Response to the Scottish Government consultation on creating an Environment Strategy

We answer some specific questions the Scottish Government asks about creating an Environment Strategy for Scotland, but also make these overall points:

The discussion paper says that a new Environment Strategy will “provide a strategic statement of the ambition and high-level outcomes that [existing strategies] work collectively to deliver.” While it is useful to summarise what other strategies will do for the environment, an Environment Strategy should be an actual strategy not a catalogue of environment-related commitments across government. It should work the other way around – the Environment Strategy should set out our strategic priorities and targets for the environment, which then influence and set a framework for the other strategies of government.

We welcome the balance between economic, social and environmental considerations which runs through the text, also the acknowledgement that landscapes and nature “are precious in their own right” and the ambition to “lead global action to address current and future environmental challenges.”

There is some excellent language on the scale of the climate/resources challenge including references to Scotland’s resource use requiring “more than three planets,” aiming to be “within planetary limits” and to “reduce Scotland’s international ecological footprint,” as well as an ambition to be part of “a world where no country uses more resources than the Earth can support and [replenishes] the natural systems that sustain us.” We also welcome the acknowledgement that there is a “moral responsibility” of “driving the transition to a low-carbon resource efficient economy.”

However, we note that the central purpose of the Scottish Government as described in the National Performance Framework “to focus on creating a more successful country with opportunities for all of Scotland to flourish through increased wellbeing, and sustainable and inclusive economic growth” is at odds with these aims. At this point in time, with resource and ecosystem collapse rapidly approaching, continued economic growth is by its very nature not sustainable, and simply not possible within planetary limits unless it is at the expense of other nations prosperity and wellbeing (as much of our historical growth has been). It is critical therefore, that the welcome development of an Environment Strategy for Scotland goes beyond summarising existing commitments, sets realistic goals within the context of planetary limits that ultimately lead to change across all portfolios, and a revised central purpose of sustainable development – that is development within environmental and social limits.

We very much welcome the theme of “protecting, maintaining and enhancing EU environmental standards” and the commitment to the four EU environmental principles, and to consult on environment governance. It is welcome that the discussion paper points to possible legislative approaches on this front, and we consider it essential that the 4 principles are enshrined in legislation. In relation to these themes we also support the Scottish Government’s priority to expand Scotland’s devolved powers and to maintain funding for environmental outcomes at least at current levels. We strongly believe the establishment of a specialist environmental court or tribunal is the best way to address environmental governance in relation to both Brexit and compliance with the Aarhus Convention. Further, the strategy should be developed in the context of the emerging UN framework principles on the right to a healthy and safe environment.

As the paper suggests Scotland did indeed take an early lead on climate targets, has been praised for its thinking on the circular economy and has proposed to ban fracking. The early commitment to contributing to the UN Sustainable Development Goals was also very commendable. But some of the good aspiration and fine words in the paper are overshadowed by under delivery or contradiction in a number of areas:

• the implication that the proposed targets in the Climate Bill are an adequate response to the Paris Agreement is not true, since they require Scotland to do almost nothing more than the current 2009 Act for the next decade. Friends of the Earth Scotland supports the Stop Climate Chaos Scotland call for a target of at least 77% reduction by 2030 and also calls for a target of net-zero emissions by 2040 at the latest.
• the paper notes that the Cleaner Air for Scotland strategy “sets out how we will reduce air pollution to protect human health and fulfil EU legal commitments by 2020” but it is quite clear that we will fail to meet that target, despite the new commitment to Low Emission Zones.
• the circular economy strategy and related international accolades, followed by more recent activity on plastic waste and the proposed Deposit Return System, are welcome but we still await a timetable and indication of content for the promised Circular Economy Bill.
• continued support for North Sea oil and gas development in the new Energy Strategy, including continued exploration, despite the fact that over 80% of known fossil fuel reserves are unburnable if we want to limit warming to ‘well below’ 2ºC. A rapid and just transition away from our economic and structural dependence on fossil fuels is essential to achieving the aim of meeting climate targets and living within planetary limits.

Download the document below to see our full response.