Climate Change: a consultation on proposals for a Scottish Climate Change Bill

Consultation Response Climate Change: a consultation on proposals for a Scottish Climate Change Bill Jonathan Hughes Head of Policy June 2008 1

About the Scottish Wildlife Trust (SWT) The Scottish Wildlife Trust (SWT) was founded in 1964 to take all appropriate measures to conserve the fauna, flora, and all objects of natural history in trust throughout Scotland. With 30,000 members, several hundred of whom are actively involved in conservation activities locally, we are proud to say we are now the largest voluntary body working for all the wildlife of Scotland. The Trust owns or manages 124 wildlife reserves and campaigns at local and national levels to ensure wildlife is protected and enhanced for future generations to enjoy. Introduction SWT welcomes this opportunity to contribute to the development of the Scottish Climate Change Bill. SWT believes that quite apart from the direct impact on humanity, climate change is also one of the biggest threats that Scotland s natural environment has ever faced. In relation specifically to biodiversity threats, a recent report by the UK Biodiversity Partnership 1 identified a number of direct key impacts of climate change upon ecosystems as evidenced from observational data and models of future trends. These include: changes to habitats and ecosystems, such as altered water regimes increased rates of decomposition in bogs and higher growth rates in forests changes to the composition of plant and animal communities changes in the timings of seasonal events, leading to loss of synchrony between species and the availability of food, and other resources upon which they depend shifts in suitable climate conditions for individual species leading to change in abundance and range changes in the habitats which species occupy SWT urges the Scottish Government to ensure not only that GHG emissions targets are achieved rapidly to limit the impact of climate change on the natural environment, but also urgently implements a package of adaptation measures under the Scottish Climate Change Adaptation Strategy. Summary of SWT recommendations In addition to the detailed comments under the questions posed in the consultation document, we have provided a summary of some of our key recommendations below. SWT recommends the Bill: Sets long and medium term greenhouse gas reduction (GHG) targets. The Bill should require Government to keep within a fair share of global greenhouse gas emissions, at a level that restricts temperature rise to 2 C. Based on current scientific evidence this requires an overarching target to reduce greenhouse gases by at least 80% by 2050, based on 1990 levels. An interim target of 50% by 2020 should also be included as this is consistent with preventing an above 2 C rise. 1 UK BAP Partnership (2007) Conserving biodiversity in a changing climate. Defra. 2

Sets statutory annual GHG reductions of at least 3%. Year on year cuts of at least 3% will be required to ensure that overall targets are met. Lower rates of annual progress will mean a higher level of cumulative emissions. Includes a duty on all public bodies to deliver their climate change responsibilities in a manner that furthers the delivery of sustainable development and the conservation of biological diversity. Ensures climate change is tackled sustainable way which does not lead to irreversible damage to the natural environment and biodiversity. The Bill should require future policies for mitigation and adaptation to be developed in accordance with the principles of sustainable development, including the conservation and enhancement of biodiversity (see also above regarding sustainability duty ). Introduces a requirement on Scottish Ministers to adapt to climate change. The Bill must include a requirement on Ministers to produce an adaptation strategy that includes environmental measures as well as a statutory requirement to regularly report on progress with adaptation measures. Includes international aviation and shipping in targets. International aviation and shipping emissions should be accounted for in targets, based on traffic through Scottish ports and airports. Sets up an independent Scottish Climate Change Commission to advise Government and monitor and report on the implementation of the Bill. Revises targets as necessary using sound science. Climate Change policy is complex and constantly developing; therefore the Bill should establish an independent climate change Commission to advise Government. Ensures transparency and accountability. Ministers must be required to report annually to Parliament on the previous year s progress towards meeting allocated budgets and their future plans for doing so. As well as reporting on the impact of climate change and Government s progress on adaptation work. Consultation questions 1. Should a Scottish target be based on carbon dioxide only or the basket of six greenhouse gases? SWT urges the Government to base the reduction target of 80% on the basket of six greenhouse gases (GHGs). A target which takes the basket approach is consistent with both the Kyoto Protocol and Scotland s Climate Change Programme. The UK Government already collects and reports emissions of all six key greenhouse gases for Scotland and reports them as carbon equivalent so this approach would not mean any additional costs. It should be noted that non-co 2 emissions in Scotland make a significant contribution to Scotland s climate emissions with around 16% coming from N 2 O and CH 4 from land use, soils and agricultural activity. Another important source is aviation, a sector responsible for many non CO2 emissions. The IPCC has estimated that the climate change impact of aircraft emissions is between two and four times greater than CO 2 emissions alone. It is therefore essential that Scotland s share of GHGs arising from aviation (and shipping) is included in the Bill. 3

2. Should the Bill contain provisions to alter which gases are included, for example if the reliability of data for a particular gas improves or if science changes in the future about which gases cause climate change? Yes, we think it makes sense to include this provision in the Bill. However, gases should not be removed without thorough independent research and on the agreement of an independent Scottish Climate Change Commission. 3. The Scottish Government wishes to ensure that the Bill gives sufficient incentives to invest in energy efficiency and renewable electricity. Should the targets be based on source emissions; an end-user inventory; or on individual targets for energy efficiency and renewable electricity? Do you have any other suggestions? SWT welcomes the emphasis in the Bill on incentivising energy efficiency and renewable electricity which is very much in line with SWT s Policy on Energy (Appendix 1). The Bill should place a requirement on Scottish Ministers to produce and regularly report on an Emissions Reduction Implementation Plan (ERIP). Such a plan must include details of initiatives to reduce energy demand, improve energy efficiency and increase the proportion of electricity generated by renewable sources. The detailed actions in the ERIP will need to be regularly revised to reflect emerging technologies and climate change science. SWT therefore recommends that the ERIP should be revised and updated on a rolling three, or four, year timescale. Specific targets for energy efficiency and renewable electricity should also be included in the Bill in addition to the main targets relating to demand reduction and renewable energy generation. Each of these targets should also be set against our production based emissions. The need to cut production emissions irrespective of trends in end users is an important point as only applying targets to our electricity consumption would only capture part of the impact. If targets are based on simply on consumption based emissions then the actual annual reduction path would have to be set against all our consumption based emissions, not just those derived from our electricity use. These targets should be seen along side annual reporting on Scotland consumption based emissions. This would allow for the balance between consumption emissions and production emissions to be more transparently set out. 4. Do you agree that the Bill should allow the means of measuring the target to be changed through secondary legislation to reflect international developments or unforeseen consequences of the Bill? Yes, in principle the Bill should allow the means of measuring the target to be changed through secondary legislation as techniques may improve. However, this should only happen following scrutiny by independent Scottish Climate Change Commission and should be based on all available, up to date scientific knowledge. 5. Should the emissions reduction target take account of the abatement effort made by companies under emissions trading schemes? If so, how? SWT supports a third option as put forward by WWF Scotland which proposes including the annually verified emissions from installations covered by the EU ETS towards the Scottish emission reduction target. In addition to the inclusion of these 4

emissions, the Bill must enable those sectors captured by the ETS to make reductions in line with the Scottish target. The current proposal for an EU-wide ETS cap (20% from 2005 levels by 2020) is considerably less ambitious than the medium-term target for Scotland based on a minimum annual reduction of 3% a year, and indeed is less than the UK target likely to emerge as a result of the review due to be conducted by the Committee for Climate Change (and probably less ambitious than the Government s proposed minimum CO 2 reduction of 26% by 2020). Although it would be necessary to build a new process for securing this additional level of emissions reduction there is no preventative barrier to achieving this. Indeed, there are strong reasons why such extra reductions must be achieved. For instance, the analysis presented by IPPR, RSPB and WWF in The 80% Challenge report shows that the first step towards the 80% target must be met through rapid and almost complete decarbonisation of the electricity generation sector. It is clear that while the ETS has an important role to play it is only one tool in the toolkit and certainly no substitute for effective national climate change policies. The Stern Review recognised that carbon markets which are in the early stages of development are too volatile, and too prone to leakage and poor caps to deliver mitigation and deployment of new technologies at the speed and scale needed to avoid dangerous climate change. This analysis is also implicit in the introduction of UK measures such as the Renewables Obligation, which aims to incentivise renewable energy generation, despite the fact that the power generation sector is already included within the ETS. SWT therefore recommends that the Scottish Government should pursue options which ensure necessary reductions are secured from those installations captured under the ETS. The Scottish Government should actively encourage the UK Government to auction ETS allowances at a level more compatible with its own domestic targets. Since the UK Government would effectively 'own' the allowances, whilst it would be entitled to auction up to levels equivalent to the EU cap it would not be obliged to do so if it wished to reign in emissions further. Although the auction of ETS allowances will be open to any purchaser in the EU, the UK, and Scotland, would have ensured additional emissions reductions had occurred in line with the its agreed reduction pathways. The impact of this would probably be to very slightly tighten the cap across the whole EU, thus raising the carbon price slightly. This action would be in line with the UK and Scotland s position as global leaders in tackling climate change. Given the extra rate of reduction demanded by the 80% target in Scotland the Scottish Government will have to take action to reduce the available further. In order to do this they could buy out credits equivalent to the necessary reduction rate. 6. Do you agree that international credits should be counted towards Scottish targets? Should there be limits on credits counted towards Scottish targets? SWT agrees that limited use of international emission reductions should be allowed. However, we also believe that unconstrained use of international credits could potentially delay domestic abatement trajectories and encourage investments in high- 5

carbon infrastructure. This could result in still rising greenhouse gas emissions for decades to come. Furthermore, putting off action at home prevents innovation and the economic opportunity which could arise from Scotland becoming a world leader and exporter of climate change mitigation technologies. Regarding credits from the Clean Development Mechanism (CDM) there is growing concern that many so called non-additional projects are being approved. These are projects which would have taken place anyway and are therefore actually allowing an increase in emissions globally when they are used to offset emissions in countries which have taken on caps. A recent report commissioned by WWF suggested that approximately 20% of the emission reductions certified under the CDM may have happened anyway 2. The Scottish Government s current position of not proposing to set a statutory limit on the amount of international credits is not in line with the necessary emphasis on driving down the emissions in developed countries and showing the important leadership required to make this global shift to a low carbon future. Driving down emissions within Scotland will improve efficiencies; generate investment, jobs and sustainable economic growth. The purchasing of credits on the other hand will simply establish a financial flow out of our economy. 7. Should the Bill allow the level of the 2050 target to be changed through secondary legislation? If so, should this only be allowed on the basis of independent, expert advice, to reflect international developments or unforeseen consequences of the Bill? Should any changes to the target be limited to an increase in the target? Yes, SWT thinks the Bill should allow for the 2050 target to be increased through secondary legislation. New figures should be based on independent, expert advice grounded in the latest scientific research and approved by the Scottish Climate Change Commission. SUPPORTING FRAMEWORK 8. What factors should be taken into account when setting the level of budgets? SWT believes budgets should be guided by the best available scientific advice and in the shorter term, the urgent need to sharply reduce GHGs. The ultimate aim of the budgets must be to ensure no more than a two degree centigrade increase in mean global temperature. 9. How long should interim budget periods be? The budget periods should be at least shorter than a Parliamentary term as this will enable sufficient scrutiny and democratic accountability. SWT believes that this will still provide sufficient time for new infrastructure such as renewables technology to develop as early reductions in GHGs arising from in demand reduction and increases in energy efficiency will not necessarily require new infrastructure anyway. 2 Is the CDM fulfilling its environmental objectives? An evaluation of the CDM and options for improvement a report for WWF by the Öko- Institut, November 2007. 6

10. How many years in advance should emissions budget periods be set in order to provide sufficient time to develop infrastructure? Future budget periods will be set anyway as a result of year on year 3% year on year targets. The detail and timing of future infrastructure developments should be outlined in an ERIP and linked to reductions in GHGs but this should not affect the annual 3% reduction target. 11. What should be the limit (in terms of absolute quantity or as a percentage of the budget period) on the amount of emissions which the Government can borrow from a following budget period? SWT strongly contends that borrowing of no more than 1% should be legally allowed between budgets. Furthermore, this 1% should only be allowed when the period in question follows a period where at least a 1% surplus has been banked. Implementing such a system will avoid getting ever more overdrawn in the early years of the Bill implementation exactly the time when it will be most critical to reduce emissions sharply, rather than borrowing from future periods. 12. Should the Bill include an interim point target? If so, what year (or years) should it before (2020, 2025, 2030, etc.)? How should the level be chosen? SWT proposes a statutory annual target of at least 3% reduction in the basket of six GHGs. Anything less than this annual target will undermine the cumulative effect of the Bill s provisions and make scrutiny and accountability much more difficult. This would substantially weaken the Bill and increase the risk of a rise in global mean temperature of greater than two degrees. SWT welcomed the SNP s commitment in its Manifesto to annual targets and hopes it can now deliver. REPORTING SCRUTINY AND FRAMEWORK 13. Should the Scottish Ministers be required to report on any other issues related to climate change in addition to the requirements already set out. If so, what and how often? SWT recommends a number of climate change related issues on which we feel Scottish Ministers should also report. These must include: Adaptation reporting on a three yearly basis which includes initiatives to change the way in which we manage land to ensure biodiversity can better adapt to climate change e.g. adoption of an ecosystem approach to land use planning including catchment planning initiatives which incorporate both freshwater and terrestrial elements; tackling overgrazing and erosion in the uplands, restoring peatlands and damaged forests, creating a National Ecological Network and regional green and integrated habitat networks to facilitate the movement and survival of marooned species and habitats. Sectoral annual reporting by the main sectors (including the public sector ) responsible for the majority of GHG emissions in Scotland; Consumption based reporting which captures Scotland s total contribution to global GHG emissions, many of which are effectively exported to other countries; 7

8 Forecast emissions reporting which projects future emissions on an annual basis and thereby allows targeting of action; Impact reporting which captures the effects climate change is having on Scotland and allows both the ERIP and the Adaptation Strategy to be modified in response. 14. Is a process of Parliamentary scrutiny the appropriate way of holding the Scottish Government to account if targets or budgets are not met? Yes, Parliamentary scrutiny is one important way of holding the Scottish Government to account. However, there must also be effective sanctions to ensure there is a real financial incentive to reduce emissions. One way of implementing a sanctions mechanism could be for the Scottish Climate Change Commission to impose a financial penalty on the Scottish Government when it fails to hit targets or budgets. The money could be transferred into a climate change fund which could be used strategically to further reduce emissions and deliver the adaptation strategy. 15. What should be the primary source of advice to the Scottish Government for setting emissions targets or budgets and why? Options include: the proposed UK Committee on Climate Change, a new Scottish Committee on Climate Change, an existing public body in Scotland, or the Scottish Government itself. SWT believes the Bill should set up a Scottish Climate Change Commission as this will be the best way of ensuring independent scrutiny of the implementation of the Bill. The Commission needs to be at Scotland level due to the differences in the legal and political systems between Scotland and UK. The Commission could be modelled on the Scottish Freedom of Information Commission, with the Commissioner sitting on the UK Committee. A Scottish Climate Change Commission could be supported by existing public bodies, such as SEPA and the Sustainable Development Commission, in the provision of advice and monitoring. 16. If it were to be an existing Scottish public body, which public body is most suited to carrying out this task and why? Given the overarching, cross sectoral nature of the climate change issue, SWT does not support tasking an existing public body with such an important advisory role. We believe the rational approach is to establish a Scottish Climate Change Commission (see Q.15). 17. Which organisation should be tasked with monitoring the progress of the Scottish Government on reducing emissions and why? Options include: the proposed UK Committee on Climate Change, a new Scottish Committee on Climate Change, an existing public body in Scotland, or the Scottish Government itself. We believe the monitoring function should be led by a new body, the Scottish Climate Change Commission (see Qs.15 and 16) working in close partnership with all relevant parts of Government and other stakeholders.

18. If it were to be an existing Scottish public body, which public body is most suited to carrying out this task and why? Given the overarching, cross sectoral nature of the climate change issue, SWT does not support tasking an existing public body with such an important monitoring role. We believe the rational approach is to establish a Scottish Climate Change Commission (see Q.15). 19. Should additional independent mechanisms for scrutinising the effectiveness of the Scottish Government s policies in reducing emissions be created by the Bill (in addition to any scrutiny already provided by the Scottish Parliament)? The primary independent mechanism should be the Scottish Climate Change Commission. It would however be useful if the Bill allowed for further independent mechanisms to be provided for in the future, pending experience with scrutinising the effectiveness of the Bill and the policies arising from it. 20. If so, which organisation is best placed to carry out this function and why? Options include a new Scottish Committee on Climate Change or an existing public body in Scotland. Given the overarching, cross sectoral nature of the climate change issue, SWT does not support tasking an existing public body with such an important scrutiny role. We believe the rational approach is to establish a Scottish Climate Change Commission (see Q.15 etc). 21. If it were to be an existing Scottish public body, which public body is most suited to carrying out this task and why? See Q. 20. 22. Are there any other functions related to climate change, existing or new, which should be carried out at arm s length from the Scottish Government and why? All identified arm s length functions should be the responsibility of the Scottish Climate Change Commission with the option (see Q.19) of developing new independent mechanisms kept open in the future. SUPPORTING MEASURES 23. Should the Bill contain enabling powers to introduce a duty on certain parts of the public sector (i.e. local authorities and large public bodies) to take specified actions on climate change or other specified environmental issues? Why? Yes, SWT recommends the Bill contains a sustainability duty on all public bodies to deliver their climate change mitigation and adaptation responsibilities in a manner that furthers the delivery of sustainable development and the conservation of biological diversity. The rationale for this duty is a. that public bodies need to show 9

leadership on this issue and b. cuts in emissions from the public sector could make a significant contribution to the target of 80% by 2050. SWT would like to emphasize the link in our proposed duty between the need to tackle climate change and the need to protect the wider environment. This is why we propose a duty which includes references to sustainable development and biodiversity conservation (consistent with the biodiversity duty in Part 1 the Nature Conservation (Scotland) Act, 2004). This will help avoid the madness of destroying the environment in the name of climate change a situation which is already a reality with rainforests being felled for biofuel plantations and carbon sink peatlands being developed as renewable energy installations. Local authorities should be supported in complying with this duty by amendments to planning legislation, for example by introducing secondary legislation which sets out how planning/regulatory authorities should treat climate change as a material consideration. 24. What should such a duty (or duties) include? As outlined above, the sustainability duty must include reference to the conservation of biological diversity. In addition we recommend it includes: a requirement to report on operational emissions and, in case of local authorities, regional/area consumption emissions a requirement to produce a plan to reduce operational emissions in line with national targets a requirement to ensure strategies and policies will deliver community-wide consumption based emissions (carbon footprint) reductions, including engagement with communities (use Local Footprints as an example text given above) a requirement to publish an annual statement on implementation of the above requirements a progress report against this duty by Audit Scotland 25. Should the Bill contain enabling powers to introduce statutory guidance for certain public sector bodies (i.e. local authorities and large public bodies) on specified climate change or other environmental measures? Why? Are there gaps in any existing guidance? Yes, the bill should require the provision of statutory guidance to support the public sector in its implementation of the duty. 26. What should this guidance include? It is important that guidance should clearly state what must be measured and monitored. SWT specifically recommends including clear guidance on adaptation measures. We have identified a number of key threats to the healthy functioning of ecosystems in Scotland which are likely to be greatly exacerbated by climate change and where adaptation measures will be required. It should also be noted that perversely, some threats to biodiversity could be made significantly worse if climate change mitigation measures are not developed and implemented sustainably (see sustainability duty above). Key areas for the guidance to consider in relation to adaptation include: 10

Measures to reduce habitat fragmentation. The affects of habitat fragmentation acting in concert with climate change will lead to species losses and potential functional breakdown of both terrestrial and marine ecosystems. This threat is greatest in highly fragmented lowland areas where the climate space for many species is likely to change rapidly but lack of connectivity between habitats will mean many species will be unable to move northwards in response. Measures to ensure appropriate design and location of new developments and infrastructure. Poorly located and badly designed developments and infrastructure can further fragment semi-natural habitats, making ecosystems in urban and peri-urban areas especially vulnerable to climate change impacts. New and existing transport infrastructures are also a severe barrier to the movement of many species and are rarely climate change proofed. Soil sealing and manipulation of natural hydrological regimes associated with new developments can also exacerbate the impacts of climate change contributing to flash flooding, poor water quality and general loss of environmental capital. Measures the enable marine and coastal ecosystems to adapt. There are raft of existing threats to the marine environment. These include overfishing, the arrival of invasive non-native species, inappropriate coastal developments, increased coastal erosion (with sea level rise), diffuse pollution from both land and marine sources and new pressures arising from the need to develop offshore marine renewable energy. The cumulative impact of these threats is predicted to get significantly worse with climate change, even under best case scenarios. Measures to strategically control invasive, non-native species. As climate space changes so will the species composition of Scotland s ecosystems. Some of the species which are already arriving from other parts of the world are likely to cause severe functional imbalances on both natural habitats and agricultural systems. Measures to make farming and forestry practices more sustainable. There are still many farms and forests in Scotland which are unsustainably managed. It is these which are most likely to be impacted by climate change as they are generally the least ecologically robust areas within the rural landscape. For example, farms without riparian buffer zones which are heavily dependant on manufactured fertilizers are likely to suffer from soil degradation and contribute to pollution (particularly nitrates) of freshwaters. Similarly, forests which are not managed using low impact silvicultural systems (such as continuous cover) are more likely to suffer soil loss and degradation, biodiversity loss and windthrow (associated with predicted increase in severe weather events). Measures to tackle overgrazing and soil degradation. The affects of overgrazing (mainly by red deer and sheep) in many parts upland Scotland are already causing erosion of peatland soils, particularly on blanket bogs which have been burned and drained in the past. Increased total winter rainfall, increased intensity of rainfall and summer droughts are likely to cause further erosion of these soils with potentially catastrophic impacts on peatland ecosystems, and the freshwater systems they drain into. Measures to prevent or ameliorate climate change mitigation measures impacting on the wider environment. As Scotland responds to the climate crisis it will need more renewable energy. This is already placing heavy 11

burdens on the terrestrial environment and will soon begin to affect the marine environment. Current impacts include: the incentivisation of biofuels planting without proper guidance or forethought of the ecological impacts; windfarms located on sensitive peatland soils or in areas of high bird biodiversity; the need for high impact transmission infrastructures to bring electricity from remotely located sources; the loss of peat soils due to increased erosion drivers. 27. Should the Bill contain enabling powers to create a requirement for certain public sector bodies (i.e. local authorities and large public bodies) to make regular reports on specific measures they are taking to tackle climate change (whether mitigation or adaptation) or other environmental issues? Why? What should be included in such reports? Yes, SWT recommends the Bill should require regular reporting to be a condition of compliance with the duty to reduce emissions, as set out under Q24. Reporting is necessary to ensure transparency of action, confidence in reporting, shared learning across the public sector and accountability. 28. As a potential non-legislative measure, should current Best Value guidance be amended to take specific account of climate change mitigation and adaptation? If so, how should Best Value guidance be amended? SWT has no view on this issue. 29. Are there any amendments to existing legislation or any enabling powers needed to allow for variable charging (for example by local authorities) to incentivise action or eliminate perverse incentives? Yes, we recommend that existing legislation is reviewed with a view to developing incentives that could be introduced by local authorities to reduce GHG emissions, particularly in the areas of energy efficiency, public transport and waste minimisation. 30. Are there any provisions to help Scotland adapt to the impacts of climate change which should be included in the Scottish Climate Change Bill? Yes, SWT feels very strongly that the Bill must require the statutory implementation of a Scottish Climate Change Adaptation Strategy. The strategy and the requirement to report on its implementation must be rooted in primary legislation. 31. Should provisions within the Environmental Assessment (Scotland) Act 2005, be amended in order to provide clearer links with emissions reduction? If so, how should this be done? Yes, amendments should be made to the Environmental Assessment (Scotland) Act 2005 so it is better placed to support the Bill. Specifically, the amendments should: require the collation and presentation of data where the scoping study has identified that the plan, programme or strategy is likely to have a significant impact on climate change adaptation grounds or GHG emissions increases. Currently, the Act only requires the presentation of data where it already exists, this has the potential to provide an incomplete assessment of the climate change impacts 12

list the Scottish Climate Change Commission as a relevant consultee body strengthen the mandate to reject plans, programmes or strategies where assessment has identified a likely significant climate change impact (adaptation or GHG emissions). At the moment the conclusions of the SEA only need to be considered and as such have a variable impact on the decision making process 32. What are the equalities implications of the measures in the proposals for the Scottish Climate Change Bill? SWT has no comment on this issue. 33. Is there any existing legislation within the competence of the Scottish Parliament (devolved) which needs to be amended so that appropriate action on climate change can be taken by sectors in society? As a general point of good practice the Scottish Government should review all existing legislation to ensure it not only takes account of climate change but seeks to make a positive contribution to the goal of an 80% reduction. SWT specifically recommends the Scottish Government transposes and applies Articles 10 and 12 of the Habitats Directive as part of its commitment to climate change adaptation. 13