January 2026
Section 1: Delivering a Just Transition
Question 1
What are your views on our approach to delivering a just transition for people and communities?
Tackling poverty is an essential component of ensuring a just transition. The climate and nature emergencies disproportionately affect the poorest and most marginalised children, exacerbating existing inequalities.[1] Yet the word poverty appears only once in this plan.
We do not feel that the outlined approach within the plan goes far enough to ensure the protection of children and families experiencing poverty in Scotland and would like to see that fundamental principles of tackling poverty become more central to the plan.
The latest Concluding Observations from the UN Committee on the Rights of the Child noted a ‘deep concern’ that 250,000 children are living in poverty in Scotland, which equates to around one in four children.[2]
Poverty is not an inevitability in Scotland, it is the result of political choices. We are disappointed that within the plan there is not more mention of supporting households experiencing poverty or the impact on children. More should be done to address this.
While we recognise that the plan and accompanying documents make reference to fuel poverty and outline a range of measures to combat fuel poverty, It is important to note that fuel poverty is only one of the ways that the plan could be addressing the impact of climate change on those experiencing or at risk of experiencing poverty. We have addressed issues relating to fuel poverty later in the consultation. Poverty is a complex issue – it is not just a lack of income but also access to services.
Often when talking about a just transition the focus can be on the creation of jobs and retraining the workforce. While this is important and young people should be given opportunities to develop these skills, it needs to go alongside other measures to tackle poverty. Sixty percent of people in poverty live in a household where someone works and nearly three quarters of children experiencing poverty live in a household where someone works[3]. If a household contains no one capable of working, due to long term illness or disability, the poverty risk is highest with more than half experiencing poverty.[4] If a just transition is to be achieved then efforts to increase income from benefits and to lower the cost of living should become part of the plan.
This plan has the potential to alleviate some issues which exacerbate child poverty, but this will only be achieved if care is taken to ensure a just transition. The focus of a move to net zero must be to reduce inequalities, not widen them. Policies must be in place to share costs fairly. We would like to see the principles of tackling poverty, become a more integral part of the plan. It is important that such principles become part of the fabric of it from the start. We feel that an outcome of the plan should be to alleviate poverty and inequality, bearing in mind that this is more complicated than just creating new jobs.
Families experiencing poverty are more likely to be affected by weather related events but less likely to be able to afford to make adaptations, gain insurance or carry out repairs. Damage can be from flooding, wild fires, heat waves, storms or changes to the seasons. We would like to see this addressed within the plan.
People experiencing poverty are less likely to be covered by insurance. There is a poverty premium with some communities having to pay more. Insurance is more expensive in areas that are seen as more ‘risky’.[5] Leaving these households less able to afford to take measures to protect against flooding or to cover costs to deal with the impacts.[6] If changes to the weather become more severe – whether this is more extremes in temperature or damage from flood or wind damage – the costs of adapting will be much harder to met to these families. We recently wrote about this in our response to the proposed Heat in Buildings Bill Consultation.[7]
We raised these concerns within our response to the consultation on the impact of flooding. Children and young people in Scotland are more vulnerable to the consequences of flooding.[8]
Households experiencing poverty are more exposed to the effects of flooding but are less likely to be able to afford the protections. Low-income households are 8 times more likely to be flooded.[9] Families from poorer communities and households experiencing poverty will experience the effects of flooding more than others.
We are pleased that the Scottish Government have made the commitment to ‘Continue to play a role in delivering global climate justice by securing global change.’ 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 has to 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. We cannot as a society benefit from acts of ecocide in other countries.
Question 4
We wish to highlight the greater impact that the approach to reaching net zero is likely to have on highland and island communities.
These communities face high rates of fuel poverty, linked to having more homes off the gas network and what is known as a ‘rural premium’.[10]
In these areas there are often greater links to industries like fishing, while we have expressed support for the expansion of marine protected areas, care needs to be taken to engage with communities, including children on how this is implemented.[11]
These regions have a disproportionately high number of wind turbines compared to other parts of Scotland—both operational and in planning—in the Highland and Islands region of Scotland compared to other parts of the UK. This region produces around 40% of onshore wind energy.[12] When we have visited schools in highland and island communities to discuss climate justice this is one of the main points they raise, while many support the use of renewable energy they question the disproportionate impact it has on their communities while there is a lack of local benefit. Again care needs to be taken to engage effectively with communities and assess the impact of proposed developments. There should be better community benefits from nearby wind energy to help reduce fuel poverty.
Section 2: Sectoral contributions, Policies and Proposals
Buildings (Residential and Public)
Question 5
How can we decarbonise homes and buildings in a way that is fair and leaves no one behind?
We support the principles outlined in the plan to transition away from the use of polluting heating systems. How we heat our homes and workplaces should be considered through a children’s rights lens. Children and young people are disproportionately affected by environmental issues. This includes an increased risk of health-related issues caused by pollution.[13]
The proposals have the potential to mitigate some of the effects of this by reducing emissions, transitioning away from the use of fossil fuels and making a cleaner and healthier environment for children to grow up in.
At present, the proposed provisions have the potential to alleviate some issues which exacerbate child poverty, particularly for those children experiencing fuel poverty. This will only be achieved if care is taken to ensure this is a just transition. The impact of moving to clean heating must be to reduce inequalities, not widen them. Polices must be in place to share costs fairly.
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.[14]
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.[15] The climate and nature emergencies afflict the poorest and most marginalised worst of all, exacerbating existing inequalities.[16]
Whilst properly insulating homes could lead to cheaper energy bills and work to reduce fuel poverty, the upfront costs of making these changes will be challenging.
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.[17]
Owner-occupiers in this situation may simply not be able to afford to make these changes, despite owning their property. They could lose their homes, putting further pressure on social housing. Households who are on a low income may not have savings to pay for decarbonisation measures. They also may not be able to access loans or payment plans to allow them to do so due to financial exclusion.[18]
In the private rented sector, there are real concerns that these costs will be passed onto tenants already facing rising costs in the private rental sector. This must be considered alongside increased protections for tenants in the form of rent freezes and caps.[19]
The Warmer Homes Scotland (WHS) scheme provides full funding for qualifying properties, Qualifying households include those in receipt of a ‘passport benefit’. This does not fully account for households in poverty, only 37 per cent of owner-occupiers and private renters who experience poverty receive passport benefits, meaning around 200,000 households in poverty in private housing do not qualify (35% of the private sector).[20] These provisions must be re-considered, and sufficient financial support put in place.
Many of the prescribed new heating systems are electricity based. Electricity prices per unit are currently higher than gas prices per unit. This could act as a further driver of fuel poverty even after the transition is made. The Scottish Government will need to ensure the move to ‘clean’ heating systems does not result in more households living in fuel poverty.[21]
Question 6
How can clean heating systems (such as heat pumps) be made more affordable for everyone?
There is a need to make available funding sources which support a variety of financial situations but in particular, those which support those on low incomes and those experiencing poverty.
Transport
Question 8
How can the Scottish Government support communities to participate in planning of local sustainable infrastructure (such as, walking, wheeling and cycling routes)?
If children and young people are going to be able to make use of ‘walking, wheeling and cycling routes’ then a number of factors needs to be addressed.
To begin with, they need to have a bike or a wheelchair which is capable of contributing to the activity and will ensure they are safe. Of course, being able to afford such items will be more challenging for low-income families. there is a real need to increase access to bikes[22], including bikes which are adapted for children with disabilities. Children who require a wheelchair need to be provided with an appropriate wheelchair for outdoor terrain and paths need to be safe and accessible for them to use. This can include access to beach wheelchairs, which are only available from charities in limited places.
Safety is an important consideration. Children need to be protected and feel safe when they are out and about and enjoying activities. This includes road safety from traffic and other road users and paths being well maintained to prevent accidents.
In this study[23] two groups of Scottish children living in two more deprived areas, told researchers about how the place where they lived contributed to their feelings of safety and promoted their health and wellbeing. This showed that the children understand how aspects of disadvantage, including place-based stigma, can limit their social participation and inclusion in society. They focused on aspects such as safety and littering and how this can impact on whether they could feel safe to access their neighbourhood. There are important lessons that can be learned from this study which not only points to the need for more investment in deprived areas but more engagement with children.
Question 9
What action by the Scottish Government would be most helpful in supporting you to live a more climate-friendly lifestyle?
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.[24]
A great deal of emphasis is placed on children and young people making personal changes, sometimes even when adults around them seem unwilling to make changes themselves. But personal changes are only one part of the process.
Most changes need to happen at a more systemic level by governments or industries. The power to make big changes and significantly reduce emissions lies with governments and industries. Those who make, or have made, the most emissions need to bear the most responsibility.
Energy Supply
Question 11
What are your views on Scotland generating more electricity from renewable sources?
We are supportive of Scotland generating more electricity from renewable sources. We would submit that these sites be placed in areas and maintained in ways that do not exacerbate the nature crisis. Ways in which bird populations can be protected should be considered.
Consideration needs to be given to disproportionate impacts on rural, highland and island communities. While it might be difficult to find solutions that please everyone – community involvement and consultation is key to successful projects. These communities should see direct benefits – reduced bills and community ownership.
Agriculture and Land Use, Land Use Change and Forestry (LULUCF)
Question 13
In the preparation of our response to the proposed Biodiversity Strategy we consulted with a group of our Young Advisors – our full responses can be found here[25]. Our Young Advisors were highly concerned about the evidence presented in the State of Nature report – Scottish wildlife has declined by 15% since 1994 and 1 in 9 native species are threatened with extinction.[26] They were clear that they wanted more done to tackle this.
It is clear to children and young people that challenges facing biodiversity loss are as important as the challenge of combatting climate change. Children and young people care a lot about Scotland’s nature. Whether this is protecting declining species from extinction, stopping pollution in our seas and rivers or protecting nature within towns and cities.
One Young Advisor told us;
“I live in a rural area surrounded by agriculture, and I see that the wildlife is not getting what it needs. I also see the impact of the non-native birds released for shooting, it is destroying the local wildlife.” (CYPCS Young Advisor)
We support the importance of investing in nature based solutions helping to reduce nature decline and restore and regenerate biodiversity in Scotland.
Setting targets is a way to measure progress towards the goal of halting biodiversity loss and restoring it.[27] It creates a level of accountability to the public, including children and young people. As supported by those in the environmental sector, these targets can serve as the turning point for threatened species and habitats.[28]
Addressing the indirect drivers of climate change and biodiversity loss is of importance and should form a part of the plan. They are directly relevant to the lives of children and young people. They focus on cultivating overall changes in culture and behaviour, including how children and young people learn about and engage with the environment around them.
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.[29] 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.
We must ensure that educational programmes increase children’s understanding of environmental issues and strengthen their capacity to respond to environmental challenges.
Research has shown that many Scottish children and young people feel there are barriers to their involvement in contributing to a nature-rich future.[30] 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.[31]
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).
Question 14
We are very supportive of these proposals. Both of these endeavours can uphold children’s rights. Both contribute to effective carbon capture and planting more trees promotes the existence of clean air. There should be a focus on planting native, mixed woodland which produce more varied and sustainable ecosystems.[32]Planting more trees and restoring peatland can also lead to better flooding protection.
Question 15
‘Biological diversity (biodiversity) is necessary for healthy ecosystems, which in turn are necessary for the full enjoyment of human rights[33]’
Farming is where our food comes from – which supports the healthy development of children – but it also can have the potential to be polluting.
Many of Scotland’s unique ecosystems are at risk. A recent study found that only 56% of Scotland’s biodiversity remains intact. On the Biodiversity Intactness Index we rank in the bottom 25% (240 countries are contained on the index)[34]. This should put us on notice that more urgently needs to be done on a domestic level to prevent further loss. There are very real threats to nature and climate caused by practices taking place in Scotland this includes the pollution of rivers by unsustainable farming practice or the release of sewage.[35]
Some children and young people have expressed they feel that these industries may be playing a role in the loss of nature and biodiversity. Whilst farming plays a vital role in Scotland, providing healthy and nutritious food, emissions from agriculture are steadily increasing.[36] These industries need to be supported to adapt their practices and made sustainable. Effective advice and support on climate change should be available to them, alongside appropriate restrictions.
We support the call for farming for nature to help boost and preserve biodiversity. This can include using farm practices which protect nesting birds like curlews and corncrakes[37], creating varied hedgerows for smaller birds to nest in[38] and also the creation of wetlands or ponds which not only support wildlife but can act as flood prevention efforts[39].
Section 3: Impact Assessments
Question 16
Children and young people are disproportionately affected by climate change and biodiversity loss. The impact on physical health is of great concern. The World Health Organisation states that climate change presents a ‘fundamental threat to human health’[40]. Children and young people are aware of this and describe to us their worries that climate change will have on their ability to access clean air and water alongside the availability of healthy and nutritious food. We know that climate change exacerbates child health inequalities,[41] children are more vulnerable to the effects of air pollution including an increase in asthma, poorer lung function and negative impact on their growth and development. They are more vulnerable to extreme weather such as heat waves and flooding. An impact of climate change includes rising energy costs meaning, families are struggling to heat their homes. Children, especially infants, are more susceptible to the effects of mould in homes.[42]
Climate change is having an impact on the mental health of children and young people, climate anxiety is something we regularly hear about.
‘Sometimes I get quite sad because it’s overwhelming’ (CYPCS Young Advisor).
There are some particular and disproportionate impacts that climate change may bring to children, young people and their families who are experiencing poverty which we have discussed above.
Disabled people, including children and young people are also disproportionately affected by climate change. Those with low or no mobility would rely on others in climate related extreme weather events – evacuation during flood or fire is more challenging and can pose a much higher risk. If power goes down, then those who rely on medical equipment can be negatively impacted. There is an intersection between poverty and disability as higher rates of disabled people living in poverty, making it harder to mitigate against the effects of extreme weather events. There is also what is coined ‘eco-ableism’ where ecofriendly measures – like limiting car access in built up areas – disproportionately negatively impact on disabled people.
Question 18
While there are many positive policies outlined within the plan there is a clear need to identify where those potential negative impacts are and put in place mitigation and support for those who need it.
A full and detailed child’s rights impact assessment (CRIA) should be carried out at early stages of the plan to identify these interactions. Where there is potential for a negative impact on rights mitigations should put in place.
The plan will serve as the guiding principles of the transition to net zero and it is right that best practice is followed and that rights interactions and potential violations are properly explored at the outset and every stage of implementation, particularly with regard to the impact on child poverty. The plan sets the standards and key considerations for implementation – it guides implementation and must be done in the right way.
It is important the voices and views of children are properly incorporated in this process. The participation of children and young people should be part of the plan.
There is a strong need to take a rights-based approach on the issues of climate change and biodiversity loss. The Special Rapporteur on the environment has commented that children are more at risk from environmental problems than adults but their views and interests are often left out of decisions.[43]
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 they 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.
The draft CRIA states ‘No negative impacts have been identified.’ While we support that addressing climate change is overall positive for children’s rights we feel that the purpose of the CRIA has been overlooked. The point is to identify potential rights interferences and mitigate against them. Some unintended consequences of these policies might impact children, including those experiencing poverty – fuel poverty is mentioned in the CRIA but not noted as a potential rights infringement – this should be highlighted and then mitigated against.
We note that the government intend to published a CRIA to accompany the final Climate Change Plan. We are pleased to see the identification of rights based issues in the draft, but this needs to be further developed.
For example, under the reference for forestry it says that ‘Woodland creation is not directly relevant to The Articles of the UNCRC (Incorporation) (Scotland) Act 2024.’ However this is contradicted by our answer to the relevant question above.
Children and young people’s participation in the creation of policy and law to tackle climate change is essential. Part of ensuring proper participation is in creating child friendly materials to promote engagement. We were pleased to see that the Government had produced a child friendly version of the climate plan. This could be improved by the following:
- it should be made clear what age group the information is aimed at – we see that this is aimed at around the early years of secondary school.
- At present, it is undesigned, monochrome and not very engaging. Visual aids and pictures would be useful to go alongside the content. These things make it more accessible to children and young people.
- When presented on the website the formatting works but when accessed as a document there are errors (repeated lines and missing page numbers) and there are no clear differences between headings and content text.
The government can improve the work it does to listen to children and young people; and include them in decisions being made in a meaningful way. 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 if child friendly documents are available, these are not going to be 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 effective.
[1] On fairness and a low carbon economy: a statement – Just Transition Commission
[2] Official child poverty statistics: Nearly a quarter of Scotland’s children still in poverty | CPAG
[3] Poverty in Scotland 2025 | Joseph Rowntree Foundation
[4] UK Poverty 2025: The essential guide to understanding poverty in the UK | Joseph Rowntree Foundation
[5] CSPF2023_01_Policy_Brief_2024_04_29_FINAL_0.pdf (crew.ac.uk)
[6] Climate change, justice and vulnerability | Joseph Rowntree Foundation (jrf.org.uk)
[7] Proposals for a Heat in Buildings Bill: Consultation response – The Children and Young People’s Commissioner Scotland (cypcs.org.uk)
[8] CSPF2023_01_Policy_Brief_2024_04_29_FINAL_0.pdf (crew.ac.uk)
[9] CSPF2023_01_Policy_Brief_2024_04_29_FINAL_0.pdf (crew.ac.uk)
[10] 3. Challenges – Rural Scotland Data Dashboard: Overview – gov.scot
[11] Response to Scottish Government Consultation on ‘Facilitating Marine Nature Restoration Through Legislation’. – The Children and Young People’s Commissioner Scotland
[12] Regional renewable electricity in 2022
[13] Opportunity/Challenge 8: Ensure that policies, action and spend necessary to mitigate and adapt to the global impacts of climate change deliver a just transition for people in Scotland – Resource Spending Review: Equality and Fairer Scotland Statement – gov.scot (www.gov.scot)
[14] UK Poverty 2024: The essential guide to understanding poverty in the UK | Joseph Rowntree Foundation (jrf.org.uk)
[15] 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)
[16] On fairness and a low carbon economy: a statement – Just Transition Commission
[17] No home left behind: Funding a just transition to clean heat in Scotland (svdcdn.com)
[18] Stage 2 – Evidence – Heat in Buildings Bill consultation: Fairer Scotland impact assessment – gov.scot (www.gov.scot)
[19] Living Rent launch open letter calling for protections after rent cap – Living Rent
[20] No home left behind: Funding a just transition to clean heat in Scotland (svdcdn.com)
[21] Decarbonising heat in homes (audit-scotland.gov.uk)
[22] Inequalities hold our young people back: here’s why increasing access to bikes makes a difference | Cycling Scotland
[23] Children’s perceptions of environment and health in two Scottish neighbourhoods – PMC
[24] 12 ways out of fast fashion – Scottish Youth Parliament (syp.org.uk), Delivering-Scotlands-circular-economy-Scottish-Youth-Parliament-response-August-2022.pdf (syp.org.uk)
[25] Response to Scottish Government Consultation on ‘Tackling the Nature Emergency – Strategic Framework for Biodiversity’. – The Children and Young People’s Commissioner Scotland
[26] Scotland – State of Nature
[27] Legal targets for nature recovery can mark turning point for threatened species – Scotlink
[28] Legal targets for nature recovery can mark turning point for threatened species – Scotlink
[29] Key pressures on biodiversity | NatureScot
[30] NatureScot Research Report 1295 – Youth Survey on NatureScot’s Corporate Plan 2022-2026 | NatureScot
[31] Young Scot Corporate – Young People and Nature Text Only
[32] Woodland: A Nature-Based Solution to Climate Change – Climate change – Our work – The RSPB Community
[33] ‘Report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment’ (2017) A_HRC_34_49_EN.docx (live.com)
[34] 2. The Evidence – Tackling the Nature Emergency – Scottish biodiversity strategy to 2045 – gov.scot (www.gov.scot)
[35] SEPA – ‘The River Basin Management Plan – 2021-2027’ (2021) RBMP3 (sepa.org.uk)
[36] Agri-climate report 2023 – GOV.UK (www.gov.uk)
[37] Curlew – advice for Farmers
[38] Hedgerow biodiversity | Hedgelink
[39] Wetlands, Ponds, & Waterways – Farming for Nature
[41] Child health inequalities and climate change in the UK – position statement | RCPCH
[42] Death of two-year-old from mould in flat a ‘defining moment’, says coroner | Housing | The Guardian