8 ADDITIONAL COMMENTS
8.1 This chapter presents the findings on Questions 7 in the consultation document:
Q7: Please provide any additional comments you have on any aspects of the consultation.
8.2 Forty five respondents made additional comments. Some respondents used this question to restate points they had already made in their responses to previous questions. Other respondents, particularly those who felt the consultation questions had not given them the opportunity to air their views, used this opportunity to make more general statements about the government's approach to tackling climate change. The relatively large number of people who responded to this question suggests that the substantive questions contained within the consultation did not always fit with the points that respondents wanted to make with regard to the issues raised in the consultation document.
Planning and Land Use
8.3 Planning was restated in respondents' comments as one of the most important issues affecting Scotland's ability to successfully adapt. There was some serious concern expressed about the lack of emphasis on planning in the Framework.
8.4 It was the view of one Third sector organisation that infrastructure in Scotland is so interactive between its multiple parts (railways, roads, bridges, sewers, energy plants etc), that it should be regarded as a "single, multi-component, infrastructural system." As a result, Scotland's vulnerability to "major catastrophe" is increased. Only substantial investment now will reduce this vulnerability.
8.5 One Third sector organisation argued that the SRDP is not sufficiently enough resourced to be taken up by land managers. It also criticised SRDP for being too short term. The current situation, as outlined by this respondent, is that only woodland measures have to be planned for more than 5 years in advance. However, this organisation feels that all measures should be just as long-term, because only long-term measures will build resilience to climate change.
8.6 It was argued by one Third sector respondent that planning rules at local and national level need to be joined-up.
8.7 It was the view of one public sector organisation that Action 9 of the consultation document should include corporate planning across the public sector and not just Scottish Government.
8.8 A more general comment from a Third sector organisation was to emphasise the importance of the Land Use Strategy and the need for it to take account of ecosystem resilience.
8.9 On the issue of land use, one public sector organisation suggested that it was "inconsistent and potentially unhelpful" to partition rural land use management into the two categories of agriculture and woodland. This respondent recommended an integrated land-management strategy instead. This would encourage farmers to recognise the importance of an integrated and balanced approach to land management e.g. promoting the combining of tree-cover with under-cover cropping and grazing to help reduce green house gas emissions.
8.10 With regards to agriculture in Scotland, one business respondent commented that when considering any adaptation measures, it was important to bear in mind the economic trade-offs which are involved. It was the view of this organisation that most adjustments will entail additional costs in the form of extra efforts, income foregone, or the loss of some public goods.
8.11 The same respondent suggested a number of ways in which agriculture could adapt to a changing climate: within season or year-on-year adjustments to the type of land use systems used (including the choice and mix of particular enterprises); changing operational and management practices (for example, through risk or business management methods of adjustment such as diversification, insurance and marketing); changing farming practices; and conducting research into new cultivars and livestock breeds.
8.12 In terms of the property industry, one business emphasised the effects of changes to how flood risk is categorised. For example, changes in SEPA's risk assessments could make major development projects unviable. Equally, increasing the number of higher flood risk assessments for land and property could have serious repercussions for the insurance industry.
8.13 This same business respondent emphasised the need for an evidence-based approach to policy-making. However, various "odd omissions" led this respondent to question how far evidence is currently informing policy making. For example, Energy Performance Certificates for commercial properties, introduced to influence the behaviour of property investors and tenants, are not recorded on a central database as they are in England. This was seen as a major oversight in terms of following through on policies which have a proven track record.
Natural Environment
8.14 A number of respondents felt the need to reiterate their concern about building the resilience of the natural environment. One public sector respondent recommended modifying the strategic aim so that it reads "to increase the resilience of Scotland's economy, society, and environment to the impacts of climate change."
8.15 As previously emphasised in responses to Question 1 on Cost-Benefit Analyses, a few organisations reiterated that loss of biodiversity does not have a comparable monetary value and that the costs of climate change should not only be considered in financial terms.
8.16 A Third sector organisation felt that the consultation's key omission was ecological adaptation, particularly the exclusion of the work by the Forestry Commission on their climate change action plan.
8.17 The same Third sector respondent asserted the need to conserve and create landscapes that will be welcoming to wildlife in times of rapid change. In order for habitats to reach maturity, it was stated that action needed to be taken now. Natural eco-systems also provide "services" such as flood relief, healthy soils, carbon sinks and future sequestration, water quality, and renewable natural resources. Woodland is also a key component. It was advised that the government should restore ancient woods and other wildlife habitats planted with non-native conifers, and create new wildlife habitats in suitable locations.
8.18 According to one public sector organisation, the importance of protecting Scottish soils is not conveyed strongly enough in the proposed Framework. This organisation highlights that soil is not only an immense carbon deposit, it also absorbs rainwater and thereby reduces the risk of flooding. By promoting soil quality, it is suggested, mitigation and adaptation measures are addressed together. In Section 2.12 of the consultation document on environmental policies, this organisation found no mention of the link between soil and climate change.
8.19 The same organisation felt that the section on the water environment focuses on the effects of heavier rainfall and increasing temperature, and ignores the likely increase in low flows which will occur, even without increased abstraction.
8.20 A couple of respondents questioned what the role of SEPA was and asked why it had not been defined better in the consultation document.
8.21 A Third sector organisation suggested establishing a Scotland-wide strategic plan for energy developments:
"in order to maximise adaptation of our energy sources and mix without incremental loss of landscape, wildness characteristics, and biodiversity." (Third sector)
Scottish Climate Change Impacts Partnership ( SCCIP)
8.22 A number of organisations made further comments about the SCCIP, in addition to those already made in response to Question 3.
8.23 According to one local authority, the SCCIP service is of high quality, but appears poorly resourced compared to the scale of the problem it is directed towards. Placing clear duties on local authorities and other bodies (public sector or otherwise) to use SCCIP, with corresponding resources would, it is suggested, enable SCCIP expertise to be effectively harnessed. An individual respondent also questioned whether there was sufficient funding going into SCCIP to research and develop the required projects.
8.24 According to a business sector respondent, SSCIP should provide a "single door" resource for trusted advice. The respondent questioned why there was no equivalent resource for mitigation. It was also suggested that SNIFFER could be drawn on for additional expertise.
8.25 There was a complaint from one academic institution that some links and contact details on the website, along with the search facility, were not fully functional and that these should be repaired/updated immediately to "instil confidence" in the government's handling of data.
8.26 Lack of awareness of SCCIP was also raised as an issue by a public sector respondent.
8.27 A Third sector organisation stated that it found the e-newsletter very helpful.
International Context
8.28 A number of respondents were concerned that the global dimension of the climate change issue had been somewhat overlooked, given that it is an international issue.
8.29 A few local government respondents were particularly concerned about securing food supplies in the event of climate change, and wanted this important issue to be addressed in the Framework. A Third sector organisation added that the Framework should take account of the secondary consequences of climate change elsewhere in the world, such as conflict over resources, disruption of global economic systems, and the spread of tropical diseases caused by major population movements. On this same point, a local authority was concerned about the likelihood of climate refugees arriving in Scotland and questioned the government's proposed strategy for dealing with this.
8.30 According to one Third sector respondent, Scotland is responsible for a disproportionate share of global emissions on a per capita basis: three times that of China; and five times that of India:
"The ethical imperative is for the burden on change to be borne according to the extend that we individually pollute the global atmospheric resource." (Third sector)
8.31 The future scarcity of oil was also highlighted by an individual respondent as something the government needs to plan for and needs to feature in the Framework.
8.32 According to one individual respondent, international agreements should take precedence over national self-interest.
Proposed Measures
8.33 A business sector respondent advised that there were major economic opportunities arising from addressing climate change, including developing and providing services to climate affected areas - either remedial or preventative services. A local authority supported this view:
"whilst we seek to limit the negative impacts of climate change, we also seek to secure and harness the potential economic and environmental benefits attached to a changing climate, e.g. increased tourism or the enhancement of a habitat or ecosystem." (Local Authority)
8.34 A Third sector respondent recommended ensuring that business and economic policies promote "locally-controlled, networked solutions to food and water supply, energy supply, transport and the management of hazardous materials."
8.35 One local authority suggested undertaking measures now such as: larger valley gutters, road water gutters, general drainage capacity for roads, and larger downpipes. In addition, this same local authority suggested harvesting grey water, the supply of which will increase as rainfall increases. New damns could also be built to use this rainfall to provide additional hydro-electric power. These actions were suggested as part of an identified need to take a more proactive approach to managing Scotland's water resources.
8.36 Another local authority suggested requiring that all settlements generate a proportion of their energy needs locally.
8.37 One Third sector organisation requested that the Framework consider how Scotland's transport links will be maintained in the event of additional rainfall and landslides, and how shipping ports will cope with an increase in sea level. One local authority suggested that money for new roads should be spent on a mass transit system. Transport was also a major concern mentioned in the workshops. One measure proposed was that in the event of a break-down of the transport system, staff should be enabled to work from home. It was also proposed that an increase in telecommunications, such as video-conferencing for conducting meetings, would offer a reasonable adaptation measure and also help with mitigation. According to a local authority respondent, Section 2.11 on the role of economic policy mentions the importance of transport infrastructure, but there are no corresponding actions in Annex A on either transport or the economy. This local authority recommends that the national strategies for both the economy and transport should be referenced in the Framework.
8.38 A public sector respondent recommended that both Scottish National Parks be used to pilot and test climate change adaptation measures that could then be applied to other parts of Scotland.
8.39 Another public sector organisation supports the policy of licensed water providers promoting water efficiency within organisations by identifying where savings can be made.
8.40 A business sector respondent suggested funding innovative measures for adaptation through a project such as the Climate Challenge Fund or a parallel mechanism set up for adaptation projects.
Views on Government Direction and Policies
8.41 Overall, there was a reiteration of the widespread expectation that the Scottish Government should provide leadership, information, guidance, and education to usher in the lifestyle changes needed to mitigate and adapt to climate change.
8.42 It was declared by one public sector organisation that too much text was devoted to describing how important adaptation is without describing in practical terms what will be done or how it will be done in Scotland. As a business sector respondent commented:
"We are concerned that real action may be delayed by prolonged academic discussions about improved data and risk assessments…[adaptation] is a concept that needs to be applied now." (Business sector)
A local government respondent agreed that there was not enough focus on action and implementation in the proposed Framework. A public sector organisation commented that it was sometimes difficult for organisations and private businesses to understand the relevance of adaptation for them, so more direction was needed from the government. Again, a public sector respondent suggested including more examples for adaptation across social, economic, and ecological systems to enhance the relevance of adaptation to different sectors.
One Third sector respondent was even more critical:
"…the framework re-iterates some of what we already know, misses some of the key actions that have already been set out, and in total appears confused and very broad brush." (Third sector respondent)
8.43 One individual urged the Scottish Government to work collaboratively with the U.K. government. Another two individuals questioned if the worst case scenario had been admitted. This links to a commonly held view that the government needs to act with a greater sense of urgency in preparing for the foreseeable and unforeseeable impacts of climate change:
"Until statements from government are clearer, with a greater sense of urgency, and are reinforced by appropriate action, little will change." (Local Authority)
8.44 Another commonly expressed view was that mitigation and adaptation must be integrated and this requires complimentary policies. For example, use of transport and energy are both key ways of mitigating and adapting to climate change, as highlighted by one Third sector organisation. A business sector respondent argued that adaptation also needs to happen with sensitivity to other pressures, most notably, the pressure posed by market conditions. The organisation suggested, therefore, that the government needs to take a holistic approach to encouraging best practice in relation to business, risk and environmental management.
8.45 Climate change is a cross-cutting issue involving all areas of policy, as one Third sector respondent pointed out. As such it is vulnerable to a lack of co-ordination and mutually contradictory policies. This organisation recommended mainstreaming responsibility for climate change across the whole of government. Another Third sector respondent was concerned that the policies identified in the Environmental Report be co-ordinated across policy sectors.
8.46 A local authority suggested that the Framework should make reference to all the major legislation covering Scotland's environment. E.g. The Nature Conservation (Scotland) Act, Flood Risk Management (Scotland) Act etc. This respondent also wants a clear explanation of how the Adaptation Framework fits with the adaptation duty on local authorities contained within the Climate Change (Scotland) Act.
8.47 One business respondent was also keen to see a more detailed plan of action, but warned that the government needed to ensure that measures did not put "growing and successful" industries at a competitive disadvantage. Another business respondent supported this view, remarking that while government policy needed to induce a positive response from all sectors, this should not come with "excessive obligation" that could undermine the economic, environmental and social contribution of sectors, such as agriculture, to the well-being of Scotland.
8.48 According to a Third sector organisation, adaptation considerations need to be accompanied by a consideration of whether the current model of economic growth and its dependence on accelerating consumption of resources is sustainable. An individual respondent supported this view, stating that the current economic crisis offers a "rare opportunity" to reassess our values. This respondent referenced a Sustainable Development Commission paper entitled "Prosperity without Growth?"
8.49 A Third sector organisation argued that the additional Forth crossing should be reviewed and postponed for 5 years in order to release funding for other projects. Instead, it suggested that further consideration be given to an alternative additional crossing to the immediate west of Rosyth combining a tidal barrage with a transport link and electricity generation. This organisation also suggested constructing additional tidal barrages at Erskine or Solway.
8.50 One individual was of the opinion that policies are generally ineffective because climate change is not affected by human activity, and therefore government policies have no role to play in determining whether man survives or not. Another individual respondent also asserted that there was no "climate crisis" and therefore no need for any adaptation measures.
8.51 A Third sector respondent felt that there was a disproportionate focus on the rural environment in the consultation. This organisation pointed out that climate change will have major implications for urban areas and that these need to be addressed more in the Framework.
8.52 For one local authority, inspired by the London Climate Change Adaptation Strategy, the solution for effective preparation lies not in drafting lots of new policies, but rather in routinely integrating an understanding of how climate change may affect the world into the decision-making processes.
Public Engagement
8.53 In order to bring about the necessary societal change, there is a need for "ongoing and inclusive" communication to all sections of society, according to one local government respondent. Along the same lines, a Third sector respondent felt that the Adaptation Framework was too "top-down", proposing instead that it be "publicly-owned" by engaging with citizens in raising awareness and establishing publicly acceptable policies:
"Public engagement is not a matter of persuading the public about the need to adopt pre-determined policies, but to engage with citizens in a deliberative dialogue to determine what the best policies might be." (Third sector)
Another Third sector organisation echoed this criticism, stating that the consultation was aimed too much at an audience of high-level policy decision-makers, whereas what was needed was encouragement of the general population to accept the need for adaptation.
8.54 One Third sector organisation asserted that the government needs to produce information in formats accessible to the Deaf and Deafblind community.
Comments on the Consultation
8.55 A few respondents congratulated the government on conducting a consultation, which, in the words of one individual, was "very comprehensive". Respondents generally welcomed the opportunity to contribute their views. In particular, there was strong support for some of the more detailed and specific actions listed at Annex A in the consultation document. Some respondents commented that they looked forward to working with the Government on implementing, or helping others to implement, adaptation measures.
8.56 However, there were also some criticisms of the consultation. A Third sector organisation commented that the Yes/No format of the consultation questions made it difficult for them to give full comments. It was also noted that the lack of introductory space at the beginning of the questionnaire template made it difficult to set the context of the response.
8.57 Another Third sector respondent noted that the consultation questions did not allow it to express the "major reservations" it had about the proposals for the Framework. The organisation therefore had to give its views outwith the formal structure of the questionnaire. Yet another Third sector organisation felt that the consultation questions did not address the "issues of priority" for the organisation."
8.58 An individual respondent maintained that the consultation represented an example of "not thinking outside the box".
8.59 A public sector organisation expressed preference for the term "climate resilience" rather than "climate-proof" because the former term sets more reasonable expectations.
8.60 One public sector organisation felt it was problematic that adaptation was not defined in any detail until section 2.1 of the consultation, because without a definition it made it difficult to interpret Diagram 1. It was also suggested that the Framework should outline the different types of adaptation (anticipatory, autonomous, and planned), in line with the Intergovernmental Panel on Climate Change's definitions:
"This would highlight the importance of different approaches in different circumstances." (Public sector)
This would also, it was suggested, provide a more comprehensive feel to the three pillars drawn in Diagram 1.
8.61 One local authority advised that section 2.8 of the consultation on "integrating adaptation into public policy and regulation" needed to make reference to influencing initiatives in the areas of transport, planning, and building standards. This same respondent recommended that Chapter One needed to take account of affects on "well-being."
8.62 A public sector organisation felt that section 2.10 of the consultation document on social policy focused solely on emergency planning/extreme weather, rather than subtle changes in the climate e.g. water resource management, impact of food production, dealing with climate-driven migration to Scotland. It was suggested that the section could also include a comment on educating the public on climate change adaptation.
8.63 A public sector organisation expressed the view that section 2.11 on economic policy did not address the effects of climate change on key industries such as agriculture, food and drink production and tourism. These sectors, the organisation suggested, will need help to adapt.
8.64 One Third sector organisation could not comprehend why Action 3 in Annex A refers only to plant species. This organisation also complained that there was too little detail about how the government intends to support the Third sector in its efforts.
8.65 A local government respondent criticised the consultation document for containing out-of-date information.
8.66 A number of respondents mentioned that their response entailed a reiteration of views already expressed in their response to the first consultation.