Technical Notes 2025, Issue 223 - Consultation on the Scottish Government’s Draft Climate Change Plan

The purpose of this technical note is to inform Elected Members of the consultation on the Scottish Government’s Draft Climate Change Plan and to share Officers’ draft technical response, which will be submitted by the closing date of 29 January 2026. Should Elected Members have any comments on the draft response, these can be sent to Neil.Samson@eastdunbarton.gov.uk by 5pm Friday, 16 January 2026 for inclusion.

• 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.
• A carbon budget-based approach to interim targets was established in November 2024 through the Climate Change (Emissions Reduction Targets) (Scotland) Bill. The independent Climate Change Committee (CCC) published recommendations for five-year carbon budget levels reflecting average reduction in emissions relative to a 1990 baseline in May 2025.
• The recommended carbon budgets cover emissions from all sectors of the Scottish economy and were adopted by Scottish Government in July 2025:
  • 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).
• 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 cited as being necessary to reach net zero in their 2025 Scottish Carbon Budget 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 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.
• On 6th November 2025, the Scottish Government published their Draft CCP for consultation. The Draft CCP sets out the policies and proposals the Scottish Government will take forward to meet their carbon budgets between 2026-2040 combined with their estimated costs and benefits. The consultation closes on 29th January 2026 and the Scottish Government committed to publishing the final CCP before the dissolution of Parliament for the 2026 election. Further information on the consultation and Draft Climate Change Plan can be found in the following link: Consultation for the Scottish Government Draft Climate Change Plan
• Cross-parliamentary scrutiny of the Draft CCP, involving several committees at the Scottish Parliament, is running in parallel with this consultation. The Parliamentary scrutiny process will examine the Draft CCP’s proposals, sectoral impacts and feasibility as set out in their webpage and runs for a period of 120 days, from 6th November until 5th March 2026. This process is being coordinated by the Scottish Parliament’s Net Zero, Energy and Transport Committee, which Council submitted input to during their Call for Views on the then forthcoming Climate Change Plan in September 2025.
• The Draft CCP includes Scotland’s progress so far, indicating that Scotland is already over halfway to net zero having reduced emissions by 51.3% since 1990 - the largest reduction in the UK and faster than the EU average. However, despite this positive progress, the CCC note that emissions reductions in transport, buildings and agriculture will need to accelerate for Scotland to meet the targets set out in the carbon budgets detailed in paragraph 2.
• The Draft CCP sets out over 150 policies and proposals to fulfil the three carbon budgets from 2026-2040 and is formatted by a sectoral approach using areas of the economy within which the actions will be taken forward. These sectors are set out below and are specified by legislation.
  • Residential and Public Buildings.
  • Transport (including international aviation and shipping).
  • Waste Management.
  • Energy Supply.
  • Business and Industrial Process.
  • Land Use, Land Use Change and Forestry (LULUCF).
  • Agriculture.
• Questions in the consultation cover sectors, including:
  • Delivering a Just Transition.
  • Sectoral Contributions, Policies and Proposals.
  • Impact Assessments.
  • Strategic Environmental Assessment.
  • Monitoring Emissions Reductions.
  • Monitoring Just Transition.
• Policy developments and emissions reduction progress on a UK and East Dunbartonshire level provide relevant context to the proposed responses to the Scottish Government’s Draft Climate Change Plan. Accordingly, recent developments on both levels are summarised below.

• The CCC emphasises the necessity for shared delivery and collaboration between national governments and recognises that while the Scottish Government can do a lot to reduce emissions with devolved powers, reserved decisions will also have a significant impact on Scotland’s ability to achieve the targets in paragraph 2 and reach net zero.
• As a result, recent progress in the UK’s plans for emissions reductions have been summarised for context.
• The UK Parliament passed the UK Climate Change Act 2008 to provide a legislative framework for the UK to reduce emissions. Under the 2008 Act, the UK was required to reduce greenhouse gas emissions by at least 80% by 2050 on 1990 levels. In 2019, on advice of the CCC, the UK committed to reaching net zero emissions by 2050 and the 2008 Act was amended to reflect this.
• The UK government is required to establish legally binding, five-year caps on emissions (carbon budgets), which set out a pathway to achieving the 2050 target. Six carbon budgets have been set to date, covering 2008 to 2037. Carbon Budget 6, the first to be set under the UK’s net zero target, was legislated for in June 2021. Emissions from the whole UK contribute to these carbon budgets, even though approaches are different in some of the developed nations, such as in Scotland.
• The UK has already met its first (2008-2012), second (2013-2017) and third (2018-2022) carbon budgets and is on track to meet the fourth (2023-2027). The UK is the first major economy to halve its emissions – having cut them by 54% between 1990 and 2024. However, despite this progress, the CCC note that emissions reductions in transport, buildings and agriculture will need to accelerate for the UK to meet future targets in its carbon budgets.
• On 29 October 2025, the UK Government published its revised plan, the Carbon Budget and Growth Delivery Plan, for meeting carbon budgets four to six (2023 to 2037) and contributing to the UK’s net zero target.
• On 25 June 2025, the CCC published the Progress in Reducing Emissions - 2025 Report to UK Parliament. This statutory report provided a comprehensive overview of the UK Government’s progress to date in reducing emissions. The CCC indicated that UK emissions targets are achievable but rely on urgent action in several critical areas in 2025:
  • Making electricity cheaper. The highest-priority recommendation is to remove policy costs from electricity prices. This will support industrial electrification and ensure the underlying lower running costs of heat pumps compared to fossil fuel boilers are reflected in household bills.
  • Accelerating heat pump deployment. By 2035, the market for low-carbon heating – and its supporting supply chains – needs to scale up to deliver all new and replacement heating installations. The CCC’s recommendations in this area include implementing regulations to ensure that new homes are not connected to the gas grid, establishing a comprehensive programme and accompanying funding to decarbonise public sector buildings, and accelerating the electrification of industrial heat.
  • Rapidly expanding the low-carbon electricity system. The CCC outlines that over 80% of the required emissions savings between 2025-2030 are needed from sectors other than energy. The majority of this comes from the electrification of key technologies, including surface transport, buildings and industry. The continued decarbonisation and expansion of the electricity system will play a key role to enable this widespread electrification. In addition, the CCC noted the renewable electricity generation capacity (offshore and onshore wind and solar) increased in 2024 by a higher rate than the previous 6 years. However, to achieve the UK Government ambitions in this sector the CCC recommends that total operational capacity of renewables will need to more than double by 2030.
  • Accelerating tree planting and peatland restoration. The CCC recommend that policies and incentives are put in place to ensure planting rates increase quickly due to the time it takes for trees to grow and sequester substantial levels of CO2.
  • Developing policy to ensure that the aviation industry takes responsibility for its emissions reaching net zero by 2050. The cost of decarbonising aviation and addressing non-CO2 effects should be reflected in the cost to fly. This would help to manage growth in aviation demand in line with Net Zero and generate the revenues needed to pay for sustainable aviation fuel and engineered removals.
  • Finalising business models for engineered removals. The CCC recognise progress in carbon dioxide removals, but note that it will be increasingly challenging for removals to meet the savings required by 2030 under current funding, the pace of technological advancement and implementation.
  • Publishing a strategy to support skills. Proactively growing the workforce is a critical enabler in areas such as heat pump installation, electrification of transport and increasing nature-based solutions. Development of a new strategy is required to support workers in sectors which need to grow or transition and in communities that may be adversely impacted.
• On 6 November 2025, the UK Government published its response to the CCC Progress Report and outlined actions being taken in response to the priority actions detailed in Paragraph 15

• 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.
• 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.
• 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.
• On 28 September 2023, Council set a net zero target of 2036 for the Council’s direct emissions and purchased energy (including emissions from the Council’s 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), and a series of actions to achieve greater resilience to the on-going impacts of climate change (EDC/011/23/NU).
• 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 reduction targets and progress against the Council’s overall emissions reduction targets. The most recent edition was approved by PNCA in November 2025 (PNCA/047/25/RS).
• East Dunbartonshire Council’s corporate emissions have decreased by approximately 56% since record keeping began in 2012/13 and the most recent corporate emissions reported in 2024/25; going from 32,420 tCO2e in 2012/13 to 14,113 tCO2e in 2024/25 (PNCA/047/25/RS).
• 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 (PNCA/047/25/RS). 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. 
• While East Dunbartonshire’s emission reductions represent positive progress, a large proportion of emission reductions 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 will be required to build on the successful record of decarbonisation.
• More information on changes within specific emission sources relevant to the draft CCP 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. Introduction of minimum energy efficiency standards for the domestic private rented sector, supporting installation of low carbon heating systems such as heat pumps and development of heat networks would therefore have a significant impact on eliminating poor energy efficiency as a driver of fuel poverty and reducing greenhouse gas emissions in the area. Furthermore, use of low embodied carbon materials and construction methods, and integrating renewable energy generation and energy efficient smart appliances are supported. 
  • 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.
• As explained in the most recent iteration of the CMP (PNCA/047/25/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.
• 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. This includes appropriate financial support from the Scottish Government and measures to ensure that the lower costs of renewable electricity generated energy are passed on to users.
• Submission of responses to the consultation is due by 29 January 2026, so any responses / input is requested by 5pm Friday 16 January 2026.
• For additional information, please contact Neil.Samson@eastdunbarton.gov.uk