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Climate Change Board Update & Decarbonisation Tracker

Argyll and Bute Council · 21 August 2025
Back to Policy and Resources Committee — 21 August 2025 and its agenda

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ARGYLL AND BUTE COUNCIL         POLICY & RESOURCES COMMITTEE
CLIMATE CHANGE BOARD               21st AUGUST 2025 
CLIMATE CHANGE BOARD UPDATE & DECARBONISATION TRACKER 
1.0 EXECUTIVE SUMMARY  
1.1 This report provides the Committee with an overview and update of recent
activity completed or underway by the Climate Change Board. Included in the is
an update is an insight and commentary around evolving national climate
change policy landscape, focusing on the recent Scottish Government (SG)
consultation on new statutory guidance for Public Bodies' Climate Change
Duties. It details the key implications for the Council and outlines our proactive
and strategic response.  
1.2     Furthermore,  the Council submitted a comprehensive and constructive
response to the SG consultation, highlighting key considerations for rural and
island authorities to help shape workable national policy. This response
recommended phased implementation of new duties and emphasised the
need for practical support from government.  
1.3    The report provides also highlights examples of the Council's integrated
approach to climate action, where resilience and emissions reduction are
addressed simultaneously. These include the innovative, low-carbon
engineering works at the Burnett Building and the strategic use of Nature
Restoration Funding to assess our land assets for both carbon sequestration
and climate adaptation benefits. 
1.4    An update from the Council’s Decarbonisation Tracker confirms tangible
progress across several key workstreams, including building energy
efficiency, fleet transition planning, and the foundational work required to meet
future mandatory Scope 3 reporting duties. 
1.5    The report concludes by reaffirming the Council’s clear understanding of its
evolving duties and its commitment to a pragmatic and evidence-based
strategy that is tailored to the unique context of Argyll and Bute, ensuring we
are well-positioned to meet future obligations.

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2.0  RECOMMENDATIONS 
2.1  That the Policy and Resources Committee is asked to:
2.1.1  Note and consider the contents of this report and the key implications for the
Council arising from the Scottish Government’s consultation on new statutory
guidance for Public Bodies' Climate Change Duties. 
2.1.2  Note and consider the updates from the Climate Change Board including Drax
LED installations, SG Consultation on draft Statutory Guidance for public bodies,
Burnett Building Climate Adaptation, the Nature Restoration Fund Initiative, the
climate change focussed work of the CPP, and the developments in the Kilmory
grounds with ACT.

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ARGYLL AND BUTE COUNCIL      POLICY & RESOURCES COMMITTEE
CLIMATE CHANGE BOARD         21st AUGUST 2025 
CLIMATE CHANGE BOARD UPDATE & DECARBONISATION TRACKER 
3.0 INTRODUCTION 
3.1  Since the last report to Policy & Resources Committee the Climate Change
Board, including the Policy Lead for Climate Change and Environment, has
continued to oversee and deliver relevant Climate Change activity. Main areas
of activity include:  
3.2     Consultation on draft Statutory Guidance for public bodies Response 
As outlined in the other report on today’s agenda titled CLIMATE CHANGE
BOARD - PERFORMANCE REPORT & PUBLIC SECTOR DUTIES RETURN,
the Council recently received confirmation and feedback on its annual carbon
footprint via the Public Bodies Climate Change Duties report.   
3.3 The Scottish Government recently concluded a comprehensive consultation on
new draft statutory guidance for Public Bodies' Climate Change Duties. This
consultation represents the first major update to the statutory framework since
2011, significantly expanding the expectations and requirements placed on
public bodies including local authorities.  One of the key activities of the
Climate Change Board over the past quarter has been to respond
comprehensively to this consultation due to its wide-ranging ramifications and
implications for resourcing.    
3.4 The proposed guidance introduces mandatory comprehensive Scope 3
emissions reporting from November 2027 and places a stronger emphasis on
area-wide climate action, comprehensive adaptation planning, and
sustainable development. This report outlines the Council's response to this
evolving context and details the proactive work already underway that aligns
with this new strategic direction. 
3.5 The Council submitted a comprehensive formal response to the consultation,
contributing to the development of workable national policy by highlighting key
considerations for rural and island authorities.
3.6 The submission recommended phased implementation approaches to ensure
successful delivery and to allow organisational capacity to be built over time. It
also emphasised the need for practical, simplified tools for impact assessment
that can be used effectively by non-specialist staff.
3.7 The response focused on constructive solutions to ensure the final guidance,
when published, can be successfully implemented across all of Scotland's

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diverse local authorities, balancing national ambition with local operational
realities.
3.8 The recent consultation on new statutory guidance signals a fundamental shift
in the scale and nature of the Council’s climate change duties, moving from a
position of guidance to one of legal compliance. The introduction of legally
binding Carbon Budgets, for instance, will require a far more rigorous and
structured approach to performance management than is currently in place.
Our analysis of the draft guidance shows that meeting these enhanced
requirements will demand substantial new investment in resources,
particularly for developing robust data collection and management systems.
Furthermore, the move towards mandatory reporting of Scope 3 emissions,
especially for our complex supply chain, underscores the urgent need to build
internal capacity and specialist expertise in carbon accounting and data
analysis to ensure the Council can meet its future statutory obligations.
4.0 STRATEGIC CLIMATE ACTION EXAMPLES & ACTIVITY OF CLIMATE
CHANGE BOARD 
4.1 The Council's approach to integrated climate action is demonstrated through
several current initiatives that combine adaptation and mitigation objectives
within single interventions. This approach reflects the emerging concept of
"Adaptive Mitigation," which places equal strategic emphasis on building
resilience to climate impacts while achieving proportionate emissions
reduction within local operational realities.
4.2 Burnett Building Climate Adaptation Project
4.2.1 The Burnett Building intervention on Campbeltown's waterfront provides a
practical example of climate adaptation in action. Built in 1899 on reclaimed
land, the building has experienced structural challenges directly attributable to
current climate change impacts including rising sea levels, intensified rainfall
patterns, and saltwater intrusion.
4.2.2  The Council's response utilised innovative, low-carbon engineering solutions
through GEOBEAR's geopolymer injection technique. This achieved structural
stabilisation while delivering significant carbon savings of approximately 50.7
tonnes, a reduction of nearly 78% compared to traditional methods. Crucially,
this solution is not only carbon efficient but also cost efficient compared to
traditional methods and lends itself well to future similar projects.
4.2.3 The project provides a replicable model for other coastal heritage assets
facing similar climate pressures, demonstrating the practical integration of
adaptation and mitigation in operational decision-making.
4.3 Nature Restoration Fund Initiative
4.3.1 The Council has agreed Phase 1 funding from the Nature Restoration Fund to
begin a comprehensive assessment of Council land assets. This initiative
demonstrates strategic integration of carbon sequestration, biodiversity
restoration, and climate adaptation through nature-based solutions.
4.3.2 The programme will establish quantified baselines for sequestration potential
and climate adaptation benefits across suitable Council land holdings. This

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dual-purpose approach ensures enhancement projects deliver measurable
outcomes against both mitigation and adaptation objectives while supporting
biodiversity recovery targets and building internal capacity for natural asset
management. 
5.0 DECARBONISATION TRACKER UPDATES
5.1 The Council maintains routine progress monitoring through its
Decarbonisation Tracker system. The latest update confirms tangible
progress on estate energy efficiency, including the rollout of enhanced
building management system controls and the installation of renewable heat
pilots, such as Air Source Heat Pumps, to gather performance data for future
capital programmes. The Council have installed 4G communications systems
at 33 sites, primarily schools, enabling remote access to Building
Management Systems (BMS). This technology allows for quicker, more
efficient, and more effective methodology for monitoring and energy
management activities. Additionally, the team has completed the installation
of Thermostatic Radiator Valves throughout Cardross Primary School, Islay
High School, and Dunbeg Primary School. These installations provide
improved temperature control and energy efficiency in these educational
facilities.
5.2 In transport, fleet optimisation measures are being implemented, including
targeted driver efficiency training and route analysis to reduce fuel
consumption. This work complements ongoing transition planning for vehicle
electrification.
5.3 To prepare for future mandatory Scope 3 reporting, foundational work is
underway, including the development of a sustainable procurement charter to
engage our supply chain and initial scoping for the required data systems.
5.4 The tracker system is also used to proactively monitor and manage
operational risks, such as national supply chain pressures and changes to
external funding landscapes, allowing for adaptive forward planning. 
6.0 COMMUNITY PLANNING PARTNERSHIP CLIMATE ACTIVITIES
6.1 The Council's climate work includes comprehensive Community Planning
Partnership arrangements, recognising that effective climate action requires
coordinated effort across multiple agencies and community stakeholders
alongside the Council's own operational activities. The CPP has established
dedicated governance structures including Climate Change Working and
Steering Groups, supported by a dedicated Climate Change Project Manager to
coordinate partnership activities.
6.2 The partnership has developed the Argyll and Bute Climate Action Strategy,
funded by CPP partners including the Council, with project leadership hosted by
Argyll Countryside Trust. This comprehensive strategy received formal approval
in April 2025, establishing a region-wide, community-led approach to achieving
net-zero and climate resilience through extensive engagement with communities
and stakeholders across Argyll and Bute.

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6.3 The strategy establishes the vision that "We make Argyll and Bute climate ready
by acting together to understand and adapt to our changing climate." The CPP
maintains a dedicated climate change signposting page providing information
and resources, alongside monthly climate funding opportunity searches to
support community and partnership climate action initiatives.
6.4 This collaborative framework ensures that Council climate actions align with
broader community objectives while maximising impact through coordinated
delivery across multiple agencies. The partnership approach recognises that the
most significant climate challenges and opportunities extend beyond individual
organisational boundaries and require collective action to achieve meaningful
progress towards regional climate resilience and net-zero objectives. 
7.0 DRAX FOUNDATION: LED LIGHTING PROGRAMME FOR SCHOOLS
7.1 The Council has successfully partnered with the DRAX Foundation to deliver a
fully funded programme to upgrade lighting to energy-efficient LEDs in seven
schools located in the area surrounding Cruachan Power Station. At the time of
writing this report, the installation programme is reaching its successful
conclusion.  This represents a strategic investment of partnership funding of
approximately £148,000 to make Council’s learning estate more energy efficient. 
We will continue to work with DRAX and other similar partners to develop future
projects.  
7.2 The upgrades have been completed at Park Primary School, Taynuilt Primary
School, Inveraray Primary School, Dunbeg Primary School, Dalmally Primary
School, Barcaldine Primary School, and Lochnell Primary School. This initiative
not only delivers significant energy efficiency savings, contributing to the
Council's decarbonisation targets, but has also substantially improved the
quality of the learning environment for pupils and staff across these sites. The
Council is grateful to the DRAX Foundation for their generous support in
delivering this valuable project. 
8.0 WOODLAND MANAGEMENT PLAN FOR KILMORY
8.1 Argyll and Bute Council has commissioned Argyll Countryside Trust (ACT) to
prepare a Woodland Management Plan for Kilmory Woodland, including a
proposal for the restoration of Kilmory Walled Garden. The Woodland
Management Plan will provide a comprehensive baseline review of Kilmory
Estate’s woodland resource and recommendations for future management.  It
will address the barriers communities face to regularly visiting and benefitting
from the woodlands. The plan will focus on encouraging more use and
enjoyment of the woodlands by local people.  It will draw together the unique
combination of activities and interests within and around the woodland park,
including productive forestry requiring assessment, access routes, outdoor
learning, social enterprise, a rainforest hub, volunteer activity, a prize plant
collection in the Victorian walled garden, development of a business park, and
Argyll and Bute Councils’ headquarters.
8.2 ACT will also prepare a phased and costed restoration plan for Kilmory Walled
Garden, including a detailed plant inventory utllising historical records and
detailed tree and vegetation surveys, a proposed programme of works including
establishing a tree risk assessment process, and a volunteer engagement

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strategy. The plans will be completed within 12 months of commissioning in
June 2025
9.0 CONCLUSION
9.1 This report demonstrates the Council’s clear understanding of the evolving
statutory climate duties and its proactive stance in preparing for them. Our
strategic approach provides a robust framework for action that is tailored to the
unique context of Argyll and Bute.
9.2 Practical examples such as the Burnett Building and Nature Restoration Fund
initiatives show this strategy in action, delivering integrated and cost-effective
solutions that build resilience and reduce emissions simultaneously. This
evidence-based approach ensures the Council is well-positioned to meet its
future obligations in a way that is both responsible and delivers lasting value for
our communities 
10.0 IMPLICATIONS
10.1 Policy The final statutory guidance will necessitate a review
of the Council’s climate-related policies to ensure full
compliance and will inform the continued
development of the Net Zero Route Map.
10.2 Financial New duties, particularly around adaptation and
Scope 3 reporting, will have resource implications.
Proactive work on externally funded projects (e.g.,
Nature Restoration Fund) and cost-efficient solutions
(e.g., Burnett Building) demonstrates a commitment
to prudent financial management.
10.3 Legal The report outlines the evolving legal duties for the
Council under the Climate Change (Scotland) Act
2009, as shaped by the new statutory guidance.
10.4 HR As noted in the consultation response, meeting the
new duties will require ongoing upskilling and
capacity building across services, which will be
integrated into existing professional development
frameworks
10.5 Customer Service The Community Planning Partnership provides a
public-facing resource via its climate change
signposting web page, enhancing access to
information for residents.
10.6 Risk The report identifies and addresses climate-related
risks (e.g., infrastructure vulnerability at the Burnett
Building) and the strategic risks associated with non-
compliance with evolving statutory duties. The
Decarbonisation Tracker is used to monitor and
manage operational delivery risks.

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10.7 Climate Change The entire report is dedicated to outlining the
Council's strategic response to its climate change
duties, covering mitigation, adaptation, and
sustainable development.
10.8 Fairer Scotland Duty 
10.9 Equalities – protected
characteristics
The principles of a Just Transition are embedded in
the strategic approach, ensuring climate actions are
developed and implemented equitably.
10.10 Consumer Duty The Council's consultation response explicitly
considered socio-economic impacts, and the
Community Planning Partnership's community-led
strategy ensures local needs are central to climate
action.
10.11 Island Communities The consultation response specifically highlighted
the unique challenges and considerations for our
island communities.
10.12 Children’s Rights and
Wellbeing
The proactive approach to building a climate-
resilient and sustainable region supports the general
principles of protecting the wellbeing of children and
future generations. 
Douglas Hendry, Executive Director with responsibility for Commercial
Services 
Policy Lead Climate Change & Environment, Councillor Luna Martin 
For Further Information:-
Ross McLaughlin, Head of Commercial Services 
Helensburgh and Lomond Civic Centre
ross.mclaughlin@argyll-bute.gov.uk 
APPENDICES
Appendix A - Climate Change Decarbonisation Tracker – July 2025
Appendix B – Climate Change Draft Guidance Consultation Response

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Appendix A – Climate Change Decarbonisation Plan Tracker – July 2025 
ACTION  LEAD (L) AND
PARTNERS 
TARGET or
MILESTONE 
FUNDING  COMMENTS  
W1 –Develop and Implement Waste
Strategy 
(L) Roads and
Amenity Services,
Community,
commercial
customers 
Implementation of the
Waste Strategy
transitioning to Landfill
ban compliant
Residual Waste
Recovery solutions by
2025. 
External funding and support being
sought from the Scottish Government 
Please see Environment, Development
& Infrastructure Reports – links below: 
WASTE UPDATE.pdf (argyll-
bute.gov.uk) Waste Update – EDI
committee 20/6/24 
GENERAL WASTE UPDATE.pdf EDI
committee 12/9/24 
Environment, Development and
Infrastructure Committee 19/12/24 –
Waste Landfill Ban Update
WASTE LANDFILL BAN UPDATE 
Environmental, Development and
Infrastructure Committee – Waste
Landfill Ban Update 19/6/25
WASTE LANDFILL BAN UPDATE 002
004.pdf
W2 – Promote the Waste Hierarchy
through community Education  
(L) Roads and
Amenity Services 
Evidence of
community Education 
Not secured  New Web content and Education
materials for Primary and Secondary
Schools were developed and delivered
to online Education Environment
Summit October 21 and the COP 26
Event on the 6th November 21. Advised
that this action has paused/stopped. 
W3 – Reduce Council use of disposable
and single use plastics across all
departments and settings  
(L) Procurement and
Commercial
Services, all Council
Services  
Adoption of new
working practices and
procurement 
No specific funding in place, research
required to impact on operation costs  A report on Single Use Plastic went to
the Policy and Resources Committee on
9 December 2021, and the following
recommendations were approved: 
• Note and consider that the
various Services that currently

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purchase SUP products consider
whether these products are
essential or if there is a potential
alternative that would meet the
Service requirements, prior to
orders being placed via PECOS or
contacting the Procurement,
Commercial and Contract
Management Team (PCCMT) for a
procurement process to be carried
out. 
• Note and consider that the
Sustainable Procurement Policy will
be updated to reflect the Climate
Change Board desire to limit SUP
where possible –wording has been
included in the Annual Review
2023/2024 version of the
Procurement Strategy 2022/2025 as
follows: “To provide procurement
support to any strategic decisions
taken by the Council in relation to
the usage of Single Use Plastic
products and their recyclability.”  
• Note and consider that the
Commodity Sourcing Strategy
templates used for Regulated
Procurements have been updated to
include a question regarding SUP. 
Changes in legislation were brought into
force by the Scottish Government on the
1st June 2022 restricting single-use
plastic cutlery, plates, straws, drink
stirrers and balloon sticks, expanded
polystyrene food containers and
expanded polystyrene cups and other
beverage containers, as well as all

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products made of oxo-degradable
plastic.   
Some products already changed and
others under review.  
W4 – Extend and explore pre-ordering
for school food to reduce food waste 
(L) Commercial
Services
and  Education  
Evidence of extension
of pre-ordering & food
waste reduction 
Project funded and solution procured  Full implementation of Cashless
Catering and Pre-ordering system is
completed. 
E1 – Deliver Renewable Sourcing
Strategy 2 
(L) Commercial
Services  
Adoption of Strategy  RSS2 consultancy work funding to be
confirmed; expectation is that project
implementation will be through
combinations of prudential borrowing
(subject to business case approvals)
and/or external funding.  
RSS2 next stage development work
includes specification development
and preparation of invitation to tender
for specialist consultancy support.
Current work in progress; intended to
be market tested early 2024.  It is now
considered that RSS2 will be included
within the Net Zero Routemap.
Following limited response from
hubNorth and some discussions with
other potential providers, we have
gone to the market with a further RFI
and responses received in June 2024
will be used in the development of the
procurement strategy for Argyll & Bute
Council Net Zero Routemap. 
Net Zero Route Map is currently being
rescoped following returns of RFIs.
Opportunities to take a refined set of
offers to the market are currently being
explored. It is expected the NZRM will
be co-developed in-house alongside
specialist external partner/s. 
The Council is in an advanced stage of
developing a comprehensive Net Zero
Route Map that is currently in draft
form and will be subject to an
engagement and approval process in
due course. Once ratified, this will

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replace our existing decarbonisation
plan and provide the structured
delivery mechanism for our climate
change priorities. 
E2 – Delivery of Non-domestic Energy
Efficiency Framework (NDEEF) Projects    
(L) Commercial
Services  
Evidence of delivery of
projects 
Project development work is funded by
combinations of the Scottish
Government and the procured provider
(costs absorbed within the tender
process).  
Funding for project implementation will
come from Council approved capital
allocations: 
• Climate Change 20/21 - £500K 
• Climate Change 21/22 - £600K 
• Asset Sustainability –  £175K 
Non Domestic Energy Efficiency Fund
(NDEEF1) Energy Performance
Contract was signed on 16 July 2021
(circa £1.25m investment with 10 year
payback). The originally intended mini
project list has been fully delivered.
Following on from the P&R Committee
report in May 2023: May PR - Climate
Change -NDEEF Progress update.pdf
(argyll-bute.gov.uk), four final mini
projects, which were added as contract
variations, remained to be implemented.
Tarbert School LED lighting was
installed in the 2023 school summer
recess; Kilmory Nursery solar pv was
installed in September 2023; the
intended low carbon heating solution
and pv installation at Cardross PS have
been intentionally delayed whilst we try
to access a recently launched funding
scheme: Scotland’s Public Sector Heat
Decarbonisation Fund | Salix
Finance.  A bid was submitted by the
5/12/23 fund deadline (value £460K with
the Council needing to contribute 20% of
that). Bid outcomes will be
communicated February 2024.  Bid was
unsuccessful and subsequently £150k of
funding which was in the 2025/26 capital
plan for a replacement heating system
has been brought forward. Delivery of
the high efficiency heating system will
be Summer 2024. High efficiency
heating system installed and
commissioned during Summer 2024

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including full BEMS controls upgrade
and 4G wireless router install for remote
monitoring of system and optimisation of
performance. 
86kW roof mounted solar PV system
installed and commissioned at Cardross
Primary School during October 2024
school holidays. This was the final
NDEEF1 mini project and now
concludes the installation phase of this
project. The Monitoring and Verification
(M+V) Phase undertaken by the
independent M+V Specialists EEVS
Insight Ltd will run until Q3 2025. The
final 15% contract retention payment will
be released on successful independent
verification of the Investment Grade
Proposal (IGP) energy savings. 
In addition to the above, the
procurement sourcing strategy for the
next batch of sites, using designation
NDEEF2, is under way.  A spend to
save investment of £2Million is being
targeted.  Awaiting formal Scottish
Government launch of new NDEEF
framework which is currently expected
Oct 2024.  Launch date of new
framework now anticipated to be
Jan/Feb 2025. 
New NDEEF framework delayed until
Oct 2025 at the earliest.
Approximately £1M of spend to save
investment on energy efficiency
projects is now being targeted to be
delivered.

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E3 – Delivery of additional solar
installations at Council assets    
(L) Commercial
Services  
Evidence of delivery of
projects 
Consultancy work funding to be
confirmed; expectation is that project
implementation will be through
combinations of prudential borrowing
(subject to business case approvals)
and/or external funding. 
Best solar pv opportunities are being
delivered within NDEEF (Ref item E2)
and advantage is also being taken to
install solar pv solutions within the asset
sustainability capital programme where
possible  e.g. as a component of roof
upgrades. 
The potential for a large solar pv ground
array at the Kilmory Estate is currently
being limited due to electric grid
constraints – engagement with SSEN is
ongoing to try to identify solutions. 
The Council now has 27no solar pv
installations in operation amounting to
over 1.3MW capacity. 
DRAX have offered installation of free
solar pv at Dalmally PS as part of the
community benefits flowing from the
planned expansion of Ben Cruachan
power station. Discussions have been
going on from June 2024. 
No significant updates on DRAX solar
offer except the Dalmally proposal has
been deemed not-financially viable by
DRAX. Alternative sites or technologies
are currently being considered.   
DRAX have given initial support to a
request to fund a replacement PV
system at Taynuilt Primary School. A
costed quote is now required from the
council to secure the funding circa £26k 
E4 – Delivery of Water Efficiency Audits
across our Estate 
(L) Commercial
Services  
Evidence of delivery of
projects 
Works items are generally small scale
and are being funded through existing
approved budgets where possible;
Significant Council wide asset
verification exercise and ensuring water
use minimised.

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otherwise costs will be met from savings
generated. 
The asset verification element of this
project is substantially complete and
substantial savings have been identified
and recovered. A case study is being
prepared to demonstrate the range of
tasks undertaken and to convey the
scale of savings made and refunds
received. The final stage of work
involves an exercise to reduce water
consumption (with carbon emissions
reduction) over a number of sites and is
underway.  Program to introduce Water
efficiency measures has commenced
and will be complete by Q1 2025. Costs
finalised and a program developed for
the introduction of water efficiency
measures focussing on reducing
consistent excessive consumption at
public toilets. Material water savings
have been identified and recovered, with
a focused programme to introduce water
efficiency measures set to conclude by
Q1 2025. 
Program to reduce water use at
public toilets ongoing and will now
run until Q4 2025.  
E5– Delivery of Energy Efficiency
Scotland Programme 
(L) Housing
Services, Registered
Social Landlords  
Evidence of delivery of
projects 
Funding amounts are determined by
localised factors and is paid as
a  proportion of the Scottish
Governments’ Heat In Buildings
Strategy   
In July 2025 Argyll and Bute Council
was awarded a Grant of  £2,229,827
through the Scottish Government’s
Energy Efficient Scotland – Area Based
Scheme (ABS) to facilitate the
installation of insulation measures to
privately owned and privately rented
properties in mainland and island
addresses throughout Argyll and Bute. 
Non-means tested grants of between

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£9,000 and £21,600 are available to
eligible households for the application of
insulation, helping to significantly reduce
household consumption of energy on a
“Fabric First” basis contributing towards
the Scottish Government’s carbon
reduction targets.    The Council also
continues to investigate avenues to work
in partnership with RSLs in Argyll and
Bute.  Whilst these carbon reductions do
not contribute directly to the Council’s
Decarbonisation Plan they help to
reduce carbon usage across Argyll and
Bute. 
E6 – Complete LED streetlight
replacement programme 
(L) Roads and
Infrastructure
Services 
Evidence of delivery of
projects 
Fully funded through prudential
borrowing 
The Council has 14442 streetlights in
total so carbon emissions have already
been greatly reduced by the LED
Upgrade Project. 
Now only limited numbers of wall
mounted and decorative / heritage style
lanterns / luminaires require to be
converted to LED. These works should
be completed this financial year
2025/26.
In 2015/16, figures were CO2 totals –
3140 tonnes.   
2024/25 emissions were 720 tonnes in
total.  Year to date (end of May 2025)
carbon totals – 90 tonnes.  
E7 – Continue support of ABRA and
review Renewable Energy Strategy
annually 
(L) Economic
Development 
Evidence of delivery of
projects 
Officer resource to support currently
funded 
ABRA met in October 2024 and
reviewed the REAP, a revised Action
Plan is being prepared.  ABRA met May
2025. SSE Networks continue upgrade
works to transmission grid to

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275kv.    Carbon Neutral Islands Capital
Fund projects for 2024/25 continue to
progress and applications are being
prepared for 2025/26 funding. Work has
commenced on a review of Council
guidance on community benefits
associated with renewable
developments and will be informed by
the Scottish Government review which
started early in 2025. 
E8 – Continue support for offshore
development of renewables 
(L) Economic
Development 
Evidence of delivery of
projects 
(expected late
2020s/early 2030s) 
Officer resource to support currently
funded 
Scottish Power Renewables are
progressing the Machair Wind project
and ESB are progressing Malin Wind,
both are expecting to seek consent
during the mid-2020s with generation
commencing in the early 2030s.  
T1 – Develop a Fleet Replacement
Strategy supportive of fuel efficient,
electric and hybrid vehicles    
(L) Roads and
Infrastructure
Services 
Adoption of Strategy  Part for current financial year  The Fleet Replacement Strategy is
complete but is subject to on-going
change in line with legislative changes
as it is an operational document. 
T2 – Develop a vehicle routing system
that will reduce road miles for
operations    
(L) Roads and
Infrastructure
Services 
Evidence of delivery of
projects 
Part for current financial year  This is progressing. The project has
slipped slightly due to staff availability
and the data gathering and cleansing
stage taking longer than we might have
hoped. There was a report to EDI in
March which sets out the revised
position and project timeline.    
T3 – Develop an electric vehicle
infrastructure strategy    
(L) Roads and
Infrastructure
Services 
Evidence of delivery of
projects 
Part for current financial year 
The development of the EV network is
funded by external grant monies from
Transport Scotland, and the costs of
developing the strategy in terms of staff
time are covered via existing budgets 
Ultimately the cost recovery model  
The strategy and expansion plan is in
place – we cannot move forward with a
delivery programme until such time as
our funding from SG is confirmed. The
national EVIF programme is seeing
some delays and changes in guidance
and application process. All Councils are
in the same position and we are in
discussions with TS/SG on how the

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programme will operate going forward
and when we are likely to see a funding
award.    
We have, through a separate fund
accessed via HiTRANS, progressed the
installation of 8 new rapid chargers
across the area in the last quarter of
2023 and these are in place and being
well used.  This brings our network up to
37. 
We have also introduced new charges
which are designed to cover all asset
management costs for the network.
These costs fall now to the Council after
having previously been funded through
grants.    
We are also continuing to progress
installs at Council hub offices with the
next sites being Union St Rothesay and
Kintyre House Campbeltown. 
We have now secured a provisional
allocation of £1million from Scottish
Government to expand our EV network
and are currently out to tender for a site
assessment exercise.  Further reports
on this will be made to EDI committee
as appropriate. 
T4 – Support Digital by Default theme
Service Review & Recovery Plan to
reduce need to travel 
All Council
Departments 
Evidence of delivery of
projects 
Part for current financial year  Council is adopting ‘Our Modern
Workspace’ programme and  Digital
First approach as services change and
evolve post pandemic.   
T5 – Develop new active travel plans for
Council buildings and our towns 
(L) Economic
Development 
Evidence of delivery of
projects 
No active travel funding is provided by
Council.  All costs, including internal
The purpose of active travel is to make it
as easy as possible and help to

Page 19

staff costs (1.7FTE), have to be funded
via successfully securing external
challenge funds. As all active travel work
is currently reliant on securing external
funding, the projects which are
progressed are those which can
successfully secure external challenge
funding. 
External competitive challenge funds are
time consuming to secure and projects
have to be shaped to fit with external
funders’ aspirations and requirements
by the 1.7FTE Active Travel staff in the
Strategic Transportation Team.
However, at present these are the only
available source(s) of funding made
available to deliver active travel
improvements. 
2023/24 Progress 
The 1.7FTE Active Travel Team secured
£2.56M external challenge funding in
23/24 for development and delivery of
22 active travel projects across Argyll
and Bute, requiring 18 separate
competitive challenge funding
applications to 5 separate funds. 
Projects funded via the active travel
team within Strategic Transportation in
2023/24 included: 
• New cycle parking at the
community owned Port Ellen Playing
Fields Community Development, Islay. 
encourage individuals, businesses and
visitors to choose to walk, wheel or cycle
for local journeys.  Increasing activity
and reducing sedentary behaviour has
significant health benefits and can
increase accessibility to essential
services, education, employment, retail
and leisure.  Walking and cycling are
lower cost travel modes and, if they are
a viable option, can help the 20% of
households (2022 census) reduce social
isolation and other households reduce
their reliance on private cars, particularly
multiple car households (34% of Argyll
and Bute households; 2022 census). 
No Council funding is currently
expended on Active Travel work, with all
costs, including internal staff costs
(1.7FTE), having to be funded via
successfully securing external challenge
funds. As all active travel work is
currently reliant on securing external
funding, therefore the projects which are
progressed are those which can
successfully secure external challenge
funding. 
Argyll and Bute Active Travel
Strategy: Officers are working to
develop an Argyll and Bute Active Travel
Strategy and present it to members for
approval.  The Active Travel Strategy
will provide the overarching context for
the Council to support and promote
active travel across the Council area.
Having an adopted and current Active
Travel Strategy is increasingly becoming
a pre-requirement to access Scottish

Page 20

• Funded Cycling UK to run the
Dunoon Cycle Bothy 
• Funded ACT to upcycle 65
bikes to return to the local Mid-Argyll
Community to increase opportunities to
cycle. 
• Creation of new Smartphone
Apps for Tobermory and Bowmore
(adding to the existing popular apps for
Campbeltown, Dunoon, Helensburgh,
Oban and Rothesay) 
• Design work progressed for
ambitious walking and cycling projects
including: 
• Campbeltown, commenced
initial design work on Phase 4 Active
Travel Improvements (Esplanade and
Kinloch Park) (initial Feasibility). 
• Dunoon, Town Centre to
Hunters Quay Active Travel route
(Concept Design). 
• Helensburgh: Helensburgh –
Cardross – Dumbarton Cyclepath
(Developed Design)and Helensburgh
– Garelochhead Cycleway (final
Technical Design). 
• Islay, Bowmore to Bridgend
Path (with Islay Community Access
Group) (final Technical Design). 
• Jura, Craighouse to Corran
Sands Active Travel Route (Concept
Design). 
• Lochgilphead: Front Green to
Crinan Canal (Concept Design)and
Town Centre to Joint Campus Active
Travel Routes (final Technical
Design). 
Government derived active travel
funding. 
Active Travel Delivery Plan: 
Following approval of Active Travel
Strategy, an Active Travel Delivery Plan
will be developed to create a prioritised
list of active travel projects for the whole
of Argyll and Bute. 
Active Travel Projects: The majority of
external funding available is provided by
the Scottish Government via a number
of distribution organisations who are
paid to distribute these funds.  The focus
for Scottish Government Active Travel
funding is to develop and deliver
infrastructure projects and associated
behaviour change.  As such, the focus
for the very limited staff capacity in the
Active Travel Team has been to develop
and deliver infrastructure projects across
Argyll and Bute with a focus on our main
towns and locations with strong
community support. 
Active Travel Plans for Towns: There
are Active Travel Plans in place for the
main towns in Argyll and Bute, albeit
some are now quite historic.  The town
Active Travel Plans focus on identifying
potential active travel route networks for
key towns.  These provide a framework
for the development of new active travel
routes, which will enable and encourage
residents, businesses and visitors to
choose to travel more actively.  No
funding is currently secured to enable

Page 21

• Rothesay, Pavilion to Albert Pier
Active Travel Improvements (Concept
Design). 
Oban, Oban Town Centre
North  Active Travel Improvements
(George St and Corran Esplanade)
(Concept Design) – concept design
proposals rejected by OLI Area
Committee on 25 June 2024. 
the Active Travel Plans for towns to be
updated. 
Council Staff Travel Plan: Officers are
exploring options to develop a Council
Staff Travel Plan.  However, this is
challenging due to the ongoing
uncertainty of longer-term staff profiles
and bases.  There is currently no
funding secured to enable this work to
be progressed.   
It should be noted that successful Staff
Travel Plans require to have strong
support from senior managers/elected
members, who also require to act in
accordance with the Plan, and from
enabling departments, e.g. finance and
HROD.  Once developed, to be fully
effective it is likely that a Staff Travel
Plan would require changes to the
Council’s travel policies and expenses
policies. 
Staff Travel Plans focus on measures to
make it easier and preferable for staff to
choose to walk, cycle, use public
transport or car share to commute to
work or for work journeys, or use
economical pool vehicles for work
journeys.   A travel plan should
encourage staff to choose the most
economical and least environmentally
damaging travel mode.  Engagement will
be required with services which manage
staff in buildings and/or council buildings
as this is essential to creating
deliverable and effective travel plans for
staff.  This includes Estates, HROD,
SMT and building users.

Page 22

PA1 – Review Council Flooding &
Coastal Protection Policy 
(L) Roads and
Infrastructure
Services 
Review of policy  No specific funding in place, research
required to impact on operation costs 
Reviews are in process.    
PA2 – Review Council Sustainable
Procurement Policy 
(L) Procurement   Review of policy   No specific funding in place, research
required to impact on operation costs 
The Sustainable Procurement Policy
has been merged with the Procurement
Strategy for 2025-2028 to create the
Sustainable Procurement Strategy, this
will continue to be reviewed on an
annual basis.    
OFF1 – Develop opportunities for
environmental sustainability
projects with ACT and partners 
(L) Climate
Change Board,
ACT and
partners
Delivery of
projects 
Limited funding via ACT for existing
projects
SSEN compensatory planting – Phase 1 and 2
complete at Kilmory. Ongoing maintenance. 
ACT working with community and SSEN to
develop a BNG project in Cowal which if
approved would see  50 hectares of Rainforest
cleared of invasive rhododendrons and form
part of the landscape scale rainforest
restoration project in West Cowal.   ACT is
leading a landscape scale rainforest restoration
project in Knapdale, working with agency
funders and private investors.  Both projects
are endorsed by the  Alliance for Scotland’s
Rainforest.
https://savingscotlandsrainforest.org.uk/projects 
ACT is delivering a 5-year programme of native
tree planting  with Mastercard’s Priceless
Planet Coalition.  We have started the planting
of 100,000  trees in West Cowal. This planting
will offer opportunities for carbon credits for
landowners.

Page 23

With support from National Lottery Heritage
Fund , Nature Restoration Fund and DRAX, 
ACT have established a Rainforest Squad to
undertake a programme of training in woodland
management,   The Squad are currently
clearing Rhododendron ponticum from
rainforest in North Knapdale and are based at
ACT Rainforest Hub at Kilmory, where ACTs
MAKI Pups, tree nursery and ReCycle project
are also based.  The Hub is being used for
community training and workshops, volunteer
activities. 
ACT undertaking peatland restoration on Islay,
Jura and Kintyre supported by ScotGov’s
Peatland Action and Esmee Fairbairn
Foundation, we also have  a habitat trainee 1-
year opportunity .   ACT now employes 34
people across Argyll and Bute in the
environmental sector. 
ACT is hosting the Community Planning
Partnership’s Climate Action Manager to
develop a Climate Action Strategy and Action
Plan over a 2 year period. The CPP agreed an
approach of developing an enabling strategy
early in order to allow more space to focus on
developing the action plan. The CPP
Management Committee approved the enabling
strategy at its December 2024 meeting and the
Action Plan is now under development,
structured around the Priority Areas for Action
agreed by the Management Committee. The
CPP’s Climate Change Working Group ran a
workshop in March 2025 to review the first draft
of the Action Plan, ensuring alignment of
structure with other action plans across CPP
members. In the wake of recent storms across
Argyll and Bute, resilience has been

Page 24

increasingly prominent in feedback so far
received from CPP partners and the wider
community, including the first round of 2025
Area Community Planning Groups. This is
reflected in the Action Plan at its current stage
of development. The CPP in December agreed
to review periodically the spread of actions
across the Priority Areas it had agreed, and an
early consideration may be the extent to which
to emphasise resilience among the broader set
of Priority Areas:  
In addition, ACT has secured funding for 25-26
to continue  partnership with the Third Sector
Interface and Time for Change to deliver the
ABCAN (Argyll and Bute Climate Action
Network) Hub.  The ABCAN project, which is
Scottish Government funded, has supported 17
community groups with funding to undertake
climate action in 24 /25, 56 since ABCAN was
launched in late 23.totalling over £50k. The
Team continues to engage with local
communities on climate action, climate literacy,
place planning with a climate lens and working
to develop the partnership network across
Argyll & Bute and engaging with the strategic
activity of the CPP Climate project. 
• ABCAN collaborated with
Sniffer/Adaptation Scotland and the
Mod Committee and launched a
bilingual version of the ‘Climate
Community Adaptation Routemap’
during Mod week in Oban. This smaller
introductory version of the Routemap
will work to address the lack of climate
change materials in Gaelic, prompting
future developments in translation and

Page 25

community access to climate change
information. 
• ABCAN staff carry on the work of the
Sustainable Food Partnership. Two
events have run at the end of FY 24/25
to build the localised networks which
will enable the creation of an SFP. All
this work will support and underpin any
future work on the Good Food Nation
Act 
Carbon Literacy Training – Free CL training has
been on offer to all A&B residents for the past
year and over 15 officers and management
have attended this training. ACT is keen to
support Argyll and Bute Council in achieving
Carbon Literate Organisation silver
accreditation.
Climate resilience workshops have also been
delivered online and in person throughout
Argyll and Bute. 
• ACT worked with A&B Education and
the Developing the Young Workforce to
host and deliver the multi school
Landscapes and Natural Diversity
STEM event at Kilmory in March 25 .
We continue to  work with all relevant
partners to both deliver on appropriate
climate change education but also look
to link with resilient skillsets and
employers, within nature restoration,
and beyond in the renewable sectors.
• ACT delivered a ‘healthy happy homes
event in Helensburgh in January 25
working with Argyll & Bute Council,
Home energy Scotland, Poverty
alliance etc. (Over 120 attendees)

Page 26

• Work continues on deliveryOutdoor
STEM Learning at Kilmory (adjacent
MAKI Pups), working with every
Primary class at Lochgilphead Primary.
Work with rural schools in Mid Argyll
will take place at, or around, the school
grounds. Additionally we are continuing
our work with the many home educating
families who attended sessions last
academic year. 
• The Outdoor STEM team delivered a
climate resilience workshop to teachers
and other educators, through the
Outdoor Woodland Learning group in
mid-September 24. This session was
based on developing school grounds to
be increasingly climate resilient. 
• reCycle is fully operational again
thanks to  funding from Grants for All
COMMUNITY PROJECT TRANSITION
FUND, HITRANS People & Place
Programme, and the Argyll & the
Islands Community Led Local
Development Fund
• Working to the aim of encouraging
people to cycle as part of their everyday
short journeys has climate outcomes,
whilst also addressing rural travel
poverty, health and wellbeing
improvement, and waste reduction
through bicycle reuse. 
COMM1- Develop and deliver
Communications Plan to support
Decarbonisation Plan
(L) Climate
Change Board
and
Delivery of
Communications
Plan
Part of Communications Support  External communications
We continue to promote actions the council is
taking, and actions that others can take, to

Page 27

Communications
Team
develop climate-friendly Argyll and Bute. For
example: 
• Promoted Outdoor Classroom Day and
the excellent outdoor learning
opportunities in Argyll and Bute.
• Promotion of council’s new fuel-efficient
Pingo bus.
• Better Journeys Active Travel Scheme
– comms campaign and photo winner.
• Ongoing promotion of various active
travel consultations in Argyll and Bute.
• Council’s announced Local Heat and
Energy Efficiency Strategy priorities.
• Islay received share of £1 million from
Scottish Government’s Carbon Neutral
Islands (CND) Capital Fund.
• Shared success of Grow Food Grow
Dunoon, Rosneath Proud and Scenic
Sandbank being recognised by KSB on
work to improve communities for
climate changes, nature and people
through national “It’s Your
Neighbourhood Initiative”.
• Ran a successful Argyll and Bute wide
schools recycling competition.
• Bute Community Forest won
Community Led Regeneration category
at 2024 SURF awards.
• Month-long festive recycling social
media campaign.
• New Active Travel Strategy.
• Promotion of help available through
Home Energy Scotland.
• From field to fork and zero air miles -
Jura Small Isles School adds local
venison to the menu.

Page 28

• Promotion  of Islay High School’s bee-
keeping club.
• Ongoing recycling help and advice on
social media platforms.
• Promotion of the council’s Home
Energy Efficiency Team drop in events
in Campbeltown and Dunoon.
• Share, Repair, Aware campaign.
• Funding for Strategic Housing Fund for
Housing Emergency projects.
• Council or join leading energy efficient
programme.
• As part of ongoing commitment to
deliver a net zero Argyll and Bute, the
council responded to SG consultation
about community benefit funds
• Promotion of active travel holiday apps.
• Shared Love Food Hate Waste’s Easter
recycling campaign on social media
platforms
• Re-launched the council’s Be A Great
Visitor Campaign to run from April until
September.
• Celebrated wild venison in schools
project winning the UK’s Best
Sustainable Project at the Public Sector
Catering Awards 2025.
• Supported No Mow May.
• Promoted Burnett Building in
Campbeltown – conservation via
environmentally friendly means.
• Celebrated Oban High winning the
Keep Scotland Beautiful Eco
Committee of the Year Award.
• Encouraged people mto vote for
Dunoon Grammar after school was
shortlisted in the People’s Choice
Award for reusable water bottles.

Page 29

• Promotion of HIRTANS funding for
active travel infrastructure in the
workplace.
• Ongoing promotion about recycling and
food waste.
• Bike Week social media posts.
COMM2 - Engage with community
and partners and deliver Climate
Change Directory for our region 
(L) Community
Planning and
Development
Team
Delivery of
engagement map 
In place until end of financial year The CPP Climate Change signposting page is
available at
https://www.argyll-bute.gov.uk/cpp-climate-
change with information and links updated as
required.  
The Climate Change Project Manager,
appointed by the CPP, has worked with the
CPP Climate Change Working and Steering
Groups to write the Argyll and Bute CPP
Climate Change Strategy.  This strategy has
been approved by the CPP Management
Committee and is available with appendices on
the signposting page.  
A dedicated Climate Change funding
opportunities search is conducted monthly and
is also available through the signposting page.  
(see also updates from ACT and partners
within this report) 
COMM3 - Monitor the delivery of
actions in the Climate Change
Action Plan and review in 2025
(L) Climate
Change Board 
Review of this
plan by
December 2025 
Monitored through Tracker to be submitted
quarterly to Policy & Resources Committee. 
Completed – next review Dec 2025

Page 30

Appendix B - Consultation on draft Statutory Guidance for public bodies:
response
The consultation can be found here
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?
Yes. To be effective, particularly for authorities managing diverse geographical areas
including island and remote rural communities and facing resource limitations, the
guidance must incorporate more practical, simplified tools for assessing equalities
impacts by non-specialist staff. It should advocate for a phased approach,
acknowledging the time needed to build capacity for comprehensive assessments.
Crucially, it needs to champion robust cross-departmental collaboration and clear
governance to ensure equalities are integral to climate action across all services,
rather than an isolated or under-resourced task. Explicit reference to duties under all
relevant equalities legislation, including the Islands (Scotland) Act, would reinforce
this. 
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?
Yes. The guidance requires practical strengthening to address socio-economic
disadvantage effectively. It should provide clear decision-making frameworks and
operational tools for frontline teams, enabling them to assess and mitigate negative
impacts in communities facing challenges such as fuel poverty or limited rural
transport. This is vital for authorities operating with constrained resources. The
guidance must better address the temporal challenge of balancing urgent climate
action with ensuring a just transition, offering methods to sequence interventions
appropriately. Stronger support for cross-departmental collaboration is needed for
holistic socio-economic impact assessments to inform climate strategies effectively. 
3. Does the guidance make it clear how public bodies can fulfil the requirement to
‘best calculate’ the climate impact of their actions?
Partially. While the aspiration is clear, the guidance currently lacks sufficiently
practical and simplified tools or methodologies for calculating climate impact that are
usable by non-specialist staff working within existing operational constraints and
limited resources. Authorities, especially those with restricted technical capacity or
fragmented data, need clearer frameworks for prioritising material emissions and
guidance on proportionate, minimum acceptable calculation approaches.
Acknowledging the temporal aspect of building this capability, through a staged
approach, and promoting cross-departmental data governance and shared
responsibility would significantly improve clarity and successful implementation.

Page 31

4. Does the guidance make it clear how public bodies should take future climate
scenarios into account when making plans and investment decisions?
No, the guidance is not adequately clear or practical here. There is a pressing need
for simplified, actionable guidance and tools, such as adaptable risk assessment
templates or relevant modelling examples, to enable authorities to effectively select
and apply climate scenarios within established operational, financial, and capital
planning processes. This is particularly pertinent given existing budget cycles and
significant resource limitations. The guidance must better address the challenge of
managing differing timescales (e.g., short-term budgets versus long-term scenarios)
and proactively support cross-departmental consistency. Centralised climate
scenario data and analysis would be invaluable for authorities with limited in-house
technical expertise. 
5. Do you have any comments about the guidance provided in this chapter (chapter 5)
on complying with the first duty?
While the chapter's thematic focus for emissions reduction is understood, it does not
sufficiently address the practical operational realities, acute resource constraints
(including skilled personnel and finance), or the temporal complexities of balancing
immediate actions with long-term decarbonisation. For authorities managing ageing
assets, geographically dispersed infrastructure, and legacy systems – common in
rural and island contexts – more realistic, phased approaches aligned with existing
capital programmes and replacement cycles are essential. The guidance must more
strongly advocate for, and provide practical advice on achieving, robust cross-
departmental collaboration, shared ownership of emissions reduction, and effective
governance to drive organisation-wide change within these constraints. 
6. Do you think the Carbon Management Plan template is suitable for its intended
purpose?
No, the Carbon Management Plan template, as presented, is largely unsuitable for
many public bodies, especially those with significant operational remits or severely
limited dedicated climate change resources. Its impracticality stems from insufficient
alignment with existing operational planning cycles and data systems, an implicit
assumption of readily available technical expertise which is often not the case, and a
failure to adequately address the temporal and cross-departmental nature of
effective carbon management. For it to be fit for purpose, it requires redesigning for
genuine operational usability, offering a more flexible, phased or tiered approach,
simplified data requirements, and clear guidance on integrating departmental
responsibilities with corporate processes, recognising carbon management as an
evolving, dynamic commitment.

Page 32

7. Do you think the Climate Change Plan template for local authorities is suitable for its
intended purpose?
No, the Climate Change Plan template for local authorities is generally considered
unsuitable in its current iteration. It appears disconnected from prevalent operational
realities and often assumes a level of cross-departmental coordination, data
maturity, resources, and organisational readiness that many authorities, particularly
those with limited capacity, do not currently possess. The template inadequately
addresses significant temporal challenges (such as developing comprehensive long-
term plans while needing to take immediate, impactful action) and the critical need
for seamless integration with existing corporate planning and budgetary cycles. A
more practical, phased, and tiered approach is strongly recommended, featuring
simplified requirements for resource-constrained authorities and clearer guidance on
establishing practical departmental responsibilities and integration mechanisms. 
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?
Somewhat disagree. While the proposed approach is logical in principle, its
practical implementation presents considerable challenges for many public bodies.
Specifically, for those without dedicated adaptation expertise or existing
comprehensive climate risk assessments, the capacity to thoroughly review SNAP,
accurately identify all relevant objectives, and translate these into actionable
operational plans is severely limited by resource constraints. The guidance does not
sufficiently address the temporal aspects of adaptation (such as balancing
immediate resilience needs with progressive long-term planning) nor does it
adequately detail the mechanisms for the essential cross-departmental coordination
and ownership required to make this approach effective in practice. 
9. Do you have any other comments about the guidance provided in this chapter
(chapter 6) about complying with the second duty?
The adaptation guidance, though setting comprehensive expectations, falls short in
delivering practical, actionable advice tailored for resource-constrained,
operationally-focused, and cross-departmentally complex organisations. There is a
critical need for practical tools readily applicable by operational teams (e.g., climate-
resilient maintenance specifications, adaptable business continuity templates for
diverse climate hazards, robust decision frameworks for prioritising adaptation
measures). The guidance should also more effectively address how to manage
diverse timescales and inherent uncertainties with limited specialist expertise.
Simplified risk assessment methodologies and clear frameworks for fostering
genuine cross-departmental collaboration and shared responsibility are vital,

Page 33

particularly acknowledging the unique and pressing challenges faced by rural and
island authorities managing extensive vulnerable infrastructure with limited
resources. 
10. Having considered the content of the chapter (chapter 7), is it clear how public
bodies should implement the third duty, to act in the most sustainable way?
No, the guidance regarding how to act sustainably is largely unclear on practical
implementation. It is perceived as overly theoretical, failing to furnish actionable
tools, pertinent operational examples, or clear pathways for procurement teams and
decision-makers, especially within resource-constrained environments where a
deep-rooted culture of sustainability may not yet be established. The guidance needs
to more effectively address the challenge of balancing sustainability objectives with
immediate service delivery pressures and prevailing budget constraints.
Furthermore, it should provide tangible strategies for managing the temporal aspects
of this duty (integrating short-term operational needs with long-term sustainability
goals), systematically building organisational literacy, and fostering the essential
cross-departmental collaboration and shared ownership required for meaningful and
lasting change. 
11. Do you have any other comments about the guidance provided in this chapter
(chapter 7) about complying with the third duty?
This chapter often seems disconnected from common operational and organisational
realities, frequently assuming a level of institutional maturity, available resources,
and cultural embedding of sustainability that is not yet widespread. There is a strong
requirement for practical tools, support for phased approaches, and assistance for
the necessary cultural change and capacity building, especially recognising that
limited staff often have responsibility for all three climate duties. Effective frameworks
for cross-departmental collaboration and supportive governance structures are vital.
The inherent tension between short-term operational and budgetary pressures and
long-term sustainability goals needs to be more explicitly and pragmatically
addressed, providing realistic examples and decision-making support relevant to
resource-constrained authorities. 
12. To what extent do you agree or disagree with the proposed baseline reporting of
the scope 3 emission categories outlined in section 8.3.5.1 of the guidance?
Somewhat disagree. While comprehensive Scope 3 reporting is a laudable long-
term objective, the proposed baseline presents immediate and significant practical
challenges. For many public bodies, the current absence of robust data, suitable
systems, necessary technical expertise, and available resources makes the task of
collecting and reporting this information accurately and consistently a major

Page 34

undertaking. This requirement can appear disconnected from operational reality and
constitutes a substantial additional burden. A phased approach to Scope 3 reporting
is strongly recommended, commencing with a smaller, more manageable subset of
emissions based on reasonably available data, and gradually expanding as local
capabilities and systems mature. Essential supporting elements include practical
guidance on data collection and estimation, standardised methodologies, and ideally,
centrally provided tools, alongside frameworks for effective cross-departmental data
governance. 
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 tick all that apply.
No. Expanding the list of Scope 3 categories at this juncture is not supported. The
predominant view is that the immediate and overriding focus must be on establishing
robust, practical, and manageable systems for the currently proposed baseline
categories (or potentially an even more limited initial set that reflects existing
capacities). There is a strong preference for a carefully phased, temporally-nuanced,
and holistic approach to all Scope 3 reporting, ideally underpinned by centralised
tools and clear, consistent methodologies, rather than prematurely broadening the
scope when capacity for existing expectations is already severely stretched. The
priority must be to improve cross-departmental data collection and governance for
the categories already proposed before considering any expansion. 
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?
Don’t know. Although the guidance offers a comprehensive framework, it frequently
falls short of providing the essential practical support required for effective
implementation, particularly for public bodies grappling with significant resource
constraints, diverse operational complexities, or those at an earlier stage of their
climate action journey. The guidance can often seem disconnected from these day-
to-day realities, lacking the readily actionable tools, simplified approaches, and
tailored support necessary. Key areas urgently needing improvement include more
effective strategies for managing temporal challenges (such as building crucial
capacity incrementally over time) and practical methods for fostering genuinely
effective cross-departmental working. Without substantial revisions to address these
shortfalls, including the possibility of more direct centralised support and resources,
the guidance risks setting expectations that are, for many, unachievable. 
15. Do you have any further comments about the guidance?

Page 35

This guidance represents a significant and notable increase in expectations for
public bodies. However, it consistently fails to adequately address the fundamental
practicalities of implementation, particularly concerning pervasive resource
constraints (in funding, essential skills, appropriate tools, and available staff time),
the critical necessity of phased and temporally aware approaches to action, and the
absolute imperative for genuine, embedded cross-departmental collaboration
supported by robust governance. There is a strong, clear, and repeated call for the
Scottish Government to commit substantial additional resources and to provide more
tangible, centralised support mechanisms (such as standardised practical tools,
targeted training programs, shared service models, clear sector-specific advice, and
dedicated funding streams). Without this commitment, there is a very high risk that
the guidance will remain aspirational at best, potentially becoming counterproductive
by creating unfunded mandates, and could inadvertently exacerbate inequalities
between well-resourced and under-resourced public bodies. A fundamental shift
towards actively supporting practical, integrated, and adequately resourced climate
action is urgently required across the entire Scottish public sector.