The draft Climate Change Plan (CCP) sets out the policies and proposals the Scottish Government think will be needed to achieve Scotland’s carbon budgets between 2026-40. Policies and proposals are listed in Annex 3 of the draft, including some description of whether they are new or existing, and their degree of importance in terms of emission reductions. This blog first sets out the approach the Scottish Government use to describe the policies, proposals and outcomes they think are needed to reduce greenhouse gas (GHG) emissions. It then summarises some of the most critical details from each of the sectors in the draft CCP. It is linked to another recent SPICe blog which describes the background to and the statutory requirements for, the draft CCP.
Policies, proposals and outcomes
The draft Plan sets out policies and proposals by sector and according to which ‘outcome’ they are related. The difference between a policy and a proposal is set out in Annex 3 of the draft CCP:
- ‘A ‘policy’ is considered to be ‘where it is possible to clearly set out a specific action, scale, a lever of choice, an outcome and a timeline, and, thus, it is possible to set out clear delivery details and cost implications.’
- ‘A ‘proposal’ is considered to be where it is ‘possible to clearly set out an outcome and a timeline, and it is recognised action needs to take place, generally these will have impact later in the plan period, so, consequently, more concrete detail on the precise policy levers and cost implications is more difficult to present.’
In the Plan, both policies and proposals can be listed as being either ‘key’, ‘enabling’ or ‘narrative’. Key policies/proposals are said to be ‘direct drivers’ of emissions reduction, that ‘often have financial impacts’. Enabling policies/proposals (sometimes labelled as ‘supportive’) help to support key policies/proposals, that could drive emissions reduction but are more likely to improve the impacts from a key policy/proposal. Narrative policies/proposals support long term action but have not progressed to having a ‘clear impact’. Examples of this are, influencing UK Government and commissioning research.
Each policy and proposal is listed next to an Outcome. Outcomes are essentially sub-goals that sit below the overall emissions reduction target and relate to it. For example, in Buildings the three outcomes are roughly to install zero carbon heating systems, make buildings more energy efficient and to make sure that these changes are fair and stimulate employment. Some of the outcomes are the same as what was in place for the CCP update in 2020, but some have been altered. As this Plan also involves a new sectoral break-down (see previous blog), there is at times a need to redefine outcomes for those sectors which have been restructured e.g. Energy Supply.
While assessing Scottish climate policy it is also worth bearing in mind the complex nature of devolved and reserved powers in this area, the subject of two recent SPICe blogs. Each sector below reflects on the relative role of the Scottish but also UK Government.
Sector summaries
The most recent verdict on progress (March 2024) toward emissions reduction in Scotland from the Climate Change Committee (CCC) adjudged that ‘current overall policies and plans in Scotland fall far short of what is needed to achieve the legal targets’. While these targets have now been re-drawn, achievement of the new carbon budgets will require a very similar rate of emissions reduction (albeit 5 years later). Below are summaries of the decarbonisation sectors as set out in the CCP.
Buildings (residential and public)
Buildings decarbonisation is considered to be ‘mostly devolved’ by the CCC. Since 1990 there has been a 40% reduction in emissions from residential and public buildings, largely resulting from progressive improvements in energy standards for new buildings, government funded energy retrofit programmes and the mandate of more efficient condensing boilers (since 2007).
This sector sees a significant change in ambitions from the CCP update (CCPu) in 2020. This Plan models a 60% reduction between 2025-40, whereas the 2020 Plan had a 66% reduction 2023-30. The draft Plan includes no mention of the Heat in Buildings (HiB) Bill, which the Programme for Government in May 2025 committed to bringing forward this year. On 18th November the Government published a new draft Buildings (Heating and Energy Performance) and Heat Networks (Scotland) Bill and stated that they planned to bring this forward as soon as possible in the next parliament. This draft Bill has less specific proposals than the previous HiB proposals and is closer to a piece of ‘framework’ legislation, where the precise details of the Government’s approach will be set out in secondary legislation.
In April 2025, the Government had indicated that a different approach would be taken to HiB and the draft CCP and new draft Bill do not contain the level of policy ambition that existed in the previous HiB proposals. For example, the previous proposals for the HiB Bill included various Minimum Energy Efficiency Standards (MEES) and dates by which the installation of clean heating systems (like heat pumps) would be required. The draft Plan includes a ‘proposal’ to consider options for MEES for owner occupiers and non-domestic properties ‘subject to further consideration’. MEES for the private rented sector can be progressed with existing powers and there is an ‘existing policy’ involving the intention to progress these regulations within this parliamentary term. The key policy is a target to decarbonise buildings, where ‘reasonable and practicable to do so’, by 2045. This is supported by enabling policies like MEES, although the lack of specific detail on these means it is not possible to assess whether the overall ambition is matched by the specific actions. There is a new commitment to a Heat in Buildings Strategy and Delivery Plan by the end of 2026.
Transport
The CCC consider there to be significant policies in surface transport that are devolved, for shipping to be partially reserved and aviation to be largely reserved. There has been a 13% reduction in transport emissions since 1990, largely as a result of the improved fuel efficiency of new petrol and diesel-powered motor vehicles that entered the fleet during this period and changes to travel patterns following the covid pandemic. This Plan projects a 68% fall in Transport emissions between 2025-40, by far the biggest absolute contributor to overall reductions in this period.
The CCP sets out six transport outcomes – create an environment for reducing car use, incentivising car drivers to switch to walking, cycling, and public transport where possible, encourage freight transport to switch from road to rail and water, phase out the need for new petrol and diesel cars by 2030, take action to ensure all road vehicles are zero emission by 2040, and work to decarbonise scheduled flights within Scotland by 2040. To support the delivery of these outcomes, the CCP sets out one ‘key enabling’ policy, seven enabling policies, one supporting policy, three proposals and two enabling proposals. Alongside this, 15 policies are listed without being described as key or enabling. Of the total, Scottish Government categorises six policies, two enabling proposals, three proposals and two enabling policies as new.
Key amongst these new initiatives is the development of a successor to the 2020 national car use reduction target and policy, the creation of new ‘consumer incentives’ to encourage electric vehicle uptake, establishment of bus priority measures on the trunk road network, and work to both decarbonise road freight and incentivise its switch from road to rail and water. Looking across these six initiatives there is one significant issue that applies to them all – it is not currently possible to confidently assess their likely impact on transport emissions as they are all reliant on future work to define issues such as scope, remit, or budget, e.g. the car use reduction target will only be set in the final version of the CCP, incentives to encourage electric vehicle uptake are not defined, while there is no detail on the budget or timeline for rolling out bus priority measures on trunk roads.
Agriculture
The CCC consider agriculture to be ‘largely devolved’. Between 1990 and 2023 there has been a 13% reduction in emissions in the sector. According to the CCC, emissions reductions in agriculture (up to 2022) are due to a decline in livestock numbers from 1990 to the mid-2010s as well as reductions in emissions from soils. It is important to recognise that sequestration activities such as tree planting and peatland restoration have occurred on farms, but these are reported in the land use, land use change and forestry (LULUCF) sector.
Since the CCPu in 2020, headline emissions from agriculture have not changed significantly. The CCPu projected that agricultural emissions would be 7.0 MtCO2e in 2020 (the actual figure in 2020, published in the 2022 emissions inventory, was 7.4 MtCO2e). Emissions in 2023 (our most recent figures) are estimated to be 7.5 MtCO2e. The CCPu had projected that agricultural emissions would fall to 6.3 MtCO2e by 2023.
This Plan projects a 21% fall in Agricultural emissions between 2025-40, the lowest of any sector. The key policy driver that is officially a ‘policy’ and is likely to generate significant interest is the policy to continue the delivery of the Agricultural Reform Route Map which has continually been updated since early 2023. This policy, and relatedly, the policy to publish the first Rural Support Plan in winter 2025, are existing steps in a long process to reform agricultural policy since the EU referendum in 2016. Most of the policies (not proposals) that are marked as ‘new’ within the draft CCP, are already set out in the Agricultural Reform Route Map (which is itself listed as a headline existing policy).
Business, Industrial Process & NETs
This wide-ranging sector lumps together emissions that would in previous CCPs be spread across three separate sectors; Industry, Negative Emissions Technologies (NETs) and Buildings. The CCC describes non-residential buildings as ‘mostly devolved’, but Industry and NETs as ‘mainly reserved’. Progress in reducing emissions in Industry has largely come from the closure of industrial sites like steelworks and papermills, and moves to ‘less energy-intensive, higher-value industrial output’. Historical emissions reduction drivers in buildings are set out in the summary above.
The primary existing policy is the UK Emissions Trading Scheme, which is a cap-and-trade mechanism that produces a carbon price for industry. Two Scottish Government funds to support industry to decarbonise and develop green hydrogen are also highlighted, although no indication of the amount of funding required to deliver the anticipated emission reductions is given. The inclusion of these funds differs from the approach taken to renewable energy funds, which are not included in the list of policies in the Energy Supply sector (see below). The plan assumes the Acorn carbon capture and storage project will be deployed by 2032.
The most substantial new policy is a loosely defined ‘New Industrial Decarbonisation Programme’. Also included are policies to work with the UK Government to ‘develop a framework for demand-side measures to increase the market for low carbon industrial products’, support SEPA to drive energy efficiency and support planning and consent for carbon capture projects. There is also the inclusion of a GB-wide policy the Renewable Heat Incentive, which closed to new applicants in 2021, and thus has no scope to increase emissions reduction.
Land Use, Land Use Change and Forestry
The land use, land use change and forestry (LULUCF) sector includes the emissions and removals from different land uses and changes between different land uses. The CCC consider the sector to be largely devolved. It is also worth noting that as the Scottish Fiscal Commission have pointed out Scotland covers 32 per cent of the UK’s land mass, has the majority of the UK’s peatland, and approximately half of its trees and so this sector is a substantial area of investment that differs from the rest of the UK.
The key policy drivers in this sector are the policies to increase and fund woodland creation and to restore peatlands. None of these policies are new but they have been reframed in the draft CCP. For forestry, the key policy in the draft CCP is to increase woodland creation each year, reaching 18,000 hectares per year from 2029/30, with a longer-term target of creating 250,000ha by 2040. This longer-term target is new, but the policy slows the pace of increasing annual woodland creation. In the 2020 CCPu, the target was to “increase new woodland creation from the current target level of 12,000 hectares annually in 2020/21 up to 18,000 hectares in 2024/25”.
For peatland restoration, the key policy in the draft CCP is to “increase peatland restoration by 10% each year to 2030 and maintain levels after that, leading to the restoration of more than 400,000 hectares by 2040.” As with the forestry policy, the longer-term target to 2040 is new. The annual peatland restoration target is also framed in a new way. The existing peatland restoration target is to restore 20,000 hectares of peatland per year, with a total of 250,000 hectares by 2030; this target has been in place since the full 2018 Climate Change Plan. Annex 2 of the new draft CCP restates the 250,000ha by 2030 target.
However, using the figures provide in the CCP, it appears that a 10% increase in the area of peatland restored per year to 2030 will not meet the target to restore 250,000ha by 2030. It does appear that this rate of restoration will exceed the target to restore 400,000ha by 2040, however. As with forestry, the CCP sets ambitious targets for future carbon budgets but slows the pace within the current carbon budget period compared to previous ambitions. For peatlands, this may be partly mitigated by an ambition in the draft CCP to increase the proportion of the most degraded and emitting peat that is restored.
Waste
The CCC consider policies in waste management to be generally devolved. In 2023, waste sector emissions stood at 1.7 MtCO2e, 73% lower than in 1990, with reductions largely resulting from reducing the amount of waste produced in Scotland, increases to recycling rates, and diverting waste from landfill thereby reducing methane emissions. Emissions in the sector however have been largely stable in the previous CCP period, during which time there have been challenges in significantly increasing recycling rates, tackling food waste and scaling up landfill gas capture. However, the overall waste generation trend (excluding construction waste) has been generally downward since 2011.
Policies described as ‘new’ in the draft CCP in waste are drawn almost exclusively from the Scottish Government’s Waste and Circular Economy 2030 Routemap (December 2024). Several new policies also relate to implementation of the Circular Economy (Scotland) Act 2024 – including publishing a Circular Economy Strategy and setting statutory circular economy targets and local recycling targets. The Scottish Government published a draft Circular Economy Strategy (required by the 2024 Act) for consultation on 21 October 2025, which, by law, the Government must prepare with a view to achieving consistency with the CCP. This consultation is running alongside the Scottish Government’s consultation on the draft CCP.
Existing policies described as ‘key’ to achieving emissions reductions include the forthcoming ban on biodegradable municipal waste (BMW) going to landfill, maximising landfill gas capture, delivering the Deposit Return Scheme (DRS) and reforming extended producer responsibility (EPR) schemes, and taking action to cut food waste. One issue to explore is that whilst the draft Plan notes the forthcoming ban on landfilling BMW as key, it was announced last month that in light of industry challenges, SEPA will effectively not enforce the ban until 2028. A further potential issue is the ability to scrutinise key assumptions made in this chapter. The draft Plan does not map emission savings for each individual policy or proposal but rather, adopts projections of total waste going to different treatment routes based on “broad assumptions around reductions in waste, improvement in recycling and, most importantly in terms of emissions, the implementation of the biodegradable municipal waste landfill ban in December 2025 (and ongoing landfill gas capture)”. Without knowing what outcomes the draft Plan is seeking to achieve, it may be more challenging to assess the sufficiency of planned actions.
Energy Supply
This sector is comprised of the sub-sectors, electricity generation and fuel supply. The CCC consider both of these to be ‘largely reserved’ to the UK Government. Since 1990 there has been an 93% fall in emissions from electricity generation largely as a result of the closure of coal power stations in Scotland (Cockenzie, Longannet, Kincardine etc.) There has been a 58% fall in emissions from fuel supply. Fuel supply relates to oil and gas extraction and processing, with reductions in oil and gas flaring and venting and a near cessation of emission from coal mining bringing down emission here. It is worth noting that emission data is currently published up to 2023, and does not, therefore, include the recent closure of the Grangemouth oil refinery.
The assumptions made are critical to understanding the role of the Scottish Government considers itself to have in this sector. For example, the Plan contains no policies for Fuel Supply, in what it considers to be a ‘reserved policy area’. It also states that all emissions reductions here are expected to be ‘market driven’. The same assumption (emission reductions will be market driven) is made for electricity generation, but here there are policies. These are split toughly 50/50 between those which apply to energy from waste (EfW; categorised here rather than in the Waste sector) and those which entail working with the UK Government or regulated energy network companies like SSEN. An example of a key policy here is to encourage existing Energy from Waste (EfW) plants to retrofit carbon capture and storage, while an enabling policy is working with SSEN to reduce reliance on island diesel power stations. Overall, no costs or benefits figures are provided for Energy Supply as change is expected to be ‘market driven’.
The above policies and proposals are listed in Annex 3. In Annex 2 – Sectoral Annexes, various Government actions related to the deployment of renewable energy, such as the Onshore Wind Sector Deal, the Offshore Wind Policy Statement and £500m over 5 years to grow the offshore wind sector, are listed. Interestingly the renewable energy policies are not given the same descriptive treatment as the policies Annex 3 (key, enabling etc.). The electricity generation sectors of the most recent CCPs (2018 and 2020) focused almost entirely on renewable energy deployment. Similar to other sectors the lack of detail on the policies and proposals (and what exactly is included as a policy/proposal) means it is not possible to assess the feasibility of the overall ambitions. There is no mention in any of the documents of the long-awaited Energy Strategy and Just Transition Plan (draft published Jan 2023), or any reference to whether the Scottish Government will have a ‘presumption against new exploration for offshore oil and gas.’
Summary
The draft CCP introduces some more details of how the Scottish Government intend to reduce GHG emissions between 2026-40. The draft Plan introduces a new approach to setting out policies and proposals with particular definitions and terminology. There are questions over how this approach has been applied in different sectors, and across the board there are questions as to how the aggregate emissions reduction and cost figures have been reached. SPICe will follow up on this blog with sector specific blogs in the coming weeks.
Niall Kerr, Anna Brand, Alan Rehfisch, Alexa Morrison, Rob Watts and Kate Berry. SPICe