E: Acting Cabinet Secretary for Net Zero and Energy
E: Acting Minister for Climate Action
28 April 2025
Dear Ms Martin,
Applying a just transition approach to the next Climate Change Plan
We welcome your officials’ proposal to hold a discussion with the Just Transition Commission to support policy development on the next Climate Change Plan (CCP) in the coming weeks. To help structure this discussion, this letter contains high-level considerations from the Commission on the critical strategic elements of the next CCP from a just transition perspective. We expect more granular advice will follow through our further engagement with this process.
In the absence of a new CCP, policy development on sectoral just transition plans has proceeded without a clearly defined set of parameters in terms of the specific mitigation policies around which fairness impacts require to be assessed. However, work to progress the Just Transition Planning Framework, including via the three major sectors where emissions are not coming down (Transport, Land Use and Agriculture, the Built Environment), as well as our own information-gathering, research and reporting, mean there are now particularly strong resources for policymakers to draw on to ensure just transition is applied in a sophisticated and enabling way within the next CCP.
This work, progressed through the dedicated input of a large number of people within and outwith your government over recent years, should help to strengthen the social license for the complex and challenging measures that will be required for Scotland to meet its obligations and rebuild its credibility as a climate leader. As you know, the Scottish Government has a legal duty as regards climate policy to demonstrate how just transition principles have been applied so as to develop and maintain social consensus through engagement with workers, trade unions, communities, non-governmental organisations, representatives of the interests of business and industry.
We look forward to scrutinising the fairness implications of mitigation policies proposed, how costs and benefits can be shared equitably and vulnerable groups protected from negative impacts.
There is now a premium on specific, tangible policy actions, based on this wealth of evidence and analysis. The new CCP should demonstrate strong and determined leadership on climate, including by giving clear messages on what will be done to avoid disadvantaging communities in rural and deprived areas.
The following are some high-level points for consideration.
- Monitoring and Evaluation. As advised in our annual report for 2024, our view is that the CCP should embed a clear, tangible process for assessing the fairness of mitigation measures including by integrating interim targets on just transition. Given the work undertaken since the previous CCP, we hope to see marked progress from high-level reference to just transition principles to a more detailed, rigorous and measurable application. It will be a major strong point for Scotland in the context of international climate policy making if we can develop a CCP with a positive, measurable element regarding the impact of climate policy on people.
- Put numbers on the social and economic up-side. The plan should be very clear about the benefits of a just transition to a low carbon economy, whether social, economic or environmental. This will require appropriate analytical capacity allocated to the development of the plan to provide robust evidence.
- Quantify the cost of failure. The plan should spell out with as much precision as possible what inaction and delay on climate will mean so that measures set out in the plan can be assessed against the counterfactual of inaction, in terms of climate impacts, missed economic opportunities, and late-mover costs.
- Land use and agriculture. The plan should clearly establish what emissions reductions measures will be taken as regards livestock and how the associated impacts will be managed, including for small producers, how tree planting will be accelerated to the levels required in a fair way, and what the delivery model for achieving the required progress on peatland restoration will be (including the required workforce). Where delivery will be slower than required, the plan should specify which other areas will make up for shortfalls.
- Heat. Clarity is needed on the options that will be taken up to finance heat decarbonisation (including via property purchases), and how these align with just transition principles so that emissions are reduced in a way which does not disadvantage those in greatest need and on low incomes.
- Transport. The plan should clearly set out what measures will be taken to reduce car use and when, integrating key just transition considerations to manage the impact of such changes, including to mitigate the risk of worsening social isolation. The plan should establish what modes will replace reduced car mileage and how this will be managed to optimise equitable outcomes.
- High emitters. In applying the core just transition principle of the equitable sharing of costs and benefits, there will be significant value in demonstrating that those with broadest shoulders and those responsible for highest emissions will be expected to pay a proportionately larger amount of the costs of transition. This could be applied to, for example, aviation (frequent fliers) and luxury high emitting vehicles. Even if these represent a relatively small percentage of emissions, addressing these more conspicuous forms of high carbon activity will be important to public perceptions of fairness and strengthen the credibility of other measures affecting basic essentials.
- Avoid over-reliance on sequestration. There is a risk of “balancing the books” in terms of emissions on sequestration rather than honestly assessing and communicating the scale of the challenge and the need for specific sectors to decarbonise much further and faster to achieve goals. We look forward to scrutinising and advising on the jobs and skills implications of CCUS proposals, particularly the just transition implications of the land use change elements of sequestration.
The Commission previously made a public statement on the topic of fairness and the transition to a low carbon economy at a time when it was a prominent topic within public debates and political announcements at UK level. In it, we noted the following:
- The strength of a just transition approach is that it offers a structured way of working through the fairness issues associated with policies that reduce our emissions. The aspiration to achieve a just transition must never be used as rhetorical cover for inaction or delay. The climate and nature emergencies afflict the poorest and most marginalised worst of all, exacerbating existing inequalities. This demands bold and innovative action to build genuine social and economic resilience in place of a status quo that is deeply unjust, as the number of people in fuel poverty and ongoing cost of living crisis shows. Policies and strategies that prolong business-as-usual in the name of fairness may achieve other ends, but they will not help to deliver a low carbon economy in a fair way.
We look forward to playing a constructive role in providing scrutiny and advice on the plan’s development, including its component chapters, and are keen to engage respective policy teams across critical areas as work proceeds.
Yours sincerely,
Professor Dave Reay and Satwat Rehman
Co-Chairs of the Just Transition Commission