E: Cabinet Secretary for Climate Action and Energy
E: Cabinet Secretary for Housing
09 January 2026
Dear Ms Martin,
Developing the Just Transition approach in the draft Climate Change Plan
We write in connection to the ongoing consultation on the draft Climate Change Plan, having had a constructive meeting with officials last month. We welcome the draft plan, which we consider has the potential to be the strongest Climate Change Plan the Scottish Government has so far produced. The further embedding of just transition principles within the plan and its heightened attention to the distribution of costs and benefits, including through the initial set of indicators for just transition, represent a real step forward. We hope to see further policy detail in terms of anticipated changes for households, workers, businesses and communities to strengthen the plan’s potential for successful delivery.
The Commission would welcome any opportunity for further constructive engagement on the Plan, in particular to (i) help strengthen the way the plan tackles areas of critical risk in terms of inequality, and (ii) help to develop proposals to support its practical delivery, particularly the justice elements associated with specific changes. We encourage the Scottish Government to consider how to maximise responses within the consultation period, by clearly communicating the key messages and proposed changes for feedback from groups likely to be impacted.
Further to this letter, we expect the final report of this second iteration of the Commission to be published on February 19 2026. As with our previously published reporting and research to date, this should provide a useful resource for policymakers to support the further development of the Climate Change Plan.
The following are some high-level points intended to support work to revise the draft plan:
- There is no just path to Net Zero through deindustrialisation. The plan should be clear that while some of Scotland’s highest emitting industrial sites are closing, disorderly and unplanned closures are not how we deliver a just transition and pose a critical risk to the social license for climate action. In terms of successful implementation of emissions reductions, cliff-edge job losses such as those at Grangemouth and Mossmorran are unwelcome and urgent work will be progressed to avoid any repeat. A greater emphasis is needed on how we can increase the number of good quality jobs in relatively dependable roles addressing emerging areas of need such as the built environment. To avoid any single points of failure in terms of its economic impact, the plan should consider contingencies to limit the reliance on emerging technologies whose economic footprint is relatively hard to predict or volatile, noting that some new economic activities typically create only a small number of jobs (for example, data centres). Can the revised plan offer more to working people in terms of jobs?
- More robust actions are needed on the built environment. The revised plan should provide greater certainty on the timing and sequencing of critical changes, to counter the risk of prolonging uncertainty for industry and the critical knock-on impact for our skills and workforce pipeline. In terms of costs and benefits there is significant potential up-side here in terms of improving people’s housing, bringing down bills, and creating good jobs. The plan should provide not only aspiration but detail in terms of the delivery of emissions reductions for this sector, including making it easier for individual households to make necessary improvements. Housing and the built environment should be included in the business section, since it is critical economic infrastructure as well as social infrastructure.
- Get ahead of potential injustices (M&E) and clarify how the plan’s just transition elements will be delivered and enhanced. This draft plan provides a strong starting point towards an approach that can better predict and pre-empt the likely effects of specific policies in terms of inequalities. We would welcome the opportunity to support the further development of the just transition indicators and how these can support practical delivery. Early warning indicators on decarbonisation clearly have a positive role to play. Can these also be developed for the social and economic dimension of the transition, such as the impact of policies on poorer households? Success here would be of international relevance as every jurisdiction will need to address these issues in time, and the new UN Just Transition Mechanism provides an ideal route to enable international learning from such policy innovation in Scotland. The M&E will be most useful to the extent that it can support an early warning system, tied to clear response mechanisms, for example, a formal requirement for ministers to report on an annual basis to parliament using just transition indicators, and set out the government’s planned response to areas of concern. The approach should also develop to allow integration and read-across to climate impact indicators for a combined view of just transition progress in terms of both climate action and climate risk.
- A greater level of detail is needed regarding specific policies and proposals within sectors. This will help surface any major risks or opportunities to realising a just transition, including allowing for a more comprehensive equalities impact assessment across different regions of Scotland and over defined timelines. This will also support a better understanding of how sensitive the success or failure of the plan’s objectives are to particular areas, as well as what possible contingencies would be.
We look forward to further constructive engagement to inform the development of the Climate Change Plan.
Sincerely,
Professor Dave Reay and Satwat Rehman
Co-Chairs of the Just Transition Commission