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Implications of a Separate Carbon Neutral Plan for Renfrewshire PCC 29 08 23

Renfrewshire Council · 29 August 2023
Back to Planning and Climate Change Policy Board — 29 August 2023 and its agenda

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___________________________________________________________________
To:  Planning and Climate Change Policy Board
On:  29 August 2023
___________________________________________________________________
Report by: Director of Environment, Housing and Infrastructure
___________________________________________________________________
Heading: Implications of a Separate Carbon Neutral Plan for Renfrewshire 
___________________________________________________________________    
1. Summary 
1.1 Renfrewshire’s Plan for Net Zero was approved in August 2022, committing to
working towards net zero by 2030 for both the Renfrewshire area as a whole
and Renfrewshire Council as an organisation. 
1.2 This target places Renfrewshire 15 years ahead of the national target (as set
out in the Climate Change (Emissions Reduction Targets) (Scotland) Act
2019, which commits Scotland to become net zero by 2045); and 20 years
ahead of the UK Government target of net zero by 2050. 
1.3 At the Planning and Climate Change Policy Board on 24th January 2023, it
was requested that a report be submitted to this Policy Board relating to a
‘Carbon Neutral by 2025’ Plan. The Carbon Neutral Plan would be distinct
from the approved Plan for Net Zero, focusing on the applicability of external
carbon offsetting and how this could be used to offset the emissions produced
by Renfrewshire. 
1.4 The purpose of this report is to outline: 
 the implications associated with external carbon offsetting if applied to
the Renfrewshire context; and 
 the appropriate steps should an additional Carbon Neutral Plan (with a
target date of 2025) be adopted in addition to the existing Plan for Net
Zero (with a target date of 2030). 
1.5 Whilst there is significant commitment and focus within the Council and across
Renfrewshire to tackle the climate emergency, the report notes that the
resource and financial capacity required to deliver two distinct Plans with
different target dates and different methodologies is unlikely to be feasible or
bring best value at this time. In addition to the potentially significant financial
impact for the Council on an ongoing annual basis, there is also a risk around
confusing the messaging, communications and engagement, which has been
a key strength of Renfrewshire’s response to date.

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1.6 Based on the information currently available, it is recommended that the
Council focus remains on continuing to work with partners towards the current
2030 targets and actions within the approved Plan for Net Zero. This remains
very ambitious and significantly ahead of the Scottish and UK targets and
incorporates levels of carbon offsetting within it, alongside the delivery of local
initiatives across all 5 themes of the Plan for Net Zero which bring a range of
direct benefits to our communities through local investment. 
1.7 However, within the Plan for Net Zero it is acknowledged that offsetting will
have a role to play to deal with residual emissions (those which cannot
otherwise be removed). The detailed phased road map and costed delivery
plans which are currently being developed will highlight levels of offsetting
required in order to reach net zero for both the Council as an organisation and
the Renfrewshire area as a whole. The development of an offsetting strategy,
looking at both local offsetting and external offsetting, which aligns to the
phased road map could be a valuable tool to support Renfrewshire’s net zero
activities. 
1.8 As noted previously, at all stages throughout the delivery of Renfrewshire’s
Plan for Net Zero, officers will look to identify opportunities with partners to
accelerate progress wherever possible within the resources and capacity
available. 
___________________________________________________________________ 
2.  Recommendations 
Members of the Planning and Climate Change Policy Board are requested to: 
2.1 note the implications, particularly the financial implications of having a distinct
and separate Carbon Neutral Plan which focuses on external carbon
offsetting in addition to the approved actions and targets within the existing
Plan for Net Zero;
2.2 note the existing Plan for Net Zero and the approved targets and actions,
including those currently relating to carbon offsetting, should remain the focus
and continue to be progressed as a priority by all partners in Renfrewshire;
and
2.3 following phase 2 of Renfrewshire’s Plan for Net Zero, agree the development
of an offsetting strategy aligning with the phased road map and costed
delivery plans to identify and maximise opportunities associated with
offsetting.
___________________________________________________________________ 
3.  Background: Carbon Neutral, Net Zero and Carbon Offsetting 
3.1  The terms ‘carbon neutral’ and ‘net zero’ are similar in principle and are
sometimes used interchangeably but represent slightly different approaches to
emissions reduction: 
 ‘carbon neutral’ typically accounts for carbon dioxide (CO2) emissions
but not emissions from other greenhouse gases.

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 ‘net zero’ is expanded in scale and refers to all greenhouse gases
being emitted into the atmosphere, including methane (CH4), nitrous
oxide (N2O) and other hydrofluorocarbons, as well as CO2. 
3.2  For the purposes of net zero, emissions from the various greenhouse gases
are converted to a standard metric, known as carbon dioxide equivalent
(CO2e) on the basis of their global warming potential. This enables different
activities to be directly comparable using one standard measurement. 
3.3  Carbon offsetting is the reduction or removal of emissions of carbon dioxide or
other greenhouse gases in order to compensate for emissions which are
generated elsewhere: 
 External carbon offsetting requires paying for emissions to be
removed from places outwith the Council’s operational boundaries for
organisational emissions targets, or outwith the Council area for area-
wide targets.
 Local carbon offsetting (also known as insetting) relates to carbon
removal projects within the Council’s operational boundary for
organisational emissions (e.g. Council-owned parks and peatbogs on
Council land) and by extension, carbon removal projects within the
Council area, such as forestry and woodland, for area-wide emissions
targets. 
3.4  Renfrewshire’s Plan for Net Zero, approved in August 2022, specifies the use
of local carbon offsetting for residual emissions that cannot be removed
(which aligns with Scotland’s default national position that targets are to be
met through domestic action, without the use of international offset credits).
As such, a Carbon Neutral Plan with a focus on external offsetting is not in
alignment with Renfrewshire’s agreed Plan for Net Zero. 
3.5  Currently officers are working with external consultants to develop a detailed
phased net zero road map to identify opportunities and solutions and to set
clear interim targets. This phased road map will include levels of residual
emissions (emissions that cannot be removed) each year that would need to
be offset in order to reach net zero. Following this current phase of work, the
development of an offsetting strategy which identifies opportunities for a focus
on local offsetting as well as opportunities for external offsetting would
enhance the Plan for Net Zero to ensure that we are taking action to deal with
all of our emissions as part of a managed transition. 
Carbon Offsetting Guidance 
3.5 Audit Scotland produced guidance on ‘Scotland’s Councils’ Approach to
Addressing Climate Change’. This outlined the importance of establishing a
maximum level of acceptable offsets to minimise the risk of over-relying on
carbon offsets.

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3.6  The UK Climate Change Committee (CCC) is an independent statutory body
established under the Climate Change Act 2008, whose purpose is to advise
the UK and devolved governments on emissions targets and to report to
Parliament on progress made in reducing greenhouse gas emissions and
preparing for and adapting to the impacts of climate change. The CCC report
on carbon offsetting, published in October 2022, highlights that the use of
carbon credits risks disincentivising emissions reductions. The CCC also
notes concerns around the integrity, quality and accuracy of carbon credits.
As such, the overarching CCC recommendation is that direct emissions
reductions and those within our supply chains should be prioritised, with
carbon credits having a limited role and being used as a last resort. 
3.7  The Plan for Net Zero aligns with the best practice and carbon offsetting
guidance within both of the above reports. At the 1 November 2022 Planning
and Climate Change Policy Board it was noted that in line with Audit Scotland
guidance, maximum levels of offsetting would be outlined for Renfrewshire
within the road map to net zero (where previously the Plan had stated
achievable levels) in order to strengthen the Plan in line with the Audit
Scotland guidance. 
3.8  A Carbon Neutral Plan focused on external carbon offsetting to deal with
residual emissions would not align with the UK CCC guidance of carbon
credits having only a limited role and to be used as a last resort. This would
also increase the risk of disincentivising stakeholders to reduce emissions if
the Council would otherwise pay to offset all residual emissions within the
area. This approach also increases the risk of over-relying on carbon offsets.
In addition, external carbon offsets would not contribute to national net zero
targets, if bought from projects outwith Scotland. 
3.9  High level projected cost indications associated with an approach which has a
focus on external offsetting can be found in Section 5. 
4.  Planning, baselining and road mapping 
4.1 As previously outlined to this Policy Board, since the declaration of a climate
emergency in June 2019, a significant work programme has been undertaken,
with engagement at the heart, to develop a road map towards a net zero
Renfrewshire. This work has included the development of the agreed ‘Plan for
Net Zero’, a recognisable brand ‘Ren Zero’, allocating the £1m climate change
action fund (including community climate fund aligned to the themes of the
Plan for Net Zero) and meetings, talks, training and the establishment of
Renfrewshire’s Climate Panel all based on the premise of working towards net
zero Renfrewshire. This also aligns with the approach of our Community
Planning Partners in Renfrewshire, who are also working towards net zero
targets, rather than carbon neutral. 
4.2 Members also approved the commissioning of independent technical support
for baselining emissions in Renfrewshire and the subsequent commissioning
of a phase 2 road map exercise which is currently underway, again based on
working towards net zero Renfrewshire.

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4.3 As well as the requirement to undertake a similar work programme described
above to develop a Carbon Neutral Plan, there is a risk that introducing a
separate Carbon Neutral Plan with different targets may impact local progress
on net zero ambitions through: 
 mixed messaging from using two different terminologies and two
different Plans with different targets; 
 resources being split between the two Plans (financial and personnel)
and the risk this brings to delivery of both; 
 the impact of the Council having to fund the offsetting of all
stakeholders’ residual emissions on an ongoing annual basis, thereby
disincentivising others to take action; and
 diverting Council funds and resources towards external offsetting with a
reduced capacity to deliver projects with wider benefits of a just
transition.   
5.  The Cost Implications of a 2025 Carbon Neutral Plan for Renfrewshire 
5.1  In order to be carbon neutral, residual emissions (i.e. those emissions that
have not been able to be removed) would need to be offset for each and
every year that they remain above zero. 
5.2  There is a financial cost if a decision was taken to purchase carbon credits to
offset residual emissions. A commitment to be carbon neutral 2025 would be
very challenging and it is suggested that the Council and local stakeholders
would not be able to deliver this within the timeframe, which would require the
purchase of significant volumes of carbon credits to be progressed to achieve
a 2025 target.   
5.3  Once a carbon credit has been purchased, it is then permanently retired so it
cannot be reused, therefore new carbon credits require to be purchased
annually in order to keep offsetting residual emissions each year. 
5.4  The Woodland Carbon Code (WCC) is the quality assurance standard for
woodland creation projects in the UK and generates high integrity,
independently verified carbon units. Woodland Carbon Code verified carbon
credits currently cost between £17 and £24 per tonne of carbon. 
5.5  The emissions baselining that was undertaken as part of the evidence base
used in the development of the Plan for Net Zero included a trajectory to 2030
using two scenarios: a best case (tailwind) scenario and a worst case
(business as usual) scenario. This trajectory showed that in 2025 under a
tailwind scenario the Renfrewshire area would have 224ktCO2e residual
greenhouse gas emissions which would require to be offset and 416ktCO2e
under a worst-case scenario.

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5.6  To calculate exactly how much of these residual emissions each year relate to
carbon dioxide (and not other greenhouse gas emissions) would require
additional consultancy and modelling (with additional time and costs). Working
on the assumption that CO2 accounts for around 76% of total greenhouse gas
emissions, then this would leave 170.24ktCO2 and 316.16ktCO2 residual
emissions under a tailwind and worst-case scenario for the Renfrewshire area
respectively. 
5.7  Taking a midpoint in the Woodland Carbon Code carbon credits price of
£23.7/tonne would result in a cost of between £4.03m and £7.49m to use
external offsetting to cover residual emissions for just the year 2025 alone. 
5.8  Similar investment would be required annually for every year after 2025 that
residual carbon emissions remain above zero in order for Renfrewshire to
remain carbon neutral. With investment in projects which contribute to
reducing carbon emissions, the residual emissions would be expected to fall
but there are two key risks with the approach of the Council using external
carbon offsetting for residual emissions: 
 Disincentivising action: if the Council were to commit to invest in
external carbon offsetting for the Renfrewshire area as a whole in order to
meet a 2025 target, then stakeholders could be disincentivised to take
action to reduce their own emissions, and the Council may be left with an
annually recurring financial burden for external offsetting in order to remain
carbon neutral.
 Rising carbon prices: even if residual emissions were also to fall, within
government projections carbon prices are expected to rise significantly to
over £100/tonne in the Low scenario and over £200/tonne in the Central
scenario by 2050 (the UK Emissions Trading Scheme prices were over
£75/tonne in October 2021, which is within the government’s High
trajectory for future carbon prices). It is difficult to predict future carbon
prices and whether these rises will remain in the High trajectory, but with
the impacts of climate change becoming greater each year and the
difficulty of maintaining global temperatures below a 1.5°C rise, it would
seem likely that carbon prices will continue to be high in the future,
bringing high levels of risk and annual investment utilising external
offsetting to remain carbon neutral. 
5.9  It is important to note that it is unlikely that large-scale external funding
sources (such as from the Scottish or UK Governments) would be made
available for external carbon offsetting as the focus of funding streams to date
has been on developing green infrastructure for example, with the associated
economic and employment benefits. 
5.10  The financial implications of this approach would require significant Council
funds to be diverted outwith the local area, towards investment in external
carbon offsetting. Given the Council’s resourcing pressures, this would require
decisions to be taken regarding disinvestment from work programmes in other
areas.

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6.  Additional Implications of a 2025 Carbon Neutral Plan for Renfrewshire 
6.1  In addition to the areas outlined above, there are some additional implications
to consider including: 
 Stakeholder engagement – considerable engagement has been
undertaken as part of Renfrewshire’s climate journey to date, including
Renfrewshire’s Climate Panel and the development of the RenZero
identity, and further engagement would be required to shift to a new
carbon neutral approach. There is a risk around confusing the
messaging; losing elements of stakeholder buy-in where partners’
planning is based on a Net Zero approach; and disengagement from
the process if we reduce the target timescales. 
 Resources and capacity – the introduction of a separate 2025 Carbon
Neutral Plan would require twin streams of separate work to be
undertaken by the Council, with dedicated resources being split
between the two Plans (both financial and personnel, including
commissioned support). 
 Community benefits – external carbon offsetting would involve
investing significant financial resources on an ongoing basis outwith
Renfrewshire, and therefore risks not delivering additional community
benefits and outcomes detailed in the Plan for Net Zero. 
7.  Next steps 
7.1 Ambition for tackling the climate emergency in Renfrewshire is welcome,
however as highlighted within the paper, the current evidence available to
officers indicates that it is unlikely that the Council and local stakeholders
would be able to commit time, capacity, capability, investment or resourcing to
deliver the infrastructure at the scale and pace required to be carbon neutral
by 2025. This would leave the purchase of large volumes of carbon credits at
a financial cost as the only option to meet a target of being carbon neutral. 
7.2  The Plan for Net Zero acknowledges that there will always be some residual
emissions which cannot be eliminated (e.g. those associated with
anaesthetics and medicine). There are areas relating to carbon offsetting
which will be brought to future Planning and Climate Change Policy Boards -
the next phase of the Plan for Net Zero will produce a detailed phased road
map, broken down into clear annual phasing and interim targets for each year
alongside costed phased delivery plans which quantify multiple outcomes
(including those that cannot be monetised, such as fuel poverty alleviation
and local job creation). 
7.3  The levels of carbon offsetting required in order to work towards net zero by
2030 will be incorporated into modelling and into the phased road map, with
maximum levels of offsetting for Renfrewshire as a means to meet our net
zero targets being set in line with Audit Scotland guidance. This would
highlight any potential shortfall of residual emissions that are unable to be met
from local carbon offsetting.

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7.4  The recommendation from officers is for the focus to remain on the delivery of
Renfrewshire’s Plan for Net Zero and the approved targets and actions,
including those currently relating to carbon offsetting, and accelerating the
work that is already in progress as a priority by all partners in Renfrewshire to
optimise local benefits. 
7.5 Updates will be provided to the Board on the ongoing implementation and
progress of the Plan for Net Zero, including the identification of opportunities
to accelerate action across different themes and work programmes. 
Implications of the Report
1. Financial – the report outlines the significant potential financial implications of
a 2025 Carbon Neutral Plan with a focus on external carbon offsetting. 
2. HR & Organisational Development – none. 
3. Community/Council Planning – the report outlines potential implications on
engagement and collaboration with local businesses, partners and
communities on the climate emergency agenda and highlights the potential
impacts on activities which support the key priorities set out in the Council and
Community Plans to tackle inequality and widen opportunity.   
4. Legal – a Carbon Neutral Plan has no significant legal implications, however
future actions associated with external carbon offsetting may have some level
of implication. 
5. Property/Assets - none. 
6. Information Technology – none. 
7. Equality and Human Rights - The Recommendations contained within this
report have been assessed in relation to their impact on equalities and human
rights. No negative impacts on equality groups or potential for infringement of
individuals’ human rights have been identified arising from the
recommendations contained in the report because it is for noting only. If
required following implementation, the actual impact of the recommendations
and the mitigating actions will be reviewed and monitored, and the results of
the assessment will be published on the Council’s website.  In addition, social
justice and reducing inequalities is at the core of the Plan for Net Zero and
one of its overarching outcomes.   
8. Health and Safety – none. 
9.  Procurement – a Carbon Neutral Plan with a focus on external carbon
offsetting would have significant procurement implications given the nature of
the work and levels of financial investment involved.

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10. Risk – the report details a number of risks associated with a Carbon Neutral
Plan which has a focus on carbon offsetting. A key risk is that stakeholders
are disincentivised to reduce emissions, leaving the Council with significant
financial burden for external offsetting annually in order to remain carbon
neutral. 
11.  Privacy Impact – none. 
12. COSLA Policy Position – COSLA has a longstanding position on climate
change, supporting Scotland’s 2045 target for net zero. 
13. Climate Risk – this report details potential implications to work currently being
undertaken and progress made by Renfrewshire Council in response to the
climate emergency.
___________________________________________________________________ 
List of Background Papers: 
 Renfrewshire’s Plan for Net Zero, 23 August 2022, Planning and Climate
Change Policy Board
 Scotland’s Councils’ Approach to Addressing Climate Change: Audit Scotland
Briefing, 1 November 2022
 Net Zero Renfrewshire, 24 January 2023 
___________________________________________________________________ 
Author:   Roz Smith, Climate Emergency Lead Officer 
Chief Executive’s Service