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West Dunbartonshire Council · 23 April 2025
Back to West Dunbartonshire Council — 23 April 2025 and its agenda

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Agenda 
West Dunbartonshire Council 
Date:  Wednesday, 23 April 2025
___________________________________________________________________ 
Time:  16:00
___________________________________________________________________ 
Format:      Hybrid meeting 
___________________________________________________________________ 
Contact:    Carol-Ann Burns, Senior Democratic Services Officer  
Email: carol-ann.burns@west-dunbarton.gov.uk   
committee.admin@west-dunbarton.gov.uk 
Dear Member 
Please attend a meeting of West Dunbartonshire Council as detailed above.   
Members will have the option to attend the meeting remotely or in person at the Civic
Space, 16 Church Street, Dumbarton. 
The business is shown on the attached agenda. 
Yours faithfully 
PETER HESSETT 
Chief Executive 
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Distribution:- 
Provost Karen Murray Conaghan Councillor John Millar
Councillor James Bollan  Councillor Lawrence O’Neill
Councillor Ian Dickson Councillor Lauren Oxley
Councillor Diane Docherty Councillor Chris Pollock
Councillor Fiona Hennebry Councillor Martin Rooney
Councillor Gurpreet Singh Johal Councillor William Rooney
Councillor Daniel Lennie Councillor Gordon Scanlan
Councillor David McBride Councillor Hazel Sorrell
Councillor Jonathan McColl Councillor Clare Steel
Councillor Michelle McGinty Councillor Sophie Traynor
Councillor June McKay 
Chief Executive
Chief Officers 
Date of issue:  8 April 2025 
Audio Streaming 
Audio recordings of the meeting (including the attendance or contribution of any party
participating or making a contribution) will be published on the Council’s website and the
Council’s host’s webcast/audio stream platform. 
You should be aware that the Council is a Data Controller under the General Data
Protection Regulation.  Data collected during this audio stream will be retained in
accordance with the Council’s Privacy Notice* and Retention Schedules including, but
not limited to, for the purpose of keeping historical records and making those records
available via the Council’s internet site. 
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WEST DUNBARTONSHIRE COUNCIL 
WEDNESDAY, 23 APRIL 2025 
AGENDA 
1 STATEMENT BY CHAIR – AUDIO STREAMING 
2  APOLOGIES 
3  DECLARATIONS OF INTEREST 
Members are invited to declare if they have an interest in any of the items of
business on the agenda and the reasons for such declarations. 
4  RECORDING OF VOTES 
The Council is asked to agree that all votes taken during the meeting will be
carried out by roll call vote to ensure an accurate record. 
5  OPEN FORUM 
The Council is asked to note that no open forum questions have been
submitted by members of the public. 
6  MINUTES OF PREVIOUS MEETING       
Submit, for approval as correct record, the Minutes of Meeting of     7 – 12 
West Dunbartonshire Council held on 26 March 2025. 
7  GLASGOW CITY REGION CITY DEAL – UPDATE      13 – 16 
Submit report by the Chief Officer – Regulatory and Regeneration providing an
update on the Exxon Infrastructure Project, and reporting on matters being
discussed by Glasgow City Region. 
8/ 
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8 CLIMATE CHANGE DUTIES – DRAFT STATUTORY GUIDANCE    17 – 286 
FOR PUBLIC BODIES: CONSULTATION   
Submit report by the Chief Officer – Regulatory and Regeneration providing an
outline of key proposed changes set out in the draft statutory guidance to public
bodies’ duties related to climate change. 
9 NOTICE OF MOTIONS 
(a) Motion by Councillor William Rooney – Clydesdale Harriers 140th Anniversary
4th May 2025 
Council congratulates Clydesdale Harriers on their 140th anniversary. 
Council recognises the remarkable legacy of Clydesdale Harriers in Scottish
athletics. Founded on 4 May 1885, the club was Scotland's first "open"
amateur athletics club, welcoming all members of the public. The pioneering
spirit of the club is evident in its many firsts: the first to host a two-day event at
Dunoon during the Glasgow Fair, and one of the first to establish both a ladies'
section and a men's junior section. It also initiated the first annual race for
youths under 17 and successfully proposed the Scottish cross-country
championship for boys under 15. 
Council notes that the club boasted notable members such as Jock Semple,
who ran in several Boston marathons and represented the USA at the first
Pan-American Games in 1951. The club's influence extended beyond its
members, contributing to the formation of the Scottish Cross-Country
Association and achieving numerous successes in cross country, track, and
field. Despite the setbacks of the World Wars, which saw a significant loss of
members, the club persevered and rebuilt, forming a ladies' section in 1932
that went on to win Scottish titles. 
Council understands that from the 1960s to the present, Clydesdale Harriers
continued to excel, with athletes representing Scotland in various endurance
events and track and field. The 1970s were particularly successful, with the
club winning the Maley Trophy and the West District Cross Country
Championship multiple times. 
Council acknowledges that Clydesdale Harriers' legacy is not just in its
achievements but in its resilience and dedication to the sport. It remains a
symbol of excellence and community spirit in Scottish athletics. 
Given the above, the Council asks the Provost to organise a civic reception to
honour and celebrate the club's achievements over its 140-year history. 
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(b) Motion by Councillor Lauren Oxley – UK Government Cuts to Social
Security 
Council notes with grave concern the contents of the Labour UK Government’s
Spring Statement, which includes £5 billion worth of cuts to social security.
This decision will have significant implications for the Scottish Government's
budget and further exacerbate the financial hardship faced by residents in our
communities. 
Council condemns these cuts, which will disproportionately affect low-income
families, disabled people, and those already struggling with the cost-of-living
crisis. With inflation continuing to rise and essential household costs soaring,
these measures will deepen child poverty and harm the most vulnerable.   
Council further acknowledges that foodbanks, charities, and frontline support
organisations are under immense strain and are dealing with additional
challenges, such as Labour’s increase in employer’s National Insurance
contributions which is hitting Scotland’s public sector and third sector the
hardest. The decision to cut social security will increase reliance on these
services and only escalate the challenges they are facing. 
Therefore, Council: 
• Calls on the UK Government to urgently reconsider the social security
cuts announced in the Spring Statement and instead introduce
measures that provide adequate financial support to those most in
need. 
• Officers are requested to prepare a report detailing the anticipated
impact of these cuts on West Dunbartonshire residents. 
• Requests that the Leader of the Council writes to the Chancellor of the
Exchequer and the Secretary of State for Work and Pensions
expressing our opposition to the cuts and urging an immediate reversal. 
(c) Motion by Councillor Chris Pollock – Wildfire Awareness 
Council recognises that recent dry and sunny weather along with irresponsible
behaviour has led to significant wildfires in the hills above West
Dunbartonshire. Council extends its thanks to our firefighters and emergency
service workers who worked tirelessly to bring these fires under control. 
Climate change is playing a part in increasing incidents of wildfires in the
Kilpatrick Hills and across many parts of Scotland. The period where we
normally have these fires is now extending from spring into summer. 
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Alongside weather and climate change people are the main cause of fires
starting. Unattended flames and campfires, glass bottles, controlled burns
gone wrong, deliberate fire setting and careless cigarette disposal are the
most common causes. 
Council asks officers to liaise with schools and the fire service to explore if
there is any literature, training or talks that can be delivered to our young
people to educate them on the importance of wildfire awareness. 
(d)  Motion by Councillor Clare Steel – Testicular Cancer Awareness 
Council notes that Cahonas Scotland is a charity that helps to raise awareness
of the signs and symptoms of Testicular Cancer.  
Research suggests that this the most common cancer in men but it is not talked
about enough. 
Locally, there is a small but dedicated team of two who can provide help and support
to those affected.    
Council also notes that, the month of April will be Testicular Cancer Awareness
Month. 
This Council thanks Cahonas Scotland for all the work that they do and agrees
to look at how we could support National Testicular Cancer Awareness month. 
10      DATE OF NEXT MEETING 
Members are requested to note that the next ordinary meeting of West
Dunbartonshire Council is scheduled to be held on Wednesday, 18 June 2025 at
4pm. 
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WEST DUNBARTONSHIRE COUNCIL 
At a Hybrid Meeting of West Dunbartonshire Council held in the Civic Space, 16
Church Street, Dumbarton on Wednesday, 26 March 2025 at 4.03 p.m. 
Present:   Provost Karen Murray Conaghan and Councillors Jim Bollan,
Ian Dickson, Diane Docherty, Fiona Hennebry, Gurpreet Singh
Johal, Daniel Lennie, David McBride, Jonathan McColl, Michelle
McGinty, June McKay, John Millar, Lawrence O’Neill, Lauren
Oxley, Chris Pollock, Martin Rooney, William Rooney, Gordon
Scanlan, Hazel Sorrell, Clare Steel and Sophie Traynor. 
Attending: Peter Hessett, Chief Executive; Alan Douglas, Chief Officer –
Regulatory and Regeneration (Legal Officer); Laurence Slavin,
Chief Officer – Resources, and Section 95 Officer; Peter Barry,
Chief Officer – Housing and Employability; Amanda Graham,
Chief Officer – Citizen, Culture and Facilities; Gail Macfarlane,
Chief Officer – Roads and Neighbourhood; Victoria Rogers,
Chief Officer – People and Technology; Carol Alderson, Finance
Manager; James Gallacher, Service Manager – ICT; Lauren
Crooks, Strategic Communication, Culture and Performance
Manager; Michelle Lynn, Asset Manager; Julie Slavin, Chief
Financial Officer; and Carol-Ann Burns, Senior Democratic
Services Officer. 
Provost Karen Murray Conaghan in the Chair 
STATEMENT BY CHAIR 
Provost Murray Conaghan advised that the meeting was being audio streamed and
broadcast live to the internet and would be available for playback. 
DECLARATIONS OF INTEREST 
Councillor Hennebry made a transparency statement in relation to Item 14(b) –
Notice of Motions under the heading ‘Motion by Councillor Lauren Oxley – Five
Years of The Promise’. 
RECORDING OF VOTES 
The Council agreed that all votes taken during the meeting would be carried out by
roll call vote to ensure an accurate record. 
ITEM 6
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MINUTES OF PREVIOUS MEETINGS 
The Minutes of Meetings of West Dunbartonshire Council held on 18 December
2024 and 5 March 2025 (Budget meeting) were submitted and approved as a correct
record. 
OPEN FORUM 
The Council noted that no open forum questions had been submitted by members of
the public. 
TREASURY MANAGEMENT STRATEGY AND ANNUAL INVESTMENT
STRATEGY 
A report was submitted by Chief Officer – Resources seeking approval of the
proposed Treasury Management Strategy Statement and Annual Investment
Strategy, and the indicators contained within. 
After discussion and having heard the Chief Officer – Resources in further
explanation and in answer to Members’ questions, the Council agreed:- 
(1) to approve the proposed Treasury Management Strategy Statement and
Annual Investment Strategy and the indicators contained within; 
(2) to approve the continued use of the Asset Life Method (using either annuity or
equal instalment) for the repayment of loan fund advances with the exception
of spend to save schemes where the funding/income profile method could be
used; 
(3) to approve the ability to continue to use countries with a sovereign rating of
AA- and above; 
(4) to note the removal of Lender Option Borrowing Option as an approved
source of borrowing; and 
(5) to note the report will be referred to Audit Committee for further scrutiny. 
GENERAL SERVICES REVENUE BUDGETARY CONTROL REPORT TO 31
JANUARY 2025 (PERIOD 10) 
A report was submitted by Chief Officer – Resources providing an update on the
2024/25 Revenue Budget position at 31 January 2025 and the forecast position of
the General Fund Reserve as at 31 March 2025. 
After discussion and having heard the Chief Officer – Regulatory and Regeneration
and Chief Officer – Roads and Neighbourhood in further explanation and in answer
to Members’ questions, the Council agreed:-
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(1) to note a current projected annual underlying adverse variance on the
revenue account of £3.454m (1.22% of total budget); 
(2) to approve any procurement and contract award of projects related to Central
Repairs Account recurring budget to be made by the Chief Officer –
Resources in consultation with the Procurement Manager, if the contract cost
is within the approved budget and the tender is in line with normal tender
parameters; and 
(3) to grant delegated authority to Chief Officer – Roads and Neighbourhood to
award contracts in relation to the procurement of replacement tyres if the
contract cost is within the approved budget and the tender is in line with
normal tender parameters. 
GENERAL SERVICES CAPITAL BUDGETARY CONTROL REPORT 2024/25 TO
31 JANUARY 2025 (PERIOD 10) 
A report was submitted by Chief Officer – Resources providing an update on the
General Services Capital financial performance to 31 January 2025. 
After discussion and having heard the Chief Officer – Resources in further
explanation and in answer to Members’ questions, the Council agreed:- 
(1) to note the current position of the 2024/25 General Services capital budget; 
(2) to note the project life total is currently on track; 
(3) to note appendix 2 and 3 to the report which detail the changes between
period 7 and 10 including changes agreed at the Council meeting on 5 March
2025; 
(4) to grant delegated authority to Chief Officer – Roads and Neighbourhood, in
consultation with the Procurement Manager, to award contracts in relation to
vehicle replacement, using appropriate procurement routes; and 
(5) to grant delegated authority to Chief Officer – Resources, in consultation with
the Procurement Manager, to award any procurement and contract awards for
projects related to Building Upgrades recurring budget using appropriate
procurement routes. 
HOUSING REVENUE ACCOUNT BUDGETARY CONTROL REPORT TO 31
JANUARY 2025 (PERIOD 10) 
A report was submitted by Chief Officer – Resources providing an update of the
2024/2025 HRA Revenue Budget position on 31 January 2025 and the forecast HRA
reserves position on 31 March 2025. 
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The Council agreed:- 
(1) to note the HRA revenue account forecasts an adverse variance of £0.723m
which would reduce the HRA reserve to under the prudential target; 
(2) to note the HRA would need to replenish its reserves to meet its prudential
target; and 
(3) to note work continues to identify efficiencies across all areas of the HRA
revenue account budget to minimise the adverse variance. 
HOUSING REVENUE ACCOUNT (HRA) CAPITAL BUDGETARY CONTROL REPORT
TO 31 JANUARY 2025 (PERIOD 10) 
A report was submitted by Chief Officer – Resources providing an update of the HRA
Capital programme to 31 January 2025. 
The Council agreed:- 
(1) to note the current position of the 2024/2025 HRA capital budget and the HRA
capital plan; 
(2) to note that in year financial performance is monitored against a 2024/2025
capital expenditure budget of £73.664m and a 2024/2025 capital income
budget of £10.003m, a one-year borrowing requirement of £63.661m; 
(3) to note that project life performance is monitored against a five-year project
life expenditure budget of £319.740m and a project life income budget of
£54.576m, a five-year borrowing requirement of £265.164m; and 
(4) to note that there are thirty-two projects reporting off track with an anticipated
over/under spend against their 2024/2025. 
DUMBARTON COMMON GOOD BUDGET UPDATE 2025/2026 
A report was submitted by Chief Officer – Resources providing an update of the
forecast position for the Dumbarton Common Good Fund as at 31 March 2025 and
seeking approval for the revised 2025/26 Dumbarton Common Good budget. 
After discussion and having heard the Chief Officer – Resources in further
explanation and in answer to Members’ questions, the Council agreed:- 
(1) to note a projected 2024/25 Dumbarton Common Good deficit of £157,805;
and 
(2) to approve the revised 2025/26 Dumbarton Common Good budget of
£468,224 expenditure against projected income of £376,000 representing a
budgeted deficit of £92,224 as set out in Appendix 1 to the report.
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Note:  Councillor June McKay left the meeting. 
FEASIBILITY REPORT RE: ALTERNATIVES TO THE SCOTTISH GOVERNMENT
PROCUREMENT UNIT FRAMEWORK IT HARDWARE AND SOFTWARE 
A report was submitted by Chief Officer – Regulatory and Regeneration providing an
update on the feasibility of the move away from the Scottish Government
Procurement Unit Framework, for the supply of IT hardware as proposed in the
motion agreed by Council at the meeting of 30 October 2024. 
After discussion, Councillor Martin Rooney moved:- 
That the Council agrees:- 
(1) to note the contents of the report, and, 
(2) to the continued utilisation of the Scottish Government Procurement Unit
frameworks for the supply of hardware and associated software where in
the professional opinion of the Chief Officer –People and Technology,
this represents the Best Value solution for the Council. 
As an amendment, Councillor Bollan moved:- 
Move to go to open tender, and with the results of the open tender being
submitted to the Tendering Committee for a final decision. 
Councillor McBride then seconded Councillor Martin Rooney’s motion and Councillor
Lennie seconded Councillor Bollan’s amendment. 
On a roll call vote being taken, 8 Members voted for the amendment, namely
Provost Murray Conaghan and Councillors Bollan, Dickson, Lennie, Oxley,
Pollock. Scanlan and Traynor and 11 Members voted for the motion, namely and
Councillors, Hennebry, Singh Johal, McBride, McColl, McGinty, Millar, O’Neill,
Martin Rooney, William Rooney, Sorrell and Steel.  1 Member abstained from
voting, namely Councillor Docherty.   The motion was accordingly declared
carried. 
NOTICE OF MOTIONS 
(a) Motion by Councillor Sophie Traynor – Y-Sort It 
Council congratulates Y-Sort It on their 25th anniversary and thanks them for
their dedication to providing youth work to the communities of West
Dunbartonshire. 
Council recognises the years of support to local young people that this
organisation has provided and the incredible impact that this work has had.
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Council request that the Provost hosts a civic reception to mark this milestone
for the organisation. 
The motion was unanimously agreed by the Council. 
(b) Motion by Councillor Lauren Oxley – Five Years of The Promise 
Council acknowledges the five-year anniversary of The Promise, a
commitment made in 2020 following the Independent Care Review, which set
out clear actions to improve the lives of Care Experienced children, young
people, and families in Scotland. 
On this milestone, Council reaffirms its commitment to The Promise,
recognising the progress made both locally and nationally. Council further
commits to continuing its work with Care Experienced children, young people,
their families, and local organisations to ensure that every child in West
Dunbartonshire is supported to grow up feeling loved, safe, and respected. 
To support this, Council requests that a report be brought to the next Full
Council meeting which assesses our progress in implementing The Promise in
West Dunbartonshire, detailing achievements, challenges, and areas for
improvement to ensure ongoing accountability and development. 
The motion was unanimously agreed by the Council. 
The meeting closed at 5.33 p.m. 
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WEST DUNBARTONSHIRE COUNCIL 
Report by Chief Officer (Regeneration and Regulatory) 
Council: 23 April 2025 
Subject: Glasgow City Region City Deal - Update 
1. Purpose 
1.1 To provide an update on the Exxon Infrastructure Project, and to report on
matters being discussed by Glasgow City Region. 
2. Recommendations 
2.1 It is recommended that Council: 
i) Notes the update on the Exxon Infrastructure Project;
ii) Notes the progress of the Glasgow City Region programme. 
3. Background 
3.1 The Glasgow City Region City Deal Infrastructure programme equates to
£1.13bn of investment during period 2015-2035. Projects are progressing
and have reached various stages from Strategic, Outline and Full Business
Case stages of approval. 
3.2 At the meeting of Council on 30 October 2024, Council heard the factors
influencing cost increases for the Exxon Infrastructure Project and approved
£0.8m of additional capital costs to deliver the project with a reduced scope
while maintaining significant economic benefit. 
4. Main Issues 
4.1 This report provides information on City Region progress and includes the
latest position on Exxon site infrastructure project development. 
Exxon Infrastructure Project 
4.2 Since reporting to Council on 18 December, the main construction contract
works commenced as planned on 27 January 2025 and work is progressing
well. 
4.3 A Change Control Request seeking approval for the variation in project cost
and scope was considered and approved by the City Region Cabinet on 25
February 2025. The Inflation Justification Report that explains the reason for
increasing inflationary costs for the project has been submitted to City Deal
ITEM 7
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Project Management Office for review and consideration. Confirmation of the
additional City Deal funding will be provided to a future Council meeting. 
City Region Update 
4.4 A Glasgow City Region Cabinet Meeting was held on 25 February. Items on
the agenda included a report on Enabling Commercial Space programme,
the Glasgow City Region City Deal Gateway Review 2,  an up-date on the UK
Shared Prosperity Fund for 2025/26, the National Wealth Fund and Glasgow
City Region Strategic Partnership and an up-date on the Investment Zone
programme. Cabinet also considered and approved Change Control
Requests from Glasgow City Council, South Lanarkshire Council and West
Dunbartonshire Council. 
4.5 The report to Cabinet on Enabling Commercial Spaces (relating to funding for
newbuild commercial / industrial units) confirmed that the Business Case
would be included as part of the City Deal Programme.  The Programme
Management Office also confirmed that the Outline Business Case that
included all enabling spaces projects, met the requirements of the HM
Treasury Green Book, however all legal and financial risks associated with
the project remained with the Member Authorities. Cabinet approved the
Strategic/Outline Programme Business Case and £4.5m of funding for
Member Authorities to use to support the development of their individual
project’s Full Business Case. Three expressions of interest were submitted
by West Dunbartonshire Council to Glasgow City Region and will now be
subject to an appraisal to short-list for the next stage of the business case
process. If successful this will deliver new/refurbished commercial / industrial
units to a net zero standard and contribute to a more sustainable, resilient
and commercial estate. 
4.6 The Glasgow City Region City Deal Gateway Review 2 paper highlighted the
significant progress in delivery of the programme and outlined the next steps
for completion of the process, including the Challenge Session that was
scheduled for 5th March 2025. The report highlighted that to support this
process the Glasgow City Region Intelligence Hub and Programme
Management Office had worked between March and October 2024 to provide
the monitoring and evaluation evidence making Glasgow City the only Region
to manage that process almost entirely in-house, and in doing so, significant
lessons had been learned and capabilities grown within the regional teams.
The Independent Evaluation Panel report had highlighted the significant
progress made in the delivery of the programme however it is anticipated that
there will be a requirement for an increased level of monitoring and
evaluation of all City Deal projects. A further report will be brought to Council
on the implications of this when information becomes available. 
4.7 The Cabinet report on UK Shared Prosperity Fund provided an update on
budget implications for the extension year (2025/26) of the Glasgow City
Region UK Shared Prosperity Fund, following the confirmation of the budget
from the UK Government in October 2024. The Cabinet noted the reduced
value of the fund for 2025/26 and a revision to the capital allocation resulting
in an opportunity for each Member Authority to each maintain a consistent
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level of capital expenditure. Cabinet agreed the capital allocations and that
the planned activity for 2025/26 would be an extension to the current
Glasgow City Region UK Shared Prosperity Fund Investment Plan model. 
4.8 The National Wealth Fund and Glasgow City Region Strategic Partnership
report provided an update on the work underway with officials from the
National Wealth Fund to create a Strategic Partnership with Glasgow City
Region. The report noted that the Glasgow City Region had been chosen as
one of four areas across the UK to take part in a new UK Government
initiative which connected regions with central government and industry
expertise to support them to unlock private investment opportunities and
boost local growth. Member Authorities were asked to identify projects which
could potentially benefit from the National Wealth Fund products and that
tackled climate change while driving regional and local economic growth.
The Council submitted four potential projects and await the outcome of on-
going discussions. 
4.9  The Glasgow City Region Investment Zone update confirmed that following
an Expression of Interest process and with over 90 expressions of interest
being submitted, the sectors of focus had been identified as Advanced
Manufacturing, Life Sciences and Digital Technology. The report presented
the proposed short-list of projects, that included the Malin Group’s proposal
for a Scottish Marine Technology Park, was approved by Cabinet allowing a
process in-depth due diligence of the short-listed projects to get underway.
This will consider the proposed interventions, expected outputs and
outcomes, together with a full budget profile, over the 10-year period of the
Investment Zone, and would also include the completion of the Gateway 4
submission. The Council will continue to work with the Malin Group to
advance this regeneration project and will up-date Council on progress. 
5. People Implications 
5.1 There are several senior officers involved in the Glasgow City Region
wider programme as identified at City Region Update paper at Council on
26 August 2021. 
6. Financial Implications 
6.1 Spend to date for financial year 24/25 was £4.59M. Overall spend to-date
is £11.37M 
7. Risk Analysis 
7.1 There are several project risks associated with the development at the
Exxon project site, and these are contained within the project risk register
and updated by the Project Board on a regular basis. The Project Board
is made up of senior officers from all key services. 
8. Equalities Impact Assessment 
8.1 Previously completed.  No further Assessment is required at this stage. 
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9. Consultation 
9.1 Consultation with all key stakeholders is progressing as we continue
to work as part of the Glasgow City Region. 
10 Strategic Assessment 
10.1 At its meeting on 26 October 2022, the Council agreed that one of its
main strategic priorities for the Strategic Plan 2022 - 2027 is ‘A Strong
local economy and improved employment opportunities’ 
10.2 The proposals within this report are specifically designed to deliver on
this priority. 
Alan Douglas
Chief Officer: Regulation and Regeneration
Date: 23 April 2025 
Person to Contact: Elaine Troup 
elaine.troup@west-dunbarton.gov.uk 
Appendix: None   
Background Papers: UK Shared Prosperity Fund Report to Housing and
Communities Committee 22 August 2022                                          
Glasgow City Region City Deal- Council 13 August 2014.                                          
“City Deal Initiative” Clyde Valley Investment Fund-
Council 30 April 2014 (Memorandum of Understanding).                                          
Clyde Valley Community Planning Partnership – City Deal
Initiative – Council 28 August 2013.   
Wards Affected: All
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WEST DUNBARTONSHIRE COUNCIL 
Report by Chief Officer (Regeneration and Regulatory) 
Council: 23 April 2025 
Subject: Climate Change Duties – Draft Statutory Guidance for Public
Bodies: Consultation   
1. Purpose 
1.1 To provide an outline of key proposed changes set out in the draft
statutory guidance to public bodies’ duties related to climate change. 
2. Recommendations 
2.1 It is recommended that Council: 
i) Notes the draft statutory guidance for public bodies; and 
ii) Notes that an officer response to the consultation will be submitted
on behalf of the Council before the closing date of 23rd May 2025. 
3. Background 
3.1 Public bodies are required to deliver on their climate change duties,
contribute to the delivery of the Scottish National Adaptation Plan, and to
act in the most sustainable way, as set out in the Climate Change
(Scotland) Act 2009. Under the 2009 Act, there is a requirement for
Scottish Ministers to provide guidance to public bodies to facilitate the
implementation of their climate change duties.     
3.2 The statutory guidance that was published in 2011 is now under review. A
formal consultation seeking views on the new draft statutory guidance has
been published. The consultation document is appended as Appendix 1. 
4. Main Issues 
4.1 All public bodies are required to meet their climate change duties through their
corporate operations, policy making and overall delivery function. Day-to-day
operations, fleet, and estate generate direct greenhouse gas emissions but
additionally, through other functions, public bodies have wider influence on
climate emissions and sustainable development. For example, local
authorities can impact beyond their organisational boundaries though
procurement, estate management, active travel policy, and engagement with
businesses. The proposed guidance aims to include these broader functions
by taking a more holistic approach and encompassing associated health and
wellbeing, equalities and biodiversity impacts. 
4.2 The consultation seeks responses on the following areas:
ITEM 8
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• Climate change and equalities, with a focus on how effective climate
action can achieve wider socioeconomic outcomes; 
• Taking climate change into account in decision making by embedding
climate change considerations in the decision making process; 
• The first duty – reducing emissions (climate change mitigation) by
developing and implementing appropriate emissions reduction policies,
strategies and action plans; 
• The second duty – adaptation by developing appropriate climate risk
assessments and adaptation plans to become resilient to the changing
climate; 
• The third duty – acting in a more sustainable way, and supporting
sustainable development; and 
• Reporting of Scope 3 emissions, with a particular focus on mandatory
reporting. 
4.3 An officer response will be prepared and submitted on behalf of the
Council. Elected members are welcome to submit their own response
in a personal capacity. Any responses to the draft Statutory Guidance
for public bodies consultation should be submitted using the Scottish
Government’s consultation hub, Citizen Space, and are required
before the closing date of 23rd May 2025. 
5 People Implications 
5.1 There are no people implications. 
6. Financial Implications 
6.1 There are no financial implications. 
7. Risk Analysis 
7.1 No risk analysis has been carried out. 
8. Equalities Impact Assessment 
8.1 No Equalities Impact Assessment is required as there is no change to policy
or procedure. Any changes to Council practice arising out of changes to the
guidance will be subject to an Equalities Impact Assessment or Screening. 
9. Consultation 
9.1 Internal stakeholder consultation will be carried out to inform an officer
response to the draft Statutory Guidance for public bodies
consultation. 
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10 Strategic Assessment 
10.1  No strategic assessment has been carried out. 
Alan Douglas
Chief Officer: Regulation and Regeneration
Date: 27 March 2025 
Person to Contact: Elaine Troup 
Elaine.Troup@west-dunbarton.gov.uk 
Appendix: Appendix 1: Consultation on draft Statutory Guidance for
public bodies: putting the climate change duties into practice
(consultation-draft-statutory-guidance-public-bodies-
putting-climate-change-duties-practice.pdf) 
Full Path 
https://www.gov.scot/binaries/content/documents/govscot/
publications/consultation-paper/2025/02/climate-change-
duties-draft-statutory-guidance-public-bodies-
consultation/documents/consultation-draft-statutory-
guidance-public-bodies-putting-climate-change-duties-
practice/consultation-draft-statutory-guidance-public-
bodies-putting-climate-change-duties-
practice/govscot%3Adocument/consultation-draft-
statutory-guidance-public-bodies-putting-climate-change-
duties-practice.pdf   
Background Papers: 
Wards Affected: All
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Consultation on draft
Statutory Guidance for public
bodies: putting the climate
change duties into practice
February 2025
Appendix1
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1
Consultation on draft Statutory Guidance for public bodies: putting
the climate change duties into practice 
Table of Contents
Public Consultation Summary ................................................................................... 7
Draft Statutory Guidance - Executive Summary ................................................... 13
Glossary and key definitions ................................................................................... 18
Draft Statutory Guidance .......................................................................................... 26
1. Context ................................................................................................................ 27
1.1 The climate change duties – legal basis ................................................... 27
1.2 Proportionality .............................................................................................. 28
1.3 Development of the guidance .................................................................... 28
1.4 Structure of the guidance ........................................................................... 28
1.5 How the guidance should be used ............................................................ 29
2. Strategic Framework ......................................................................................... 31
2.1 Scotland’s Strategic Framework ................................................................ 31
2.1.1 National Performance Framework ...................................................... 32
2.1.2 The Climate Change (Scotland) Act 2009 .......................................... 33
2.1.2.1 Mitigation ............................................................................................ 34
2.1.2.2 Climate Change Plan ......................................................................... 34
2.1.2.3 Just Transition ................................................................................... 35
2.1.2.3.1 Just Transition Planning ............................................................... 36
2.1.2.4 Public Engagement Strategy ............................................................ 38
2.1.2.5 Mitigation – scope of the duties....................................................... 39
2.1.2.6 Adaptation .......................................................................................... 39
2.1.2.7 Scottish National Adaptation Plan 2024-2029 (SNAP3) ................ 40
2.1.2.8 Adaptation – scope of the duties ..................................................... 40
2.1.2.9 Acting sustainably – scope of the duties ....................................... 40
2.1.2.10 Reporting on compliance with the climate change duties ....... 41
2.1.3 Wider context, legislative and regulatory framework ...................... 41
2.1.3.1 Scotland’s Environment Strategy .................................................... 41
2.1.3.2 Biodiversity and the natural environment ...................................... 42
2.1.3.3 Wellbeing economy ........................................................................... 43
2.1.3.4 Land Use ............................................................................................. 43
2.1.3.5 Circular economy............................................................................... 44
2.1.3.6 Equalities legislation ......................................................................... 45
2.1.3.7 Health and wellbeing ......................................................................... 45
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2.1.3.8 Human Rights ..................................................................................... 46
2.1.3.8.1 Children’s Rights ............................................................................ 46
2.1.3.9 UK Emissions Trading Scheme ....................................................... 47
2.1.3.10 Best Value ....................................................................................... 48
2.1.3.11 Health and Safety legislation ........................................................ 48
2.1.3.12 Sectoral and wider policy areas ................................................... 49
2.2 Impact assessments .................................................................................... 49
3. Equalities............................................................................................................. 59
3.1 Introduction .................................................................................................. 59
3.2 Climate, health and equalities .................................................................... 60
3.2.1 How climate impacts affect health ...................................................... 60
3.2.2 Unequal distribution of health and social risks ................................ 60
3.2.3 Policy response and widening inequalities ....................................... 62
3.2.4 Procedural justice ................................................................................. 62
3.3 Public Sector Equality Duty ........................................................................ 62
3.4 Fairer Scotland Duty .................................................................................... 63
3.5 Illustrative worked example - EQIA and FSDA ......................................... 64
4. Putting the duties into practice ........................................................................ 68
4.1 A whole systems approach ........................................................................ 68
4.1.1 Key principles to a whole systems approach ................................... 69
4.2 Implementing the climate change duties: a step by step method ........ 71
4.2.1 A step by step method: key outcomes ............................................... 71
4.2.2 Step 1: Understanding the duties ....................................................... 74
4.2.3 Step 2: Assess climate impacts .......................................................... 74
4.2.4 Step 3: Plan and Take action ............................................................... 76
4.2.5 Step 4: Reporting .................................................................................. 77
4.3 Leadership and governance ....................................................................... 77
4.3.1 Leadership ............................................................................................. 78
4.3.2 Corporate leadership ............................................................................ 79
4.3.3 Leaders as role models ........................................................................ 80
4.3.4 Governance ............................................................................................ 81
4.3.5 Risk and opportunity ............................................................................ 82
4.4 Mainstreaming .............................................................................................. 84
4.4.1 Organisational capability and maturity .............................................. 85
4.4.2 Organisational culture .......................................................................... 87
4.4.3 Capacity building .................................................................................. 88
4.4.4 Organisational KPIs .............................................................................. 89
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4.5 Taking climate into account in decision making ..................................... 90
4.5.1 Climate change in impact assessments ............................................ 91
4.5.2 Financial decision making ................................................................... 93
4.5.2.1 Tools and methodologies to aid financial design making ........... 94
4.6 Functions and wider influence ................................................................... 94
4.7 The role of audit ........................................................................................... 98
4.7.1 Climate change and the role of audit ................................................. 98
4.7.2 Understanding the various forms of public sector audit ................. 99
4.7.3 Public sector climate change audit examples ................................ 101
5. Implementing the first duty: reducing emissions ........................................ 102
5.1 Introduction to the first duty .................................................................... 102
5.2 Reducing emissions: background and context ..................................... 104
5.2.1 The importance of taking action to reduce emissions................... 104
5.2.2 Maximising co-benefits and minimising unintended consequences
105
5.2.3 The net zero approach to mitigation................................................. 106
5.2.4 Decarbonisation pathways ................................................................ 107
5.2.5 Carbon budgets ................................................................................... 111
5.3 Reducing emissions in practice: key principles .................................... 113
5.4 Taking corporate mitigation action ......................................................... 116
5.4.1 Climate change statement ................................................................. 117
5.4.2 Climate change strategy .................................................................... 117
5.4.2.1 Sectoral approaches ....................................................................... 118
5.4.3 Route maps .......................................................................................... 119
5.4.4 Emissions reduction targets ............................................................. 122
5.4.5 Carbon management plan .................................................................. 124
5.4.5.1 Template plans ................................................................................. 125
5.4.6 Dealing with residual emissions: carbon insetting and offsetting
126
5.4.6.1 Offsetting business travel emissions ........................................... 128
5.4.6.2 Selling carbon credits from projects on publicly owned land ... 129
5.4.7 Action plans ......................................................................................... 130
5.4.8 Monitoring and reporting ................................................................... 130
5.5 Area wide emissions and wider influence .............................................. 131
5.5.1 Local area wide emissions and place based climate action ......... 132
5.5.2 What makes up area wide emissions ............................................... 132
5.5.3 Public bodies duties and action on area wide emissions ............. 134
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5.5.3.1 Public bodies’ influence and collaboration .................................. 134
5.5.3.2 Developing plans, projects and policies to reduce area wide
emissions .......................................................................................................... 135
5.5.3.3 Focusing on resource allocation and implementation ............... 136
5.5.3.4 Monitoring, reporting and decision making ................................. 136
5.5.4 What does this mean for public bodies? ......................................... 137
5.5.4.1 What action public bodies should be taking ................................ 137
5.5.5 Developing partnerships for area wide emissions reduction ....... 138
5.5.6 What support is available? ................................................................ 139
6. Implementing the second duty: adaptation .................................................. 139
6.1 Introduction to the second duty .............................................................. 140
6.2 What is adaptation to climate change?................................................... 140
6.3 How to adapt ............................................................................................... 142
6.3.1 Key principles for effective adaptation ............................................ 142
6.3.2 Getting started ..................................................................................... 145
6.3.3 Understanding the challenge ............................................................ 147
6.3.4 Strategy, Implementation and Monitoring ....................................... 149
6.3.5 Organisational culture and resources .............................................. 150
6.3.6 Working together................................................................................. 152
6.3.7 Overcoming adaptation challenges .................................................. 152
6.4 Going further: beyond the basics ............................................................ 153
6.4.1 A whole systems approach to understanding climate risk ........... 154
6.4.2 Climate change risk assessments: best practice ........................... 156
6.4.3 Why assessing vulnerability is important ....................................... 157
6.4.4 Climate change scenario analysis .................................................... 158
6.4.5 Tips for carrying out a climate change risk assessment ............... 161
6.4.6 Adaptation strategy and planning .................................................... 163
6.4.6.1 Developing a strategic approach to adaptation planning .......... 163
6.4.6.2 Financial planning for adaptation .................................................. 167
6.4.7 Culture, governance and mainstreaming climate change adaptation
169
6.4.8 Collaboration for adaptation .............................................................. 173
6.4.9 Additional sector specific resources ............................................... 176
7. Implementing the third duty: acting in the most sustainable way ............ 178
7.1 Introduction to the third duty ................................................................... 178
7.2 Sustainable development: background and context ............................ 179
7.2.1 What is sustainable development?................................................... 179
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7.2.2 Why might we want to develop sustainably? .................................. 179
7.2.3 Bringing about sustainable development – the challenges .......... 180
7.3 The UK Shared Framework for Sustainable Development ................... 181
7.3.1 Implementing the five principles ....................................................... 182
7.3.2 From environmental limits to planetary boundaries ...................... 186
7.3.2.1 Working to minimise impacts on key planetary systems .......... 188
7.3.3 Social equity ........................................................................................ 190
7.3.3.1 Working to maximise social equity ............................................... 190
7.3.4 Wellbeing and a sustainable economy ............................................ 192
7.3.4.1 What is wellbeing? .......................................................................... 192
7.3.4.2 What are fundamental human needs? .......................................... 192
7.3.4.3 What is a wellbeing economy? ...................................................... 193
7.3.4.4 Working towards a wellbeing economy ........................................ 194
7.3.5 Sound science and good governance .............................................. 195
7.3.5.1 Sound science and good governance for sustainable
development ..................................................................................................... 195
7.4 Mainstreaming sustainable development ............................................... 196
7.4.1 Contributing to the NPF national outcomes .................................... 197
7.4.2 Using the National Performance Framework .................................. 198
7.4.3 Sustainable development thinking ................................................... 198
7.4.4 Impact assessment ............................................................................. 200
7.4.5 An integrated approach to the three duties ..................................... 200
7.5 Multiple duties and compliance ............................................................... 201
7.5.1 Sustainable procurement duty .......................................................... 201
7.5.2 Sustainable land use .......................................................................... 202
7.6 Sector specific approaches ...................................................................... 203
8. Reporting........................................................................................................... 206
8.1 Reporting: introduction ............................................................................. 206
8.2 Public bodies climate change duties reporting ..................................... 206
8.3 The reporting duty ..................................................................................... 207
8.3.1 Background and legislation ............................................................... 207
8.3.2 Reporting on scope 1, 2 and 3 emissions ....................................... 208
8.3.3 Scope 1 reporting ................................................................................ 210
8.3.4 Scope 2 reporting ................................................................................ 210
8.3.5 Scope 3 reporting ................................................................................ 211
8.3.5.1 Scope 3 reporting – baseline expectations .................................. 211
8.3.5.2 Scope 3 reporting – expanding on the baseline .......................... 212
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8.3.5.3 Scope 3 reporting - data sources .................................................. 213
8.3.6 Reporting land-based emissions and removals ............................. 218
8.3.7 Reporting on alignment of resources with net zero targets.......... 220
8.3.8 Reporting on adaptation action......................................................... 221
8.3.9 Sustainability reporting ...................................................................... 222
8.3.10 Reporting on wider influence emissions ...................................... 222
8.4 Local authorities – additional reporting duties ...................................... 223
8.4.1 Scope 3 reporting for local authorities ............................................ 223
8.4.2 Area based reporting for local authorities ....................................... 223
Annex A: Baseline Carbon Management Plan template .................................... 223
Annex B: Climate Change Plan template for local authorities .......................... 236
Annex C: Resources ............................................................................................... 248
Annex D: References .............................................................................................. 261 
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Public Consultation Summary 
The Climate Change (Scotland) Act 2009 (‘the 2009 Act’) places duties on relevant
public bodies to reduce greenhouse gas emissions, contribute to delivery of the
Scottish National Adaptation Plan, and to act in the most sustainable way. These
duties are known as the climate change duties, or the public bodies climate change
duties. 
Under the 2009 Act, Scottish Ministers are required to provide the public bodies with
guidance, to support them in putting their climate change duties into practice.
Statutory guidance was originally published in 2011 and now requires to be updated.
This consultation seeks your views on new draft statutory guidance which has been
developed for this purpose, and which will replace the 2011 guidance. By law, public
bodies subject to the climate change duties are required to have regard to the
statutory guidance. The new guidance will only be effective if it is informed by, and
tailored to, the needs of public bodies. 
During the public consultation period on this draft statutory guidance a formal public
consultation will be opened on the Scottish Government’s ‘Citizen Space’.
In this Public Consultation Summary, you will find details on:
• general questions on the proposed content of the guidance
• questions about specific sections of the guidance including the Carbon
Management Plan template (Annex A) and the Climate Change Plan template
for local authorities (Annex B)
• responding to this consultation and post-consultation next steps.
You will find questions in two formats, either open ended questions asking for
general opinions or specific questions asking you to share if, and how much, you
agree with the relevant question.
To respond to these questions please go to the Scottish Government’s Citizen
Space here - Scottish Government consultations - Citizen Space – and search for
‘climate change duties’.
Finally, in addition to this Public Consultation Summary, you will also find a full copy
of the draft guidance. The draft guidance includes a number of annexes that contain
important supplementary information: Annex A – Carbon Management Plan template
and Annex B – Climate Change Plan template for local authorities. These form part
of the guidance and will be published in the final version.
Proposed content of the guidance
The public sector plays a vital role in enabling Scotland’s just transition to net zero
and climate resilience. Public bodies are required to meet the climate change duties
as they ‘exercise their functions’. These functions could be corporate operational
functions, policy making functions or influence, and the overall delivery function (i.e.
the purpose of the body). 
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All public bodies will be responsible for some direct greenhouse gas emissions, for
example through their day-to-day operations, estate and fleet. However, many public
bodies will, through their varied functions, have a wide and significant influence on
climate change action and sustainable development far beyond their organisational
boundaries. 
For example, for a local authority, corporate operational functions may include
procurement, estate management and finance. Policy making functions might
include public transport and active travel planning, impacting on greenhouse gas
emissions from transport in a particular local area, and on wider linked issues
including resilience of infrastructure. Influence might include direct influence, for
example over suppliers; and wider influence through Local Development Plans and
engagement with local businesses. The delivery function or purpose would be to
deliver local government services within that authority area. 
The guidance aims to take a holistic approach that includes these broader functions
and secures wider linked benefits including to health and wellbeing, biodiversity and
equalities. 
The proposed content of the guidance includes:
• the background to the guidance and an explanation of the relevant legislation 
• the broader context, wider related legislation and policy, and impact
assessments
• climate change and inequalities
• how public bodies should approach putting the climate change duties into
practice, including the importance of leadership and governance,
mainstreaming and how to take climate change into account in decision
making
• dedicated chapters on each of the three climate change duties: reducing
emissions, adaptation, and acting in the most sustainable way
• reporting on climate action and progress towards targets and outcomes
• a Carbon Management Plan template (Annex A) aimed at smaller and less
complex public bodies that may have limited capacity to measure, monitor
and report on their carbon emissions
• a Climate Change Plan template for local authorities (Annex B) intended to
help them demonstrate their compliance with the three climate change duties,
across their corporate and area wide boundaries. 
Public consultation questions
Climate change and equalities
Chapter 3 of the guidance focuses on climate change and equalities, and aims to
make it clear how effective climate action can help achieve wider outcomes including
reduced inequalities and improved health and wellbeing outcomes. Section 2.2
outlines the most common impact assessments. 
1. With respect to the protected characteristics, could the content of the statutory
guidance be changed or added to, to strengthen any positive impacts or
lessen any negative impacts as it is implemented by public bodies?
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2. With respect to inequality caused by socio-economic disadvantage, could the
content of the statutory guidance be changed or added to, to strengthen any
positive impacts or lessen any negative impacts as it is implemented by public
bodies? 
Taking climate change into account in decision making
For public bodies to demonstrate compliance with the climate change duties, in
particular to show how they have met the requirement to best calculate the impact
of their actions in terms of mitigation and adaptation, climate change considerations
should be embedded in decision-making processes, with a robust and auditable
record.
Section 4.5 of the draft guidance provides information on embedding climate
considerations into decision-making processes through the use of appropriate impact
assessments and other tools. Chapter 5 and chapter 6 provide specific guidance
around implementing duty (a) to contribute to mitigation targets and duty (b) to help
deliver the National Adaptation Programme.
3. Does the guidance make it clear how public bodies can fulfil the requirement
to ‘best calculate’ the climate impact of their actions? 
4. Does the guidance make it clear how public bodies should take future climate
scenarios into account when making plans and investment decisions?
The first duty - reducing emissions (climate change mitigation)
Chapter 5, Implementing the first duty: reducing emissions, lays out the overarching
principles and actions which all public bodies would be expected to undertake, in a
manner proportionate to their size and nature, to reduce their greenhouse gas
(GHG) emissions, i.e. to develop and implement appropriate emissions reduction
policies, strategies, route maps, plans and supporting action plans. 
Annex A contains a template Carbon Management Plan and associated guidance.
This is aimed at smaller and less complex public bodies, who may lack the capacity,
skills or resource to develop their own carbon management plan. It is intended as a
starting point, with bodies adapting it to suit their own organisation and
circumstances.
Annex B contains a template Climate Change Plan for local authorities. It is
intended to help local authorities demonstrate their compliance with the three climate
change duties, across their corporate and area wide boundaries.
5. Do you have any comments about the guidance provided in this chapter on
complying with the first duty? 
6. Do you think the Carbon Management Plan template is suitable for its
intended purpose? (Annex A - template Carbon Management Plan: ‘baseline’
plan aimed at smaller public bodies) 
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7. Do you think the Climate Change Plan template for local authorities is suitable
for its intended purpose? (Annex B – template Climate Change Plan for local
authorities) 
The second duty – adaptation
Chapter 6, Implementing the second duty: adaptation lays out the overarching
principles and actions which all public bodies would be expected to undertake, in a
manner proportionate to their size and nature, to adapt and become resilient to the
changing climate. Core to this is undertaking appropriate climate risk assessments
and developing an adaptation plan or equivalent. 
8. The guidance lays out an approach whereby public bodies should review the
Scottish National Adaptation Plan (SNAP); identify the objectives relevant to
them; contribute towards those objectives; and, where relevant, report
annually on progress in their public bodies’ climate change duties report. To
what extent do you agree with this proposed approach? 
9. Do you have any other comments about the guidance provided in this chapter
about complying with the second duty? 
The third duty - acting in the most sustainable way
Chapter 7, Implementing the third duty: acting in the most sustainable way, lays out
the overarching principles and actions which all public bodies would be expected to
undertake, in a manner proportionate to their size and nature, to implement the third
duty. Key to this is to mainstream sustainable development into the functioning of
Scottish public bodies, i.e. work must be carried out in a way that supports
sustainable development.
The guidance notes that, due to the individual nature of each public body and the
unique nature of the decisions that they make, it is not possible to take a prescriptive
approach to this duty. Public bodies are required to consider their actions carefully
and apply an awareness of wider impacts to their approach.
10. Having considered the content of the chapter, is it clear how public bodies
should implement the third duty, to act in the most sustainable way? 
11. Do you have any other comments about this chapter? 
Reporting of scope 3 emissions
Chapter 8, Reporting, provides an overview of reporting, with a particular focus on
the mandatory reporting required under The Climate Change (Duties of Public
Bodies: Reporting Requirements) (Scotland) Order 2015, as amended (the public
bodies climate change duties reporting).
Previously issued guidance mandated reporting of relevant scope 1 and 2 emissions,
while reporting of scope 3 emissions was recommended on a voluntary basis. This
new guidance proposes a reporting baseline for selected scope 3 emissions, which
all public bodies would be expected to include in their inventory (see section 8.3.5),
the emissions associated with: consumption of mains water; waste and waste water
treatment; business travel; staff commuting and homeworking; student travel (for
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colleges and universities); and fuel and energy-related activities not included in
scopes 1 and 2. 
12. To what extent do you agree with the proposed baseline reporting of the
scope 3 emission categories as outlined? 
13. Do you think that any other categories of scope 3 emissions should be
included in the recommended baseline for reporting, where these are relevant
and applicable? 
Please indicate which other categories of scope 3 emissions you think should
be included, and provide an explanation. 
Overall reflections
The purpose of the Statutory Guidance is to support public bodies in meeting their
climate change duties. It aims to help public bodies to minimise their operational
emissions, adapt and become resilient to the current and future impacts of the
changing climate, live within environmental limits, and ensure a strong, healthy and
just society. 
14. Do you think that the guidance fulfils its stated purpose of providing support to
public bodies in putting the climate change duties into practice? 
15. Do you have any further comments about the guidance? 
Responding to this consultation 
We are inviting responses to this consultation by Friday 23 May 2025. 
Please respond to this consultation using the Scottish Government’s consultation
hub, Citizen Space, to access and respond to this consultation online. You can save
and return to your responses while the consultation is still open. Please ensure that
responses are submitted before the closing date of Friday 23 May 2025. 
If you are unable to respond using our consultation hub, please email your response
together with a completed Respondent Information Form to:
climate.change@gov.scot. 
Alternatively, your response and a completed Respondent Information Form can be
posted to: 
Net Zero Public Sector Team
Scottish Government
Area 3F - South
Victoria Quay
Edinburgh
EH6 6QQ 
If you have any questions please email: climate.change@gov.scot 
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Handling your response 
If you respond using the consultation hub, you will be directed to the About You page
before submitting your response. Please indicate how you wish your response to be
handled and, in particular, whether you are content for your response to published. If
you ask for your response not to be published, we will regard it as confidential, and
we will treat it accordingly. 
All respondents should be aware that the Scottish Government is subject to the
provisions of the Freedom of Information (Scotland) Act 2002 and the Environmental
Information (Scotland) Regulations 2004, and would therefore have to consider any
request made to it under the Act or Regulations for information relating to responses
made to this consultation exercise. 
If you are unable to respond via Citizen Space, please complete and return the
Respondent Information Form along with your response and post to the address
noted above. 
To find out how we handle your personal data, please see our privacy policy:
https://www.gov.scot/privacy/ 
Next steps 
Where respondents have given permission for their response to be made public, and
after we have checked that they contain no potentially defamatory material,
responses will be made available to the public at http://consult.gov.scot.  If you use
the consultation hub to respond, you will receive a copy of your response via email. 
Following the closing date, all responses will be analysed and considered along with
any other available evidence to help us. Whether you answer all of the questions, or
only some, your views will be carefully considered by the Scottish Government when
we are finalising the statutory guidance. 
An analysis report will also be made available. 
Comments and complaints 
If you have any comments about how this consultation exercise has been conducted,
please send them to the contact address above or email to
climate.change@gov.scot. 
Scottish Government consultation process 
Consultation is an essential part of the policymaking process. It gives us the
opportunity to consider your opinion and expertise on a proposed area of work. 
You can find all our consultations online: http://consult.gov.scot. Each consultation
details the issues under consideration, as well as a way for you to give us your
views, either online, by email or by post. 
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Responses will be analysed and used as part of the decision making process, along
with a range of other available information and evidence. We will publish a report of
this analysis for every consultation. Depending on the nature of the consultation
exercise the responses received may: 
● indicate the need for policy development or review
● inform the development of a particular policy
● help decisions to be made between alternative policy proposals
● be used to finalise legislation before it is implemented 
While details of particular circumstances described in a response to a consultation
exercise may usefully inform the policy process, consultation exercises cannot
address individual concerns and comments, which should be directed to the relevant
public body. 
Draft Statutory Guidance - Executive Summary 
The public sector has a critical role in helping Scotland to reduce greenhouse gas
emissions, make a just transition to a low carbon economy and prepare for the future
This statutory guidance is issued by the Scottish Ministers to Scottish public
bodies under the Climate Change (Scotland) Act 2009 (‘the 2009 Act’). 
The 2009 Act places a legal responsibility on relevant public bodies in Scotland
to meet the climate change duties. The duties are set out in section 44(1) of the
2009 Act and require that a public body must, in exercising its functions, act – 
(a) in the way best calculated to contribute to the delivery of emissions
reduction targets (i.e. mitigation)
(b) in the way best calculated to help deliver the Adaptation Programme
(c) in a way that it considers most sustainable. 
Under the 2009 Act, public bodies subject to the climate change duties are
required to have regard to the statutory guidance. This guidance is an advisory
document only, not a definitive statement of the law, and responsibility for
compliance with the climate change duties rests with public bodies themselves. 
The purpose of this statutory guidance is to support public bodies in performing
their climate change duties. It aims to help public bodies to minimise their
operational emissions, adapt and become resilient to the current and future
impacts of the changing climate, live within environmental limits and ensure a
strong, healthy and just society. This guidance will replace the statutory guidance
published in 2011.   
Within the guidance, while certain actions are recommended or encouraged,
these should be undertaken in a way that is proportionate to the climate impact
that the body has in terms of its size, assets, function and influence. Bodies are
responsible for determining what is appropriate for their own organisation, and for
taking such measures and actions forward in the most effective way.
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climate. Public bodies have an important leadership role to play as corporate
organisations with estates, fleet and staff; bodies delivering national, regional and
local services; as anchor organisations with significant influence on local places and
communities; as bodies with significant collective annual budgets and buying power;
as partner organisations and as trusted messengers. 
Leadership and Governance 
Strong governance, leadership and commitment within the public sector is vital to
ensure that Scotland meets its targets and commitments. Key outcomes that will
help demonstrate that such leadership is in place within the body are:
• publishing a formal declared commitment to action on climate change. Making
a public body’s commitment to deliver against the climate change duties
visible and transparent, both to those who work within the organisation and to
stakeholders, suppliers and service users, will increase the level of scrutiny of
climate change actions, and public bodies will begin to exert positive influence
over the behaviours of their stakeholders, suppliers and service users
• ensuring climate change governance is integrated into the existing corporate
governance approach, and that this is both robust and effective. By ensuring
that responsibility for leadership on climate change is clear within the
organisation, both at management level and cascaded throughout,
accountability for climate change action will be increased
• embedding climate change into the management of risks and opportunities
across the organisation
• reflecting climate action in the organisation’s corporate plans and annual
reporting mechanisms. These may include dedicated climate change
strategies and carbon management plans to address carbon emissions
reduction and adaptation plans. Climate and sustainability should be included
in other relevant statutory plans including, where relevant, Local Outcome
Improvement Plans and Locality Plans. Corporate strategies and plans should
include targets; performance against these targets should be included in
annual reports
• ensuring that climate change considerations are mainstreamed across the
organisation (mainstreaming means ensuring that climate and sustainability
issues are considered in everything that the body does, and in how it makes
decisions)
• ensuring that climate change systemically informs strategic investment
planning and decision-making processes. By integrating climate change within
business and financial planning, for example through policy appraisal, impact
assessment or Strategic Environmental Assessment, the body will develop a
process whereby the ‘climate change question’ and ‘sustainability question’ is
routinely asked as part of the decision-making process. This will ensure the
impact of that decision on climate change is considered and public bodies are
seeking to act sustainably
• ensure that taking effective climate action is a corporate priority, with
commitment across the organisation. Investment should follow priority
• actively seeking opportunities for partnership working with other public bodies,
for example those in the same or adjacent geographical area or working in the
same sector, to share best practice, maximise efficiency and increase the
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impact of climate change action and acting sustainably. Where possible,
public bodies should put formal declarations of partnership in place to
encourage formal working together at a strategic level. Such opportunities are
more likely to contribute to multiple outcomes encompassing sustainability,
health, equity and economic development.
• embedding climate change and sustainable development within corporate
learning and development programmes. 
Implementing the first duty: reducing emissions 
The first of the climate change duties set out in section 44 of the Climate Change
(Scotland) Act 2009 requires public bodies, in exercising their functions, to act in the
way best calculated to contribute to the delivery of national emission reduction
targets, i.e. to reduce greenhouse gas emissions, also known as climate change
mitigation. In the context of the duties, ‘targets’ means both the national five-yearly
carbon budgets and the 2045 target. 
To help demonstrate compliance with this duty, public bodies should:
• develop a climate change strategy that includes net zero and other relevant
targets and has regard to just transition principles
• develop and implement a carbon management plan or equivalent
• develop action plans to deliver key elements of the carbon management plan,
detailing interim steps, costs, timescales and dependencies
• set up a process of monitoring and reporting, to report on performance
against their targets and action plans
• ensure that mitigation actions maximise co-benefits, such as improved public
health, reduced inequalities and enhanced biodiversity, and minimise
unintended consequences such as maladaptation and negative environmental
impacts
• undertake the above giving due consideration to their physical assets
including buildings, land and fleet; their staff and service users; the services
they deliver; the investments they manage; and the functions they exercise. 
Key outcomes will be that public bodies:
• focus efforts on the material decarbonisation opportunities in each of their
areas of wider influence, scopes 1 and 2, and scope 3
• work with urgency to reduce GHG emissions as quickly as possible in order to
get under and stay under 1.5°C aligned decarbonisation pathways, i.e. to go
as far as possible as fast as possible, and minimise cumulative emissions
• put governance processes, systems and senior level accountability in place
that ensure policy and project development is aligned to national emission
reduction targets
• measure, monitor and report on annual progress against their targets and
decarbonisation pathway.
Implementing the second duty: adaptation 
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Under section 44 of the 2009 Act, relevant public bodies have a duty, in exercising
their functions, to act in the way best calculated to help deliver the Scottish National
Adaptation Plan (SNAP).   
All public bodies must identify the national adaptation objectives from SNAP relevant
to their functions and act in a way that supports the delivery of these objectives.   
Organisations will have varying degrees of influence in relation to adaptation in
Scotland depending on their particular role, functions and responsibilities, but all
public bodies need to be resilient to the future climate and to plan for business
continuity in relation to delivery of their functions and the services they deliver to the
wider community.   
To help demonstrate compliance with this duty, public bodies should:
• undertake a climate related risk assessment or assessments
• develop and implement an adaptation plan or plans with, as best practice,
regard to just transition principles
• ensure that appropriate climate risks are included on corporate risk registers
• where applicable, note the specific adaptation action assigned to them in the
SNAP and align their work with these
• actively seek to work in partnership with other organisations to develop and
implement wider placed-based adaptation plans
• undertake the above giving due consideration to their physical assets
including buildings, land and fleet; their staff and service users; the services
they deliver; and the functions they exercise. 
Key outcomes will be that public bodies:
• have a sound understanding of why adaptation is important for their
organisation and what the impacts of climate change could mean, and will
have identified and assessed their risks, vulnerabilities and any potential
opportunities
• have identified and assessed the adaptation options, and have measures in
place to implement their chosen strategies so that their physical assets, daily
operations and service delivery are adapted to the changing climate and are
resilient to its impacts 
• monitor and evaluate implemented measures to ensure that adaptation efforts
remain sufficient and responsive to changing conditions
• where applicable, contribute to the achievement of the specific adaptation
outcomes assigned to them in the SNAP, and are able to track and report on
delivery
• contribute to the effective adaptation of the places in which their sites,
operations and services are located and delivered. 
Implementing the third duty: acting in the most sustainable way 
The third of the climate change duties set out in section 44 of the Climate Change
(Scotland) Act 2009 requires public bodies, in exercising their functions, to act in the
way that they consider to be most sustainable. 
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The National Performance Framework (NPF) is the overarching framework within
which the work of central and local government, and the wider public sector, takes
place. The NPF National Outcomes are aligned with the United Nations Sustainable
Development Goals (UN SDGs). Section 1 of the Community Empowerment
(Scotland) Act 2015 requires public authorities, in carrying out their functions, to
have regard to the National Outcomes. 
To help demonstrate compliance with the third duty, public bodies should:
• align their work to the NPF and delivery of the National Outcomes and, as
best practice, to the just transition principles
• ensure that sustainable development is embedded in strategies, policies,
plans and projects
• integrate a sustainable development impact assessment, or equivalent,
process into decision-making processes, including financial decisions
• ensure that procurement activities are undertaken in line with relevant
legislation and the Sustainable Procurement Duty
• monitor and evaluate policy implementation and outcomes against the five
principles of the UK Shared Framework for Sustainable Development.
Key outcomes for public bodies will be that:
• potential policies and decisions are, before they are finalised, assessed for
fairness, ecological impact, economic sustainability, whether they are based
on good evidence, and whether those who are likely to be affected have had a
chance to participate in the decision-making process
• activities remain within planetary boundaries, and focus on the fair distribution
of both benefits and disbenefits
• good governance for sustainable development ensures participation,
accountability and transparency
• the procurement process is used as an opportunity to maximise social and
environmental, as well as economic, benefits; and to ensure that
environmental and other harms are minimised
• they contribute, through their functions, to the National Outcomes and
achievement of the UN SDGs.
Reporting 
All public bodies subject to the climate change duties should include climate change
and sustainability reporting as part of their annual corporate reporting process. 
Over 180 public bodies deemed to be ‘major players’ have a statutory duty under
The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland)
Order 2015, as amended, to report annually on their compliance with the climate
change duties. These bodies are listed in schedule 1 of the Order. 
Recording greenhouse gas emissions, and the actions taken to contribute to
adaptation and sustainability, allows public bodies to set targets and monitor
progress towards achieving these targets. In order to reduce emissions and work
towards net zero and other targets, bodies need to understand how their emissions
arise.
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To date, emissions reporting by public bodies has focused primarily on scope 1 and
2 emissions: from heating and power used in buildings, and on the emissions from
fleet vehicles. It is important, moving forwards, that while bodies continue to focus
efforts on reducing their scope 1 and 2 emissions, they also start to measure,
monitor and reduce scope 3 emissions from the wider value chain. 
As a baseline, public bodies subject to the reporting duty are expected, as part of
best practice, to include scope 3 emissions from: 
• consumption of mains water 
• waste and waste water 
• business travel including, where appropriate, overnight stays 
• commuting and homeworking 
• fuel and energy-related emissions not included in scopes 1 and 2 
Over time those subject to the reporting duties, in particular bodies with larger spend
and influence, are expected to expand reporting of scope 3 emissions to include all
relevant categories. For most public bodies, indirect emissions from the wider value
chain will be where their greatest climate impact lies – typically from the procurement
of goods, works and services, from construction, and from investments. It is
important that public bodies work towards fuller reporting of scope 3 emissions, to
provide a more complete picture of their climate impact. In turn, this will enable
bodies to focus resource to where they can achieve the greatest emissions
reductions. 
Glossary and key definitions 
This guide to key terms and glossary explains the meanings as intended within
this guidance document. They should not be relied upon for any purpose beyond
assisting with using this guidance. 
In particular, bodies should note the following: 
• ‘Must’: the word ‘must’ is used where bodies have a statutory obligation to
undertake the activity or meet the requirement. For example, relevant
bodies must, under the Climate Change (Scotland) Act 2009, contribute to
national emissions reduction targets. ‘Must’ is also used where a specified
action is required in order to meet an external standard, for example the
Woodland Carbon or Peatland Codes.
• ‘Should’: ‘should’ is used where bodies are expected or strongly
recommended to undertake the activity, but it is not a legal requirement.
For example, public bodies should, where relevant, develop a carbon
management plan or equivalent.
‘Could’: ‘could’ is used where undertaking the action would be an example of
best practice but it is not an expectation. These measures may not be
appropriate or relevant to every public body. For example, a body could
implement an environmental management system. However, this is neither
legally required nor expected, and is likely to be an action more appropriate to a
larger body. 
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Guide to key terms 
‘Exercising functions’: public bodies functions are often conferred by legislation,
depending on the nature of the body and whether it is set up by legislation or as a
company limited by guarantee. Schedule 1 of the Interpretation and Legislative
Reform (Scotland) Act 2010 defines “functions” as including both powers and duties. 
In fulfilling the climate change duties, ‘exercising functions’ should be taken to
encompass the body’s corporate operational functions, policy making functions or
influence, and the overall delivery function (i.e. the purpose of the body). 
For example, for a local authority, corporate operational functions may include
procurement, estate management and finance. Policy making functions might
include public transport and active travel planning, impacting on greenhouse gas
emissions from transport in a particular local area, and on wider linked issues
including resilience of infrastructure. Influence might include direct influence, for
example over suppliers; and wider influence through Local Development Plans and
engagement with local businesses. The delivery function or purpose would be to
deliver local government services within that authority area. 
‘Major players’: within the context of this guidance, ‘major players’ is intended to
mean public bodies deemed to be significant either within their sector or the public
sector as a whole. They may be bodies with large estates and or large numbers of
staff; large expenditure; provide an audit or regulatory function; or hold significant
influence over other bodies, the sector or the wider public. They include local
authorities, NHS health boards, integration joint boards, colleges and universities,
transport partnerships, executive agencies and NDPBs. 
The major players are listed in schedule 1 of the Climate Change (Duties of Public
Bodies: Reporting Requirements) (Scotland) Order 2015, as amended.
Glossary 
Adaptation - Adaptation to climate change involves the deliberate and systematic
adjustment of systems and processes to effectively address both anticipated and
actual climate change impacts.  
Area wide - Area wide refers to the totality of activities either planned or currently
occurring within a defined geographic area. This aggregates and then breaks down
measures, activities, and actions at an area wide scale. 
Bottom-up approaches - A bottom-up approach within an organisation is where
employees are involved in the decision-making process, not just management or
those at the "top" of the organisation. The bottom-up approach is based on the
assumption that the employees have the best knowledge and experience of the daily
operations and challenges of the organisation. They are able to provide valuable
insights and suggestions that can improve the quality and effectiveness of the
decisions. In the wider context, a bottom-up approach would involve local residents,
businesses and other stakeholders in a similar way, to ensure that local needs and
experience are built into the decision-making process.
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Carbon credits - Measured in tonnes of carbon dioxide equivalent (tCO2e), carbon
credits reduce inputs to or remove from the atmosphere the equivalent amount of
CO2 or other GHG, and can be used to offset emissions generated by an
organisation. Nature-based credits use natural carbon stores and sinks, such as
woody biomass and soils. Other types of credits include engineered removals, such
as direct air capture and storage technologies. 
Within this guidance, we refer to three types of nature-based carbon credits, defined
as:
• Emissions reductions: such as reducing the emissions from degraded
peatland by undertaking restoration activities. The Scottish Government
supported Peatland Code issues these type of carbon credits. 
• Removals: such as creating new woodland which actively sequesters
atmospheric carbon. The Scottish Government supported Woodland Carbon
Code (WCC) issues these type of carbon credits.
• Avoidance: credits associated with, for example, retaining a carbon store or
sink in its present condition, e.g. avoiding further deforestation. There are no
current Scottish Government supported carbon codes that issue avoidance
credits. 
Carbon credits are externally verified and purchased or sold on a market. In
principle, they could also be “gifted”. This guidance relates specifically to carbon
credits within the voluntary carbon market. 
Carbon insets - Carbon ‘insets’ are carbon and GHG management and reduction
activities within the organisation’s operational boundary on their own landholdings or,
by agreement, on the wider public estate. While a wide range of insetting activities
exist, this guidance focuses on nature-based insetting projects, for example peatland
restoration or woodland creation. 
Carbon neutral - Carbon neutrality describes an approach whereby a body reduces
and or offsets its carbon emissions. Unlike net zero carbon, this approach does not
prioritise emissions reductions: carbon neutrality can be achieved by simply
offsetting 100% of them. Carbon neutrality is a less robust approach to climate
change mitigation, and as such is not supported or aligned to the Scottish
Government’s approach to climate change mitigation. 
Carbon offsets - Carbon offsets are used to counterbalance emissions of carbon
dioxide or other greenhouse gases (GHGs) generated by an organisation's
operational activities. Measured in tonnes of carbon dioxide equivalent (tCO2e),
offsets reduce or remove from the atmosphere the equivalent amount of CO2 or
other GHG generated by the organisation. Offsetting allows organisations to balance
emissions within their boundary with carbon savings realised elsewhere, for example
carbon sequestered in woodland on a third party’s land, to achieve overall net zero
emissions. Offsets can take various forms: the most common are carbon credits. 
Cascading risks - Cascading risk refers to the domino effect of risks. It is the
principle that one risk may lead to further impacts downstream, or in another part of
the system. For example, increases in heavy downpours of rain may lead to flooding.
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Cascading risks from this might include soil run-off on contaminated land, leading to
river pollution. 
Climate justice – Climate justice is a people-centred, human rights-based approach
that aims to share the benefits of equitable global development. It recognises that
those who are being affected first and worst by climate change have often done little
or nothing to cause the problem. Climate justice addresses the disproportionate
impacts of climate change on vulnerable communities and systems. Prioritising
equitable outcomes ensures that adaptation projects are inclusive and
comprehensive. It involves actively seeking input from marginalised communities,
who often bear the burden of negative climate impacts and events. This approach
can result in more resilient strategies that cater to and accommodate the often very
context-specific needs of these communities and reduce the likelihood of future
resistance. 
Climate scenarios - Climate scenarios are plausible representations of the future
climate of the Earth, based on its current observed state and different greenhouse
gas emission scenarios. They are useful for investigating potential impacts of
anthropogenic climate change. 
Co-benefits - A positive effect that a policy or measure aimed at one objective has
on another objective, thereby increasing the total benefit to society or the
environment. (IPCC Glossary) Health co-benefits are benefits to health and
wellbeing beyond those intended by the climate action. They are delivered through
key pathways including consumption of healthy sustainable diets, promotion of
sustainable transport, increase use of nature based solutions, increasing the energy
efficiency of homes and reductions in air pollution from replacing fossil fuel with
clean renewable energy sources. 
Community resilience - Communities and individuals harnessing resources and
expertise to help themselves prepare for, respond to and recover from emergencies,
in a way that complements the work of the emergency responders. 
Data-informed climate change risk assessment - Data informs the risk
assessment, however there is more focus on weaving in lived-experience, and
qualitative data that is harder to quantify. An organisation using this approach might
not need in-depth climate models or may value a quicker risk assessment process. 
Data-led climate change risk assessment - Data is at the core of the risk
assessment. A data-led approach prioritises the use of data to make assessments
about climate change risk. This is a more scientific approach using quantitative
analysis around climate risk. An organisation using this approach might model
potential climate impacts on their organisation. 
Decarbonisation pathway - A decarbonisation pathway sets out the trajectory for
reaching net zero carbon by a target date. It defines interim emission reductions
targets. Whether emissions are cut earlier or later in the pathway has a material
consequence on the cumulative carbon emissions over time. A decarbonisation
pathway which makes deep reductions in the early years will have significantly less
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cumulative emissions that a pathway (for the same emission source) that leaves
reductions until close to the target year. 
Emission – The release of a greenhouse gas into the atmosphere. Under the
Greenhouse Gas (GHG) Protocol, emissions are classified as direct or indirect,
and are categorised into scopes for the purposes of carbon accounting and
reporting. 
Exposure - In relation to climate change adaptation, exposure refers to the degree
to which a system (such as a human population or ecosystem) or asset is subjected
to climate related hazards. Exposure is highly context specific and is influenced by
various factors including geographic location, land use and land management
practices, infrastructure and socio-economic conditions. It encompasses not only the
physical hazard posed by the changing climate but also considers factors such as
safety or mitigating measures that may be in place, societal vulnerabilities, and
governance 
Greenhouse gas (GHG) - Greenhouse gases in this guidance are as defined in the
Greenhouse Gas Protocol, and are the six gases listed in the Kyoto Protocol: carbon
dioxide (CO2); methane (CH4); nitrous oxide (N2O); hydrofluorocarbons (HFCs);
perfluorocarbons (PFCs); and sulphur hexafluoride (SF6). 
Greenhouse Gas (GHG) Protocol - GHG Protocol definition: “A multi-stakeholder
collaboration convened by the World Resources Institute and World Business
Council for Sustainable Development to design, develop and promote the use of
accounting and reporting standards for business.” It comprises of a series of
standards, including the GHG Protocol Corporate Accounting and Reporting
Standard and the Corporate Value Chain (Scope 3) Standard, the principles of which
public bodies are recommended to follow for their corporate GHG accounting and
reporting. 
Hazard - In relation to climate change adaptation, hazard refers to a specific climate
related event or phenomenon with the potential to cause harm or adverse impacts on
the environment, human health, economies or societies. Hazards associated with
climate change include extreme weather events (hurricanes, floods, droughts and
heatwaves) sea level rise, changes in precipitation patterns and shifts in
temperature. 
Just transition - For the Scottish Government a just transition means becoming a
net zero, climate resilient economy in a fair way that seeks to tackle inequality and
injustice. Just transition is about both the outcome – a fairer, greener future – and
the way we get there in partnership with those most likely to be impacted by the
change. 
Mainstreaming – mainstreaming the climate change duties means ensuring that
that climate and sustainability issues are considered in everything the public body
does, and in how it makes decisions. Climate change and sustainability should be
embedded across the organisation and in corporate processes. 
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Maladaptation - The unintended consequence of misjudged or miscalculated
adaptation measures, that can lead to counterproductive and even harmful
outcomes if not carefully considered and managed. Misguided adaptation actions
and projects can result in economic losses and exacerbate social disparities,
affecting marginalised communities disproportionately (contrary to the goal of
ensuring climate justice and equitable adaptation), inadvertently harm the
environment, fail to address the community’s true needs and in some cases cause
resistance to new or further projects. 
Materiality - In relation to greenhouse gas emissions, materiality relates to
significance and impact, and involves a value judgement. The emission sources
which are most material to an organisation are those which contribute significantly to
the overall footprint; and where mitigation action would have the highest impact, i.e.
result in the greatest reductions in emissions. These sources may lie in scope 3,
outside the direct control of the organisation, but within its influence (e.g. emissions
related to procured goods and services). 
Mitigation - Reducing greenhouse gas emissions that contribute to climate change. 
Net zero (or net zero carbon) – Net zero describes an approach which reduces an
actor’s GHG emissions as far as possible. Any remaining unavoidable residual
emissions may be inset or offset through a credible and robust offsetting
mechanism. 
Overshoot - In relation to decarbonisation pathways, overshoot occurs when
emissions fail to be reduced in line with the chosen pathway, leading to higher
cumulative emissions over the same time period. The emissions related to this
overshoot can be balanced out (in terms of meeting targets) by an equivalent
amount of undershoot in future years. 
Place based – ‘Place based’ refers to the design of future solutions and approaches
by considering the specific needs and attributes of a place (however that place is
defined). This recognises the complex and interconnected nature of a place, and in
this case the impact that has on the effectiveness of measures to address climate
change. 
Public body - Within this guidance, public bodies are those bodies subject to the
climate change duties,  defined in section 44(2) of the Climate Change (Scotland)
Act 2009. 
RCP pathways - Representative concentration pathways (RCPs) are scenarios
used to help characterise the uncertainty in climate models so scientists can
generate data about possible future climates 
Residual emissions – see unavoidable emissions. 
Resilience - Building long term capacity and enhancing a region’s ability to absorb
shocks or to recover from a hazard or impact of climate change. Leading to
transformative change. 
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Risk - Interaction of a hazard, exposure and vulnerability where a hazard is a
physical event such as a flood or heatwave, exposure is the regional area in which
the hazard may occur and vulnerability refers to the propensity of those exposed to
suffer 
Scope – In relation to carbon accounting, scopes are a way of categorising emission
sources in relation to the reporting organisation. They are used to provide
transparency in emissions accounting, making it clear the type of emission source
and the level of control of the reporting organisation over the source. Three scopes
have been defined and are used on a global basis. 
Scope 1 - Direct greenhouse gas emissions from sources owned or controlled by the
reporting organisation. For example, emissions from fuel combustion in boilers or
vehicles, fugitive emissions from refrigeration or air conditioning equipment or
emissions from chemical production in processing equipment are all sources of
scope 1 emissions if the equipment is owned or controlled by the organisation. 
Scope 2 - The indirect greenhouse gas emissions from the generation of purchased
electricity, heat, steam or cooling. While scope 2 emissions physically occur at a
generation facility, responsibility for the emissions is allocated to the end-users
based on the amount purchased. 
Scope 3 - All other indirect greenhouse gas emissions which occur as a
consequence of the activities of the reporting organisation, not already counted
under scope 2. Scope 3 emissions can occur both upstream and downstream in the
value chain from an organisation. Upstream emissions sources include purchased
goods and services, transportation and distribution, business travel and employee
commuting. Downstream emissions include use of sold products, end-of-life
treatment of sold products, and investments. Under the GHG Protocol, scope 3
emissions are reported under 15 categories. 
Stacked hazards (or stacked risks) - Stacked risks or hazards are simultaneously
occurring risks or hazards impacting a spatial area, business unit or organisation.
For example, flooding occurring alongside high winds and spring tides. These risks
may or may not interact. 
Sustainable development - UK Shared Framework for Sustainable Development
definition: Sustainable development is based on five principles. The two essential
conditions for sustainable development - living within environmental limits and
ensuring a strong, healthy and just society – are supported by three additional
conditions: achieving a sustainable economy, using sound science responsibly, and
promoting good governance. 
Theory of change – United Nations definition: “a theory of change is a method that
explains how a given intervention, or set of interventions, are expected to lead to a
specific development change, drawing on a causal analysis based on available
evidence”, i.e. a theory as to how and why specific policies and activities lead to
certain impacts and outcomes. 
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Transformative adaptation - Similar to resilience, transformative adaptation looks
to address the root causes of vulnerability, leading to societal or systems change. 
Transitional risk – Transitional risks are those that arise from efforts to move to a
lower carbon economy. Transition risks include policy, legal, technological, market
and reputational risks (TCFD, 2017). 
Unavoidable emissions (or unavoidable residual emissions) - In the net zero
carbon context, unavoidable residual emissions are those emissions which remain
after a body has taken all reasonable steps to reduce or remove them. They may
include emissions related to specific processes or technologies for which no viable
alternative currently exists, for example anaesthetic gases used in healthcare
settings or refrigerant gases used in heat pumps. 
Undershoot - In relation to decarbonisation pathways, undershoot occurs when
emissions are reduced faster than the chosen pathway, leading to lower cumulative
emissions over the same time period. 
Vulnerability - In relation to climate change adaptation, vulnerability is the extent to
which a society, economy or ecosystem is at risk of adverse impacts from climate
related hazards. This concept focuses not only on physical exposure to climate
driven events but considers socio-economic factors like poverty, inequality and
access to resources. It also considers the system's capacity to recover and adapt
following climate related events. 
Whole life carbon - Whole life carbon assessment considers the entire life cycle of
a product or asset. Whole life carbon includes the carbon associated with resource
extraction, the manufacture or construction of the asset or product, and its treatment
at end of useful life, as well as the carbon associated with maintaining and operating
it. 
Whole systems approaches (or whole systems thinking) - Whole systems
thinking works to understand how systems, and elements within those, are
connected, where dependencies lie, and how they influence each other. Whole
system approaches take systems thinking and tools and apply them to support
collaborative action across a broad set of partners to address complex problems. 
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Draft Statutory Guidance 
Climate change duties: Draft Statutory guidance for
Scottish public bodies on putting the climate change
duties into practice 
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1. Context 
This section outlines the legal context, the purpose of this guidance, who should
have regard to it and how it should be used. 
1.1 The climate change duties – legal basis 
This statutory guidance is issued by the Scottish Ministers to Scottish public bodies
under the Climate Change (Scotland) Act 2009 (‘the 2009 Act’). 
The 2009 Act places a legal responsibility on relevant public bodies in Scotland to
meet the climate change duties. Section 44(2) defines a “public body” as a Scottish
public authority within the meaning of section 3(1)(a) of the Freedom of Information
(Scotland) Act 2002 (asp 13). Public bodies must check whether they fall within the
definition and act accordingly. 
The duties are set out in section 44(1) of the 2009 Act and require that a public body
must, in exercising its functions, act – 
(a) in the way best calculated to contribute to the delivery of emissions reduction
targets (i.e. mitigation)
(b) in the way best calculated to help deliver the Adaptation Programme
(c) in a way that it considers most sustainable. 
The purpose of this statutory guidance is to support public bodies in
performing their climate change duties. It aims to help public bodies to minimise
their operational emissions, adapt and become resilient to the current and future
impacts of the changing climate, live within environmental limits and ensure a strong,
healthy and just society. 
Section 45 of the 2009 Act requires Scottish Ministers to give guidance to public
bodies in relation to the duties. When deciding how best to fulfil their duties, public
bodies are required to take this statutory guidance into account – under the Act they
must have regard to such guidance. 
Statutory guidance for public bodies under section 45 was first published in 2011
(‘the 2011 guidance’). Since the 2011 guidance was published, related legislation
covering areas including emission reduction targets and reporting on compliance
with the climate change duties has come into force. In addition, the fields of
knowledge around carbon reporting, mitigation, adaptation and sustainable
development have moved forward significantly. This guidance replaces and
supersedes the 2011 guidance in full. 
Interim, non-statutory guidance Public Sector Leadership on the Global Climate
Emergency was published in 2021 (‘the 2021 interim guidance’). It was
supplementary to the 2011 guidance, and aimed to provide more up to date advice
for public bodies on certain key areas. This statutory guidance supersedes the 2021
interim guidance. 
The climate change duties require public bodies, in exercising their functions, to act
in the way best calculated to contribute to emissions reductions (climate change
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mitigation), climate change adaptation, and to act sustainably. It is important that the
three duties are considered together in an integrated and holistic way, and that they
are given equal weight or importance in decision making. 
This guidance is intended to be useful to all public bodies, not just those legally
subject to the duties. The guidance aims to be a potential source of information, tools
and support for any public body aiming to contribute to Scotland’s national climate
change targets and plans. 
1.2 Proportionality 
What is required in compliance with the climate change duties will vary between
bodies, depending upon various factors including the size of body, its functions,
budget and wider influence. It is considered appropriate that actions taken by
individual bodies are proportionate to that body’s nature and function. 
Actions taken by a small public body with limited influence on emissions, and a small
estate or staff numbers and budget should reflect their resources and the nature of
what they do. Equally, there are a number of public bodies that Scottish Ministers
consider to be 'major players' as they have a larger influence or impact on climate
change than others, for example local authorities, NHS health boards, colleges and
universities, transport partnerships and executive agencies. The major players are
expected to show leadership in climate action.  
The major players are listed in Schedule 1 of The Climate Change (Duties of Public
Bodies: Reporting Requirements) (Scotland) Order 2015.
1.3 Development of the guidance 
This guidance was co-developed in discussion with the Sustainable Scotland
Network (SSN) Steering Group, and through a series of pre-consultation stakeholder
engagement workshops and events held to inform the preparation of the guidance
and the supplements. Content and case studies have been contributed by bodies
from across the public sector. 
This draft guidance was issued for public consultation in February 2025 for a 12
week period, seeking views to inform development of the final guidance. A copy of
the consultation document can be accessed via Scottish Government’s consultation
website. In due course, where respondents have supplied the appropriate
permissions, their responses will be made available, along with the consultation
analysis report. 
1.4 Structure of the guidance 
This document forms the statutory core of the guidance to public bodies, and is
intended to provide guidance on the overarching principles and the high level actions
that all public bodies are expected to undertake. This core statutory guidance will be
accompanied by a series of non-statutory topic supplements, which are intended to
provide more detailed guidance to practitioners working in each area, and some of
which may be more relevant to some public bodies than others. The intended
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content of these supplements is outlined below. Additional supplements may be
added in the future as required. 
Built Estate – estate decarbonisation, heat in buildings, energy and
renewables, heat networks, social housing, whole life carbon. 
Travel and Transport – the sustainable travel hierarchy, active travel, public
transport, fleet decarbonisation, sustainable travel planning. 
Land and Nature – nature based solutions, biodiversity, regenerative
agriculture, coastal change adaptation planning, estimating land-based
emissions. 
Sustainable Places – place based approaches, planning, National Planning
Framework 4 (NPF4), community wealth building and community planning
partnerships, sustainable development impact assessments. 
Health and Wellbeing – the NHS sector, public health, guidance for
Integration Joint Boards (IJBs). 
Finance – ethical investing, adaptation finance, reporting on emissions
associated with investments, writing an effective business case. 
Working Together - collaboration, behaviour change and engagement,
community climate hubs. 
Sustainable Procurement - sustainable procurement, the circular economy,
supplier and contract management, estimating Scope 3 emissions from
purchased goods and services. 
Public bodies must ensure that they familiarise themselves with the content of this
core statutory guidance before referring to the supplements. Although the
supplements are arranged by topic, public bodies are likely to find that relevant
information may be covered by several supplements. The case studies included are
intended to be useful on a number of levels and illustrate various aspects of best
practice. For example, a case study in the Travel and Transport supplement may
also talk about finance, procurement, health and wellbeing and working together. 
The core guidance and the topic supplements will be kept under review to ensure
that they remain an effective tool for assisting public bodies in their action on climate
change. Further materials which support this guidance will also be made available
through the Scottish Government, and through the Sustainable Scotland Network
(SSN), Scotland’s public sector network on sustainability and climate change. 
1.5 How the guidance should be used 
Due to their non-statutory nature, the supplements are not included in this
consultation. They are not publicly available at this time. 
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This guidance should be used by public bodies to assist them in fulfilling their duties
under section 44 of the 2009 Act. Public bodies are reminded that it is an advisory
document only, not a definitive statement of the law, and that responsibility for
compliance with the climate change duties rests with public bodies
themselves. 
Following this guidance will assist public bodies in considering how they mainstream
climate action into their strategic and corporate processes. It does not constitute
legal advice to public bodies on compliance, nor does it absolve them of the duties
placed upon them in legislation. In all matters of interpretation of the duties set out in
the 2009 Act, public bodies must satisfy themselves that they are compliant, seeking
their own legal advice if required. 
Public bodies operate in a complex landscape of policy, legislation and statutory
obligations, often dependent upon the sector in which they function. In following this
guidance, bodies must ensure that they take the wider context into account, as
appropriate to their role and sector. It is the responsibility of the public body itself to
ensure that it follows all current and relevant legislation and regulation as it develops
its corporate policies and plans to fulfil its climate change duties.   
The Scottish Government strategies, policies, plans and guidance referred to in this
guidance will change over time – many of them require to be updated at five yearly
intervals, for example. Bodies should be aware of this and ensure that they refer to
the current versions, which may supersede those referenced by name in this
guidance. 
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2. Strategic Framework 
This chapter outlines Scotland’s strategic framework for climate action: the policies
and legislation which embed climate change and sustainable development in the
work of government. 
It also aims to set climate and sustainability action within the wider context of a just
transition, highlighting other key interlinked areas of policy and legislation including
biodiversity, the wellbeing economy, community wealth building, sustainable
development, equalities, health and wellbeing, human rights and health and safety. 
The chapter ends with a section on impact assessments, outlining the key statutory
and non-statutory impact assessments that bodies are likely to undertake as they
develop and implement climate and sustainability plans, programmes and projects. 
The strategic framework is supported by relevant sectoral legislation, for example
covering heat in buildings, heat networks and the circular economy. This supporting
legislation is detailed in following chapters and the accompanying supplements. 
2.1 Scotland’s Strategic Framework 
The Scottish Government’s strategic framework for action on climate change,
sustainable development and a just transition puts them at the heart of government.
Action is embedded through the National Performance Framework (NPF) and
through various strategies, programmes, policies and plans. This strategic
framework is made up of legislation, policies, practical support and tools. Delivery of
the climate change duties by public bodies is an important aspect of the framework,
both in terms of bodies exercising their functions, and in the influence they can bring
to bear on service users, stakeholders and the supply chain. 
The Environment Strategy creates an overarching framework for Scotland's
environment and climate change policies, including the Climate Change Plan and
National Adaptation Plan. The Scottish Government recognises biodiversity loss as a
crisis as significant as, and closely interlinked with, the climate crisis, and has
responded by publishing the Scottish Biodiversity Strategy. Over the coming years,
biodiversity delivery plans and a monitoring framework will be progressed through
developing and driving investment in nature based solutions. The biodiversity
framework will play a significant role in delivering the national commitment to a
nature-positive net zero and climate resilient Scotland. 
Our action on climate change and biodiversity are aligned with our vision to create a
wellbeing economy, where Scotland thrives across economic, social and
environmental dimensions. 
Public bodies should ensure they understand the strategic framework and take
relevant policy, legislation and statutory obligations into account as they work to fulfil
their climate change duties. Relevance will vary depending on the nature of the
public body and its functions, and the sector in which they work. Key elements are
described in the sections below. 
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2.1.1 National Performance Framework 
The National Performance Framework (NPF) is the overarching framework within
which the work of central and local government, and the wider public sector, takes
place. The NPF aims to create a more successful country, with increased health and
wellbeing and reduced inequalities, and where social, environmental and economic
progress are given equal importance. It includes values which guide the approach to
government and public services in Scotland - to treat all our people with kindness,
dignity and compassion, and act in an open and transparent way. 
To help achieve its aims, the framework sets out National Outcomes. The Outcomes
describe the kind of country the framework is trying to create. These align with the
United Nations Sustainable Development Goals (UN SDGs), reflect the values and
aspirations of the people of Scotland and are intended to help to track progress
towards their achievement. 
Figure 1: the National Performance Framework 
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Climate action is likely to contribute primarily to the Environment Outcome ‘we value,
enjoy, protect and enhance our environment’. However, due to the multiple
dependencies between climate, environment and other factors, and the opportunities
offered by a just transition to a low carbon economy, it will also contribute to all the
key outcomes. For example: 
• Economy – we have a globally competitive, entrepreneurial, inclusive and
sustainable economy
• Fair Work and Business – we have thriving and innovative businesses, with
quality jobs and fair work for everyone
• Communities – we live in communities that are inclusive, empowered, resilient
and safe
• Health – we are healthy and active. 
Climate change is not a single-issue policy area. Appropriate and effective action to
tackle climate change and promote sustainable development is likely to enhance all
National Outcomes. Conversely, the impacts of the changing climate will add stress
and complexity to the achievement of the other outcomes. 
The NPF measures Scotland’s progress against the National Outcomes using a
series of National Indicators. These include a range of social, environmental and
economic indicators, and are intended to give a measure of national wellbeing. 
These illustrate how climate action is embedded across all of the National
Outcomes, and how rising to meet climate challenges can achieve benefits across
society and the economy. For example: 
• Installing an air source heat pump to generate renewable heat and displace
oil consumption from an old boiler contributes to the Environment Outcome,
through the energy from renewable sources indicator; and to the Economy
Outcome through the carbon footprint indicator. Reducing pollution and
contributing to improved air quality contributes to the Health Outcome; while
supporting renewable technology can provide opportunities for skills
development and employment. 
• Developing a sustainable business travel strategy to reduce travel emissions
will contribute to the Economy Outcome through the carbon footprint indicator;
and to the Health Outcome through the physical activity, active travel journeys
and mental wellbeing indicators. Reducing the emissions associated with
transport will help improve air quality, again contributing more widely to the
Health Outcome.
• Creating new woodland to help manage flood risk as part of an adaptation
plan may contribute to the Environment Outcome biodiversity indicator; to the
Economy Outcome natural capital indicator; and Community Outcome access
to blue and green space indicator. Increased opportunities to access green
space and nature can contribute positively to the Health Outcome indicators
for mental wellbeing and physical activity. Equally, by reducing the risk of
peoples’ homes being flooded, the many negative impacts on physical and
mental health and wellbeing can be reduced. 
2.1.2 The Climate Change (Scotland) Act 2009 
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The Climate Change (Scotland) Act 2009 as amended is the central legislation of the
climate change framework and supports the just transition to a sustainable, resilient,
low-carbon economy. 
It requires the Scottish Government to take action in relation to both climate change
mitigation and adaptation, to develop a public engagement strategy, and allows for
the provision of subordinate legislation, if required to take certain actions forward. As
outlined in section 1.1, section 44 of the 2009 Act places climate change duties on
public bodies to contribute to emission reduction targets (mitigation), to the
adaptation programme, and to act in a way that it considers most sustainable. 
2.1.2.1 Mitigation 
Statutory reduction targets for Scotland’s greenhouse gas (GHG) emissions were
first introduced by the 2009 Act, covering carbon dioxide and other GHGs including
methane and nitrous oxide. In direct response to the Paris Agreement, an
international treaty under the United Nations Framework Convention on Climate
Change, the original targets were strengthened by the Climate Change (Emission
Reduction Targets) (Scotland) Act 2019 (‘the 2019 Act’), creating the Scottish net
zero target of 2045, and introducing annual and interim targets. 
The Climate Change (Emission Reduction Targets) (Scotland) Act 2024 (‘the 2024
Act’) recently adjusted this approach, replacing the annual and interim targets with 5-
year carbon budgets while 2045 remains the national net zero target. The carbon
budgets are to be set through secondary legislation pending receipt of advice from
the Climate Change Committee. This advice is expected in spring 2025: once
received, Scottish Government will have three months in which to introduce draft
regulations to the Scottish Parliament. It is therefore expected that the national
carbon budgets will be set in legislation before the end of 2025. 
The 2009 Act also sets out the principles for achieving a just transition to net zero, as
outlined in section 2.1.2.3 below.  
All of Scotland’s statutory targets are economy-wide and include all territorial
greenhouse gas emissions, a share of those from international aviation and shipping,
and territorial removals (including from the land use sectors). The statutory
framework sets a default position that the targets must be met through domestic
action alone.
Public bodies should be aware that, in addition to the national targets, further specific
non-statutory targets are in place. Such targets are detailed in the relevant
supplements. 
2.1.2.2 Climate Change Plan 
Part 3 of the 2009 Act requires Scottish Ministers to produce a climate change plan
every five years. The Climate Change Plan (CCP) is a strategic delivery plan and
sets out Scottish Ministers’ proposals and policies for meeting the emissions
reduction targets over the plan period. The CCP is required to cover sectors
including energy supply, transport, business and industrial processes, buildings
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(residential and public), waste management, land use, land use change and forestry,
and agriculture.
The draft of the next Climate Change Plan, covering period 2026 to 2030, will be
introduced to the Scottish Parliament within two months of the secondary legislation
setting the national 5-year carbon budgets coming into force. Due to this
dependency, it is not possible to provide a specific date at this stage. A period of
scrutiny on the draft requires to be carried out before the plan can be finalised. 
Scottish Ministers are required to publish annual statutory monitoring reports against
the Climate Change Plan by the 2009 Act. Each annual report must contain an
assessment of progress towards implementing the proposals and policies contained
in the Climate Change Plan.
2.1.2.3 Just Transition 
For Scottish Government a just transition means becoming a net zero, climate
resilient Scotland in a way that also seeks to deliver fairness, tackle inequality and
injustice and improve health. Just transition is about both the outcome – a fairer,
greener future – and the way we get there in partnership with those most likely to be
impacted by the change. It is a cross-cutting agenda that encompasses our
economic, societal and environmental ambitions. 
Scotland has shown international leadership in embedding just transition principles
into its statutory climate legislation. The 2009 Act requires the next Climate Change
Plan (draft due 2025) with reference to the just transition principles to: 
(a) explain how the proposals and policies set out in the plan are expected to
affect different sectors of the Scottish economy and different regions in
Scotland, including how they are expected to affect employment in those
sectors and regions
(b) set out the Scottish Ministers’ proposals and policies for supporting the
workforce, employers and communities in those sectors and regions. 
The 2009 Act also embeds the just transition principles, requiring Ministers to have
regard to them in preparing the Climate Change Plan. The just transition principles
set out the importance of taking action to reduce net Scottish emissions of GHGs in
a way which:
(a) supports environmentally and socially sustainable jobs
(b) supports low-carbon investment and infrastructure
(c) develops and maintains social consensus through engagement with
workers, trade unions, communities, non-governmental organisations
representatives of the interests of business and industry and such other
persons as the Scottish Ministers consider appropriate
(d) creates decent, fair and high-value work in a way which does not negatively
affect the current workforce and overall economy
(e) contributes to resource efficient and sustainable economic approaches
which help to address inequality and poverty. 
The just transition principles provide vital context to our wider just transition
obligations and ensure that our wider climate actions support a fair transition.
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2.1.2.3.1 Just Transition Planning 
Where the Climate Change Plan must set out the overall roadmap to net zero by
focussing on the proposals and policies for meeting emission reduction targets in the
plan period, Just Transition (JT) Plans are concerned with the manner of the
transition, identifying economic, environmental and social opportunities (and risks). 
They will aim to provide greater certainty for businesses, workers and communities
on what the journey to net zero means in practice.   
The Scottish Government published the National Just Transition Planning
Framework in September 2021. This set out the government’s intention to develop
sectoral, regional and site Just Transition Plans and an approach to just transition
planning more broadly. It sets out a framework to guide others in their own planning
for net zero. 
The framework sets out eight broad National Just Transition Outcomes. These have
been distilled into the following four areas reflecting the main goals for just transition
across all sectors: 
• Jobs, skills and economic opportunities – Scotland has a thriving net zero
economy, enabling businesses to set up and grow sustainably. People are
equipped with the skills and opportunities to access good, green jobs in a net
zero economy. This economy delivers a liveable world for people and planet,
ensuring a thriving, biodiverse environment and fair work and full lives for
people (National Just Transition Outcomes 2 and 4). 
• Communities and places should be accessible places for people to grow,
investing in their environment and economy. Communities should be
empowered to reach net zero in a way that meets their needs, and builds on
their unique local strengths, in an equitable fashion as part of a just transition
(National Just Transition Outcomes 1 and 7). 
• People and equity – People are able to enjoy basic rights, freedoms and
quality of life and have access to necessities such as heat, food, housing,
employment, childcare and wider wellbeing. They are healthier, happier and
treated with respect and have access to full, varied opportunities that add
value to their lives. Opportunities, wealth and power are spread more equally;
costs primarily fall to those who can bear them (National Just Transition
Outcomes 3 and 8). 
• Environment, biodiversity and adaptation - Our environment must meet
the needs of those living in and depending on it – this includes both our
natural and built environment. Our spaces must be resilient to the impacts of
climate change and restore our biodiversity. Spaces must provide those living
or dependent on them with everything they need to live full and healthy lives
as they support the transition (National Just Transition Outcomes 5 and 6). 
These outcomes reflect what Scottish Government has identified as the main areas
that just transition activity should cover, including effective reskilling and new
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economic opportunities, as well as engaging communities and reflecting fairness and
a person-centred approach in policy making. 
Sectoral Planning 
The draft Energy Strategy and Just Transition Plan was published in 2023 for public
consultation. A finalised version of the document is due to be published. The plan will
lay out a shared vision for Scotland’s energy system, and identify concrete steps to
manage the economic and social impacts of the transition fairly. 
Three further sectoral just transition plans are currently in development: 
• Aligning with the National Transport Strategy 2, the Transport Just
Transition Plan will set out a pathway towards reducing transport emissions
in a way that tackles existing inequalities and promotes a managed transition
to a future transport system, supporting behaviour change away from private
car use and identifying the workforce and skills changes needed in the
transport industry. 
• The Land Use and Agriculture Plan will take a wider lens on the livelihoods,
skills, health, and wellbeing of those who live in and rely on Scotland’s land as
well as on maintaining and supporting thriving rural and island communities. It
will look to introduce and promote a baseline approach and policy actions
whilst setting out the strategic direction of travel for future plans. 
• The development of a Built Environment and Construction Just Transition
Plan will follow the Transport and Land Use and Agriculture Just Transition
Plans. This will focus on providing a pathway for our built environment and
construction sectors to deliver net zero. 
To support the development of these sectoral plans, the Scottish Government
published three discussion papers in June 2023: these set out proposed JT
outcomes and priority policy areas for the transport, land use and agriculture, and
the built environment and construction sectors. 
Site Planning 
Site Plans will focus on areas in which significant industrial change is expected to
take place. On 7 November 2024 we published the draft version of a site-specific
Just Transition Plan for the Grangemouth Industrial Cluster. This Plan seeks to
understand the impacts of major structural changes at Grangemouth on a wide
range of actors, including industrial operators at the forefront of technological
change, their workforces who hold much of the skills and expertise to support this,
and crucially, the surrounding community which has an intrinsic link with the
industrial cluster. A co-designed vision for the future charting the actions that will be
required in order to make this transition as equitable as possible for those in
Grangemouth was also published alongside the draft Plan on 7 November. A
discussion paper on this Plan was published in September 2023. 
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The Scottish Government has committed to developing a Just Transition Plan for the
Mossmorran industrial complex. Work on this plan is scheduled to begin following
the publication of the final version of the Grangemouth Just Transition Plan. 
Regional Planning 
We are also committed to setting out an approach to support regional planning.  We
will be working with key partners, including COSLA, the Just Transition Commission
and existing regional partnerships to explore possible options.  The goal will be to
learn from areas (such as the North East, Glasgow and Edinburgh) where net zero
plans are already more developed and design an approach that can best coordinate
and enhance existing work.   
2.1.2.4 Public Engagement Strategy 
Under section 91 of the 2009 Act, Scottish Ministers are required to publish a public
engagement strategy setting out steps to inform people about climate change
targets, encourage them to contribute to achieving those targets and identify actions
which people in Scotland can take. The strategy must be reviewed every five years.
Where Ministers vary the strategy following review, the revised strategy must be
published as soon as reasonably practicable.
The latest strategy, Net Zero Nation: A Public Engagement Strategy for Climate
Change, was published in 2021 and is a framework for engaging the public and
communities on climate change. It takes a people-centred approach to climate
change policy; and underpins the role of public engagement in mitigating and
adapting to climate change, moving from encouraging incremental changes in
attitudes and behaviours, to supporting a society-wide transformation.
The Scottish Government is supporting the development of a network of regional
community climate action hubs, to provide a strategic regional approach to climate
change action. 
The government is not, should not and cannot be, the only body that engages
with the public on climate change issues. Public bodies should, in all cases,
engage with their staff and key stakeholders as they develop their own climate
change policies and plans. Additionally, the majority of public bodies are likely to
engage with other bodies, stakeholders and the public as they exercise their
functions. Through this engagement, public bodies can play a key role, as ‘trusted
messengers’, in broadening the conversation on climate, and in ensuring that the
interests of people and communities most affected by our transition to net zero are
understood, and acted upon. Public bodies and community climate action hubs
should work together to ensure full community engagement, as appropriate. 
The 2021 strategy is focused on three strategic objectives: Understand, Act and
Participate. It aims to ensure people are aware of the action that all of Scotland is
taking to tackle climate change and understand how it relates to their lives. It aims to
enable people to actively participate in shaping just, fair and inclusive policies that
promote mitigation of and adaptation to climate change. And it aims to encourage
households, communities and places across Scotland to take action on climate
change.
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Bodies should reference the strategy and consider their own stakeholder
engagement using the approaches outlined.
2.1.2.5 Mitigation – scope of the duties 
The first of the climate change duties is that, in exercising their functions, public
bodies must act in the way best calculated to contribute to delivery of the emission
reductions targets, described above. The targets include both the overarching target
of net zero by 2045, and the 5-yearly carbon budgets. While the targets are
economy-wide and do not constitute specific targets for the public sector, public
bodies should lead by example by setting ambitious targets for their own
emissions. In keeping with their leadership role, public bodies should consider
setting their own emission reduction targets and develop delivery plans to reach net
zero by 2045 or, wherever possible, ahead of this date.
Public bodies contribute direct GHG emissions, for example through the use of
natural gas to heat buildings and water, and the use of petrol and diesel in fleet
vehicles. They also contribute indirect emissions, for example: emissions associated
with mains electricity; emissions from the treatment of waste and waste water
generated by the organisation; and transport emissions associated with business
travel. Bodies may also play a key role in influencing GHG emissions in the wider
environment through the way they exercise their functions in relation to policy,
service delivery and procurement. Public bodies are advised to approach the
climate change duties broadly and include both direct and indirect emissions,
and give due consideration to those within their wider sphere of influence.
The climate change duties and the other actions that, as best practice, public bodies
should take are explored in more detail in chapter 5 Implementing the first duty:
reducing emissions, and chapter 8 Reporting. As equalities and climate change are
interlinked, bodies should also refer to chapter 3 Equalities. Section 2.2 provides
guidance on impact assessments.
2.1.2.6 Adaptation 
The framework for climate adaptation is set out in relevant sections of both UK and
Scottish legislation. Section 56 of the UK Climate Change Act 2008 requires the
Secretary of State to lay reports before Parliament assessing the risks for the UK of
the current and predicted impacts of climate change (‘the UK Climate Change Risk
Assessment’) every five years. The Climate Change Committee (CCC) has a duty to
provide advice on the preparation of each report.
Section 53 of the 2009 Act establishes the legislative framework to pursue the
Scottish Government's ambitions for climate adaptation. After each round of UK
Climate Change Risk Assessment, Scottish Ministers are required to prepare a
strategic programme for climate adaptation – now referred to as the Scottish
National Adaptation Plan (SNAP). This programme must set out the objectives in
relation to adaptation, the proposals and policies for meeting those objectives,
arrangements for involving stakeholders, mechanisms for ensuring public
engagement and the timescales within which the proposals and policies will be
introduced. The 2009 Act also requires annual reporting to the Scottish Parliament
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on progress towards delivering the programme, and two rounds of independent
assessment of progress within each five year cycle.  
2.1.2.7 Scottish National Adaptation Plan 2024-2029 (SNAP3) 
The third Scottish National Adaptation Plan (SNAP3) was published in September
2024. SNAP3 sets out five long term adaptation outcomes, a set of 23 shorter term
national adaptation objectives, and policies and proposals to respond over the period
2024 to 2029 to the risks for Scotland identified in the 2022 UK Climate Change Risk
Assessment (CCRA3).
SNAP3’s strategic aim to build Scotland’s resilience to climate change aligns with the
National Performance Framework, and its five long-term adaptation outcomes are:
• Nature connects across our land, settlements, coasts and seas
• Communities are creating climate-resilient, healthy and equitable places
• Public services are collaborating in effective and inclusive adaptation action
• Economies and industries are adapting and realising opportunities in our
Just Transition
• Scotland’s international role supports climate justice and enhanced global
action on climate adaptation.
2.1.2.8 Adaptation – scope of the duties 
The second element of the climate change duties requires public bodies, in
exercising their functions, to act in the way best calculated to help deliver the
Scottish National Adaptation Plan. 
All public bodies must identify the national adaptation objectives relevant to
their functions and act in a way that supports the delivery of these objectives.
Organisations will have varying degrees of influence in relation to adaptation in
Scotland depending on their particular role, functions and responsibilities, but all
public bodies need to be resilient to the future climate and to plan for business
continuity in relation to delivery of their functions and the services they deliver
to the wider community. 
Typically, the first step involved is to understand the likely impacts the changing
climate will have on the organisation and the risks that these pose. All bodies should
undertake climate risk assessments, put appropriate adaptation plans into place and
be in a position to track and report on delivery. Further details are provided in
chapter 6 Implementing the second duty: adaptation.
2.1.2.9 Acting sustainably – scope of the duties 
The third duty places a requirement on public bodies, in exercising their functions, to
act in the way they consider most sustainable. In reaching well informed
decisions, public bodies should ensure that the full range of social, economic and
environmental considerations are fully taken into account alongside the impact on
GHG emissions, and that these aspects are viewed over the short and long term. 
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Public bodies should integrate sustainability into their decision-making
processes, for example by assessing the sustainability of policy decisions and
strategies, budgets and capital projects; and by considering how these contribute to
the National Performance Framework outcomes. Impact assessments can be an
effective tool for integrating sustainability into decision making. 
Sustainable development and the actions public bodies are expected to take are
explored in more detail in chapter 7 Implementing the third duty: acting in the most
sustainable way. 
2.1.2.10 Reporting on compliance with the climate change duties 
As laid out in chapter 1, public bodies have climate change duties under section 44
of the 2009 Act. Scottish Ministers may require certain public bodies, by order under
section 46 of the 2009 Act, to report on their compliance with the climate change
duties. 
The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland)
Order 2015, as amended, sets out annual reporting requirements and the list of
major public bodies who must fulfil such requirements. Reporting, both statutory and
non-statutory, is covered in detail in chapter 8.
2.1.3 Wider context, legislative and regulatory framework 
Public bodies operate within a wider landscape of legislative, policy and regulatory
frameworks. Some key elements are detailed below. 
2.1.3.1 Scotland’s Environment Strategy
The Environment Strategy provides an overarching framework for Scotland’s
environment and climate policies, including the Climate Change Plan and Adaptation
Plan. It aims to bring strategies and plans together, and identify new strategic
priorities and opportunities to promote a whole-of-government approach supporting
Scotland’s role in tackling the climate and nature emergencies.
In guiding us as we protect and restore Scotland’s natural environment and strive to
live within our planet’s sustainable limits, the strategy recognises that this will require
transformative, systemic changes in Scotland’s economy and society. Therefore, it
aims to explore what these transformations will mean in practice in Scotland, and
how the Scottish Government can help to drive these, as part of its commitment to a
just transition, in ways that create wider benefits for people’s health and wellbeing,
for tackling inequalities and for supporting green jobs and businesses.
The Environment Strategy forms part of the Scottish Government’s strategic
approach to environmental policy and was placed on a statutory basis by the UK
Withdrawal from the European Union (Continuity) (Scotland) Act 2021 (‘the
Continuity Act’) which created new duties for Scottish Ministers to publish an
‘environmental policy strategy’ and to have due regard to it when developing policies.
While the full Strategy is being developed in phases, its vision and outcomes will
help to guide the future development and delivery of our environmental strategies
and plans by establishing our long-term direction and shared goals.
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Scotland's arrangements for environmental governance are defined by the
Environment Strategy, Environmental Standards Scotland and our Statutory
Guidance on the Guiding Principles on the environment.  
The guiding principles, which were also established by the Continuity Act, support
the objective to maintain and improve environmental standards, contributing to
Scotland's response to the twin climate and nature emergencies and keeping aligned
as far as possible with EU standards. The duties in the Continuity Act require
Scottish Ministers and Scottish public authorities to have due regard to the guiding
principles on the environment. The duty on Scottish Ministers to have due regard to
the guiding principles on the environment will extend to all policy development
(including proposals for legislation). The duty on other public authorities only applies
to projects which require an environmental assessment under the Environmental
Assessment (Scotland) Act 2005.
2.1.3.2 Biodiversity and the natural environment 
A consensus is building internationally around the urgent need to address the twin
crises of biodiversity and nature loss and climate change together. Similar to climate
change, the degradation of our natural environment and the loss of species poses an
existential threat to humanity. The Scottish Government is clear that this is an
emergency, and requires an emergency response. The Scottish Biodiversity Strategy
to 2045 sets out a clear vision in response to the challenge, to take urgent action at
scale across Scotland’s land and seas, in order to halt biodiversity loss by 2030 and
reverse that trend by 2045. Restoring and regenerating biodiversity will build climate
resilience, and Scotland’s communities and people are central to a nature positive
future. 
Collaboration is at the heart of the Strategy. No one can tackle the nature emergency
alone, and it will be vital that public bodies work together and with their many
stakeholders and communities, to deliver the changes that are needed over the
coming years. 
The strategic delivery framework for responding to the biodiversity crisis includes the
Strategy itself, the Natural Environment Bill, five-year Delivery Plans setting out
detailed actions to be taken, an Investment Plan and a monitoring and reporting
framework. Public bodies, in particular those with landholdings, should ensure that
their policies and actions are in line with the Strategy and other elements of the
strategic framework. 
The final strategy and the Strategic Biodiversity Delivery Plan 2024-2030 were
published on 27 November 2024, following public consultation in 2023.  Broad
frameworks and specific guidance relating to the implementation of Nature Networks,
protecting 30% of our land by 2030 (‘30 by 30’), and developing with nature through
the National Planning Framework (NPF4) are published by NatureScot.   
The Natural Environment Bill to be introduced in this Parliamentary session (2021-
2026) will set out a framework for statutory targets for nature recovery.  While the
detail is still being progressed, we expect to develop targets that will support delivery
of the priority themes and outcomes laid out in the Biodiversity Strategy. The Bill will
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also contain legislation that supports our National Parks, the management of wild
deer, and the ambitious ‘30 by 30’ commitment.      
Every public body, in exercising its functions, is under a duty to further the
conservation of biodiversity, so far as is consistent with the proper exercise of those
functions under the Nature Conservation (Scotland) Act 2004. Guidance in relation to
the biodiversity duty is published by NatureScot. Every effort should be made by
public bodies to enhance biodiversity and restore nature, and public bodies should
also maximise opportunities for enhancing biodiversity as an essential co-benefit of
taking climate action. For example, bodies with landholdings should maximise
opportunities to restore nature and further enhance biodiversity as part of wider land
based mitigation and adaptation projects. 
2.1.3.3 Wellbeing economy 
The National Strategy for Economic Transformation (NSET) has a vision of a
Wellbeing Economy, based on the principles of prosperity, equality, sustainability
and resilience. It involves taking a broader and more holistic view of what a
successful country, society and economy look like, putting people and planet at the
centre. It will improve economic resilience, reduce our vulnerability to future
economic and environmental shocks, and so improve wellbeing for current and
future generations. Boosting fair, green, economic growth helps achieve the Scottish
Government’s four priorities and promotes the wellbeing of all Scotland’s people. 
The NSET is aligned with the National Performance Framework, and with existing
plans targeted at specific aspects of our economy, and regional and sectoral
strategies, including the Climate Change Plan, Environment Strategy, Just Transition
Plans and Energy Strategy, the Green Industrial Strategy, the Biodiversity Strategy
and the Circular Economy Strategy. 
One practical way to support the achievement of a wellbeing economy is through the
Community Wealth Building (CWB) approach to economic development. CWB
encourages public bodies to consider their role as ‘anchor organisations’ through
using their economic levers, such as spend, employment, land and assets and
investment, in different ways to maximise the benefits for the economy, local
communities and the environment. The Scottish Government has committed to
introducing legislation on CWB within this Parliamentary session. 
2.1.3.4 Land Use 
Scotland's land is a valuable resource and fundamental to the economy, the
environment, biodiversity and the wellbeing of the nation. Public bodies, when
considering their land and land management, must think beyond how it is used to
who benefits from that use, and how land use can help achieve wider outcomes and
benefits, as laid out in the Land Use Strategy 2021-26 Land – getting the best from
our land. This sets out the Scottish Government’s long term vision for sustainable
land use in Scotland, a set of sustainable land use principles to guide decision
making, as well as key objectives and policies for delivery. 
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In line with the legal requirement that Scottish Ministers produce a Land Use
Strategy every five years, the process of developing a fourth strategy for publication
in 2026 is beginning. This will build on previous strategies while also reflecting recent
changes in the policy context in order to ensure that the strategy is aligned with
Scotland’s national outcomes, as set out in the NPF, and contributes to delivery of
the UN SDGs. 
The Land Rights and Responsibilities Statement and the Land Use Strategy’s
Principles for Sustainable Land Use should be at the centre of land use and land
management decision making. 
Management and use of public land for carbon such as increasing carbon removals
(e.g. woodland creation, hedgerows, seagrass) and reduction of emissions, such as
peatland restoration or improved soil management, should be undertaken in line with
the SG’s Natural Capital Markets Framework. This sets out how natural capital
projects, including those focussed on carbon goals, should support integrated land
management (delivery of wider co-benefits beyond carbon e.g. biodiversity
improvements, resilience of food supply and natural flood management) and
community benefits. Investment in natural capital for carbon management should be
both measurable and verifiable, such as through the government-backed Woodland
Carbon Code and the Peatland Code. 
2.1.3.5 Circular economy 
The Scottish Government recognises that sustainable consumption and production
are essential for Scotland’s transition to a low carbon and green economy, which will
meet Scotland’s obligations to tackle the twin climate and nature emergencies.
Material consumption and waste are primary drivers of nearly every environmental
problem Scotland currently faces, from water scarcity to habitat and species loss.
Estimates suggest around four fifths of Scotland’s carbon footprint comes from the
products and services we manufacture, use and throw away. A circular economy
gives us an alternative economic model that can benefit everyone within the limits of
our planet. 
Building a more circular economy requires all parts of Scottish society to play their
part. The Circular Economy (Scotland) Act 2024  contains provisions to underpin
Scotland’s transition to a circular economy and modernise Scotland’s waste and
recycling services.  Primarily, the Act delivers enabling powers that will set a
framework for taking action into the future. 
Some of the provisions included in the Act are: 
• Circular economy strategy: placing a duty on Scottish Ministers to publish
or refresh a circular economy strategy at least every 5 years in order to direct
national policy on the circular economy.
• Circular economy targets: developing statutory targets for the Scottish
Ministers to provide a focus for action. 
• Restrictions on the disposal of unsold consumer goods: providing
powers to limit the disposal or destruction of unsold goods in order to reduce
wasteful practice.  
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• Charges for single-use items: creating a power to set a minimum charge for
certain throwaway items in order to drive waste reduction and greater use of
reusable items (the intention is for this initially to be applied to single-use
disposable beverage cups).
• Local Authorities: development of a code of practice on household waste
recycling; development of recycling targets for local authorities; and
enforcement provisions relating to fly tipping and household waste. 
2.1.3.6 Equalities legislation 
The Equality Act (2010), section 149, introduced the Public Sector Equality Duty
(PSED) which requires public authorities, in exercising their functions, to have due
regard to what are known as the ‘three needs’, that is the need to: eliminate
discrimination, harassment, victimisation and any other conduct prohibited under the
2010 Act; advance equality of opportunity between those who share a relevant
protected characteristic and those who do not share it; and to foster good relations
between those who share a protected characteristic and those who do not share it. 
The Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 place further
duties onto listed Scottish public authorities, including to report progress on
mainstreaming the equality duty, and to assess the impact of applying new or
revised policies, plans or processes against the three needs of the PSED. This
assessment typically takes the form of an Equality Impact Assessment (EQIA).
Further details on EQIA are provided below in section 2.2. 
Under Part 1 of the Equality Act 2010, certain bodies are also subject to the public
sector duty regarding socio-economic inequality. In Scotland, this duty was
introduced in 2018 as the Fairer Scotland Duty (FSD). The duty places a legal
responsibility on named public bodies in Scotland to pay due regard to how they can
reduce inequalities of outcome caused by socio-economic disadvantage, when
making strategic decisions. 
Bodies should refer to chapter 3 for further guidance on equalities and climate
change. 
2.1.3.7 Health and wellbeing 
Planetary and human health are inextricably linked 1, 2. Climate change, and the
measures we take to achieve net zero and adapt to its impacts, present risks to, and
opportunities for, human health.   
Climate impacts will exacerbate, and be exacerbated by, the significant population
health challenges Scotland faces 3, 4.  Life expectancy and healthy life expectancy
are falling, and health inequalities are widening. Our population is aging, and the
burden of disease is projected to rise placing additional pressure on our health and
social care system. Concurrent system shocks including the COVID-19 pandemic
and the cost-of-living crisis have exposed, and deepened, existing inequalities
leaving our most vulnerable and marginalised people and communities behind: the
same people and communities that will be disproportionately affected by the impacts
of climate change.
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The impacts of climate change in Scotland and globally are, and will continue to,
impact directly and indirectly on the health and wellbeing of people and communities
5. Higher temperatures increase heat-related illness. Frequent flooding can increase
risk of exposure to pathogens and directly cause injury or death from drowning or
hypothermia. Wildfires can exacerbate respiratory illness and may directly cause
injury or death. Climate impacts also affect health indirectly. They undermine the
building blocks of health including a safe and secure home, access to transport,
health and social services, and affordable and healthy food (food security),
contributing to physical and mental health problems. They also influence changes in
disease and disease vectors, global security and migration patterns. 
For example, flooding can have a wide range of social and economic impacts, which
in turn affect health. The immediate losses – being displaced from homes, ongoing
disruption to work and education, restricted access to essential services, and
disrupted utilities – can have long term and severe impacts on mental and physical
health. Research suggests that the biggest burden of ill-health from major flood
events will be on mental health 6. 
The action we take to achieve a net zero, nature-positive, climate-resilient future are
an opportunity to deliver wider benefits for climate, health and equity – sometimes
referred to as ‘triple wins’ 7.  Investment in areas such as transport, housing, clean
energy, sustainable livelihoods and the natural environment will bring a wide range
of health and social benefits for individuals and communities.   
Integrating health and equity at the heart of tackling the interconnected climate and
nature emergencies can contribute to achieving a just transition to net zero and
climate-resilient, healthy, equitable communities. Working nationally and locally and
adopting a ‘Health in All Policies’ approach, public bodies can deliver near-term co-
benefits for population health, wellbeing and equity from cross sectoral climate
action8 . 
2.1.3.8 Human Rights 
Public bodies have a legal obligation to embed human rights considerations
throughout the policy-making process. This ensures that new policies and legislation
comply with legal requirements and uphold human rights principles. Human rights
should be considered in all impact assessments, as they encompass a broad range
of policy areas. 
The National Performance Framework includes the outcome 'We respect, protect
and fulfil human rights and live free from discrimination', which aligns with the UN
SDGs. By taking a human rights-based approach to policy development, public
bodies can empower individuals to understand and claim their rights, while improving
accountability for those responsible for respecting, protecting, and fulfilling these
rights. This approach is crucial for leading by example in human rights, including
economic, social, cultural, and environmental rights. 
2.1.3.8.1 Children’s Rights 
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Our vision is of a Scotland where children’s human rights are embedded in all
aspects of society. We are taking steps to ensure that children enjoy their rights, as
set out in the United Nations Convention on the Rights of the Child (Incorporation)
(Scotland) Act 2024 (the ‘UNCRC Act’). These include: 
• Section 6 of the UNCRC Act, makes it unlawful for public authorities, including
Scottish Government, to act incompatibly with the UNCRC requirements when
delivering relevant functions under powers conferred by or under an Act of the
Scottish Parliament or common law. Some private and third sector
organisations may be caught by the duty if they carry out certain functions of a
public nature. 
• Section 17, legally requires Scottish Ministers to prepare and publish a Child
Rights and Wellbeing Impact Assessment (CRWIA) in respect of all new Bills,
most Scottish Statutory Instruments, and all decisions of a strategic nature
that relate to the rights and wellbeing of children (refer to section 2.2 of this
document) 
• Section 1 of the Children and Young People (Scotland) Act 2014 (the “2014
Act”) placed a duty on the Scottish Ministers to keep under consideration
whether there are any steps which they could take which would or might
secure better or further effect in Scotland of the UNCRC requirements, and, if
they consider it appropriate to do so, take any of the steps identified by that
consideration. Section 22 of the UNCRC Act, repeals Part 1 (including section
1) of the 2014 Act and this duty is now replaced with new, stronger, duties in
the UNCRC Act. 
• Further to this, section 23 obliges the Scottish Ministers when bringing forward
any new legislation (save for certain SSIs) to make a statement about its
compatibility with the UNCRC requirements.
The UNCRC is the base standard for children’s rights, and is the most widely ratified
human rights treaty in the world. It sets out the specific rights that all children have.
Article 24 (right to health) emphasises the importance of clean drinking water, taking
into consideration the dangers and risks of environmental pollution .   
The UN Committee on the Rights of the Child has published General Comment No.
26, which focuses on the environment and climate change. General Comments are
intended to assist States Parties in their implementation of the UNCRC, but are not
legally binding documents in themselves. General Comment No. 26 explains how
certain rights, such as the right to non-discrimination, the right to life and the right to
health are being particularly threatened by climate change. The general comment
emphasises the need for urgent action, clarifies obligations of States, and provides
guidance on appropriate measures to address environmental harms, with a focus on
climate change. As the youngest members of society children have not contributed
to the changing climate but are those most likely, over the coming decades and the
course of their lifetimes, to feel its impacts. Currently children’s rights are, globally,
being threatened by climate change and other environmental harms. 
2.1.3.9 UK Emissions Trading Scheme
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The UK Emissions Trading Scheme (ETS) was implemented across the UK following
the UK’s exit from the EU. The UK ETS is administered by the ETS Authority, which
is comprised of the UK, Welsh, and Scottish governments, as well as the
Department of Agriculture, Environment and Rural Affairs in Northern Ireland. The
ETS is used as a mechanism to incentivise cost-effective decarbonisation and
continues from the EU ETS in the provision of a cap-and-trade system with a market-
determined price on carbon emissions. 
The UK ETS applies to energy intensive industries, the non-renewable power
generation sector, and some aviation emissions. In future it will also apply to
maritime emissions and energy from waste and waste incineration - this may be of
particular interest to local authorities and other public bodies. More information can
be found at the links below. In addition, there is a scheme for hospitals and small
emitters which is applied to emitters with emissions lower than 25,000t CO2e per
annum. Operators of sites covered by the UK ETS should be aware of their
inclusion. 
Guidance on how to participate in the scheme is published on the UK Government
website, and is also available from the Scottish scheme regulator, SEPA (UK
Emissions Trading Scheme | Scottish Environment Protection Agency (SEPA). 
2.1.3.10 Best Value 
Since 2002, a number of public bodies now covered by the climate change duties
including NDPBs, Executive Agencies and NHS bodies, have also been subject to
the Best Value in Public Services duty. This duty requires relevant bodies to ensure
continuous performance improvement in delivering services, maintaining an
appropriate balance between cost and quality, and in making those arrangements to
contribute to the achievement of sustainable development. Guidance on the
Best Value duty is provided in the Scottish Public Finance Manual and in guidance
for Accountable Officers.
Local authorities are not subject to the duty of Best Value in Public Services. They
are however subject to a similar duty under Part 1 of the Local Government in
Scotland Act 2003. This places a duty on local authorities to make arrangements
which secure best value – best value being defined as continuous improvement in
the performance of the authority’s functions. This duty must be discharged in a way
which contributes to the achievement of sustainable development. Statutory
guidance on this duty has been published by Scottish Ministers. 
Public bodies and local government should build a shared understanding of Best
Value, especially given the need for collaboration and partnership working.
2.1.3.11 Health and Safety legislation 
The Health and Safety at Work etc. Act 1974 places a duty on employers to ensure,
so far as is reasonably practicable, the health, safety and welfare of all of their
employees. The duty applies to those working in offices or on sites owned by the
employer, to agile and remote workers, and to those working from home. 
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Public bodies should be aware of the potential interlinkages between the impacts of
climate change and their legal responsibilities in relation to health and safety. For
example, the impacts of the changing climate such as increased heavy rainfall
events causing a site to flood, or flood more severely or more frequently, should be
assessed though a climate risk assessment (refer to chapter 6), but are likely to also
pose a health and safety risk. Other examples might include the risks posed to
outdoor workers during heatwaves and the risks posed to those who travel for work
by extreme weather events. All employees are likely to become increasingly
vulnerable to potential injury, delays, disruption and damage as the climate changes. 
Bodies will be aware of the responsibilities named individuals within their
organisation hold in relation to health and safety. They should ensure that all such
individuals are suitably trained in relation to climate impacts and climate risks, so
these can be taken fully into account as bodies discharge their responsibilities in
relation to health and safety. 
2.1.3.12 Sectoral and wider policy areas 
Climate change action is embedded across many policy areas including energy, heat
in buildings, transport, waste and the circular economy, business and industry,
procurement, planning, community planning, agriculture, forestry, marine and land
use. The supplements accompanying this guidance will provide subject-specific
guidance on themes that include many of the areas listed. The policies, legislation
and regulations relevant to each theme will be set out in these supplements.
2.2 Impact assessments 
As public bodies develop, update and implement climate change policies, strategies
and plans, it is likely most will be required to undertake one or more impact
assessments. Impact assessments are designed to test policies, plans and projects
against certain criteria, to gain a deeper understanding of likely impacts, allow
negative impacts to be mitigated against, minimised or removed, maximise
opportunities for positive outcomes and, critically, to feed into the development of the
policy or plan. 
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The requirement to carry out any particular assessment will vary depending on the
body and the nature of the proposed policy or plan. It is the responsibility of the
public bodies themselves to ensure they are aware of their statutory obligations in
relation to impact assessment. Bodies not required to undertake specific
assessments on a mandatory basis may still find them a valuable exercise to carry
out as best practice. 
Guidance has been developed for each assessment outlined below. In some cases,
toolkits and templates are also available. Bodies are, however, free to take their own
approach, and could consider an integrated impact assessment process. Integrated
impact assessment aims to take an holistic view, and assess various criteria or
factors as part of a single exercise. There are almost always interdependencies, for
example between socio-economic disadvantage, equalities, health, the impacts of
climate change, the ability to adapt effectively to a changing climate, etc., and this
more holistic approach highlights these, helping to avoid unwanted impacts in other
domains. Where an integrated approach is taken, bodies must ensure that any
specific legal duties related to the requirement for the individual assessments are
fulfilled, and that any associated statutory guidance is given due regard. 
The most commonly required assessments are outlined below. 
Strategic Environmental Assessment (SEA) 
• Legislation: Environmental Assessment (Scotland) Act 2005. 
• Description: SEA is a broad, integrated assessment process that aims to
establish the likely environmental effects of implementing a Plan, Programme
or Strategy. The findings of the assessment are detailed within an
Environmental Report and a public consultation has to be carried out on both
the plan and the report, early in the preparation process and prior to the
adoption of the plan. 
In all cases, it is important that public bodies: 
• approach the assessment with an open mind and with the aim of gaining a
deeper understanding of the issues
• start the assessment process early, so that the results can feed into the
development of the policy or plan and influence decisions
• gather relevant qualitative and quantitative evidence, and engage with
appropriate individuals, groups, communities and organisations as part of
the consultation process and to gather additional evidence of likely impact
where required
• ensure that the results of the assessment feed into the proposal and help
bring about demonstrable change
• make a plan to monitor the success of any mitigating or enhancing actions
set out in the assessment
• take an approach proportionate to the size of body and the size or scope
of the proposal. 
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The environmental report must consider likely significant effects on the
environment across the short, medium and long-term, on aspects including
biodiversity, human health, water, air and climatic factors. SEA is therefore a
key tool in ensuring positive climate change actions are integrated at both a
local and national level.   
SEA aims to ensure that significant adverse effects, where possible, are either 
avoided or mitigated and where feasible significant positive environmental
effects enhanced. 
SEA can help those developing plans consider how they could be delivered
differently, to achieve better environmental outcomes, while still resulting in
the planned outcomes. 
• Qualifying criteria: The Act requires responsible authorities to undertake
SEA for qualifying plans that have the potential to generate significant
environmental effects. Qualifying plans may include, for example, Local
Development Plans, Transport Strategies, Corporate Plans and Flood Risk
Strategies. Section 2.4 of the SEA guidance provides further information on
which plans are likely to require a SEA, and which may be exempt. 
It should be noted that most plans of a public character will require screening
or pre-screening if they do not fall into a full SEA. During the screening
process, the requirement for a SEA should be confirmed with assistance from
the consultation authorities. Only plans that are set out in section 4(3) or
section 6 of the Act are fully exempt. 
Responsible authorities are defined in section 2 of the Act and include the
majority of public bodies to whom climate change duties apply. 
• Guidance and tools:  Scottish Government have published non-statutory
guidance on SEA. Further guidance is provided by NatureScot, Historic
Environment Scotland and SEPA, including guidance on the consideration of
climatic factors within SEA. Enquiries can also be directed to the SEA
Gateway mailbox. 
Guiding Environmental Principles 
• Legislation: UK Withdrawal from the European Union (Continuity) (Scotland)
Act 2021. 
• Description: The Environmental Principles are not a form of impact
assessment. However, the principles should be considered alongside any
other impact assessments that are required. 
The principles are:
o protecting the environment should be integrated into the making of
policies
o the precautionary principle as it relates to the environment
o preventative action should be taken to avert environmental damage
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o environmental damage should as a priority be rectified at source
o the polluter should pay. 
Ministers and public authorities should give due regard to the guiding
principles through the established SEA processes, including during the
completion of SEA pre-screening, screening and environmental report. 
• Qualifying criteria: Under section 14, in making policy (including proposals
for legislation), Scottish Ministers are required to give the guiding principles
due regard. Under section 15, other responsible authorities are required to
have due regard to the principles when undertaking anything to which the duty
under section 1 of the Environmental Assessment (Scotland) Act 2005
applies. 
• Guidance and tools: Statutory guidance published by Scottish Government
provides information on how officials across government should apply the
environmental principles when developing policy: Scotland's guiding principles
on the environment: statutory guidance. 
Environmental Impact Assessment (EIA) 
• Legislation: The Town and Country Planning (Environmental Impact
Assessment) (Scotland) Regulations 2017. Related sector-specific regulations
covering electricity works; transport and works; roads; marine works;
agriculture, land drainage and irrigation projects; and forestry. 
• Description: EIA forms part of the Planning process, and is a means of
drawing together, in a systematic way, an assessment of the likely significant
environmental effects arising from a proposed development. The EIA must
identify, describe and assess the likely significant effects of the proposed
development on environmental factors including population and human
health; biodiversity; land, soil, water, air and climate; and material assets,
cultural heritage and the landscape. 
• Qualifying criteria: Developments falling within a description in Schedule 1
automatically require an EIA. Those described within Schedule 2 of the 2017
EIA Regulations and that meet the threshold in Column 2 or are within a
‘sensitive area’ need to undertake screening to determine whether an EIA is
required. 
• Guidance and tools: Planning Advice Note 1/2013: Environmental Impact
Assessment and Planning Circular 1/2017: Environmental Impact Assessment
regulations. 
Equality Impact Assessment (EQIA) 
• Legislation: Equality Act 2010. Equality Act 2010 (Specific Duties) (Scotland)
Regulations 2012, as amended. 
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• Description: EQIA are intended to ensure that new or revised policies and
plans consider their impact on each protected characteristic as defined by the
Equality Act, in respect of the three needs of the Public Sector Equality Duty
(PSED). 
The PSED was placed on public authorities by the Equality Act 2010 and
requires them, in the exercise of their functions, to have due regard to the
need to eliminate discrimination, harassment and victimisation, to advance
equality of opportunity and foster good relations between persons who share
a protected characteristic and those who do not. 
Additional specific duties for listed Scottish public authorities were introduced
by the 2012 Regulations as amended. Under these regulations, listed
authorities are required to assess the impact of implementing a proposed new
or revised policy or practice against the three needs of the PSED, i.e. to carry
out an EQIA and publish the results. 
There are multiple dependencies between climate change and equalities,
particularly when the consideration of different socio-economic groups, rural
and island communities are included. 
• Qualifying criteria: Public authorities are listed in Schedule 19 of the Equality
Act 2010. Scottish bodies subject to the 2012 regulations are listed in the
Schedule and include many of the bodies also subject to the climate change
duties. 
• Guidance and tools: The Equality and Human Rights Commission publishes
guidance on meeting the PSED and the specific duties for Scottish public
authorities. This includes dedicated guidance on how to undertake equality
impact assessments. 
The following chapter of this guidance, Equalities, provides further detail on
the potential dependencies between equalities and climate change, given
their possible significance. 
The chapter aims to provide bodies with guidance and examples of how to
effectively consider and embed equalities into climate change plans and
actions. Taking an integrated approach to the consideration of climate action
and the furthering of the PSED can harness these interdependencies and
create multiple positive outcomes. 
Fairer Scotland Duty assessment (FSDA) 
• Legislation: Part 1 of the Equality Act 2010. 
• Description: The Fairer Scotland Duty requires named public bodies, to
actively consider (‘pay due regard to’) how they can reduce inequalities of
outcome caused by socio-economic disadvantage, when making strategic
decisions. It is recommended that listed authorities publish a written
assessment demonstrating their consideration of the duty. 
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The duty seeks to reduce the inequalities associated with being socio-
economically disadvantaged. Examples of these inequalities are worse health
outcomes and lower life expectancy, poorer educational outcomes, fewer
opportunities to work, train or enter quality and fair work, and difficulty
accessing quality housing. As with equalities, there are multiple dependencies
between socio-economic disadvantage, the impacts of climate change and
the ability to respond effectively to a changing climate 
• Qualifying criteria: Named bodies subject to the Fairer Scotland Duty
include local authorities, health boards, integration joint boards and a small
number of other bodies. 
• Guidance and tools: Statutory FSD guidance for public bodies is published
by the Scottish Government. The following chapter of this guidance, section
3.4, provides further information and an illustrative example. 
Island Communities Impact Assessment (ICIA) 
• Legislation: The Islands (Scotland) Act 2018. Section 8 of the Islands Act
requires relevant authorities to carry out an Island Community Impact
Assessment (ICIA) for any new policy, strategy or service, when the impact on
island communities is likely to be significantly different from its effect on other
communities. 
• Description: The Islands Act contains measures designed to improve
outcomes for island communities. Communities living on Scotland’s islands
can have different needs and vulnerabilities to mainland communities. Islands
are often reliant on life-line ferry services, and can face higher costs, limited
services and other challenges associated with a more remote location. 
Islands also face the direct impacts of climate change, such as increased
storms disrupting ferry services, and rising sea levels predicted to inundate
low-lying areas. Adaptation to the changing climate is therefore of particular
importance to such island communities. 
• Qualifying criteria: Relevant authorities as defined in section 7(2) of the
Islands Act must have regard to island communities in carrying out their
functions. 
The relevant authorities are listed out in the Schedule and include many
public bodies to whom climate change duties also apply (relevant local
authorities, NHS health boards, integration joint boards, Transport
Partnerships and others).   
• Guidance and tools: Statutory guidance on carrying out an ICIA, and a
toolkit, have been published by Scottish Government. 
Business and Regulatory Impact Assessment (BRIA) 
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• Legislation: BRIA are encouraged as best practice. They are not a statutory
impact assessment. 
• Description: BRIA helps assess the likely costs, benefits and risks of any
proposed legislation, policy changes or guidance that may have an impact on
the public, private or third sector. The BRIA can help identify and address
unintended impacts on businesses and on competitiveness. 
• Qualifying criteria: BRIA are likely to be of most relevance to local
authorities and other large bodies, working at a regional level and developing
policy. 
• Guidance and tools: a toolkit providing guidance and information on how to
complete a BRIA is available on the Scottish Government website. The
intended audience for this guidance is government officials; while it may be
used by other bodies, they should first consider whether it suits their
purposes. 
Human Rights impact assessment 
• Legislation: Human Rights Act 1998. This Act incorporates much of the
European Convention on Human Rights (ECHR) into UK law. The ECHR is an
international agreement which sets out basic human rights. The Scotland Act
1998 ensures that the Scottish Parliament can only pass laws that are
compatible with the Convention rights. 
• Description: Public authorities have a legal obligation to ensure that all new
policies and legislation comply with existing laws and uphold human rights.
Taking a human rights based approach to policy development is important.
There are some underlying principles which are important in applying a
human rights based approach in practice. These are known as the PANEL
Principles. This approach supports understanding and analysis of the impact
of our policy on the human rights of those who will be mostly affected.
Convention rights should be considered whenever undertaking any form of
impact assessment (but are not a form of assessment in themselves). 
• Qualifying criteria: Convention rights must be respected and realised at all
levels of governance in Scotland. Scottish Government Ministers have ‘no
power to act’ in a way that breaches these ECHR rights. All decisions and law
we make must be compatible with the rights set out in ECHR. 
• Guidance and tools: Information on taking a human rights based approach is
available on the Scottish Human Rights Commission website. 
Child Rights and Wellbeing Impact Assessment (CRWIA) 
• Legislation: United Nations Convention on the Rights of the Child
(Incorporation) (Scotland) Act 2024. CRWIA are not a statutory impact
assessment for Public Authorities but are for Scottish Government and
Executive Agencies. 
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They are recommended by UNICEF, and are recognised as one of the
general measures of implementation under the UN Convention on the Rights
of the Child (the UNCRC). The UN Committee on the Rights of the Child also
recommends all levels of government - national, regional and local – complete
a CRWIA as part of their policy development. 
• Description: Part 3, section 17 of the UNCRC Act, legally requires Scottish
Ministers to prepare and publish a CRWIA in respect to all new Bills, most
Scottish Statutory Instruments and all decisions of a strategic nature that
relate to the rights and wellbeing of children. 
• Qualifying criteria: Scottish Government and Executive Agencies are
included in Part 3 section 17 of the UNCRC (Incorporation) (Scotland) Act
2024. 
• Guidance and tools: Guidance and example templates for external
stakeholders are available on the Scottish Government website, along with
non-statutory  guidance on Taking a children's human rights approach.
Statutory guidance for public authorities will be published in the coming
months. 
Habitats Regulations Appraisal (HRA) 
• Legislation: The Conservation (Natural Habitats, &c.) Regulations 1994. A
Habitats Regulations Appraisal (HRA) is required for any plan or project that
could affect a European site – no matter how far away it is. 
• Description: The term ‘European site’ is used to refer to what were
previously known as ‘Natura’ sites: Special Protection Areas (SPAs) and
Special Areas of Conservation (SACs). These were originally designated
under European legislation and protect species and habitats shared across
Europe. 
Under the Habitats Regulations, all ‘competent authorities’ must consider
whether a project or plan could have a significant effect on a European site
before it can be authorised to be carried out. If the action is considered likely
to have a significant effect, they must carry out an ‘appropriate assessment’
(AA). 
HRA comprises both the process for determining whether an AA of the
environmental risk is required, and the AA itself. Where an AA is required, the
competent authority must consult NatureScot. 
• Qualifying criteria: Bodies should be aware if any of their land is a
designated SPA or SAC site. A ‘competent authority’ is the body with the
power or duty to determine whether or not a proposal can proceed. They
include Scottish Ministers, government departments, local authorities, SEPA
and Scottish Forestry, among others. 
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• Guidance and tools: Guidance is published on the NatureScot website. 
Health Impact Assessment (HIA) 
• Legislation: HIA is not currently a statutory requirement but are encouraged
as good practice. EIA and SEA should include impacts on human health but
do not consider all relevant impacts. Poor health outcomes resulting from
socio-economic inequality can be considered as a relevant category when
undertaking a Fairer Scotland Duty Assessment. Completing an HIA may
meet the requirements for some other impact assessments and so form a
useful integrated assessment.   
• Description: Health Impact Assessment is a combination of procedures,
methods and tools that systematically judges the potential, and sometimes
unintended, effects of a policy, program or project on the health of a
population, and the distribution of those effects within the population – i.e.
health inequalities. HIA identifies appropriate actions to manage those effects. 
• Qualifying criteria: May be relevant to any plan, policy or strategy that
affects people and can be proportionate to the nature, scale and scope of the
proposal and kinds of impacts being assessed. 
• Guidance and tools: Public Health Scotland provides guidance on HIA on
their website. 
Consumer Duty impact assessment 
• Legislation: The Consumer Duty is a statutory duty introduced by the
Consumer Scotland Act 2020 that places an obligation on relevant public
authorities in Scotland to improve the extent to which consumers are
considered in strategic policy and decision making. 
Consumer Scotland, the statutory and independent body for consumers in
Scotland, has the legislative responsibility for developing the guidance to
support the Duty. 
• Description: the Consumer Duty aims to put consumer interests at the
centre of strategic decision making across the public sector to deliver better
policy outcomes. An impact assessment approach has been developed to
assist public authorities to meet the Consumer Duty requirements. 
• Qualifying criteria: relevant public authorities subject to the Duty are listed
in the Schedule of The Consumer Scotland Act 2020 (Relevant Authorities)
Regulations 2024. They include local authorities, executive agencies,
executive NDPBs, IJBs and NHS Health Boards. 
All relevant public authorities must have regard to the impact of strategic
decisions on consumers in Scotland and the desirability of reducing harm to
them. This should be applied in a proportionate manner aligned to the impact
that the decision has upon consumers.
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As laid out in section 1.11 of the draft guidance for public authorities, it will be
for each individual Scottish public authority to determine if a decision is of a
strategic nature. However, it is expected that this type of decision will be
made at an executive or board level rather than operational day-to-day
decision making. 
• Guidance and tools: Draft guidance has been issued by Consumer
Scotland: this includes advice on how to meet the Consumer Duty for public
authorities and senior decision makers and includes a draft impact
assessment template. A final version of the guidance will be issued by April
2025, following the 2024-25 implementation year. 
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3. Equalities 
3.1 Introduction 
Climate change and inequalities are inextricably linked. Globally, those least likely to
have contributed to emissions are often those to feel the first, and most severe,
impacts of the changing climate 9. Within Scotland too, the impacts of the changing
climate will be felt in unequal ways, with some areas more likely to be subject to
drought, some at high risk of extreme flooding, and others at risk of coastal erosion.
The impacts of the changing climate will be felt in unequal ways, with the worst
impacts likely to fall on the most vulnerable in society, and those least able to take
individual action to protect themselves. 
It is likely that the changing climate will deepen existing inequalities within our
society unless action is taken, be those related to health, environment, housing,
education, employment opportunities or income. Social inequalities including
housing, education and employment often contribute to and exacerbate health
inequalities 10, 11. 
Intersectionality – multiple and compounding inequalities – is highly relevant to
vulnerability to climate change. Climate change and social, economic and personal
factors (such as gender, race, income, age, religion and health status) can act
together as risk multipliers, contributing to the negative impacts climate change has
on health and other inequalities. For example, non-Christian religious minorities are
less likely to be employed than those with no religion, with the employment gap
particularly acute for Muslims. Despite overall exclusion rates declining across
Scotland, having additional support needs (ASN), or being assessed or declared as
having a disability continues to be associated with an increased likelihood of
exclusion. Households headed by single women with dependent children, and single
men without dependent children are most likely to experience poverty 12. 
Public sector bodies must take a leadership role in mitigating the negative impacts of
climate change on the environment and any related impact on inequalities. They
must work to actively improve outcomes and wellbeing for all in their work to mitigate
and adapt to climate change, by maximising on the opportunities available to them
as anchor organisations to consider equalities as part of this work. Climate action
and sustainability should be embedded throughout their governance, how they direct
resources and develop their organisational capabilities, and how they collaborate
with partners and communities. 
Bodies should be aware that the impacts of the decisions they make in relation to
climate change and sustainability could potentially affect everyone in Scotland,
directly or indirectly. Where policies and plans may have potential equality
impacts, it is a legal requirement that appropriate assessments are undertaken. It
is therefore important that bodies integrate equality considerations and
mainstreaming into their climate action, and approach equality impact
assessment and Fairer Scotland Duty assessment as an integral part of climate
policy and project development. 
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How public bodies choose to implement this guidance as a whole will determine the
impacts on service users, staff, customers, stakeholders, local communities and
wider society. Equality impact assessment and Fairer Scotland Duty assessment
should be fully integrated into climate policy and project development. 
As mentioned in section 2.2 above, bodies could, where appropriate, use integrated
impact assessment approaches that consider impacts holistically on protected
characteristics, socio-economic status, health and sustainability, with the proviso that
any integrated approach must meet the legal requirements for each individual
assessment. 
The duties and illustrative examples of fairness, equality, procedural justice and
health in this chapter illustrate why Scottish Government has embedded just
transition principles in climate legislation and emphasised the importance of planning
for a fair transition.   
3.2 Climate, health and equalities 
3.2.1 How climate impacts affect health 
Local and international climate impacts, such as increased temperatures, extreme
weather events and reduced food production will affect the health and wellbeing of
people in Scotland. Most will contribute to poorer health and risk worsening health
inequalities, though some opportunities have been identified 13, 14 .    
The risks to health include direct effects. For example, higher temperatures increase
the risk of heat-related mortality and respiratory and cardio-vascular problems;
extreme flood events can cause death, injury or health issues due to biological and
chemical contamination and changing vector distributions can lead to different
patterns of vector borne diseases 15 . 
Climate impacts also affect health and wellbeing indirectly through the social,
economic, and physical environment we live in. Known as the building blocks of
good health, these include warm, dry, affordable housing, accessible and good
quality transport systems and natural environments, strong social networks,
affordable nutritious food, and secure, high quality employment. 
Damage to homes and critical infrastructure from flooding, for example, may cause
displacement, financial difficulties and limit access to education, work and services.
This in turn can result in mental health problems, which research suggests is the
biggest burden of ill-health from major flood events in the UK. Similarly, extreme
weather events are likely to affect international food production and markets. This
may influence food purchasing decisions and consumption of healthy diets. 
3.2.2 Unequal distribution of health and social risks 
The impacts of climate on human health are not evenly distributed. In addition to
geographical variation, individuals and communities living in climate impact-prone
areas vary in the extent they are affected 16, 17 . This depends on their: 
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• level of exposure to climate impacts: housing conditions and the physical and
natural environment people live in can accentuate or offset the severity of a
climate impacts. 
• level of adaptive capacity: income, knowledge, insurance, community
networks and mobility can influence how well people and communities can
prepare for, respond to and recover from climate impacts. 
• sensitivity to climate impacts: age and current health status can increase the
likelihood of an adverse effect on health and wellbeing. 
People experiencing social and economic disadvantage are one, but not the only,
group likely to be disproportionately affected by climate impacts.  They are more
likely to live in poor quality housing and environments, for example with a higher
proportion of vacant and derelict land and less green space. This can increase their
exposure to high temperatures and flooding. They often have fewer financial
resources to make adaptations, obtain insurance or move. Private tenants, for
example, have fewer rights to adapt their home and may be on a lower income.
Social isolation, lack of information and poor English language skills can also limit
capacity to respond and recover from extreme weather events. People living in areas
of deprivation are also more likely to be in poor health and therefore more sensitive
to climate impacts. 
Climate impacts and these social, economic and personal factors act together as risk
multipliers to increase the risk of poor health and health inequalities. 
Illustrative example
A housing development starts to flood more regularly and more severely. The
rental and sale values of the properties drop, and the more affluent residents
move away. The development becomes home to those on low incomes with less
choice in where they can afford to live, including elderly residents and those
reliant on welfare payments. These residents are less likely to be able to afford
the high home insurance premiums demanded due to the high flood risk, and as
a result most are uninsured. The homes may also now be owned by landlords
less inclined or less able to spend money on adapting the properties against
flooding. 
When the homes do flood again, causing damage to the properties and loss of
personal belongings, residents are unable to afford to make good or replace
personal items. This leaves them more vulnerable and likely to require additional
support from local government, charities and the social security system.
However, they may also lack the resources or social networks to support them in
finding temporary accommodation or in accessing support. In addition, the
flooding causes anxiety and emotional upset, impacting on mental health and
wellbeing. For those of working age, this may have a negative impact on their
ability to work, or to work full time. They may have the kind of employment that is
difficult to sustain under such circumstances. 
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3.2.3 Policy response and widening inequalities 
Policies or actions to address climate impacts and reduce GHG emissions may not
equally benefit everyone 18. For example, recent work in Scotland suggests that
suspending travel services during severe weather is important from an overall risk-
reduction perspective but disproportionately impacts those on the lowest incomes,
particularly those employed on zero-hour contracts or who are less able to work from
home 19 . 
Policies and plans can also have unintended negative health and social impacts. For
example, costs associated with improving homes to make them more climate
resilient or more energy efficient can be passed on to tenants through rent increases. 
Considering the differential impacts and potential unintended negative
consequences of policies and plans is important. It allows mitigation measures to be
considered and implemented or trade-offs to be made. 
3.2.4 Procedural justice 
People experiencing social and economic disadvantage often have less power and
influence to inform decisions about their lives and their communities. This is due to
lack of resources such as knowledge, prestige and beneficial connections.
Inequalities in power, influence and decision making are underlying drivers of both
health inequalities and the unjust distribution of climate impacts. 
Empowering communities to exercise control over decisions which support their
ability to adapt, such as local development and coastal management plans and
housing rights, is important in achieving a just transition to a climate resilient and net
zero Scotland. 
3.3 Public Sector Equality Duty 
As outlined in section 2.1.3.6., section 149(1) of the Equality Act 2010 (‘the 2010
Act’) places a Public Sector Equality Duty (PSED) on public authorities, requiring
them, in the exercise of their functions, to have due regard to the need to –
(a) eliminate discrimination, harassment, victimisation and any other conduct
that it prohibited by or under the 2010 Act
(b) advance equality of opportunity between persons who share a relevant
protected characteristic and persons who do not share it
(c) foster good relations between persons who share a relevant protected
characteristic and persons who do not share it. 
These are known as the three needs of the PSED. 
Section 5 of the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012
places a duty on listed authorities to undertake an assessment of applying a
proposed new or revised policy or practice against the three needs. This assessment
– an equality impact assessment (EQIA) – must be made for all protected
characteristics, bearing in mind that it is the degree of impact, rather than the
number of people affected that is relevant. When approaching climate change and
equalities, public bodies are strongly advised to take an intersectional approach and
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look beyond the protected characteristics to include wider socio-economic
considerations such as those living in low income areas, in island communities and
in remote rural areas. However, if a public body identifies these types of impacts,
they cannot satisfy their legal obligations by only including a section in the EQIA.
They must also fully complete the relevant impact assessments, namely the Fairer
Scotland Duty assessment and or Island Communities Impact Assessment. 
As bodies develop or revise policies, strategies, plans, programmes and projects that
support implementation of the climate change duties, it is important that these are
assessed for equality impacts for two primary reasons: 
• bodies must not assume that decisions or changes that are advantageous in
terms of the climate change duties will be so in terms of the PSED – it will be
important to assess whether the proposals have the potential to negatively
impact on particular groups of people or equalities communities
• where the needs of the PSED and impacts on protected characteristics and
other equality groups are taken into consideration as part of developing
proposals associated with the climate change duties, decisions are likely to be
more robust. Importantly, they are also likely to be more sustainable, thus
bringing them in line with the third climate change duty: to act in the most
sustainable way. The EQIA is a tool for better and more robust decision
making that can identify unintended consequences of proposed actions before
these are implemented. 
3.4 Fairer Scotland Duty 
Under Part 1 of the Equality Act 2010 certain bodies, including local authorities,
Health Boards, integration joint boards and the enterprise agencies, are also subject
to the public sector duty regarding socio-economic inequality. In Scotland, this duty
was introduced in 2018 as the Fairer Scotland Duty (FSD). The duty places a legal
responsibility on named public bodies in Scotland to actively consider (‘pay due
regard’ to) how they can reduce inequalities of outcome caused by socio-economic
disadvantage, when making strategic decisions. Due regard is best demonstrated in
a published assessment (FSDA). 
The duty applies to strategic decisions – these are the key, high-level decisions that
the public sector takes, such as deciding priorities and setting objectives. In general,
they will be decisions that affect how the public body fulfils its intended purpose.
They may also be coordinated with other strategic decisions as part of an
overarching plan. These would normally include strategy documents, decisions
about setting priorities, allocating resources, delivery or implementation and
commissioning services – all decisions agreed at Board level (or equivalent). The
duty also applies to any changes to, or reviews of, these decisions, not just the
development of new strategic documents. Examples of strategic decisions include:
preparation of a corporate plan, preparation of annual budgets, major procurement
exercises, decisions about the shape, size and location of the estate, and making
strategic decisions on workforce planning. For a full list of examples and further
information refer to the statutory guidance on the Fairer Scotland Duty published by
the Scottish Government. 
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There may be key ways that the climate change duties can align with the Fairer
Scotland Duty, given that decisions taken in line with the climate duties may very
well have a high potential to lessen inequalities of outcome resulting from socio-
economic disadvantage. 
3.5 Illustrative worked example - EQIA and FSDA 
Illustrative example 
A city council may take a decision that could reduce air pollution in areas of the
city where they know there is a higher concentration of both pollution and socio-
economic inequality according to the SIMD, such as by increasing pedestrian
only zones or restricting heavy vehicle traffic. This is likely, in time, to lessen
inequalities in health outcomes between these areas and those that are less
deprived. 
Conversely, if they choose to make it easier for heavy industrial traffic to drive
from one side of the city to the other, without considering whether the routes they
are trying to open up to heavier traffic run predominantly through areas of higher
socio-economic deprivation, this will likely worsen inequalities of outcome from
socio-economic inequality. The same thinking can be applied to where a local
authority may choose to invest money or focus in terms of promoting or
increasing access to green spaces, improving parks, and so on, given the
inequality that exists in access to blue or green spaces. 
This illustrative example is hypothetical. It is intended to illustrate how
undertaking an EQIA and a FSDA for the development of a policy or practice
related to climate action can ensure the achievement of wider linked benefits
both for groups with protected characteristics and for groups experiencing socio-
economic inequalities. This example is focused on the development of a
sustainable travel plan. 
A public body decides to develop a corporate sustainable travel plan, primarily to
help reduce carbon emissions associated with staff commuting and business
travel. The body is located in a large office building in an edge-of-city business
park, adjacent to a housing estate which is in a low SIMD area. The residents in
the housing estate are generally on low incomes, and more likely to be elderly or
belong to a minority ethnic group. 
Through developing its sustainable travel plan, the public body aims to reduce
the number of staff driving to work. This could have positive impacts on local air
quality, in turn benefitting the health of local residents. It may also help reduce
traffic congestion at peak times. 
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With a focus on encouraging staff to use active travel for their commute, the
public body engages with their local authority to lobby for improved cycling
infrastructure in the area and the development of off-road cycleways. Increasing
cycling rates would have direct health benefits for those staff. As the cycleways
would be open to all, this could result in wider health and wellbeing benefits for
local residents too. Cycling is usually an affordable means of transport and would
improve accessibility for residents. The creation of pathways with associated
trees and other planting could improve the quality of local greenspace and help
enhance biodiversity. 
Improved cycling infrastructure and public transport provision may make the
business park a more attractive proposition and encourage other businesses to
lease space or develop there, increasing local employment opportunities and
stimulating other local development. 
As legally required, the public body undertakes an equality impact assessment
as well as a Fairer Scotland Duty assessment as part of the process of
developing its sustainable travel plan. The EQIA considers the three needs of the
PSED while the FSDA considers impacts on inequality for groups experiencing
socio-economic disadvantage. Undertaking the EQIA highlights areas where the
body can deliver on its statutory obligations against the three needs of the PSED;
undertaking the FSDA does so in relation to statutory obligations under the Fairer
Scotland Duty. 
The EQIA 
(a) Eliminating discrimination
The body wants to encourage all staff to cycle to work more, but their last travel
survey indicated that very few female staff cycle to work. The body investigates
these findings by engaging with their staff as part of the EQIA process, and finds
that many female staff are put off by the route into the business park which is via
a busy road and exposed, leaving them feeling vulnerable to potential attack or
anti-social behaviour. They also feel that the current cycle parking, which is at the
edge of the car park, is isolated and poorly lit adding to feelings of insecurity.   
The body wants to ensure that all staff feel safe and able to cycle if they wish.
They improve the lighting to the staff car park and move the cycle parking close
to the main entrance to the building to ensure line of sight to reception,
enhancing perceptions of safety. 
Another barrier identified in information gathered for the EQIA was lack of
adequate facilities for cyclists and other active travellers. While the office does
have showers, three of these are located in the men’s changing area, with only
one in the female changing area. Needing to queue for a shower upon arrival has
put a number of the female staff off using active travel to commute. The public
body reconfigures the washroom facilities, ensuring that equal provision is
provided. They also increase the number and size of storage lockers available so
that active travellers have space to keep their kit. 
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(b) Advancing equality of opportunity
The body sets up a bicycle user group to encourage and facilitate cyclists to
support one another, and as a forum to discuss cycling related issues.
Representatives from the group become key points of contact for related areas of
the business including facilities management and HR, ensuring that cyclists and
would-be cyclists have a stronger voice and are involved in relevant decision
making. 
The public body also prioritises engagement with the local authority to lobby for
the development of off-road cycling and walking infrastructure to establish an
alternative route avoiding the busy road, to create a safe route for active travel for
all. 
The public body wants to increase the proportion of staff using public transport.
The body engages with the local bus company to improve bus service provision
to the business park. It also reviews its working arrangements, and allows for
more flexible working hours to enable staff to adjust their start and finish times to
meet specific bus services or to avoid peak times when journey times are longer.
These improved arrangements help bus travel become a feasible option for many
more members of staff, in particular benefitting women with caring responsibilities
and younger members of staff, as identified through the staff travel survey. 
(c) Fostering good relations
Through the travel survey and the bicycle user group, it is identified that lack of
skills and the confidence to cycle on busy roads is a barrier to many employees,
including those with disabilities, women, and others who are nervous about
cycling. A cycling buddy scheme is set up, where more skilled and confident
cyclists, including those with experience in adaptive cycling, lead a series of
lunchtime rides and accompany less confident riders on part of their commute.
This builds confidence and skills in the less able riders, increases understanding
between the two groups of riders, and helps build positive social relationships.
Over time, initially less confident cyclists, including those with disabilities, are
enabled to lead rides and act as buddies; and the scheme is extended to
members of the local community facing similar barriers. Additionally, the
organisation reviews its salary sacrifice Cycle to Work scheme, to ensure that it
includes provision of adaptive bicycles and necessary accommodations to ensure
inclusivity for all participants. 
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The FSDA 
In the FSDA process, the public body identified statistical evidence that low
income groups were more reliant on public transport than higher income groups,
were less likely to travel by private car, and that their active travel was more likely
to involve walking than cycling. They consulted with groups experiencing poverty
in the local community, and identified that an improved bus service would also
benefit local residents through more regular provision of affordable and
accessible public transport, widening access to employment opportunities.
Affording, securing and insuring cycles were seen as a barrier to cycling for many
in the area. 
Local residents in the adjacent low SIMD housing benefit from more buses at
peak times and services that run later into the evening. This improves access to
services, and opens up additional employment opportunities such as shift work,
which would previously not have been an option for many due to lack of
affordable transport options. 
Wider influence 
The public body introduces an affordable cycle leasing scheme with a local
supplier and engages with the local authority to lobby for improved local cycling
infrastructure, including off-road shared-use pathways with good connections to
public transport and secure lockup facilities. The local authority undertakes
community consultation and engagement around the design of the pathways and
associated green spaces. Different community groups, including marginalised
groups, and users, including the public body, are engaged in the co-design
exercise. This leads to improved understanding of the needs of different groups,
a sense of community ownership, greater community cohesion, and a design that
successfully meets wider needs. 
New relationships between the public body and the local community are built
during the consultation process. The bicycle user group expands and becomes
more diverse, extending its lunchtime rides and buddying scheme to include local
community members. A beginners’ running group is formed to make use of the
new dual-use pathways. The body explores possibilities to set up a work
experience and summer internship scheme with local youth groups. 
Staff surveys suggest that inequalities in feeling healthy, worrying about finances
and job satisfaction have decreased between those on the lowest and the highest
incomes, and between male and female employees.
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4. Putting the duties into practice 
This chapter focuses on putting the climate change duties into practice. While certain
actions are recommended, these should be undertaken in a way that is proportionate
to the climate impact that the body has in terms of its size, assets, function and
influence. Bodies are responsible for determining what is appropriate for their own
organisation, and for taking such measures and actions forward in the most effective
way. 
The chapter starts by outlining a whole systems approach; provides a step by step
model aimed at bodies who may be at a less mature stage in taking climate action;
and covers leadership, governance and mainstreaming. The following chapters then
look in more detail at implementing each of the three duties in turn. 
4.1 A whole systems approach 
Climate change is a complex problem. Coordinated actions across the whole of
society are needed to achieve a just transition to net zero and make Scotland a
climate resilient, healthy, equitable place to live, work and play. Aligned policy
actions across a wide range of areas can deliver multiple social, economic and
environmental outcomes while protecting and improving population health and
wellbeing and reducing inequalities. This will support Scotland deliver against our
national outcomes located within the UN Sustainable Development Goals. 
Determinants and impacts are interdependent. Solutions that have positive impacts
in one policy area can have unintended negative consequences in another.  
Whole system approaches take systems thinking and tools and apply them to
support collaborative action across a broad set of partners to address complex
problems. This often involves challenging the effectiveness of current systems and
focusing on the longer-term impacts, social injustices and power imbalances. These
approaches involve stakeholders across the local or national system working
together to build a shared understanding within a local context and agree aligned
actions to deliver multiple outcomes, strategies to mitigate unintended consequences
and make decisions about trade-offs.
Local authorities and other public bodies are well placed to work with communities
and local partners to reduce emissions, adapt and act sustainably in a way that also
maximises other policy outcomes. This will require collaboration and effective
partnership working across national and local government, the public, private, third
sectors, academia, and local communities. Collective and adaptive leadership will be
required to agree priorities and secure commitment to deliver aligned shared
outcomes. 
The balance between a strategic approach to design and delivery, and enabling local
solutions is challenging. Climate change plans and route maps should include
mechanisms that support creativity and innovation and foster a learning culture to
ensure spread and scale of effective local approaches. 
A robust monitoring and evaluation framework, populated with timebound outcomes,
is required to demonstrate impact on multiple policy outcomes. Monitoring and
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evaluation are key to learning and refining actions, ensure that intended outcomes
are being delivered, equity maximised, and unintended harms minimised. 
4.1.1 Key principles to a whole systems approach 
There are several key principles to a whole systems approach. These characteristics
are reiterated across the guidance in relation to meeting public bodies duties both
within organisations and in the communities and geographical areas public bodies
serve. 
Principle 1: Shared outcomes
Scotland's public sector should play a key role and set an international example
through:
• ensuring that the transition to a low carbon economy is a just one. Public
bodies should embrace the opportunities the transition offers to realise
multiple outcomes across sectors, for example delivering wider social, health
and equity benefits consistent with the NPF outcomes and just transition
principles. The Just Transition Planning framework may be a helpful resource
to aid planning 
• building a resilient Scotland prepared for the challenges of the changing
climate, biodiversity loss, health, social and economic challenges
• using their wider influence to further climate action in the wider community
through engagement with service users, suppliers, the third sector, local
businesses, community groups and other stakeholders
• ensuring that we meet the needs of the present without compromising the
ability of future generations to meet their own needs, in line with the UK
Shared Framework for Sustainable Development (see section 7.3). 
Principle 2: Leadership 
Through exercise of their wider functions and community engagement, the public
sector has a leadership role in Scotland's response to climate change. Local
authorities, for example, are thought to have influence over around a third of
emissions in their authority area 20. Public sector influence comes from procurement
of goods, works and services; investments; Planning; policy making, regulation and
wider partnership working; public engagement and place making. 
As well as reducing their own corporate emissions, public bodies have a key role to
play in leading by example and promoting climate change action more widely. Strong
leadership at all levels will be crucial if Scotland is to meet its ambitious climate
change targets. 
Principle 3: Effective and efficient
Knowledge, intelligence and evidence should underpin adaptation and mitigation
plans and route maps. This should include data and intelligence about climate risks
and the effectiveness of climate actions. It should factor in social vulnerability,
protected characteristics, the health of the local population as well as the building
blocks for health - such as poverty, access to services, housing and natural capital.
Community voices should feature in this data and intelligence.
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Keeping abreast of data and evidence is essential if public bodies are to understand
climate change issues and methodologies for tackling these. Public bodies should
use evidence-based policy and decision making to identify priorities and in due
course demonstrate compliance with the duties. It is also important that public bodies
have information about the communities they serve, and the people they employ, in
order to champion climate change mitigation and adaptation in the broader sense. 
Public bodies may wish to make use of existing mechanisms in relation to corporate
planning processes and existing reporting arrangements where possible, in order
that planning and reporting on progress is done in an effective and efficient way, and
so that public bodies are not required to duplicate work. The guidance also has
regard to proportionality: what is expected of public bodies should be a reflection of
their impact and influence, as well as the nature of what they do, in order to balance
proportionality and flexibility with effectiveness and delivery.
This approach to implementing the climate change duties seeks to mainstream
climate change action across organisations and make it a natural part of decision-
making processes, with the aim of keeping associated potential costs as low as
possible. Reducing emissions through, for example, improved energy efficiency may
also contribute cost savings. 
Principle 4: Collaboration and partnership working
Public bodies should ensure stakeholder participation when planning and
implementing actions in relation to the climate change duties. Just transition
principles include the need to develop and maintain social consensus on climate
action, through engagement with workers, communities, NGOs, business, industry
and any other relevant groups. 
Public bodies are encouraged to work together through existing mechanisms, such
as Community Planning Partnerships and Regional Transport Partnerships, or
through devising new partnerships, and to explore opportunities for building capacity,
sharing best practice and involving of a broader range of delivery partners. 
Principle 5: Open and accountable
Public bodies should be open and transparent to enable the Scottish Government,
the Scottish Parliament and the wider community to understand their plans in relation
to climate change action and to determine progress. 
Public bodies should determine their own priorities and plans in relation to climate
change. The guidance aims to offer suggested actions which empower public bodies
themselves to deliver the duties in a way which best meets their own circumstances
and those that they deliver services to. 
Principle 6: Building capacity and capability
Knowledge and research about climate change and what is effective in tackling it are
growing all the time. While taking timely and effective climate action can be a
formidable task, it also brings many opportunities and supports improved health,
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wellbeing and equity. In taking forward their responsibilities, public bodies should
consider how best to build capacity both within their organisation and in the wider
communities they serve. Building capacity to take action on climate change should
be a core action for public bodies. This may mean looking at embedding new
approaches and cultures across their operations or creating or improving capacity in
relation to specific tools or projects. 
Cultural and behavioural change among organisations and employees will be a key
part of successful climate change action. Cultural and behavioural change have been
shown to be most successful when seen as a joint endeavour where individuals are
equal partners in collective action towards the same goal, with mutual benefits for
both employer and employee. One example is encouraging and supporting
employees to consider alternative methods of travelling to work, such as walking or
cycling, which will not only help them to live longer healthier lives but also assist the
organisation in reducing its carbon footprint. Public bodies should consider how they
will work with their staff as joint partners in promoting cultural change, in order to
achieve buy-in to action throughout the organisation, and identify those areas of
activity which would both help meet their climate change duties and have positive
effects on employees' everyday lives. 
4.2 Implementing the climate change duties: a step by step method 
It is crucial that climate action and sustainability are mainstreamed in all public
bodies' business processes and functions. To do this effectively, public bodies
should set targets and milestones and integrate climate and sustainability into
business practice, through their existing processes and procedures. 
Many bodies will be at a mature stage, and will already have successfully integrated
climate action into their corporate structures and processes. However, other bodies
may be at a less advanced stage, or may have made more progress in some areas
and less in others. The step by step approach outlined below is intended to assist
those bodies requiring support. It is not intended to be prescriptive, or to replace
approaches bodies may already have developed and successfully implemented
themselves. 
Chapters 5, 6 and 7  provide guidance on the actions that all public bodies are
expected to take to help ensure compliance with each of the three climate
change duties. 
Further topic specific guidance will be contained in the supplements accompanying
this guidance, aimed primarily at practitioners working in each field (see section 1.4). 
4.2.1 A step by step method: key outcomes 
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Mainstreaming of climate change into strategic and corporate processes and actions
is the overarching goal for public bodies to work towards. However, it is
acknowledged that public bodies will be at different stages of development and
understanding of climate change action, and that effective mainstreaming could
require more time and effort for some bodies than for others. 
Addressing climate change is an ongoing process. To reflect this, the step by step
process has been developed into a cyclical diagram (with Step 1 following Step 4 in
a new cycle), representing public bodies' continual evaluation of and building upon
their climate change and sustainability action. However, the steps can also be
undertaken concurrently as developing knowledge and individual areas of action
inform new or revised approaches to embedding climate change action. 
Figure 2: a step by step method 
Further details on what is involved in each step are provided in figure 3 below. 
Figure 3: A step-by-step approach for public bodies to climate change action 
The outcomes of the step-by-step process will be: 
• climate change and sustainability action is mainstreamed into the
corporate governance of public bodies
• the public sector provides a leadership function to the rest of Scotland
(private sector, voluntary sector, individuals and households) in its
approach to climate change and sustainability. 
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4.2.2 Step 1: Understanding the duties 
In order to deliver the climate change duties effectively, public bodies need a good
understanding of the legislative and policy context influencing action on climate
change in Scotland, as set out in chapter 2. Public bodies should be mindful of key
drivers to reduce greenhouse gas emissions, adapt to the changing climate and act
sustainably. 
The climate change context is continually evolving. For the latest position please
refer to the Scottish Government website. 
More information on: 
• the importance of reducing greenhouse gas emissions can be found in section
5.2 below
• the importance of adapting to the changing climate in sections 6.2 and 6.3
• acting sustainably in section 7.2. 
4.2.3 Step 2: Assess climate impacts 
Public bodies are required by the 2009 Act to consider the climate change duties in
'exercising their functions'. Step 2 explores how to assess a public body's impact and
influence on greenhouse gas emissions, how to understand the impact of the
changing climate upon a public body as an organisation, and a public body's
influence in preparing Scotland for a changing climate. 
Impact and influence on emissions
Public bodies have a direct impact on emissions through management of their staff
and estate, and how they carry out their daily operations. In addition, the way bodies
carry out their functions, the decisions they make and their engagement with
stakeholders means that they have a much wider influence on GHG emissions. It is
important that public bodies understand this indirect impact and wider influence, and
how they can address GHG emissions through their influence. 
The outcome of Step 1 will be: 
• public bodies understand the three climate change duties: mitigation,
adaptation and acting sustainably. This understanding should extend
across the organisation’s senior leadership team and across departments:
it is not sufficient for understanding of the duties to be limited to a single
climate change officer or team. 
The outcomes of Step 2 will be that public bodies can identify: 
• how they impact on and influence greenhouse gas emissions
• how they can help prepare Scotland for a future climate and how climate
change could affect their organisation
• how they can incorporate the principles of sustainability into their
decisions and actions. 
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Chapter 5 provides further details on reducing GHG emissions, and chapter 8
provides guidance on reporting. Sections 4.6 and 5.5 provide further guidance on
wider influence. 
Adapting to the impacts of the changing climate
The impacts of climate change will be felt by all organisations, their staff and the
communities they serve irrespective of their size, location, activities and services.
Public bodies depend on secure supply chains, resource supplies (energy, water,
materials) and infrastructure and these are likely to face risks related to the changing
climate. To operate effectively, public bodies must become resilient to climate
change. Understanding the changes and how these changes could impact on the
day to day running of the organisation is a useful starting place (see chapter 6). 
Through carrying out their functions, some public bodies will play a central role in
preparing Scotland for a changing climate, for example planning authorities taking
account of flood or drought risk in local development decisions. Public bodies can
also influence Scotland's resilience by, for example, protecting ecosystem services
such as natural flood management. Another key role for public bodies will be in
influencing and supporting the resilience of individuals and communities to the
impacts of climate change, for example by building adaptive capacity through raising
awareness of impacts and community consultation as part of the adaptation planning
process, and by ensuring people have the resources, skills and opportunities to
adapt. 
Chapter 6 provides further details on adapting to the changing climate. Section 6.3 is
aimed at those at a lower level of maturity in relation to adaptation action, while
section 6.4 provides more technical guidance aimed at public bodies with greater
adaptation needs, owing to the size or nature of their organisation, or because they
deliver essential services. 
Functions
All functions of a public body need to be examined in relation to their impact and
influence on GHG emissions, and how the changing climate could impact on those
functions. The wide range of public sector functions can be grouped into three high
level generic areas: corporate, policy and delivery. Public bodies should also
consider how a changing climate might impact on the measures they have in place
under each of these areas, and on action to reduce emissions. 
• Corporate functions - include business planning, staff management, estate
and fleet management, finance and budgeting, and procurement
• Policy – includes policy making, decision making, influencing and consultation
functions of public bodies
• Delivery - includes regulation, spatial planning, education, advice, awareness,
engagement, grants, funding, subsidies, licensing, research, monitoring,
science and other service delivery such as waste collection, healthcare and
recreation. 
Acting sustainably
Public bodies must also ensure they are acting sustainably through their actions and
through the decisions they make, including procurement decisions. To do this
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effectively, bodies should robustly and transparently integrate sustainability into their
decision making and other processes. 
One approach to integrating sustainability into the decision-making process could be
through the use of appropriate impact assessments. 
Further guidance is provided in chapter 7. The ‘Sustainable Procurement’
supplement will, in due course, provide guidance on procurement, the sustainable
procurement duty and related tools and resources. 
4.2.4 Step 3: Plan and Take action 
Mainstreaming means integrating climate change into the everyday work of a public
body at all levels including senior management, policy makers, service delivery and
external partners. This will require strong leadership and robust and transparent
governance, as outlined in chapter 4. Strong governance, leadership and
commitment within the public sector is vital. 
As outlined in chapter 5 below, bodies should develop appropriate strategies, plans
and route maps, and set targets, to clearly lay out their journey to net zero carbon.
Bodies should report on their performance against their targets, to track progress
and ensure that they remain on course. 
As detailed in chapter 6, bodies should undertake climate related risk assessments,
and develop an adaptation plan. Climate related risks should be included in
corporate risk registers. 
Acting sustainably will mean building in sustainability principles across a public
body's functions and decision-making processes and considering the principles of
sustainable development in setting out plans and priorities, as outlined in chapter 7. 
To take effective climate action, bodies will need to work with others: other public
bodies, the third and private sectors, communities and the public. Bodies are
encouraged to work together through existing mechanisms such as Community
The outcomes of Step 3 will be:
• public bodies have strategies and action plans to address climate change
as appropriate
•  public bodies' governance supports climate change action
• public bodies set outcomes and targets for emission reductions
• public bodies integrate climate action into decision making through the
impact assessment process
• public bodies take action to help them implement the climate change
duties
• public bodies are prepared for a changing climate
• public bodies supporting climate change awareness and engagement
work
• public bodies in Scotland are acting sustainably. 
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Planning Partnerships and, where applicable, regional adaptation partnerships; and
to pro-actively seek out new opportunities and partners for collaborative action. 
4.2.5 Step 4: Reporting 
It is important that public bodies monitor how they are doing in respect of their
climate change duties to gauge progress and to make adjustments if necessary.
They also need to be accountable for this to stakeholders, Scottish Ministers, the
Scottish Parliament, audit and regulatory bodies, and their communities. Transparent
and open reporting is a crucial element of maintaining public confidence in the
performance of a public body. It will also assist a public body in demonstrating that it
has complied with its climate change duties. 
Public bodies are used to reporting their performance across many aspects of their
functions. Bodies are expected to ensure that their reporting addresses the progress
they are making in relation to climate change and sustainability action. It is important
that their reporting is linked to the outcomes, indicators and targets for climate action
set through the body's business planning process (see Step 3: Take Action). This will
enable public bodies to review when and where adjustments in policy and practice
might be required over time. 
All public bodies are expected to report annually on their climate and sustainability
performance, and to ensure that such reports are publicly available. Refer to chapter
8 for further guidance on reporting. 
4.3 Leadership and governance 
The outcome of Step 4 will be:
• transparent and open reporting on the delivery of the climate change
duties, which generates public confidence in the performance of public
bodies, drives improvement and assists public bodies in demonstrating
compliance with their climate change duties. 
Key outcomes 
In implementing the climate change duties, key leadership and governance
deliverables or outcomes for public bodies should include: 
• publishing a formal declared commitment to action on climate
change. Making a public body’s commitment to deliver against the climate
change duties visible and transparent, both to those who work within the
organisation and to stakeholders, suppliers and service users, will
increase the level of scrutiny of climate change actions, and public bodies
will begin to exert positive influence over the behaviours of their
stakeholders, suppliers and service users 
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4.3.1 Leadership 
The public sector has a critical role in helping Scotland to reduce greenhouse gas
emissions, make a just transition to a low carbon economy and prepare for the future
climate. Strong governance, leadership and commitment within the public sector is
vital to ensure that Scotland meets its targets and commitments.
Public bodies have an important leadership role to play as: 
• ensuring climate change governance is integrated into the existing
corporate governance approach; and that this is both robust and effective
(see section 4.3.4 below). By ensuring that responsibility for leadership on
climate change is clear within the organisation, both at management level
and cascaded throughout, accountability for climate change action will be
increased
• embedding climate change into the management of risks and
opportunities across the organisation (see section 4.3.5)
• reflecting climate action in the organisation’s corporate plans and
annual reporting mechanisms. These may include dedicated climate
change strategies and carbon management plans to address carbon
emissions reduction (section 5.4) and adaptation plans (section 6.3).
Climate and sustainability should be included in other relevant statutory
plans including, where relevant, Local Outcome Improvement Plans and
Locality Plans. Corporate strategies and plans should include targets;
performance against these targets should be included in annual reports
• ensuring that climate change considerations are mainstreamed across
the organisation (see section 4.4)
• ensuring that climate change systemically informs strategic
investment planning and decision-making processes (section 4.5). By
integrating climate change within business and financial planning, for
example through policy appraisal, impact assessment or Strategic
Environmental Assessment, the body will develop a process whereby the
‘climate change question’ and ‘sustainability question’ is routinely asked
as part of the decision-making process. This will ensure the impact of that
decision on climate change is considered and public bodies are seeking to
act sustainably
• ensure that taking effective climate action is a corporate priority, with
commitment across the organisation. Investment should follow priority
• actively seeking opportunities for partnership working with other public
bodies, for example those in the same or adjacent geographical area or
working in the same sector, to share best practice, maximise efficiency
and increase the impact of climate change action and acting sustainably.
Where possible, public bodies should put formal declarations of
partnership in place to encourage formal working together at a strategic
level. Such opportunities are more likely to contribute to multiple outcomes
encompassing sustainability, health, equity and economic development.
• embedding climate change and sustainable development within
corporate learning and development programmes. 
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• corporate organisations with estates, fleet and staff
• bodies delivering national, regional and local services
• bodies with considerable influence over policy, infrastructure, stakeholders
and the general public
• anchor organisations with significant influence on local places and
communities through employment, environmental sustainability, land and
assets, and service design and delivery
• bodies with significant collective annual budgets and buying power, as buyers
with considerable influence over their supply chain, suppliers, logistics, the
circular economy and waste management, and the related carbon emissions
• partner organisations working across wider regional areas or delivery
programmes
• trusted messengers. 
By showing clear leadership through the way that they deliver their functions and use
their influence, public bodies can help drive wider positive change, fulfil their climate
change duties, and in doing so make a significant contribution to delivering
Scotland’s climate change targets and programmes. Public bodies should become
exemplar organisations in terms of climate action, driving innovation, stimulating the
market and creating the culture and conditions to enable the private sector and wider
society to take the necessary action.  
Actions taken in response to climate change have the potential wider linked benefits
of improving population health and wellbeing, reducing health and social inequalities,
protecting health and improving air quality as well as enhancing biodiversity and
protecting the environment. Public bodies should actively take impacts on these
wider outcomes and the interconnectedness of ecosystems into consideration.
4.3.2 Corporate leadership 
Within an organisation, leadership is vital to ensure that action is taken and
lasting change is made. The importance of having senior leadership buy-in to
drive climate action and embed climate thinking into decision making cannot be
overstated. 
Public bodies should: 
• ensure that all managers receive appropriate carbon, biodiversity and
sustainable development training. In addition, senior leaders should
receive appropriate climate leadership training to provide them with the
knowledge and skills to lead their organisation in taking effective climate
action
• ensure that climate change, sustainability practices and compliance with
the climate change duties are fully integrated into corporate governance
structures and risk management processes
• assign ultimate responsibility for compliance with the climate change
duties and delivering on net zero commitments to the most senior level of
leadership. Accountability should sit at the most senior level of the
organisation, with responsibility clearly identified in roles
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In addition to the essential points above, as best practice, public bodies could
consider:
• appointing a Chief Sustainability Officer with board-level responsibility, or
equivalent. This could help embed sustainability within the organisation by
creating a structure similar to other corporate functions such as procurement,
finance or HR
• implementing an Environmental Management System based on relevant ISO
standards (ISO 14001, 26000, etc.) or equivalent to assist in the continuous
improvement of environmental performance. With leadership at the centre of
the model, it also allows for proactive management of environmental risks and
opportunities, reducing impacts, increasing compliance, and a structured
manner to evidence the achievement of environmental objectives
• applying for or complying with an external accreditation scheme, such as the
Carbon Trust Route to Net Zero Standard
• ensuring that relevant staff receive communications training, to enable them
to confidently communicate with non-experts around climate, sustainability
and behaviour change. 
4.3.3 Leaders as role models 
In addition to their corporate role, senior leaders also have significant influence as
individuals. Members of an organisation will look to their leadership, take cues from
their behaviour and model their actions. The behaviour of, and choices made by,
leaders influence organisational culture. It is essential that senior leaders ‘walk the
talk’ and demonstrate a commitment to their organisation’s climate action and targets
through, for example, how they make and prioritise financial and other decisions,
how they travel for business, and in their support for and compliance with internal
environmental and climate policies. Organisational culture will not shift in relation to
climate change if employees and stakeholders see leaders treating it as low priority
or as optional. 
• ensure that strategic plans and major financial decisions are consistent
with net zero targets and pathways or carbon budgets, and support
effective climate change adaptation and sustainable development 
• consider and act on climate change and sustainability as core deliverables
for the public body, across all business areas. Public bodies should seek
to understand the wider context and systems within which they work;
successful climate action is likely to be linked to broader outcomes across
the system. 
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4.3.4 Governance 
Governance can be described as the system and processes by which organisations
are led and controlled, including the processes for making and enforcing decisions.
Good governance provides leadership, empowerment and strategic oversight. 
It is also essential to ensure accountability and fairness. A key element of
governance is risk management, enabling the organisation to plan and respond
effectively to changes, both internal and external. Particularly for public bodies, good
governance should ensure transparency and is vital to maintaining the trust of staff,
stakeholders and the public. 
Public bodies work within a wide range of statutory duties and compliance regimes,
including the climate change duties. Governance should ensure that such obligations
and compliance are met, including in relation to the conduct of the governance
boards or committees themselves. Supporting the governance structure are
governance processes: the systems and procedures used by the public body to
provide oversight of risks and control measures. The systems used should monitor
performance and alert boards and management if there is an increased risk of failing
to meet statutory duties. 
Public bodies should ensure that appropriate internal governance structures are in
place in relation to climate change and sustainability. Climate change governance
should be mainstreamed and embedded into the corporate governance structure.
Such arrangements will vary by the size and nature of the body. For small bodies,
oversight by their Board may be considered adequate. For larger or more complex
bodies, extended lines of governance spanning different functions and management
levels within the organisation are likely to be required. 
In all cases it is essential that the climate governance structure is clear and that
responsibility is assigned to named roles and individuals to ensure accountability.
Ultimate responsibility and oversight should lie with the most senior level of
leadership. 
Public bodies should: 
• ensure that structures are in place to guarantee oversight,
accountability and transparency in climate-related decision making
• assign responsibility to named roles and individuals to ensure
accountability
• embed climate change and sustainability into decision making at all
levels, with evidence reported and recorded of how this influences
decisions on plans, projects and resources
• actively engage with internal or external auditors to seek feedback
and drive improvement, strengthening their climate governance processes
and structures
• work to proactively influence partners, citizens and stakeholders to
drive change at scale, locally, regionally and nationally. 
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The governance structure should be clearly laid out in the body’s corporate strategy
or equivalent document, and should be available to staff, stakeholders and to the
public. 
Establishing a climate and sustainability steering committee or group can be a useful
approach and provide a level of dedicated focus to drive climate action across the
organisation. Steering groups should include representation from all key parts of the
organisation, to ensure that climate change is embedded across all areas. These
include both areas responsible for operational emissions and those that have a wider
role in influencing climate action by the stakeholders, suppliers and communities that
the organisation works with. They should have clear outputs or deliverables aligned
to setting or meeting the organisation’s targets. However, care should be taken to
ensure that climate change is mainstreamed and not seen as the remit only of these
specialist sub-groups: climate change action should be embedded fully into the
corporate governance structure. 
Public bodies should proactively engage with the audit process in relation to climate
change, to help drive improvement, identify areas of weakness and increase the
robustness and effectiveness of their climate governance. Taking action to
strengthen a public body’s governance, leadership and commitment in regard to
climate change will significantly contribute to the successful implementation of the
climate change duties. Further guidance on the role of audit is provided in section
4.7 below. 
General guidance on governance has been published by CIPFA: International
Framework: good governance in the public sector. 
4.3.5 Risk and opportunity 
Risk management is a key element of governance, enabling the organisation to plan
for and respond effectively to changes. It is the process of taking actions to reduce,
mitigate or avoid risk, for example by putting measures in place to decrease the
likelihood of an event occurring, or to reduce the negative consequences if it does. In
positive terms, it can also involve ensuring that bodies plan for and are ready to take
advantage of the opportunities offered by an event or change. 
All public bodies will have risk management processes in place, and should ensure
that climate related risks and opportunities are identified, assessed and managed as
part of their mainstream corporate risk management system. Public bodies should
take a broad and thorough approach to identifying climate risks. Examples relevant
to public bodies may include: 
• Compliance risks – the risk of being in breach of regulations, potentially
resulting in regulatory action or fines. An example might include more frequent
heavy rainfall events resulting in increased discharge of untreated waste
water to sea by the water company, with subsequent fines from the water
quality regulator, loss of stakeholder trust and reputational damage. 
• Legal risks – the risk of being in breach of the law, leaving the body open to
legal challenge. For example, if a public body made no attempt to reduce its
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greenhouse gas emissions, or made decisions that resulted in a significant
increase in emissions, it could be open to legal challenge in the courts. 
• Reputational risks – these are risks that threaten the public standing of the
body, or trust in the body. For example, if a public body set corporate net zero
targets but then failed to put in place action plans to work towards these or
make any progress, this would likely result in loss of public trust and
confidence, and damage to the reputation of the body. 
• Strategic risks – strategic risks can occur when a strategy is flawed, or
where leaders fail to follow the strategy. As an example, if a health board
failed to consider the changing climate in its long term estate strategy, and did
not consider the adaptation measures required, it could find in the future that
its main hospital campus was no longer fit for purpose or able to cope with
extreme weather events. This could result in the health board being unable to
fulfil its primary purpose of delivering emergency and planned health care
services. 
• Financial risks – financial risks can occur when an organisation fails to
undertake adequate financial planning and costing. It is highly likely that the
changing climate will impose costs on organisations. These could include
direct costs related to, say, repairing storm or flood damage; or more indirect
costs such as the investment needed to adapt buildings and infrastructure to
the changing climate or to relocate buildings away from flood plains. While the
investment needed to upgrade and adapt assets to the changing climate can
seem high, this often constitutes preventative spend, resulting in savings in
the long term as the costs of retrospective action may be much higher. It is
also important that public bodies understand the concept of ‘spending to stand
still’ - i.e. the level of investment required to ensure that services can continue
to be provided at the agreed level over the coming decades in the context of
the changing climate - and incorporate this into their financial planning (see
section 6.4.6.2). 
• Operational risks – operational risks threaten business as usual activities.
They can include damage to assets, or risks that threaten the delivery of a
service. For example, an extreme weather event such as a major storm may
cause flooding, knock out power lines and prevent public transport from
running, all of which could prevent the delivery of at-home social care services
as well as directly impacting on vulnerable service users. Operational risks
may also impact on supply chains. For example, the manufacture of computer
chips is a water intensive process, and global supply of such essential IT
components could be impacted by drought in the country of manufacture. This
could lead to, say, issues with sourcing laptop computers, which are now
essential for the day to day running of many organisations.  
• Physical risks – physical risks threaten physical assets including buildings
and infrastructure, and people. As the changing climate increases the
likelihood of hotter, drier summers, the incidence of wildfires is likely to
increase. For a public body with large landholdings, this could result in
commercial timber crops being lost to wildfire. The body would lose income
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from sale of the timber and could incur costs clearing and replanting the area
and repairing damage to boundary fencing. 
It is essential that climate risks and opportunities are incorporated into the existing
risk management process. Public bodies are likely to manage risk at various levels,
and have separate risk registers for different functions and activities ranging from
project risk registers to overarching strategic risk registers. Climate risks and
opportunities should, where appropriate, be escalated to higher levels within the risk
management structure to ensure that they are given due consideration. Bodies will
have different appetites to climate risks, dependent on the nature of their functions
and on the risks they have identified. This appetite will, in turn, influence the
measures bodies chose to take and the priority placed on specific reducing risks. 
Refer to chapter 6 for further guidance on the assessment of climate risks. 
Further general guidance on risk management can be found in the Scottish Public
Finance Manual. Guidance on management of risk in government has been
published by the UK Government.  The HM Treasury Orange Book provides
guidance on the principles and concepts of risk management.   
4.4 Mainstreaming 
If climate change is to be tackled effectively, it should be mainstreamed across all
areas and decisions – public bodies cannot take a siloed approach. Mainstreaming
the climate change duties means ensuring that climate and sustainability
issues are considered in everything the body does, and in how it makes
decisions. Climate and sustainability considerations should be integrated into the
everyday work of the public body at all levels, including senior management, policy
While it is for public bodies themselves to determine how best to mainstream the
climate change duties in their day-to-day functions, key actions should include: 
• considering the climate change duties when exercising functions,
both wider functions and corporate functions and processes including
budget setting and project planning. For example, a body could ask itself
“how can the climate change duties be performed in the exercise of this
function?” A public body may typically have functions related to
employment and service delivery. For each function, the body should
consider how the function can be carried out in a way which helps the
body to minimise emissions, adapt to the changing climate and act in the
most sustainable way.
• integrating climate change and sustainability into development,
planning and decision-making processes using tools such as equality,
climate change, sustainable development and health impact assessments
• ensuring that corporate templates, such as for Board reports and other
relevant decision-making reports, feature climate change and
sustainability
• reporting on progress to integrate the climate change duties into the
exercise of its functions, where relevant. 
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makers, service delivery, procurement functions and external partners. Historically,
climate change has often been seen as the reserve of specialist functions such as
facilities management. Public bodies should work to ensure that all functions
understand how their work contributes to, and is impacted by, climate change; and
how in turn they can contribute to the organisation’s climate response and act in the
most sustainable way. 
The climate change duties can be used as a lever, alongside other statutory duties
and obligations, to drive continuous improvement. A useful parallel can be drawn to
equalities law, and the approach that public bodies have taken to mainstream the
three needs of the Public Sector Equality Duty (PSED). In implementing the PSED,
public bodies have worked to embed equalities into their leadership and governance
structures, staff training programmes, organisational culture, internal processes and
corporate performance indicators. Public bodies should build on approaches to
delivering the PSED to ensure that climate change and sustainability are equally
embedded across the organisation. Climate change and inequalities are interlinked,
and bodies are recommended to consider them together, as outlined in chapter 3
above. 
A second useful example can be drawn from the implementation of health and safety
legislation. Health and safety is, rightly, seen as an area where compliance is
essential – this is reflected in governance arrangements, and the clear assignment of
overall responsibility to named senior leaders. Employees have a duty to contribute
to both their own health and safety, and that of the overall organisation; and
structures can be put in place to support this. General mandatory training is required
for all employees, with further specialist training for particular roles. 
There are clear links between an organisation’s response to climate change – in
particular the adaptation measures put in place to manage the risks posed by the
changing climate – and aspects of health and safety. Public bodies should consider if
the existing governance structure and processes that ensure their compliance with
health and safety legislation could be revised to include relevant aspects of
compliance with the climate change duties. 
The examples above were selected, in particular, to illustrate the weight that public
bodies should be giving to compliance with the climate change duties. The duties
should, from a leadership perspective, be thought of as an area of compliance with
equal weight to equalities and health and safety, and should be fully mainstreamed
in an equivalent way. Under the 2009 Act, compliance with the climate change duties
is a legal obligation. 
4.4.1 Organisational capability and maturity 
It is important that senior leaders have a clear understanding of their organisation’s
capability and maturity in relation to climate action. Leaders should undertake regular
assessments to identify strengths and weaknesses in their organisational response
to the climate and nature emergencies, and identify areas where further action is
needed. 
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A useful tool for undertaking such an assessment is the Leader’s Climate
Emergency Checklist co-developed by Scottish Government, SSN, the Improvement
Service, NHS and other public sector partners, published on the SSN website and
illustrated in Table 1 below. Adaptation Scotland have produced an Adaptation
Capability Framework which identifies four key capabilities for a body’s adaptation
journey, and the tasks to develop over four stages from starting to mature (refer to
section 6.3.2). 
The Leader’s Climate Emergency Checklist is based on the mainstreaming of
climate action within standard corporate structures and systems, and is designed as
a capability framework. It facilitates assessment of performance in key areas
including governance, finance, skills and delivery, and lays out a maturity pathway
for each. Organisations are likely to find that their maturity varies across different
areas, so regular assessments can help track improvements in performance and
identify areas to prioritise action. The checklist will assist leaders to understand
legislative responsibilities and align with national and local policy developments while
ensuring a just transition that delivers sustainable benefits for Scotland’s people and
environment. 
Table 1: Leaders Climate Emergency Checklist (taken from the SSN checklist) 
Foundation
(structured and
focused)
Advanced
(comprehensive
and professional)
Exemplary
(innovative and
transformational)
Strategy Action on climate
change is a
strategic
corporate
priority.
Key areas for
action have
robust strategies
in place to inform
delivery.
Climate change is
embedded in all
organisational
strategies and
plans, and shapes
decision making
and resource
allocation.
Targets Targets set with
clear baselines,
boundaries,
inventories and
interim targets,
supported by
delivery pathways
and aligned with
national policy
objectives.
Targets and
outcomes set for
key functions of
the body,
including
procurement and
supply chains,
upstream and
downstream
impacts of the
body's functions.
Targets and
outcomes go
beyond net zero,
aimed at
regenerative and
holistic
sustainability
transformations.
Governance Structures are in
place to ensure
oversight,
accountability and
transparency in
climate-related
decision making.
Climate change
embedded into
decision making at
all levels, with
evidence reported
of how this
influences
The body is
proactively
influencing
partners, citizens
and stakeholders
to drive change at
scale, locally,
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decisions on
plans, projects and
resources.
regionally and
nationally
Delivery Climate action
incorporated in
policy
development and
service design,
with policies and
projects in place
and actively
managed.
Coordination of
delivery across
service areas and
projects to
maximise benefits
and avoid
unintended
consequences.
Working
collaboratively to
align and scale
policies, projects
and partnerships
on climate action
Finance Investigating how
to align spend with
targets and steps
being taken to
progress.
Understanding of
how to align spend
with targets.
Finance gaps
identified and work
underway to
secure resources.
Resource and
spend clearly
aligned with
targets, climate
impact of
investments being
managed, and
collaborations in
place to leverage
in resources.
Performance Mandatory climate
change reporting
used to inform
delivery and
communicate
progress.
Progress on
climate change is
part of regular
performance
monitoring and
accounts and
corrective actions
taken.
Monitoring is
above and beyond
mandatory
requirements and
reporting is shared
and reviewed with
stakeholders.
Skills Key staff aware of
how climate
change is part of
their roles and
responsibilities.
All staff
understand how
climate change fits
into their activity
and key staff
taking action to
embed climate
change.
All staff
empowered to act
and contribute to
climate targets and
outcomes. 
4.4.2 Organisational culture 
Organisational culture relates to shared values and behaviours in the workplace.
Culture can include the way things are perceived in an organisation, and extend to
the way that people think and act. Culture therefore effects the way that employees
interact with each other and with stakeholders, and how a body fulfils its functions
and influences its stakeholders. 
Mainstreaming climate change and sustainability thinking within the culture of an
organisation can be encouraged by:
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• senior management demonstrating visible leadership in this area and by
linking climate change and sustainability performance to the objectives
of senior leaders to ensure clear accountability
• ensuring leaders undertake suitable carbon, biodiversity, sustainability
and climate leadership training
• introducing mandatory climate, sustainability and biodiversity training for
new staff as part of their induction, rolling out mandatory training to existing
staff and ensuring that refresher training is delivered at regular intervals
• providing specialist training for roles where an additional level of
knowledge is required, or where staff are keen to deepen their knowledge;
and by creating opportunities and roles for staff at all levels to take a
leadership role on climate or sustainability action
• cascading climate objectives down to team and individual level to ensure
every role contributes to the organisation’s climate response
• using points such as the development or revision of plans and programmes as
an opportunity to reconsider how services are delivered and to actively
engage with stakeholders to seek low carbon and more sustainable
models
• using procurement as an opportunity to embed sustainability including
circular economy aspects into contracts and ensuring ongoing supplier
and contract management to realise and measure progress
• ensuring staff receive regular communications around the organisation’s
climate performance 
• providing opportunities for staff to feedback to the organisation, to make
suggestions and for innovation to be fostered
• reporting on climate change and sustainability initiatives such as training and
integration into the staff performance management system in annual reports. 
4.4.3 Capacity building 
For climate change to be successfully mainstreamed, most public bodies will need to
build the capacity of their existing staff. While use of specialist external consultancy
will continue to be appropriate for some projects, public bodies are strongly
encouraged to invest time and resource in building the knowledge and skills of their
own staff. This should offer best value for money in the longer term, provide valuable
opportunities for staff development and result in an appropriately skilled workforce,
increasing the resilience of the organisation and the public sector as a whole. 
Leaders should ensure that staff are given the time and training opportunities to
ensure the workforce is climate literate. Public bodies should consider delivering
general climate, carbon, biodiversity and sustainability training to all staff. In addition,
practitioners working in functional areas are likely to require more specialist and
technical training, for example Climate Literacy for Procurers e-learning is available
on the Sustainable Procurement Tools website. It is important that all staff
understand that every role and function has an impact on climate and sustainability,
albeit some roles more directly than others. Staff should be given the time to
consider the climate and sustainability impacts of their area’s core functions, and
managers should ensure that these are reflected in performance indicators and
objectives. 
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Due to the importance of training across organisations some public bodies have
worked with external providers to seek a ‘Train the Trainer’ approach, with a smaller
group attending external training courses and then being able to train others within
their organisation. This approach can be very effective and save costs while
maximising impact. Examples include the Carbon Literacy Project and training
offered by the Royal Scottish Geographical Society. Historic Environment Scotland
are establishing a new national hub for retrofit of traditional buildings which will
deliver training. Sniffer offer training on becoming climate resilient. 
There is a depth and breadth of knowledge and experience across the Scottish
public sector. Bodies are strongly encouraged to actively seek out opportunities to
work with and learn from other organisations, and to share their knowledge in turn.
Staff should be encouraged and supported to engage with practitioners’ networks
and forums, maximising opportunities for peer to peer learning. Opportunities may be
found in membership organisations, professional groups, the Public Sector Climate
Adaptation Network and through the SSN.   
4.4.4 Organisational KPIs 
To ensure that climate change and sustainable development are fully mainstreamed
into an organisation, bodies should include climate change and sustainability
performance in their key performance indicators (KPIs). These should have a clear
link back to the body’s climate change and sustainability plans and targets, but may
also focus on more specific areas of climate and sustainability action that are the
priority for the current period, for example those that form part of the action plans for
the coming year. 
For some areas, such as mitigation, it is easier to have directly measurable KPIs. For
other areas such as adaptation, this is more challenging. In the absence of directly
measurable KPIs, bodies should consider the use of intermediate or proxy indicators.
Process or structural indicators can also be helpful in demonstrating change ahead
of longer term outcome indicators. 
KPI performance should be regularly monitored as part of the organisation’s overall
performance management, and action taken if performance is going off track. Annual
performance against KPIs should be included in the body’s annual corporate report
or equivalent. 
Examples of typical KPIs could include: 
• Emissions reductions: reporting performance against targets for scope 1
direct emissions and scope 2 emissions; against specific targets relating to
the decarbonisation of buildings and fleet; against an overall net zero target;
and against specific targets that might be set for scope 3 emissions, for
example those related to procurement, business travel or investments.
Bodies could consider a targeted approach to procurement emissions, for
example by focusing on their largest suppliers or priority product categories in
terms of annual spend per year. 
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• Capacity building: reporting performance related to staff training, such as
the number or proportion of staff who have received carbon and biodiversity
training, or the number of senior leaders who have received climate
leadership training. 
• Adaptation: bodies could consider developing indicators that relate to SNAP
outcomes they can contribute to, as illustrated in sections 6.3.4 and 6.4.6.1,
e.g. the number or percentage of traditional buildings on their estate that
have been climate risk assessed, or the number or proportion of third party
organisations in receipt of grant funding, who are taking adaptation action. 
• Sustainability: the number or proportion of staff who have received
sustainability training; use of sustainable development impact assessments
for relevant policies and plans; the number or proportion of buildings for
which a sustainability assessment has been carried out. 
Bodies could also set KPIs related to initiatives designed to engage service users or
other stakeholders. Areas of priority focus could include, for example, procurement
and contract management: KPIs could be designed to monitor use of the sustainable
procurement tools, specialist training undertaken by staff, supplier engagement and
the use of continuous improvement clauses within existing contracts to improve
environmental performance. 
4.5 Taking climate into account in decision making 
There are various methods available to assist with integrating climate thinking into
the decision-making process, both quantitative and qualitative. A small number are
outlined below. Bodies may choose to use a single method, or a variety, as best
suits their organisation, its function, and the nature of the decision that requires to be
made.   
Integrating climate and sustainability into the decision-making process is important to
meet the duties, but also to avoid unintended consequences that may increase
carbon emissions, lock in high carbon behaviour or result in maladaptation.   
Scottish Public Finance Manual and HM Treasury’s ‘Green Book’ 
It is important to develop policy and take decisions with an awareness that our
climate is changing. Climate projections are clear: warmer, wetter winters, hotter,
drier summers, more extreme weather events and rising sea levels are all set to
increase for decades to come. Many policies, programmes and projects will be
directly or indirectly affected by climate impacts. Appraisal should account for such
impacts, where significant, and respond to them where cost-effective to do so.
Otherwise decisions will not necessarily be being based on full understanding of how
public value can best be delivered over time. 
It is essential, if public bodies are to be compliant with their obligations under the
2009 Act, that the climate change duties are a part of decision making; and that
the thought process behind the decision can be clearly demonstrated and
explained. 
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Well established and updated guidance is available on how to factor climate impacts
into decision making. Key sources are outlined below. It is noted these guides
support that global temperature scenarios below +2 degrees of warming may be
more appropriate for analysing transitional risks rather than physical risks. The HMT
Green Book, Defra Adaptation Reporting Power and the latest assessments of
climate risk from the Climate Change Committee all use scenarios based on global
warming levels focussed on both +2 and +4 degrees by the end of the century. 
The Scottish Public Finance Manual (SPFM) is issued by the Scottish Ministers to
provide guidance on the proper handling and reporting of public funds: Appraisal and
evaluation - Scottish Public Finance Manual 
HM Treasury’s Green Book is guidance issued on how to appraise policies,
programmes and projects. It is not a mechanical or deterministic decision making
device. It provides established thinking models and methods to support the provision
of advice to clarify the social – or public – welfare costs, benefits and trade-offs of
alternative implementation options for the delivery of policy objectives. 
Defra has issued supplementary guidance to HM Treasury's Green Book which is
tailored to climate adaptation. This guidance supports analysts and policy makers to
ensure, where appropriate, that policies and projects are resilient to the effects of
climate change and that these are considered when appraising options: Accounting
for the effects of climate change - Supplementary Green Book guidance 
4.5.1 Climate change in impact assessments 
The most commonly used impact assessments are outlined in section 2.2. While a
small number of these explicitly include climate, such as Strategic Environmental
Assessment (SEA), many decisions fall outside the scope of these statutory
assessments. Public bodies should therefore ensure that their internal assessment
process adequately accounts for climate. 
Strategic Environmental Assessment 
SEA is required when bodies are preparing a plan, programme or strategy that deals
with issues that can be considered to be of a public character (the phrase ‘public
character’ seeks to capture the full extent of the public sector) and where the plan,
programme or strategy is likely to result in significant environmental effects, which
can be positive or negative. As noted in the SEA guidance, ‘significance depends on
the character, quality and sensitivity of the environment which will be affected by the
plan as well as the scale, magnitude, frequency and certainty of the effects
occurring.’ 21 Examples of plans where full SEAs have been undertaken include
Local Development Plans, Climate Change Strategies, Transport Strategies,
Corporate Plans and Flood Risk Strategies. 
Some plans or programmes, where the environmental effects will be minimal, can be
‘pre-screened’ out of the SEA process. However, the majority will require to be
screened and the requirement for a SEA confirmed with assistance from the
consultation authorities. Guidance on SEA is provided on the Scottish Government
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website, and by NatureScot, Historic Environment Scotland and SEPA. Further
enquiries can be directed to the SEA Gateway mailbox.   
Climate change impact assessment 
One way that bodies can incorporate climate thinking into their decision-making
process is through the use of climate change impact assessments (CCIA). These
can use both qualitative and quantitative data to help inform and shape the decision-
making process. As with all impact assessments, CCIA should be undertaken early
in the overall process, and can be used iteratively as the project develops over
different stages. CCIA is suitable for use on all types of projects, plans and policies,
and including procurement. 
Similar to the way that equality impact assessment seeks both to minimise potential
harms and to maximise positive opportunities, CCIA aims to help understand and
then remove or minimise potential negative climate impacts, and to maximise and
promote the opportunities for positive interventions and outcomes. For example,
carrying out a CCIA would typically involve minimising carbon and other greenhouse
gas emissions from the project, avoiding maladaptation, and actively seeking to
contribute to effective adaptation and create wider benefits that may include
enhanced biodiversity, cleaner air and improved public health. 
Although introducing a CCIA framework into the decision-making process is not
statutory, there are several reasons why introducing such a framework is
beneficial to meeting the requirements of the climate change duties: 
• it creates a mechanism for gathering appropriate evidence to analyse,
record, monitor and demonstrate the potential carbon and climate impacts
of projects or spending proposals. In doing so, it helps to mainstream
climate change within the organisation and ensure it is a central
consideration
• it ensures climate impacts are visible and understood at the point at which
a project is proposed and to be decided upon. It does not in itself stop a
project from progressing, but it removes the potential for decisions to be
taken in ignorance of their climate impacts
• it should be a platform to understand and promote positive as well as
negative ramifications, and exists to better inform decision making. It is a
demonstrable introductory action to meet multiple policy drivers and
aligned statutory requirements to which public bodies are held
accountable, including: 
o where the organisation has declared a Climate Emergency or a
date by which to be net zero, the CCIA is a tool for putting the
principle into practice and ensuring projects are delivered in line
with the necessary carbon reduction pathway
o the public bodies climate change reporting duties which require that
public bodies include in their annual returns “how the body will align
its spending plans and use of resources with emissions targets”,
where applicable 
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Without a CCIA or equivalent assessment no quantifiable judgement can be made,
with any impacts only being captured retrospectively at best, when it is too late,
increasing the risk of negative consequences on the climate, environment and other
policy areas; and missing opportunities to mitigate risks. 
Guidance on project or programme climate resilient appraisal is provided in the HM
Treasury Green Book and the accompanying supplements. 
An alternative approach could be to develop an integrated impact assessment
process, where climate change is considered alongside other aspects such as
sustainable development, equalities and public health. This is a more complex
approach, but can ensure that issues are considered in the round. It can also be an
effective method of identifying wider, less tangible benefits or unintended
consequences than if climate is considered alone. This approach may be particularly
suitable where a place based approach is being taken. 
4.5.2 Financial decision making 
It is vital that public bodies understand the climate impacts of their financial decisions
and embed carbon into their business cases, budgetary processes, financial
planning and reporting. If climate change is treated as a corporate priority, it will
impact on how the body allocates and spends its budget, and ensure that spend is
directed to where it will have the greatest impact. Public bodies’ strategic planning
and major budgetary decisions should be consistent with their net zero and wider
climate goals, over both capital and resource expenditure. 
Finance teams should be actively engaged in this process. Achieving net zero will be
dependent on the processes, skills and knowledge held by the finance team. Where
net zero targets and pathways have been set, finance teams will be well placed to
contribute to the development of budgets and investment programmes, report on
progress and to integrate climate change into the decision-making process. 
Public bodies should, as best practice, align with appropriate good practice
guidance. The Accounting for Sustainability Net Zero Practical Guide for Finance
Teams outlines appropriate actions bodies should adopt such as: 
• embedding net zero targets into decision-making processes, including
budgeting and capital planning processes
o Audit Scotland have written to public bodies to confirm their
expectation that all funding and investment decisions are based on
their contribution to climate change ambitions. Further, there is an
expectation that the public sector is able to demonstrate that
climate change is at the heart of decision-making at all levels, and a
central element of all local authority activity. 
Practical guidance on developing and implementing a CCIA process has been
published by the SSN, Developing a Climate Change Impact Assessment
Framework Guidance for Local Authorities and Public Sector Bodies. 
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• recognising the broader influence and impact that your organisation can have
on local development and investment planning
• incorporating sustainability into your organisation’s financing strategy and
communications. 
Public bodies subject to the statutory reporting duty should include information on
their financial decision-making processes and alignment with net zero in their annual
reports. Following a robust process, including use of the tools and methodologies
outlined below or others, can help demonstrate compliance with the climate change
duties. 
As best practice, public bodies could consider reporting to external frameworks such
as the Task Force on Climate-related Financial Disclosures (TCFD). 
4.5.2.1 Tools and methodologies to aid financial design making 
Often, more sustainable and energy efficient products, services and assets carry a
price premium. The principle of ‘spend to save’ means spending more initially to
obtain a better quality product, asset or outcome that costs less to run, is likely to last
longer and is future-proofed to a reasonable degree. It is important that carbon and
wider sustainability factors are taken into account when making such decisions, to
ensure that best value over the useful life of the asset is achieved. 
CCIA, explained above, can be a useful tool to aid the financial decision-making
process and could be a suitable starting point for bodies unused to integrating
climate explicitly into their thinking process. 
Other tools and methodologies are available. Bodies should consider and implement
a proportionate approach which will best suit their own organisation. Examples
include: 
• carbon budgets
• including the cost of carbon in business cases
• assessment of whole life carbon, for example using the Net Zero Public
Sector Building Standard, the UK Net Zero Carbon Buildings Standard, the
RICS whole life carbon assessment or by following PAS 2080 (2023)
• The Institute for Climate Economics (I4CE) methodology for the climate
assessment of local authority budgets
• Sustainable Procurement Tools. 
4.6 Functions and wider influence 
The public sector plays a vital role in enabling Scotland’s transition to net zero and
climate resilience. Through their varied functions, public bodies can have a wide and
significant influence on emissions and climate action far beyond their organisational
boundaries. Public bodies can and should act collaboratively to create the conditions
by which national, regional and local targets and outcomes can be achieved. 
The 2009 Act places duties on all public bodies to use the range of their functions to
address climate change. Public bodies have a wide range of functions that can
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influence emissions and adaptation. These include spatial and transport planning,
service delivery, place-making, investment, infrastructure development, economic
development, funding, regulation, communications, education, community
development, and partnership development and facilitation. 
Public bodies must ensure that the policies and plans they develop to take
climate and sustainability action encompass their wider functions. 
At a local authority area level, community planning is a statutory requirement to
support and enable community empowerment and place making. Local authorities
have planning and financing powers, and at national and regional levels a range of
public bodies have powers and responsibilities for planning, development,
investment and public engagement. All of these functions need to be brought to bear
to enable Scotland to increase the scale and pace of climate action and support a
just transition to net zero. 
The wider influence of public bodies on emissions can be categorised, in part, as the
scope 3 upstream and downstream impacts of their functions. For example, when
developing new housing in a locality, there will be upstream impacts due to the
resources used in the construction of the housing, and there will be downstream
impacts due to the emissions generated by the new households. Housing should be
developed with these upstream and downstream impacts in mind, and action taken
to have a positive influence along the value chain that public bodies can influence. 
Another way of addressing these wider influence emissions is through the lens of
place making and the need to transition to net zero places. In many local authority
areas, for example, public bodies are working together to develop net zero plans and
partnership on area wide emissions. Local authority place based emissions work is
guided by the Greenhouse Gas Protocol for Cities and the Global Protocol on
Community-Scale Emission Inventories, and can often be linked to local authority
commitments, such as the Global Covenant of Mayors. 
The sections below outline key areas where public bodies are likely to wield wider
influence and how the climate change duties can be incorporated into these. 
Anchor institutions
Public bodies, particularly larger bodies including the NHS, colleges and universities,
central government bodies and local authorities, are often anchor institutions in the
places they are located. They tend to have significant physical assets and influence
with other bodies that operate in the area including public transport providers,
businesses and the local authority. Their assets and daily operations can be used to
meet the climate change duties, support the local community and bring wider
benefits, for example through employment, procurement, training and educational
opportunities, and land and building use. 
As anchor organisations, public bodies can influence development in their locales,
for example by connecting to or developing district heat networks. 
Policy setting
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All public bodies will have a policy setting function. For some bodies, such policies
will relate to and primarily influence corporate operations only. For others, their
policies will have a much wider influence, impacting on for example, local businesses
and industry, land use or land management practices, local and regional transport,
delivery of services, service users and the general public. 
Public bodies should in all cases consider the climate impacts of their policies and
routinely assess these alongside other impacts, such as on equalities, health,
biodiversity and business. This could be achieved using the climate change impact
assessment process outlined above in section 4.5.1. 
Bodies should also consider how their policies can contribute to wider priority policy
objectives such as the just transition and tackling poverty, and maximise
opportunities for wider linked benefits such as enhanced biodiversity, improved
public health, reduced fuel poverty and reduced inequality. 
Planning and delivering services
Many public bodies are involved in planning and delivering services. Bodies should
consider how services are delivered, and look for ways to reduce emissions and
make the service more resilient. The changing climate is highly likely to pose risks to
the delivery of essential services in the future, and it is vital that bodies assess and
take appropriate steps to mitigate these risks (see section 4.3.5 and chapter 6). 
In some cases delivery of the service will be undertaken by others, and public bodies
should use the procurement or funding award process to drive positive climate and
sustainability action. Where bodies are responsible for delivering services
themselves, they should mainstream climate change into the delivery model and
actively seek opportunities to reduce emissions, adapt for the impacts of the future
climate and act in the most sustainable way. 
Education
Scotland's learning for sustainability action plan, Target 2030: A movement for
people, planet and prosperity, aims to build an inspiring movement for change so
every place of education for learners aged 3 to 18 years becomes a Sustainable
Learning Setting by 2030. Local authorities and other public bodies involved in
places of education should integrate the 2030 commitment into their improvement
plans, strategic plans, curriculum frameworks, corporate plans and activities. Refer
to section 7.6 for further details. 
Higher and further education institutions, and other public bodies involved in adult
and further education, should consider how a similar commitment and aims can be
integrated into the work of their organisation. In considering their wider influence, this
is particularly important in relation to the range and content of courses that are
offered, and to the local community and place within which the body works. 
Procurement
Public sector procurement in Scotland is worth over £16 billion annually. It is
essential that public bodies work to reduce the climate impact of this spend.
Procurement, supplier management and ongoing contract management processes
can be used to drive carbon reductions and improve environmental and sustainability
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performance through the supply chain. Procurement can be used to support the
move to a circular economy, reduce waste and improve resource efficiency. 
By carefully considering if, what, how and how much they buy, public bodies can
contribute to the delivery of emissions reductions and ensure that they are acting
sustainably. Further detailed guidance will be provided in the ‘Sustainable
procurement’ supplement in due course. 
Grants and other funding
Many public bodies are responsible for awarding or distributing funding to other
organisations across the public, private and third sectors. This may be in the form of
grants, loans or other funding mechanisms. Public bodies should embed climate and
sustainability action into this funding where appropriate, for example through
eligibility criteria, terms and conditions, and service level agreements. 
Investments
Public bodies may have investments. These are most likely to include pension funds,
but may also include forms of trust funds or endowments. Some bodies may have
commercial investments in joint ventures or companies. For example, a local
authority may be a major shareholder in a company that provides sports or public
transport services in the authority area.   
In all cases, public bodies should consider the climate impact of their investment.
Bodies should consider developing and adopting an ethical investment policy and,
over time, may wish to align their investments with their net zero and other climate
targets. Examples may include divesting from fossil fuels or prioritising investments
in renewables and sustainable technologies. Bodies are strongly encouraged to
minimise any negative climate impacts from their investments, and to actively seek
out opportunities for their investments to contribute to wider sustainability aims. 
For example, a body could use its pension fund to invest in the development of new,
high quality low carbon social housing or a district heating system, which would
benefit local communities, help tackle fuel poverty and contribute to the delivery of
wider national policies and outcomes including improved health and reduced reliance
on health services. 
Working together
It is vital that public bodies collaborate to achieve the scale and pace of action
needed to reduce emissions and adapt to the changing climate. Bodies should
proactively seek opportunities to work with other public bodies to share knowledge
and practical learning; to develop larger scale investable projects; and to benefit from
economies of scale and shared resources. 
Public bodies can influence the implementation of the climate change duties by other
bodies. Wherever possible, public bodies should facilitate benefits for others, for
example, a body may generate waste heat that could be offered to and utilised by
another public body located in the area. 
To support delivery of the statutory Public Engagement Strategy for Climate Change,
many public bodies, including the NHS and local authorities, can act as trusted
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messengers and encourage positive climate action in the community through
communication and engagement with their stakeholders and service users. Public
bodies should maximise opportunities to influence and encourage behaviour change
in the wider public, local businesses, third sector organisations and other
stakeholders through leadership, community engagement, communication and
partnership working, including through Community Climate Action Hubs. This may
include participating in or promoting national initiatives such as Scotland’s Climate
Week. 
Local authorities may also want to reach out to third sector organisations with a
focus on climate change or environmental activities that are active in their local area.
The Scottish Communities Climate Action Network and Transition Network Hub
which supports community-led action in Scotland to address the climate and nature
emergency and work for a just, thriving and resilient Scotland might be able to assist
to make these connections. 
4.7 The role of audit 
Auditing climate change is becoming increasingly important internationally. The
International Organisation of Supreme Auditing Institutions for example, conducted a
survey in 2021 showing that climate change and environmental auditing of national
governments is increasing 22. In Scotland, Audit Scotland has published a strategy
setting out how it will audit climate change across the public sector. Internal auditors
are increasingly focussing on climate change within their work. 
Climate change auditing standards, methods, and expertise is growing, and public
sector audit increasingly treats climate change as an inherent and embedded key
aspect of good governance and effective management. 
4.7.1 Climate change and the role of audit 
Audit has a vital role to play in supporting public bodies to comply with their climate
change duties and to improve the design and delivery of public sector climate action.
Both internal and external audit in Scotland is embedding climate change duties as a
key focus. 
Audit plays an important role in reviewing and supporting: 
• effective responses to legislative requirements in the Climate Change
(Scotland) Act 2009, and related policy and legislation, including mandatory
public bodies climate change duties reporting
• embedding climate change into organisational decision making, assurance,
management and governance systems and structures across all areas of
activity
• transparency of actions and spend, and assessment of the impact and value
for money of plans and projects
• leadership, risk management and public sector transformation. 
Both internal and external audit can help enhance the planning, performance,
improvement and accountability of public bodies’ climate change action. 
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4.7.2 Understanding the various forms of public sector audit 
Internal audit
Internal audit undertake a systematic and continuous review of an organisation’s
internal controls, risk management and governance arrangements in line with
regulations, legislative obligations and Public Sector Standards for Internal Audit,
through delivery of a risk-based annual plan. 
Internal audit supports public bodies to meet their climate change responsibilities by:
• ensuring that climate change is embedded into decision making at all levels
within the organisation and across all business areas
• providing independent assurance on the completeness, accuracy and
timeliness of management information on progress and risks
• providing effective challenge about the extent to which policy development
integrates climate change and on internal collaboration across disciplines
• helping ensure targets are clear and transparent and that there is a clear
understanding of the gaps between climate change targets and policy
objectives and the actual plans, policies and resources in place to achieve
them
• helping ensure that governance and risk management processes are working
effectively
• providing an objective assessment of the capacity, knowledge and skills
required to support decision making on climate change. 
The recommendations that internal audit make are a fundamental part of supporting
continuous improvement and ensuring that risks are managed effectively. That
includes managing the risks of the organisation failing to respond effectively to the
climate emergency, of not making sufficient progress towards emissions reduction
goals, or of failing to build resilience and prepare for the impacts of climate change.
Internal audit could also assist by assessing a body’s legal compliance in relation to
the climate change duties. For example, the audit could review evidence relating to
decision making, and whether decisions have been clearly and robustly made ‘in the
way best calculated’ to meet the duties. If this cannot be demonstrated, the audit
should highlight this as governance failure, and the body can work to strengthen their
systems and processes accordingly. 
The SSN Leaders Climate Emergency Checklist provides an effective overarching
framework for public body leaders and practitioners to scope, assess, and track
performance improvement and transformational change. It will help support internal
audit processes as public bodies seek to assess their climate change performance. 
External annual audit
The Auditor General for Scotland and the Accounts Commission for Scotland are
responsible for securing the independent audit of the accounts and performance of
public sector bodies in Scotland. Audit Scotland, the national public sector audit
agency, supports them in delivering their work programmes, appointing auditors and
undertaking two-thirds of the annual audits of public bodies (the remaining one-third
is undertaken by external firms appointed by Audit Scotland). 
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External audit perform the statutory audit of a public body’s annual report and
accounts in accordance with the requirements of various public sector audit
regulations. 
External auditors have a role in assessing whether climate-related risks are
considered as part of the accounting carried out by public bodies for areas such as
property, plant and equipment and provisions. They also assess whether accurate,
relevant climate-related disclosures are included in bodies’ annual report and
accounts. 
Current guidance on climate related disclosures required in public bodies’ annual
reports and accounts is limited but is likely to expand over the next few years. 
Guidance on disclosure requirements are emerging and beginning to be applied to
bodies including the following:
• Task Force on Climate-related Financial Disclosures (TCFD) – aligned
disclosure application guidance 
• IFRS S1 – General requirements for disclosure of sustainability related
financial information
• IFRS S2 – Climate-related disclosures. 
Certain Scottish central government and arms-length bodies must comply with the
TCFD aligned disclosure application guidance from 2023-24. Other public bodies
may adopt the TCFD aligned disclosure in full or in part. Required climate-related
disclosures to be included in annual reports and accounts are likely to be expanded
across the public sector in the coming years. Auditors will review compliance with
any existing and emerging standards that apply to Scottish public bodies. 
Until new standards emerge, the work of external auditors will be determined by their
local risk assessment processes. The latest guidance for external auditors is on the
Audit Scotland website. 
External performance audit  
Audit Scotland undertakes performance audits on behalf of the Accounts
Commission or the Auditor General. They produce national reports that focus on
efficiency and effectiveness in the use of public resources across the public sector. 
The challenge of tackling climate change is hugely complex and requires a whole-
systems approach, with effective collaboration between public bodies, the private
sector and communities. Public audit can look across the public sector to consider
these complex relationships and assess how well public money is being spent and
how services are performing, and identify opportunities for improvement. 
Audit Scotland has a programme of performance audit work on climate change,
which includes consideration of: 
• roles and responsibilities, governance arrangements, key risks and risk
management 
• the development and implementation of plans and strategies to reduce
emissions 
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• progress in integrating climate change adaptation into policies, strategies and
implementation plans
• investment, alignment of spend across policy areas, and value for money 
• partnership working and collaborative leadership
• good practice, barriers and challenges. 
Performance audit reports and recommendations can support public bodies in
meeting their climate change responsibilities by providing assurance, offering
constructive challenge, supporting decision-making and sharing learning to help
drive change and improvement. 
4.7.3 Public sector climate change audit examples 
Examples of performance audit work undertaken by Audit Scotland include the
following: 
• Scotland's councils' approach to addressing climate change (September 2022)
- This briefing on behalf of the Accounts Commission highlights the critical role
of councils in helping Scotland achieve its national climate change goals and
includes recommendations for councils to consider to help improve their
response to the climate emergency.  
• Decarbonising heat in homes (February 2024) – This report on behalf of the
Auditor General highlights the significant increase in the scale and pace of
domestic heat decarbonisation required, if Scotland is to be able to phase out
fossil-fuel home heating systems by 2045.
• How the Scottish Government is set up to deliver climate change goals (April
2023) – This report on behalf of the Auditor General focuses on how effective
the Scottish Government’s climate change governance and risk management
arrangements are in supporting it to drive the delivery of Scotland’s national net
zero targets and climate change adaptation outcomes.  
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5. Implementing the first duty: reducing emissions 
5.1 Introduction to the first duty 
To support the duty to reduce emissions, this chapter briefly sets out:
• the importance of taking action to mitigate emissions
• the net zero approach to mitigation
• decarbonisation pathways
• reducing emissions in practice – climate strategies, target setting, carbon
management plans, monitoring and reporting. 
It is likely for most public bodies that the majority of direct scope 1 emissions will
come from heating buildings. Public bodies should make decisions about the heating
systems in their buildings in line with the Local Heat and Energy Efficiency Strategy
(LHEES) for their area. When installing or replacing heating systems, due
consideration should be given to individual clean heating systems and the future
potential for heat networks, as suggested by an LHEES. These set out zones where
heat networks may present a potential decarbonisation option. Public sector
buildings should be an early focus to allow exploration of opportunities for
coordinated action on decarbonisation of heat, including the identification of public
buildings that could act as anchor loads in any future heat network. Harder to treat
buildings many benefit from this early exploration. 
For some public bodies direct emissions from fleet, process emissions and fugitive
emissions may also be significant. Bodies are also likely to have substantial indirect
The first of the climate change duties set out in section 44 of the Climate Change
(Scotland) Act 2009 requires public bodies, in exercising their functions, to act in
the way best calculated to contribute to the delivery of national emission
reduction targets, i.e. to reduce greenhouse gas emissions, also known as
climate change mitigation. In the context of the duties, ‘targets’ means both the
national five-yearly carbon budgets and the final 2045 target. 
To help demonstrate compliance with this duty, public bodies should:
• develop a climate change strategy that includes net zero and other
relevant targets and has regard to just transition principles
• develop and implement a carbon management plan or equivalent
• develop action plans to deliver key elements of the carbon management
plan, detailing interim steps, costs, timescales and dependencies
• set up a process of monitoring and reporting, to report on performance
against their targets and action plans
• ensure that mitigation actions maximise co-benefits, such as improved
public health, reduced inequalities and enhanced biodiversity, and
minimise unintended consequences such as maladaptation and negative
environmental impacts
• undertake the above giving due consideration to their physical assets
including buildings, land and fleet; their staff and service users; the
services they deliver; the investments they manage; and the functions
they exercise. 
Key outcomes will be that public bodies:
• focus efforts on the material decarbonisation opportunities in each of their
areas of wider influence, scopes 1 and 2, and scope 3
• work with urgency to reduce GHG emissions as quickly as possible in
order to get under and stay under 1.5°C aligned decarbonisation
pathways, i.e. to go as far as possible as fast as possible, and minimise
cumulative emissions
• put governance processes, systems and senior level accountability in
place that ensure policy and project development is aligned to national
emission reduction targets
• measure, monitor and report on annual progress against their targets and
decarbonisation pathway. 
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scope 2 emissions associated with acquired electricity, and potentially heat, steam
and cooling. 
However, the majority of total emissions will likely be indirect scope 3 emissions from
the wider value chain, in particular those resulting from purchasing e.g. all of the
things a public body buys in order to deliver its functions, from buildings to vehicles,
and furniture to IT equipment. 
It is therefore likely the key actions for most public bodies will include: 
• The decarbonisation of heating systems and fleet e.g. replacing gas boilers or
combined heat and power plants with air, water or ground source heat pumps,
or connecting to a district heating network powered by the same. 
Public bodies should focus investment in reducing emissions in those
buildings that are planned to remain part of the estate in the longer term. The
‘Built Estate’ supplement will, in due course, set out the recommended
approach to understanding future estate needs. This should be followed, so
as to focus energy efficiency and clean heat investment on those buildings for
which there is confidence on future need. Where a public body expects to
vacate a building, improvements should be limited to those required as part of
planned maintenance requirements and to meet other statutory obligations. 
• Public bodies having clear long term strategies for their assets and the
sustainable management of those assets. Public bodies should consider the
size and location of their estate, whether it matches service requirements and
future needs, opportunities for co-location of services – to maximise use and
minimise waste (including emissions). This includes adapting the assets to net
zero standards and making assets resilient to a changing climate.  
• Replacing petrol and diesel vehicles with electric or low carbon fuelled
vehicles. 
• The reduction of electricity use wherever possible via, for example, improved
building fabric to reduce heating demand, installation of renewables, LED
lighting, and replacement of inefficient equipment with energy efficient
alternatives. 
• Achieving net zero will, generally, see public bodies using more electricity for
heat in their buildings – particularly if they are moving to electrical heating. At
the time of writing, electricity costs more than other heating fuels,
notwithstanding the efficiencies of electrically-powered heating systems like
heat pumps. Public sector organisations may therefore consider on-site
electricity generation technologies. This should always be supported by an
investable business case that does not expose the body to excessive
risk.  Public bodies could consider investing any savings made in energy
costs into improvements to the fabric of their buildings and or the additional
costs of clean heating systems 
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• The move to a circular economy approach to procurement by:
o thinking early about whether, what, how much and how to buy
o extending the life of equipment wherever possible
o considering leasing and shared ownership models where practical and
economical
o reusing and repurposing equipment wherever possible
o where a purchase is required, procuring products that have been used
(including refurbished products) or remanufactured, or are designed to
be repaired, reused, refurbished, remanufactured or recycled.
This chapter lays out the high level actions that bodies should take, such as setting
targets and developing a carbon management plan or equivalent. Detailed guidance
on the individual measures that bodies could take, for example to decarbonise the
heating in their buildings or to develop a sustainable travel strategy, will be provided
in the topic supplements which will accompany this guidance.  
5.2 Reducing emissions: background and context 
5.2.1 The importance of taking action to reduce emissions 
In order to limit future climate change caused by human activity, we need to rapidly
reduce, by significant amounts, levels of greenhouse gases being emitted to the
atmosphere. The most recent synthesis (AR6) from the Intergovernmental Panel on
Climate Change (IPCC) notes that we need to achieve 43% global emissions
reductions from 2018-19 levels by 2030 to give a 50% chance of avoiding exceeding
1.5°C of global warming, the temperature targeted by the Paris Agreement in 2015
as the safe limit of climate change. 
A more recent synthesis of the science suggests that five climate tipping points cross
a 50% probability threshold, i.e. become more likely than not, at 1.5°C 23. These
include the collapse of the Greenland Ice Sheet, the abrupt thaw of boreal
permafrost (which holds vast reserves of methane gas), and the die-off of low
latitude coral reefs. 
A climate tipping point by its nature is irreversible, representing a shift from one
stable state to another. Once the process starts, even if we were to immediately
cease all carbon emissions, change will continue until the end of its change process,
shifting to a different stable state, e.g. the Greenland ice sheet would continue
melting until gone. Whilst some of these tipping points may take hundreds or
thousands of years to complete, they could be triggered in the coming decade if we
do not achieve 1.5°C aligned decarbonisation pathways. 
There is also a risk of cascading tipping points, where the triggering of one may raise
temperatures sufficiently to trigger another. For example, the loss of Antarctic sea ice
reduces the albedo effect, meaning the dark ocean surface absorbs more heat than
the reflective white surface of sea ice, further warming the Earth. The abrupt thaw of
the boreal permafrost would release vast reserves of methane gas, a potent
greenhouse gas, further accelerating climate change and risking triggering further
tipping points. 
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This highlights that every increment of warming matters, and stabilising the climate 
with minimal ‘overshoot’ beyond 1.5°C remains a key objective from a global and
national equity viewpoint. 
5.2.2 Maximising co-benefits and minimising unintended consequences 
Co-benefits 
Many of the actions to reduce emissions can deliver benefits for other policy areas
such as health and wellbeing, equity and economic development. Bringing these
benefits to the fore can help drive more ambitious climate action and provide an
additional narrative across stakeholders. The Lancet Pathways to a healthy net-zero
future noted: 
There is increasing evidence that many actions to reduce emissions can deliver
near-term health co-benefits 24. Several programmes of work are underway in the UK
and internationally to understand the scale of these benefits and how we can
maximise them.  Health co-benefits can be achieved when climate action addresses
the building blocks of good health, for example through: 
• promotion of active and sustainable transport which can increase physical
activity, reduce air and noise pollution, and increase footfall in local areas with
positive impacts on the local economy
• replacing fossil fuels with clean renewable energy which reduces air pollution
• consumption of sustainable and healthy diets 
• promotion of accessible greenspace with benefits for mental and physical
health.  
Key to a just and equitable transition will be to ensure that benefits delivered by
climate mitigation in relation to emissions, health, equity and social outcomes are
fully accessible to all.
Unintended consequences 
Implementation of mitigation actions can have both positive and negative, planned
and unintended impacts on other policy areas and inequalities. For example, urban
planting, both a mitigation and adaptation measure, can have benefits for health and
wellbeing thereby supporting just transition outcomes. However, there is some
evidence urban trees can increase property values and if unevenly distributed to lead
to gentrification, making land inaccessible to low income residents 25, 26. Similarly,
retrofit schemes to increase energy efficiency are associated with improved health
and social outcomes. However, increasing the airtightness of buildings without
sufficient ventilation can contribute to poor indoor air quality. For some residents the
“a focus on the opportunities for transformative change to an economy that
supports health and equity within planetary boundaries can provide hope
and a compelling vision of an inclusive and sustainable future, engage more
diverse audiences and build support for change” 1 
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cost of housing retrofit can be passed on in increased rental values, particularly for
low income residents in the private rental sector. Where mitigation actions are not
considered in relation to adaptation this can contribute to policy fragmentation and
increase the risk of unintended consequences. 
Whilst trade-offs across policy areas may be necessary, if the unintended impact on
different population groups and different policy areas are not explicitly considered,
these trade-offs can be unacceptable.
Working with stakeholders across policy areas, staff and the wider community, in
particular the most affected population, using systems approaches to co-design and
implement mitigation actions, and integrating mitigation and adaptation, can help
support the delivery of multiple policy objectives, avoid maladaptation, reduce the risk
of unintended consequences and prevent increased inequalities.
5.2.3 The net zero approach to mitigation 
Activities that help reduce greenhouse gas emissions are referred to as climate
change mitigation. 
Climate mitigation is often framed by one of two concepts, net zero carbon or
carbon neutral. These terms are sometimes used interchangeably. It is important
that public bodies understand that they are not synonymous and actually reflect quite
different approaches. 
If a body achieves net zero carbon, it is by definition carbon neutral. However,
carbon neutrality can be achieved without reaching net zero carbon. 
Carbon neutrality is a less robust approach to climate change mitigation, and as
such is not supported or aligned to the Scottish Government’s approach to climate
change mitigation. Public bodies should achieve climate mitigation through a
net zero approach in a meaningful way. 
• Net zero carbon (or net zero) is intended to describe an approach which
reduces an actor’s emissions as far as possible, with only the remaining
unavoidable residual emissions offset through a credible and robust
offsetting mechanism. 
• Carbon neutrality by comparison can be achieved either in the same way
as net zero carbon or by not reducing emissions whatsoever and
offsetting 100% of them. 
In the net zero context, ‘unavoidable residual emissions’ are those emissions
which remain after a body has taken all reasonable steps to reduce or remove
them. They may include emissions related to specific processes or technologies
for which no viable alternative currently exists, for example anaesthetic gases
used in healthcare settings or refrigerant gases used in heat pumps. 
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5.2.4 Decarbonisation pathways 
It is important to understand that within the net zero carbon approach it is not simply
the date by which an organisation reaches net zero that matters, but the pathway to
net zero carbon as the following example demonstrates. 
Some sectors, such as aviation and maritime transport, face greater challenges
and technological solutions may not currently be available on the market. In
these cases, emissions should be reduced as far as possible, for example by
seeking greater efficiencies and using alternatives where feasible. New
technologies and solutions are continually being developed, and bodies should
ensure that opportunities to further reduce or remove emissions are maximised
when they become available. 
Cost and complexity should not be used as excuses to delay mitigation action,
particularly for situations where existing and robust alternative technologies are
available. There may be a point beyond which costs become excessive, e.g. to
remove the final residual 5-10% of emissions associated with a particular source.
However, bodies should bear in mind the future costs that will be imposed on
society should mitigation targets fail to be reached. Whole life analysis,
incorporating the financial cost of carbon into business cases and appropriate
use of impact assessments, as noted in section 4.5 above, can assist bodies to
make robust and equitable decisions. 
Example 
The figures below illustrate four different hypothetical decarbonisation pathways,
each with the same starting and finishing points. Whether emissions are cut
earlier or later in a decarbonisation pathway en route to a net zero carbon target
has a material impact on the cumulative greenhouse gases emitted. As
illustrated, an organisation might for example emit 4 million tonnes of CO2e
(figure 4), or less than 1.5 million tonnes of CO2e (figure 7) depending on its
approach, and still technically achieve net zero carbon by the same target date. 
Figures 4 to 7: Hypothetical pathways to net zero illustrating cumulative
carbon emissions based on early versus late carbon emissions reductions 
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Figure 4: Graph illustrating a ‘typical’ pathway to net zero emissions 
Figure 5: Graph illustrating a ‘straight line’ pathway to net zero emissions 
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Figure 6: Graph illustrating a 10% reduction pathway to net zero emissions 
Figure 7: Graph illustrating a 20% reduction pathway to net zero emissions 
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Due to the impact of cumulative emissions, public bodies should, wherever possible,
set a corporate decarbonisation pathway that reflects the national pathway, and are
strongly encouraged to set a pathway aligned to the IPCC recommendations for a
1.5°C, Paris Agreement pathway. Scotland’s national emissions reduction target is
net zero by 2045.   
A pathway can be developed based on annual or less frequent targets; or bodies can
take a carbon budgeting approach similar to the national approach. In either case,
the absolute amount of carbon emitted over the given time or budget period (e.g. 1
or 5 years) decreases over subsequent periods, down to the target date and residual
or zero emissions level. 
The decarbonisation pathway should be calculated, visualised and planned for
against scope 1 and 2 emissions combined, and separately for wider scope 3
(indirect) emissions. This is aligned to the Greenhouse Gas Accounting protocol.
Should progress in scope 3 emissions reductions be ahead of target, this cannot be
used to justify or “net off” any shortfalls in scope 1 and 2 emissions, they must be
treated separately. 
Public bodies can use nature based carbon removal insetting projects and offsetting
to achieve net zero by counterbalancing residual unavoidable emissions within
scopes 1 and 2. Bodies are not expected to use any purchased offsets against
residual emissions within scope 3. Instead, they can achieve net zero emissions
within scope 3 by ensuring the supply chain uses insetting or offsetting for those
residual emissions owned by the supply chain. Any offsetting required by public
bodies of the supply chain should meet minimum offset standards as defined in
section 5.4.6 below. 
Visualising a 1.5°C aligned decarbonisation pathway 
In the visualisation below (figure 8), the red line represents the decarbonisation
pathway required to give a 50% chance of limiting global warming to 1.5°C for a
hypothetical organisation. The other lines represent alternative potential
decarbonisation pathways for the organisation. Note that none of the proposed
pathways in this figure satisfy a science aligned 1.5°C pathway due to the absolute
amount of carbon emissions before 2030 being above the 1.5°C pathway
(‘overshoot’). For any emissions that overshoot the pathway, a later equivalent
‘undershoot’ is required to balance the total carbon emitted. 
Figure 8: Graph illustrating a 1.5°C aligned decarbonisation pathway 
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5.2.5 Carbon budgets 
One way of monitoring the balance of carbon emissions ahead of target reductions is
for public bodies to work to carbon budgets. As best practice, organisations taking
this approach should work to at least two carbon budgets: one up to 2030, and one
for the period 2031 to 2045. The reason for breaking the approach into two sections
is due to the risk of triggering climate tipping points by exceeding 1.5°C, which is
likely to happen on current projections without significant change before 2030.
Splitting the time into four 5-yearly carbon budgets (2026 to 2030, 2031 to 2035,
2036 to 2040 and 2041 to 2045) would align with the national budget periods. 
Figure 9: Visualising your carbon budget 2020 to 2030 
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Using one of the graphs from the example above to illustrate, the shaded area in the
graph represents the carbon budget from 2020 to 2030. 
Figure 10: Carbon budget 2031 to 2045 
The carbon budget from 2031 to 2045, represented by the shaded area in figure 10
above, is significantly smaller than the carbon budget from 2020 to 2030. This is
aligned to the idea that significant decarbonisation will have taken place before 2030.
This leaves a much smaller carbon budget to work within, and with likely harder
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actions required to achieve these smaller reductions, having achieved the easier
measures before 2030. 
5.3 Reducing emissions in practice: key principles 
To achieve the national net zero target of 2045, a step change in ambition and action
is required. 
Before outlining some principles that will help guide this step change in ambition, it is
important to recognise that the approach bodies will take to developing their plans
will differ due to their size, nature and purpose. This guidance is organised by duty
(mitigation, adaptation and acting in the most sustainable way) for clarity. However,
bodies should consider the duties together in an integrated way and may choose to
develop plans or strategies that include all aspects. 
To help focus action in those areas likely to have the greatest emission reduction
impact, following a number of broad principles will be helpful. 
Materiality
It will be necessary to focus efforts on those actions which achieve the most material
impacts first. 
Traditionally totemic actions may have been the focus of much climate action, such
as recycling, electric vehicles or on-roof solar PV, which while they bring benefit are
rarely the most impactful actions. In the future, there may be a greater focus on
procurement policy and purchasing behaviour across the organisation’s buying
community, exploring major renewables installations with direct wire connections or
sleeved power purchase agreements with explicit additionality in the contract. 
It is worth noting that a significant proportion of Scotland’s GHG emissions come
from the land and land management activities. It is important that landholding bodies
work to understand and address GHG emissions from their land, such as from
degraded peatland, to maximise nature based opportunities to reduce emissions and
to capture and store carbon, and to ensure that their lands are resilient in the face of
the changing climate. 
Wider influence
Closely related to materiality, is ensuring consideration of an organisation’s wider
impacts. For example, a local authority may achieve far greater emission reductions
via adjusting the local plan by introducing a carbon tax per tonne of embodied and
operational carbon on all new developments than by installing PV on the roofs of its
own buildings (noting that the former will contribute to area wide targets that may in
place, and the latter primarily to corporate targets). 
Similarly, ensuring the local transport plan drives the reductions in car mileage
aligned to Scottish Government targets for reducing car mileage may be more
effective than converting its own fleet to electric vehicles. Ultimately both direct and
indirect area wide emissions will need tackled, but prioritising those areas of
influence with the largest impact will be critical to achieving a science aligned
pathway.
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Below are some prompts to help public bodies consider where their own potential
wider impacts and influences on climate change might be. These can then be used
as a starting point to explore action to be taken in response. For example, answering
‘yes’ to any of the questions should prompt further inquiry into the nature and
materiality of the impact and the means by which this is best understood and
managed. 
Does your public body influence: 
• the construction or reconstruction of any infrastructure? 
• the construction methods and energy standards of homes, offices or other
developments?
• energy generation, energy efficiency or energy consumption? 
• planning and or land use strategies including development, farming, forest
planting, forest management, nature based solutions or soil management? 
• agricultural practices and production? 
• travel patterns including number and length of journeys and the mode of
travel?
• individual behaviour such as dietary choice, physical activity levels, or time in
nature?
• waste arising or the amount of biodegradable waste going to landfill? 
Urgency
Due to the risk of triggering climate tipping points, and the fact climate change is
driven by absolute and cumulative carbon emissions, the importance of the pathway
to the net zero carbon target is equally important to arriving at net zero on the target
date. 
Spending effort on actions that result in immediate reductions is important, whilst
working on actions for the largest carbon reductions that might take longer to put in
place. For example, replacing a large combined heat and power (CHP) plant with an
air source heat pump might take over four years from concept to finish. Switching off
that CHP (assuming there are back-up gas boilers) now would immediately offer
significant carbon savings based on the difference between the emissions from the
CHP and grid electricity emissions. This may result in increased revenue spend as
electricity is more expensive than gas, but may be a rapid way to make significant
carbon reductions whilst larger changes are worked on. 
Public bodies should focus on urgent action to reduce emissions as far as possible
as fast as possible over the next decade to minimise cumulative emissions, whilst
still ensuring the goal of achieving net zero by 2045. 
Supply chain
Most effort has, historically, gone into addressing scope 1 and 2 emissions, primarily
generated by heating and powering buildings and fleet. For most public bodies
indirect scope 3 emissions from the wider supply chain will make up the majority of
emissions, and can be influenced or controlled by the public body to some degree.
Categories of scope 3 emissions likely to be significant hotspots for public bodies
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include the emissions associated with purchased goods, works and services, capital
assets and investments. 
For example, whilst the scope 3 emissions from the construction of a new building
are the scope 1 and 2 emissions of the construction company procured to undertake
the project, ultimately the public body’s decision to commission that building creates
those emissions. An alternative, particularly in a hybrid working environment, of
better utilising existing space via hot desk policies, refurbishment, repurposing
buildings, or purchasing and refurbishing existing buildings rather than building new,
would significantly reduce scope 3 emissions in this example. 
Bodies wield considerable influence over their supply chain through their
procurement practices and activities; influence that can cascade down through the
tiers of a contract or supply chain. Climate and sustainability action can be built into
the procurement process, from the initial identification of need and specification,
through to the end of contact or the useful life of the asset. 
Mainstreaming
Ultimately, in regards to each of the principles above, it is crucial that climate change
action is mainstreamed in all public bodies' business processes and functions, as
laid out in section 4.4 above. To do this effectively, public bodies will need to set
targets and milestones and integrate climate change into business practice, through
their existing processes and procedures. Embedding decarbonisation into core day
to day business will be essential to achieve corporate and national net zero and
other targets. 
Demand management
When considering any source of emissions, whether energy or purchased goods,
demand management is key – the lowest carbon option is always not to buy or
consume at all. It is therefore important that approaches begin from a demand
reduction perspective. 
This will be of particular importance as buildings and fleet are electrified, placing
higher demands on grid infrastructure. Bodies should work to ensure that such
demands are minimised, for example by reducing heat demand by insulating
buildings and by undertaking behaviour change programmes with staff and building
users. 
Worked example: Materiality 
Taking a large Higher Education institution as an example, there are several
areas of materiality in each of the main themes below. 
Direct and indirect emissions
Indirect scope 3 emissions will make up a significant proportion of emissions,
with most institutions having between 65% and 85% of their emissions within
scope 3. Within scope 3, the material sources of emissions are typically, in order
of size: the things the organisation buys including, in this example, laboratory
equipment, IT equipment, vehicles and furniture; then international student
flights; followed by the construction of new buildings, as illustrated in figure 11. 
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5.4 Taking corporate mitigation action 
This section outlines the key actions that all public bodies are expected to take, in a
proportionate manner, to reduce their corporate (organisational) emissions. Many
public bodies will already be at a more mature stage, and have some or all of these
elements already in place. 
Within scopes 1 and 2, building heating will be the largest source of emissions,
with electricity usage typically the next material source of emissions. Fleet
emissions will usually be relatively small. 
In this example the priority actions would be in engaging with procurement and
the buying community to reduce purchasing wherever possible. 
Figure 11: Illustrative large Higher Education emissions breakdown 
Wider influence
In this Higher Education institution example, arguably the largest impact is
through the education of its students, and through research into solutions such
as renewable technology and energy storage. Whilst this does not directly impact
on the Higher Education institution’s emissions, embedding climate change
meaningfully across degree programmes, and incentivising and supporting
research into climate solutions, is arguably the largest impact that the institution
can have, whilst reducing its own direct and indirect measurable emissions. 
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5.4.1 Climate change statement 
It is essential that public bodies have a statement or policy in place that clearly states
their approach to climate change and sustainability. For example, many local
authorities have a climate statement which recognises the interlinked climate and
nature emergencies and makes a commitment to reaching net zero. Bodies should
ensure that their statement and or policies cover all three climate change duties and
are signed off at senior level. 
Bodies should ensure that other pertinent policies, for example those relating to
procurement and business travel, properly reflect the climate change duties. In
particular the third duty, to act in the most sustainable way, is highly likely to be
relevant to most other corporate policies. 
All policies should be easily available to staff and stakeholders. As best practice
bodies should make them publicly available, for example through their website. 
5.4.2 Climate change strategy 
Climate change statements can be a useful starting point when it comes to
developing a climate change strategy. While actions on mitigation, adaption and
• Climate change statement - a clear statement that outlines the body’s
approach to climate change and sustainability. For example, many local
authorities will have a high level statement that recognises the climate and
nature emergencies, and makes a commitment to reach net zero. 
• Climate change strategy – a strategy that outlines the body’s headline
mitigation targets, key milestones and actions.
• Route maps – alongside the strategy, the body should develop route
maps laying out, at a high level, steps illustrating how targets and
milestones will be achieved. It may be appropriate for bodies to develop
separate route maps for different areas of activity, e.g. for building and
fleet decarbonisation. 
• Targets – alongside an overarching net zero target, public bodies should
set individual targets, such as a date for achieving clean heating in all of
their buildings, and a date for electrifying their fleet. Targets should be
ambitious but achievable, evidence-based, and appropriate to the body. 
• Carbon management plans – carbon management plans are more
detailed than the strategy, and lay out how the strategy will be
implemented over a given time period. Smaller bodies may find that the
strategy and plan can be combined as a single document, to take a
proportionate approach.
• Action plans – action plans sit below the carbon management plan and
lay out in detail interim steps that need to be taken. They should include
critical milestones, decisions, dependencies, costs, key people and lead
times. 
• Monitoring and reporting – bodies should monitor progress and report
on this through their corporate reporting processes. 
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acting sustainably have, for clarity, been laid out in separate chapters in this
guidance, bodies may find that developing a strategy which encompasses all three
areas is the most effective approach.   
When developing or reviewing their climate strategy, public bodies should be
cognizant of the wider policy context. For example, local authorities will have
developed Local Heat and Energy Efficiency Strategies (LHEES) and Heat Network
Zones (HNZs) which are likely to influence their corporate climate strategy and
related plans, and certainly their area wide planning. 
A climate change mitigation strategy should include:
• scopes 1 and 2, and detail the elements of scope 3 included
• a description of the wider material influences the organisation has on carbon
emissions
• what the final decarbonisation targets are for the organisation, including any
targets or action regarding its wider influence
• a visual breakdown of the organisation’s carbon footprint
• a high level timeline of key actions that will achieve the targets (i.e. a route
map, see section 5.4.3 below)
• a narrative of where the material impacts are, including an explanation of why
certain actions are being prioritised over others chronologically or by effort
• the approach that will be taken to offsetting, which residual emissions
offsetting will cover, and what proportion these residual emissions represent
of the baseline carbon footprint
• a high level overview of risks.
As a minimum, and as detailed in Reporting chapter 8, bodies are recommended to
include within their boundary scope 3 emissions from water, waste and waste water,
business travel, student travel where relevant, and staff commuting and
homeworking. 
In addition to the above, the strategy should consider, where relevant, the
contribution the body can make to wider net zero aims. For example, a body may
generate significant waste heat which could be made available to other bodies or to
a local district heat network. There will be other strategic opportunities to assist the
wider public sector or community, and such opportunities should be maximised.
5.4.2.1 Sectoral approaches 
Sector wide approaches to mitigation, including sectoral targets and aligned
approaches, are being taken by key parts of the public sector. Due to the varied
nature of public bodies, appropriate approaches and actions will differ. 
NHS Scotland 
A policy for NHS Scotland on the climate emergency and sustainable development
(DL (2021) 38) was issued by Scottish Government to Health Boards on 10
November 2021. It sets out the aims and associated targets relating to sustainable
development and climate change for Health Boards to work towards. It takes account
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of relevant wider Scottish Government policies and existing statutory duties. Further
details will be provided in the Health and Wellbeing supplement in due course. 
The NHS Scotland Climate Emergency Strategy 2022-2026 sets out actions directed
at achieving the aims and targets in policy DL (2021) 38 noted above. It sets out
actions which will either begin between 2022 and 2026, be completed during that
period, or are already underway and will continue during that time. 
Integration Joint Boards (IJBs)
While developing a climate change strategy is likely to be appropriate for most
bodies, a different approach may suit others. For example, Integration Joint Boards
(IJBs) are a unique type of public body and own no assets – their emissions and
influence lie entirely in scope 3 indirect emissions. For IJBs, a more suitable
approach would be to embed climate and sustainability action within their Strategic
Plan. 
Local authorities
Local authorities (LAs) have worked in partnership with central government to
establish the Scottish Climate Intelligence Service (SCIS). This jointly funded service
aims to build capacity within councils to develop and deliver area wide programmes
of emission reductions. The SCIS supports a national digital platform to collate area
wide emissions data, enabling LAs to build a baseline of emissions and calculate,
visualise and report on their area wide emission reduction strategies. The service
will, through a network of regional officers, support LAs in building the knowledge
and skills to use the data effectively to enable planning, monitoring, reporting and
delivery of area wide climate action. 
A consistent approach by local authorities to developing climate change plans,
covering both corporate and area wide emissions, will be facilitated by the use of a
standard template (see Annex B). 
Further and Higher Education
The Scottish Funding Council’s (SFC) Net Zero and Sustainability Framework for
Action establishes a clear, long-term plan to support Scotland’s colleges and
universities through the transition to net zero, reflecting improved corporate
accountability and collective responsibility across the Further and Higher Education
sectors. 
The SFC expects institutions to have or to put in place organisation-wide net zero
plans by the end of 2024, and to be able to highlight key priorities and dates for
delivery of these. 
5.4.3 Route maps 
Net zero carbon targets are typically longer term targets ranging from 5 to 25 years
into the future. Science aligned decarbonisation pathways require significant carbon
emission reductions well before typical net zero target dates. In addition, where
woodland creation is a key part of achieving a net zero target, the time lag between
planting and active sequestration (typically 15 to 25 years) means that such activities
also require urgent action if aligning to net zero 2045 targets. 
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A route map is therefore helpful in breaking down the journey to net zero, helping to
ensure that sufficient action is taken to deliver the chosen pathway. 
Route maps can take a variety of visual forms. A high level visual giving key dates
and top line actions can be useful for overview presentations. 
A more detailed quantification of carbon emissions reductions delivered by each
intervention can be useful in delivering a granular analysis of how the
decarbonisation pathway is going to be achieved, and to clearly identify any gaps
between planned action and the pathway. 
High level route maps can include actions on both scopes 1, 2 and 3, as well as
insetting and offsetting, as a helpful overview of the full mitigation programme, and if
not over-crowded could also include adaptation. 
A public body route map will typically include the following specific actions on
decarbonisation as a minimum:
• heat in buildings
• fleet
• business travel
• waste
• reduction in electricity consumption (excluding increases caused by the
electrification of heating and the transition to electric vehicles). 
As best practice, bodies should also include:
• supply chain action
• insetting and offsetting action, where relevant
• land and land use, where relevant
• investments. 
Table 2 below is an example of the kind of high level actions that might be used to
populate a decarbonisation route map for a public body. 
Table 2: Example timeline of actions that might be placed along a route map
for a public body* 
Yea
r
Decarbonisin
g heat
Decarbonisin
g fleet Electricity
Supply
chain
Investment
s
202
5 
All end-of-
lease vehicles
to be replaced
by EV 
Achieve
50% LED
lighting
across the
estate
Circular
economy
policy; buy
less, share,
lease etc.
Publish
supply
chain route
map 
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202
6
Deep retrofit of
most carbon
intensive
buildings
Introduce
cargo bikes for
appropriate
journeys
Upgrade
most
carbon
intensive
equipment
Analyse
supply
chain
impacts 
202
7
Deep retrofit of
less carbon
intensive
buildings
Complete
upgrades of
onsite
charging
infrastructure
Achieve
75% LED
lighting
across the
estate
Begin
supplier
engagemen
t to reduce
largest
emissions 
202
8
First major
CHP replaced
100% of car
and LCV fleet
replaced by
EV  
33% supply
chain
emissions
1.5°C
aligned
Divest from
all fossil
fuels
202
9
Retrofit of least
carbon
intensive
buildings  
Achieve
100% LED
lighting
across the
estate  
Establish
1.5°C
pathway for
investments
203
0
Second major
CHP replaced
25% of HGV
fleet to be low
emissions
vehicles
25% of
electricity
consumed
to be self-
generated
using
renewable
technologie
s
66% supply
chain
emissions
1.5°C
aligned 
Start
adjustment
of
investments
to ensure
1.5°C
alignment
203
1         
203
2
District
Heating
Network for
social housing
completed
50% of HGV
fleet to be low
emissions
vehicles
33% of
electricity
consumed
to be self-
generated
using
renewable
technologie
s
80% supply
chain
emissions
1.5°C
aligned
Complete
adjustment
of
investments
to ensure
1.5°C
alignment 
*Note: the examples provided in the table above are illustrative only. It is for each
public body themselves to determine the most appropriate range of actions and
measures in their journey to net zero. 
Route maps should typically cover at least a five year period (e.g. to align with the
body’s carbon management plan), and could cover the full journey to net zero carbon
if appropriate, and where actions and timelines are understood (i.e. to illustrate the
full strategy). It is likely that most public bodies will have a clearer picture of the next
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five years, with decreasing certainty with time. For that reason public bodies in most
cases should develop route maps 5 to 10 years in duration, noting any material
action that will be required beyond the end of the route map horizon, and noting that
this will be updated at least one year in advance of the end of the current route map
timeline. 
It is likely, especially for larger public bodies, that achieving net zero will be reliant to
some extent on the activities of others, such as for the development of heat
networks. Bodies intending to electrify the heat in their buildings and fleet may be
dependent on upgrades to grid infrastructure taking place in advance of work
commencing on their sites. A vital part of developing the route map will therefore be
identifying the key partners and stakeholders associated with each element or
project, establishing contact and building relationships. This process can be lengthy,
and bodies are encouraged to establish these relationships early, especially with
their Distribution Network Operator (DNO) in relation to grid upgrades, as these can
take many months or even years to come to fruition. 
5.4.4 Emissions reduction targets 
The approach to setting targets 
Targets often form the most visible and public part of an organisation’s strategy for
taking climate action. It is therefore important that these are well considered,
evidence-based and appropriate to the body. When setting targets, bodies should
consider the nature and functions of their organisation, their resources and the
actions that will be needed to deliver on the targets, as outlined in the following
sections. 
It can be helpful to approach target setting using the SMART criteria: 
• Specific – be clear on what is included and excluded in your target or targets,
and avoid general ‘catch-all’ targets. For example, if setting a target related to
car kilometres travelled per year, be clear as to whether that applies to pool
cars, hire cars, grey fleet, etc. Aim to develop specific targets relating to the
body’s significant sources of emissions, such as heat in buildings or road
fleet. 
• Measurable – to enable realistic targets to be set, and for performance to be
monitored and reported on, the target must be measurable. Consider the data
sources available, data quality, where improvements can be made to enhance
accuracy and reliability of data, and to streamline or automate data collection
and verification processes. 
• Ambitious (but achievable) – it is important that targets are stretching and
drive action, but it is also important that they are evidence-based and are felt,
with due effort, to be achievable. Unachievable targets may, in effect, set a
body up to fail and may work against delivery by facilitating delays and the
prioritisation of other work or spend, and by demotivating staff. There are also
significant reputational risks associated with missing targets, or with having to
alter them in the future. 
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• Relevant – targets should be relevant to the organisation and to the body’s
overall footprint. Efforts should be focused where they will have the most
impact, or where targets support other priority outcomes or policies. 
• Timebound – effective targets should be timebound. They should include a
target date plus, where relevant, a baseline year which progress is measured
against. Where a target lies in the more distant future, such as 2045, consider
milestones and how to maintain focus and help ensure that progress stays on
track. 
Corporate emission reduction targets 
Corporate emission reduction targets should include, as best practice and where
relevant: 
• an overall net zero target for scopes 1 and 2 of no later than 2045, earlier
where possible
• individual targets for zero direct emissions from heating of buildings, zero
direct emissions from road fleet vehicles (some public bodies may find it
appropriate to have separate targets for cars, LCVs and HGVs) and zero
direct emissions from the ferry fleet
• targets related to land use and land use change, in particular where land
based emissions, such as those from degraded peatland, are a source of
direct scope 1 emissions
• targets covering other direct emissions, e.g. from use of machinery
• targets covering waste, e.g. waste to landfill, recycling rates, circular economy
• targets related to procurement
• targets related to other sources of indirect emissions, such as business travel,
car kilometres travelled, etc. 
The organisational net zero strategy should map out any intended use of nature-
based carbon removals on the body’s landholdings (insetting) or carbon offsetting
required to achieve net zero targets. The residual unavoidable emissions that will be
sequestered should be estimated as part of net zero planning. Residual emissions
should be as small as possible, and any assumptions and uncertainties clearly
explained. Further information is provided in section 5.4.6 below. 
In addition to net zero targets and those related to decarbonisation of buildings and
fleet, bodies are strongly encouraged to set wider additional targets that reflect, or go
further than, national policy, such as a 20% reduction in car kilometres by 2030.
In all cases, targets should include:
• specific information around what is, or is not, covered by the target
• a target date
• where relevant, baseline information. 
For example, a target focused on reducing car kilometres travelled could be: 
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• 20% reduction in car km taken for business travel by 2030, including pool cars
and grey fleet, in relation to the baseline year 2019.
Targets may relate to carbon (e.g. absolute or relative reductions in emissions) or
may take alternative forms, as in the car kilometres example above. For example, a
body may decide that the most effective way for them to tackle the emissions
associated with procurement would be to carry out an emissions reduction
programme based on prioritisation of procurement of goods, works and services with
a high climate impact. Public bodies may use early market engagement and the
contract management process to identify key performance indicators (KPIs) that can
be used to seek and measure improvements against a baseline during the lifetime of
the contract. KPIs should be relevant and proportionate to the contract in question. 
This may start with qualitative data, moving to quantitative date over time as data
available improves. 
Other measures of progress on procurement and climate maturity may include, for
example, indicators from the Procurement and Commercial Improvement
Programme (PCIP) such as numbers of staff having completed climate literacy
training or evidence that climate has been consistently addressed in relevant
procurements. 
Illustrative baseline targets can be found in the template Carbon Management Plan
(Annex A). This is aimed at smaller and less complex bodies and should be adapted
to suit the circumstances of the individual body. 
5.4.5 Carbon management plan 
A carbon management plan (CMP) is a more detailed document than a climate
change strategy, and lays out how the strategy will be implemented over a given
time period. While the term CMP is used in this document, bodies may use different
terms such as, for example, carbon reduction plan or climate action plan. 
The CMP should include the boundary and governance arrangements, the baseline
and targets set by the organisation and a visualisation of the decarbonisation
pathway. It should reflect the principles outlined at the beginning of this section, i.e.
an approach created through the lens of materiality, wider influence, supply chains,
urgency and demand reduction, and which embeds approaches reflecting all of the
above in the core business governance systems and processes. 
Illustrative targets are included in the template baseline carbon management plan in
Annex A. 
An important element of developing the CMP will be the identification of key
stakeholders and partner organisations, who will be critical to successful
implementation of the plan. Such stakeholders may be internal or external and are
likely to include the Distribution Network Operator (DNO), other public bodies, local
Planners and district heat network developers or providers. Internal stakeholders are
likely to include Finance, Estates, Fleet, Facilities Management and Procurement
colleagues.
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It is important that an organisation’s CMP and other key strategies and plans are
aligned with, where relevant, the estate strategy, planned maintenance and plant
replacement schedules, fleet strategies and fleet replacement plans, and the
procurement strategy. There are likely to be many dependencies between these
strategies and plans, particularly in relation to budgets and implementation. 
Public bodies may often achieve value-for-money by installing clean heating systems
when existing plant has reached (or is nearing) the end of its useful or economic life
and where works can be combined with wider building improvements. Public bodies
should understand and refer to their planned maintenance schedules for heating
system replacement and building refurbishment projects. When making a decision
on the technology to install in place of the current heating system, public bodies
should undertake feasibility studies and decisions should follow the process set out
in the supplementary guidance on the Built Estate (to follow in due course). 
Interim solutions 
Expensive or technically complex interventions can take longer to develop or gain
approval for, so that emissions reductions are not realised in the short or medium
term. In such cases, public bodies could explore interim solutions that can mitigate
emissions in the meantime whilst long term interventions are developed. It may be
possible to utilise hybrid technology that helps reduce emissions until a full transition
to a zero emissions system can be realised. 
Leasing assets whilst awaiting capital budget, maturation of technology or approval
for long term purchases is another bridging mechanism that allows for short term
emissions reductions whilst working on long term solutions. For example, a body
may have an asset at end of useful life. While a zero emissions alternative may not
currently be available, the body may be confident that an option will be brought to the
market within a few years. In this case, leasing a replacement asset as an interim
stage could be an appropriate approach and avoid the lock-in that a purchase now
would result in. 
Flexible approaches 
Approaching budgets flexibly may be necessary in reflecting short, medium and long
term decarbonisation opportunities, and bodies are encouraged to consider their
investment budgets holistically. It may be helpful to temporarily move budget from,
for example, estates to fleet whilst estates plans are further developed but immediate
spend is not required; and then move fleet budget to estates later when major capital
works are required. Similar policy-related budget flexibility may be wise in
maximising area wide impacts. 
5.4.5.1 Template plans 
Annex A contains a baseline carbon management plan template and associated
guidance. It is intended to assist smaller public bodies that may have limited
capacity. It has been designed to align with the mandatory public bodies climate
change duties reporting. In all cases, public bodies should use the template as a
starting point and develop it to reflect their own needs and circumstances.
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Annex B contains a template climate change plan for local authorities. This is a more
extensive document and covers mitigation, adaptation and acting sustainably from
both an organisational and an area-based perspective. It is intended to act as a
guide to what local authorities’ plans are expected to include. 
5.4.6 Dealing with residual emissions: carbon insetting and offsetting 
The main focus of climate change mitigation action for Scottish public bodies should
be action within Scotland to reduce greenhouse gas (GHG) emissions and increase
nature-based carbon sinks. Public bodies should have plans and demonstrable
actions in place to reduce GHG emissions to as close to zero as possible, including
land-based GHG emissions. Offsetting and carbon removal insetting projects must
not be a replacement for emission reductions. 
Offsetting should only be used as a last resort and, in most cases, as an interim
measure while solutions to emissions that bodies are currently unable to eliminate
are developed. Offsetting and insetting should form part of organisational targets and
transition plans aligned with Scotland’s statutory national emission reduction targets
and the global goals of the Paris Agreement. 
The use of insetting and offsetting should be clearly laid out in the carbon
management plan or equivalent, that is transparent as to: 
• why and how insetting and offsetting are to be used as a tool on the route to
net zero
• what proportion (%) and amount (tCO2e) of emissions are to be inset or offset
• what type of insets and offsets are to be used and where they are sourced
from
• which emissions sources or categories these are to cover
• how the insets and offsets will be appropriately accounted for to avoid double-
counting (e.g. in the case of peatland credits which may also be part of the
body’s land-based scope 1 emissions). 
Where insetting and or offsetting have been deemed appropriate, public bodies with
landholdings should maximise opportunities for nature-based insetting projects on
their own land. On the route to organisational net zero carbon, investment in
insetting projects should be prioritised ahead of the purchase of carbon offsets from
elsewhere. Landowning public bodies should consider carefully the emissions saving
claims they make in relation to nature-based projects on their land, in line with good-
practice carbon accounting and reporting principles (further guidance will be
provided in the Land and Nature supplement in due course). For example, peatland
carbon credits produced on a public body’s own landholding cannot be used to
counterbalance other emissions within their inventory as this would constitute double
counting (as land-based emissions from degraded peatland, where relevant, should
be reported as part of the public body’s land-based scope 1 emissions).
Definitions of carbon offsets, carbon insets and carbon credits, including types of
credits (emission reductions, removals and avoidance), as used in this guidance,
are provided in the glossary.
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For some public bodies with larger landholdings, nature-based projects on their land
may enable the removal and storage of more carbon than they emit through their
operations, or that is required for insetting residual emissions as part of a Paris
Agreement aligned transition plan. Public bodies with a nature-based carbon surplus
beyond their own requirements to reach net zero should give careful consideration
as to the most appropriate use for this surplus. Central government bodies could
consider allocating (which could include selling or gifting) the surplus to other public
bodies who are unable to reach net zero within their own boundary. Other bodies,
including local authorities, should ensure that decisions made in relation to the end-
use of such carbon savings or credits are transparent and equitable, and consistent
with wider climate change duties. 
Opportunities for insetting projects on a public body’s landholdings should be
balanced with other local, regional and national priorities including food security,
housing and energy. Care should be taken to promote, and not to harm, other
objectives especially climate adaptation and nature recovery. Where possible,
nature-based projects on the public estate should be designed to achieve multiple
objectives in line with other relevant SG policy, including the Land Use Strategy, the
Natural Capital Market Framework and the Scottish National Adaptation Plan. 
Consideration should be given to wider linked issues and policies. Partnership
working, collaboration and area-based approaches will be important to achieve the
highest quality outcomes, for example via landscape scale clusters of public and
Scottish Crown Estate land. Projects should benefit local communities and contribute
to a just transition. Guidance on delivering community benefits from land is published
by the Scottish Land Commission. 
Public bodies with coastal holdings should also consider the protection and
restoration of blue carbon habitats such as saltmarsh and seagrass: blue carbon is
the organic carbon captured and stored in marine and coastal habitats. With their
ability to sequester and store carbon, to provide natural coastal protection, and to
support complex biodiverse ecosystems, such habitats offer a small but important
role in climate change mitigation, adaptation and resilience. 
Adaptation and mitigation agendas should, where possible, be integrated, ensuring
that climate risk assessments are included in carbon and GHG emissions
assessments. Emissions from degraded or vulnerable nature-based carbon stores
may affect the ability of public bodies, particularly those with larger landholdings, to
reach net zero. Therefore targeted actions to restore any such degraded carbon
stores, especially peatlands, may be required. Where these activities are also to be
used for insetting purposes, care needs to be taken with the type of claims made
linked to high-integrity carbon accounting and reporting practices as noted above. 
When considering changes to land use on public land as part of insetting or
offsetting activities, carbon leakage should be avoided, i.e. where actions taken on a
public body’s landholdings displace carbon-generating activities elsewhere which
then take place outside the reporting boundary.  
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If offsetting activity is to be undertaken as part of an organisation’s net zero transition
plan, there is a strong preference for public money to benefit communities and high-
integrity projects within Scotland, as opposed to investing in international offsets.
Supporting high-integrity nature-based carbon reduction projects within Scotland can
bring benefits to local economies and communities, enhance biodiversity and provide
wider environmental benefits, in addition to contributing to progress towards
Scotland’s statutory national emissions reduction targets. 
As laid out in the GHG Protocol Land Sector and Removals Guidance, public bodies
should ensure that any carbon credits obtained for offsetting purposes meet quality
criteria including additionality, credible baselines, permanence and avoid leakage.
Credits should be high-integrity and verified under Scottish Government supported
carbon codes such as the Peatland Code and the Woodland Carbon Code. Use of
credits verified under the Codes can provide confidence that the GHG Protocol’s
quality criteria will be met: for example, both the current SG supported Carbon
Codes include tests of legal and financial additionality. 
Offsetting by public bodies should only be used as a last resort. Scotland’s climate
change legislation sets a default position that statutory national emissions reduction
targets will be met solely through domestic effort, without any reliance on purchase
of international offsetting credits by the Scottish Government. Any international
offsets purchased by other bodies would not contribute to progress towards
Scotland’s national emissions reduction targets. However, there may be other
motivations for bodies to engage in international offsetting. Scottish Government has
adopted the principle of climate justice internationally and recognises that mitigation
activity and carbon offsetting projects must not cause loss and damage to
communities or habitats overseas. 
5.4.6.1 Offsetting business travel emissions 
Bodies may be asked, for example as part of funding conditions, to offset any
business travel emissions associated with research or other programmes. As noted,
the preference is for emissions generated in Scotland to be offset within Scotland.
Where it is not possible to source high integrity, verified credits directly attributable to
Scottish projects, a reasonable approach would be to purchase UK-based credits.
Any purchased credits should be from a government supported code such as the
Woodland Carbon and Peatland Codes. Bodies should refer to section 8.3.6 in
relation to how purchased credits should be included in the annual public bodies
climate change duties report. 
Offsetting international flights 
As noted above, bodies may find that a requirement to offset business travel,
including international flights, is a condition of grant or research funding, in particular
in the higher education sector. If a body chooses to offset international flights,
whether business travel or other flights such as student travel, the country of
departure should be taken as having national ownership of those emissions. For
example, for a return flight from Scotland to the USA, the emissions from the
outbound leg to the USA would be classed as Scottish emissions, and those from
the return leg as USA emissions. Such Scottish emissions should be offset or inset
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within Scotland. The body may choose where to offset the non-domestic share, i.e.
within Scotland or internationally. 
Bodies who wish to offset the domestic share of international aviation emissions may
do so using Peatland Code credits. Offsetting of such emissions is not, at the time of
writing, permitted using Woodland Carbon Code credits due to differences in the way
that the codes have been established. Bodies could also, where feasible, consider
nature-based carbon removals projects on their own lands, externally verified to an
MRV standard equivalent to one of the SG supported carbon codes. 
They could also consider, for the non-domestic share, the purchase of high integrity,
verified international credits from an accredited scheme such as the Gold Standard. 
5.4.6.2 Selling carbon credits from projects on publicly owned land 
Landowning public bodies may be in a position to generate investment in nature-
based projects through the sale of carbon credits. Any such projects should be
included in the body’s carbon management, climate change or equivalent plans, and
contribute to key outcomes that the public body has identified. Such outcomes are
likely to go beyond carbon and could include adaptation, flood risk management and
biodiversity. Any credits intended for sale should be high-integrity and verified
through one of the government supported codes. 
Bodies should consider carefully: 
• whether the sale of credits is appropriate to their function, objectives and legal
basis or constitution
• whether the nature-based project supported by carbon finance would be
considered additional, corporately in terms of any potential legal drivers that
influence the body’s objectives or functions and therefore how it is required to
manage its land (e.g. legal obligations to reduce land-based emissions) and
also at the project level in relation to whether the project passes the
additionality tests of the code in question
• their own organisational carbon footprint and how the sale of any carbon
credits may impact on their ability to achieve their own net zero targets
• wider benefits and outcomes the investment can be used to help deliver
• what additional considerations may be required, for example, who the carbon
credits are being sold to and for what purpose (e.g. that the credits are to be
used for offsetting residual emissions only or as part of a transitional plan).
Bodies should be careful to ensure that the intended use of the credits avoids
any accusations of ‘greenwashing’ and potential reputational damage. 
It is for individual bodies to make such decisions, taking their own legal advice where
necessary. 
Carbon credits verified through the Woodland Carbon and Peatland Codes can be
used to offset emissions generated in the UK. However, there is a strong
preference for credits arising from publicly-owned and Scottish Crown Estate
land in Scotland to be used only to offset emissions generated within
Scotland. Bodies should assure themselves that the buyer intends to use the credits
against emissions generated by their operations within Scotland only. 
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The design of the arrangements for checking and auditing that only emissions from
activity in Scotland are being offset by carbon credits issued from public land is for
individual public bodies to determine. Bodies could, for example, take a risk-based
approach such as requiring information and a statement of assurance from each
buyer. This could be backed up by an audit process drawing on a sample-based
approach as an alternative to the need to audit every purchaser. However, it would
be a matter for individual bodies to ensure they comply with legal and financial duties
and Scottish Public Finance Manual guidance. Further guidance on demand-side
issues and engagement with buyers of nature-based credits, including carbon, is
included in the Natural Capital Market Framework. 
Responsible private investment for natural capital projects on the public estate has
the potential to play an important role contributing to land use policy delivery and
value for money in public expenditure. Public bodies considering private investment
for natural capital projects should ensure that their projects and financing
arrangements are aligned with relevant Scottish Government policy, notably the
vision for high-integrity markets for natural capital as set out in the Principles for
Responsible Investment in Natural Capital and the Natural Capital Market
Framework. This includes ensuring that projects deliver integrated land use and
community benefits, contributing to a just transition. The overall goal should be to
ensure that any engagement by public bodies with private finance for natural capital
is responsible and of high integrity. 
5.4.7 Action plans 
Below the CMP will sit an action plan, or series of action plans. These will take the
headline actions outlined in the CMP, and clearly lay out the interim steps that need
to be taken in order to achieve the end results. The action plans should include
critical milestones, decisions, dependencies, costs, key people and lead times. They
can form the basis of a project plan to deliver that element of the work. 
For example, the CMP may include a target to replace any remaining fossil fuelled
fleet vehicles with electric vehicles by 2030. The action plan would break this down
into a series of steps, likely arranged by financial year, required to meet this target.
Typical steps might include: getting senior management sign off for the target;
confirming vehicle costs and lead times with suppliers; developing a 5-year budget;
getting sign off on the budget; updating the fleet replacement plan; and developing a
plan to schedule in the placing of orders, delivery of new vehicles, disposal of old
vehicles, etc. 
Developing action plans will be vital to ensure the CMP is delivered. Many projects
will have dependencies, for example gaining Planning permission or being
contingent upon electrical grid upgrades, and it is important that these are identified
early and allowed for. They can assist in the identification and management of risks,
and facilitate resource planning. Progress should be monitored and reported on
through existing project management processes and KPIs. 
5.4.8 Monitoring and reporting 
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Public bodies with statutory reporting duties under the Climate Change (Duties of
Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended, must
report all scope 1 and 2 emissions, along with relevant scope 3 emissions, as
outlined in chapter 8 Reporting below. 
Bodies out-with the mandatory reporting duty are encouraged to follow the guidance
provided in the Reporting chapter, as best practice, and to include the information
within their annual corporate reports. Climate action and sustainability should be
integrated into existing monitoring and reporting processes and documents, such as
the annual corporate report and organisational KPIs. 
Public bodies should monitor and report emissions annually, tracking progress
against their decarbonisation pathways and or carbon budgets. Detailing any
emissions over or under budget, and tracking a cumulative figure, is key to staying
within the organisation’s carbon budget. 
As well as reporting on overall progress toward targets, bodies should ensure that
progress on action plans is monitored and reported on, to ensure that barriers and
potential delays to delivery are identified early, and solutions can be developed. 
5.5 Area wide emissions and wider influence 
Section 44 of the 2009 Act provides that public bodies have duties, in exercising
their functions, to address mitigation, adaptation and sustainability. Many public
body functions are key to supporting wider society’s transition to net zero, building
climate resilience and achieving sustainable development outcomes. This section
addresses the area wide emissions that public bodies have a critical role in tackling
as part of Scotland’s just transition net zero. 
Public bodies, especially local authorities, can have significant influence on area
wide emissions. This is recognised in a range of policy documents and reports
emphasising the importance of local area action on climate change, notably: 
• The Scottish Parliament’s Net Zero, Energy and Transport Committee Report
on the Role of Local Government and its Cross-Sector Partners in Financing
and Delivering a Net Zero Scotland (January 2023)
• Environmental Standards Scotland’s Climate Change Delivery Investigation
Improvement Report (December 2023)
• The Climate Change Committee’s Local Government and the Sixth Carbon
Budget Report (2020)
• The Carbon Scenario Tool report by Edinburgh Climate Change Institute (May
2022) 
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5.5.1 Local area wide emissions and place based climate action 
Places, and place based solutions, should be designed and optimised at different
scales for different challenges and solutions. In this guidance, area wide is used
primarily to describe plans for emissions reduction which target emissions sources at
a local authority level. 
5.5.2 What makes up area wide emissions 
‘Area wide emissions’ refers to all emissions allocated to local authority areas. There
are various methodologies that can be used for this, but protocols and data sets are
being established that are improving consistency and clarity. Key for work in
Scotland are: 
• The Global Protocol on Community-Scale Emission Inventories, produced by
the GHG Protocol initiative of the World Resources Institute (WRI) and the
World Business Council for Sustainable Development (WBCSD). 
• The Local Authority GHG Emissions datasets produced annually as Official
Statistics by the UK Government, under the National Atmospheric Emissions
Inventory (NAEI). 
• The PAS 2080 Standard (and associated Guidance from the Institute of Civil
Engineers) on the carbon assessment of infrastructure, buildings, and wider
public sector investment decisions. 
Estimates of greenhouse gas emissions are produced for each local authority and
National Park area in the UK from the following broad source categories: 
• industry (including electricity-related emissions) 
• commercial (including electricity-related emissions) 
‘Area wide’ and ‘place based’ are terms often used interchangeably. Broadly
speaking, for the purposes of this guidance, they are used as follows: 
• Area wide refers to the totality of activities either planned or currently
occurring within a defined geographic area. This aggregates and then
breaks down measures, activities, and actions at an area wide scale, in
this context those specifically related to sources of emissions and actions
for emissions mitigation.
• Place based refers to the design of future solutions and approaches by
considering the specific needs and attributes of a place (however that
place is defined). This recognises the complex and interconnected nature
of a place, and in this case the impact that has on both emissions from a
place and the effectiveness of measures to target them. The Place
Standard with a Climate Lens is a useful resource for addressing climate
change at a place based level.
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• public sector (including electricity-related emissions) 
• domestic (including electricity-related emissions) 
• transport 
• land use, land use change and forestry (LULUCF) (including removals of
carbon dioxide from the atmosphere, so that net emissions from this sector
can sometimes be negative) 
• agriculture (including electricity-related emissions) 
• waste management (distributed based on the waste arising in each local
authority. 
Figure 12: Territorial emission sources of a typical local authority area wide
inventory 
Breaking down emissions by source enables the alignment of local area plans,
actions and measures for emissions reduction and can be used to develop cost
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estimates for area-wide emissions reduction pathways. An example of this is the
Net-Zero Carbon Roadmap for Edinburgh published in 2020. 
Local area wide emissions reduction plans should also be designed to secure co-
benefits relevant to the National Performance Framework and policy commitments
on adaptation, wellbeing, health, economic development, justice and inclusion and
biodiversity improvement. 
The Scottish Climate Intelligence Service, established in 2023, supports a consistent
approach to area wide emissions accounting and local area wide emission reduction
planning and action across all local authority areas. 
5.5.3 Public bodies duties and action on area wide emissions 
5.5.3.1 Public bodies’ influence and collaboration 
Public bodies need to use their various functions to influence the reduction of area
wide emissions. Central to this is the role of local authorities and their Community
Planning Partners. Other public bodies can support plans, projects and policies at
local authority level to support efforts to reduce emissions locally. 
Key to working on area wide emissions is recognising that public bodies have
significant influence on these emissions, while they mostly do not have direct control.
Much like local economic development and public health improvement, for example,
public bodies should work to use their various functions and to collaborate across the
public sector and with communities, businesses and third sector organisations, to
influence local area emissions from various sources. 
Figure 13: Control and influence on area wide emissions (developed from Figure
1 in the Carbon Scenario Pathfinder Project report (2022), ECCI 27) 
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5.5.3.2 Developing plans, projects and policies to reduce area wide emissions 
Having clarified the area wide emissions inventory, public bodies (especially local
authorities) should develop a plan for area wide emissions reduction. These plans
need clarity on targets, emission reduction pathways, projects and policies. Local
authorities and public bodies can draw on Scotland’s Climate Change Plan for
relevant policies and projects, and also supplement these with local initiatives. 
Of critical importance is a clear policies and projects register, with associated carbon
impact assessment that allows calculation of reduction pathways and projections. 
Good practice area wide emissions reduction plans should:
• develop plans with clear policies and projects that have a clear and auditable
impact on emissions
• consider the functions of your public body and how these influence local area
emissions
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• identify the collaborations and partnerships needed to effect change and scale
up impact
• allocate resources, financial and human, to ensure projects and policies are
implemented
• maintain the area wide emissions reduction plan as a live document that
remains relevant and impactful on decision making and investment, with on-
going monitoring and reporting of progress (where applicable, linked to
mandatory public bodies climate change duties reporting). 
Influencing area wide emissions is a complex, multi stakeholder challenge. Public
bodies are encouraged to use holistic, systems thinking approaches to plan and
implement actions. A helpful approach is to make use of the Scottish Government’s
Individual, Social, Material (ISM) framework to understand and address the multiple
barriers that can affect the effectiveness of projects and policies. For example,
consideration needs to be given to material change (infrastructure, technical
actions), social change (community engagement, public level information, shifting
social norms), and individual change (actions that individuals and families can take
and how public bodies can support these). 
5.5.3.3 Focusing on resource allocation and implementation 
Plans, policies and projects to reduce area wide emissions need to be resourced and
implemented to be effective. The policies and projects register should provide a
register of commitments and opportunities that require resourcing.   
Public bodies need to take steps to align their own financial, staff and other
resources to support implementation of the policies and projects. However, area
wide emissions plans require investment, support and resources from other local
actors, within the public sector and within business, the voluntary sector and
communities. Projects will be of varying scales and will require different levels of
investment over varying timescales. 
Area wide emissions reduction plans need to be treated as investment plans, with
pipelines of investable opportunities. These plans should form the basis of
investment portfolios that local authorities and their partners can use to attract both
public and private sector investment. 
5.5.3.4 Monitoring, reporting and decision making 
It is vital that area wide plans are actively managed, monitored and reported on, and
used to attract and scale up investment towards net zero targets on an ongoing
basis. Effective monitoring and reporting of area wide plans are needed to ensure
they are used for active and committed decision making. The data and reporting of
area wide plans should provide leaders and decision makers with information that
can be used in spatial and investment planning and decision making. 
Local authorities and their partners should use the voluntary Wider Influence section
of the mandatory public bodies climate change duties report to report on their area
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wide emissions plans, policies and projects, and to report progress towards targets.
Guidance can be found on the SSN website. 
5.5.4 What does this mean for public bodies? 
All public bodies across Scotland should be contributing to area wide
emissions reduction in designing and delivering their services. Different bodies
have distinct roles in designing, supporting, and delivering area wide emissions
reduction programmes: 
• local authorities are currently leading area wide emissions reduction
strategies and action planning across Scotland
• national and regional public bodies should support delivery of local area
wide strategies by using their functions to contribute to delivery of projects
and policies; and by prioritising their investments, regulatory functions, and
activities to enable effective implementation of local projects and policies
• all public bodies should contribute to area wide emissions reductions by
minimising their operational impact in the areas in which they are based and
operate
• all public bodies should improve their contribution to area wide emissions
reductions by recognising and using their wider influence on place. 
For all public bodies, this means embedding climate impact into organisational
decision making, service delivery and future investment. 
5.5.4.1 What action public bodies should be taking 
All public bodies should fully understand their role in area wide emissions reduction
and deliver it to the best of their ability. This means building internal capability and
capacity to ensure climate impact is embedded into decision making at all levels, and
actively supporting other public bodies to develop and deliver area wide emissions
reduction strategies. 
Given the different roles of public bodies, what this means in practice is that: 
• Local authorities should have a plan in place for area wide emissions
reduction, which sets out actions for climate mitigation against their place
based emissions profile on a pathway to net zero by 2045 at the latest.
Plans should have estimated costs based on recognised methodologies
against sets of actions for climate mitigation. Local authorities should also
be actively convening local partnerships of critical partners who can
support and enable development and delivery of area wide programmes.
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5.5.5 Developing partnerships for area wide emissions reduction 
Many of the solutions required for net zero delivery cannot be optimised within one
organisation and often other organisations may be better placed to facilitate change.
Recognising this, it is important to identify and engage critical local partners as early
as possible and to share resources and build collaborations for net zero delivery.
Critical partners will come from both the public and private sectors, in particular
organisations within an area who may be: 
• responsible for a significant share of local emissions
• able to share assets and investment to make better use of resources
• able to reduce the emissions impact of delivering local services
• able to engage local stakeholders in changes to behaviours or business
practices. 
To realise the benefits of partnerships in delivering net zero, it is important to find
mechanisms and resources to ensure partners are aligned, work is coordinated,
opportunities are realised, investment is shared, and effort is not duplicated. 
Several mechanisms exist or are emerging which either build on or establish new
mechanisms focussed on net zero delivery. These include partnerships for strategic
infrastructure investment, independent local bodies such as climate commissions
and community-led initiatives for local action. All of these can contribute to
accelerating place based approaches to climate action making the need for
coordination even more vital for effectiveness and impact. 
Formal public sector partnerships at local or regional levels can also be important in
fostering a partnership approach to local area emissions planning and delivery.
These include: 
• Community Planning Partnerships
• Regional Land Use Partnerships
• National and regional public bodies should prioritise area based
emissions reduction as part of their climate change duties, coordinating
effectively with local authorities and between public bodies to target
measures where national investment is needed to enable effective
delivery of local area wide emissions reduction strategies, and where
national investments and policies can deliver the most impact into local
area wide emissions reduction plans. 
• All public bodies should fully contribute to area wide emissions reduction
using both their operations and their wider influence. This means that as
well as delivering their own commitments to reduce operational emissions,
they should actively use their influence on partners, suppliers and service
users to reduce area wide emissions, contribute to local partnerships for
planning and delivery of emissions reduction, and look for opportunities to
share the costs and risks of investment in mitigation actions.   
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• Regional Growth Deal Partnerships
• Regional Economic Partnerships
• Regional Transport Partnerships
• Community Climate Action Hubs
• Local public health partnerships
• Local biodiversity and environmental partnerships 
5.5.6 What support is available? 
Support is available to local authorities and public bodies for the development and
delivery of area wide emissions reduction plans through the recently established
Scottish Climate Intelligence Service (SCIS) This has been established by joint
funding from Scottish Government and the 32 local authorities to build capacity in
local authorities to deliver area wide programmes of emissions reduction as part of
the national Climate Change Plan. The SCIS manages a national data platform and
supporting service to help local authorities to design, manage, monitor and deliver
area-wide programmes for emissions reduction. It is delivered in partnership by the
Edinburgh Climate Change Institute, the Improvement Service, and the Sustainable
Scotland Network. 
The Sustainable Scotland Network (SSN) is an established network of sustainability
practitioners across all of Scotland’s public bodies. SSN runs an active programme
of events, forums and challenge-specific networks to support collaboration and
knowledge sharing across the public sector in responding to climate change and
delivering climate impact. It welcomes approaches from public bodies where SSN
can support collaboration and progress on key issues. 
6. Implementing the second duty: adaptation 
Under section 44 of the 2009 Act, relevant public bodies have a duty, in
exercising their functions, to act in the way best calculated to help deliver the
Scottish National Adaptation Plan (SNAP).   
All public bodies must identify the national adaptation objectives from SNAP
relevant to their functions and act in a way that supports the delivery of these
objectives.   
Organisations will have varying degrees of influence in relation to adaptation in
Scotland depending on their particular role, functions and responsibilities, but all
public bodies need to be resilient to the future climate and to plan for business
continuity in relation to delivery of their functions and the services they deliver to
the wider community.  
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6.1 Introduction to the second duty 
This chapter starts by providing a brief explanation of what climate adaptation is, why
it is important and by providing context for adaptation action. It is understood that
public bodies will be at differing levels of maturity in relation to adaptation action. The
guidance aims to provide a baseline level of information, aligned with the guidance
and resources developed by the Adaptation Scotland programme. 
The chapter then moves on to provide more technical and complex guidance aimed
at organisations with greater adaptation needs, either owing to the size and nature of
their estate and assets, or due to their function, i.e. those bodies responsible for
delivering essential services. 
6.2 What is adaptation to climate change? 
The climate is changing. Current advice from the UK Climate Change Committee is
that Scotland needs to adapt to 2ºC of warming and assess the risks up to 4ºC 28.
To help demonstrate compliance with this duty, public bodies should:
• undertake a climate related risk assessment or assessments
• develop and implement an adaptation plan or plans with, as best practice,
regard to just transition principles
• ensure that appropriate climate risks are included on corporate risk
registers
• where applicable, note the specific adaptation actions assigned to them in
the SNAP and align their work with these
• actively seek to work in partnership with other organisations to develop
and implement wider placed based adaptation plans
• undertake the above giving due consideration to their physical assets
including buildings, land and fleet; their staff and service users; the
services they deliver; and the functions they exercise. 
Key outcomes will be that public bodies:
• have a sound understanding of why adaptation is important for their
organisation and what the impacts of climate change could mean, and will
have identified and assessed their risks, vulnerabilities and any potential
opportunities
• have identified and assessed the adaptation options, and have measures
in place to implement their chosen strategies so that their physical assets,
daily operations and service delivery are adapted to the changing climate
and are resilient to its impacts 
• monitor and evaluate implemented measures to ensure that adaptation
efforts remain sufficient and responsive to changing conditions
• where applicable, contribute to the achievement of the specific adaptation
outcomes assigned to them in the SNAP, and are able to track and report
on delivery
• contribute to the effective adaptation of the places in which their sites,
operations and services are located and delivered.
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Whilst global efforts to mitigate further warming will continue, we must ensure we are
prepared for the future climate. 
Adaptation refers to adjusting to the impacts of climate change, including hazards
such as flood and heatwaves. Adaptation involves the deliberate and systematic
adjustment of systems and processes to effectively address both anticipated and
actual climate change impacts. This comprehensive approach focuses on increasing
preparedness to future extreme weather events, reducing existing vulnerabilities,
increasing climate resilience, mitigating damages caused by climate change impacts,
and takes advantage of positive opportunities that changes may offer. 
Adaptation to climate change addresses a range of challenges enabling societies
and ecosystems to thrive in a changing climate. It is an ongoing process that
requires collaboration and flexibility within and between organisations; and
integration into broader strategies, plans and operational practices, including links to
policy areas such as climate change mitigation, land management, health and
welfare. 
Human and natural systems are complex. Adaptation will take place within the
context of significant societal challenges including those related to population health,
the cost of living crisis, and the biodiversity and loss of nature crisis. Integrated and
aligned policy actions can deliver multiple outcomes for population health, equity, the
environment and the economy, contributing the Scotland’s National Outcomes and
the UN SDGs.   
Key areas of focus for adaptation in practice include understanding when and how to
adapt infrastructure to cope with increased weather extremes, and changing land
management practices. There are however areas of significant overlap with activities
that could help to meet both mitigation and adaptation goals, such as naturalising
river catchments for flood risk and water management, woodland restoration, blue-
green infrastructure and education, all of which will deliver multiple benefits. Figure
14 demonstrates the differences and the areas of overlap between adaptation and
mitigation.   
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Figure 14: Venn diagram showing the differences and the crossovers between
mitigation and adaptation (based on a diagram developed by Highland Adapts) 
6.3 How to adapt 
6.3.1 Key principles for effective adaptation 
The Climate Change Committee has set out ten principles for effective adaptation as
part of the third Independent Assessment of UK Climate Risk (CCRA3) 29. These can
be used to sense check adaptation planning or decision making and to ensure any
initial planning takes big picture adaptation aims into account. 
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Figure 15: Ten Principles for effective adaptation (based on a Climate Change
Committee visualisation from CCRA3 30) 
The ten principles include: 
1. Ensuring that adaptation plans fit the vision for a well-adapted UK and
Scotland. Public bodies can do this by reviewing the SNAP3; identifying the
national adaptation outcomes relevant to them; and contributing towards
those outcomes. 
2. Integrating adaptation into other policy areas and organisational priorities. A
host of organisational priorities and goals will be undermined by the effects of
climate change. Current policies on climate change mitigation and healthcare
for example should be explored to determine where and how adaptation could
be addressed simultaneously, while addressing any co-benefits or trade-offs. 
3. Organisations should be planning for tomorrow’s climate and not today’s.
Public bodies can do this by considering the lifetime of plans, policies,
projects and assets and making decisions based on future warming scenarios
and the public bodies own climate risk assessment.
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4. Adaptation plans should aim to avoid ‘lock-in’. An example of lock-in is
building new homes without designing in adaptations to future conditions
including extreme heat. Retrofitting windows and shutters is around four times
more expensive than including them at design stage. Adaptation plans should
create flexibility within an organisation or body, offering different pathways for
the future and the ability to deal with extreme events and hazards. 
5. Adaptation plans should allow preparation for unpredictable extremes by
increasing flexibility. Undertaking storyline approaches or ‘what if’ scenarios
could be used here, and more headroom could be given to policies and
operations to account for any sudden extreme changes including reaching
climate tipping points. 
6. Interacting risks or ‘compound risks’ such as a heatwave and drought
occurring simultaneously can cause significant challenges when addressing
climate risks. Adaptation planning should consider a range of hazards and
how they may interact. Siloed thinking can pose problems particularly for risks
that interact or those that could lead to cascading impacts that are dealt with
by different groups or departments. This highlights the importance of
collaboration between groups and with a range of stakeholders. Examples of
regional adaptation collaborations include Highland Adapts and Climate
Ready Clyde. 
7. Understanding threshold effects is a key part of an effective adaptation plan.
Bodies should understand what thresholds exist for their critical assets and
services. Risk assessments that look at average changes over time assume
that a risk will gradually increase, so can miss specific points that ‘tip’ the
system or asset into a different state. 
8. Adaptation plans should reduce inequalities and focus on socially just
outcomes. Actions to address climate change could also exacerbate existing
inequalities without careful planning, known as maladaptation. This includes
using the holistic definition of risk as a function of hazard, exposure and
vulnerability. This highlights the importance of understanding where
vulnerabilities lie. Collaborating with community groups and a wide range of
relevant stakeholders can help to address this. Use of participatory tools, such
as the Place Standard with a climate lens and health impact assessments,
can be used to identify and assess differential impacts of adaptation and
policy responses, take steps to maximise health, wellbeing and equity benefits
and minimise harms. 
9. Opportunities should also be considered when creating adaptation plans. This
could relate to, for example, opportunities that come from milder winters as
well as opportunities for heightened collaboration and co-benefits with other
policy areas. This includes integrating mitigation and adaptation policy. 
10. Funding and resourcing are critical to effective adaptation. Knowledge sharing
could help in this regard. In addition, having strong governance and
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accountability in place within a body or organisation is key to be able to
monitor and track progress against relevant indicators. 
6.3.2 Getting started 
The Adaptation Scotland programme provides advice and support to help
organisations, businesses and communities prepare for, and build resilience to,
climate change. 
The Adaptation Capability Framework for the Scottish public sector, developed by
Adaptation Scotland, outlines four capabilities needed for an organisation’s
adaptation journey. It describes 42 tasks to develop these capabilities over four
stages from ‘starting’ to ‘mature’ (table 3). The four capabilities are: 
• understanding the challenge
• organisational culture and resources
• strategy, implementation and monitoring
• working together. 
The Capability Framework is supported by a handbook which contains information
related to each of the tasks. 
Table 3: Adaptation Scotland capability framework 31 
Stage Understandin
g the
challenge
Organisationa
l culture and
resources
Strategy,
implementatio
n and
monitoring
Working
together
Starting UC1A Learn
about
Scotland’s
changing
climate and
impacts 
UC1B Develop
understanding
of climate risk
and
vulnerability 
UC1C Record
and consider
the impact of
recent weather
events on your
organisation
OC1A
Consider how
adaptation fits
with your
organisation's
objectives 
OC1B Identify
resources
already
available for
adaptation 
OC1C Identify
key internal
stakeholders
for adaptation
SIM1A
Consider how
you contribute
to Scotland's
adaptation
outcomes 
SIM1B Identify
existing
adaptation work
within your
organisation 
SIM1C Define
strategic
adaptation
outcomes and
or vision
WT1A Define
your
objectives and
opportunities
for joined
working 
WT1B Identify
relevant
groups,
partnerships
and forum 
WT1B Identify
relevant
groups,
partnerships
and forums
Intermediat
e
UC2A Map out
how your
organisation's
OC2A Engage
with
colleagues to
SIM2A Identify
a range of
potential
WT2A Engage
with relevant
groups,
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functions might
be affected by
climate change 
UC2B
Consider
scenarios for
future climate
change
impacts 
UC2C Engage
with
stakeholders
using
participatory
approaches
optimise
adaptation
opportunities 
OC2B Define
resource
requirements
to plan and
deliver
adaptation 
OC2C
Establish
governance
adaptation
actions 
SIM2B  Identify
plans, policies
and procedures
that can include
climate
adaptation 
SIM2C Deliver
initial
adaptation
actions
partners and
forums 
WT2B Co-
ordinate with
partners to
deliver initial
actions
Advanced UC3A Carry
out climate
change risk
assessment 
UC3B
Integrate
climate
adaptation
knowledge into
internal training
and
procedures 
UC3C Improve
understanding
of stakeholder
needs
OC3A Ensure
key people are
responsible for
adaptation
actions 
OC3B Develop
an investment
plan to
mobilise
resources for
adaptation
SIM3A
Appraise
adaptation
options 
SIM3B Develop
an adaptation
strategy and
action plan 
SIM3C Develop
a monitoring
approach for
achieving your
adaptation
outcomes
WT3A
Formalise
partnership
working 
WT3B
Develop
communicatio
n activities
with partners
Mature UC4A
Undertake
project-level
risk
assessment 
UC4B
Mainstream
climate change
risk
assessment 
UC4C Identify
knowledge
gaps, seek
OC4A Review
and update
governance
arrangements
for adaptation 
OC4B Secure
resources to
plan and
deliver
adaptation
SIM4A
Implement a
programme of
adaptation
actions 
SIM4B Adopt
an adaptive
management
cycle for
adaptation
planning
WT4A  
Enhance long-
term
partnership
working 
WT4B Lead in
networks and
peer
organisations
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expertise and
foster links with
research and
innovation 
The Adaptation Scotland starter pack provides information for bodies who are
beginning their adaptation journey. The starter pack outlines how to begin identifying
what impacts climate change could have on different functions within bodies before
finding links between organisational priorities and adaptation. The starter pack also
provides guidance on how to identify resources and relevant stakeholders. 
The following checklist is based on the ‘starting’ level of the Adaptation Capability
Framework. All public bodies should complete the actions outlined in this checklist. 
Further information relating to each item is provided the sections below. Please refer
to the Adaptation Scotland website for a comprehensive overview and for further
guidance. 
6.3.3 Understanding the challenge 
Under the ‘understanding the challenge’ capability, bodies should start by: 
• learning about Scotland’s changing climate and impacts.
• developing an understanding of climate risk and vulnerability.
Adaptation starter checklist 
Understanding the challenge - public bodies should:
• learn about Scotland’s changing climate and impacts
• develop understanding of climate risk and vulnerability
• record and consider the impact of recent weather events on your
organisation 
Strategy, implementation and monitoring – public bodies should:
• consider how you contribute to Scotland’s adaptation outcomes
• identify existing adaptation work within your organisation
• define strategic adaptation outcomes and or vision 
Organisational culture and resources – public bodies should:
• consider how adaptation fits with their organisation and its objectives
• identify resources available for adaptation 
• identify key internal stakeholders for adaptation 
Working together – public bodies should:
• define your objectives and opportunities for joint working
• join and participate in relevant professional and adaptation networks
• identify relevant groups, partnerships and forums 
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• recording and considering the impact of recent weather events on your
organisation. 
Raising awareness of adaptation and understanding of why it is important within
bodies is the first step to becoming an adaptative organisation. 
The UK Climate Change Risk Assessments (CCRA) reports identify 61 risks and
opportunities from climate change across the UK. Some key risks for Scotland
include the: 
• impact of a changing climate and extreme weather on terrestrial species and
habitats
• cascading failures for infrastructure networks
• the risk of climate change impacts, especially more frequent flooding and
coastal erosion, causing damage to our infrastructure services, including
energy, transport, water and Information and Communication Technologies
(ICT).
• impact of high temperatures on health and wellbeing
• impact of flooding on people, communities and buildings
• impact of flooding on business sites
• coastal businesses impacted by extreme weather, sea level rise, coastal
erosion and flooding
• decreasing yields of food internationally affecting supply 
• impact of vector borne diseases on health 
• international interaction and cascades of named risks.
As a next step, public bodies should, as a minimum: 
 Explore future projected changes in Scotland’s climate, for example using
the Met Office climate data portal. 
 Read the latest Climate Change Risk Assessment (CCRA) national
summary report for Scotland to explore the full list of risks and
opportunities identified for the UK and Scotland. 
 Identify weather events that have impacted their organisation in the past –
the response and an understanding of the impacts of these events could
help to inform the creation of an adaptation strategy. Consider how such
weather events could be different in the future, e.g. more severe or more
frequent. 
 Create a briefing on what climate change is and why adaptation is
important for their body including what the impacts of climate change (and
the risks set out in the CCRA report) could mean for their organisation. 
 Consider investing in training on climate change adaptation and resilience
(or ensuring that any carbon or climate training currently available
includes climate adaptation) to ensure that technical terms and
fundamental concepts of adaptation are understood. 
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6.3.4 Strategy, Implementation and Monitoring 
Under the ‘strategy, implementation and monitoring’ capability, bodies should start
by: 
• considering how they contribute to Scotland’s adaptation outcomes
• identifying existing adaptation work within the body
• defining strategic adaptation outcomes and or a vision. 
Planning and implementation are crucial elements to achieving the long term
challenge of becoming a more adaptive organisation. Adaptation should be
embedded within an organisation’s function and purpose. An important first step is to
identify actions already being taken within an organisation. It is very likely that bodies
are already undertaking adaptation actions, related to flooding responses for
example, even if they are not recognised as such. 
The public sector has a pivotal role to play in building Scotland’s overall climate
resilience by helping to deliver the Scottish National Adaptation Plan (SNAP).
Looking at the bigger picture can help to make the most of opportunities and to
define a public body’s strategic adaptation vision and outcomes. Bodies should
consider how their adaptation actions can contribute to the SNAP outcomes and
objectives.
 Read the UK Health Security Agency (UKHSA) reports on the Health
Effects of Climate Change in the UK to gain a deeper understanding of the
risk to population health posed by climate change, where appropriate.
As a next step, public bodies should, as a minimum: 
 Identify actions that are already delivering adaptation – for each service or
department relevant to the body, provide examples of how it may be
affected by climate change and any existing action, plans or policies that
support adaptation actions in that service or department, and how they
could be strengthened. 
 Read the Scottish National Adaptation Plan and its outcomes and
objectives. 
 Consider how each SNAP objective may be relevant to their body. 
For example, for SNAP3 outcomes:
(C5) Culture and historic environment: Scotland's historic environment is
preparing for a future climate, and the transformational power of culture,
heritage and creativity supports Scotland's adaptation journey. 
Public bodies may have direct responsibilities for looking after the historic
environment, either through buildings or monuments on their own estate
or as part of their wider function; have relevant regulatory powers such as
those related to Planning; or provide funding or other support to the
cultural and creative sectors. 
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6.3.5 Organisational culture and resources 
Under the ‘organisational culture and resources’ capability, bodies should start by: 
• considering how adaptation fits with their organisation and its objectives
• identifying resources available for adaptation 
• identifying key internal stakeholders for adaptation. 
Adaptation strategies and actions can be implemented in a way that benefits from
and influences organisational culture. Adaptation action can be progressed by
reviewing and identifying existing structures, legislative drivers and resources
available. Understanding how adaptation can support the delivery of strategic
objectives, and wider co-benefits for population health, wellbeing, equity and
biodiversity, can help to communicate its relevance and importance. Another
important step is to identify where adaptation is best placed within a body including
what groups, departments or committees will develop and deliver adaptation plans
internally. 
(PS4) Transport system: the transport system is prepared for current and
future impacts of climate change and is safe for all users, reliable for
everyday journeys and resilient to weather-related disruption. 
Public bodies including local authorities, Transport Scotland and the
Regional Transport Partnerships will have direct responsibilities in relation
to this outcome. However other bodies may own or manage land, other
assets or deliver services that could impact on transport systems. For
example, a body may own land at risk of landslides that, should a
landslide occur after a heavy rainfall event, would block a road. Or, a body
may own land higher up a river catchment area where a change in land
use could help prevent flooding and related road and rail closures
downstream. 
(B1) Increasing business understanding of climate risks and adaptation
action: businesses understand the risks posed by climate change and are
supported to embed climate risks into governance, investment, and
operations, and are collaborating on effective adaptation action. 
While the enterprise agencies could be seen as the bodies with the most
direct responsibility, all public bodies will work with businesses in some
way and can use their influence to contribute to this outcome. For
example, bodies including local authorities may provide grants or other
funding to businesses in their area and could include aspects related to
climate risk and governance in the funding conditions. All public bodies
will procure goods and services, and could use procurement exercises to
further progress towards this outcome. Bodies can also work to influence
members of adaptation partnerships they are part of, and to encourage
businesses they work with, where appropriate, to join such partnerships. 
Bodies should consider their contribution to the outcomes in a broad way.
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As a next step, public bodies should, as a minimum: 
 Consider what motivated their organisation to address climate adaptation.
Some common triggers for taking action on adaptation are: 
o developing and reviewing your local climate risk assessment
o providing support for service area reports and business case
development
o impacts of an extreme weather event (e.g. a flood or heatwave) on
operations, services, finances, health or safety
o increasing resilience to disruption to services from extreme weather
o ethics and public expectations
o statutory duties
o investing money to save in the future
o avoiding future liability
o making decisions about the resilience of long-term assets (e.g.
infrastructure or land use or land management practices). 
 Consider what their organisation wants to achieve with their adaptation
plan or strategy. For example: 
o a more climate resilient local area
o robust reporting for service areas
o an updated risk register
o greater protection of properties against flooding or reduced
vulnerability of care homes to extreme heat events
o cost savings for responding to severe weather events
o realise population health, wellbeing and equity benefits and
contribute to multiple social outcomes including National Outcomes
and the UN SDGs. 
 Consider how climate change may impact their organisation’s strategic
priorities. 
 Consider what the risk appetite of their organisation is. For example, does
their organisational policy specify what acceptable and unacceptable risk
is? How does this change for different assets or services (including critical
assets and services)? 
 Work with their risk manager or appropriate team or department to
understand any existing approaches to managing weather and climate
related risks. 
 Consider if there are groups, committees or partnerships within their
organisation who could be involved in adaptation work. 
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6.3.6 Working together 
Under the ‘working together’ capability bodies should start by: 
• defining their objectives and opportunities for joint working
• joining and participating in relevant professional and adaptation networks
• identifying relevant groups, partnerships and forums 
Collaboration is a critical element of adaptation planning and implementation. No
organisation can adapt alone. By joining networks bodies can share knowledge and
learning from other groups. Delivering adaptation actions often requires partners
working in a collaborative relationship. This includes within and outwith their own
organisation, working with community groups or community planning partnerships for
example. There are already networks and groups that bodies could consider joining.   
6.3.7 Overcoming adaptation challenges 
Acknowledging any potential barriers or constraints from the outset is an important
step in developing an adaptation plan. These can also then be incorporated into
monitoring and review processes. How these barriers can be minimised should also
be considered as well as how to maximise the relevant drivers to adaptation. 
Some common drivers of adaptation include: 
• increased awareness in an organisation after an extreme weather event such
as a flood or heatwave event
• leadership
• societal pressure from local or national groups or campaigns
• need to comply with statutory guidance or legislation 
• need to ensure delivery of services. 
Some common barriers or constraints include: 
As a next step, public bodies should, as a minimum: 
 Identify existing groups, partnerships or forums that they could join or
collaborate with. Consider their aims, existing adaptation links or on-going
work and potential future adaptation links with their own organisation. 
Some groups to consider include: 
o Community Planning Partnerships
o Community climate hubs and community action networks 
o Local plan district groups
o Regional climate adaptation and resilience initiatives, such as those
listed on the Adaptation Scotland website. 
 Join relevant professional adaptation networks. Some examples include: 
o Sustainable Scotland Network 
o Public Sector Climate Adaptation Network 
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• lack of buy-in or scepticism from senior leaders and or colleagues
• lack of awareness in organisations
• lack of skills and knowledge of adaptation 
• coordinating resourcing (time pressures and competing priorities)
• a focus on short-termism 
• a focus on mitigation – the importance of adaptation not being recognised
• siloed policy making – climate adaptation is a complex problem and there are
challenges to taking a whole systems approach. 
6.4 Going further: beyond the basics 
This section aims to provide more technical guidance on adaptation planning and
compliance with the core duty to contribute to the Scottish National Adaptation Plan
and reporting on progress. 
It covers a whole systems approach to understanding climate risk. 
It is intended to support organisations that may have a greater role in adaptation or
greater needs owing to:
• infrastructure
• land and natural resource management
• complex operations subject to multiple interdependencies
• multiple sites across Scotland 
• critical functions such as health, social care, education, emergency services
provision or defence.
It is important to note that public bodies may be starting their adaptation journey in
some capabilities, but might be more mature in others. Therefore, this guidance is
likely be useful wherever public bodies are on their journey. 
Public bodies should take responsibility to ensure understanding of the challenges of
climate change, their role in providing solutions, and in leading the way with action to
support an adapting and resilient Scotland. Public bodies should be engaging,
As a next step, public bodies should, as a minimum: 
 Consider what their organisation’s drivers and potential barriers or
constraints are. 
 Consider how their adaptation planning can minimise barriers and or
maximise drivers. For example, training on climate change adaptation
and mapping their organisation’s priorities to climate change impacts
could help colleagues and senior leaders to understand the need for
adaptation action. 
 Share the Leaders’ Climate Emergency checklist with senior leaders
which outlines the requirement for action on climate adaptation. 
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collaborating and leading beyond their boundaries to reduce risks, protect the natural
and built environments, communities and organisational staff. 
All public bodies have a vital role in influencing, supporting, and taking adaptation
action, internally and across whole systems, beyond their organisational boundaries,
regardless of land ownership, scope or size. 
6.4.1 A whole systems approach to understanding climate risk 
The effects of climate change influence many complex relationships within
organisations, places and ecosystems. Climate hazards affect population health,
health, wellbeing and equity as a consequence of the impact on natural and human
systems including physical infrastructure, emergency management, supply chains,
economic vitality, and many social issues. 
When trying to understand climate change risk and vulnerability, particularly when
the scale of assessment is beyond project level, it can often be simpler to break the
hazards and risks into smaller segments. It helps to take the colossal, complex
problem of a changing climate, and simplify it into more manageable parts, providing
an easier route to tangible actions for adaptation. 
However, viewing climate risk in segments negates the bigger picture: public sector
bodies cannot understand the full risk profile if they do not bring the segmented parts
back together, view them as a whole, and consider how they behave in a wider
context. Climate hazards are and will occur and interact simultaneously, increasing a
likelihood of cascading risks – a chain reaction of events set off by an initial hazard.
Understanding and preparing for diverse cascading events is crucial as these
interconnected sequences can escalate the complexity and severity of subsequent
risks, posing challenges to effective response and ongoing adaptation efforts. 
Consequently, public bodies’ vulnerability and responses will be shaped not only by
changing socio-economic and demographic factors but also by increased probability
of cascading risks. To decrease the risk and reduce the adverse effects of cascading
hazards, public bodies should ensure they explore both a range of possible future
climate scenarios and socio-economic context. 
Cascading risks in the context of disaster and adaptation involve a chain
reaction of events set off by an initial hazard. Examples include physical
cascades, where one event leads to another (e.g. heavy rainfall leading to river
overflow which in turn could trigger landslides, dam failures and local flooding)
and social cascades where societal responses amplify risks (e.g. panic
worsening evacuation efforts, overwhelming emergency services and hindering
an effective response). These interconnected events highlight the need for
comprehensive adaptation strategies that address both the primary hazard and
its potential cascading impacts. In the context of adaptation understanding and
preparing for these diverse cascading events, both natural and societal, is crucial
for effective disaster management and recovery. 
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What is needed is a systems approach - an approach that requires organisations to
think holistically, and beyond of their own organisation and sector, to the wider place
and context they are situated in; how the actions they do or do not take may impact
the whole system. 
A systems approach helps to consider interactions between different parts of the
system, related uncertainties, and how these can combine to affect an outcome. A
clearer understanding of the entirety of the system will enable the identification of the
multiple intervention points required to minimise risk, build resilience, and adapt to
the future climate. 
Of course, there will be actions and activities that public bodies can control and
deliver independently, and they should act on these, but there will be areas of
adaptation that require collaboration due to interlinking dependencies. Intervention in
one part of the system will impact on other areas of the system, and could impact on
multiple outcomes with potential unintended consequences because of the
complexity and interdependencies. 
Through working in partnership, public bodies will ensure they take a just and
inclusive approach to adaptation. By ensuring adaptation plans are built on
inclusivity, equity, resilience, and shared responsibility, this minimises disparities and
the likelihood of maladaptation and unintended consequences. It also ensures that
responses deliver multiple benefits through adaptation for nature, biodiversity,
business, equality, and public health. 
Whole systems thinking also supports place based approaches to climate change,
inclusive of and beyond the scope of adaptation. Public bodies should, where
appropriate, link in with relevant policy frameworks, for example the National
Planning Framework, Local Development Plans and national sectors (e.g. water,
energy, transport, health). 
Example: A local authority may be concerned over public water supply
availability for their community during periods of drought. They may reach out to
Scottish Water to get a better understanding of risk in their area, who in turn may
offer to work in partnership to ensure decisions the local authority makes are not
causing further future ‘lock-in’, increasing vulnerabilities to this risk. They may
also engage with local landowners who have a part to play to ensure our natural
landscape supports public water supply. The local authority may also look to
engage and work in partnership with a wide range of community groups, and
education establishments to ensure education about water usage is on the
agenda in an accessible format for all.
Public bodies should seek to understand the whole system in which they operate
and should proactively nurture opportunities to collaborate to deliver adaptation
and wider multiple benefits in partnership, in addition to reducing risk.
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6.4.2 Climate change risk assessments: best practice 
Risk is considered as the interaction between a hazard or weather event,
exposure and vulnerability. It can be defined as the potential for adverse effects
on human health, ecosystems, economies and societies resulting from the
interactions between climate related hazards (such as extreme weather events,
sea level rise and temperature changes) and the vulnerability and exposure of a
specific region or system. 
Hazard refers to a specific climate related event or phenomenon with the
potential to cause harm or adverse impacts on the environment, human health,
economies or societies. Hazards associated with climate change include extreme
weather events (hurricanes, floods, droughts and heatwaves) sea level rise,
changes in precipitation patterns and shifts in temperature. 
Exposure refers to the degree to which a system (such as a human population
or ecosystem) or asset is subjected to climate related hazards. Exposure is
highly context specific and is influenced by various factors including geographic
location, land use or land management practices, infrastructure and socio-
economic conditions. It encompasses not only the physical hazard posed by the
changing climate but also considers factors such as safety or mitigating
measures that may be in place, societal vulnerabilities and governance. 
Vulnerability is the extent to which a society, economy or ecosystem is at risk of
adverse impacts from climate related hazards. This concept focuses not only on
physical exposure to climate driven events but considers socio-economic factors
like poverty, inequality and access to resources. It also considers the system's
capacity to recover and adapt following climate related events. 
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Figure 16: Simplified risk framework showing risk as a function of hazards,
exposure and vulnerability (adapted from IPCC 32) 
6.4.3 Why assessing vulnerability is important 
Due to existing societal inequalities, certain communities or groups experience
climate change impacts disproportionately. Vulnerability can be the result of
marginality and lack of access to resources that can be exacerbated by a hazard. 
The concept of intersectionality – multiple and compounding inequalities – is highly
relevant to the assessment of vulnerability to climate change. Climate change and
social, economic and personal factors (such as gender, race, income, age and
health status) can act together as risk multipliers, increasing the impacts on health,
and health and other inequalities 33.  Taking an intersectional approach can identify
and highlight the lived experiences of people with intersecting identities, and help to
develop policies, plans and services that address structural inequalities 34. 
For example, green spaces can provide shade during heatwaves and can help with
rainfall run-off, and these tend to be found in higher-income areas. A study on Wales
and England showed that new homes built in economically deprived areas between
2008 and 2018 are more likely to become exposed to high flooding risk as opposed
to new housing situated in higher income areas 35. This vulnerability often arises
from challenges such as limited ability to secure property insurance and difficulties in
evacuating during floods. In addition, elderly people and those with underlying health
conditions can be disproportionately impacted by heatwaves, for example. The heat
throughout summer 2022 has been estimated to have led to the death of
approximately 60,000 people in Europe and around 3500 in the UK 36. 
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Any adaptation plan or policy should address inequalities in the first place and
embed fairness by acknowledging that different groups and communities will be
impacted by hazards and weather extremes differently. The Scottish Government’s
Equalities and Fairer Scotland Duty impact assessment may contain research to aid
considerations. Further guidance on equalities is provided in chapter 3. 
6.4.4 Climate change scenario analysis 
Further changes in the climate by 2050 are inevitable as the world will take several
decades, at the very least, to reach net zero emissions. But longer-term (post-2050),
changes in the UK’s climate will largely depend on how rapidly global emissions are
reduced 37. Climate scenario analysis can help address this future uncertainty. 
Current policies in place around the world put the world on track for a central
estimate of 1.8 to 3.5°C above preindustrial levels by 2100, with uncertainty due to
the climate response to greenhouse gas emissions meaning that global average
surface temperatures of in excess of 3.5°C by 2100 are still a possibility. Warming
reaching 4ºC above preindustrial levels by 2100 remains at the upper end of
possible outcomes 38. 
In Scotland, temperature rises of up to 2°C would bring warmer temperatures in all
seasons, drier summers and wetter winters, more extreme weather events and sea
level rise. However, a more sluggish jet stream could periodically lead to prolonged
cold winters as well as hot summers. These trends will be felt to a greater or lesser
extent across different localities, and the change will not be steady, linear or gradual.
These changes will have different impacts for different sectors and places, which
means public bodies should understand, plan for and adapt to these changes
urgently. By understanding the risks associated with climate change public bodies
can integrate these into internal systems and procedures and make informed
decisions based on actual or expected changes. 
In addition to considering all of the parts of the system that could be impacted by
climate change, it is also important to assess risk in varied possible future climate
scenarios. Scottish Government has committed to developing a climate scenario
decision tool to support the public sector. As an initial step, research has been
commissioned via ClimateXChange (CXC) on ‘Future climate in today’s decision-
making’. This research is due to be published by spring 2025. 
While Scottish Government considers the CXC research and development of a
decision tool, this guidance recommends that public bodies should seek to
understand what a 2°C and 4°C scenario will mean for organisational climate
risk at multiple points in the future (e.g. 2050s and 2080s), apply these findings
to adaptation plans, and where possible make publicly available what climate
futures they are planning for. Where applicable, they should also utilise projections
for socio-demographics of the population, as this will influence who is impacted by
the changing climate, and how.  
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Public bodies should be clear on the climate change pathways and scenarios, and
the risks and implications for their services that they have considered as part of their
adaptation planning. 
It is important to consider possible interdependencies when conducting a climate
change risk assessment, to ensure possible impacts to the organisation are fully
sighted, in addition to the impacts extending beyond the body’s boundaries. 
Example:  A land manager is planning the next iteration of a local land
management plan, and they are looking to see how climate change will impact
the landscape in addition to infrastructure in the area. They have a bridge in the
area that is due for maintenance in 2027, and land that is due for commercial
timber replanting now that will stand for the next 60 years and is a very important
asset. 
They choose to look at 2°C and 4°C climate scenarios for the years 2050, 2080
and 2100 to assess the climate risks and vulnerabilities. They decide to replant
this area of forest in a way that is resilient under a 3 to 4°C warming scenario as
the trees will be standing beyond 2080. This includes consideration of the
changing growing conditions, water availability, the changing risks from pests
and diseases and the species mix. They decide not to take immediate action on
adapting the bridge as, short term, the climate scenarios suggest limited damage
that can be tolerated. However, they plan to adapt the bridge at the next
maintenance cycle to futureproof it and save on resources. 
They plan out future decision review points in line with climate risk assessment
review points and ad hoc reviews as new developments come forward from
climate science and review bodies, like the Met Office, Climate Change
Committee and IPCC. They also agree to review should experience suggest that
they may not have gone far enough in their adaptation measures, for example if
they see a more rapid change in flooding frequency or severity. 
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Figure 17: Interdependencies between climate impacts and key services 
Public bodies should consider what the wider impacts to Scotland are from climate-
related incidents occurring on their land or within their boundaries and should seek to
work in partnership with other stakeholders to progress adaptation in these areas.
Disruption to core infrastructure and services have a significant impact on health,
wellbeing and equity, for example people being unable to access work, education,
food, social support, health and social care. 
If, for example, a public body manages assets, land or infrastructure that runs along
a water course that is at risk of flooding, it is expected that consideration is given to
the potential upstream and downstream impacts, and the consequences arising from
decisions made within the organisation’s management area. However, this is not to
say that it is the responsibility of that organisation to mitigate upstream and
downstream risk in isolation – partnership working is required. 
Public bodies should consider the knock-on consequences of emission reduction
strategies on adaptation efforts, e.g. considerations to decarbonise buildings or
restore peatland should also include considerations around future climate scenarios,
risk and vulnerabilities. 
Public bodies should consider the wider (or interdependent) risks arising from
climate change, for example vulnerabilities to power supplies, communications,
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transport, or supply chains for critical materials and components, and how they might
increase resilience where appropriate. 
It is considered best practice for public bodies to make organisational climate risks
publicly available, and where applicable for relevant public bodies, provide a link to
where they can be found in their annual report under the mandatory reporting duty. 
The Adaptation Scotland programme has developed guidance and tools to support
organisations in undertaking climate change risk assessments. They have also
developed guidance to help identify climate hazards in the workplace, which are
essential to be sighted on in order to protect staff in a changing climate. Local
Partnerships have also developed a climate adaptation toolkit and climate risk and
opportunities matrix template. 
Public bodies should review climate risks in line with relevant organisational and
business planning cycles, SNAP cycles or where new climate risk data becomes
available, where proportionate. 
Additional tips for carrying out a climate change risk assessment can be found
below. 
6.4.5 Tips for carrying out a climate change risk assessment 
Engagement and collaboration
• Even if there is a lead person or team conducting the risk assessment, be
sure to involve stakeholders from across the business to test thinking,
particularly for indirect risks and knock-on impacts
• Ensure early engagement with key stakeholders to ensure there is meaningful
participation in the process.
• Where appropriate, involve external parties and communities in the risk
assessment. This will help to get a clearer picture of how hazards play out
across a system and what interdependencies exist. Think about how
stakeholders are identified, whose interests they represent, and encourage
diverse views and experiences.
• Within an information governance framework, share data between
organisations as far as possible, particularly where there is cross-over or
similarities in place, sector, etc. This greatly reduces duplication of resources,
data, and effort and fosters collaboration. 
Data
• Decide early on if the risk assessment will be data-informed or data-led based
on the needs of the organisation. This will have an impact on certainty levels
and the time required, amongst other factors.
• Don’t consider hazards in isolation: there will often be instances where
multiple hazards coincide and exacerbate vulnerabilities, e.g. high wind gusts
may coincide with flooding.
• Consider worst case scenarios, socio-economic factors, population health
profiles and tipping points to create a full picture of potential risks and what
impacts the organisation may face in these scenarios. This could work well as
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a workshop with a variety of stakeholders to ensure interdependencies,
differing viewpoints and expertise are considered.
• Ensure current risk is assessed and how recent weather events have
impacted the organisation, people and systems.
• Ensure data is from credible sources, particularly narrative data. Make use of
sector and subject experts and reports they may have issued to bolster
numerical data and climate projections.
• Plan future re-evaluation points. 
Useful data sources:
• Met Office Climate data Portal and Local Authority Climate Service
• Local Climate Adaptation Tool (LCAT)
• Met Office UKCP18 products
• National Trust's Hazard Mapping Tool
• National summaries (CCRA3-IA) - UK Climate Risk
• Datasets - British Geological Survey (bgs.ac.uk)
• Climate Risk Indicators (uk-cri.org)
• UK Climate Risk
• Sixth Assessment Report — IPCC
• ForestGALES - Forest Research
• Welcome to the Climate Change Hub - Forest Research
• Flood maps | Scottish Environment Protection Agency (SEPA)
• Adaptation Scotland :: Climate Trend tool
• Independent-Assessment-of-UK-Climate-Risk-Advice-to-Govt-for-CCRA3-
CCC.pdf (theccc.org.uk)
• Population or community health profiles (see Home – ScotPHO) 
Structure and presentation
• If the organisation exists across different parts of Scotland, the UK, or the
world, consider carrying out a whole organisation climate risk assessment, in
addition to more local or business area risk assessments. This allows for a
clearer understanding of the differences in risk across the business and
therefore the change in potential priorities for different areas of the business.
• Consider who will be using this data. What considerations would be helpful for
them? How can results be displayed in a usable format to ensure the
outcomes are included easily in future planning. For example, a land-based
organisation who relies on maps and spatial data might try and display the
results spatially or in a manner that can be integrated with current
mechanisms for planning. 
Communication and buy-in
• Ensure outputs are communicated in easy to understand and meaningful
ways for stakeholders. The information gathered needs to be usable across
the organisation and so should appeal to different audiences. Consider
accessibility requirements, in particular for versions designed for the general
public.
• Consider providing headline summaries for different areas of the organisation
to ensure they can understand the key messages for their business area.
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• Keep communications engaging – risk may not be the most exciting subject
for everyone.
• Ensure senior leaders are well versed on the main risk areas so they can
communicate these to their teams.
• Ensure there are relevant risk owners that are across the organisation.
Ownership of climate risk should not only fall to climate change or
environmental management professionals, as the whole business plays a part
in adaptation.
• Ensure climate risks are included in or inform the organisational risk registers. 
6.4.6 Adaptation strategy and planning 
6.4.6.1 Developing a strategic approach to adaptation planning 
Public bodies’ risk assessment outcomes are part of the foundation to developing an
adaptation strategy and action plan. Adaptation is a long term, movable challenge
that requires strategic, flexible, implementation and planning to achieve outcomes. 
Developing an adaptation strategy and plan is not an exercise for individual staff
members to do in isolation. To ensure an adaptation strategy and plan are holistic
and inclusive, there is a need for bottom-up approaches. Public bodies should
assess which parts of the organisation might be impacted by climate hazards, who
might feed into strategies and plans, and who might be key to delivering adaptation. 
Adaptation strategies should set out what future scenario the public body is planning
for and why. It should contain flexibility to allow movement between shifting
scenarios and should lay out residual risks, i.e. acknowledgement of risks associated
with tipping points and uncertainty. 
Public bodies should consider how their adaptation strategy fits in within the wider
policy and adaptation strategy framework. Linkages should be made with strategy
areas such as the Climate Change Plan, Economic Strategy, National Flood
Resilience Strategy, Biodiversity Strategy, and Scotland’s National Adaptation Plan
(SNAP). If public bodies are a named delivery partner in SNAP, these deliverables
must be included in a public body’s adaptation strategy. 
The following is a guide to considerations public bodies should make while
developing their adaptation strategy and plan: 
Set the framework
• Consider scenario planning or an adaptation pathways approach. Considering
incremental changes allows the organisation to take the appropriate action for
the relevant timescale. If a tree is planted now that takes 60 years to mature,
one should ensure that consideration is given to the future climate it will exist
in, and factor these into current decisions. It is important to remain flexible
with adaptation pathways to ensure the organisation can be reactive to
changes in circumstances or science.
• Be explicit and transparent in your assumptions and basis for decision
making.
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• Consider the asset type and the maintenance or replacement cycles. Is it a
one off or are there going to be opportunities to adapt further in the future?
For example, if you know you are building a bridge now but will be replacing it
in 2070, you perhaps don’t need to ensure it is fully adapted to a 2070 future;
however you may still want to build in some flexibility.
• What is the expected lifetime or timescale you expect the adaptation to be
effective over?  
• Build in future check points to interrogate how real-time events are playing out
against scenarios and utilise adaptive approaches.
• Demonstrate the scale of the transition challenge.
• Establish thresholds for key risk areas that show when vulnerabilities increase
and when adaptation action is required.
• Develop response plans for reacting to current and future climate hazards.
• Develop contingency plans for catastrophic events in your organisation. 
Whole systems approach
• Explore stacked hazards and risks and consider worst case scenarios and
extremes in climate hazards.
• Adaptation, mitigation, and nature restoration goals all need to speak to each
other: be aware of potential conflicts in decision making and planning.
• Consider your organisational position in a wider context – what systems are
you part of? Will your adaptation plans impact others? Consider testing plans
with external stakeholders to ensure cohesive, place-based action is taken.
• Are you dependent on others internally or externally to take the required
action?
• Identify elements or pressures in the system which are working against the
overall strategy, plan, or goal. Consider these along with the points of greatest
leverage where interventions will make most difference.
• Consider opportunities for additional benefits such as improved public health
or biodiversity.
• Resilient systems build in diversity, complexity, connectivity, redundancy and
flexibility. Ensure these are held at the foundations of your strategy.
• To avoid maladaptation, you need to explore bottom-up approaches to
adaptation, and assess potential unintended consequences of interventions.
Interventions may impact differently on different population sub-groups.
• Incorporation of bottom-up approaches into core documents is instrumental. It
sets the tone for potential projects, emphasising inclusivity, equity and shared
responsibility. When communities and stakeholders perceive adaptation
projects as just and fair, it diminishes the likelihood of maladaptation and
resistance. 
Implementation
• Make use of maintenance windows to implement adaptation action. Ensure
flexibility and modularity is built in and lock-in is avoided.
• Consider ‘Theory of Change’ in your approach to Implementation and or
implement a change process that includes interim goals that you can more
easily monitor.
• Ensure consideration is given to cultural, behavioural and social factors that
may act as a lever or barrier to change.
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• Ensure people from across the organisation are involved in the strategy and
planning stages to ensure buy-in and ownership.
• Consider what information is required to inform important future decisions and
make it available and understandable.
• Prioritise actions and align outcomes. Taking a whole systems approach
should allow delivery of multiple outcomes and sharing resources. 
• Ensure financial planning is carried out and supports your action plan. Explore
mechanisms for financing your plan. Sniffer has developed guidance and
case studies on financing adaptation through the Adaptation Scotland
programme. 
• Communicate good news stories and share best practice to increase
organisational knowledge, buy-in and ownership.
• Integrate robust mechanisms to evaluate the potential consequences of
adaptation initiatives. This approach decreases the risk of maladaptation and
ensures that strategies are not only well intentioned but also effectively
executed, benefitting both the environment and communities. Prioritising the
needs of communities, rather than imposing projects upon them, will ensure
more effective and equitable outcomes. 
Monitoring and reporting
• Consider how you will assess whether adaptions efforts are matching the
adaptation plan and the requirements.
• Build in future check points to interrogate how real-time events are playing out
against scenarios and utilise adaptive approaches.
• Understand what data you need to show the link between service
performance, how climate change impacts that, and how successful
adaptation actions are in maintaining service levels.
• Develop a mechanism for keeping tabs on adaptation action across the
organisation, and how these align with SNAP3 – this will make reporting
easier.
• Where possible gather data on money spent in responding to climate related
incidents (e.g., floods, landslip) to gather more intelligence for business cases
on adaptation and financing them. This can be compared to the cost of
implementing adaptation measures. Further guidance and case studies on
business case development and economic models for adaptation
interventions can be found on the Adaptation Scotland website.   
A Monitoring and Evaluation framework was published alongside SNAP3. When
assessing how best to monitor their adaptation action, bodies may find it helpful
to look at the national monitoring indicators, and consider whether these could
also be useful at local or organisational level, in an adapted form. 
For example (these are intended to be illustrative only and are not exhaustive): 
(C5) Culture and historic environment: Scotland's historic environment is
preparing for a future climate, and the transformational power of culture,
heritage and creativity supports Scotland's adaptation journey.
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Options appraisal
Deciding what adaptation actions to take can be overwhelming, particularly with the
uncertainties of future projections. However, it is important not to succumb to
decision paralysis. 
In order to make informed decisions about what adaptation actions will be included in
adaptation plans, public bodies may consider carrying out an options appraisal.
Below is some guidance on considerations to make during an options appraisal: 
• Select assessment criteria relevant for your organisation: these will depend on
your organisational context and situation. Potential factors to assess against
include:
Example organisational indicators for a public body that owns historic
buildings as part of its estate (e.g. a body may own traditional listed
buildings in a city centre):
• Proportion of historic buildings which have been climate risk
assessed
• Proportion of historic buildings for which a site-specific
adaptation plan has been developed. 
(PS4) Transport system: the transport system is prepared for current and
future impacts of climate change and is safe for all users, reliable for
everyday journeys and resilient to weather-related disruption. 
Example organisational indicators for a local authority responsible for
maintaining the road network (excluding trunk roads and infrastructure
under the responsibility of Transport Scotland):
• Proportion of A roads which require close monitoring
• Proportion of B roads which require close monitoring
• Proportion of A roads which may require maintenance
• Proportion of B roads which may require maintenance
• Proportion of road bridges which have been climate risk
assessed
• Proportion of road bridges which may require maintenance. 
(B1) Increasing business understanding of climate risks and adaptation
action: businesses understand the risks posed by climate change and are
supported to embed climate risks into governance, investment, and
operations, and are collaborating on effective adaptation action. 
Example organisational indicators for a public body that awards grant
funding to businesses:
• Proportion of businesses in receipt of grant funding monitoring
climate related risks
• Proportion of businesses in receipt of grant funding reporting
taking action to adapt to the effects of climate change.
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o Resource availability – are there sufficient human, financial or physical
resources for this option to be undertaken?
o Organisational feasibility – how likely is it that the option would be
supported and successfully implemented in your organisation? To what
extent does it align with wider organisational priorities or objectives?
o Efficiency – how effectively will the option address climate impacts
o Costs – what are the up-front costs, upkeep and maintenance costs
and are there are non-economic (i.e., social and/or environmental)
costs?
o Co-benefits – Are there wider, additional health and wellbeing, equity,
social, economic, and environmental benefits or mitigation benefits?
o Decision scale – can your organisation make or implement this option,
or would it require buy in from other organisations or higher level of
governance or decision making?
o Level of risk– is it low regret, no regret or win-win?
o Flexibility – can you alter the action in light of new information?
o Timing or urgency – would the option be best implemented now or in
the future?
o Climate Justice – how does the option affect vulnerable groups or
individuals?
o Unintended Consequences – what knock on implication might this
action have?
• This may require hosting a workshop or meeting to bring together relevant
department heads or key decision makers to get their feedback.
• If appropriate, use decision support tools, such as:
o Economic appraisals
o Cost benefit analysis
o Cost effectiveness analysis
o Multi criteria decision analysis
o Adaptation pathways assessment
More detailed guidance can be found in The Green Book: Central Government
Guidance on Options and Appraisal and the supplementary business case guidance
for projects and programmes. 
It is important to remember that there is no final state to adaptation. Once strategies
and plans are complete and action has been taken, this does not signify the end of
the journey. Public bodies will need to periodically review strategies, plans, actions,
and capabilities to ensure climate adaptation and resilience is maintained. 
6.4.6.2 Financial planning for adaptation 
In order to deliver value-for-money spending and reduce future losses resulting from
climate change it is important that public bodies consider climate risks as part of
long-term financial planning. 
The cost of damages resulting from climate impacts are significant. Public bodies
should firstly seek to understand potential costs associated with climate impacts on
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their organisation. The Climate Change Committee’s Monetary Valuation of Risks
and Opportunities in CCRA3 offers details on the costs of climate change impacts.
The Scottish Fiscal Commission’s Fiscal Sustainability Perspectives: Climate
Change report may also be of help. 
With the impacts of climate change already felt, the cost to maintain current service
levels are increasing. Public bodies delivering essential services should develop an
understanding of their baseline service levels, the impacts climate change will have
on these and the investment required to maintain current service levels in the
changing climate. It is advised however, that all public bodies should consider this. 
Public sector example: 
Scottish Water - Sustaining services in a changing climate 
Adapting infrastructure to cope with the challenges of climate change is a
complex issue with infrastructure. Scottish Water is considering the implications
of climate change in terms of the level of services provided by its infrastructure
today, and the way in which this will be impacted by climate change over the next
25 years. This covers issues such as the hydraulic capacity of its networks, the
balance between water resources and customer demand, and the increased risk
to the integrity of its assets. 
This enables Scottish Water to get a perspective on the adaptation requirements
and costs to sustain today’s level of service in a climate change future. This is
important to enable the financial impact of climate change to be reflected in
strategic investment planning.  A simple model of this approach is shown below
in figure 18. 
Figure 18:  Adaptation investment to sustain existing service levels 
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The Climate Change Committee have outlined an additional investment need
(across public and private sources) of £10 billion per year this decade to help
improve the UK’s preparedness for climate change 39. Increased investment will be
needed to respond to climate impacts and public bodies should engage in
preventative spend, whereby there is a recognition that early, preventative spend will
save money in the longer term. Early, preventative spend in adaptation has been
shown to save money in the longer term – with benefit-cost ratios ranging from 2:1 to
10:1, i.e., every £1 invested in adaptation could result in £2 to £10 in net economic
benefits 40. 
To support the mobilisation of additional resources, public sector organisations
should develop an investment plan for climate adaptation, which develops a strong
business case for their selected adaptation actions and the funding options. 
Adaptation Scotland have developed a Guide to Climate Adaptation Finance, which
identifies current barriers to adaptation finance, and aims to support development of
the knowledge and skills needed to successfully finance adaptation projects in
Scotland. This guide will be helpful to public bodies who are looking to assess
financing options for climate adaptation related projects. 
The Green Book: Central Government Guidance on Options and Appraisal and the
supplementary business case guidance for projects and programmes can support in
undertaking value for money appraisals which account for climate change. The
CCC’s Investment for a well-adapted UK report may aid in conversations around
adaptation investment needs and support business cases. 
6.4.7 Culture, governance and mainstreaming climate change adaptation 
To ensure adaptation plans are implemented and the organisation is making
progress with adaptation, it will need to align with organisational priorities, culture,
and resources. Adaptation and climate considerations should be mainstreamed into
procedures, investment decisions, plans, and policies. Adaptation considerations
should become as standardised as operational or financial considerations.
Adaptation should not be viewed as an add-on or a tick box exercise. Adaptation is
about taking action now to future proof Scotland, and to respond to existing climate
change challenges. 
Successful climate adaptation needs:
• strong leadership: this is needed from senior leaders to help prioritise and
accelerate adaptation, but it is also needed from key stakeholders across the
An example of this in practice is the service implications of more water pipe
bursts.  Scottish Water has identified a risk that there will be more bursts in the
network in the future as soil moisture levels change, the ground moves and more
bursts occur.  If the rate of mains repair and rehabilitation is not increased there
will be a deterioration in service and more customers may be at risk of service
interruptions. It is possible using this approach to estimate how much Scottish
Water may need to spend in the future to sustain today’s service levels. 
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organisation, people who can act as “adaptation champions” in their business
area
• governance structures to support adaptation: adaptation should fit into
pre-existing organisational governance structures, but it is also helpful to set a
clear structure for making decisions and providing assurance around
adaptation
• committed resources: an organisation needs financial, human, physical and
knowledge building resources committed to adaptation. These will likely be
both internal and external
• flexibility and reflection: organisations should be continuously learning from
previous experiences to help improve and adjust strategies, plans and actions
and flexibility should be built into these to deal with changes and uncertainty.
Senior leadership in public bodies should prioritise and accelerate adaptation in their
organisation, and should complete the Leaders’ Climate Emergency Checklist. 
Public bodies should explore where adaptation considerations fit into existing
governance structures (e.g., risk and assurance, investment planning, business case
approvals, business planning, etc.) and establish governance arrangements for
adaptation. 
When adaptation is seen as an add on, or where the wider organisation is not
supportive of adapting to climate change, it can be difficult to know where to begin to
gain buy-in and to commit resources to adaptation. 
The sections below offer points for consideration on how public bodies might seek to
nurture their organisation’s culture to promote adaptation, identify and commit
resources, gain buy-in and mainstream adaptation in business policies and
processes. 
Communicate climate adaptation and gain buy-in
• Take advantage of opportunities that arise from policy or legislation drivers,
such as new regulations, mandates, or targets to incorporate adaptation.
• Use new publication of the Climate Change Committee’s Adaptation Progress
Reports and Climate Change Risk Assessments to offer key windows of
opportunity to argue for advance adaptation planning
• Use formal and informal meetings, events, and workshops to engage widely
across your organisation and with external stakeholders including suppliers,
community planning partners and the public on the topic of and importance of
adaptation. This includes everything from informal one to one discussions
through to more formal presentations and awareness raising workshops.
• Consider using alternative phrases to communicate adaptation in a way that is
meaningful to different stakeholders: e.g., business continuity in a changing
climate, flood risk management, futureproofing, sustainable development, risk
minimisation, climate justice etc.
• Start by selecting one or two relevant policy areas and identify how existing
adaptation policy hooks could be used to strengthen your organisations
approach to adaptation. Look for hooks such as business continuity, flood risk
management, sustainable procurement, risk prevention.
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• Use the Adaptation Scotland programme and Climate Outreach’s values
based guide to communication to find out about communicating adaptation
and research the best approach for your stakeholders. If you communicate
with stakeholders in a way that is meaningful for them, they are more likely to
make time for discussions around it.
• Include climate adaptation in induction materials.
• Align adaptation with job descriptions to encourage responsibility and action.
• Identify potential adaptation champions who are knowledgeable and
enthusiastic advocates for adaptation. Ideally the number of adaptation
champions will develop over time and will include people working across the
organisation in a wide range of different roles.
• Identify specific roles and or ‘asks’ that adaptation champions could contribute
to. This could range from supporting awareness raising, joining an adaptation
steering group or influencing adaptation within specific projects/ departments.
Look for and create opportunities for champions to present and speak publicly
about climate change adaptation at internal and external events and
conferences.
• Ensure climate adaptation and risk information is made digestible, relatable,
and accessible.
• Get senior management to review the Adaptation Section of the public bodies
climate change duties report and take accountability for the organisation's
progress.
• Create a buzz around celebrating adaptation. Use internal and external
communications to celebrate staff, departments or projects that have
contributed to adaptation. This will also help raise awareness of what
adaptation looks like in your business and provides opportunities for shared
learning.
• Embed adaptation across the organisation through cross-departmental
working groups, adaptation champion networks or allocating departmental,
team or individual climate change responsibilities or objectives. 
Commit resources
• Identify existing relevant resources within your organisation that may be
available to support adaptation work. 
o Human resources - Identify job roles, teams, committees or
individuals that may already be developing policies, plans or actions
aligned with adaptation or who have knowledge of climate change
issues and duties.
o Physical and material resources - Understand the different types of
assets and what their roles in adaptation might be. Identify any assets
that your organisation owns or manages that support resilience and
adaptation (for example flood prevention infrastructure or estates and
greenspaces that provide ecosystem services).
o Financial resources - Examine what funding is currently allocated to
support work aligned with adaptation and what funding opportunities
exist.
o Intellectual resources – Catalogue the skills that your organisation
has access to that could help with adaptation work (for example risk
managers, engineers, GIS and data analysts, community engagement,
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resilience practitioners, communication or environment specialists and
those with facilitation skills).
o Information resources - Determine what adaptation information
(including records of climate impacts) your organisation currently
promotes internally and or externally and identify who holds these
resources.
o Monitoring resources – Understand what resources (staff, processes,
metrics and indicators) the organisation has for monitoring, evaluating,
and reporting. Continue to review and update an internal resources list. 
• Clearly define the short-term adaptation activities that require resourcing.
Estimate the resources (for example staff time, funding, access to technical
expertise) required to deliver the activity.
• Where there is a resource gap (i.e. there are not enough existing resources
available to deliver the activity) identify a budget holder or funder who may be
able to resource the activity and find out about the procedure for submitting a
budget request. Alternatively build a business case to resource adaptation
activity.
• Increase understanding of internal budget and investment cycles to see where
you might approach people for budget considerations.
• Identify lead in times and business cases requirements for annual and multi-
year budget allocations. 
• Find out if partner organisations are planning to carry out similar adaptation
activities and explore opportunities to share resources such as data, technical
expertise or staff time.
• Identify opportunities to share resources, benefit from in-kind support and
reduce duplication of effort. 
Mainstream adaptation
Nurturing a positive culture to adaptation and mainstreaming it in the organisation
may not be a quick process, however investing time and effort to integrate
adaptation into ways of working will have long term benefits when adaptation is seen
as business as usual. Be patient and flexible; allowing multiple iterations and time to
embed. 
• Consider how internal policies or legislation may further enable adaptation
and take advantage of opportunities such as consultation on new or review of
pre-existing policies and strategies to submit comments on how adaptation
could be included or incorporated.
• Create a list of upcoming policy and strategy review opportunities and allocate
time to providing consultation responses or feedback on those with greatest
potential to influence adaptation.
• Speak with colleagues about incorporating adaptation into existing processes
which can be used to screen new policies, plans, strategies and projects for
climate-related threats and opportunities. Example processes and guidance
which can incorporate adaptation include spatial planning, sustainable
procurement guidance, business continuity arrangements and estate asset
management guidance.
• Identify timescales and processes for factoring adaptation into all relevant
policies, plans and projects.
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• Provide evidence and communicate how and why adaptation should be
included in strategic plans such as your organisations corporate strategy or
asset management strategy.
• A requirement for climate resilience should be included in relevant supplier
contracts.
• Carry out a Climate Change Impact Assessment using this guidance from the
SSN.
• Link adaptation work to your organisational outcomes and demonstrate the
importance of adaptation to the overall organisation by showing how existing
adaptation work contributes to achieving organisational objectives or how
planned adaptation work will support progress towards organisational
outcomes; provide evidence of social, economic, and environmental benefits.
Integrate climate change adaptation into pre-existing established programs,
policies or strategies.
• Provide guidance to the organisation’s leadership on optimal ways to
incorporate climate change adaptation considerations into critical decision-
making.
• Embed climate risks, adaptation actions or relevant climate resilient KPIs in
your corporate strategy and performance framework.
• Climate impacts should be considered early on in business case development
and adaptation actions should be designed and costed in at an early stage.
• Use your organisation's risk registers (at corporate or service level) as a way
to heighten awareness, consideration and action on climate adaptation. Work
with your organisation's Risk Manager to define and embed adaptation risk
within your risk register.
• Ensure it is clear where accountability for climate change lies, and where
individuals and groups have defined responsibilities. This can be done on the
back of your climate change risk assessment to establish risk owners.
• Consider accreditation to, or working towards, ISO 14090:2019, Adaptation to
climate change - Principles, requirements and guidelines. 
6.4.8 Collaboration for adaptation 
Adaptation is not possible without collaboration. No organisation can adapt in
isolation; by working together public bodies can achieve positive, cooperative
adaptation outcomes. 
It is imperative that public bodies establish good relationships and connections with
key partners across the space, place, community and system in which they operate.
Collaborating allows for knowledge sharing, resource sharing, joined-up solutions
and inclusive adaptation. 
It is also crucial to the success of certain adaptation actions. All key partners need to
work towards the same goal: often a break in this chain can lead to unsuccessful
adaptation or greater resource spent on trying to fight against the outliers. 
The Christie Commission Review of Public Services in Scotland (2011) presented a
number of recommendations all of which were accepted by Scottish Government. 
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The four main themes were: prevention, partnership, people and performance. All
remain relevant but the first two are especially relevant to the management of
climate risks through adaptive approaches, requiring both preventative spend and
working in partnership. This requires the right people and organisations to act at the
right time, to the right degree and in the right place to maximise the combined impact
of resources. This governance challenge, the timely alignment of priorities and
resources across different public bodies and the private sector, remains a key
Christie Commission challenge. 
To build the organisation’s capacity to collaborate, public bodies should seek to:
• join relevant networks for their sector or for climate adaptation – more can
be achieved by learning from and sharing with others
• engage with a wide range of stakeholders on an on-going basis 
• take participatory and bottom-up approaches
• work in partnership to achieve adaptation outcomes
• take joint action to adapt to climate change.
The sections below offer points for consideration on how public bodies might seek to
nurture their organisation’s ability to collaborate to adapt to climate change. 
Collaborate for adaptation
• Identify and contact priority member organisations or individuals that can
support your adaptation work.
• Arrange meetings with a small number of identified groups or individuals who
may be relevant to your adaptation work. Have informal conversations, learn
about what they are doing and where there may be overlaps with your
organisation’s current or planned activities. Consider potential areas for
collaboration.
• Identify simple, quick actions that you can take forward with partner
organisations to help develop collaborative working. This may include sharing
data and information about climate impacts, methods for assessing climate
risks and case studies of adaptation actions.
• Identify whether there is interest from partners in developing two or three
longer term opportunities to collaborate on adaptation. Consider developing
basic project outlines and scoping out potential funders and opportunities to
influence progress and implementation. It is often easier to identify funding
and take up new funding opportunities as they emerge if you have a basic
project outline in place.
• Identify different options for formalising partnership working and assess the
strengths and weaknesses of each. Considering the role and remit of
partnership working and developing a business case will assist with this
process.
• Create a joint vision amongst partners. Agree desired outcomes; consolidate
partners’ aims in a shared vision that you are collectively working towards;
create a programme of work together to achieve the agreed vision, that
supports each partner’s aims.
• Consider the role and remit of partnership working:
o What is the vision, aims and objectives that the partnership is seeking
to achieve?
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o What will the partnership deliver? For example, will the partners deliver
a joint strategy or plan? Will the remit of the partnership extend to
implementing the plan and delivering joint action? Or do partners want
to focus on delivering a specific project?
o How will the partnership be structured? For example, will the
partnership be made up of one partnership board, an open networking
group or a combination?
o What legal structure does the partnership require?
o What is the lifespan of the partnership? Will it operate for a limited
time? Or be open ended?
• Consider climate justice, health and equity – at an early stage reflect on how
climate justice is considered as part of your engagement on adaptation. How
can you enable vulnerable groups to influence the adaptation actions that
affect them? The Climate Just Tool may help in this or reference to the
Adaptation and social justice report from the Climate Change Committee. 
• For place based projects working at a localities scale - identify other projects,
partnerships and initiatives that are seeking to influence change within the
location that you are targeting. At localities scale it is important to work with
others to integrate adaptation as part of projects and initiatives that are
addressing the outcomes and priorities that communities have identified.
• Monitor and evaluate the delivery and implementation of shared actions and
assess their impact. 
• Undertake long-term planning and look for projects or issues that would
benefit from collaboration
• Design an engagement strategy and plan to continue to engage with partners.
Refresh this periodically to ensure it maintains up to date.
• Contact Local Councils within your area to discuss joint action: Adaptation
Scotland :: Local Authority Climate Contact Directory
• Identify existing partnerships you already have that could be used to progress
adaptation.
• Identify existing groups, partnerships and forums that you could contribute to
and learn from in the adaptation space. Groups to examine may include:
o Climate Action Hubs
o Community planning partnerships
o Environment partnerships or forums
o SSN Local Authorities Forum
o Green network partnerships
Climate justice
Climate justice addresses the disproportionate impacts of climate change on
vulnerable communities and systems. Prioritising equitable outcomes ensures
that adaptation projects are inclusive and comprehensive, and supports a just
transition. For instance, when developing flood resilience initiatives, climate
justice entails actively seeking the input of marginalised communities who often
bear the burden of such events. This approach can result in more resilient
strategies that cater to and accommodate the often very context-specific needs
of these communities and reduce the likelihood of future resistance. 
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o Regional resilience partnerships
o Flood Risk Management Local Plan District Groups
o Regional climate adaptation initiatives such as:
- Climate Ready Clyde 
- Climate Ready South East Scotland
- Aberdeen Adapts
- Highland Adapts
• Join networks to meet others working on adaptation to benefit from shared
learning and opportunities to work together formally or informally. Relevant
Networks may include:
o Sustainable Scotland Network (SSN)
o Adaptation Scotland’s Public Sector Climate Adaptation Network
o SSN’s Local Authority Forum.
6.4.9 Additional sector specific resources 
Coastal change
Information and guidance on coastal change is provided on the Dynamic Coast
website. This includes guidance, aimed at local authorities, on developing a Coastal
Change Adaptation Plan (CCAP). NatureScot have published guidance on Looking
ahead: planning for coastal change. 
Further and higher education
Risk register guidance, including a tool and template, for the further and higher
education sector has been published by EAUC. 
Land use and forestry 
Climate change will have significant impacts on land, and implications for land use.
How the land is managed and used in Scotland must change and adapt to address
the climate and nature crises. This is a core part of Scotland’s National Adaptation
Plan (SNAP3). 
Moreover, healthy ecosystems underpin healthy societies and economies: they can 
both help to mitigate climate change and help to protect communities and
businesses against climate related hazards. There is a strong case for investing in
nature-based solutions to build resilience to climate risks. 
Below is a list of resources that may be useful: 
• Land Use, Land Use Change and Forestry briefing (UK Climate Risk): 
summarises how land use, land-use change and forestry (LULUCF) has been
assessed in the latest UK Climate Change Risk Assessment (CCRA)
Technical Report, and what types of action to adapt to climate change risks
and opportunities would be beneficial up to 2027.
• Land Use and Climate Change Adaptation in Scotland: Insights report
(Adaptation Scotland, 2023): sets out current perceptions, the barriers to
including adaptation in land-related decisions and identifies priorities to
enhance climate change adaptation and resilience in the context of land use
and ownership in Scotland.
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• Forest Research Climate Change Hub provides a wealth of adaptation
resources for the forestry sector in Scotland. This advice is also useful for
those who manage land that is or will be a wooded area. 
• Adaptation and the nature emergency report (Climate Change Committee,
2023). 
Health, wellbeing and equity
Public Health Scotland, Adaptation Scotland and the Improvement Service have
produced a briefing Working together to build climate-resilient, healthy and equitable
places: A briefing for local government and partners. 
The UK Health Security Agency recently published the first Health Effects of Climate
Change (HECC) report drawing together the latest evidence on how our changing
climate is already impacting on the UK’s health and publishing future projections
based on a plausible worst case scenario. 
Scottish Public Health Observatory Online Profile tools - the profiles present a range
of indicators to give an overview of health and its wider determinants at a local level.
The profiles give a snapshot of health for each area and highlight variation through a
variety of different visualisations. 
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7. Implementing the third duty: acting in the most sustainable way 
7.1 Introduction to the third duty 
The third of the climate change duties set out in section 44 of the Climate
Change (Scotland) Act 2009 requires public bodies, in exercising their functions,
to act in the way that they consider to be most sustainable. 
The National Performance Framework (NPF) is the overarching framework within
which the work of central and local government, and the wider public sector,
takes place. The NPF National Outcomes are aligned with the United Nations
Sustainable Development Goals (UN SDGs). Section 1 of the Community
Empowerment (Scotland) Act 2015 requires public authorities, in carrying out
their functions, to have regard to the National Outcomes. 
Public bodies are, in addition, required to contribute to the achievement of
sustainable development under various other pieces of Scottish legislation. 
To help demonstrate compliance with the third duty, public bodies should:
• align their work to the NPF and delivery of the National Outcomes and, as
best practice, to the just transition principles
• ensure that sustainable development is embedded in strategies, policies,
plans and projects
• integrate a sustainable development impact assessment, or equivalent,
process into decision-making processes, including financial decisions
• ensure that procurement activities are undertaken in line with relevant
legislation and the Sustainable Procurement Duty
• monitor and evaluate policy implementation and outcomes against the five
principles of the UK Shared Framework for Sustainable Development. 
Key outcomes for public bodies will be that:
• potential policies and decisions are, before they are finalised, assessed for
fairness, ecological impact, economic sustainability, whether they are
based on good evidence, and whether those who are likely to be affected
have had a chance to participate in the decision-making process
• activities remain within planetary boundaries, and focus on the fair
distribution of both benefits and disbenefits
• good governance for sustainable development ensures participation,
accountability and transparency
• the procurement process is used as an opportunity to maximise social and
environmental, as well as economic, benefits; and to ensure that
environmental and other harms are minimised
• they contribute, through their functions, to the National Outcomes and
achievement of the UN SDGs. 
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The third of the duties set out in section 44(1) of the Climate Change (Scotland) Act
2009 is about acting in the most sustainable way. This duty may be the most
important in ensuring a holistic and integrated approach to the future. 
At present, there is no definition of ‘sustainability’ or ‘sustainable development’ in
Scottish or UK legislation, and ‘sustainable development’ has often been
misconstrued. Therefore, this chapter starts by providing a brief outline of what the
Scottish Government considers sustainable development to mean and require before
providing guidance on implementation. 
The third duty is about mainstreaming sustainable development into the functioning
of Scottish public bodies. Sustainability considerations should not be tagged onto
business as usual activities; rather sustainability practices should be integral to the
functions of the organisation. Work should be carried out in way that supports
sustainable development. This is a requirement, not just of the 2009 Act, but of
various other Acts of the Scottish Parliament 41.   
7.2 Sustainable development: background and context 
7.2.1 What is sustainable development? 
The term ‘sustainable development’ is used to mean many different things, and to
justify and bolster different perspectives and interests 42. This section starts by taking
a look at the UN definition, why it is important, the UK Shared Framework and how
the principles can be implemented. 
The UN defines sustainable development as development that meets the needs of
the present without compromising the ability of future generations to meet their own
needs 43. 
7.2.2 Why might we want to develop sustainably? 
When considering why we might want to develop sustainably, it can be useful to first
consider unsustainable development. Unsustainable development occurs when
people act in a way that has immediate or short term benefits, often restricted to
particular individuals or interest groups, at the expense of the environment or other
people and the wider community. For example, dumping waste chemicals into a
watercourse may benefit the owner of a manufacturing business by minimising waste
treatment costs, and so allow them to expand their business rapidly with the aim of
generating financial profit. This may produce wider short-term benefits, such as
increased local employment opportunities. However, it is likely to negatively impact
on the local environment and on communities downstream. The chemicals may
“Sustainable development is how we must live today if we want a better
tomorrow, by meeting present needs without compromising the chances 
of future generations to meet their needs. The survival of our societies and
our shared planet depends on a more sustainable world.”         
- United Nations 1 
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poison fish populations, resulting in negative impacts on the fishing industry on which
other communities depend. Over time, chemicals may build up in the river sediment
resulting in toxicity levels that are harmful to humans and mean that access to the
area has to be restricted, or that clean-up costs are imposed on those who want to
restore the waterway or utilise the area in the future. 
Unsustainable development can contribute to and compound environmental
degradation, pollution, social and economic inequalities and climate change. In turn,
these can result in poor health outcomes, poverty, hunger and conflict over access to
resources and opportunities. 
Conversely, sustainable development takes a longer-term and holistic view and aims
to balance economic growth, social inclusion and environmental protection 44. Where
sustainable development is achieved, everyone has access to education, health care
and fair work; and use of natural resources stays within environmental limits. 
7.2.3 Bringing about sustainable development – the challenges 
Sustainable development is not a straightforward and easy state of affairs to bring
about, in part because it requires fundamentally shifting the developmental pathway
of our society as a whole. The current dominant model of societal development has
taken us to a point where the ways in which we live pose a threat to our own
wellbeing. In other words, the nature of many human societies that exist today
cannot be sustained in their present form in the long term.   
There are relatively few examples of contemporary ecologically and socially
sustainable societies. There is no clear precedent for transitioning from a large scale
consumption based society to one that works in harmony with the ecosystems of
which we are a part, but there are many possible pathways that could be followed. 
This means that there is no single or uniform ‘solution’ that everyone can apply. 
Rather we need to understand and apply sustainable development principles and
thinking to our work and to developing interventions and initiatives to address
human-induced ecological change and social inequity wherever we are. This will
mean transformative changes to our systems, processes and way of life. Sharing
information about what has been tried, what has worked, and what has not, will of
course be critical, but no one size will fit all. 
However, this chapter provides some information to help public bodies that are at an
early stage on their sustainability maturity journey to implement the sustainable
development duty.  It briefly sets out reference information about the duty and about
sustainable development, plus some ways in which organisations can begin to
implement the duty, including how sustainable development can be put into practice,
with an emphasis on avoiding conflicting policies and decision making. 
Developing initiatives and interventions for sustainable development requires an
understanding of the problem of unsustainable development, and a thoughtful and
intelligent, evidence-based, approach that is context specific.  There is no recipe or
checklist that all public bodies can all follow, but rather a multiplicity of possible
choices, based on the specific situation.
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The two essential principles or conditions of sustainable development are set out in
the UK Shared Framework for Sustainable Development, outlined in the sections
below. 
Further resources can be found on the SSN website. 
7.3 The UK Shared Framework for Sustainable Development 
The UK Shared Framework (see figure 19) shows two essential conditions for
sustainable development on the top line – living within environmental limits and
ensuring a strong, healthy and just society - plus three supporting conditions:
• a sustainable economy – one which does not breach environmental limits,
and whose benefits and disbenefits are distributed fairly
• sound science – ensuring that policy is evidence based
• good governance – based on participatory decision making. 
Figure 19: the UK Shared Framework for Sustainable Development (2005) 45 
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This framework clearly shows that sustainable development has two key goals –
environmental and social, and three important means (among others) to support their
achievement– a pro-social and pro-ecological economy; evidence based decision
making; and participatory governance. Together these are known as the five
principles. It focusses on the original problems that the notion of sustainable
development was created to address: social-ecological wellbeing. 
The UK Shared Framework definition is the one which Scottish Government uses,
and that public bodies are encouraged to adopt. 
7.3.1 Implementing the five principles 
As noted above there is no checklist or recipe for sustainable development. 
However, good starting points are:
• thinking about how the five principles of the UK Shared Framework can be
applied
• undertaking appropriate impact assessments as outlined in section 2.2.
Bodies could consider using a  specific sustainable development impact
assessment (SDIA) tool, such as the tool developed by the Scottish
Parliament, or, if more appropriate, the health impact assessment (HIA) tool
developed by Public Health Scotland. Both are freely available online, along
with guidance and contact information. Both impact assessment tools are
based on key factors for wellbeing and sustainable development.  
Working for sustainable development requires a thoughtful and intelligent approach.
In addition to using impact assessment tools, public bodies may find the following
problem-solving approach relating to attitude, methods and supporting activities
helpful. As best practice, bodies should embed these principles into their approach
and working practices. 
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Attitude
Three key attitudes to solving problems and making change are:
• Curiosity: always ask ‘what is going on here?’  Understanding and
breaking down a problem situation is essential to developing effective
solutions.
• Criticality: this does not mean criticising people, it means challenging
one’s own assumptions and those of others. For example, ‘we’ve always
done it this way’ is a common, but dangerous, assumption that a process
that was instituted in a previous set of circumstances is still fit for the
current set. This is not always true. For example, just because we started
using lots of nitrogen fertiliser to increase crop yields as human
populations expanded, does not mean that it is still a good idea: its
production is energy-intensive and results in greenhouse gas emissions 1,
1.
• Compassion: to work effectively with people, it is important to interact
with them in their space, and to understand their situation as best we can. 
Respecting and utilising their expertise, and working with them to make
change in their areas is often much more effective than trying to force
ideas onto them. Empowering others with knowledge, ideas and new ways
of seeing the world, or a particular problem is key – when someone
changes their thinking, they carry that new thinking with them, and can
work out what needs to change in their domain, and perhaps more
importantly, how. 
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Method
1. Acquire expertise: this can be done by finding and or building up in-
house expertise and seeking external support, including through relevant
networks.  Knowledge is key to the next step. 
2. Understand the problem: understanding a problem is the first step to
solving it.  The sections below set out the key problems that each of the
five principles seeks to address, and some thoughts on implementation. 
3. Consider whether and how your organisation, or the public you
serve, are contributing to, or are affected by, the problem: it may be
both – for example, the latest research on planetary boundaries (see
figure 21, below), shows that novel entities – human-made or human-
altered substances and organisms – in the environment present a very
high risk. Nevertheless, we continue to put vast amounts of them into the
air, water and soil, often without being aware of the fact that they might be
helping to destabilise planetary systems, and our own body systems. 
For example, you might want to find out what human made chemicals are
used in, or by, your organisation, or those you regulate or have an
influence over, whether there is data available on how safe they are for
humans and for ecosystems.  What might be the consequences of not
changing this state of affairs?  Who might be being affected, including as
part of supply chains or disposal processes?  What about ecological
effects? 
4. Identify what needs to be done: it is useful to envision what the best
outcome would be, e.g. no use of harmful human made chemicals, or no
use of those whose safety has not been proven. 
5. Assess how your organisation can support, or participate in, working
towards that outcome:  what further information might you need to
gather?  What levers are available to you?  What are the decisions and
actions required?  Who holds the power to make decisions in this
situation?  Who is likely to support or be able to help you? 
Alongside this process of defining and breaking down a problem and possible
solutions, there are supporting activities that bodies can undertake, that could
help and improve problem-solving: 
• Starting and maintaining conversations: people – colleagues and
stakeholders – are the holders of knowledge about current practices and
possible future solutions.  Invite and encourage them to get involved:
complex problems with no clear solutions are much better addressed by a
diverse group of people who bring different knowledge, experience, and
expertise to the table.   
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Table 4 below shows how each supporting activity can help to understand and
ameliorate the problem situation. 
Table 4: Activities to support sustainable development thinking 
Build
expertise
Understand
the
problem
Assess
the
causes
and
effects
of the
problem
Identify
the
desired
outcome
Consider
how to
work
towards
the
desired
outcome
Conversations Can help
you develop
your
expertise.
Can help you to
unpack the problem
situation.
Can help
you to
envision
what a
desirable
future
might
look like.
Can feed
knowledge
and ideas
into your
thinking
about how
to address
the
problem
Coalitions Allows you
to tap into
the expertise
of others
and work
together on
the problem
Bring different views to
the table.
Testing
solutions,
reflecting and
refining
Support the
development
of your
know-how.
What doesn’t work tells you more about the
problem.
What works well tells you where to put more
emphasis. 
The following sections provide more information on environmental limits, a just
society, a sustainable economy, sound science and good governance.  Each section
outlines the key problem of unsustainable development that the relevant sustainable
• Build coalitions: trust-based relationships, both inside and external to
your organisation, with those who share your interest in a particular
problem can help you to access some of the different decision makers
who will need to sanction or implement new processes, such as phasing
out cleaning chemicals and using more eco- and human- friendly
alternatives. 
• Develop and test initiatives and interventions: as there may be no tried
and tested solution to your sustainable development problem, use your
allies to help you come up with, and trial, possible solutions.  Reflect on
what went well and what didn’t, and refine your solutions accordingly.
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development principle seeks to address. This is followed in each case by some
comments on organisation-specific implementation. 
7.3.2 From environmental limits to planetary boundaries 
Environmental limits 
An environmental limit is an estimate of how much harmful impact a particular Earth
system can tolerate before it changes in a way that is a risk to humanity. For
example, warming of 1.5°C above pre-industrial levels is an environmental limit
beyond which the climate is increasingly likely to become a threat to human societies
46. 
Figure 20 below compares sustainable and unsustainable economies. It visualises
how an unsustainable economy breaches environmental limits (the red arrows),
causing the safe and stable space for humanity to deteriorate, whereas a sustainable
economy remains mostly within environmental limits (the green arrows), thereby
safeguarding the ecological stability that allows us to thrive within the Earth system. 
Figure 20: Environmental limits (adapted from Michael Jacobs’ original included in
‘The Green Economy: environment, sustainable development, and the politics of the
future’ 47) 
This model has been refined by Earth system scientists, and we now have a much
clearer idea of which environmental limits, or ‘planetary boundaries’ are critical to the
survival of human societies. 
Planetary boundaries 
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There are nine major systems and processes whose functioning and stability are
thought to be critical to human societies, see figure 21 below. Transgression of the
planetary boundary of any of these thresholds could tip important sub-systems, such
as the monsoon system “into a new state... with deleterious or potentially disastrous
consequences for humans” 48. 
Figure 21: the 2023 update to the planetary boundaries 49 
The planetary boundaries model depicts a ‘safe operating space’ – the green inner
circle – which shows the extent to which human activities can probably safely disrupt
Earth systems. Beyond the safe operating space is the zone of increasing risk, which
becomes higher further away from the centre of the diagram.  Those planetary
systems which are represented by only a green wedge, such as the ozone layer, are
thought to be functioning well enough not to present a risk to human societies.
However, those wedges which are orange- or red-ended show systems that have
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been severely disrupted, and whose altered functioning is a risk to us. It is important
to note that Earth systems are interlinked, and the disruption of one of them is likely
to affect others. 
Further information: Planetary boundaries - Stockholm Resilience Centre 
7.3.2.1 Working to minimise impacts on key planetary systems 
This section illustrates how the key principles outlined in the approach above can be
applied to minimise our impact on the planetary boundaries. 
1. Acquire expertise: Since the publication of the first planetary boundaries
model in 2009, we have learned much more about the state of the Earth
system, and the extent of disruption of the nine planetary systems that are
essential for the survival of human societies. More information about the
global scale of the problem can be found from the Stockholm Resilience
Centre. 
Work has also been done to look at more local contributions to ecological
disruption, e.g. by the Good Life for All within Planetary Boundaries
project. 
Other sources of expertise might include colleagues in the your own
organisation, other public bodies, including academia, and consultants. 
2. Understand the problem: One route to understanding a complex
problem, such as that of planetary boundaries, is to work out what its most
essential components are, e.g. 
o human societies depend on Earth systems, but are damaging and
disrupting them
o because of this, Earth systems are changing, which may cause
societal collapses 1. 
Once you have understood this, and gained some knowledge about the
details, you can begin to assess your context 
3. Consider whether and how your organisation, or the public you
serve, are contributing to, or are affected by the problem:  Looking at
the UK-level disruption of planetary boundaries on the A Good Life for All
within Planetary Boundaries website, we can see that:
o per capita carbon dioxide emissions are nearly eight times higher
than the planetary boundary allows for
o phosphorus use is nearly six times higher than it should be
o nitrogen use is just over eight times higher than it should be
o blue water (surface and ground water) use is less than half the
threshold value 
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o the amount of energy we consume by using other organisms, e.g.
for food, fuel, fibre, or by changing land from a state that can
capture the sun’s energy for food and support food chains (e.g. a
forest), to a state that does this less or not at all (e.g. cropland, or a
car park) , is just under the maximum level it should be
o in addition, our ecological and material footprints – measures of our
consumption – are just under two and a half, and three and a half
times the maximum they should be.
Consider questions such as:
• Which of these impacts are affecting the public or organisations you serve
or regulate?  
• Which of them is being created in your geographical or regulatory area?  
• Which do you have influence over?  
• Which of them do other public bodies have influence over?  
• Which bodies could you work with to bring these impacts to within safe
levels?   
4. Identify what needs to be done: what is the outcome you want to see? 
For example, the amount of nitrogen that is industrially or intentionally
converted from a gas in the air to, for example, fertiliser, is eight times
higher than safe levels. Perhaps we might want to see an eightfold
reduction in the use of nitrogen fertiliser? Or the cessation of industrial
nitrogen fixation, or of its importation? 
What steps might we have to take to move towards our desired outcome? 
Who can help plan these steps? 
5. Make a plan: which sets out how you and your organisation might support
or participate in moving towards the desired outcome; which aspects of
the solution are within your gift;  what actions are required from others,
and in what order;  how you might make a space for collaboration, and
bring actors together. For example, if you have responsibility for public
land, such as parks or golf courses, you might want to start by checking
the Scottish Government’s Principles for Sustainable Land Use
established through the Scottish Land Use Strategy.  You may also want
to  explore specific site related land management practices, such as
whether nitrogen fertiliser is being used on them.  If it is, your next step
might be to consider and discuss alternatives with experts and
stakeholders, and agree on what actions can be taken.  How will you
monitor progress and outcomes? 
6. Reflect on, and adjust your plan as you progress: as you and your
collaborators move forward with the plan, keep reflecting on what has
worked, and what hasn’t. Adjust your plan based on your reflections.
Reflecting together can be far more powerful than reflecting alone.
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7.3.3 Social equity 
As a social species, our brains are hard-wired to dislike unfairness.  This helps us to
cooperate, which we need to do because we are generally far less likely to survive
as isolated individuals.  In fact, there is significant evidence to show that more unfair
societies are worse off on the whole.   
For example, the Equality Trust which focusses on socio-economic inequality points
to bodies of research50 which show that:
• rates of violent crime are higher in more unequal societies51, which would
make societies less safe
• higher income inequality results in lower levels of trust, which we need for
social cohesion and cooperation
• The main factor that determines both health and educational outcomes is
socio-economic status52
• Obesity rates are significantly higher in more unequal societies. The US, for
example, has one of highest rates of inequality and also obesity
• Income inequality is linked to higher prisoner rates and harsher punishments.
These issues of inequality affect societal functioning and collective and individual
wellbeing. Research carried out by two of the founders of the Equality Trust shows
that poor outcomes (in states with high monetary incomes), are more related to
inequality than average income 53 . Societies where income is distributed more
equally are more beneficial for their members, and score better on an index of health
and social measures. Unequal societies, even those with higher average incomes,
scored worse. There is no clear relationship between income levels and health and
social problems. This evidence suggests that the pursuit of equality or equity might
be more effective in improving social function and individual health than the pursuit
of income growth.   
In order to develop into societies that are not creating the conditions likely to lead to
their own collapse, and which function well because individual members are well, as
are their relationships with each other, our activity should remain within planetary
boundaries, and should focus on the fair distribution of both benefits and
disbenefits. 
To achieve this, we need a sustainable economy, and participatory decision making
based on sound science (see section 7.3.5, below). 
7.3.3.1 Working to maximise social equity 
You can follow or adapt the problem solving method outlined in section 7.3.1 above
to focus on social equity, and any of the following three supporting principles for
sustainable development. The key is to start by understanding the problem; to work
through developing and trialling solutions or interventions; to reflect on results or
findings; and refine methods. 
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One of the most important actions we can take for sustainable development is to
assess potential policies and decisions before they are finalised for fairness,
ecological impact, economic sustainability, whether they are based on good
evidence, and whether those who are likely to be affected have had a chance to
participate in the decision-making process.  You can do this by using an appropriate
impact assessment tool (see section 2.2). 
In relation to social equity, or fairness, there are a few key things to consider in
relation to understanding the problem: 
1. A good way to think about equity or fairness is in relation to people’s
capability to meet their fundamental human needs (see figure 22 below). 
A fair society would be one which enables its members to acquire the
capabilities they need in order to meet their needs.  For example, one of
our fundamental needs is nutrition, so perhaps there are actions we can
take to ensure that the people who we serve:
o have access to nourishing food
o can acquire the knowledge and skills they need to obtain and
prepare nourishing food
o have access to the tools they might need to do this. 
2. Addressing inequity or unfairness may therefore be focussed on
assessing the capabilities of the public we serve to meet their fundamental
human needs, and using our assessments to inform future policy and
action.  Amartya Sen’s and Martha Nussbaum’s ‘capability approach’ 1
was developed to do just this.   
Some examples of how this has been used include:
o in evaluating public health interventions 1 
o to understand multidimensional poverty 1
o to support housing policy 1 
3. Unfairness is often structural.  What this means is that the structures we
put in place can favour some, while disadvantaging others. For example, if
we focus on building roads, we will be favouring those who have access to
private transport. However, if we focus on developing public transport
networks, far more people are likely to able to travel to where they need to
be, they may be less exposed to air pollution, and more likely to be a bit
more active.   
Structural inequity can be compounded by lock-in. For example, if we
replace public transport networks with roads, people may have no
alternative but to become car users. If they aren’t able to do this, then they
are less likely to be able to access opportunities that are further away than
people who have access to a car. 
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7.3.4 Wellbeing and a sustainable economy 
7.3.4.1 What is wellbeing? 
Often wellbeing is assessed (and therefore understood) through self-reported life
satisfaction or 'happiness’.  This is referred to as ‘subjective’ or ‘hedonic’ wellbeing
because it is reliant on the subject’s perspective.  While this type of data can be
relatively easily gathered, it can be problematic for a number of reasons, including
that:
• it is natural and healthy to sometimes feel less happy, for example grieving is
an important psychological process
• individuals and cultures can vary in how they might choose to rate their mood
• in itself, it doesn’t provide much information to support policy development.
A probably more informative approach to understanding wellbeing is ‘objective’ or
‘eudaemonic’ wellbeing, which is about the extent to which people are able to satisfy
their fundamental human needs. 
7.3.4.2 What are fundamental human needs? 
It has long been understood that human activity is motivated by the urge to meet our
needs. For example, if we need hydration, we feel thirsty, which drives us to look for
something to drink. It is thought that there is a set of fundamental needs that is
almost universal amongst humans.  Although there are various ways in which these
needs can be understood and categorised, perhaps the most straightforward is that
humans have:
• biological needs, such as clean air to breathe, food, shelter and warmth
• social needs, such as belongingness, participation and love
• self-actualisation needs, such as expressing one’s true nature 54 .
The objective wellbeing approach is therefore more policy-relevant because a well-
functioning society would support the capability of its members to meet their needs. 
For example, to meet our need for clean breathable air, society must ensure that air
pollution is properly controlled. 
At a wider level, to meet our biological needs and enable us to meet our social
needs, we require a well-functioning ecosphere (section 7.3.2).  To meet our social
needs, we require a well-functioning society which, as outlined above (section 7.3.3),
would be one in which benefits and disbenefits are fairly distributed. A wellbeing
economy could be described as one that operates to equitably meet our fundamental
human needs within planetary boundaries. 
Raworth’s ‘doughnut’ model of a sustainable economy 55  (figure 22 below) illustrates
this, depicting not just a safe operating space for humanity, but a safe and just one –
the green doughnut-shaped ring in the diagram. The ring has a dark green ecological
ceiling, representing the planetary boundaries that we must not breach if we aim to
maintain contemporary societies. Below this is a dark green social foundation, which
represents human needs and which we must not go below for an equitable and well-
functioning society.   
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The doughnut model mirrors the UK Shared Framework for Sustainable
Development (figure 19) in showing that human wellbeing depends on ecological
integrity (environmental limits) and social equity (a strong, healthy and just society).   
As the nature of our economies and governance systems dictate how we meet our
needs, and the extent to which we disrupt planetary systems in seeking to do so, a
transition to wellbeing economies, as depicted by the doughnut model, is necessary. 
Figure 22: The doughnut model of a sustainable economy (based on Kate
Raworth’s doughnut model of social and planetary boundaries 56) 
7.3.4.3 What is a wellbeing economy? 
While definitions vary, a wellbeing economy can be described as an economic
system operating within safe environmental limits, that serves the collective
wellbeing of current and future generations first and foremost. 
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It is a system that empowers communities to take a greater stake in the economy,
with more wealth generated, circulated and retained within local communities, while
protecting and investing in the natural environment for generations to come. 
It provides opportunities for everyone to access fair, meaningful work, and values
and supports responsible, purposeful businesses to thrive and innovate. The
approach recognises that reducing inequality and improving the lives of citizens
through a human rights-based, social justice approach can also make the economy
more resilient. 
It supports the transformations in our economy and society needed to thrive within
the planet’s sustainable limits and capitalises on the opportunities this creates for
improving people’s mental and physical health and wellbeing, tackling inequalities
and supporting green jobs and businesses. 
Traditional economic metrics such as Gross Domestic Product (GDP), Gross Value
Added (GVA), productivity and headline employment rates are regarded as important
indicators of how an economy is functioning and contributing to economic objectives.
However, it has been widely acknowledged that these metrics do not provide a full
picture of the whole economy, as they do not recognise unpaid work, and do not
distinguish between economic activity which contributes positively to the health and
wellbeing of people and the natural environment, and that which has negative
impacts on wellbeing outcomes. They also fail to reflect inequalities within the
economy. The Scottish Government’s Wellbeing Economy Monitor tracks broader
economic outcomes beyond GDP on issues such as health, equality, fair work and
the environment, and helps us assess Scotland’s progress in building a fairer,
greener and more prosperous economy. 
7.3.4.4 Working towards a wellbeing economy 
Models and frameworks for building a wellbeing economy vary, though they share
some key aspects and goals. A broad range of environmental sustainability issues
should be considered, including opportunities for protecting and restoring natural
assets, reducing greenhouse gas emissions and transitioning to a circular economy
– also recognising the range of wider benefits this can create for improving health
and wellbeing, tackling inequalities and supporting green jobs and businesses. 
The Scottish Government’s goal is to help people live happier and healthier lives with
higher living standards, to help businesses boost profitability, and build a more
resilient Scottish economy that promotes the wellbeing of all Scotland’s people. Our
approach to building a fair, green, growing economy is informed by our Wellbeing
Economy Expert Advisory Group and through our international engagement with the
Wellbeing Economy Governments (WEGo) network. Key features of the approach
include: 
• taking an open, transparent, participatory approach to developing strategy
and policy, involving those impacted by the policy, empowering citizens and
diverse communities 
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• setting a clear purpose and vision for economic policy and activity, focused on
collective wellbeing 
• establishing clear outcomes and metrics for measuring if and how our
economy is delivering wellbeing for people, place and planet 
• taking an evidence-based (qualitative and quantitative), whole-systems view
to understand the key drivers of wellbeing outcomes, how they interrelate, and
which have the greatest impact 
• adopting a preventative approach by focusing interventions on upstream parts
of the system to avoid negative impacts on outcomes downstream and
building long-term resilience 
• embedding inclusion, equality and fairness into economic policy from the
outset, working with and empowering communities and citizens to gain a
greater stake in the economy and removing barriers to participation 
• monitoring, evaluating and encouraging continuous learning, being open to
innovative and experimental approaches. 
The Scottish Government’s Wellbeing Economy Toolkit provides a guide for local
authorities and other public bodies to view the Wellbeing Economy as a system and
to develop local strategies focused on wellbeing outcomes, based on Scotland’s
National Outcomes. 
7.3.5 Sound science and good governance 
These last two supporting conditions for sustainable development are interlinked. 
Sound science is about ensuring that decisions are based on good evidence – the
term ‘science’ is used in its literal sense, to mean ‘knowledge’, not limited to so-
called ‘natural’ or ‘hard’ science. Good governance for sustainable development
should be built on evidence-based decision making, which includes the evidence of
lived experience, and the needs and opinions of those who might be affected. It
should therefore ensure participation, accountability and transparency. 
This also relates to community empowerment. Scottish Government is committed to
supporting communities to do things for themselves, and to make sure their voices
are heard in the planning and delivery of services. 
7.3.5.1 Sound science and good governance for sustainable development 
Together, the principles of sound science and good governance mean that decision-
making processes (which include decisions about internal and public policy, as well
as operational decisions, strategies and plans, etc.) should include: 
• gathering and reviewing evidence, e.g. research, expert and public opinion,
understanding relevant lived experience
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• dialogue and deliberation – ensuring that people with a range of backgrounds,
perspectives and experience can feed in to the process
• assessing potential impacts, and especially considering what unintended
consequences could occur.
An evidence-based approach to implementation is also important, and should
include:
• trialling, if possible, before full implementation, with a view to making
adjustments to improve outcomes
• monitoring and evaluation, to understand what positive and negative
outcomes are actually occurring; this can include ongoing engagement with
those who are affected by the decision or policy
• adjusting and improving as new information becomes available – this might be
from monitoring and evaluation, feedback, changing knowledge, observation
of impacts, etc.
Most importantly, good governance should also seek to ensure that decision making
is pro-social and pro-ecological, unlikely to contribute to the breaching of planetary
boundaries, and likely to increase social equity.  That is to say, that decision making
across an organisation should be focussed on supporting sustainable development. 
Assessing the likely impact of decisions, e.g. about buying something, in terms of
how they could affect ecosystems, people, the ability of economies to meet people’s
needs, and whether they are based on good evidence and are likely to be well-
governed, is key to this.  Using existing or bespoke impact assessment tools can
help with this (section 2.2 and section 4.5). 
Guidance and resources on participatory budgeting can be found on the PB Scotland
website. Guidance on assets transfers, for assets to pass into community ownership
or management, is published by the Scottish Government. 
7.4 Mainstreaming sustainable development 
As noted above, the third duty set out in the 2009 Act requires relevant public bodies
to carry out their functions in a way that they consider to be most sustainable, i.e.
that supports sustainable development. They are also required, under the
Community Empowerment (Scotland) Act 2015, to have regard to the National
Outcomes, aligned with the UN SDGs, in carrying out their functions. This means
that a more holistic and joined up approach needs to be adopted to integrate
sustainable development thinking into all policy and decisions. 
Integrating sustainable development doesn’t mean ‘business as usual but with more
recycling and low emissions vehicles’. It means that the way in which public bodies
carry out their functions supports sustainable development – rather than sustainable
development being an add-on. Sustainable development principles should be
embedded in the practices and functioning of the organisation. 
As sustainable development concerns all aspects of societal development, it is a
complex subject, and may require expert technical support. It also requires everyone
to participate. A checklist approach, such as could be useful in seeking to reduce
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greenhouse gas emissions by listing areas where reductions should be made, is not
feasible for sustainable development. This is because there are no blanket
solutions that work for all situations, and most importantly, we need to make
holistic decisions based on multiple ecological and societal factors. Instead,
we need to change the way we think and solve problems. 
7.4.1 Contributing to the NPF national outcomes 
The National Performance Framework (NPF) is the overarching framework within
which the work of central and local government, and the wider public sector, takes
place. The NPF supports a shared way of working and asks everyone to work
together to improve the lives of the people of Scotland. It aims to create a more
successful country, with increased health and wellbeing and reduced inequalities,
and where social, environmental, and economic wellbeing are given equal
importance. 
As outlined in section 2.1.1, the national outcomes are aligned with the UN SDGs,
illustrated in figure 23 below. 
Figure 23: the UN Sustainable Development Goals 57 
The Community Empowerment (Scotland) Act 2015 places a duty on public
authorities to have regard to the national outcomes in carrying out their functions.
Through their work, public bodies should contribute towards the achievement of the
national outcomes, and in turn the UN SDGs. 
Public bodies should, as best practice, ensure that decisions such as those around
public finances and budgets, major expenditure, public service delivery (including the
closure or cessation of existing services) and major development proposals, are
assessed in relation to wellbeing, sustainable development, addressing inequalities
and the needs of future generations. 
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7.4.2 Using the National Performance Framework 
Public bodies should align their work with the national outcomes and the associated
SDGs, as illustrated in figure 24. 
Figure 24: Aligning with the National Outcomes 
The NPF website provides resources and advice on outcomes working, including
examples of how public bodies are using the NPF and aligning their work to it. 
7.4.3 Sustainable development thinking 
There are four main interlinked components to sustainable development thinking:
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• Knowledge – an understanding of how ecological and social systems
function, and how they are interlinked
• Ontology (world view) – that is systemic and understands that humans
are one species among countless others, entirely dependent on them for
our survival and wellbeing
• Cognition (thinking) – fostering ways of thinking that seek to understand
and address the root causes of problems, that are long term, deep, and
broad, as well as holistic and systemic
• Practice – practitioners of specific disciplines, such as Planning or public
health, are best placed to use their expertise to develop solutions to
problems in their domain, although collaboration with sustainable
development experts may be necessary to ensure those solutions support
sustainable development.
Knowledge 
Sustainable development is a highly complex matter, and our current unsustainable
development is a ‘wicked problem’. Wicked problems 58 are multifaceted, can be
contradictory and changeable, and often feature complex interdependencies. There
are no clear or simple solutions, and very little in the way of precedents to draw on. 
Sustainable development relates to all aspects of human life, and therefore requires
a trans- (or post-) disciplinary approach – decisions should be made based on
several factors, rather than just one such as monetary price or convenience, and
considered from a number of angles. Although we are generally taught and trained to
carry out our work in a certain way, depending on our profession, we can no longer
afford to make decisions from one point of view, or take only one set of
considerations into account, e.g. health and safety, without thinking about wider
impacts.   
Integrating sustainable development thinking so that people apply it routinely in their
day to day work requires expert support and advice.  Fortunately, there is
considerable expertise that exists within the Scottish public sector, civil society
organisations, academia, and among other practitioners, like consultants. 
Worldview
A holistic big picture understanding of the world is essential, as well as the
understanding of how one’s own work fits into it. This can tell us which levers we
need to use to support sustainable development, which of those are within our reach,
and which we might need to collaborate with others to use. To foster a holistic
For example, using personal protective equipment to protect workers from
harmful chemicals may provide individuals with protection from direct exposure
but: 
• will toxic substances still end up in the environment?  
• how will they affect ecological functioning?  
• where will they end up – in water sources, in the air or in soils?  
• how would this affect us in the long term?
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perspective, sustainable development knowledge is necessary, and support to think
beyond the boundaries of one’s own work, to understand how it connects to that of
others, and what effects it might have. 
Thinking
We are often trained to think in linear, mechanistic ways.  Supporting staff members
to think about the consequences of decisions, including whether we should carry on
doing things the way we always have, and how that might affect society and
ecosystems at various different levels, including spatial and temporal, can help lead
to integrated solutions and policy coherence, which are necessary for development
to shift to a sustainable pathway.   
An integrated solution is one which depends not on trade-offs, but on win-win-win
solutions, which can usually only be arrived at by resolving the root cause of a
problem.   
Practice
Sustainable development knowledge, worldview and thinking take time to internalise. 
Nevertheless, they can support the realisation of individual and collective agency 59 –
the power one has to choose to act with purpose. Pro-sustainable development
action across an organisation can result in real change, especially if colleagues are
empowered, mandated and supported to decide how to integrate sustainable
development considerations into their work. 
7.4.4 Impact assessment 
Addressing a wicked problem like unsustainable development is highly complex. 
One type of tool that can support more pro-social and pro-ecological decision-
making is impact assessment that takes a holistic, integrated approach. The impact
assessment process should provide much needed space and time for colleagues to
think together, deliberate, and consider an issue from a wide range of angles, which
should support better thought-out solutions. 
Impact assessments are outlined in section 2.2.; and chapter 3 provides further
examples around equality impact assessment. The topic supplements will, in due
course, provide further information and examples, including Public Health Scotland’s
health impact assessment and the Scottish Parliament’s sustainable development
impact assessment. Both these examples require the participation of sustainable
development or public health experts, ideally as facilitators. 
7.4.5 An integrated approach to the three duties 
The climate system and the biosphere are believed to be the two core, mutually
dependent, systems essential to the stability of the Earth system as a whole. Indeed
each ecological system, from a tiny local ecosystem – say a small woodland - to the
planetary systems that circulate nutrients around the globe, or maintain our
protective atmosphere, is inextricably intertwined with bigger, smaller and
neighbouring systems 60.   
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While working to remedy a problem in one area, it is therefore important to consider
and avoid or minimise harmful effects in others. For example, wind energy forms an
important part of plans to decarbonise grid electricity. However, ill-considered
development of windfarms on deep peat can cause widespread, long term damage
and high greenhouses gas emissions, so that ‘the payback time is calculated to be
longer than the lifetime of the windfarm.’ 61 
Not only can poorly thought out initiatives cause ecological damage, they can also
harm other human societies. For example, ‘green colonialism’ has recently been
brought to light, whereby the efforts of wealthy countries to acquire the minerals and
metals they ‘need’ to reduce their harmful impacts is damaging societies which live in
older ways, sometimes outside the global capitalist economy 62 . 
Ensuring that broad holistic social-ecological thinking is brought to bear on problem
solving, rather than basing action only on the comparison of calculated GHG
emissions is more likely to help to minimise and avoid causing unintended harms. 
7.5 Multiple duties and compliance 
Public bodies are likely to have a number of statutory duties. In some cases, these
may appear to be conflicting. However, the 2009 Act states that public bodies must
carry out their functions in a way that supports mitigation of, and adaptation to,
climate change, and act in way that supports sustainable development. Other duties,
which confer other functions on public bodies, should be carried out in ways which
support mitigation, adaptation and sustainable development. 
For example, where there are duties on ‘sustainable economic growth’ this should be
interpreted in a way that supports the mitigation of, and adaptation to, climate
change. 
7.5.1 Sustainable procurement duty
Public procurement in Scotland aims to use collective spending power to deliver
sustainable and inclusive economic growth.  The Public Procurement Strategy for
Scotland 2023-2028, published on 27 April 2023, sets out that this spending power
can be used to make Scotland a better place to live, work and do business.  How
goods, works and services are procured should promote inclusive economic
growth, create fair opportunities for all, and accelerate the just transition to a
net zero economy.
Legislation governs how Scottish public bodies buy goods, services and works.  The
sustainable procurement duty in the Procurement Reform (Scotland) Act 2014
requires that before a contracting authority buys anything, it must think about:
• how it can improve the social, environmental and economic wellbeing of the
area in which it operates, with a particular focus on reducing inequality
• how its procurement processes can facilitate the involvement of SMEs, third
sector bodies and supported business
• how public procurement can be used to promote innovation.
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It requires a contracting authority to be aware of how its procurement activity can
contribute to national and local priorities and to act in a way to secure this.
Procurement spend should be considered in this context, before the start of the
formal procurement process, by all those involved, including: external stakeholders,
budget holders, commissioners and policy leads. 
A range of guidance and tools has been developed to assist public bodies in their
sustainable procurement activity, including statutory guidance on the sustainable
procurement duty, and the sustainable procurement tools. 
Further guidance and resources will be provided in the relevant supplement in due
course.
7.5.2 Sustainable land use 
Scotland’s Land Use Strategy sets out the long-term vision for sustainable land use
in Scotland:
How land is owned and managed is fundamental to how we live in Scotland, and is a
platform on which many of the national outcomes can be delivered.  The climate and
nature emergencies cannot be addressed without changes to the way that land is
used and managed. Land offers opportunities to help meet net zero targets, to adapt
to climate change and restore nature. 
Public bodies with landholdings or an interest in land should look to form or join
Regional Land Use Partnerships (RLUPs). RLUPs are intended to help local and
central government, land owners, communities and other stakeholders to work
together, to find ways to optimise land use in a sustainable, fair and inclusive way,
with the aim of meeting local and national objectives, and helping achieve national
climate change targets through changes to land use and good land management
that supports a sustainable future. 
The Land Rights and Responsibilities Statement takes a human rights approach and
contains six principles that should underpin every decision made about land,
including greater transparency, responsible exercise of land rights, and greater
engagement and collaboration between those making decisions and those affected
by such decisions. It lays out a vision where all land contributes to a sustainable and
successful country, supports a just transition to net zero, and where rights and
responsibilities in relation to land and natural capital are recognised and fulfilled. 
Guidance on engaging communities in decisions relating to land has been published
by the Scottish Land Commission.  
“A Scotland where we fully recognise, understand and value the
importance of our land resources, and where our plans and decisions
about land use will deliver improved and enduring benefits, enhancing the
wellbeing of our nation.” 
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7.6 Sector specific approaches 
NHS Scotland 
A policy for NHS Scotland on the climate emergency and sustainable development
(DL (2021) 38 was issued by Scottish Government to Health Boards on 10
November 2021. It sets out the aims and associated targets relating to sustainable
development and climate change for Health Boards to work towards. It takes account
of relevant wider Scottish Government policies and existing statutory duties. 
The NHS Scotland Climate Emergency Strategy 2022-2026 sets out actions directed
at achieving the aims and targets in DL (2021) 38. It sets out actions which will either
begin between 2022 and 2026, be completed during that period, or are already
underway and will continue during that time. 
The national NHS Scotland Sustainability Action Programme was established in
2022-23 to introduce a defined, structured and timebound approach to the delivery of
Once for Scotland actions with the intention of supporting NHS Boards to implement
the strategy locally. The programme is delivered by NHS Scotland bodies and the
Scottish Government in collaboration with other organisations including NatureScot,
Zero Waste Scotland and Scottish Water. 
Education: Sustainable Learning Settings 
Scotland's learning for sustainability action plan 2023 to 2030, Target 2030: A
movement for people, planet and prosperity, aims to build an inspiring movement for
change so every place of education for learners aged 3 to 18 years becomes a
Sustainable Learning Setting by 2030. Local authorities and other public bodies
involved in places of education should integrate the 2030 commitment into their
improvement plans, strategic plans, curriculum frameworks, corporate plans and
activities. 
The concept of sustainable learning settings includes the curriculum, culture,
community and campus and is about every aspect of the learning context. It is about
what and how students learn, how the setting manages its physical environment and
resources, how staff and learners relate to each other, how they work with their local
community and how they reach out to the wider world. In a Sustainable Learning
Setting staff will be supported to build their confidence, develop their practice and
access training and support. Learning, teaching and assessment will provide rich
learning opportunities for children and young people; opportunities that are rooted in
real life, with access to interdisciplinary and work-based learning which prepares
learners for the future. Improvements to buildings and grounds and links to the wider
community will also flow from this whole-setting approach. 
Further and Higher Education 
The SFC’s Outcomes Framework and Assurance Model sets out the expectations of
colleges and universities in return for the funding they receive, and the mechanism
by which SFC will engage with colleges and universities to monitor delivery against
outcomes. Net zero and sustainability is a cross-cutting outcome across nine themes
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(seven for colleges), setting the expectation that institutions mainstream and embed
net zero and sustainability into all aspects of their operations: Outcomes Framework
and Assurance Model - Scottish Funding Council 
EAUC Scotland’s mission is to inspire, empower and support leadership and
collaborative action for sustainability across the Scottish further and higher education
(FHE) sector. Its 2024-25 programme (EAUC Scotland Programme 2024-2025 |
EAUC) builds upon previous outcome agreement work with the SFC, and on behalf
of Scottish further and higher education institutions. 
The Quality Assurance Agency for Higher Education (QAA) has published guidance
intended to help UK higher education institutions embed Education for Sustainable
Development (ESD) within their curricula. ESD aims to support all learners to
envision and work towards a world that recognises the interdependencies between
the environment, social justice and economic wealth, acknowledging that resources
are limited and that they provide the foundation for our societies and the economy. 
Guidance and information on opportunities for collaborative working can be found on
the QAA website (some information is restricted to QAA members). 
Internationalisation and sustainability 
Scotland welcomes international students, staff, and researchers, recognising the
important and valuable contribution they make to the Scottish economy, our
educational environment, our society, and our communities. 
Our universities and colleges are globally respected. The National Strategy for
Economic Transformation (NSET) highlights that Scotland has more top universities
per head of population than any other country in the world and is in the top quartile of
OECD countries for Higher Education Research & Development. As highlighted by
the College Development Network’s International Ambitions Report, Scottish
colleges successfully export, engage, and excel overseas. They welcome students
from over 130 countries, hold partnerships from Azerbaijan to Vietnam and attracted
more Erasmus+ funding per capita for their staff and students than the rest of the
UK. Colleges act as ‘enablers’ of internationalisation given their responsibility to
reflect the needs of industry, government, and internationally competitive skills. 
Our universities and colleges provide world class education, skills training, and
overseas collaborations that bring education to developing countries. This allows
Scotland to work towards the UN Sustainable Development Goals by providing
education, research, and innovation in other countries. Such initiatives are an
important part of our overall inclusive, welcoming, and diverse educational
environment, which actively promotes knowledge transfer and shared experience
between nations. 
However, internationalisation strategies and operations can run outside of, and in
tension with, institutional sustainability policies and commitments. 
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Universities and colleges should therefore review internationalisation strategies and
operations and explore opportunities for improving the environmental sustainability of
institutional practices. 
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8. Reporting 
8.1 Reporting: introduction 
The Scottish public sector has been playing a crucial part in taking action on climate
change for many years. Public bodies contribute to tackling climate change by
supporting national and local climate policy, reducing emissions from public sector
assets and supply chain, and ensuring public services are resilient.  Recording
greenhouse gas emissions, and the actions taken to contribute to adaptation and
sustainability, allows public bodies to set targets and monitor progress towards
achieving these targets. In order to reduce emissions and work towards net zero and
other targets, bodies need to understand how their emissions arise, through a
combination of environmental and carbon management processes and reporting. 
To date, emissions reporting by public bodies has focused primarily on scope 1 and
2 emissions: from heating and power used in buildings, and on the emissions from
fleet vehicles. Many bodies also include indirect emissions such as those from
waste, business travel and staff commuting. It is important, moving forwards, that
while bodies continue to focus efforts on reducing their scope 1 and 2
emissions, they also start to measure, monitor and reduce scope 3 emissions
from the wider value chain. 
For most public bodies, indirect emissions from the wider value chain will be where
their greatest climate impact lies. It is estimated that typically over 90% of an
organisation’s emissions fall under scope 3 63; and that the emissions from
purchased goods and services could make up over 70-80% of a local authority’s
overall carbon footprint 64. It is therefore important that public bodies work towards
fuller reporting of scope 3 emissions, to provide a more accurate and complete
picture of their actual climate impact, and to enable them to take action accordingly. 
8.2 Public bodies climate change duties reporting 
All public bodies subject to the climate change duties are expected, as best practice,
to include climate change reporting as part of their annual corporate reporting
process, in terms of mitigation (carbon emissions reductions), adaptation and
sustainability. 
Mandatory reporting on compliance with the climate change duties was introduced
for the ‘major players’ within the public sector by The Climate Change (Duties of
Public Bodies: Reporting Requirements) (Scotland) Order 2015 (‘the 2015 Order’),
All public bodies subject to the climate change duties should include climate
change and sustainability reporting as part of their annual corporate reporting
process. 
Over 180 public bodies deemed to be ‘major players’ have a statutory duty under
The Climate Change (Duties of Public Bodies: Reporting Requirements)
(Scotland) Order 2015, as amended, to report annually on their compliance with
the climate change duties. These bodies are listed in schedule 1 of the Order.
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as amended. Bodies subject to mandatory reporting are listed in schedule 1 of the
Order. 
Bodies not subject to mandatory climate change duties reporting are
encouraged to adopt the principles outlined below as best practice. 
Public bodies are likely to be subject to other reporting or disclosure duties which
include climate impact reporting. Statutory examples include the UK Streamlined
Energy and Carbon Reporting (SECR), the Taskforce on Climate-related Financial
Disclosures (TCFD) and International Financial Reporting Standards Foundation
(IFRS) recommendations. Voluntary examples include the Global Covenant of
Mayors and the Carbon Disclosure Project (CDP). In all cases, public bodies should
ensure that they are aware of their responsibilities and act accordingly. 
8.3 The reporting duty 
This section explains the mandatory public bodies climate change duties reporting
duty (‘the reporting duty’), which bodies are covered by it, and contains guidance to
help public bodies understand and meet the duty. While the guidance is primarily
addressed to the public bodies subject to the reporting duty, it is intended to be
useful to all public bodies. 
8.3.1 Background and legislation 
Provision for reporting on climate change duties was introduced by section 46 of the
Climate Change (Scotland) Act 2009. Subsection 46(1)(a) states that Scottish
Ministers may, by order, require relevant public bodies to prepare reports on
compliance with the climate change duties. The order may set out the information to
be included in the reports, the form and manner of the reports, and the reporting
period. 
Mandatory reporting for relevant public bodies using the power under section 46 of
the 2009 Act was introduced by The Climate Change (Duties of Public Bodies:
Reporting Requirements) (Scotland) Order 2015, which came into force on 23
November 2015.  It has required over 180 listed public bodies to report annually on
compliance with their climate change duties since 2015. 
• Schedule 1 of the 2015 Order lists all public bodies who have a mandatory
requirement to report.
• Schedule 2 includes the questions public bodies are required to answer as
part of their report, such as details of their carbon emissions, and questions
on mitigation, adaptation and procurement.   
Since becoming a statutory requirement in 2015, Scotland’s reporting duty has been
credited with driving climate action and delivering robust measurement of public
bodies’ scope 1 and scope 2 emissions.  Reports provide valuable detail to share on
emissions reductions efforts by public bodies and in more recent years reports
provide increased detail on scope 3 emissions. There is a strong demand among the
public sector for robust, consistent and comprehensive measurement and reporting
of the entire carbon footprint of public bodies. Mandatory reporting also helps to
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improve the transparency, consistency and quality of reporting, and increases
collaborative working between public bodies. 
Following public consultation in 2019, the Scottish Government strengthened the
legislative framework for the reporting duty. The Climate Change (Duties of Public
Bodies: Reporting Requirements) (Scotland) Amendment Order 2020 amended the
2015 Order and from November 2022, relevant public bodies have been required to
provide in their annual climate change duties reports: 
• where applicable, the body’s target date for achieving zero direct emissions of
greenhouse gases, or such other targets that demonstrate how the body is
contributing to Scotland achieving its emissions reduction targets
• where applicable, targets for reducing indirect emissions of greenhouse gases
• how the body will align its spending plans and use of resources to contribute
to reducing emissions and delivering its emissions reduction targets
• how the body will publish, or otherwise make available, its progress to
achieving its emissions reduction targets
• where applicable, what contribution the body has made to helping deliver the
National Adaptation Plan. 
8.3.2 Reporting on scope 1, 2 and 3 emissions 
All public bodies have a direct impact on emissions through the way they carry out
their functions, including how they manage their estates and staff.  Public bodies can
reduce emissions through the way they manage their estate; this includes energy
use, water use, waste management and staff travel. For most public bodies, indirect
emissions from the wider value chain, i.e. scope 3 emissions, will be where their
greatest climate impact lies. It is important that public bodies work towards fuller
reporting of scope 3 emissions, to provide a more complete picture of their climate
impact. In turn, this will enable bodies to focus resource to where they can achieve
the greatest emissions reductions. 
Reporting data on scope 1 and 2 emissions has improved and become more
established since mandatory reporting began. The Greenhouse Gas (GHG) Protocol
defines direct and indirect emissions as follows: 
• direct GHG emissions (scope 1) are emissions from sources that are owned
or controlled by the reporting entity, e.g. emissions from heating buildings with
gas or oil, or from petrol or diesel fleet vehicles
• indirect GHG emissions are emissions that are a consequence of the activities
of the reporting entity, but occur at sources owned or controlled by another
entity. They include emissions from purchased electricity, heat, steam or
cooling (scope 2) and all other indirect emissions from the wider value chain
(scope 3) such as those associated with procurement, business travel and
waste. 
Public bodies should align their carbon accounting methodology with the GHG
Protocol. As set out in the Corporate Accounting and Reporting Standard, GHG
accounting and reporting should follow five key principles: 
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• Relevance – the inventory should appropriately reflect the emissions of the
organisation
• Completeness – all emission sources and activities within the chosen
inventory boundary should be accounted and reported on, with any specific
exclusions disclosed and explained
• Consistency – use of consistent methodologies should allow meaningful
analysis of emissions over time
• Transparency – assumptions made and methodologies and data sources
used should be clearly stated, producing a clear audit trail 
• Accuracy – estimation of emissions should be systematically neither under or
over actual emissions, as far as can be judged, and uncertainties should be
reduced as far as is practicable. 
The reporting duty requires annual reports to be submitted using the standard
Scottish Government reporting template. Detailed practical guidance on public
bodies climate change reporting, completing the template and supporting resources
are available on the Sustainable Scotland Network (SSN) website. 
Boundary setting 
A vital first step in carbon management and reporting is to define the organisation’s
boundaries. The inventory boundary determines which emissions are accounted for
and reported by the organisation. Bodies should refer to the Corporate Accounting
and Reporting Standard for guidance: they should first define their organisational
boundary and approach; and then set the operational boundary. This will involve
identifying the sources of emissions generated by their operations, categorising them
as direct or indirect, and choosing the scope for indirect emissions. 
As noted in the five key principles above, the inventory boundary should include all
relevant assets, activities and emissions generated by the organisation. Further
guidance is provided below regarding the activities and emission categories which
public bodies are, as best practice, expected to include within their boundary. The
body should, in defining the boundary, be transparent as to any sources of emissions
which have been excluded from the inventory and provide an explanation for these. 
Setting a defined boundary is important for clarity in reporting, and to avoid double
counting within the organisation’s inventory. For example, purchased electricity
should be reported under scope 2. As this is a purchased service, it will appear on
financial reports: bodies that report on purchased goods and services under scope 3
would therefore need to ensure that the electricity spend is extracted and excluded
from any calculation in relation to scope 3 emissions, to avoid these being double
counted.   
Conversion factors 
Calculation of carbon emissions typically involves applying a carbon equivalent
conversion factor to a unit of consumption (kg or tonnes CO2e per unit of
consumption, e.g. kg CO2e per kWh of electricity consumed or tonnes CO2e per m3
of natural gas consumed). For the purposes of the mandatory reporting, the UK
Government greenhouse gas reporting conversion factors should typically be used. 
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Other conversion factors are available and may be used where appropriate. For
example, Scottish Water have calculated a conversion factor for the supply of mains
water within Scotland which provides a more accurate estimate of emissions than
the UK factor. The public bodies climate change duties reporting template contains
built-in conversion factors for the majority of emission sources, which are updated
annually. Where bodies choose to use a different factor, or to calculate their own,
this should be clearly stated and further details provided. 
Environmental data management 
Public bodies should ensure that their data collection, collation and processing
methods are recorded, to ensure consistency year on year, and to support audits,
business continuity and resilience. While it may be appropriate for bodies with larger
or more complex datasets to have an environmental data management strategy or
equivalent, a proportionate approach should be taken. 
For bodies subject to the mandatory reporting duty, it is important that changes in
staffing or staff responsibilities do not impact on their ability to comply with the duty.
Ensuring that an operational environmental data management manual is maintained
can assist with this. 
Sector specific reporting guidance 
Guidance for Scottish colleges and universities has been developed by EAUC
Scotland to assist with the mandatory reporting from a higher and further education
perspective. 
8.3.3 Scope 1 reporting 
All relevant scope 1 emissions must be reported and are likely to include energy and
fuel use in buildings and vehicles. Fugitive gases, such as leaks of refrigerants from
cooling systems and heat pumps, should also be included as good practice. 
Some public bodies may have specific fugitive emissions, for example anaesthetic
gases in the health sector, that should be scoped and reported as they typically have
a higher Global Warming Potential (GWP) and so may make a significant
contribution to the footprint. A small number of public bodies may generate process
emissions and effort should also be made to include these, where material. 
Public bodies should refer to the GHG Protocol for guidance on the calculation of
scope 1 emissions. 
Over time, as bodies work to decarbonise their fleet and estate, emissions from
sources such as natural gas and diesel will decrease, and the relative contribution
made by sources such as fugitive gases may increase. It is therefore important that
bodies undertake regular reviews of their GHG inventory, to ensure that their reports
continue to be relevant and complete.   
8.3.4 Scope 2 reporting
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Scope 2 emissions must be reported on and include those from acquired electricity,
heat, steam and cooling.  For most public bodies, scope 2 emissions are likely to
come primarily from mains electricity, but may also include heat and steam
purchased from district heating networks. 
When reporting on scope 2 emissions from the purchase of electricity, bodies should
follow the location-based method and use the emission factor for standard UK grid
electricity. REGOs (Renewable Energy Guarantee of Origin certificates) are not
considered to be truly additional in relation to UK grid electricity. Any REGO certified
electricity purchased should be reported, in terms of emissions, as grid standard. 
An exception to this may occur where a body purchases electricity via a Power
Purchase Agreement (PPA). 100% renewably-generated electricity covered by the
PPA can be reported as zero emissions, where appropriate. 
Public bodies should refer to the GHG Protocol for guidance on the calculation of
scope 2 emissions. 
8.3.5 Scope 3 reporting 
Scope 3 covers all indirect emissions (aside from those already accounted for under
scope 2) from the value chain of an organisation and looks at both upstream and
downstream activities. The GHG Protocol splits scope 3 emissions into fifteen
categories, for example category 1 emissions from purchased goods and services,
category 5 emissions from waste, and category 6 business travel. 
Full information on scope 3 reporting can be found in the GHG Protocol Corporate
Value Chain Accounting Standard.  Further detailed guidance on how to calculate
scope 3 emissions is provided by the GHG Protocol scope 3 technical guidance
documents, and bodies can also refer to the SSN Net Zero Manual. 
All public bodies subject to the climate change duties are expected, as part of best
practice, to include certain scope 3 emissions in their reports. Public bodies are at
different stages of maturity in relation to environmental data and reporting, and also
have differing levels of capacity and resource. However, it is vital that bodies work
towards expanding their reporting boundary to include relevant scope 3 emissions to
better understand, monitor and reduce their overall climate impact. 
Following an Environmental Standards Scotland (ESS) investigation (reference
IESS.21.012), local authorities may in the future become subject to an additional
mandatory reporting duty in relation to scope 3 emissions (refer to the ESS
Improvement Report, Scottish Government’s Improvement Plan, and the Net Zero
and Transport Committee’s report for further details).  Any such changes would
require public consultation and changes to the existing subordinate legislation. Local
authorities should refer to section 8.4 below for further details. 
8.3.5.1 Scope 3 reporting – baseline expectations
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As a baseline, public bodies subject to the reporting duty are expected, as part of
best practice, to include scope 3 emissions from: 
• consumption of mains water (category 1)
• waste and waste water (category 5)
• business travel including, where appropriate, overnight stays (category 6)
• commuting and homeworking (category 7)
• fuel and energy-related emissions not included in scopes 1 and 2 (category
3).
Colleges and universities are, in addition, strongly encouraged to include student
travel within their reporting boundary. This should include estimates of emissions
from daily commuting to and from campus; and from relocation travel (travel from the
place of permanent residence to the location of study at the start and end of each
term or academic year). 
The rationale for including waste, water, business travel, commuting and student
travel is that these are areas where public bodies have more influence, and they
offer opportunities to engage staff, visitors and customers. Emissions from these
areas can be more easily influenced and managed through policy and operational
processes. They are also areas where data should be more readily available to the
organisation, or can be more easily and accurately estimated (see section 8.3.5.3).  
Reporting on fuel and energy-related emissions (category 3) provides a fuller picture
of the carbon impact of using, say, natural gas as it includes the upstream emissions
associated with extracting, refining and transporting the fuel. As such, it can assist in
the development of robust business cases and impact assessments that support the
transition to low or zero carbon alternatives.
If all bodies include these categories of emissions, it will provide a consistent
baseline across the public sector, allow more accurate analysis, and facilitate
sectoral comparisons and benchmarking. 
8.3.5.2 Scope 3 reporting – expanding on the baseline 
Over time those subject to the reporting duties, in particular bodies with larger spend
and influence, are expected, as best practice, to expand reporting of scope 3
emissions to include all relevant categories. Such bodies include local authorities,
NHS Health Boards, universities, central government bodies and executive
agencies. 
Expansion of the reporting boundary can progress in a phased approach, focusing
first on the scope 3 categories which contribute the most to the organisation’s overall
footprint. Such priority categories will differ according to the body’s functions, budget
and operations. As best practice, bodies should undertake an initial high level
scoping exercise, first to identify the priority categories; and then to identify the
emission ‘hotspots’ within those categories, to allow resources to be focused where
they will have the most impact. 
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For most bodies, priority categories may typically include purchased goods and
services (category 1) and capital goods (category 2), in particular the embodied
carbon related to construction and large retrofit projects. Some bodies may find that
investments including pension funds (category 15) are also a hotspot. 
Where bodies choose to take a phased approach to expanding their boundary, they
are encouraged to develop a clear plan and timeline for this, as part of their overall
carbon management plan or equivalent. This should identify key stakeholders from
across the organisation, as tackling scope 3 emissions is likely to require cross-
departmental working, and involve staff who may never have been involved in
environmental reporting before. It will be important that the plan recognises the need
to provide training for such staff, to ensure they have the necessary climate
knowledge and skills. 
8.3.5.3 Scope 3 reporting - data sources 
When public bodies start reporting on scope 3 emissions, or expand their reporting
to include previously un-reported sources, data maturity may be low. For example,
data may be incomplete or contain a high level of uncertainty. However, bodies
should not let this be a barrier to reporting on that source at all. It is recognised that
each organisation is on a maturity journey, and it is essential that public bodies start
to take the first steps into reporting scope 3. As part of this process, bodies should
be transparent as to the source of their data, its limitations, and so the accuracy of
the associated estimated emissions. Over time data quality, accuracy and
completeness can be improved as data management processes mature. 
The sections below outline some of the common sources of data for the scope 3
emission categories public bodies are expected to include in their reporting as a best
practice baseline. 
Purchased mains water (category 1) 
There are emissions associated with the supply of mains water. The majority of sites
will have water meters – whether analogue meters or digital meters with remote
monitoring – and water consumption can therefore usually be measured fairly easily.
At a basic level, meter readings could be taken on an annual basis. More advanced
meters, typically digital meters with remote monitoring capabilities, take readings at
regular intervals such as daily, hourly or half-hourly, and can also be used to monitor
consumption patterns and identify maintenance issues. 
Most utility bills include an estimate of consumption. Bodies should be cautious
about using unverified bills as a source of consumption data, as they can be
inaccurate. Bodies are advised to using billing or invoice data only where this has
been verified using meter readings, where possible. 
Where water meters are not installed, or where one meter covers an area shared
with another organisation, estimated data can be used. For the former, the bill or
invoice will include an estimate of consumption. For the latter, a proportionate share
could be estimated based on, for example, overall share of floorspace or numbers of
staff on site. Any assumptions and estimates should be clearly stated.
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Waste and waste water (category 5) 
All public bodies will generate waste through their day to day operations. Types and
volumes of waste generated will however vary widely, from simple food waste and
packaging, through to specialist streams of clinical, scientific and chemical waste.
Waste data should be readily available to most public bodies. Waste is a heavily
regulated sector, and clear records at each stage between site collection and final
disposal are required. Where public bodies are responsible for their own waste
contracts, the waste contractor should be able to supply detailed data including types
of waste, volume or weight of waste collected, and treatment or disposal route. This
information can be used, with the UK Government conversion factors, to estimate
the emissions associated with the waste collection, treatment and end destination of
the treatment output or residue. 
Waste data is typically based on estimates, based on size of bin and how full the
average bin is at the time of collection. This data can be improved by undertaking
waste surveys. Bodies generating particularly large volumes of waste could consider
installing scales on site to allow for accurate measurement. 
Where public bodies do not arrange their own waste contracts, for example where a
landlord arranges such services, bodies can request this data. Bodies on shared
sites could estimate their share of the emissions using an appropriate proportional
approach based on, for example, overall share of floorspace or numbers of staff on
site. Any assumptions or estimates should be clearly stated. 
UK Government plans to introduce mandatory digital waste tracking across the UK
from April 2025. While waste policy is a devolved matter, SG, the other devolved
administrations and UK Government have agreed to work together to introduce a
single UK system. Further information and guidance on this system will be available
from SEPA in due course. 
Waste water is typically estimated to be 95% of mains water consumption. Bodies
responsible for producing large volumes of effluent may have waste water metering
in place and be able to take more accurate measurements. However, this is
uncommon for most public bodies and taking the 95% approach for reporting is
acceptable. This assumption should be clearly stated, in line with the principle of
transparency. 
Business Travel, including overnight stays (category 6) 
Emissions in this category should include emissions associated with business travel
taken by staff, using vehicles or modes of transport that are not owned by the public
body, in the course of their work. Such emissions are likely to include journeys on
public transport, in hire cars, and by air. ‘Grey fleet’ journeys – those taken in
personal vehicles and for which staff claim a mileage rate – should also be included.
Business travel emissions should, as good practice, also include overnight stays. 
Emissions from trips taken in vehicles owned by the organisation, such as pool cars,
fall under scope 1 and are excluded from this category. 
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When reporting on business travel, bodies should take a proportionate approach and
focus effort on reporting sources material to their footprint. For example, a body may
on occasion use taxis, but the use of these may be minimal such that the emissions
form only a very small proportion of their overall footprint, and obtaining the data may
be resource intensive. In such a case, the body may choose to exclude taxi travel,
and should note this along with an explanation. However, there may be other
reasons to report on specific travel modes. For example, if a body’s use of public
transport is currently low, but they want to encourage a modal shift from grey fleet to
public transport, they may want to monitor and report on this. 
There are likely to be multiple sources of business travel data within a public body. 
• Travel agent: many public bodies hold a contract with a travel agent for the
booking of business travel and overnight stays. Travel agents are likely to be
able to provide detailed management information (MI) including the mode of
travel, class of ticket, distance travelled, starting point and destination, price
paid, country, and other relevant details for estimating emissions. Bodies may
be able to work with their supplier to tailor MI reports to their environmental
reporting needs; or could use the point of retendering the contract to introduce
such a requirement. 
• Other travel suppliers: bodies may have other travel-related suppliers such
as hire car contractors, who will also be a source of MI from which emissions
can be estimated. Hire car contractors, for example, may be able to provide
data including distance travelled, fuel type used, size of car, and sometimes
even amount of fuel consumed. 
• Corporate expenses system: expenses claims are likely to include
mileages, and travel tickets and accommodation paid for by the individual.
This data is likely to be less detailed than that provided by a travel agent, but
can still be used to estimate emissions. For example, if only the price of a
train ticket is recorded, rather than any details about the journey and distance
travelled, an appropriate spend-based factor can be used. Improvements to
data quality should be sought over time, for example by introducing additional
mandatory fields for claimants to complete. 
• Corporate expenses cards or credit cards: some organisations may hold a
number of expenses cards or credit cards, to allow the purchase of travel,
consumables and other items at short notice. The statements from these
cards are another valuable source of data – this may require more manual
processing but should not be overlooked. 
• Travel surveys: staff travel surveys can be used to gather data such as how
often individuals travel to attend meetings, the mode of transport used, and
the reasons for choosing that mode. This more qualitative information can
help inform the development of travel plans and policies.   
Commuting and home working (category 7) 
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Public bodies should report on both commuting and homeworking emissions. This is
important for a number of reasons. If a body only reports on homeworking emissions,
an increase in the number of employees working from the office will create a false
impression of emissions going down, as the decrease in homeworking emissions is
not counterbalanced by a corresponding increase in commuting emissions (or vice
versa). Being able to compare commuting emissions with homeworking emissions
will be important as bodies develop evidence-based policies around hybrid working,
noting that emissions are only one of many factors to be taken into account. 
While a standard conversion factor is provided for estimating homeworking
emissions, there is no standard ‘Scottish commuter’ conversion factor and bodies will
require to estimate commuting emissions themselves. 
Public bodies should consider how they can effectively engage with their employees
to understand how staff commute to and from work, how often staff commute and to
which sites, and how often staff are working from home; and put in place measures
to collect or estimate this data.   
• Staff travel surveys: carrying out a regular travel survey across the
workforce is a good way to collect data on employee commuting
behaviour, produce a clearer picture of the types of transport staff use to
travel to the workplace and the distance they travel in an average week.
This data can then be used to estimate commuting emissions. Surveys
can also be used to identify barriers to sustainable and active travel, and
the measures which would encourage people to travel more sustainably.
Such information can be used to help justify and target investment, for
example in improved cycling facilities at particular sites or introducing
cycle to work or electric vehicle salary sacrifice schemes. 
A Commuter Emission Calculator tool has been developed by Zero Waste
Scotland. The tool includes a staff survey and an emissions calculator. 
• Homeworking or hybrid working survey: hybrid working is now
widespread across the public sector. Homeworking emissions can be
simply estimated using a standard homeworking conversion factor, based
on the number of full time equivalent (FTEs) employees working from
home. However, bodies may wish to include questions on working from
home in a staff survey, for example in a hybrid working survey. This could
seek to elicit more detailed information around energy use at home and
heating behaviour. This could allow more accurate homeworking
emissions to be calculated. In addition, the information could also inform
employee engagement and communications plans, for example providing
signposting to home energy advice services. 
• Site occupancy data: buildings with a security system that registers staff
as they enter and leave the building may be able to estimate typical
building occupancy. Where more detailed data is not held, this could be
used to estimate homeworking and commuting rates, e.g. average 20% of
staff coming to the office, and so 20% of staff commuting and 80% working
from home. The details of this calculation would depend upon the nature of
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the body and its staff, and could be supplemented with related data held in
the HR system. 
Student travel: reporting student relocation travel emissions 
Student relocation travel emissions are those generated by students travelling from
their place of permanent residence to the place of study at the start and end of each
term or academic year. Domestic and international student relocation emissions form
a significant proportion of university scope 3 emissions: for example, within the 2021-
22 public bodies duties reporting, these emissions accounted for between 11 and
21% of total reported emissions for the institutions that included them. In line with the
GHG Protocol, universities should measure and report emissions arising from this
source. 
The sector can use the Domestic and International Student Travel Emissions
Calculator Tool developed by the University of Aberdeen and made available
through EAUC Scotland to measure and report these emissions. The tool requires
student registry data (number of students per nation) and the distance from London
to the university (in kilometers) to start measuring and reporting these emissions.
Universities can improve the granularity of the tool in future based on available
student travel survey data. The tool also includes historical UK GHG conversion
factors to allow universities to backdate emission source data to 2015-16. EAUC will
update the tool annually with the latest conversion factors. 
EAUC have also developed a Commuting Survey Guide and Tool. This resource
package intends to provide a standardised approach for the further and higher
education sectors to report on staff and student commuting emissions. 
Fuel and energy-related emissions not included in scopes 1 and 2 (category 3)
This category includes emissions related to the production of fuels and energy
purchased and consumed in the reporting year, that are not already included in
scopes 1 or 2. It includes the upstream emissions of purchased fuels (e.g. emissions
generated by the extraction, production and transportation of fuels, also referred to
as ‘well to tank’ (WTT) emissions), upstream emissions from purchased electricity,
and transmission and distribution losses. Transmission and distribution losses are
the amounts of energy in a system that are not consumed by end users or
customers, for example losses through leakage or energy dissipation, or the energy
needed to power the equipment that runs the distribution system. 
To estimate the emissions associated with this category, bodies are recommended
to use an average data method, and utilise the conversion factors provided by the
UK Government. If this approach is taken, bodies can use the fuel and energy
consumption information already gathered for scope 1 and 2 reporting, and apply the
relevant conversion factors. 
Bodies should refer to the practical reporting guidance for further details. 
Capital assets – embodied carbon from construction and retrofit projects
(category 2)
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Bodies are encouraged, as best practice, to calculate the whole life carbon of
projects in line the Net Zero Public Sector Building Standard, RICS whole life carbon
assessment, the UK Net Zero Carbon Buildings Standard, PAS 2080 (2023) or
equivalent, as appropriate. Public bodies should keep records of whole life carbon
emissions (in tonnes CO2e), including embodied carbon, predicted to result from
their major built environment projects. Such information on built environment carbon
emissions impact should be made available upon request from Scottish Government
by all public bodies. 
Public bodies subject to the reporting duty should, as best practice, include the
embodied carbon emissions from construction and retrofit projects in their annual
report. 
If a public body’s construction or retrofit project is completed within a single reporting
year, the total embodied carbon emitted from its construction should be reported in
tonnes CO2e. Typically, building projects will span several years. In this case, an
estimate of the embodied carbon emitted during the reporting period should be
included, e.g. a proportion of the total estimated embodied carbon based on
construction spend in the period. This would result in the same project being
reported over a number of years, with the annual emissions adding up to the total
embodied carbon resulting from the project. 
8.3.6 Reporting land-based emissions and removals 
Land-based emissions should be accounted for and reported on in line with the
principles of the GHG Protocol Land Sector and Removals Guidance. In doing so,
public bodies should follow the GHG Protocol principles of relevance, transparency,
accuracy, completeness, consistency, conservativeness and permanence when
compiling an inventory that includes land use activities and or nature-based
removals. 
Before adding land-based emissions to their inventory, it is important that bodies set
a boundary in relation to their land and land use activities. The boundary should
reflect the nature of the public body, its estate and functions, noting the GHG
Protocol principles of relevance and completeness, etc. For example, a public body
with large landholdings or land management functions is likely to find including land-
based emissions is appropriate, whereas a small body with an administrative
function and landholdings restricted to areas around office buildings would not. The
Land Sector and Removals Guidance provides further details. 
Key to reporting insetting activities is the need to have an organisational inventory of
land-based emissions and carbon capture. If carbon reductions are to be reported
and the benefit claimed, such as through woodland creation, then other land-
based emissions must also be included, such as losses from change of land
use or from degraded peatland. Carrying out an inventory assessment of the
condition of existing carbon stores will enable restoration activities to be prioritised to
the most degraded or vulnerable areas. Such an inventory should be regularly
refreshed to take account of changing environmental conditions, the impact of
nature-based projects and land use changes.
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The scope and level of detail included in such a land and emissions inventory should
be appropriate to the scale and nature of the organisation’s landholdings. It is
acceptable for an organisation to take a phased approach to their land-based
emissions reporting, such that specific land parcels are added year-on-year as data
become available. If a phased approach is taken, there should be a clearly defined
timescale for the inclusion of all relevant land and land-based emissions. If a land
parcel is added to the reporting, both emissions and reductions from that land should
be reported, and should be included thereafter. When introducing a piece of land,
and the related emissions, to the annual PBCCD report for the first time, bodies
should ensure that a note is included in the relevant table or tables to explain the
increase or decrease in emissions. 
Carbon reductions from nature-based insetting projects should be verified using an
MRV (measurement, reporting and verification) equivalent to a government
supported carbon code. Bodies may choose to verify insetting projects externally
through one of the Scottish Government supported carbon codes, however, there is
no requirement to do so, assuming that any carbon reductions are intended for
internal use. Carbon credits intended for sale or transfer to another body should be
verified and issued externally through one of the codes. The methodologies used to
calculate any carbon emissions reductions or carbon stored should be robust,
transparent and independently audited, whether these are for internal use or external
sale or transfer. 
Emissions that arise within Scotland’s territorial boundary should be inset or offset
within Scotland. Scope 1, scope 2 and certain scope 3 emissions (e.g. from water
supply and wastewater treatment, waste, staff commuting and homeworking,
domestic business travel, and upstream and downstream leased assets) are likely to
occur within Scotland’s territorial boundary. 
Any purchased or “gifted” offsets should be high-integrity and from projects verified
under Scottish Government supported carbon codes such as the Woodland Carbon
Code, Peatland Code or other such government-supported codes which may be
developed in the future. Offsets must be retired when the carbon benefit is claimed.   
Verified nature-based carbon offsets or insets from projects within Scotland can be
expected to contribute to national statutory emissions reduction targets, by
increasing the size of carbon sinks. Such offsets and carbon removal (e.g.
woodland) insets can therefore be included in the carbon accounting section (Part 3)
of the PBCCD report, to counterbalance organisational emissions that arise within
Scotland’s territorial boundary.
[i.e. Such offsets and carbon removal insets are acceptable to credit against a public
body’s relevant scope 1, 2 and 3 emissions as reported annually in Part 3 of the
PBCCDR. Emission reduction insetting projects such as peatland restoration should
be reported under land-based scope 1 emissions, and should result in lower direct
emissions from the source than before the restoration work took place]. 
Occasionally an unplanned, destructive event may cause damage on a public body’s
landholdings such that carbon is released, for example a wildfire destroying an area
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of woodland. The GHG emissions from such events should be estimated and
included in the annual report under land-based scope 1 emissions. 
Public bodies may sell or otherwise allocate (e.g. “gift”) carbon from projects on their
landholdings, surplus to their own operational requirements to reach net zero, to
other organisations, either other public bodies, private investors or other end-users
of the credits. Such carbon reductions or credits must not be included in the
originating body’s own corporate carbon account, as this would constitute double-
counting. Reference to carbon allocated or credits sold to others should be included
in the PBCCD reports as supporting information only (further guidance and reporting
requirements around carbon credits are to be developed and will be included in the
Land and Nature supplement in due course). Carbon credits issued for sale under
Scottish Government supported carbon codes must also be able to demonstrate
additionality in line with the codes. 
International offsets do not contribute to progress to Scotland’s national statutory
emissions reduction targets. Therefore, these must not be included in the annual
PBCCD reports as credits against organisational scope 1, 2 and 3 emissions that
arise within Scotland. Reference to such international credits should only be included
as supporting information. 
Direct air capture with carbon storage (DACCS) and other negative emissions
technologies (NETs) are not currently accounted for in the national GHG inventory,
i.e. they are not classed as “Scottish removals” as defined in the Climate Change
(Scotland) Act 2009 65, and do not count towards national emissions reduction
targets. There is provision within the 2009 Act for this to be changed in the future, if
appropriate. Until such a change is made, engineered emissions removals from
NETs should not be included in the annual PBCCD reports as credits against
organisational scope 1, 2 and 3 emissions that arise within Scotland. Reference to
such removals should only be included as supporting information. 
8.3.7 Reporting on alignment of resources with net zero targets 
Bodies subject to the mandatory reporting duty are required to include, in their
annual reports, how they will align their spending plans and use of resources to
contribute to reducing emissions and delivering their emission reduction targets.
Bodies are encouraged to take a broad approach to reporting on this aspect of their
activities and to consider staff resources and time, as well as financial resources. For
example, by: 
• reporting on how their capital investments contribute to reduction of their
scope 1 and 2 emissions, for example by investing in low emission
replacement fleet vehicles, or by replacing polluting heating systems with
clean heating systems in their buildings
• considering wider spending plans and budgets: spending on procurement and
service design and delivery, for example, can be used to drive emission
reductions
• demonstrating the use of appropriate tools and methodologies that have been
used in policy and project appraisal, for example whole life carbon
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assessment, and incorporating the cost of carbon into the cost benefit
analysis of business cases
• investing in systems that will support delivery of emissions reductions
• having staff members, roles or teams with a dedicated remit around climate
action could help demonstrate alignment of resources with emission reduction
targets, as could embedding climate action into annual staff objectives
particularly for senior managers
• expanding staff resource allocated to climate action
• ensuring that staff are given the time to undertake climate-related and
sustainability training, and for other climate-related activities and processes
such as climate change impact assessments. 
8.3.8 Reporting on adaptation action 
A key goal of climate adaptation is to increase preparedness to extreme weather
events now and in the future and to reduce vulnerability to climate change impacts.
Evidence shows investment in adaptation action represents good value for money,
with the costs of preparing for the impact of climate change outweighing those
associated with response and recovery. 
Effective and inclusive adaptation action requires collaboration and flexibility within
and between organisations. This also requires adaptation action to be embedded
into an organisation’s strategies with links made to other relevant policy areas. 
The mandatory climate change duties report includes a set of questions focused on
adaptation, the majority applying at corporate level, with one specific question on the
contribution to national adaptation objectives. 
Public bodies subject to the reporting duty should report on:
• understanding of current and future climate-related risks
• arrangements in place to manage climate-related risks
• action taken to adapt
• arrangements in place to review risk and monitor and evaluate the impact of
actions
• adaptation priorities for the year ahead. 
Public bodies subject to the reporting duty are, where applicable, also expected to
report on:
• progress in delivering the Scottish National Adaptation Plan (SNAP3). 
All public bodies should consider how the exercise of their functions can support the
national adaptation objectives and, where applicable, report on contributions to
national adaptation objectives, as outlined in section 6.3.4 and section 6.4.6.1. Public
bodies identified as owners of one or more policies (or proposals) in the Scottish
National Adaptation Plan, should report on policy delivery. 
To support statutory duties on adaptation action and reporting, public bodies are
encouraged to use the Capability Framework developed by Adaptation Scotland for
the Scottish public sector. As outlined in section 6.3.2 , the Capability Framework
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outlines four capabilities needed for an organisation’s adaptation journey and
describes a number of tasks to develop these capabilities over four stages from
‘starting’ to ‘mature’. 
8.3.9 Sustainability reporting 
General reporting 
Where bodies prepare annual corporate reports, these should incorporate
sustainability. Bodies should, as best practice, report on alignment with, and
contribution to, the NPF national outcomes through the delivery of their plans and
programmes. By integrating sustainability into their existing reporting suite, bodies
can avoid creating a separate, siloed sustainable development report, and help
ensure that sustainability is embedded across all business areas. 
Mandatory public bodies climate change duties reporting 
At time of publication, the mandatory reporting duty does not include a question
explicitly around compliance with the third duty, to act in the most sustainable way. In
the future, consideration may be given to introducing a question specifically around
this duty; and relevant bodies would be required to comply with any additional
reporting requirements. 
Part 5 of the annual mandatory report focuses on procurement. Any procurement
activity undertaken by Scottish public bodies should be in line with the Sustainable
Procurement Duty (see section 7.5.1), and this part of the report should reflect that
approach. 
Bodies are encouraged to report on their compliance with the third duty using other
sections of the reporting template, for example using the free text fields provided for
additional and supporting information, and the recommended voluntary questions for
reporting on wider influence. Mainstreaming sustainability into decision making
through the use of sustainable development impact assessments, for example,
would help demonstrate compliance with the third duty, and would produce a clear
audit trail. 
8.3.10 Reporting on wider influence emissions 
Through the climate change duties, the 2009 Act requires all public bodies, in
exercising their functions, to contribute to addressing climate change. Collectively,
public bodies have a wide range of functions that can influence emissions including
spatial and transport planning, place-making, investment, infrastructure
development, economic development, funding, regulation, communications,
education, community development, and partnership development and facilitation. 
Bodies are unlikely to be able to report in quantitative terms on the emissions impact
of these activities, but should make efforts to report these voluntarily in qualitative
terms under the recommended wider influence questions in the mandatory reporting
template. 
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8.4 Local authorities – additional reporting duties 
8.4.1 Scope 3 reporting for local authorities 
At the time of this consultation, Scottish Government is taking forward the actions
outlined in the Improvement Plan developed in response to an Improvement Report
issued by Environmental Standards Scotland (ESS) concluding investigation
IESS.21.012. The investigation looked into the effectiveness of the systems in place
to support local authorities in their duty to contribute to the delivery of climate change
targets.  The Improvement Plan focuses on the recommendation made by ESS that
the reporting of scope 3 emissions should be made mandatory for local authorities. 
This section of the guidance will be updated in due course as the actions outlined in
the Improvement Plan are taken forward. Introducing mandatory reporting of scope 3
emissions will require amending The Climate Change (Duties of Public Bodies:
Reporting Requirements) (Scotland) Order 2015. 
8.4.2 Area based reporting for local authorities 
As part of the informal resolution process to the ESS investigation noted above,
Scottish Government agreed that local authorities will move towards the reporting of
area based emissions. This section will be updated in due course as the monitoring
and reporting of area based emissions is developed by local authorities and the
Scottish Climate Intelligence Service (SCIS). 
Annex A: Baseline Carbon Management Plan template 
The purpose of this template and guidance 
Who is this document for? 
This carbon management plan template and guidance is to help smaller and less
complex public bodies that may have limited capacity to measure, monitor and report
on their carbon emissions, and that have relatively simple corporate emissions
inventories and influence over these emissions. It is designed to ensure all public
bodies tackle the essential emissions relating to their operations, and to highlight the
importance of focusing on the use of public body functions to influence change more
widely. 
Why have a Carbon Management Plan? 
A Carbon Management Plan (CMP) serves as a strategic and action-oriented
document to help public bodies understand, measure, manage and reduce their
corporate carbon emissions. 
What are the key parts of a Carbon Management Plan? 
As outlined in this guidance and template, the key parts of a Carbon Management
Plan are:
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• A brief overview of the organisation: it’s size, key activities and functions.
• An explanation and or illustration of CMP governance and management
arrangements, including how the CMP fits into corporate management and
governance structures and processes. This section should also include a
signed declaration verifying that the CMP information is accurate and formally
signed off by an appropriate senior manager.
• Brief overview of the key drivers and objectives of the CMP, often including
reference to key policy and organisational priorities.
• Setting a baseline year for the CMP, from which emissions will be monitored.
• Setting clear boundaries of which emission sources (relating to
organisational functions) will be included in the CMP. 
• Collating an emissions inventory based on the emission sources within the
agreed boundary.
• Setting out clear emissions reduction targets, overall and activity specific.
• Developing a register of emission reduction projects.
• Monitoring and reporting the impact of the emissions reduction projects and
setting out the expected impact of projects in the years ahead.
• Publishing annual reports on progress including, where applicable, via the
mandatory public bodies climate change duties annual reporting process. 
Mandatory public bodies climate change duties reporting 
Many sections of this Carbon Management Plan correspond to the public bodies
climate change duties reporting (PBCCDR) master template available on SSN’s
Reporting Resources page. This guidance indicates where the Carbon Management
Plan relates to the mandatory reporting template, using the relevant Part and table or
question numbers. 
The PBCCDR template is publicly available to all public bodies, not just those
subject to the mandatory reporting duty. All bodies are free to use it as a tool. 
Please refer also to the public bodies climate change duties reporting guidance on
how to fill out the annual report which can be found at SSN Reporting Resources,
where applicable. 
Baseline Carbon Management Plan Template 
1. Public Body Overview 
Provide a general description of the organisation stating key information such as
when established, size or scale, current practices and key functions. Provide a
brief description of your offices or physical estate, number and type of buildings
used, number of staff, if you operate any fleet vehicles etc. 
Please enter this information in Part 1 (a-g) of the public bodies climate change
duties report. 
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2. Governance and management
3. Drivers and motivation for change 
Explain the arrangements in place to provide a robust system of governance and
management of the Carbon Management Plan, covering decision making and
leadership. Include the review period for the CMP, e.g. to be reviewed annually. 
• Governance refers to arrangements at Board (Non-Executive) level. 
• Management refers to senior executive functions such Chief Executives,
Finance Directors and the likes of Corporate Management Teams. 
Please enter the information in Part 2 (a and b) of the public bodies climate
change duties report. 
Set out a brief overview of the key drivers and objectives of the Carbon
Management Plan. This could contain reference to: 
• Key strategy and policy commitments of the body
• An overview of how the Carbon Management Plan supports other
organisational objectives
• Key drivers within the public sector and motivations of leaders and
managers
• Reference to the financial and operational benefits of the Carbon
Management Plan. 
Reference should also be made to the legislative drivers within the Climate
Change (Scotland) Act, where Section 44 of the Climate Change (Scotland) Act
2009 sets out Public Bodies Climate Change Duties on: 
Mitigation - greenhouse gas emissions reduction.
When carrying out their operations, public bodies must act in the way best
calculated to contribute to delivery of the Act's greenhouse gas emissions
reduction targets. The Climate Change (Duties of Public Bodies: Reporting
Requirements) (Scotland) Order 2015, secondary legislation under the Climate
Change (Scotland) Act 2009, mandates annual reporting for listed bodies. The
2020 Amendment Order adds requirements including, where relevant, target
dates for zero emissions, alignment of spending with emission reduction, and
contributions to Scotland's Climate Change Adaptation Programme.
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4. Baseline period 
The baseline year for this Carbon Management Plan is financial year [--------] 
5. Organisational boundary 
Adaptation - adapting to the impacts of a changing climate 
The Securing a Green Recovery on a Path to Net Zero: Climate Change Plan
2018–2032 Update outlines ambitious emission reduction targets, following
advice from the Committee on Climate Change and the 2019 Climate Change
Act requiring net-zero emissions by 2045. For adaptation, public bodies must act
resiliently, aligning with the statutory adaptation programme.  The Scottish
National Adaptation Plan 2024-2029 addresses climate impacts, guided by the
third UK Climate Change Risk Assessment (CCRA3). CCRA3 was based on the
Independent Assessment of UK Climate Risk and national summaries, including
the National Summary for Scotland that assesses 61 climate change risks and
opportunities for Scotland. 
Acting Sustainably - sustainable development as a core value.
Acting Sustainably mandates public bodies to align with wider sustainable
development goals, such as the United Nations Sustainable Development Goals
(SDGs). Scotland's National Performance Framework aligns with SDGs, tracking
progress through 81 indicators, including carbon footprint, greenhouse gas
emissions, natural capital, renewable energy, waste, biodiversity, active travel,
public services, and local influence. 
The date included here should be the period chosen as the first estimation of
your emissions. 
Information on establishing a baseline can be found in the SSN Reporting
Guidance available from the Reporting Resources page. 
The Carbon Management Plan should clearly set out the organisational boundary
used for monitoring and managing emissions. A basic Carbon Management Plan
should, where applicable, have the following organisational boundary of emission
sources, grouped by standard carbon accounting protocol scopes. These could
be included in a table, as illustrated below: 
Operational area or
activity
Source of emissions* Scope
designation
Buildings** Gas use, primarily from heating 1
Other heating fuels, e.g. oil, biomass 1
Mains electricity 2
Fugitive gases, where applicable. 
Most likely to be refrigerant gases
from cooling equipment or heat
pumps
1
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Upstream energy and fuel-related
emissions, i.e. those associated with
the extraction, refining and transport of
fuels, and transmission and
distribution losses
3
Fleet vehicles owned or
operated by the public
body 
Fuel used (e.g. petrol, diesel) in fleet
vehicles
1
Electricity used by EVs (electricity
used to charge vehicles may be
included within the overall building
consumption if not separately
metered)
2
Upstream energy and fuel-related
emissions, i.e. those associated with
the extraction, refining and transport of
fuels, and transmission and
distribution losses
3
Business travel Personal vehicles used for business
(i.e. ‘grey fleet’)
3
Public transport used for business 3
Flights taken for business 3
Overnight stays taken for business 3
Staff commuting Staff vehicle fuel used in commuting
Public transport used in commuting
3
Staff working from
home
Number of staff working from home or
actual energy and fuel use reported by
staff while working at home 
3
Waste  Waste generated by the public body 3
Water Water supply or consumption; and
related waste water treatment
3
*Section 8.3.5.3 provides information on common data sources for some of the
emissions listed. Refer also to the GHG Protocol for further guidance. 
**Note: certain public bodies may not have direct control over their buildings and
services if they lease space. In such cases taking a proportionate approach will
suffice. Depending on the occupancy level and lease arrangements a pro-rata
approach may be most appropriate. Where relative occupancy rates are low and
part of the estate of another public body, it may make more sense to either note
this or attribute estimates as scope 3 emissions, as the body has no direct
control.  When co-located with other public bodies, all parties should agree on
respective reporting boundaries to avoid double counting, but more importantly,
focus on actions to reduce energy use, waste and water consumption in
partnership with co-occupants and building owners. 
Bodies may choose to report on other sources of emissions, and these should be
included as appropriate. The table is intended to illustrate a starting point only.
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6. Setting a baseline carbon emissions inventory 
Baseline Carbon Emissions Footprint 
Methodology: We have classified our greenhouse gas (GHG) emissions in line with
the Greenhouse Gas Protocol (revised edition). All emissions have been converted
to carbon dioxide equivalent (CO2e) and calculated using UK government emission
factors, unless otherwise stated.
The table below outlines our overall carbon footprint for the baseline year of [--------] 
Baseline Emissions – Scopes 1 and 2: [--------] tonnes CO2e
Baseline Emissions – Scope 3: [--------] tonnes CO2e 
Total Baseline Emissions – [--------] tonnes CO2e 
Baseline year emissions
Emission Scopes Total Emissions (tCO2e) by
activity 
Total emissions (tCO2e)
Scope 1 Buildings:     
Fleet vehicles: 
Scope 2 Buildings:   
Fleet electric vehicles: 
Scope 3 Buildings - Upstream fuel and
energy related emissions: 
Fleet - Upstream fuel and
energy related emissions:
Business Travel: 
Staff commuting: 
Staff working from home: 
Waste: 
Water and waste water:
Total Baseline
Emissions    
Matches table 3a in PBCCDR and table 3a can be extracted and used in the
Carbon Management Plan. 
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7. Emissions reduction targets 
The body’s overarching CO2e emissions reduction target is [absolute target,
percentage reduction target or net zero target] of [------------] by year [--------]. 
Based on the agreed boundary, a baseline inventory of emissions should be
calculated. The table above illustrates a simplified way of presenting this. This
can be done using the emissions reporting tables in Part 3 of the public bodies
climate change duties report template, tables 3a and 3b. These tables require
information on the consumption of gas, electricity and fuels, as well as
information on business travel modes and distances, and data on waste
generated and water consumed. 
Once these tables have been completed, a Carbon Management Plan summary
table, as illustrated above, can be published. 
To calculate the emissions relating to each scope and area of activity, please use
table 3b in Part 3 of the public bodies climate change duties report template. This
template is publicly available and can be used as a tool by all public bodies, not
just those subject to the mandatory reporting duty. 
The PBCCDR template will calculate emissions and allocate scopes based on
consumption data entered against each type of activity. Table 3b can be
extracted and used within the Carbon Management Plan to provide a more
detailed overview of emissions by activity. 
The public body should establish an overarching net zero carbon target, in line
with the Scottish Government target of net zero by 2045 where feasible, ideally
earlier, covering emissions from scopes 1 and 2. 
They should also set appropriate scope 3 targets including a target for reducing
car kilometres travelled and targets related to waste and recycling. Targets
should be set for each source of emissions, relating to the various activities, as
illustrated in the table below. Targets should include a date and, generally, a
baseline year - refer to section 5.4.4 in the guidance above for further information
on target setting.  
The targets included in the table below are intended to be illustrative examples
only. Bodies should set evidence-based targets appropriate to their own body,
assets, location and operational activities. 
Operational area or
activity
Source of emissions by
activity
Scope Target* 
Buildings All - All owned
buildings to be
energy efficiency
rating band C or
better by 2038. 
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Gas 1 80% reduction in
emissions by
2035, from [the
baseline year]. 
Zero emissions
by 2038.
Other heating fuels 1 Zero emissions
by 2038.
Electricity 2 20% reduction in
total electricity
consumption by
2040. 
By 2040, 25% of
total electricity
consumed is to
be self-generated
using on-site
renewables.
Vehicles owned by
the body
All - 20% reduction in
car km travelled
by 2030.
Fuel used (petrol, diesel) 1 No new fossil
fuelled cars to be
added to the fleet
from 2025. 
80% of the cars in
the fleet to be
EVs by 2025. 
Fleet to be fully
electric by 2030.
Business Travel All 3 25% reduction in
total business
travel emissions
by 2030.
Personal vehicles (‘grey
fleet’)
3 20% reduction in
car km travelled
by 2030.
Public transport 3 10% increase in
the number of
journeys taken
using public
transport by
2030. 
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Flights 3 Zero domestic
flights to be taken
by 2028 (within
mainland UK). 
25% reduction in
emissions from
non-domestic
flights by 2028.
Staff commute** All 3 25% reduction in
total staff
commuting
emissions by
2030.
Active travel to work 3 25% of journeys
to made by active
travel by 2030.
Public transport travel to
work
3 15% of journeys
to be made using
public transport
by 2030.
Private vehicle travel to
work
3 20% reduction in
car km travelled
by 2030. 
All owned sites
with car parking
to provide at least
2 EV charging
points accessible
to staff by 2030
(where feasible).
Working at home** Energy efficiency actions
at home
3 Home energy
efficiency training
to be added to
staff induction
process by 2026;
and delivered to
all staff by 2028.
Waste Weight or volume of
waste generated
3 25% reduction in
the [weight or
volume] of waste
generated by
2030.
% of waste recycled 3 80% of waste to
be recycled by
2030.
% of waste to landfill 3 Zero waste to
landfill by 2028. 
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8. Policies and projects 
Water Volume of water used 3 20% reduction in
the consumption
of water by 2030. 
*  Targets can take various forms. For scopes 1 and 2, these should focus on
carbon reductions, e.g. a 75% reduction in the scope 2 emissions from electricity
by 2030. Scope 3 targets may focus on carbon emissions, or may relate to the
activity, e.g. 70% of waste to be recycled by 2030; 50% of business travel
journeys to be taken using active travel or public transport by 2035. Refer to
section 5.4.4 in the guidance above for further information. 
** Note:  the number of staff commuting and the number of staff working at home
are related. Targets should encourage both low carbon commuting (walking,
cycling, public transport) and, only where appropriate, working from home (which
is typically lower carbon than commuting). Public bodies should encourage staff
to adopt good practice energy efficiency and low carbon behaviours while
working at home in order to minimise emissions generated while working at
home. 
Targets should be set for overall emissions reductions, as well as sub-targets on
reducing demand (energy efficiency, etc.) and greening supply (shifting to low
carbon alternatives) in each of the activities that are sources of emissions. 
Targets should be set in line with policy objectives set by the Scottish Government
or agreed collectively by public bodies by sector. 
Targets should be set out and reported annually in table 3d. in Part 3 of the public
bodies climate change duties report template. 
To meet targets public bodies should develop and implement policies and
projects that support emission reductions. Each policy and project should be
carbon impact assessed to calculate the likely carbon reduction impact. Public
bodies need to use these reduction estimates to assess the range of policies and
projects needed to meet agreed targets. 
Within this section, outline why you have chosen these specific policies and
projects. Outline those which are directly related to meet your reduction targets,
describe how you are planning on implementing and identify any barriers which
could prevent their implementation. Not all projects have to be directly related to
emissions reduction, they could be around behavioural change or education (i.e.
enabling measures). 
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Policies and projects register 
The policies and projects included in the example register below are intended to be
illustrative examples only. Bodies should plan and implement approaches and
measures appropriate to their own body, assets, location and operational activities. 
Project
name
Description Direct
emissions
reduction
or
enabling
measure
Emissions
Scope
addressed
Predicted
carbon
reduction
(tCO2e)
Target
completion
date 
Example:
EV charging
infrastructure
Installation
of EV
charging
points for
fleet
vehicles at
all sites
Enabling
measure
1 Not
applicable
2025-26
Example:
EV charging
infrastructure
Install at
least 2 EV
charging
points for
staff
vehicles at
all owned
sites (where
feasible)
Enabling
measure
3 Not
applicable
2029-30
Example:
Renewable
electricity 
Install solar
PV panels
at HQ
building
Direct
measure
2 5  2027-28
Example:
Clean
heating in
buildings –
phase 1
Replace gas
heating in
HQ building
with air
source heat
pump
Direct
measure
1 150  2029-30
Example:
Clean
heating in
buildings –
phase 2
Replace oil
heating in
main
laboratory
building and
2x regional
offices with
air source
heat pumps
Direct
measure
1 75  2032-33 
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Annual reporting of policies and projects 
9. Other factors influencing emissions 
The other factors that have influenced the body’s emissions in the past or are
expected to in the future are: 
10. Monitoring and reporting 
Governance and management of the Carbon Management Plan: 
Reporting arrangements for the Carbon Management Plan:
Internal:
External:
Carbon reduction policies and projects should be reported annually in mandatory
public bodies climate change duties reports. 
• Estimated total annual carbon savings from all policies and projects
implemented by the body in the reporting year. Use PBCCDR table 3e. 
• Detail the top carbon reduction projects carried out in the reporting year:
provide details of the projects which are estimated to achieve the highest
carbon saving during the reporting year. Use PBCCDR table 3f. 
• Carbon reduction projects for the year ahead: anticipated annual carbon
savings from all projects to be implemented by the body in the year ahead.
Use PBCCDR table 3h. 
• Estimated decrease or increase in emissions from other sources in the
year ahead. If the body’s corporate emissions are likely to increase or
decrease for any other reason in the year ahead, provide an estimate of
the amount and direction. PBCCDR table 3i. 
• Total carbon reduction project savings since the start of the year the body
used as a baseline for its carbon footprint. PBCCDR Table 3j.
Sometimes emissions will increase or decrease due to other factors influencing
the operations of the organisation. This could include such things as significant
changes in the scale of staffing, operations and budgets, changes in office
locations or number of buildings, or ways of working. These contextual influences
on emissions should be reported within the Carbon Management Plan; and also
reported in mandatory public bodies climate change duties reports (PBCCDR
table 3g). 
If significant change takes place, organisations may need to recalculate their
baseline emission and overhaul their Carbon Management Plan. 
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11. Verification and senior leadership declaration 
Verification of the Carbon Management Plan and related reports has been done
using the following: 
An outline of how the Carbon Management Plan is monitored and reported on
should be provided. This can be done as narrative text as a minimum, but can
also include diagrams or tables to help explain structures and processes to a
range of stakeholders. 
Within this section bodies should make it clear how the Carbon Management
Plan will be reported on internally and externally. 
Example text: 
“We collect data from multiple internal and external sources to calculate
our operational emissions. This includes our building facilities
management contractors, travel agent, and our finance and operational
departments. Staff commuting is captured via annual employee surveys….
Data to measure the progress of our CMP is collected quarterly, with
updates provided to relevant working groups and the organisation’s Board,
as well as communicated externally via the organisation’s website, and in
the annual report and accounts.” 
As referenced throughout this guide the body, where relevant, should also use its
mandatory public bodies climate change duties report as a key data reporting
and publication mechanism. The public bodies climate change duties report
requires reporting of Governance, Management and Strategy in Part 2, as well as
detailed annual reporting of emission, targets, policies and projects. The Carbon
Management Plan should feature clearly within the body’s annual mandatory
reports.   
Verification of Carbon Management Plan data and reporting is good practice. For
Carbon Management Plans, this verification could be done internally, by working
with internal auditors, by working collaboratively with peers in the public sector to
undertake peer-to-peer review, or by engaging a third party to provide a
verification or external audit service. For most smaller public bodies, internal
auditing of data should be sufficient and cost-effective. Peer-to-peer review offers
benefits in terms of knowledge sharing and capacity building.   
If verification is undertaken, make reference to this in a statement in your Carbon
Management Plan and in any progress reports. 
Carbon Management Plans should also contain a formal senior level declaration
from the organisation’s Chair or Chief Executive endorsing the Carbon
Management Plan and confirming that all information in the CMP is accurate and
agreed. 
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Leadership Declaration 
I confirm that the information in this report is accurate and provides a fair
representation of the body’s performance in relation to carbon management. 
Name:…....………………………………………………………………….. 
Position:……………………………………………………………………… 
Organisation:.……………………………………………………………… 
Date:.………..……………………………………………………………….. 
Next review due date:………………………. 
Annex B: Climate Change Plan template for local authorities 
The purpose of this template and guidance 
Who is this template for? 
This template is for use by Scottish local authorities (LAs) only. It is intended to help
LAs demonstrate their compliance with the three climate change duties, across their
corporate and area wide boundaries. 
What is the purpose of the Climate Change Plan template? 
This document provides a template of how local authorities should present the action
being taken in respect of their climate change duties in the form of Climate Change
Plans (CCPs). The content of the template is not exhaustive, however it does contain
the areas LAs CCPs should cover in order to demonstrate that they are meeting their
climate change duties. 
LAs are free to develop and structure their CCP, or equivalent, as best suits their
own organisation, for example as a single overarching plan or a series of linked
plans covering different areas. This document is intended to provide an overview of
what LAs’ plan or plans should include, as a minimum, to demonstrate how they are
acting in the way best calculated to contribute to the national mitigation targets and
to help deliver the national adaptation programme, and in the most sustainable way,
i.e. how they are meeting the public bodies climate change duties. 
What should a Climate Change Plan include? 
In developing their CCP, LAs should consider corporate and area wide activities in
terms of mitigation (reducing emissions), adaptation and acting in the most
sustainable way, i.e. they should cover the full scope of the climate change
duties. 
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LA Climate Change Plans (CCPs) should cover:
• corporate (organisational) assets and activities and the emissions
generated by these, including relevant scope 3 emissions
• area wide activities and emissions, many of which will lie outside the control
of the LA but within their sphere of influence. 
The climate change duties require to be met as the body ‘exercises its functions’ –
for LAs, these functions should be taken to include:
• corporate operational functions
• delivery of public services within the authority area
• policy making functions or influence
• discharging of other mandatory duties
• exercise of regulatory powers. 
The CCP therefore needs to be a much more comprehensive plan that one which,
say, considers building and fleet decarbonisation alone. LAs may find, in operational
terms, that the CCP is supported and implemented by a series of targeted policies,
route maps and action plans which lay out the more granular detail for relevant
assets, functions and activities. 
Given the interlinked nature of the climate and biodiversity crises, LAs may wish to
develop strategies or plans that tackle these together. The content of this template
focuses on climate action and sustainability. LAs should follow the available
guidance in relation to biodiversity and nature recovery. Further relevant guidance
may be developed in the future in relation to the proposed Natural Environment Bill
and the proposed statutory targets for nature restoration.   
Climate Change Plan template for local authorities 
1. Introductory information about the LA 
i. Background information about the LA area (high level)
ii. Background information about the council (high level) 
Including, for example: location, geography, population, socio-economic
status and influencing factors, key industries and land use, nationally or
regionally important assets or infrastructure, e.g. regional NHS sites, large
Scottish Water assets, HE/FE institutions, key transport infrastructure. Key
climate vulnerabilities and impacts, such as coastal erosion, drought risk
or flooding, specific to the LA area. 
Overview of the council, including numbers of staff; overview of assets
such as buildings, fleet and social housing; services and delivery (e.g.
waste, social care – procured as contracts or delivered inhouse); other
mandatory duties; and regulatory powers, e.g. planning. Key delivery
partners and stakeholders. 
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iii. Climate policy and implementation (high level) 
2. Developing the Climate Change Plan 
i. Assessment of the current situation – where we are now 
Table: Relationships of scopes across the organisational (corporate) and area-wide
protocols (adapted from the GHG Protocol) 
Scope Definition in relation to
organisational
emissions
Definition in relation to
area-wide emissions
1 Direct GHG emissions
from sources that are
owned or controlled by
the organisation
GHG emissions from
sources located within the
local authority boundary
2 Indirect GHG emissions
from acquired electricity,
heat, steam or colling
consumed by the
organisation
GHG emissions occurring
as a consequence of
using grid-supplied
electricity, heat, steam
and or cooling within the
local authority boundary
3 All other indirect
emissions that are a
consequence of the
activities of the
organisation
All other GHG emissions
that occur outside the
local authority boundary
as a result of activities
taking place within the
local authority boundary 
Brief statement around the climate emergency, action taken to date, key
policies and related strategies (including links to where these can be
found). This could include identifying key relevant national targets,
strategies and policies, and outlining how the council has delivered or
plans to deliver on those, with gaps and exemplar action noted. 
Brief statement about mainstreaming or embedding climate action into the
council’s activities and decisions; note key responsible roles (governance
to be covered in more detail in further sections). 
The LA’s and the LA area’s impact on climate change; and how climate
change is, and will, affect the organisation and region (refer to chapters 5
and 6 of the guidance). 
Emissions: 
Refer to section 5.5 of the guidance and the table below. 
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• Corporate (organisational) emissions – main sources of
emissions both direct and indirect (i.e. including relevant
scope 3 and, where applicable, land based emissions) and
explanatory narrative
• Area wide emissions – main sectoral sources of emissions
(e.g. heating, energy, transport, industry, land use) and
explanatory narrative. Further guidance will be developed
by the Scottish Climate Intelligence Service (SCIS) in the
coming months to assist LAs with this.
• Where the LA and LA area is now, and the gap to net zero,
i.e. areas where action needs to be focused. 
Adaptation: 
Refer to chapter 6 of the guidance.
• Corporate adaptation – main hazards, vulnerabilities and
exposure; key risks and opportunities in relation to assets,
service delivery and fulfilment of LA functions; key partners
and stakeholders. Where relevant, how corporate adaptation
relates to and links with the regional adaptation approach
and plan.
• Area-wide adaptation – main hazards, vulnerabilities and
exposure; key risks and opportunities for the LA area (or
wider region if appropriate) and wider priorities (e.g.
economic development); key partners and stakeholders.
Regional approaches that are already in place or in
development.
• Where the LA and LA area is now; the gap to being a well-
adapted and resilient organisation or region; and the gap in
relation to SNAP3 outcomes. 
Acting in the most sustainable way: 
Refer to chapter 7 of the guidance.
• Corporate sustainability – consideration of wider
environmental, social and economic issues, beyond GHGs
and net zero, e.g. waste, pollution, use of plastics, the
circular economy, equalities and just transition in service
delivery and procurement. Contribution to and alignment with
the National Performance Framework and UN SDGs.
• Area wide sustainability - wider environmental, social and
economic issues; LA area or regional issues such as air and
water pollution, contaminated or abandoned land or
property, health, areas of deprivation, inequalities. Any
specific issues, challenges and opportunities. How the LA
fits into the national picture, contribution to and alignment
with the National Performance Framework and UN SDGs.
Where the LA or LA area is now, and the gap to being a
sustainable and equitable organisation or region.
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ii. Drivers, goals and objectives – where we want to get to 
iii. Impact assessments 
iv. Planned reviews and updates 
This section is about recognising a problem and the causes, and the costs
and benefit of inaction versus cost and benefit of action. This section
needs to enable understanding of why change is needed, and can include
a vision for the future and the local benefits and costs that accrue from
this. It should include consideration of co-benefits and show how climate
action can be used to further wider outcomes and objectives including
improved biodiversity, access to green space, reduced inequalities and
improved health and wellbeing, etc.
• Drivers for developing the plan (corporate and area-wide
aspects)
• Goals and objectives (corporate and area-wide, high level,
outlining what success looks like), covering:
o mitigation – key goals and objectives, including wider
linked objectives, e.g. improved air quality, improved
health and wellbeing, etc.
o adaptation – key goals and objectives, contribution to
delivering the Scottish National Adaptation Plan
(SNAP), wider linked objectives
o acting sustainably – key goals, objectives and
outcomes, links to national priorities, National
Performance Framework outcomes and UN SDGs. 
Note the impact assessments, such as EQIA and FSDA, that have been
carried out in relation to the this plan or plans, and explain how feedback
from the assessments was taken into account as the plans developed.
Where copies of the impact assessments or related information are
available publicly, provide links. 
Briefly note how often this plan will be reviewed and by whom, and note
the frequency of any official update cycle. The review and update
frequency is likely to vary depending on how the LA structures its plan or
plans. For example, if the overarching CCP contains a net zero target of
2045 this is unlikely to require regular review, however the supporting
route maps and action plans on how to achieve this target will need to be
reviewed on at least an annual basis, potentially more frequently.
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3. Boundaries 
Note where the CCP will be published or made available. It is
recommended that, as best practice, LAs should make their high level
plans publicly available. The supporting detailed action plans and risk
assessments, etc., may contain more sensitive information, and it is for
individual LAs to decide whether and how they wish to share these. LAs
are encouraged, in the interests of transparency, to make information
publicly available where it is appropriate to do so. 
In this section, LAs should describe which assets and activities are included in
their CCP in a transparent way. Any exclusions should be noted, along with a
reason for this. Refer to section 8.3.2 in the guidance. 
This section of the template will be updated as the Improvement Plan related to
the Environmental Standards Scotland investigation progresses through the
Parliamentary process. The template will be updated to align with the agreed
actions, specifically in relation to the reporting of scope 3 emissions.  
• Corporate boundaries – the LA should describe how their boundary has
been set, the approach taken and why; list which assets, infrastructure
and activities have been included; and note and explain any exclusions.
The boundary (assets, land and activities) is reasonably expected to
include the built estate including street lighting, landholdings, fleet and
business travel, corporate waste, staff commuting and homeworking, and
procurement. Section 8.3.5.1 of the guidance outlines the ‘baseline’
emission categories LAs are, as best practice, expected to include in their
boundary and reporting on mitigation.  
• Area wide boundaries – the geographical boundary (land and sea), and
within that the sectors, sources and activities that are included. Content
should follow the guidance that will be developed by SCIS. Over the
coming 12-18 months, a standard approach to area-wide boundary and
target setting, planning and reporting for mitigation will be developed in
partnership with SCIS. Boundaries for adaptation may be different from
those for mitigation and may be at a regional level. 
LAs typically own other assets, such as social housing, and provide
services such as municipal waste treatment. Given that these are not
under the direct control of the council (for example in terms of how much
energy a household uses, or how much waste it produces) it is suggested
that these be included within the boundary for the area-wide plan rather
than the corporate plan – noting that the approach to these wider
assets and services is to be developed in partnership with the SCIS,
to ensure a consistent approach is taken by all LAs.
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4. Targets 
i. Corporate targets 
Corporate emission reduction targets 
In this section, LAs should detail out their climate change targets and how these
align with and support other strategic priorities. While such targets should include
those related to emissions reduction, adaptation and acting sustainably, they
could also include broader targets related to, for example, skills and capacity
building. Refer to section 5.4.4 and section 6.4.6 of the guidance.
There are various national policy targets and ambitions in place, for
example around heat in buildings, fleet decarbonisation and the circular
economy. When setting their corporate targets LAs should, as best
practice, align to these; and could show greater ambition where this is felt
to be achievable. 
Corporate emission reduction targets should include, as best practice and
where relevant: 
• an overall net zero target for scopes 1 and 2 (or separate targets
covering both scopes) of no later than 2045, earlier where possible.
Where a target lies far off (such as 2045), bodies are encouraged
to consider ways to help ensure they stay on track such as setting
milestones
• individual targets covering zero direct emissions from cooking and
heating, zero direct emissions from road fleet vehicles (LAs may
find it appropriate to have separate targets for cars, LCVs, HGVs,
etc.) and zero direct emissions from the ferry fleet
• targets related to land use and land use change, in particular where
land based emissions, such as those from degraded peatland, are
a source of direct scope 1 emissions
• targets covering other direct emissions, e.g. from use of machinery
• targets covering waste, e.g. waste to landfill, recycling rates,
circular economy
• targets related to procurement
• targets related to other sources of indirect emissions, such as
business travel, car kilometres travelled, etc. 
Further guidance can be found in section 5.4.4. 
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Corporate adaptation targets 
ii. Area wide targets 
LAs have a statutory duty to help deliver the Scottish National Adaptation
Plan. SNAP3 has five long-term outcomes and 23 objectives. SNAP3
objectives relating directly to LAs’ corporate adaptation include:
• Objective PS1: “Providers of public services have the governance,
culture, skills and resources for and are collaborating in effective
and inclusive adaptation action.”
• Objective PS2: “People can access the public services they need;
and critical assets, systems and networks are resilient to the
impacts of the changing climate.” 
LAs may consider it appropriate to report on progress against a mix of
outcomes and quantitative targets. These could relate to both hard
measures or softer measures such as community resilience building.
Further guidance and resources are provided by Adaptation Scotland. 
Corporate sustainability targets
To act in the most sustainable way, LAs should ensure that sustainable
development principles are built into their decision-making process (refer
to section 7.4 of the guidance). LAs may consider it appropriate to report
on progress towards sustainability outcomes, similar to the approach to
adaptation outlined above. 
Area wide emission reduction targets
Content should follow the guidance that will be developed by SCIS and
shared over the coming months. 
As best practice, LAs are encouraged to aim for net zero on an area
wide basis by 2045, in line with the Scottish national target. LAs are
encouraged to consider milestones, where the overall date lies far off, to
help ensure that they stay on track. 
Area wide adaptation targets
LAs need to consider carefully what adaptation outcomes, targets and
metrics are appropriate to their region, communities and the climate-
related risks and opportunities that they face. 
LAs have a statutory duty to act in the way best calculated to help deliver the
Scottish National Adaptation Plan. SNAP3 has five long-term outcomes and 23
objectives. Depending on context, all of the SNAP3 objectives could relate
directly to area wide adaptation. LAs must consider the SNAP3 objectives
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5. Leadership and Governance 
i. Roles and responsibilities 
ii. Mainstreaming 
iii. Climate considerations in decision making 
they can help to deliver, including though place-based action and
participation in regional collaborations. 
LAs may consider it appropriate to report on progress against a mix of
outcomes and quantitative targets. 
Area wide sustainability targets
LAs need to consider carefully what sustainability outcomes, targets and
metrics are appropriate to their region and communities. They may
consider it appropriate to report on progress against a mix of outcomes
and quantitative targets. 
In this section, LAs should clearly lay out the roles and responsibilities in
relation to delivering their CCP. This should include detailing the
responsibilities assigned to individual roles and teams, and include an
overview of the governance structure and risk management, including
relevant Boards. LAs may find it helpful to illustrate this section with an
organogram. Refer to section 4.3 of the guidance. 
It is essential that climate change and sustainability is embedded
throughout the work of the LA. This section should include consideration
of the climate change duties when exercising functions; integration of
climate change and sustainability into development, planning and
decision-making processes; and reporting on progress. LAs should outline
the processes and structures which ensure climate and sustainability are
embedded across all business areas. 
The LA could also describe organisational culture, and related aspects
such as leadership, training, performance management and objectives,
and staff engagement and communications. 
Refer to section 4.4 in the guidance above. 
In this section, LAs should provide more detail around how climate and
sustainability are taken into account in the decision-making process. They
should note specific tools, impact assessments and or methodologies that
are used, and for what types of decisions. 
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6. Functions and wider influence 
7. Quality assurance and audit 
8. Monitoring and reporting 
In particular in relation to major financial and policy decisions, LAs should
outline the methodology they employ, for example SEA, other impact
assessments, carbon budgets, assessment of whole life carbon and
carbon costs in business cases or options appraisal, and so on. Refer to
section 2.2 and section 4.5 of the guidance. 
Through their varied functions and influence, LAs can have a wide and significant
influence on emissions and climate action far beyond their organisational
boundaries. This section should identify these functions and influence, and briefly
describe how the LA is, and will, help drive climate and sustainability action more
broadly. 
Such functions and influence for LAs will typically include: spatial and transport
planning, service delivery, place-making, investment, infrastructure development,
economic development, funding, regulation, communications, education,
community development, and partnership development and facilitation. 
Refer to section 4.6 and section 5.5 of the guidance. 
It is important that LAs’ climate action is subject to the same robust scrutiny as,
for example, their financial management. LAs should briefly describe their quality
assurance processes and internal audit mechanisms. They could also consider
external verification or audit in relation to their climate action. It is likely that
different processes will be required in relation to corporate and area-wide climate
actions. Refer to section 4.7 of the guidance. 
In line with the necessity to mainstream climate and sustainability action within
the organisation, reporting on these should be embedded in the standard
corporate reporting structure (noting that reporting on corporate and area wide
climate actions should be kept separate). 
This section should briefly describe how performance towards agreed mitigation,
adaptation and sustainability targets and outcomes is reviewed and assessed, for
example via regular Board meetings and use of KPIs, interim targets and short-
term indicators. It should include the processes or actions that will be taken
forward if progress falls off track and detail where the information can be found,
e.g. in corporate reports, and include links to the webpages. 
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Reducing emissions (mitigation) 
9. Corporate emission reductions 
10. Area wide emission reductions 
Any related statutory reporting, including the public bodies climate change duties
reporting, biodiversity duty reporting and social housing reporting (EESSH or its
successor), should be briefly described and links provided. 
Refer to chapter 8 of the guidance. 
In sections 3 and 4.1 above, LAs will have defined their corporate boundary and
laid out their emission reductions targets. Here, further detail should be provided
around how the targets will be achieved. LAs should develop route maps and
action plans as laid out in chapter 5 of the guidance. The route maps and plans
should demonstrate, clearly and quantifiably, how actions and measures have
been assessed in terms of their contribution to meeting targets. The action plans
in particular are likely to be separate documents, and should detail out interim
steps, costs, timescales and dependencies. 
Where the route maps and action plans are separate to this document and are
publicly available, links should be provided. 
Where the information is contained within another strategy or plan, such as
LHEES or heat network plans, LAs should summarise the information briefly here,
and provide links to these separate documents or webpages. 
More detailed guidance on the measures that LAs can take, for example to
decarbonise the heating in buildings or to develop a sustainable travel plan, is
provided in the topic supplements which will accompany this guidance. These
supplements, listed in section 1.4 of the guidance, will be available to view and
download from the Scottish Government website. 
In sections 3 and 4.2 above, LAs will have defined their area wide boundary and
laid out their area wide emission reductions targets. Here, they should outline as a
high level summary only, how these targets will be achieved. The route maps and
plans should demonstrate, clearly and quantifiably, how actions and measures
have been assessed in terms of their contribution to meeting targets. Refer to
section 5.4.3 and section 5.5 of the guidance. 
Where route maps and action plans are separate documents and are publicly
available, links should be provided. 
LAs should note where detail is provided in other strategies and plans, such as
LHEES, heat networks and local housing plans, and provide links to these
separate documents or webpages. 
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Adaptation 
11. Corporate adaptation 
12. Area wide adaptation 
Content should follow the guidance that will be developed by SCIS. 
It is the intention that, through the SCIS, area wide emissions information
will be publicly available via the data platform, ClimateView. The
ClimateView platform provides public-facing dashboards that illustrate
policies, planned actions and expected emission reductions, and will in
effect become ‘live’ area wide net zero plans. 
In sections 3 and 4.1 above, LAs will have defined their corporate boundary and
laid out their adaptation targets and or outcomes. Here, further detail should be
provided around how those targets and or outcomes will be achieved. It is
expected that LAs will undertake climate risk assessments and develop and
implement an adaptation plan in line with the SNAP, as outlined in chapter 6. of
the guidance. These plans should show a clear pathway towards meeting
organisational outcomes and targets. 
Where these are separate to this document and are publicly available, links
should be provided. 
More detailed guidance on the measures that LAs can take, for example to
develop nature-based solutions or adapt buildings to the changing climate, is
provided in the topic supplements which will accompany this guidance. These
supplements, listed in section 1.4 of the guidance, will be available to view and
download from the Scottish Government website in due course 
Resources and support in relation to adaptation planning and action are provided
by Adaptation Scotland. 
In sections 3 and 4.2 above, LAs will have defined their area wide or regional
boundary and laid out their adaptation targets and or outcomes. Here, they
should lay out in more detail how those targets and outcomes will be achieved.
These plans should show a clear pathway towards meeting area wide outcomes
and targets. 
SNAP3 objective C1 is that: “Regional collaborations are driving inclusive,
effective and place-based adaptation action across all of Scotland”. SNAP3
proposes that action at a regional scale includes collaborating on regional risk
and opportunity assessment, adaptation priority setting, and long-term planning
and investment; taking a place-based approach and including diverse
communities as part of action to reduce inequalities. 
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Acting in the most sustainable way 
13. Corporate sustainability 
14. Area wide sustainability 
Annex C: Resources 
This annex collates the resources and sources of additional guidance identified
within this document, plus additional resources which public bodies may find useful.
These are provided for information only. The resources are grouped by topic. Further
resources will be provided in each of the supplements in due course. 
Legislation, statutory duties and impact assessment are highlighted in the section
below for ease of reference. 
Resources and support in relation to adaptation planning and action are provided
by Adaptation Scotland. 
The SCIS will focus on emission reductions. While it is possible that, in the long
term, the remit of the SCIS may extend to include adaptation, there are currently
no plans for it to do so. LAs should not delay area wide adaptation planning and
action based on this expectation. 
In sections 3 and 4.1 above, LAs will have defined their corporate boundary and
laid out their corporate sustainability targets and or outcomes. Here, they should
lay out in more detail how those targets and or outcomes will be achieved. These
plans should show a clear pathway towards meeting organisational outcomes
and targets. 
LAs are likely to have some sustainability plans already in place, for example in
relation to food, procurement and learning settings. There is no need to duplicate
details here: such plans can be briefly referenced in this section, and links to the
individual documents or webpages provided. 
More detailed guidance on the measures that LAs can take is provided in the
topic supplements which will accompany this guidance. These supplements,
listed in section 1.4, will be available to view and download from the Scottish
Government website in due course. 
In sections 3 and 4.2 above, LAs will have defined their area-wide boundary and
laid out their area-wide sustainability targets and or outcomes. Here, they should
lay out in more detail how those targets and or outcomes will be achieved. These
plans should show a clear pathway towards meeting area wide outcomes and
targets. 
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Legislation, statutory duties and impact assessment 
Climate change legislation, duties and statutory guidance 
• Climate Change (Scotland) Act 2009
• Climate Change (Emission Reduction Targets) (Scotland) Act 2024
• Climate Change (Emission Reduction Targets) (Scotland) Act 2019
• Public bodies climate change duties (section 44 of the Climate Change
(Scotland Act 2009)
• Definition of ‘public body’ within the Climate Change (Scotland) Act 2009
(section 3(1)(a) of the Freedom of Information (Scotland) Act 2002 asp 13)
• The Climate Change (Duties of Public Bodies: Reporting Requirements)
(Scotland) Order 2015 – public bodies subject to the duties are listed in
Schedule 1
• The Climate Change (Duties of Public Bodies: Reporting Requirements)
(Scotland) Amendment Order 2020 
• Statutory guidance for public bodies in relation to the climate change
duties (2011), Scottish Government
• UK Climate Change Act 2008 
Wider legislation, duties and statutory guidance 
Best Value
• Best Value in Public Services duty – Scottish Public Finance Manual
• Best value in public services: guidance for accountable officers (2011),
Scottish Government 
• Local authorities’ duty to secure best value (section 1 of the Local
Government in Scotland Act 2003)
• Best Value Guidance, statutory guidance for local authorities in relation to
the Local Government in Scotland Act 2003 (2004), Scottish Government 
Biodiversity 
• Biodiversity duty (Part 1 of the Nature Conservation (Scotland) Act 2004)
• Biodiversity duty reporting (section 36 of the Wildlife and Natural
Environment (Scotland) Act 2011) 
Consumer duty
• Consumer Duty (section 21 of the Consumer Scotland Act 2020)
• Consumer Duty – list of relevant public authorities (Schedule to The
Consumer Scotland Act 2020 (Relevant Public Authorities) Regulations
2024)
• Consumer Scotland 
Environment
• Guiding principles on the environment (section 13 of the UK Withdrawal
from the European Union (Continuity) (Scotland) Act 2021)
• Statutory guidance on the guiding principles on the environment (2023),
Scottish Government
• Circular Economy (Scotland) Act 2024 
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• The Town and Country Planning (Environmental Impact Assessment)
(Scotland) Regulations 2017
• Environmental Assessment (Scotland) Act 2005
• The Conservation (Natural Habitats, &c.) Regulations 1994 
Equalities
• Public Sector Equality Duty (section 149 of the Equality Act 2010)
• Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 –
includes equality impact assessment
• Public sector duty on socio-economic inequality (Part 1 of the Equality Act
2010) – introduced in Scotland in 2018 as the Fairer Scotland Duty
• Fairer Scotland Duty: statutory guidance for public bodies (2022), Scottish
Government
• Duties in relation to island communities (Part 3 of The Islands (Scotland)
Act 2018) 
Human and Child Rights
• Children and Young People (Scotland) Act 2014
• Human Rights Act 1998
• Health and Safety at Work etc. Act 1974
• Scotland Act 1998
• United Nations Convention on the Rights of the Child (Incorporation)
(Scotland) Act 2024 
Impact assessment
• Scottish Government Environmental assessment policy (EIA, HRA and
SEA)
• Business and Regulatory Impact Assessment (BRIA) toolkit – intended for
use by Scottish Government officials but may be of wider interest
• Child Rights and Wellbeing Impact Assessment (CRWIA) – impact
assessment guidance and templates, Scottish Government
• Child Rights and Wellbeing Impact Assessment (CRWIA) – Taking a
children’s human rights approach: guidance (2024), Scottish Government
• Climate Change Impact Assessment (CCIA) - Developing a Climate
Change Impact Assessment Framework – Guidance for local authorities
and public sector bodies, Sustainable Scotland Network
• Consumer Duty impact assessment, Consumer Scotland
• Environmental Impact Assessment (EIA) - Planning Advice Note 1/2013
• Environmental Impact Assessment  (EIA) regulations - Planning Circular
1/2017
• Equality Impact Assessment (EQIA) guidance, Assessing impact and the
Public Sector Equality Duty: Scotland (2016), Equality and Human Rights
Commission
• Habitats Regulations Appraisal (HRA) guidance, NatureScot
• Health Impact Assessment (HIA) guidance and tools, Public Health
Scotland
• Human Rights Based Approach guidance and resources, Scottish Human
Rights Commission
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Adaptation
• Scottish Government’s adaptation policy
• Scottish National Adaptation Plan 2024-2029 (SNAP3, 2024), Scottish
Government
• Scottish National Adaptation Plan 2024-2029: monitoring and evaluation
framework (2024), Scottish Government
• Adaptation Scotland 
• Adaptation Capability Framework, Adaptation Scotland
• Adaptation and the nature emergency report (2023), Climate Change
Committee
• Climate Adapt: Sharing Adaptation Knowledge for a Climate-resilient Europe
• Climate risk - Independent Assessment of UK Climate Risk: advice to
Government for the UK’s third Climate Change Risk Assessment (CCRA3,
2021), Climate Change Committee
• Climate risk - UK Climate Risk
• Climate risk - UK Climate Change Risk Assessment 2022 – Policy paper
(CCRA3), UK Government
• Climate risk - Climate Adaptation Toolkit and Risk and Opportunities Matrix,
Local Partnerships
• Climate risk - Climate Risk Register Guide and Tool for universities and
colleges, EAUC
• Climate risk - Guidance on Scenario Analysis for Non-Financial Companies,
Task Force on Climate-related Financial Disclosures
• Coastal change - Coastal Change Adaptation Plan Guidance (2023), Dynamic
Coast
• Coastal change - Dynamic Coast
• Coastal change - Planning and development: coastal change, NatureScot
• Communicating Climate Change Adaptation: A practical guide to values
based communication (2024), Adaptation Scotland and Climate Outreach
• Flood Risk Management Plans, SEPA
• Island Communities Impact Assessment (ICIA) guidance and toolkit,
Scottish Government
• Strategic Environmental Assessment (SEA) – guidance and templates,
Scottish Government
• Strategic Environmental Assessment (SEA) – planning and development
guidance, NatureScot
• Strategic Environmental Assessment (SEA) – planning guidance, SEPA
• Strategic Environmental Assessment (SEA) - Our roles in Strategic
Environmental Assessment, Historic Environment Scotland 
Procurement
• Sustainable procurement duty (section 9 of the Procurement Reform
(Scotland) Act 2014)
• Statutory Guidance on the Procurement Reform (Scotland) Act 2014
including the sustainable procurement duty 
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• ISO 14909: 2019 Adaptation to climate change – principles, requirements and
guidelines, International Organization for Standardization (ISO)
• Land use - Land Use, Land Use Change and Forestry briefing (2021), UK
Climate Risk
• Land use - Land Use and Climate Change Adaptation in Scotland: Insights
report (2024), Adaptation Scotland
• Leaders Climate Emergency Checklist, Sustainable Scotland Network
• Local Authority Climate Contact Directory, Adaptation Scotland
• Local Climate Adaptation Tool (LCAT)
• Met Office – UKCP18 Guidance: Representative Concentration Pathways
(RCPs)
• Met Office – UKCP e-Learning modules (access by request)
• Met Office – UK Storm Centre 
• A Pathways approach to adaptation planning (2017), Coast Adapt
• Public Sector Climate Adaptation Network (PSCAN), Adaptation Scotland
• Ready Scotland
• Regional Resilience Partnerships, Ready Scotland
• Re-thinking Cultural Heritage and Climate Change Adaptation, Open
Educational Resources, The University of Edinburgh
• SME Adaptation tool – available on the Find Business Support website 
Adaptation partnerships
• Aberdeen Adapts
• Climate Ready Aberdeenshire
• Climate Ready Clyde
• Climate Ready South East Scotland
• Highland Adapts
• Outer Hebrides
• Public Sector Climate Adaptation Network (PSCAN), Adaptation Scotland
• Tayside Adaptation Partnership 
Audit
• Accounts Commission for Scotland
• Auditor General for Scotland
• Audit Scotland
• Auditing Climate Change Our Strategy (2022), Audit Scotland
• Christie Commission Review of Public Services in Scotland (2011), Scottish
Government
• Decarbonising heat in homes report (2024), Auditor General
• Environmental and climate audits on the rise, 10th INTOSAI WGEA survey on
environmental auditing (2021), INTOSAI WGEA
• Financial Reporting Manual (FReM), UK Government
• How the Scttish Government is set up to deliver climate change goals report
(2023), Auditor General
• International Framework: good governance in the public sector, CIPFA
• International Organisation of Supreme Auditing Institutions (INTOSAI)
• Leader’s Climate Emergency Checklist, Sustainable Scotland Network
• Public audit in Scotland 2023-28 (2023), Audit Scotland
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• Public Sector Internal Audit Standards, UK Government
• Scotland’s councils’ approach to addressing climate change report (2022),
Accounts Commission
• Successful Collaborations in the Public Services: the role of internal audit
(2021), CIPFA
• Technical guidance for external auditors, Audit Scotland 
Behaviour change and public engagement
• Scottish Government’s community led climate action policy
• Scottish Government’s community empowerment policy
• Community climate action hubs: contact details, Scottish Government
• Guidance on asset transfers (community empowerment), Scottish
Government
• Influencing behaviours: ISM technical guide (2013), Scottish Government
• Net Zero Nation: public engagement strategy (2021), Scottish Government
• Participatory Budgeting in Scotland - PB Scotland
• Scottish Communities Climate Action Network (SCCAN) and Transition
Network Hub for Scotland 
Carbon management
• ETS - Guidance on the ETS, SEPA
• ETS - Participating in the UK ETS guidance (2024), UK Government
• ETS - UK Emissions Trading Scheme
• ISO Net Zero Guidelines
• Net Zero Public Sector Building Standard
• PAS 2080 Carbon Management in Infrastructure and Built Environment, BSI
• Public Sector Leadership on the Global Climate Emergency (2021), Scottish
Government and Sustainable Scotland Network
• RICS whole life carbon assessment, RICS
• Route to Net Zero Standard, Carbon Trust
• Science Based Targets Initiative (SBTi)
• Scottish City Region and Growth Deals: carbon management guidance for
projects and programmes (2022), Scottish Government
• UK Net Zero Carbon Buildings Standard 
Circular economy
• Scottish Government’s policy on circular economy
• Making Things Last: a circular economy strategy for Scotland (2016), Scottish
Government
• Zero Waste Scotland 
Climate change policy
• Scottish Government’s climate change policy
• Green Industrial Strategy (2024), Scottish Government
• Securing a Green Recovery on a Path to Net Zero: Climate Change Plan
2018–2032 Update (2020), Scottish Government
• Climate Change Committee
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• The Climate Change Committee’s Local Government and the Sixth Carbon
Budget Report (2020)
• Climate X Change – Scotland’s centre of expertise connecting climate change
research and policy
• Intergovernmental Panel on Climate Change (IPCC)
• AR6 Synthesis Report: Climate Change 2023, IPCC
• The Carbon Scenario Tool report, Edinburgh Climate Change Institute (2022)
• The Paris Agreement, United Nations Climate Change 
Climate data: sources
• Adaptation Scotland – Climate change trends and projections
• British Geological Survey - Datasets
• Dynamic Coast
• Forest Research - Climate Change Hub: Home of UK forestry climate change
adaptation guidance
• Forest Research - ForestGALES
• IPCC - Sixth Assessment Report — IPCC
• Local Climate Adaptation Tool (LCAT)
• Met Office - Local Authority Climate Service
• Met Office - Met Office UKCP18 products
• National Trust - Hazard Mapping Tool
• Scottish Public Health Observatory (Scot PHO) - Population or community
health profiles
• SEPA (Scottish Environment Protection Agency) – Flood maps
• UK Climate Risk
• UK Climate Risk - National summaries
• UK Climate Risk Indicators (uk-cri.org)
• UK Government – open data
• UK Government - Flood Risk Management (FRM) Local Plan Districts 
Climate plans and sectoral approaches: examples from the public sector
• Aberdeenshire Council – Climate Change and Sustainability webpage,
includes links to download key documents including the Route map to 2030
and beyond, and supporting Action Plan; and climate risks.
• Creative Scotland – A Climate Emergency and Sustainability Plan for Creative
Scotland (2022)
• Dundee and Angus College – Climate Emergency Action Plan 2021-2026 Our
path to net-zero (2021)
• Dundee City Council – Dundee Climate Action Plan (2019)
• Dumfries and Galloway College – Climate Change Action Plan 2020-2025 
• Forestry and Land Scotland – Climate Change Plan (2021)
• Glasgow City Council – Glasgow’s Climate Plan Our response to the Climate
and Ecological Emergency
• Historic Environment Scotland – Climate Action Plan 2020-2025
• NatureScot – NatureScot Adapts Framework (2024)
• NatureScot – Net Zero Plan (2021)
• NHS Scotland - A policy for NHS Scotland on the climate emergency and
sustainable development (DL (2021) 38)
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• NHS Scotland - The NHS Scotland Climate Emergency Strategy 2022-2026
• Scottish Funding Council, HE/FE sector, Net Zero and Sustainability
Framework for Action (2022)
• Scottish Water – Climate Change Adaptation Plan 2024 (2024)
• Scottish Water – Net Zero Emissions Routemap
• Shetland Islands Council – Climate Change Strategy 2023-2027 and Action
Plan (2023)
• Transport Scotland – Transport Scotland’s Approach to Climate Change
Adaptation and Resilience
• University of Edinburgh – Zero by 2040 Climate Strategy 2016-2026 (2016)
• University of St Andrews – Environmental Sustainability Strategy Net Zero by
2035 (2021) 
Environment and biodiversity
• Scottish Government’s biodiversity policy
• Scottish Government’s environmental assessment policy
• The Environment Strategy for Scotland (2020), Scottish Government
• Scottish Biodiversity Strategy to 2045 (2024), Scottish Government
• Scottish Biodiversity Delivery Plan 2024-2030 (2024), Scottish Government
• CREW Centre of Expertise for Waters – connecting water policy and science
• Environmental Standards Scotland
• Historic Environment Scotland
• NatureScot – Scotland’s nature agency 
Finance
• Scottish Government’s economic policy
• Accounting for Sustainability
• Best value in public services: guidance for accountable officers (2011),
Scottish Government 
• Business case guidance for projects and programmes, HM Treasury
• Carbon valuation, UK Government
• Financial Reporting Manual (FReM), UK Government
• Fiscal Sustainability Perspectives: Climate Change report (2024), Scottish
Fiscal Commission
• Green Book: Central Government Guidance on Options and Appraisal, HM
Treasury
• Green Book supplementary guidance: climate change and environmental
valuation, HM Treasury, UK Government
• Green book supplementary guidance: Valuation of energy use and
greenhouse gas emissions for appraisal, HM Treasury, UK Government
• Guide to Adaptation Finance and developing adaptation finance business
cases, Adaptation Scotland
• International Financial Reporting Standards (IFRS) Foundation
• IFRS S1 General Requirements for Disclosure of Sustainability-related
Financial Information
• IFRS S2 Climate-related Disclosures
• Investment for a well-adapted UK report (2023), Climate Change Committee
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256
• Monetary Valuation of Risks and Opportunities in CCRA3, Report to the
Climate Change Committee as part of the UK Climate Change Risk
Assessment 3 (2021). Paul Wakiss Associates, UK Climate Risk. 
• National Strategy for Economic Transformation (NSET), Scottish Government
• Net Zero Practical Guide for Finance Teams, Accounting for Sustainability
• The role of local government and its cross-sectoral partners in financing and
delivering a net-zero Scotland report (2023), Net Zero, Energy and Transport
Committee, the Scottish Parliament
• Scottish Fiscal Commission
• Scottish National Investment Bank
• Scottish Public Finance Manual, Scottish Government
• Task Force on Climate-related Financial Disclosures (TCFD) 
Health
• Scottish Government’s health and social care policies
• Climate change: health effects in the UK (HECC), UK Health Security Agency,
UK Government
• Global Green and Healthy Hospitals
• Health Care Without Harm
• Health impact assessment (HIA) guidance and tool, developed by Public
Health Scotland
• NHS Scotland - A policy for NHS Scotland on the climate emergency and
sustainable development (DL (2021) 38, Scottish Government
• NHS Scotland - The NHS Scotland Climate Emergency Strategy 2022-2026
• Pathways to a healthy net-zero future: report of the Lancet Pathfinder
Commission (2024), Whitmee, Sarah, et al. The Lancet, Volume 403, Issue
10421, 67-110
• Public Health Scotland
• Public Health Scotland’s adverse weather and health plan 2024-2027, Public
Health Scotland, 2024.
• Scottish Public Health Observatory
• Scottish Public Health Observatory Online Profile tools
• Working together to build climate-resilient, healthy and equitable places: A
briefing for local government and partners (2023), Public Health Scotland 
Just transition
• Scottish Government’s just transition policy
• Adaptation and social justice report (2023), Committee for Climate Change
• Climate Just mapping tool
• Draft Energy Strategy and Just Transition Plan (2023), Scottish Government
• Grangemouth Industrial Cluster – draft Just Transition Plan (2024), Scottish
Government. Stakeholder consultation on Citizen Space. 
• Just Transition - A Fairer, Greener Scotland: Scottish Government response
(2021), Scottish Government
• Just transition for the built environment and construction sector: a discussion
paper (2023), Scottish Government
• Just transition for the Grangemouth industrial cluster: discussion paper
(2023), Scottish Government
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257
• Just transition for the transport sector: a discussion paper (2023), Scottish
Government 
• Just transition in land use and agriculture: a discussion paper (2023), Scottish
Government
• Just Transition Commission 
Land, land use and natural capital
• Scottish Government’s agriculture and the environment policy
• Scottish Government’s forestry policy
• Scottish Government’s policy on land use
• Scotland’s third Land Use Strategy: Land use: Getting the best from our land
2021 to 2026 (2021), Scottish Government
• Carbon credits - Gold Standard 
• Carbon credits - Peatland Code 
• Carbon credits - Woodland Carbon Code 
• Crown Estate Scotland
• Delivering community benefits from land guidance, Scottish Land Commission
• Enabling a Natural Capital Approach guidance, UK Government
• Interim Principles for Responsible Investment in Natural Capital, Scottish
Government
• James Hutton Institute – scientific research and solutions for sustainable land
and resource use
• Land Rights and Responsibilities Statement 2022, Scottish Government
• Land Rights and Responsibilities Protocols (guidance and webinars), Scottish
Land Commission
• Natural Capital Market Framework (2024), Scottish Government
• Reporting on land based emissions - Land Sector and Removals Guidance,
GHG Protocol
• Scottish Forum on Natural Capital
• Scottish Land Commission
• SRUC Scotland’s Rural College 
Place based approaches
• Global Covenant of Mayors for Climate and Energy
• Participatory mapping of climate impacts, Adaptation Scotland
• Place Standard with a climate lens
• Reporting - Greenhouse Gas (GHG) Protocol for Cities
• Reporting - The Global Protocol on Community-Scale Emission Inventories,
produced by the GHG Protocol initiative of the World Resources Institute and
the World Business Council for Sustainable Development
• Scottish Climate Intelligence Service 
Planning
• Scottish Government’s community planning overview
• Scottish Government’s planning and architecture overview
• Community Planning guidance – Community Empowerment (Scotland) Act
2015, part 2 Community Planning: guidance (2016), Scottish Government
• Local Development Planning Guidance (2023), Scottish Government
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• Local Development Planning Guidance – Annex C: Impact Assessments
(2023), Scottish Government
• National Planning Framework 4 (NPF4) 
Procurement
• Scottish Government’s public sector procurement policy
• Public Procurement Strategy: 2023 to 2028 (2023), Scottish Government
• Statutory Guidance on the Procurement Reform (Scotland) Act 2014 including
the sustainable procurement duty
• SPPN3/2022 Public procurement - taking account of climate and circular
economy considerations
• Sustainable Procurement Tools
• Circular procurement guidance, Zero Waste Scotland
• Driving Emission Reductions through the Public Sector Supply Chain: Scope
3 Procurement Emissions report (2023), by Sustainable Procurement Limited
and Aether Limited on behalf of ClimateXChange 
Reporting
• Biodiversity duty reporting guidance, NatureScot
• Biodiversity duty reporting templates, Scottish Government
• Carbon Disclosure Project (CDP)
• Conversion factors for reporting of GHG emissions, UK Government
• GHG Protocol - Greenhouse Gas Protocol 
• GHG Protocol - Corporate Accounting and Reporting Standard
• GHG Protocol - Corporate Value Chain (Scope 3) Standard
• GHG Protocol - Scope 3 Calculations Guidance
• GHG Protocol - Land Sector and Removals Guidance
• GHG Protocol - Greenhouse Gas (GHG) Protocol for Cities
• GHG Protocol - Global Protocol on Community-Scale Emission Inventories,
produced by the GHG Protocol initiative of the World Resources Institute and
the World Business Council for Sustainable Development 
• Global Covenant of Mayors for Climate and Energy
• Guidance for Scottish colleges and universities: Public Bodies Climate
Change Duties Reporting, EAUC Scotland
• International Financial Reporting Standards (IFRS) Foundation
• Local Authority GHG Emissions datasets produced annually as Official
Statistics by the UK Government, under the National Atmospheric Emissions
Inventory (NAEI)
• Net zero manual and other resources, Sustainable Scotland Network (SSN)
• Scottish Climate Intelligence Service
• Streamlined Environmental and Carbon Reporting (SECR), UK Government
• Taskforce on Climate-related Financial Disclosures (TCFD) 
Risk management
• Management of risk in government: framework, UK Government
• Orange Book: Management of risk, HM Treasury, UK Government
• Scottish Public Finance Manual, Scottish Government 
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Sustainable development and equalities
• Scottish Government’s policy on sustainable procurement
• Scottish Government’s community empowerment policy
• Scottish Government’s policy on international development
• Choosing dimensions: the capability approach and multidimensional poverty,
Sabina Alkire (2007), Oxford Poverty and Human Development Initiative,
University of Oxford
• Doughnut economics, Kate Raworth
• Education for Sustainable Development, The Quality Assurance Agency for
Higher Education (QAA)
• Equality and Human Rights Commission
• Equality Trust
• Food for Life
• Guidance on asset transfers (community empowerment), Scottish
Government
• Health impact assessment (HIA) guidance and tool, developed by Public
Health Scotland
• How to Apply the Capability Approach to Housing Policy? Concepts, Theories
and Challenges (2020), Housing, Theory and Society, 37(3), pp. 257–277. 
• Human Rights - Scottish Government’s human rights policy
• Human Rights - Scottish Human Rights Commission
• Human Rights - The European Convention on Human Rights
• Human Rights - Taking a children’s human rights approach: guidance (2024),
Scottish Government
• Local food for everyone: our journey (2024), Scottish Government – the local
food strategy
• National Performance Framework
• Participatory Budgeting in Scotland - PB Scotland
• Planetary Boundaries, Stockholm Resilience Centre, Stockholm University
• Planetary boundaries - A Good Life for All Within Planetary Boundaries
project, University of Leeds
• Principles for Sustainable Land Use, Scotland’s third Land Use Strategy: Land
use: Getting the best from our land 2021 to 2026, Scottish Government
• Sustainable development impact assessment (SDIA) tool developed by the
Scottish Parliament (available to download and use)
• “Target 2030” A movement for people, planet and prosperity, Learning for
Sustainability: action plan 2023 to 2030 (2023), Scottish Government
• UK Shared Framework for Sustainable Development, Sustainable
Development Commission
• United Nations - United Nations Sustainable Development Goals (UN SDGs)
• United Nations - CRC/C/GC/26: General Comment No. 26 (2023) on
children’s rights and the environment with a special focus on climate change
(2023), United Nations Human Rights Office of the High Commissioner 
Theory of Change
• Center for Theory of Change
• Mapping Change Using a Theory of Change to Guide Planning and
Evaluation (2018), GrantCraft
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• Theory of Change UNDAF Companion Guidance, United Nations
Development Group
• The Theory of Change Process – Guidance for Outcome Delivery Plans, 
Government Analysis Function, UK Civil Service 
Training
• Carbon Literacy Project
• Climate Solutions courses, Royal Scottish Geographical Society
• National hub for the retrofit of traditional buildings, Historic Environment
Scotland
• Sustainable Procurement Tools
• Becoming Climate Resilient training, Sniffer 
Travel and transport
• Scotland’s National Transport Strategy 2 (2020), Transport Scotland
• Commuter Emission Calculator, Zero Waste Scotland
• Commuting Survey Guide and Tool for the post-16 education sector, EAUC
• Domestic and International Student Relocation Travel Emissions Calculator
Tool, Sustainability Exchange, EAUC
• Transport Scotland – the national transport agency for Scotland 
Waste and recycling
• Digital waste tracking across the UK, UK Government
• Waste regulations, guidance and data, SEPA
• Zero Waste Scotland 
Wellbeing economies
• Scottish Government’s economic policy
• National Strategy for Economic Transformation (NSET), Scottish Government
• Wellbeing Economy Monitor (2022), Scottish Government
• Wellbeing economy toolkit: supporting place based economic strategy and
policy development (2022), Scottish Government
• Applying Resilience Thinking: Seven principles for building resilience in socio-
ecological systems, Stockholm Resilience Centre
• Institute for Social Capital
• New Economics Foundation
• Schumacher Centre for a New Economics
• Stockholm Resilience Centre, Stockholm University
• Towards an EU Wellbeing Economy – A fairer, more sustainable Europe post
Covid-19 (2020), WWF
• Wellbeing Economy Alliance
• Wellbeing Economy: an effective paradigm to mainstream post-growth
policies?  Ecological Economics, Volume 192, 2022, 107261
• Wellbeing Economy Expert Advisory Group, Scottish Government
• Wellbeing Economy Governments (WEGo), Scottish Government webpage
• Wellbeing Economy Governments (WEGo), Wellbeing Economy Alliance
webpage
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• Wellbeing Economy Ideas for Cities: Lessons for Implementation, Journal of
City Climate Policy and Economy, 2024 2:2, 189-203 
Annex D: References 
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3  Chief Medical Officer for Scotland. Annual Report 2022–2023. Realistic Medicine:
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11 Institute of Health Equity. Health Equity in England: the Marmot Review 10 years
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35 Victor Roezer and Swenja Surminski. New build homes, flood resilience and
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40 Paul Watkiss Associates. Monetary Valuation of Risks and Opportunities in
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41 Examples include: National Parks (Scotland) Act 2000 (section 1); Land Reform
(Scotland) Act 2003 (sections 34, 38, 51, 71, 74, 77); Local Government in Scotland
Act 2003 (sections 1(5), 13(6)(e)(i)); Further and Higher Education (Scotland) Act
2005 (section 20); Transport (Scotland) Act 2005 (section 5); and Police and Fire
Reform (Scotland) Act 2012 (sections 37 and 113). 
42 Ishani Erasmus. Sustainable Development Thinking: disrupting business as usual
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59 Ishani Erasmus. Sustainable Development Thinking: disrupting business as usual
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61 Jo Smith. Planning peatland windfarms with carbon calculations. University of
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62 Jenni Monet. ‘Green colonialism’: Indigenous world leaders warn over west’s
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