
energy efficiency and increase the proportion of electricity generated by renewable
sources. The detailed actions in the ERIP will need to be regularly revised to reflect
emerging technologies and climate change science. SWT therefore recommends that
the ERIP should be revised and updated on a rolling three, or four, year timescale.
Specific targets for energy efficiency and renewable electricity should also be
included in the Bill in addition to the main targets relating to demand reduction and
renewable energy generation. Each of these targets should also be set against our
production based emissions. The need to cut production emissions irrespective of
trends in end users is an important point as only applying targets to our electricity
consumption would only capture part of the impact. If targets are based on simply on
consumption based emissions then the actual annual reduction path would have to
be set against all our consumption based emissions, not just those derived from our
electricity use. These targets should be seen along side annual reporting on
Scotland consumption based emissions. This would allow for the balance between
consumption emissions and production emissions to be more transparently set out.
4. Do you agree that the Bill should allow the means of measuring the target to
be changed through secondary legislation to reflect international
developments or unforeseen consequences of the Bill?
Yes, in principle the Bill should allow the means of measuring the target to be
changed through secondary legislation as techniques may improve. However, this
should only happen following scrutiny by independent Scottish Climate Change
Commission and should be based on all available, up to date scientific knowledge.
5. Should the emissions reduction target take account of the abatement effort
made by companies under emissions trading schemes? If so, how?
SWT supports a third option as put forward by WWF Scotland which proposes
including the annually verified emissions from installations covered by the EU ETS
towards the Scottish emission reduction target. In addition to the inclusion of these
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
emissions, the Bill must enable those sectors captured by the ETS to make
reductions in line with the Scottish target.
The current proposal for an EU-wide ETS cap (20% from 2005 levels by 2020) is
considerably less ambitious than the medium-term target for Scotland based on a
minimum annual reduction of 3% a year, and indeed is less than the UK target likely
to emerge as a result of the review due to be conducted by the Committee for
Climate Change (and probably less ambitious than the Government’s proposed
minimum CO2 reduction of 26% by 2020). Although it would be necessary to build a
new process for securing this ‘additional’ level of emissions reduction there is no
preventative barrier to achieving this. Indeed, there are strong reasons why such
extra reductions must be achieved. For instance, the analysis presented by IPPR,
RSPB and WWF in The 80% Challenge report shows that the first step towards the
80% target must be met through rapid and almost complete decarbonisation of the
electricity generation sector.
It is clear that while the ETS has an important role to play it is only one tool in the
toolkit and certainly no substitute for effective national climate change policies. The
Stern Review recognised that carbon markets which are in the early stages of
development are too volatile, and too prone to leakage and poor caps to deliver
mitigation and deployment of new technologies at the speed and scale needed to
avoid dangerous climate change. This analysis is also implicit in the introduction of
UK measures such as the Renewables Obligation, which aims to incentivise
renewable energy generation, despite the fact that the power generation sector is
already included within the ETS.
SWT therefore recommends that the Scottish Government should pursue options
which ensure necessary reductions are secured from those installations captured
under the ETS. The Scottish Government should actively encourage the UK
Government to auction ETS allowances at a level more compatible with its own
domestic targets. Since the UK Government would effectively 'own' the allowances,
whilst it would be entitled to auction up to levels equivalent to the EU cap it would not
be obliged to do so if it wished to reign in emissions further. Although the auction of
ETS allowances will be open to any purchaser in the EU, the UK, and Scotland,
would have ensured additional emissions reductions had occurred in line with the its
agreed reduction pathways.
The impact of this would probably be to very slightly tighten the cap across the whole
EU, thus raising the carbon price slightly. This action would be in line with the UK and
Scotland’s position as global leaders in tackling climate change.
Given the extra rate of reduction demanded by the 80% target in Scotland the
Scottish Government will have to take action to reduce the available further. In order
to do this they could ‘buy out’ credits equivalent to the necessary reduction rate.
6. Do you agree that international credits should be counted towards Scottish
targets? Should there be limits on credits counted towards Scottish targets?
SWT agrees that limited use of international emission reductions should be allowed.
However, we also believe that unconstrained use of international credits could
potentially delay domestic abatement trajectories and encourage investments in high-
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
carbon infrastructure. This could result in still rising greenhouse gas emissions for
decades to come. Furthermore, putting off action at home prevents innovation and
the economic opportunity which could arise from Scotland becoming a world leader
and exporter of climate change mitigation technologies.
Regarding credits from the Clean Development Mechanism (CDM) there is growing
concern that many so called ‘non-additional’ projects are being approved. These are
projects which would have taken place anyway and are therefore actually allowing an
increase in emissions globally when they are used to ‘offset’ emissions in countries
which have taken on caps. A recent report commissioned by WWF suggested that
approximately 20% of the emission reductions certified under the CDM may have
happened anyway2.
The Scottish Government’s current position of not proposing to set a statutory limit on
the amount of international credits is not in line with the necessary emphasis on
driving down the emissions in developed countries and showing the important
leadership required to make this global shift to a low carbon future. Driving down
emissions within Scotland will improve efficiencies; generate investment, jobs and
sustainable economic growth. The purchasing of credits on the other hand will
simply establish a financial flow out of our economy.
7. Should the Bill allow the level of the 2050 target to be changed through
secondary legislation? If so, should this only be allowed on the basis of
independent, expert advice, to reflect international developments or
unforeseen consequences of the Bill? Should any changes to the target be
limited to an increase in the target?
Yes, SWT thinks the Bill should allow for the 2050 target to be increased through
secondary legislation. New figures should be based on independent, expert advice
grounded in the latest scientific research and approved by the Scottish Climate
Change Commission.
SUPPORTING FRAMEWORK
8. What factors should be taken into account when setting the level of
budgets?
SWT believes budgets should be guided by the best available scientific advice and in
the shorter term, the urgent need to sharply reduce GHGs. The ultimate aim of the
budgets must be to ensure no more than a two degree centigrade increase in mean
global temperature.
9. How long should interim budget periods be?
The budget periods should be at least shorter than a Parliamentary term as this will
enable sufficient scrutiny and democratic accountability. SWT believes that this will
still provide sufficient time for new infrastructure such as renewables technology to
develop as early reductions in GHGs arising from in demand reduction and increases
in energy efficiency will not necessarily require new infrastructure anyway.
2 “Is the CDM fulfilling its environmental objectives? An evaluation of the CDM and options for improvement” a report for WWF by the ÖkoInstitut, November 2007.
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
10. How many years in advance should emissions budget periods be set in
order to provide sufficient time to develop infrastructure?
Future budget periods will be set anyway as a result of year on year 3% year on year
targets. The detail and timing of future infrastructure developments should be
outlined in an ERIP and linked to reductions in GHGs but this should not affect the
annual 3% reduction target.
11. What should be the limit (in terms of absolute quantity or as a percentage
of the budget period) on the amount of emissions which the Government can
borrow from a following budget period?
SWT strongly contends that borrowing of no more than 1% should be legally allowed
between budgets. Furthermore, this 1% should only be allowed when the period in
question follows a period where at least a 1% surplus has been banked.
Implementing such a system will avoid getting ever more overdrawn in the early
years of the Bill implementation – exactly the time when it will be most critical to
reduce emissions sharply, rather than borrowing from future periods.
12. Should the Bill include an interim point target? If so, what year (or years)
should it before (2020, 2025, 2030, etc.)? How should the level be chosen?
SWT proposes a statutory annual target of at least 3% reduction in the basket of six
GHGs. Anything less than this annual target will undermine the cumulative effect of
the Bill’s provisions and make scrutiny and accountability much more difficult. This
would substantially weaken the Bill and increase the risk of a rise in global mean
temperature of greater than two degrees. SWT welcomed the SNP’s commitment in
its Manifesto to annual targets and hopes it can now deliver.
REPORTING SCRUTINY AND FRAMEWORK
13. Should the Scottish Ministers be required to report on any other issues
related to climate change in addition to the requirements already set out. If so,
what and how often?
SWT recommends a number of climate change related issues on which we feel
Scottish Ministers should also report. These must include:
• Adaptation reporting on a three yearly basis which includes initiatives to
change the way in which we manage land to ensure biodiversity can better
adapt to climate change e.g. adoption of an ‘ecosystem approach’ to land use
planning including catchment planning initiatives which incorporate both
freshwater and terrestrial elements; tackling overgrazing and erosion in the
uplands, restoring peatlands and damaged forests, creating a National
Ecological Network and regional green and integrated habitat networks to
facilitate the movement and survival of ‘marooned’ species and habitats.
• Sectoral annual reporting by the main sectors (including ‘the public sector’)
responsible for the majority of GHG emissions in Scotland;
• Consumption based reporting which captures Scotland’s total contribution
to global GHG emissions, many of which are effectively ‘exported’ to other
countries;
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
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Registered at Edinburgh under No 40247 Charity Registration No SC005792
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Forecast emissions reporting which projects future emissions on an annual
basis and thereby allows targeting of action;
Impact reporting which captures the effects climate change is having on
Scotland and allows both the ERIP and the Adaptation Strategy to be
modified in response.
14. Is a process of Parliamentary scrutiny the appropriate way of holding the
Scottish Government to account if targets or budgets are not met?
Yes, Parliamentary scrutiny is one important way of holding the Scottish Government
to account. However, there must also be effective sanctions to ensure there is a real
financial incentive to reduce emissions. One way of implementing a sanctions
mechanism could be for the Scottish Climate Change Commission to impose a
financial penalty on the Scottish Government when it fails to hit targets or budgets.
The money could be transferred into a climate change fund which could be used
strategically to further reduce emissions and deliver the adaptation strategy.
15. What should be the primary source of advice to the Scottish Government
for setting emissions targets or budgets and why? Options include: the
proposed UK Committee on Climate Change, a new Scottish Committee on
Climate Change, an existing public body in Scotland, or the Scottish
Government itself.
SWT believes the Bill should set up a Scottish Climate Change Commission as this
will be the best way of ensuring independent scrutiny of the implementation of the
Bill. The Commission needs to be at Scotland level due to the differences in the legal
and political systems between Scotland and UK.
The Commission could be modelled on the Scottish Freedom of Information
Commission, with the Commissioner sitting on the UK Committee. A Scottish
Climate Change Commission could be supported by existing public bodies, such as
SEPA and the Sustainable Development Commission, in the provision of advice and
monitoring.
16. If it were to be an existing Scottish public body, which public body is most
suited to carrying out this task and why?
Given the overarching, cross sectoral nature of the climate change issue, SWT does
not support tasking an existing public body with such an important advisory role. We
believe the rational approach is to establish a Scottish Climate Change Commission
(see Q.15).
17. Which organisation should be tasked with monitoring the progress of the
Scottish Government on reducing emissions and why? Options include: the
proposed UK Committee on Climate Change, a new Scottish Committee on
Climate Change, an existing public body in Scotland, or the Scottish
Government itself.
We believe the monitoring function should be led by a new body, the Scottish Climate
Change Commission (see Qs.15 and 16) working in close partnership with all
relevant parts of Government and other stakeholders.
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Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
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Registered at Edinburgh under No 40247 Charity Registration No SC005792
18. If it were to be an existing Scottish public body, which public body is most
suited to carrying out this task and why?
Given the overarching, cross sectoral nature of the climate change issue, SWT does
not support tasking an existing public body with such an important monitoring role.
We believe the rational approach is to establish a Scottish Climate Change
Commission (see Q.15).
19. Should additional independent mechanisms for scrutinising the
effectiveness of the Scottish Government’s policies in reducing emissions be
created by the Bill (in addition to any scrutiny already provided by the Scottish
Parliament)?
The primary ‘independent mechanism’ should be the Scottish Climate Change
Commission. It would however be useful if the Bill allowed for further independent
mechanisms to be provided for in the future, pending experience with scrutinising the
effectiveness of the Bill and the policies arising from it.
20. If so, which organisation is best placed to carry out this function and why?
Options include a new Scottish Committee on Climate Change or an existing
public body in Scotland.
Given the overarching, cross sectoral nature of the climate change issue, SWT does
not support tasking an existing public body with such an important scrutiny role. We
believe the rational approach is to establish a Scottish Climate Change Commission
(see Q.15 etc).
21. If it were to be an existing Scottish public body, which public body is most
suited to carrying out this task and why?
See Q. 20.
22. Are there any other functions related to climate change, existing or new,
which should be carried out at arm’s length from the Scottish Government and
why?
All identified ‘arm’s length’ functions should be the responsibility of the Scottish
Climate Change Commission with the option (see Q.19) of developing new
independent mechanisms kept open in the future.
SUPPORTING MEASURES
23. Should the Bill contain enabling powers to introduce a duty on certain parts
of the public sector (i.e. local authorities and large public bodies) to take
specified actions on climate change or other specified environmental issues?
Why?
Yes, SWT recommends the Bill contains a sustainability duty on all public bodies to
‘deliver their climate change mitigation and adaptation responsibilities in a manner
that furthers the delivery of sustainable development and the conservation of
biological diversity’. The rationale for this duty is a. that public bodies need to show
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Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
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leadership on this issue and b. cuts in emissions from the public sector could make a
significant contribution to the target of 80% by 2050. SWT would like to emphasize
the link in our proposed duty between the need to tackle climate change and the
need to protect the wider environment. This is why we propose a duty which includes
references to sustainable development and biodiversity conservation (consistent with
the ‘biodiversity duty’ in Part 1 the Nature Conservation (Scotland) Act, 2004). This
will help avoid the madness of destroying the environment in the name of climate
change – a situation which is already a reality with rainforests being felled for biofuel
plantations and carbon sink peatlands being ‘developed’ as renewable energy
installations.
Local authorities should be supported in complying with this duty by amendments to
planning legislation, for example by introducing secondary legislation which sets out
how planning/regulatory authorities should treat climate change as a material
consideration.
24. What should such a duty (or duties) include?
As outlined above, the ‘sustainability duty’ must include reference to the conservation
of biological diversity. In addition we recommend it includes:
• a requirement to report on operational emissions and, in case of local
authorities, regional/area consumption emissions
• a requirement to produce a plan to reduce operational emissions in line with
national targets
• a requirement to ensure strategies and policies will deliver community-wide
consumption based emissions (carbon footprint) reductions, including
engagement with communities (use Local Footprints as an example – text
given above)
• a requirement to publish an annual statement on implementation of the above
requirements
• a progress report against this duty by Audit Scotland
25. Should the Bill contain enabling powers to introduce statutory guidance for
certain public sector bodies (i.e. local authorities and large public bodies) on
specified climate change or other environmental measures? Why? Are there
gaps in any existing guidance?
Yes, the bill should require the provision of statutory guidance to support the public
sector in its implementation of the duty.
26. What should this guidance include?
It is important that guidance should clearly state what must be measured and
monitored. SWT specifically recommends including clear guidance on adaptation
measures. We have identified a number of key threats to the healthy functioning of
ecosystems in Scotland which are likely to be greatly exacerbated by climate change
and where adaptation measures will be required. It should also be noted that
perversely, some threats to biodiversity could be made significantly worse if climate
change mitigation measures are not developed and implemented sustainably (see
‘sustainability duty’ above). Key areas for the guidance to consider in relation to
adaptation include:
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Measures to reduce habitat fragmentation. The affects of habitat
fragmentation acting in concert with climate change will lead to species losses
and potential ‘functional breakdown’ of both terrestrial and marine
ecosystems. This threat is greatest in highly fragmented lowland areas where
the ‘climate space’ for many species is likely to change rapidly but lack of
connectivity between habitats will mean many species will be unable to move
northwards in response.
Measures to ensure appropriate design and location of new
developments and infrastructure. Poorly located and badly designed
developments and infrastructure can further fragment semi-natural habitats,
making ecosystems in urban and peri-urban areas especially vulnerable to
climate change impacts. New and existing transport infrastructures are also a
severe barrier to the movement of many species and are rarely climate
change proofed. Soil sealing and manipulation of natural hydrological regimes
associated with new developments can also exacerbate the impacts of
climate change contributing to flash flooding, poor water quality and general
loss of environmental capital.
Measures the enable marine and coastal ecosystems to adapt. There are
raft of existing threats to the marine environment. These include overfishing,
the arrival of invasive non-native species, inappropriate coastal
developments, increased coastal erosion (with sea level rise), diffuse pollution
from both land and marine sources and new pressures arising from the need
to develop offshore marine renewable energy. The cumulative impact of these
threats is predicted to get significantly worse with climate change, even under
best case scenarios.
Measures to strategically control invasive, non-native species. As
climate space changes so will the species composition of Scotland’s
ecosystems. Some of the species which are already arriving from other parts
of the world are likely to cause severe functional imbalances on both natural
habitats and agricultural systems.
Measures to make farming and forestry practices more sustainable.
There are still many farms and forests in Scotland which are unsustainably
managed. It is these which are most likely to be impacted by climate change
as they are generally the least ecologically robust areas within the rural
landscape. For example, farms without riparian buffer zones which are
heavily dependant on manufactured fertilizers are likely to suffer from soil
degradation and contribute to pollution (particularly nitrates) of freshwaters.
Similarly, forests which are not managed using low impact silvicultural
systems (such as continuous cover) are more likely to suffer soil loss and
degradation, biodiversity loss and windthrow (associated with predicted
increase in severe weather events).
Measures to tackle overgrazing and soil degradation. The affects of
overgrazing (mainly by red deer and sheep) in many parts upland Scotland
are already causing erosion of peatland soils, particularly on blanket bogs
which have been burned and drained in the past. Increased total winter
rainfall, increased intensity of rainfall and summer droughts are likely to cause
further erosion of these soils with potentially catastrophic impacts on peatland
ecosystems, and the freshwater systems they drain into.
Measures to prevent or ameliorate climate change mitigation measures
impacting on the wider environment. As Scotland responds to the climate
crisis it will need more renewable energy. This is already placing heavy
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burdens on the terrestrial environment and will soon begin to affect the
marine environment. Current impacts include: the incentivisation of biofuels
planting without proper guidance or forethought of the ecological impacts;
windfarms located on sensitive peatland soils or in areas of high bird
biodiversity; the need for high impact transmission infrastructures to bring
electricity from remotely located sources; the loss of peat soils due to
increased erosion drivers.
27. Should the Bill contain enabling powers to create a requirement for certain
public sector bodies (i.e. local authorities and large public bodies) to make
regular reports on specific measures they are taking to tackle climate change
(whether mitigation or adaptation) or other environmental issues? Why? What
should be included in such reports?
Yes, SWT recommends the Bill should require regular reporting to be a condition of
compliance with the duty to reduce emissions, as set out under Q24. Reporting is
necessary to ensure transparency of action, confidence in reporting, shared learning
across the public sector and accountability.
28. As a potential non-legislative measure, should current Best Value guidance
be amended to take specific account of climate change mitigation and
adaptation? If so, how should Best Value guidance be amended?
SWT has no view on this issue.
29. Are there any amendments to existing legislation or any enabling powers
needed to allow for variable charging (for example by local authorities) to
incentivise action or eliminate perverse incentives?
Yes, we recommend that existing legislation is reviewed with a view to developing
incentives that could be introduced by local authorities to reduce GHG emissions,
particularly in the areas of energy efficiency, public transport and waste minimisation.
30. Are there any provisions to help Scotland adapt to the impacts of climate
change which should be included in the Scottish Climate Change Bill?
Yes, SWT feels very strongly that the Bill must require the statutory implementation
of a Scottish Climate Change Adaptation Strategy. The strategy and the requirement
to report on its implementation must be rooted in primary legislation.
31. Should provisions within the Environmental Assessment (Scotland) Act
2005, be amended in order to provide clearer links with emissions reduction? If
so, how should this be done?
Yes, amendments should be made to the Environmental Assessment (Scotland) Act
2005 so it is better placed to support the Bill. Specifically, the amendments should:
• require the collation and presentation of data where the scoping study has
identified that the plan, programme or strategy is likely to have a significant
impact on climate change adaptation grounds or GHG emissions increases.
Currently, the Act only requires the presentation of data where it already
exists, this has the potential to provide an incomplete assessment of the
climate change impacts
12 Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792
•
•
list the Scottish Climate Change Commission as a relevant consultee body
strengthen the mandate to reject plans, programmes or strategies where
assessment has identified a likely significant climate change impact
(adaptation or GHG emissions). At the moment the conclusions of the SEA
only need to be considered and as such have a variable impact on the
decision making process
32. What are the equalities implications of the measures in the proposals for
the Scottish Climate Change Bill?
SWT has no comment on this issue.
33. Is there any existing legislation within the competence of the Scottish
Parliament (devolved) which needs to be amended so that appropriate action
on climate change can be taken by sectors in society?
As a general point of good practice the Scottish Government should review all
existing legislation to ensure it not only takes account of climate change but seeks to
make a positive contribution to the goal of an 80% reduction. SWT specifically
recommends the Scottish Government transposes and applies Articles 10 and 12 of
the Habitats Directive as part of its commitment to climate change adaptation.
13 Pr ot ect i ng Scot l and’ s w il dl if e f or t he f ut ur e
Headquarters: Cramond House, 3 Kirk Cramond, Edinburgh EH4 6HZ
●Tel: 0131 312 7765 ●Fax: 0131 312 8705 ●Email: [email protected]
Registered at Edinburgh under No 40247 Charity Registration No SC005792