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Consultation on Proposals for A Scottish Climate Change Bill: Analysis of Responses

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ANNEX 3 THE CAMPAIGNS

As noted in Section 1, amongst the responses to the consultation document were a large number of "campaign responses" where a series of identical (or very similar) responses were submitted as part of a campaign. This annex provides a summary of the nature of the campaign responses and the main points made.

The campaigns

A total of 8 campaigns ran over the course of this consultation, generating almost 21,000 responses. The campaigns, and the total responses received from each, are set out in the table below:

Table 1. Campaigns and responses

Campaign

Number

Friends of the Earth

187

RSPB International

72

RSPB Scotland

657

UNISON

10

World Development Movement

31

WWF International

12,944

WWF Scotland (email)

1,130

WWF Scotland (postcard)

5,697

Total

20,728

Analysis of the campaign responses

The core texts from each campaign were treated as discrete consultation responses, included in the analysis and reflected in the report. For all of the campaigns, the views which were expressed have been included, although, as with all of the responses to the written consultation, the source of the comments is not always identified.

A specific and unusual issue arose with some of the campaign responses in this consultation, where these were based upon the main campaign response, but involved some changes to their content, with an expressed view that they be included and analysed as individual responses.

Additionally, the Friends of the Earth (FoE) campaign provided a response to each question, with some variation in the text of the response in each case (with 98 statements used, covering the 33 questions). As noted in Section 1, this was achieved by enabling an electronic "response" to be created from elements drawn apparently at random from a series of pre-prepared statements.

These approaches suggest that some respondents wished to make individual points while supporting the points made in a campaign. It is also possible that some respondents or campaigns believed that a large volume of individual submissions would carry more weight than if these were considered as campaign responses.

It is important to clarify, however, that the purpose of the consultation was to reflect the range, depth and overall patterns of views rather than to measure and quantify these patterns, for all of the reasons outlined in Section 1. In this context, while it is important to recognise the strength of opinion in campaigns which generated almost 21,000 responses, these are no more or less significant than if they were designated as being from individuals. The important issue is to ensure that the total number of responses overall is identified, and that the points made are included in the report.

Given the unprecedented nature of the campaigns, the Scottish Government had no standardised approach to handling amended campaign responses and, accordingly, there was no text in the consultation documentation to indicate to respondents how these would be treated in the context of the overall analysis. With this in mind, an approach tailored to the unusual circumstances was developed whereby the Scottish Government sifted all the campaign responses to identify those that contained additional material to the campaigns' suggested texts. A total of 420 campaign responses of this type were identified, and these were analysed separately. Similarly, an analysis was carried out of the separate responses to each of the questions in the Friends of the Earth campaign.

It is important, in the context of other Scottish Government consultations, to stress that the approach developed for handling campaign responses to the Scottish Climate Change Bill consultation may not set a precedent for future consultation analysis. It may be in future that responses which are based upon core campaign texts (whether or not the respondent has made some additional comments) will be identified and treated as campaign responses, and will not be included as individual responses. On the basis of the methodology and purpose which have been detailed in this report, it should be clear that this will not in any way diminish their significance in a consultation. It will simply ensure that an appropriate and proportionate approach is taken to large scale campaign responses, and to the analysis overall, which recognises that a consultation is neither a referendum nor a social survey, and the numbers (while demonstrating a level of interest) are not indicative of the relative importance of a view. Importantly, it is intended that the approach that will be taken to campaign responses in the future (including where campaigns adopt methods such as those taken here) will be made clear from the outset. This will help to ensure that the nature and purpose of the consultation, as a means of ensuring the input of wide ranging views and expertise is retained, and that it does not become a quantitative "weighing" of views.

The campaign texts

While the core text of each campaign will not be reproduced verbatim, the main points covered in the campaigns are summarised below:

General issues

All of the campaign texts included comments on general issues, as follows:

  • The importance / global significance or threat of climate change and / or the need for action (some Friends of the Earth respondents; RSPB International; RSPB Scotland; Unison; World Development Movement; WWF International).
  • The importance of a commitment to delivering strong legislation ( WWF Scotland).
  • The importance of, or opportunity for leadership / leadership by example (some Friends of the Earth respondents; RSPB International; RSPB Scotland; Unison; WWF International; WWF Postcard; WWF Scotland).
  • The need for Scotland / the Scottish Government to do its share to limit the global average temperature increase to not more than 2°C above pre-industrial levels (some Friends of the Earth respondents; RSPB International; RSPB Scotland; Unison; World Development Movement).
  • The need for the legislation or targets to be strong and / or bold ( RSPB International; RSPB Scotland; Unison; WWF International; WWF Postcard; WWF Scotland).
  • An expressed willingness by the respondent to play a part in reducing emissions ( WWF Scotland).
  • The potential consequences of a lack of action (Unison; World Development Movement).
  • Commendment or congratulation on aspects of the proposals, and / or a wish for success ( RSPB International; RSPB Scotland; WWF International; WWF Scotland).
  • A number of additional comments relating to different aspects of the consultation (some Friends of the Earth respondents).

Targets

All of the campaign texts included comments on a range of aspects of targets (although some of the specific questions were only addressed in the Friends of the Earth campaign). Comments were as follows:

  • Support for a target of 80% (or at least 80%) by 2050 ( RSPB International; RSPB Scotland; Unison; World Development Movement; WWF International; WWF Postcard; WWF Scotland).
  • The need to base the target on all greenhouse gases, or the basket of gases (Friends of the Earth; RSPB International; RSPB Scotland) or reference in the response to the reduction of greenhouse gas emissions (Unison; World Development Movement; WWF International; WWF Postcard; WWF Scotland).
  • Support for provision to alter the gases included (some Friends of the Earth respondents).
  • The basis of targets to be source emissions, while including calculation or reporting of consumption (Friends of the Earth).
  • The suggestion that the Bill should not allow the means of measuring the target to be changed through secondary legislation (Friends of the Earth).
  • The need for the target to take account of the abatement effort made by companies under emissions trading schemes (Friends of the Earth).
  • The need for a strict limit on any international credits counted towards Scottish targets, working towards a zero level of counting of these (Friends of the Earth).
  • Support for provision to allow the level of the 2050 target to be amended on the basis of advice, but to be limited to an increase (Friends of the Earth).
  • A wish for the Bill to include emissions from international aviation and shipping in the reduction targets (some Friends of the Earth respondents; RSPB International; RSPB Scotland; Unison; World Development Movement; WWF International; WWF Postcard; WWF Scotland).
  • The need to set strong targets for the public sector to lead by example, with negotiated green workplace agreements (Unison).
  • The need for the Bill to include both cumulative and end-point emissions targets (some Friends of the Earth respondents).

Supporting framework

All of the campaign texts contained comments on aspects of the supporting framework (although some of the specific questions were only addressed in the Friends of the Earth campaign). Comments were as follows:

  • The need to take account, in setting the level of budgets, of a range of factors (Friends of the Earth).
  • The need for interim budget periods to be one year (Friends of the Earth).
  • The need for budget-setting to be 10-15 years in advance with, for some, annual budgets or indicative budgets to 2050 (Friends of the Earth).
  • The need for strictly limited borrowing (Friends of the Earth).
  • Support for the Bill to include an interim target of at least 50% by 2020 (Friends of the Earth).
  • A wish for the Bill to include annual targets (in some cases statutory) of at least 3% emission reductions (some Friends of the Earth respondents; RSPB International; RSPB Scotland; Unison; World Development Movement; WWF International; WWF Postcard; WWF Scotland).

Reporting and scrutiny framework

Only the Friends of the Earth campaign text contained comments on the reporting and scrutiny framework, and these were as follows:

  • Support for the Scottish Ministers to be required to report, with a preference by some for annual reporting on a range of issues, and reporting by the First Minister (Friends of the Earth).
  • A perception that Parliamentary scrutiny is not sufficient alone and should be supported by other measures (Friends of the Earth).
  • Support for a new Scottish Climate Change Committee as the primary source of advice to the Scottish Government (Friends of the Earth).
  • Support for a new Scottish Climate Change Committee to have responsibility for monitoring progress on reducing emissions (Friends of the Earth).
  • A need for the creation of additional independent mechanisms for scrutinising the effectiveness of the Scottish Government's policies in reducing emissions, in the form of a new Scottish Climate Change Committee (Friends of the Earth).
  • The identification of some potential functions which should be carried out at arm's length from the Scottish Government (some Friends of the Earth respondents).

Supporting measures

Three of the campaign texts contained comments on supporting measures (although some of the specific questions were only addressed in the Friends of the Earth campaign). Comments were as follows:

  • Support for the Bill to contain enabling powers to introduce a duty on certain parts of the public sector to take specified actions, with suggestions about what these should include (Friends of the Earth).
  • Support for the Bill to contain enabling powers to introduce statutory guidance for certain public sector bodies, with suggestions about what this should include (Friends of the Earth).
  • Support for the Bill to contain enabling powers to create a requirement for certain public sector bodies to make regular reports (Friends of the Earth).
  • Support for current Best Value guidance to be amended to take specific account of climate change mitigation and adaptation (Friends of the Earth).
  • Support for amendments to existing legislation or enabling powers to allow for variable charging (Friends of the Earth).
  • The need for the Bill to include a requirement for a Scottish climate change adaptation strategy (Friends of the Earth).
  • Support for provisions within the Environmental Assessment (Scotland) Act 2005 to be amended to provide clearer links with emissions reduction (Friends of the Earth).
  • An outline of the impact of emissions on wildlife ( RSPB International; RSPB Scotland).
  • The need to recognise the value of the environment and wildlife ( RSPB International; RSPB Scotland).
  • The need to ensure that delivery does not cause further harm to the environment ( RSPB International; RSPB Scotland).
  • The need for inclusion in the Bill of a duty to apply the principles of sustainable development in measures to reduce emissions (some Friends of the Earth respondents).
  • The need to ensure that delivery does not cause further harm to wildlife, and enhances wildlife ( RSPB International; RSPB Scotland).
  • The need for resources and effort to be directed to improving the resilience of wildlife ( RSPB International; RSPB Scotland).
  • The view that there are no equalities implications of the measures set out in the consultation (Friends of the Earth).
  • The identification of some existing legislation within the competence of the Scottish Parliament which is seen to require amendment (Friends of the Earth).
  • The need for the establishment of a "carbon fund" or "climate fund" (some Friends of the Earth respondents).

As noted above, there were additional points made by respondents through the Friends of the Earth campaign, and these have also been reflected in the body of the report.

The campaign responses with additional material - "campaign plus" responses

As noted previously, there were also 420 campaign responses identified as containing additional material to the campaigns' suggested texts. A brief summary of the main additional points made within these responses is provided below. These issues have also been reflected in the main report. In the remainder of this section, the term "campaign text" has been used to signify the original wording provided by the sponsor, and "campaign plus" responses to signify the responses containing additional material to the campaigns' suggested texts.

General issues

As noted earlier, a number of the campaign texts congratulated or commended the Scottish Government or Scottish Ministers in some way on aspects of the proposals set out in the consultation document. A small number of "campaign plus" respondents added additional congratulatory comments (such as "Whoohoo! Hooray for Scotland!!"), or personalised those suggested in the campaign texts (for example, "I am a teacher from Australia, and have read with great admiration your plans for a world leading climate change bill"). These comments will not be detailed further here.

A very small number of negative general comments were offered. One respondent, for example, "condemned" the Scottish Government for "demonstrating herd mentality" in seeking to address climate change.

There were also many comments in the campaign plus responses focusing on the leadership shown by the Scottish Government through the consultation document. Again, most of these followed the campaign texts, although in some cases, they were supplemented in some way. This included, for example, making reference to the approach taken by the respondent's country of residence or expressing a view that other governments should take a similar approach. In some cases, reference was made to the encouragement that Scotland could offer to other jurisdictions. Again, these comments will not be detailed further here. Slightly over a fifth of the campaign plus respondents urged (in some way) the Scottish Government to take action. Some of these added to this by suggesting, for example, that the Bill should have the "necessary" or "real" teeth.

Campaign plus respondents provided personal testimony on a wide variety of issues relating to climate change, including issues such as: the need to address this; its global and interconnected nature; and its impact on people, animals, plants and landscapes. A number of respondents also identified ways in which they were seeking to make personal changes, or ways in which their governments were (or were not) responding to climate change. One noted that "ordinary people do not want to feel helpless on this matter". A small number of respondents also offered (largely positive) personal views about aspects of Scotland (including its climate and landscape), usually based on visits to the country.

As noted above, the campaign texts also made a number of specific points about issues central to the consultation document. A number of the campaign plus respondents used these, and added to them in some way. They also added a number of comments on other issues. These comments are detailed below as they relate to the main areas of the written consultation document.

Targets

Most campaign plus respondents used the campaign texts to support the level of the target (an 80%, or at least 80% reduction by 2050). However, a very small number of additions, amendments and clarifications were made including the following:

  • A target of 90% (two respondents).
  • A target of at least 55%.
  • A reduction of 100% by 2030.
  • A concern that haste is required as "scientists … tell us that 2025 may be the point at which natural systems collapse".
  • A suggestion that emissions between now and 2050 should not exceed a fair share of a safe global total.

A small number added (in various ways) that reductions should be achieved as early as possible in the period.

Additionally, most used the campaign text in relation to the basis of the targets, by suggesting the use of a basket of gases. The following additional points and clarifications were made:

  • A view that there would be "little point" in introducing targets for CO 2 without also introducing targets, for example, for methane.
  • An observation that other gases are more "potent" on a ton for ton basis.
  • A concern that there may be unintended consequences for levels of other gases if only CO 2 were to be used in the target.
  • A view that the use of a basket of gases would be more cost-effective.
  • A view that the use of a basket of gases would allow a wider focus on the need to act against a warmer climate caused by human activities.

Most campaign plus respondents used the campaign text when referring to the need to include international aviation and shipping in the targets. Three respondents mentioned aviation, but did not mention shipping. Some, however, provided additional details or qualifications, including the following:

  • A suggestion that, due its popularity, aviation is the "nettle no-one wants to grasp" and a view that it "does not make sense" to ignore certain emissions because they are claimed to be difficult to count.
  • A note that aviation and shipping were fast growing sectors in terms of their effect on climate change.
  • A suggestion that journeys should be included where they start in Scotland.
  • The observation that the US Mail has recently cancelled surface mail for small parcels.
  • The observation that average temperature in New York dropped by 1 o centigrade after 9/11 because of the lack of air traffic.

As well as many campaign plus respondents following, and adding to the campaign texts in the above ways, a range of individual suggestions were made which related to specific questions in the consultation document (which are already covered in the main analysis). In relation to targets, these included views that 46:

  • A sound mechanism for measuring emissions should be established and adhered to (1,2,4).
  • The Bill should include financial inducements and financial penalties, for example, to encourage a more proactive stance on carbon reduction and holistic reorganisation (3).
  • Targets should be easy to communicate to the public (3).
  • Source and end-user emissions methods should be used (3).
  • Changes to the means of measuring the targets should not be permitted (4).
  • Changes should be permitted, but only on the advice of an independent Scottish Climate Change Committee (4).
  • The target should include companies' trading emissions and if necessary, the Government must buy back emissions permits to ensure that overall targets are being met (5).
  • The Scottish Government should introduce a form of carbon rationing such as "tradeable / trading energy quotas" (5).
  • There should be regulation in the sale of carbon offsetting (6).
  • There should be a cap on the level of international credits used (6).
  • Only increases should be allowed to the targets (7).
  • The Scottish Government should set strong targets for the public sector (other issues).
  • Statutory targets should be developed to reduce emissions caused by consumption of materials and services (other issues).

Supporting framework

As with other issues, most campaign plus respondents used the campaign text when referring to the wish to see an annual minimum reduction of at least 3%. A small number of additions, amendments or clarification were made including the following:

  • An annual reduction of at least 2% per year.
  • An annual reduction of at least 5% per year (two respondents).
  • A shift to a low carbon pathway by 2010-2012, and statutory targets of 9% per annum for the next 20 years.
  • An annual reduction of at least 10% per year.
  • An annual reduction of at least 12.5% per year.
  • A starting target of approximately 3% per annum increasing as systems to decrease emissions become more efficient and participation increases.

Individual suggestions (which can be linked to specific questions in the consultation document) in relation to the supporting framework included views that:

  • The most recent climate science should be taken into account in setting the level of budgets, with evidence from NASA on climate feedback loops being cited by one respondent (8).
  • Interim budget periods should be shorter than a parliamentary term, or should be 4 years, or could be aligned with UK reporting periods (9).
  • Budget periods should be 15 years, with indicative budgets to 2050 (10).
  • Borrowing emissions from future years should not be permitted, or if borrowing is permitted, an interest rate should be set on the advice of an independent Scottish committee (11).
  • There should be interim targets, with a 50% reduction by 2050 (12).

Reporting and scrutiny framework

Most of the campaign texts did not contain comments on the reporting and scrutiny framework, as noted earlier. Individual suggestions (which can be linked to specific questions in the consultation document) in relation to the reporting and scrutiny framework included views that:

  • There is no need to create a new body to support actions for climate change (15).
  • An existing Scottish body should not be given a role in advice, monitoring or scrutiny as it is "too important and large" to be delegated as an add-on (16, 18, 21).
  • Independent scrutiny would be wise (19).

Supporting measures

In relation to supporting measures, a large majority of campaign plus respondents used the campaign texts when expressing a view that the delivery of the measures in the Bill should not cause further harm to the environment, and that it should provide a strategy of adapting to climate change in a way which does not further harm wildlife (as set out earlier in this section). A small number of variations and additions to this were offered, including the following:

  • A view that "pristine or valuable habitats" should not be placed under pressure, or affected while implementing climate change strategies. (The respondent went on to suggest that a particular wind farm project should be abandoned.)
  • A suggestion to further help "creatures" by protecting further / replacing habitats and/or foods necessary for survival.
  • A suggestion that animals which have suffered from the pollution caused by gases should be protected and treasured more because of the pain caused.
  • A view that policies should "work with nature to benefit biodiversity, the economy and local communities" (3 respondents), and that these should ensure that biodiversity is not further harmed, or cause the loss of biodiversity or habitats.
  • A view that preserving Scotland's environment would be good for tourism.
  • A suggestion that the Bill should contain measures "to combat the devastating effect on climate of the meat and dairy industries worldwide".

Individual suggestions (which can be linked to specific questions in the consultation document) relating to supporting measures included views that:

  • There should be a duty on the public sector (23).
  • No policy decisions should be taken which increase emissions (23).
  • Statutory guidance should be issued (28).
  • Scotland should help "poorer" countries to cut emissions (30).
  • The Environmental Assessment (Scotland) Act 2005 should be amended if required (31).
  • There are some equalities issues relating to the Bill, although these were not always detailed. One noted that "there may be some equalities issues arising in the fuel poverty debate" (32).
  • Implementation should not involve new taxes or interfere with any of the lower-middle classes' comfort of living (32).

Campaign plus respondents also made a wide range of suggestions about things that the Scottish Government could do to address climate change, some of which would require legislation, while others would not (33). Some relate specifically to Scotland, while some have a wider focus. More details of these are provided below, and for ease of reading, these have been grouped under the main headings with the relevant section of the main report.

In relation to legislation, regulation and taxation, campaign plus respondents suggested the need to:

  • Legislate to make it mandatory that all emissions are offset, with customs fees imposed on products which are not offset.
  • Support companies and vehicles using alternative fuel sources (not bio-diesel).
  • Reduce taxation on sustainable commercial activity, but increase taxes on those that "go about industry in a damaging manner".

In relation to new technology, campaign plus respondents suggested the need to:

  • Support businesses to "grasp" the opportunities presented.
  • Have a "proactive technological development program".

In relation to agriculture and fishing, a campaign plus respondent suggested the need to:

  • Ban over-fishing in deep waters.

In relation to the environment, a campaign plus respondent suggested the need to:

  • Encourage large-scale tree planting.

In relation to transport, campaign plus respondents suggested the need to:

  • Reduce emissions through the transport sector (described by one respondent as the "most effective way" of reducing emissions).
  • Discourage road and air transport.
  • Set targets for car / vehicle manufactures on fuel efficiency (with a suggestion that some vehicles should not be permitted in Scotland).
  • Price aviation fuel and petrol according to its environmental impact.
  • Cease building more roads or runways (see above). (It was suggested that this would not mean the contraction of the economy, rather an expansion of local economies.)
  • Develop initiatives to manage industries, airports and urban areas.
  • Encourage walking and cycling (mentioned by a number of respondents in various ways).
  • Encourage public transport, for example through subsidised fares or greater petrol duty.
  • Make more investment in the rail network.
  • Impose a ban on parents dropping children off at school gates.
  • Fine operators of empty planes or ships to encourage full usage.
  • Differentiate on the level of impact of different types and ages of vehicle.
  • Phase out budget flights in order that additional runways would not be required (with a view being expressed that flying should return to being an "expensive luxury").
  • Develop a TGV-type rail link from Edinburgh / Glasgow to London via Manchester.

In relation to waste, campaign plus respondents suggested the need to:

  • Develop proposals to reduce electronic waste.
  • Make recycling compulsory.
  • Make manufacturers responsible for recycling their own products.
  • Introduce initiatives to reduce packaging.

In relation to energy, campaign plus respondents suggested the need to:

  • Reduce basic energy consumption (in various forms), with one respondent suggesting that this should be made mandatory by legislation (but, as far as possible, without incurring extra expense or adversely impacting on vulnerable people).
  • Make it easier for householders to introduce renewable energy to their home.
  • Have fewer streetlights on motorways.
  • Make a "stand" against nuclear power, and for "no coal".
  • Encourage community projects, and microgeneration projects.
  • Reduce the extraction and exportation of mineral oil to a volume which is "justifiable by strict requirements of necessity". Another respondent suggested that there should be no subsidies for mineral oil extraction.
  • Increase funding for research into alternative energy solutions.

In relation to building, housing and property, campaign plus respondents suggested the need to:

  • Move away from the use of non-green products in insulation programmes.
  • Put in place negotiated green workplace agreements.

In relation to education and awareness raising, campaign plus respondents suggested the need to:

  • Foster more public awareness on climate change, and develop (mandatory) education on energy saving and related issues for all citizens (in one case, with schools and colleges/universities mentioned by others).
  • Encourage wider public engagement and discussion, and publicise activities as much as possible.
  • Undertake regular checks on individuals about how much effort they are making to affect the climate.

In relation to other suggestions, amongst campaign plus respondents:

  • One stated that the Scottish Government should study ISO 14001.
  • Another proposed a form of yoga.
  • Another suggested a book, " The Revenge of Gaia".
  • Another believed that the Scottish Government should take "guidance" from CPULs Andriv Viern and "council" from John Thackara.

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Page updated: Friday, August 15, 2008