Response to Consultation on the Draft Environment Strategy

We responded to the Scottish Government consultation on the draft
Environment Strategy

Question 1: Do you agree with the vision of the Environment Strategy?

Overall, we welcome the vision of the Environmental Strategy. There are some parts we would like to see developed, especially in relation to the rights of children and young people, particularly those experiencing poverty. These are themes we have outlined throughout the extent of this response.

Scotland (along with the rest of the world) faces a nature-climate crisis. Due to global warming, it is projected that changes for Scotland will include increases in intense, heavy rainfall in both summer and winter, leading to increased flooding. We agree that Scotland needs to significantly improve its response to this crisis, including adaptions to mitigate the effects of climate change,[1] alongside reducing inequality and promoting a good relationship with the natural world.

During our most recent strategic plan consultation, we heard from children and young people from across Scotland on a wide range of issues, including climate change. We have consulted with our Young Advisors on the combined climate and nature crisis, both on climate adaptations and on the Biodiversity Strategy.[2]

There are several issues that are repeatedly raised by the children and young people we work with.

‘Climate change is really important. It’s pointless working on everything ese if the planet is not going to be liveable’ (Child, CYPCS Strategic Plan consultation response)

Climate change is having an impact on the mental health of children and young people. Climate anxiety is something we hear about regularly.

‘Sometimes I get quite sad because it’s overwhelming’ (CYPCS Young Advisor).

It is important that adults, and especially those in power, make robust plans in order to improve our climate.

We are supportive of the strong approach that has been taken in the strategy to tackling the nature crisis, the loss of biodiversity and repairing our relationship with the natural world. We see these themes woven throughout the strategy through creating nature rich spaces, supporting nature-based education and enhancing the role of the arts. This is a matter of significant importance to Scotland’s children and young people.

Children’s Rights – We are pleased to see that a children’s rights-based approach has been outlined in the draft CRIA. Whilst there is room for improvement, we feel that a lot of key issues have been identified in this document.

The Environmental Strategy directly engages UNCRC rights, now incorporated into Scots law, including;

Article 6 – the right to life and development.

Article 12 – the right to express their views freely on all matters affecting them.

Article 24 – the right to good quality health care and a clean environment.

Article 27 – the right to a decent standard of living, including food, housing, water.

Article 28 – the right to education.

The UN Committee on the Rights of the Child highlighted the importance of these issues in its recent General Comment No. 26 (2023)^[3] which focused on children’s rights and the environment;

‘The extent and magnitude of the triple planetary crisis, comprising the climate emergency, the collapse of biodiversity and pervasive pollution, is an urgent and systemic threat to children’s rights globally.’

The most recent Concluding Observations made by the UN Committee on the Rights of the Child with regard to the UK highlighted the need to;

‘Ensure that national policies and programmes on addressing environmental protection, climate change and disaster risk management… are developed and implemented in accordance with the principles of the Convention and take into account children’s needs and views^[4].’

Article 6 – Life and Development

Children and young people are more vulnerable to the health related impacts of climate change. For example, Studies have shown that children from deprived areas are disproportionately affected by air pollution and more likely to live near major roads.[5] Children and young people in Scotland are relatively more vulnerable to the consequences of flooding.[6]

Fuel poverty has some serious consequences for children and young people. Studies have found an increased risk of respiratory diseases and other health conditions associated with exposure to mould. This results in more hospital admissions. It has also been shown that there is a link between fuel poverty and low educational attainment.[7] The climate and nature emergencies afflict the poorest and most marginalised worst of all, exacerbating existing inequalities.[8]

Article 12 – Right to Express Views

What we have not seen addressed in the Strategy or the CRIA are the importance of children and young people’s article 12 rights to have their views heard and to be active participants in the creation and development of environmental policy.

Children and young people should be properly involved in decision making processes surrounding these issues. This should be meaningful, effective and not tokenistic. They must be actively involved in identifying solutions and policy and legislative changes to address the environmental emergency.

Meaningful participation of children and young people in matters surrounding environmental issues needs to be progressed. Children and young people are clear that it is their future environment and want to be properly involved in protecting it. They should be fully consulted in environmental decision making. They have clear ideas on how to protect their health, that of the planet, and ensure their right to a healthy environment.

There is a lack of participation and engagement of children and young people in climate focused areas of policy and law. If the government and policy makers do not include children and young people and listen to their voices, then they cannot be properly part of the solutions. As stated by one Scottish Youth Parliament Member;

‘When young people are part of the conversation, they ensure policies and targets are ambitious and hold decision makers to account. But it is also a critical part of building climate solutions. By involving young people in decision-making on climate in a meaningful way, you gain:

Fresh ideas and perspectives on climate solutions,
Future leaders to tackle the challenges we will inherit,
And the support of a key group who will have to make sustainable personal choices if Scotland is going to tackle the climate emergency.’[9]

Children and young people have consistently told us that they feel like the government and other decision-makers do not include them properly.

Some told us they feel powerless and that ‘no one listens’ and this can lead to apathy;

‘At this point what can we do – the governments are not doing what they need to’(Child, CYPCS Strategic Plan consultation response)

Some comment that young people are not taken seriously or that young activists are ridiculed.

We spoke to our Young Advisors about what meaningful and effective participation should look like. They told us that the ways in which consultations were done were a real barrier to them. Little effort is made to make materials available in child friendly formats. Even where more child friendly documents are available, these are not appropriate for all children and young people.

‘It works great if it’s easily accessible to all children and young people.’ (CYPCS Young Advisor).

Some suggested that more has to be done to reach them – politicians and civil servants should be making the effort to engage with schools and other organisations to find out what they think.

‘Workshops are really good ideas. It would work really well if they did that in schools or community groups. Lots of different people.’ (CYPCS Young Advisor).

They suggested that doing surveys were a good way to allow a range of children to give their opinions.

They thought that making videos was a helpful tool – most children spend time accessing social media and they felt that these communication channels could be better used to reach them.

‘How many people my age are going to read the document? Videos…we live with social media. If you really want a mass of young people, the best way to do that would be to get it over that way.’ (CYPCS Young Advisor).

‘I know a lot of people in my school don’t enjoy reading and would enjoy listening to podcasts.’ (CYPCS Young Advisor).

Some spoke positively about events they had been to in the past on education reform and felt similar formats might be used to discuss climate change.

‘National Discussions…in a local area people from different schools. There was primary and secondary school children talking to each other. It was very good. They had us make videos. I did a rap. I want to know the impact of my rap!’ (CYPCS Young Advisor).

They also wanted to share that being asked about an idea once and then never hearing from decision makers again was not acceptable. They want decision makers to be accountable to them and return to tell them how their input has been used and in what ways it has been considered.

Children and Young People as Active Participants –

Within the CRIA we note that there is a need to recognise that children and young people are not only rights holders when considering the environment but also active participants in nature restoration activities and climate activism. Promoting and protecting this status should be included within the assessment.

As outlined in our response to the Marine Restoration consultation[10], we note that there has been a ‘strong groundswell of interest from local communities across Scotland who want to take part in nature restoration in the marine environment’[11] – this includes groups of children and young people, for example:

Ullapool Sea Savers[12] who have been doing some excellent work both to raise awareness of marine related issues and to actively be involved in conservation work.
Young Sea Changers Scotland[13], who state as part of their mission;

‘We directly engage with marine policymakers and stakeholders to ensure that young people’s voices are heard. We advocate for policy engagement processes that are accessible to young people, ensuring their ideas and solutions stand alongside those of established sectors’.

Another recent project saw school children adopt oysters to be grown in cages before being released in the local loch, participants in this projects spoke of growing up with a sense of ownership for the oysters and thereafter the loch.[14] Some of these issues were also explored in our response to the Flood adaptation Plan consultation.[15]

A project conducted by the National Flood Forum, in connection with Save the Children, looked at the lived experience of children and young people affected by flooding.[16] They reported that recognising children’s perspectives was an important part of building community resilience to flooding. They also highlighted that understanding children’s capacity was of vital importance. Children wanted to be included in prevention work and wanted to understand what the risks were. They also wanted to be recognised in recovery efforts. This gave them a sense of ownership in a time when much of what they had had been taken away or they had been displaced.

They recommended that there by some form of flood education programme in schools, to learn about flood warnings or make a flood plan, this was identified by the child participants as being important.

‘Children should be given more information before, during and after flooding because they have the right to know how to prepare, what to expect and how they can contribute. Children can play an active part in helping their communities during and after a flood and derive benefit from this. Such efforts need to be understood so that children can be seen as active citizens and not passive victims.’

Children and young people must also be properly protected from any negative reprisals from acting as human rights defenders, when taking part in demonstrations.

Article 24 – Right to a Healthy Environment

We note that within the Strategy it is mentioned that the right to a healthy environment had been developed within the Scottish Human Rights Bill. Putting aside the challenges that Bill has had, it is important to recognise that children and young people do already have a right to a healthy environment enshrined within Article 24 and incorporated within domestic law in the UNCRC (Incorporation) (Scotland) Act 2024.

Article 28 – Right to Education

Children and young people clearly want to learn more about environmental issues, including biodiversity loss and what they can do to contribute to improving this. Our Young Advisors wanted young people to be involved in decisions that were made on these issues and highlighted that it’s ‘our future land’. They felt they needed more information to be able to do this;

“There was not enough education provided so I went out and researched it, I didn’t get taught in school” (CYPCS Young Advisor).

The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) highlighted that people’s disconnection to nature leads to a lack of value and importance being placed on it.[17] This is itself an indirect driver of biodiversity loss, it can lead to patterns of unsustainable production and consumption. Children and young people need to be taught, not just about nature, but what they can do to help it.

This was reflected in the most recent Concluding Observations on the UK by the UN Committee of the Rights of the Child who stressed that the UK needed to ensure education through ‘active participation of schools’ on climate change, to raise children’s awareness. This should include; ‘awareness-raising for children on relevant climate legislation and their right to a clean environment and the enjoyment of the highest attainable standard of health’.[18]

Research has shown that many Scottish children and young people feel there are barriers to their involvement in contributing to a nature-rich future.[19] Although 76% of children and young people felt nature was important to them, the vast majority were not involved in any nature or conservation activities.[20] A lack of education and relevant opportunities have been highlighted as contributing to this.

There are inequalities in accessing outdoor or nature-based education and activities, this could be addressed more fully through overarching goals and policies to reduce poverty and inequality, something we have outlined later in our submission.

Question 2: Are there any outcomes that you feel should be removed, added or changed in the Environment Strategy? Outcome pathways

We have developed our answer to this more fully in response to Question 9 where we outline that we feel a specific outcome regarding reducing poverty and inequality should be added to the outcomes and not just included within the umbrella term of ‘just transition’.

Question 5: What are the top priorities the Scottish Government should focus on to improve the environmental impact of Scotland’s activities on other countries? – For example, this could include the impacts of producing the goods and services we import into Scotland, our exports of waste and our approach to international engagement.

Under the Paris Agreement[21] there was a commitment made to recognise ‘common but differentiated responsibilities and respective capabilities’; acknowledging the variations in capability and responsibility of individual countries to respond to climate change. Countries like Scotland have a bigger role to play on a global level.

Whilst we are concerned with the effects of climate change in Scotland, children and young people often speak to us about the global impact of climate change. Scotland must be conscious not only of the damage that is done to our own environment here in Scotland but the impact we have on a wider scale. We cannot simply ‘outsource’ our emissions, or waste to other countries or rely on taking resources from them. This is a matter which holds great importance to children and young people in Scotland

Question 7: To what extent do you agree/disagree that societal changes, including in our lifestyles and behaviours, are needed to help tackle the nature, climate and pollution crises? If you agree, please explain in the text box below how you think the Scottish Government could most effectively support and enable these changes in ways that also help to improve people’s lives and tackle inequalities. Or, if you disagree, please explain in the text box below why you don’t think that societal changes, including in our lifestyles and behaviours, are needed to help tackle the nature, climate and pollution crises.

We agree that societal changes, including in our lifestyles and behaviours are needed. However, those who cause the most damage to the environment should bear the brunt of these changes.

‘It’s frustrating we change our lifestyles but it’s discouraging, It’s caused by big companies – not by average people’ (Child, CYPCS Strategic Plan consultation response)

‘I worry about climate change and how everyone says to do something, but they don’t let us’ (Child, CYPCS Strategic Plan consultation response)

Children and young people regularly demonstrate that they are willing to make personal changes. We have been inspired by some of the climate related activities we have seen in schools – clothing swaps, eco-clubs, school gardens. Many young people are involved in nature-based activities, some simply to enjoy a connection to nature or others to actively care for this such as through the Scouts, Woodcraft Folk or the Junior Rangers Project.

There are many children and young people taking personal actions where they can and demonstrating knowledge and care on issues like fast fashion, recycling, and the circular economy.[22]

A great deal of responsibility is placed on children and young people to make personal changes, sometimes even when adults around them seem unwilling to make changes themselves. Personal changes are only one part of the process and a lot of the changes that need to happen are at a more systemic level by governments or industries.

Question 9: To what extent do you agree/disagree that a just transition to a net zero, nature positive, circular economy is needed to support Scotland’s role in tackling the nature, climate and pollution crises? If you agree, please explain in the text box below how you think the Scottish Government could most effectively support this transition in ways that create wider economic opportunities for Scotland, including for jobs and businesses. Or, if you disagree, please explain in the text box below why you don’t think a just transition to a net zero, nature positive, circular economy is needed to support Scotland’s role in tackling the nature, climate and pollution crises.

We strongly agree that a ‘just transition’ is needed and we would like to see more importance placed on this within the plan alongside more detail on what this involves.

A just transition will involve considering the impact on different vulnerable groups within Scotland. This includes the impact on children and young people, we are particularly concerned with the effects climate change policy will have on households experiencing poverty. Addressing climate change is intrinsically linked to reducing poverty and inequality as those who experience poverty and inequality are more vulnerable to the effects of climate change and less able to adapt to it.

Delivering a just transition means ensuring that adapting to climate change is achieved in a fair way that does not disproportionately, negatively impact children and young people. Considering environmental policy as a children’s rights issue is important, to fully understand the impact it has on children and young people.

We note that mention is given to reducing poverty, but we feel that this alongside reducing inequalities, should be a primary focus of the strategy and woven through every part. In the outcomes, the only mention is with reference to a ‘just transition’ in 2.2. This is an umbrella term and what is meant by a just transition can be interpreted in different ways. Sometimes the focus of this can solely translate to policies surrounding green energy jobs without enough consideration to the need to significantly reduce poverty. We would like to see poverty and inequality more explicitly addressed in the outcomes, bringing this to the forefront of the strategy.

Scotland has some areas with the lowest life expectancy in the UK. Around 1 in 5 people in Scotland live in poverty and shockingly, 1 in 4 children.[23] Poverty is not an inevitability in Scotland, it is the result of political choices.

Those experiencing poverty are more likely to suffer the effects of climate change and are less equipped to deal with the consequences. For example, low-income households are 8 times more likely to be flooded.[24]

People experiencing poverty are less likely to be covered by insurance. We know that there is a poverty premium with some communities having to pay more for services. Insurance is more expensive in areas that are seen as more ‘risky’.[25] Leaving these households less able to afford to take measures to protect against flooding or to cover costs to deal with the impacts.[26]

The Joseph Rowantree Foundation has highlighted that;

‘While considerable effort has been made to understand patterns of current and future hazard-exposure, much less effort has been spent on addressing social, personal and environmental factors that render people more or less vulnerable to losses in well-being.’[27]

Within the Strategy there are some parts which could be better developed to focus on reducing poverty;

Creation of Jobs –

There is focus on the benefits of the creation of a wide range of green jobs. Whilst this is welcome policy, it is important to recognise that the creation of jobs is not the only measure needed to reduce poverty and inequality.

There are many barriers to accessing employment including disability, ill health, refugee status and childcare needs. Experiences of poverty are incredibly complex; it must also be noted that in-work poverty is a real issue in Scotland. The proportion of working-age adults in poverty living in working households has increased, with 61% of working-age adults and 75% of children in poverty living in a household with at least one adult in work[28].

Within the sections of the strategy on food, transport and housing, we see that more could be developed here to address issues of inequalities in these areas. The theme of addressing poverty could be woven in at every stage.

Food –

There are significant barriers to shifting food habits for those experiencing poverty. The foods they would need to switch to can be more expensive and require cooking, involving paying for utilities. Many people do not yet have knowledge of sustainable food habits.

Transport –

For transport, an acknowledgement that those who are wealthier are responsible for more emissions so should shoulder the costs, for example discussions around emissions from aviation. This is simply not something being used by the poorest in society nor is owning a car. They will rely far more on public transport, which has variable quality and availability, especially in rural areas or for those working late hours or shift patterns.

Housing –

When discussing issues of housing it is important to address the issues of homelessness in Scotland, including those in temporary accommodation. Alongside issues of fuel poverty.

The Scottish Fuel Poverty Advisory Panel highlight that in Scotland around 850,000 households (34% of households) are currently living in fuel poverty and 23% of households are living in extreme fuel poverty. These issues are deepening with the cost-of-living crisis, and many families need to make the choice between heating and eating.[29]

With new provisions on heat in buildings it is important to protect those in the private rented sector from having the costs of adaptations passed down by the landlord in increases in rent. The impact of moving to clean heating must be to reduce inequalities, not widen them. Polices must be in place to share costs fairly.

We agree with the recommendations made by the Institute for Public Policy Research (IPPR) that low-income and vulnerable households must be supported with the costs of transition, ensuring that costs are fair across the income spectrum – meaning a progressive distribution. They recommend the use of up-front grants to fund the transition.[30]

Overall

We should try to understand the unique experiences and vulnerability of children and young people, especially those experiencing poverty. There are social dimensions to vulnerability to climate change, the effects of extreme weather events will not be distributed evenly. How badly a person or group will be affected will depend not just on their exposure to the event, but on their vulnerability. We recognise that there is reference to this, but we feel that there should be more importance placed on this and more focus at various stages of the strategy on how this can be addressed.

[1] Response to the Climate Change Adaptation Plan Consultation. – The Children and Young People’s Commissioner Scotland (cypcs.org.uk)

[2] Response to Scottish Government Consultation on ‘Tackling the Nature Emergency – Strategic Framework for Biodiversity’. – The Children and Young People’s Commissioner Scotland (cypcs.org.uk)

[3] CRC/C/GC/26: General comment No. 26 (2023) on children’s rights and the environment with a special focus on climate change | OHCHR

[4] Concluding observations on the combined 6th and 7th periodic reports of the United Kingdom of Great Britain and Northern Ireland :

[5] socrr23_final.pdf (togetherscotland.org.uk)

[6] CSPF2023_01_Policy_Brief_2024_04_29_FINAL_0.pdf (crew.ac.uk)

[7] How fuel poverty affects children – Beat the Cold (beatcold.org.uk), The impact of Fuel Poverty on Children Professor Christine Liddell Fuel Poverty FINAL (savethechildren.org.uk)

[8] On fairness and a low carbon economy: a statement – Just Transition Commission

[9] #CabinetTakeover 2023: Climate Crisis – Scottish Youth Parliament (syp.org.uk)

[10] Response to Scottish Government Consultation on ‘Facilitating Marine Nature Restoration Through Legislation’. – The Children and Young People’s Commissioner Scotland

[11] Facilitating marine nature restoration through legislation (www.gov.scot)

[12] Ullapool Sea Savers