i. Accountability. The Bill currently contains no consequences for Ministers who miss their targets. Given that they are responsible for their success or failure, Ministers need to know what will happen if they fail.
ii. Urgency. The current proposal for annual targets suggests a very relaxed start, with very low reductions in emissions until 2020. Earlier shifts will make the biggest difference to Scotland's overall contribution to climate change and provide better opportunities to gain the competitive advantages a low carbon economy will bring. A stronger start is therefore needed.
iii. Domestic action. The draft Bill contains no limit set on the proportion of Scotland's emissions reductions which can be "bought in" through international credits. It is vital that all or almost all of these reductions are actually achieved here in Scotland. Support for emissions reductions in developing countries is vitally important, but it not a substitute for putting our own house in order.
iv. Scientific independence. The Bill proposes to use the UK Climate Change Committee to provide scientific advice, and to allow Ministers to create a Scottish version if they see fit. However, the Scottish Committee would, if the Bill is unamended, be appointed by Scottish Ministers, not Parliament, which reduces its independence and credibility, not least because Ministers do not always have a working majority in Parliament.
v. Scale. The Bill proposes a long term 2050 target of 80% reductions in Scotland's emissions, but the evidence from the internationally-respected Tyndall Centre and others is that a 90% reduction will be required over this same period.
vi. Policy shift. The Scottish Government's policies as currently designed will aggravate climate change, especially in the areas of transport, energy and demand reduction. Ministers cannot promote airport expansion and a massive road-building programme and simultaneously deliver a credible policy on climate change. The Bill does move towards discussion of the implications for each sector of the economy, but does not mandate sector by sector targets and an action plan to deliver them.
Anything else you'd add?
And what marks would you give the SNP? I give it a B+, could try harder. It's certainly better than the B- I'd expected.
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