We need a strong climate bill - and no fracking

The Scottish Government are updating the landmark Climate Change Bill (2007), which is so important for our trajectory and accountability on the road to a sustainable, low carbon future and the Broad Alliance agreed to make a submission.

While this is broadly a positive and progressive proposal. we are not alone in voicing concern that this simply doesn’t go far enough. The focal point of the consultation is an ambition to reduce greenhouse gas emissions by 90% (compared to 1990 levels) by 2050. This is a worthy revision on the previous target of an 80% reduction in emissions by 2050, although it does raise the question of why we are not aiming to reduce emissions by 100%, when we know that the technology to attain such a transition is already in existence (and increasingly affordable). Our overall approach has been informed by taking the very positive elements already in the consultation document and either amplifying them or bringing them to the foreground of climate policy-making and leadership in Scotland. 

There are so many ways to respond to this consultation. While we would suggest having a read at the Consultation Document and answering the questions through the Consultation Portal website, not everyone has the time to do that in the coming weeks and there are some easy, accessible options too;

-Support Friends of the Earth e-action on this Bill- https://act.foe.scot/climate-action

-Support Stop Climate Chaos e-action on consultation - https://act.foe.scot/sccs-climate

-Copy and Paste our template answer (contained below), adding your name, editing/adding any additional information and sending it to Scottish Government at- CCBill@gov.scot

-The full Scottish Government consultation is available through - https://consult.scotland.gov.uk/energy-and-climate-change-directorate/climate-change-bill/

Our Answer :

Broad Alliance of Scottish Communities united against Unconventional Oil and Gas Exploration  

Submission to Scottish Government Climate Bill Consultation 2017


Dear Scottish Government, 

We welcome the chance to submit to this consultation and as community members, most of us living in areas which would be directly affected by fracking, to have some input into this new Climate Change Act. In order to submit to this consultation, we first read the consultation document and picked out some key themes from what the Scottish Government aims to do with this policy which we broadly support, although believe could go further. We have defined these headings as guiding principles, and these include; ‘Climate Leadership’, ‘Progressivism’ focusing on the need to keep moving towards a zero-emissions economy, ‘Accountability and Transparency’ which focuses on climate change as an issue for every level of democratic governance and the need for parsimony and communication about policy in this area, as well as a 'Hierarchy of concerns’ in the criteria for policy, which places community needs and a ‘fair and safe’ emissions budget as supreme and deserving of more concern than the ‘competitiveness of certain sectors of the economy’. 

While our overall approach to this submission has about adjusting the saturation and brightness of the consultation document, in order to make the very positive aspects of it clearer and to really bring them into the foreground, we also have a few additions to the Bill. We would like to see a ban on all new fossil fuel frontiers and all forms of unconventional gas (both exploration in Scotland and importing from other countries, including other UK jurisdictions), included in this Bill. We would also really like to problematise the idea of ‘safety’ in the context of the emissions budget of Scotland and climate change more generally. From events this year in South Asia, droughts around the world and Hurricane Harvey and Hurricane Irma in the Americas, it seems very clear that there is no safe level of climate change. Prime Minister Gaston Browne of Barbuda and Antigua, whose Caribbean islands have just been ravaged by Hurricane Irma recently stated that ‘The science is clear. Climate change is real in the Caribbean we are living with the consequences of climate change. It is unfortunate that there are some who see it differently.’ (Weaver, Phipps, Levin and Lartey, in The Guardian, 7th of September, 2017). As such, the conversation has to become about trying to be as safe as possible and including voices from the majority world, which seems to be more vulnerable to and to have less resilience to dramatic climate events.  

Climate Leadership

While it is great to see the Scottish Government taking on board the Climate Change Committee target of reducing emissions by 90% for 2050 (rather than 80%). The only concern from the Broad Alliance is the desire to stop at 90% when we believe that 100% is achievable. With regards to the questions about interim emissions reduction targets, this would require increasing the ambition of 2030 and 2040 targets to 77% reductions by 2030 and at least 87% by 2040, as well as more ambitious year to year targets over the next decade. Work by Jacobson et al (2017), has examined how generating 100% of the power required for electricity, heating, agriculture and transport is possible from wind, water and sunlight within most of the countries of the world and this is not an unrealistic ambition. 

It is also promising to see that the Scottish Government acknowledge that their is a risk to GDP of climate change mitigation and of moving away from a highly polluting economy, however the risk of ‘business as usual’ is far greater. This is refreshing to hear, because many governments around the world and think tanks do not seem to take this view and present these issues as being the ‘jobs versus the environment’. While Climate change mitigation and prevention is likely to cost governments up to 3.5% of their GDP over time, failing to take any action and allowing the worst climate scenario to occur is more likely to mean a reduction in GDP by at least 11% (possibly up to 20%), due to the disasters. The Broad Alliance welcomes such an observation, however there this is a picture of climate change which is overly abstract and focused on macroeconomics. In order to create greater engagement with these issues, which is a must in a democratic society where policies require some level of popular support, it would also be helpful to also look at climate change in terms of the effects of local places and economies (both in Scotland and in other regions of the world), on habitats, as well as focusing on issues of trauma and displacement that go hand in hand with climate disasters which a warming world make so much more likely. In educational materials about climate change, the Scottish Government must be rigours and scientific, though should not underestimate the power of a narrative about climate change which takes into account the human cost and struggle. The journalist George Monbiot, who is known for his pioneering work to engage citizens in environmental issues has recently recommended that we move a way from a vocabulary of ‘climate change’ to referring to ‘climate breakdown’, as this more accurately depicts the problem which humanity is facing;

'Every aspect of our weather is affected by the fact that global temperatures rose by about 4C between the ice age and the 19th century. And every aspect of our weather is affected by the 1C of global warming caused by human activities. While no weather event can be blamed solely on human-driven warming, none is unaffected by it.’ (George Monbiot, in The Guardian, 29/08/2017). 

Scotland is one of the leaders in western Europe on climate change policy and given this status, we only have the impetuous to be more ambitious. Scotland’s policy may be used as a model by our European and international neighbours when drafting their own policies. Being a ‘Climate Leader’ should not be taken as an acknowledgement of past successes alone and Scotland should work at cultivating and strengthening this status in years to come. Scotland should also be looking to take more of a responsibility for consumption based emissions, which are often attributed to the country in which goods are manufactured, though Scottish consumers and policy makers bear a lot of responsibility for the demand in this situation. Scotland should attempt to start these difficult conversations and dialogues at an international level- including attempting to help other states take into account emissions from shipping. This also involves taking decisions to help countries in the Global South to transition their economies, to leapfrog past the highly polluting early phase of development which countries like the UK were built on and to generate an infrastructure which creates resilience to climate shocks that are already setting in at 1 degrees celsius of climate change.  


This principle reminds the Scottish Government of the importance to keep pushing forward in the direction to a zero-emission economy, and is addressed most explicitly in question 9 of the consultation document- ' What are your views on the proposal that any shortfall against previous targets should be made up through subsequent Climate Change Plans?'

This is incredibly important. If there are shortfalls in achieving targets, they cannot be revised downwards and this should flag up a process which would aim to evaluate what has gone wrong in terms of climate policy and industrial strategy, so that such an issue does not occur in subsequent years. 

Broad Alliance members would also like to see a commitment to 'no new fossil fuel frontiers’, in line with an ambition not to raise global temperatures beyond 1.5oC and to continually lower emissions. There has been a lot of discussion about natural gas as ‘bridge fuel’, a ‘clean’ hydrocarbon, which can complement renewable energy technologies. The Broad Alliance is extremely skeptical about the validity of this assessment, given the previously underestimated fugitive emissions of very potent greenhouse gas methane from unconventional gas extraction, which mean the total carbon footprint of unconventional gas is higher than other fossil fuels (Howarth, 2015). A recent report by the New Climate Institute (2017), also highlights the potential for zero-emissions economies by 2050 and the need to move away from fossil fuel infrastructure to meet the target of 1.5 degrees (Celsius) of warming as outlined in the Paris Agreement. In line with this objective, the Broad Alliance would like to see a ban on all forms of unconventional oil and gas within Scotland, including the importing of shale gas which is currently taking place at the INEOS Refinery at Grangemouth and any potential imports of English unconventional gas products.

EU Emissions Trading Scheme and the need for Transparency and Accountability

The Broad Alliance are very supportive of the Scottish Government’s approach the EU Emissions Trading Scheme (ETS). The methodology of the ETS could be misleading and imply that companies are decarbonising their Scottish operations when they are really only offsetting operations in other countries. This means that national governments would have very little control over emissions and be too reliant on EU level mechanisms. I think that the conversation about climate needs to be something which takes place regionally, nationally as well as in communities. Broad Alliance members have concerns that having emissions controlled at only the highest level would leave community perspectives underrepresented and large companies and industry lobbying groups with disproportionate voice. The Environmental Impact assessment also highlights that emissions which take place in Scotland, through road traffic emissions for instance, also has direct impacts on human health in the surrounding community in addition to contributing to climate change. This is also the case for many commercial projects which are based in Scotland that contribute to local emissions issues as well as having this global dimension. This means that the conversation has to be inclusive and in order to do that, this must take place at all levels to include all of the stakeholders in these decisions. Scottish Government leadership on this issue and targets are an important part of this. We are fully supportive of this element of the new bill. 

A Hierarchy of Concerns- Communities and Climate Justice over Competitiveness of Highly Polluting Industries

In general, the Broad Alliance are quite impressed with the criteria of the Scottish Government, as proposed within this Bill, where the Government sets out various pressures on climate policy. There are however stipulations and questions which arise when reading this document. We are not at all satisfied with the ‘competitiveness of particular sectors of the Scottish Economy’ section, as this seems very vague and open to interpretations which are problematic and may even halt the transition to a low carbon economy.If this criteria has to be in this section at all, it should be close to the bottom of a hierarchy of priorities, below efforts to create a ‘fair and safe’ emissions budget. As community members living within areas where fracking is proposed, we do not feel that any industry has an inherent right to be based within Scotland. It is clear that incentivising low carbon and renewable technologies, setting strict emissions targets (as well as the concept of a ‘circular economy’), presents a risk to the competitiveness of the unconventional gas industry and potentially wider fossil fuel interests. This should not be viewed as a barrier to updating targets and the Scottish Government should focus on retraining and a just transition for workers within these industries and areas where such industries are based or proposed rather than being cautious about interfering with corporate competitiveness. Where there are conflicts within policy making, it is clear that communities and the most vulnerable should always be the most important concern. The emissions budget must be ‘fair and safe’ for all citizens of the world, knowing that the people and most vulnerable to the effects of climate breakdown may not reside in Scotland, we nonetheless view their wellbeing as Scotland’s moral concern. Having a policy based on 'climate justice’ would mean that community members and the needs of the wider climate are prioritised above corporate interest. The need for a ‘fair and safe emissions budget’ should be viewed as fundamental and supreme, given a higher level of consideration than ‘competitiveness of particular sectors of the Scottish Economy’. 


Howarth, R., W., 2015. Methane emissions and climatic warming risk from hydraulic fracturing and shale gas development: implications for policy. Energy and Emission Control Technologies2015:3 pp.45–54. 

Jacobson et al., 2017 (in press). 100% Clean and Renewable Wind, Water, and Sunlight All-Sector Energy Roadmaps for 139 Countries of the World, Joule, Available at < http://dx.doi.org/10.1016/j.joule.2017.07.005 >

Monbiot, G. 2017. Why are the crucial questions about Hurricane Harvey not being asked?, in The Guardian, published 29.08.2017. Available at< https://www.theguardian.com/commentisfree/2017/aug/29/hurricane-harvey-manmade-climate-disaster-world-catastrophe >

New Climate Institute., 2017. Foot off the Gas: Increased Reliance on Natural

Gas in the Power Sector Risks an Emissions Lock-in. CAT Decarbonisation Series - climateactiontracker.orgavailable at < https://newclimateinstitute.files.wordpress.com/2017/06/cat-2017-06-16-decarbonisationseries-naturalgas2.pdf > [Accessed 08/09/2017].

Weaver, M., Phipps, C., Levin, S. and Lartey, J. 2017. Caribbean islands suffer huge damage after Irma – as it happened. In The Guardian, published 07/09/2017. Available at < https://www.theguardian.com/world/live/2017/sep/06/hurricane-irma-caribbean-islands-category-5-storm?page=with%3Ablock-59b0ec6ce4b066447a05c903 >