Proposals for Scottish Climate Change Bill
ACE welcomes the Scottish Government’s ambition in introducing a Climate Change Bill which sets statutory targets for reductions in greenhouse gas emissions and which supports the delivery of those targets. We also welcome the overall target of an 80% reduction in emissions by 2050 on 1990 levels, which is broadly in line with the current scientific consensus. However, we believe the detailed proposals fall short of what is needed to achieve a fair and equitable reduction in Scotland’s emissions and will not give business and industry the certainty they need to invest for emissions cuts.
There are in our view a number of conspicuous shortcomings in the proposals that will hamper the Bill’s effectiveness. Principle among these is the lack of any limit on the number of carbon credits that can be purchased from abroad. The Scottish Government should be aiming for 100 percent internal provision to achieve the Scottish target. This would allow the Scottish economy to benefit from early action to reduce emissions, and, if investment is suitably targeted, would also help to achieve existing Scottish Government targets on fuel poverty.
ACE believes strongly in the effectiveness of statutory targets, with a variety of incentives and sanctions including the option of affordable legal challenge. Statutory targets will not only give direction to Government, but are vital to give business the certainty it needs to make the appropriate investment decisions. For building materials (including energy efficiency materials), the investment required to increase production is immense, and local workforces must be trained up and retained. This is not a business where imports can be relied upon to make good a shortfall in domestic production – imports are more expensive because of the bulky nature of the materials. For this reason and several others, ACE supports sectoral targets, as set out below.
In addition, the three year “budget cycle” proposed is too long and lacks adequate accountability to make the Bill effective. A cycle of annual reports to Parliament on progress towards meeting annual targets, ideally given by the First Minister, would deliver the required level of accountability.
Finally, it is essential that all greenhouse gas emissions, including those from aviation and shipping, are included in the Bill.
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