Technical Notes 2025, Issue 150 - Call for views on forthcoming Scottish Government Climate Change Plan

The purpose of this technical note is to inform Elected Members of the Scottish Government’s Call for views on forthcoming Scottish Government Climate Change Plan and to share Officers’ draft technical response which will be submitted by the closing date of 19 September 2025. Should Elected Members have any comments on the draft response these can be sent to robert.seale@eastdunbarton.gov.uk by 5pm Thursday 11 September 2025 for inclusion.

1. The Scottish Parliament’s Net Zero, Energy and Transport Committee have launched a public Call for Views on the Scottish Government’s forthcoming Climate Change Plan (CCP). Input received from the Call for Views will support parliamentary committees in scrutinising the draft CCP, which is expected to be published later in 2025

2. The draft CCP will set new interim emission reduction targets covering the period of 2026-2040 in the form of five-year carbon budgets, expressed as an amount in carbon equivalent tonnage, covering all sectors of the Scottish economy. These targets are intended to pave way to delivering on the Scottish Government’s target to reach net zero greenhouse gas emissions by 2045. The CPP must also set out the costs and benefits of its policies, whilst taking into consideration the principles of a Just Transition

3. It is anticipated that the Scottish Government will base its CCP on advice from the independent Climate Change Committee (CCC) and accept the CCC proposals for the following carbon budgets relative to 1990 levels of emissions:

• 57% lower for the First Carbon Budget (2026 to 2030)
• 69% lower for the Second Carbon Budget (2031 to 2035)
• 80% lower for the Third Carbon Budget (2036 to 2040)
• 94% lower for the Fourth Carbon Budget (2041 to 2045).

4. The CCC note that achieving these emissions reduction targets and getting to net zero by 2045 will require immediate action, at pace and scale.  Key transitions that the CCC cite as being necessary to reach net zero include:

• Electrification: the need for a rapid increase in the adoption of electric vehicles and heat pumps, with a goal of 60% of cars and vans being fully electric by 2035 and 40% of homes using low-carbon heating by 2035, the latter of which would be in line with observed rate of increase in the Netherlands and the Republic of Ireland. These transitions will need to be accompanied by significant increase in renewable energy generation and grid capacity
• Decreases in demand for high carbon goods and services including through increased energy efficiency, an increase in the proportion of journeys made by public transport and active travel, a reduction in waste generated, greater circularity in resource use, and a reduction in meat and dairy consumption - in particular beef and lamb
• Increases in nature-based solutions with a reduction in land-intensive agriculture freeing up land for peatland restoration, increasing woodland coverage and other nature-based solutions
• Low-carbon farming, low-carbon fuels, Carbon Capture and Storage (CCS) and engineered removals to target emissions in areas where a large-scale low-carbon alternatives are not seen as viable by the CCC by 2045 such as aviation, cement production, industry and livestock. Hydrogen is anticipated to have a small role in decarbonising industry but not in heating buildings

5. Questions in the call for views cover sectors including electricity; buildings; transport; industry; waste and circular economy; agriculture and land use; and negative emissions technologies. The Parliament is also seeking views on policy proposals, how the proposed policies should be funded and how to overcome challenges in delivering them

6. Further information on the call for views can be found on the Scottish Parliament Website

7. The Committee have called for responses from a wide range of individuals and organisations by the closing date of 19 September 2025.

8. The Scottish Government has set a legally binding target to reach net zero greenhouse gas emissions by 2045, under the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. More recently, the Scottish Parliament passed the Climate Change (Emissions Reduction Targets) (Scotland) Bill which replaced the 2030 and 2040 interim targets to net zero with a carbon budget-based process in November 2024

9. The Scottish Government’s updated CCP is expected before the next Scottish Parliament election in 2026. A public consultation will run in parallel with the 120 days that the Scottish Parliament will have to scrutinise the draft CCP

10. The Climate Change (Scotland) Act 2009 places a legal responsibility on relevant public bodies in Scotland to meet the climate change duties. The duties are set out in section 44(1) of the 2009 Act and require that a public body must, in exercising its functions, act: 

• in the way best calculated to contribute to the delivery of emissions reduction targets (i.e. mitigation)
• In the way best calculated to help deliver the Scottish National Adaptation Programme
• In a way that it considers most sustainable.

11. Local Authorities are amongst the public bodies that Scottish Ministers consider to be 'major players' as they have a larger influence or impact on climate change than others. These major players are listed in Schedule 1 of The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015 and are expected to show leadership in climate action

12. The climate change duties are required to be met as Public Bodies exercise their functions.  For Councils, these functions include:

• • Corporate operational functions
  • Delivery of public services within the authority area
  • Policy making functions or influence
  • Discharging of other mandatory duties

13. The Scottish Government issued draft Statutory Guidance to support public bodies in performing climate change duties under section 45 of the Climate Change (Scotland) Act 2009 for consultation from 24 February to 23 May 2025. East Dunbartonshire Council submitted a response to the consultation as detailed in PNCA/022/25/RS

14. Environmental Standards Scotland (ESS) undertook an investigation on the effectiveness of the systems in place to support local authorities in their duty to contribute to the delivery of climate change targets. Following this investigation, ESS submitted a Report and Improvement Plan with a series of recommendations to the Scottish Parliament in December 2023.

This included a call for mandatory reporting of additional indirect emissions (known as scope 3 emissions) from local authority activity to support local authorities in their duty to contribute to the delivery of national climate change targets under the Climate Change (Scotland) Act 2009 (EDC/049/24/RS). Scottish Government is currently taking forward the actions set out in their response to the ESS recommendations.  

15. Council approved the Climate Action Plan (CAP) Evidence and Options Report on 28 September 2023 (EDC/011/23/NU) which detailed the Council’s approach to the mitigation and adaptation strands of the 2009 Climate Change Act. This included setting a net zero target of 2036 for the Council’s direct emissions and purchased energy (including emissions from the fleet of vehicles, buildings and electricity), a target of 2045 for all other emissions, including emissions from the Council’s supply chain and emissions in East Dunbartonshire as a whole (area-wide emissions), and a series of actions to achieve greater resilience to the on-going impacts of climate change

16. Council submits an annual statutory Public Bodies Climate Change Duty (PBCCD) Report which measures annual progress in emission reduction targets and provides updates on adaptation related actions. This information is supplemented with a Carbon Management Plan (CMP), which provides an analysis of corporate emissions, costs associated with key aspects of the Council’s corporate carbon footprint, short-term corporate emissions reductions targets and progress against the Council’s overall emissions reduction targets. A summary of the most recent PBCCD report was shared via technical note in October 2024 (TN Number 188-24) and the most recent CMP report, and 8th edition, was approved by Council in December 2024 (EDC/049/24/RS)

17. East Dunbartonshire Council’s corporate emissions have decreased by approximately 55% since record keeping began in 2012/13 and the most recent corporate emissions reported in 2023/24, going from 32,420 tCO2e in 2012/13 to 14,720 tCO2e in 2023/24

18. Similarly, East Dunbartonshire’s area-wide emissions have decreased significantly since record keeping began: going from 786.41 ktCO2e in 2005 to 399.13 ktCO2e in 2023

19. East Dunbartonshire also has the second lowest per capita emissions out of the 32 local authorities in Scotland according to the most recent UK Government data - UK local authority and regional greenhouse gas emissions statistics, 2005 to 2023.  The only Local Authority with lower emissions than East Dunbartonshire, Argyle and Bute, has significant negative emissions with ‘Land Use, Land Use Change and Forestry’ emissions at -404.3 ktCO2e in 2025.  East Dunbartonshire’s low emissions appear to be due to a combination of factors including a lack of major industrial emissions, a lack of major agricultural emissions and the Council's proximity to Glasgow, including East Renfrewshire, West Dunbartonshire and Inverclyde - tend to have relatively low per capital emissions as do city local authorities including Glasgow, Edinburgh and Dundee.  

20. While East Dunbartonshire’s emission reductions represent positive progress, a large proportion of emission reduction have been due to decarbonisation of electricity generation – particularly the removal of coal from this process – in line with an increasing trend across the OECD.   A reduction in emissions across a broader range of sections, as set out in paragraph 4, will be required to build on the successful record of decarbonisation

21. More information on changes within specific emission sources relevant to the Call for Views in East Dunbartonshire include the following:

• Electricity: domestic, public sector and commercial electricity have gone from a combined 201.1 ktCO2e in 2005 to 47.7 ktCO2e. The CCC suggest that renewables are expected to continue to squeeze out gas from UK electricity generation and the electricity grid is expected to be largely decarbonised by the early 2030s
• Buildings: account for almost a fifth of Scottish emissions. This is largely due to approximately 80% of buildings being heated using gas.  These buildings will need to transition to zero direct emission heating systems for Scottish net zero targets to be achieved.  Emissions from domestic, public sector and commercial gas in East Dunbartonshire decreased from in 219.6 ktCO2e in 2005 to 143.8 ktCO2e in 2023.  Energy efficiency is still a challenge with a total of almost 30,000 properties in East Dunbartonshire that are below EPC band C, which is considered by Scottish Government a good standard of energy efficiency
• Transport: emissions have decreased from 163.9 ktCO2e in 2005 to 124.5 ktCO2e in 2023. This reduction needs to accelerate significantly to achieve the Council’s target. Modal shift to active travel and sustainable travel are optimal in terms of emissions reductions, improved air quality, reduced financial pressure on the NHS and other co-benefits. An increased proportion of fossil fuel powered vehicles being replaced by electric vehicles is expected to contribute to significant emissions reductions by 2030, supported by the UK and Scottish Government targets to phase out the sale of new petrol and diesel cars from 2030
• Industry emissions have decreased from 44.8 ktCO2e in 2005 to 13.6 ktCO2e in 2023 and constitute a relatively small part of East Dunbartonshire’s carbon footprint compared to local authorities with emission intensive clusters, such as Falkirk and Fife at 1,235.4 ktCO2e and 1,253.9 ktCO2e in 2023 respectively
• Waste and circular economy saw a significant decline from 92.7 ktCO2e in 2005 to 20.4 ktCO2e in 2023. The CCC explains that reductions in the amount of commercial waste, household waste, and food waste generated, followed by increased recycling rates and engineered solutions to capture and store residual emissions, would be the main facets of the decarbonisation trajectory for this area
• Land use, land use change and forestry saw very limited change in emissions from 18.4 ktCO2e in 2005 to 16.3 ktCO2e in 2023. Increasing the amount of land available for nature-based solutions is identified by the CCC as being central to reducing emissions in this area
• Agriculture saw a minor decrease from 33.2 ktCO2e in 2005 to 25.2 ktCO2e in 2023. The CCC notes that reduced meat and dairy will be necessary to reduce emissions and free up land for peatland restoration, increasing woodland coverage and other nature-based solutions.

22. As explained in the most recent iteration of the CMP (EDC/049/24/RS) despite the economic benefits of climate change mitigation far outweighing the costs,  challenges to building on East Dunbartonshire’s successful record of decarbonisation include the fact that some zero emissions technologies have higher operational costs than high-carbon emitting systems due to the relatively high price of electricity compared to gas and higher up-front costs due to a more limited economy of scale compared to higher emitting systems.  Paradoxically, renewable energy is a significantly cheaper means of generating electricity than fossil fuels, but these savings are not passed on to consumers due to a variety of factors including carbon taxes, coupled electricity and gas rates and policy costs. This is particularly pronounced in the UK where electricity prices are amongst the most expensive in Europe

23. These challenges are compounded by the fact that local authorities are faced with severe financial pressures, including disproportionate exposure to inflation, rising demand for essential services and an expanding set of statutory duties.   Delivering many actions required to achieve net zero, particularly decarbonising heat, the Council’s fleet of vehicles and the Council’s supply chain, will depend on substantial investment and resource commitment including appropriate financial support from the Scottish Government or measures to ensure that the lower costs of renewable electricity generation energy are passed on to users

24. The proposed responses to the consultation are therefore geared towards overcoming the barriers detailed in paragraphs 22 and 23, supporting the CCC recommended transitions set out in paragraphs 4 and 21 to help Council to achieve its net zero targets as set out in paragraph 15  

25. Submission of responses to the consultation is due by 19 September 2025, so any responses / input is requested by 5.00pm Thursday, 11 September 2025.

26. For additional information, please contact robert.seale@eastdunbarton.gov.uk