This blog considers the Energy Supply sector in the draft Scottish Climate Change Plan (CCP) published on the 6 November 2025. It links to recently published CCP overview blogs that can be found at the SPICe CCP hub.
There are two main components of the Energy Supply sector; ‘Electricity supply’ and ‘Fuel supply’ (in Scotland this essentially relates to oil and gas). The CCP is made up of various other sectors that involve energy demand e.g. Transport, and Industry. Since 1990 there has been an overall 82% fall in emissions from Energy Supply.
The Climate Change Committee (CCC) consider both Electricity and Fuel supply sectors to be ‘largely reserved’ to the UK Government (UKG), but the Scottish Government’s (SG) role is still significant. The Scottish Government has control over the consenting of electricity infrastructure, which, for example, allows it to currently have a different policy on nuclear power to that of the UK Government. There is a recent SPICe blog that sets out more details on the devolved / reserved split in energy policy. The blog below looks at the detail of electricity and fuel supply in Scotland and examines what is set out in the draft CCP.
Electricity supply
Emissions
Since 1990 there has been an 93% fall in emissions from electricity supply largely as a result of the closure of coal power stations e.g. Cockenzie, Longannet and Kincardine. According to the draft CCP, emissions from electricity supply in the latest year of data (2023), were 0.6 Mt CO2e from Peterhead gas plant, 0.3Mt CO2e from energy from waste (EfW) plants and 0.05 Mt CO2e from island diesel generators (roughly 1Mt in total).
The advice of the CCC plays an essential role in informing the new Scottish carbon budgets and the contents of the CCP. It is important, therefore, to compare the assumptions and projections of the CCC with the draft proposals of the Scottish Government. One complication in achieving this is that the CCC do not include EfW in the electricity supply sector (they include it in the Waste sector), but the SG do. EfW emissions were roughly 30% of electricity supply emissions in 2023.
The emission pathways for electricity supply were:
Emissions source | 2026-30 | 2031-35 | 2036-40 |
CCP | 5.2 | 2.5 | 1.9 |
CCC | 1.32 | 0 | 0 |
Note: CCP figures from Table 34 Annex 3 of CCP. CCC data from Scotland Target Advice Full Data Set). The SG include the emission reductions from non-road mobile machinery (NRMM) in the Energy Supply sector despite the emissions from this occurring in other sectors. NRMM has, therefore, been excluded from the comparison here.
The lower CCC figures can be explained by the absence of EfW and because of different assumptions around the Peterhead gas plant. The SG modelling assumes that the Peterhead gas plant is replaced by a new gas plant which uses carbon capture and storage (CCS) in 2032. The existing plant is assumed to maintain 2024 emission levels up until 2032, and then the new plant is assumed to operate at 100% load for almost the entire year (8,000 out of 8,760 hours in a year) with a 90% CO2 capture rate. The CCC assume that the Peterhead site ceases all operations by 2030.
The Peterhead plant is the only gas plant of significant scale to have ever existed in Scotland (current capacity 1.2 GW). The future of this site is the subject of debate, with the owners submitting a planning application in 2022 to develop a CCS-enabled plant (0.9GW) to replace the current power station around 2030. Some environmental NGOs are opposed to the proposals. The draft CCP appears to envisage that this plant gets the go ahead:
‘emissions are projected to decline to 0.37 MtCO2e by 2040, due primarily to the closure of the existing Peterhead power station and its replacement by a modern gas fired plant (CCGT) utilising carbon capture and storage technology (CCS)’
This assumption contradicts that of the CCC who set out that ‘Peterhead closes in 2030’ with their modelling having no low-carbon dispatchable power stations using gas with CCS (or hydrogen) in Scotland (their latest modelling at the UK level does include this kind of plant). They explain that if low carbon, dispatchable power plants were to be built in Scotland, these decisions would be:
‘influenced by a range of factors including UK and international energy policy, demand for electricity in the UK and Scotland, and company-specific decisions around dates of decommissioning or low-carbon conversion of unabated gas plants, as well as developments and operations in the GB-wide system.
‘While there are no low-carbon dispatchable power stations that require the use of gas with CCS in our pathway, if capacity was built in Scotland, we would expect Scottish emissions to remain at very low levels (around 0.2 to 0.4 MtCO2e per year).’
Giving evidence to the NZET committee on the 2 September 2025, Dr James Richardson from the CCC set out the following:
‘It will ultimately be a market decision. SSE (the owners) is interested in converting Peterhead to CCS—that is a choice for SSE in the market. The model does not pick that, but that does not mean that it will not happen. We are not making recommendations about where those sites should be located. It is just about function. It is probably driven by the ground transmission infrastructure, but other choices are available.’
In the CCP, decarbonisation of the other main component of electricity emissions, EfW plants, also hinges on the use of CCS. The prospects of CCS delivery in Scotland are covered in a forthcoming SPICe blog on the Business, Industry and Negative Emission Technologies sector. There are policies in the Energy Supply sector related to CCS including ‘working constructively with the UK Government’ on projects like Acorn CCS.
Although not included in the CCC Electricity supply emissions figures above, the SG and CCC assumptions on EfW are similar. The SG assume that 45% of EfW sites (by emissions) install CCS at 90% capture rate by 2032 (graphic Annex Page 82). The CCC assume that 16% of EfW capacity has CCS by 2030 and 49% by 2035 (Table 3.10 in Scottish carbon budget advice). EfW and waste incineration require the production of non-recycled waste and is covered in more detail in a forthcoming SPICe blog on the Waste chapter.
The SG also assume that for EfW plants in Scotland 50% of emissions are from biogenic sources (biodegradable organic matter i.e. food waste) and thus the use of CCS will result in ‘negative emissions’ i.e. the removal of emissions from the normal carbon cycle, otherwise known as bioenergy CCS (BECCS).
The CCC had more to say on the future of EfW plants when they gave evidence to the NZET committee on 2 September 2025:
‘We think that it is important that all the remaining energy from waste plants are connected to CCS infrastructure. That has implications for siting, because the CCS infrastructure will predominantly be concentrated around industrial clusters. You can connect to those pipes, but you cannot easily connect across the whole country, so that suggests that you would probably want to have a smaller fleet of larger individual plants, connected to CCS near the pipelines’
The final source of emissions here is fossil-fuel (typically diesel) generators. The Plan contains a pledge to work with SSEN to reduce reliance on island diesel generators by improving electricity connections to the mainland, and to ‘explore’ the use of hydrotreated vegetable oil (HVO) as an alternative fuel.
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 oil and gas.’
Low carbon electricity
The electricity supply sector goes beyond just reducing the remaining emissions set out above. The provision of a low carbon electricity system and the electrification of transport, buildings heating and industry is arguably the most important route to emission reductions in the CCP. While the market framework for these technologies is reserved, as mentioned Scotland has control over consenting and has previously deployed much more renewable energy (per capita) than the rest of the UK. As set out in the overview SPICe blog, policies relating to the deployment of renewable energy are set out in Annex 2. They are not included in the main list of policies and proposals in Annex 3 and thus are not described with the heightened level of detail of the actions in this list. This contrasts with previous CCPs where renewable energy policies are central in this sector.
As of Q2 2025 there is 10.4GW of onshore wind, 4.3GW of offshore wind and 0.8GW of solar in Scotland. The Scottish Government have ambitious plans for these numbers to increase:
- 20 GW of onshore wind by 2030: a joint industry and Scottish Government commitment set out in the Onshore Wind Sector Deal.
- 8-11 GW of offshore wind by 2030 is the current commitment (set in 2020), and the Government consulted on a new target of 40GW by 2040 earlier this year.
- 4-6GW of solar by 2030 as communicated to the Net Zero, Energy and Transport committee in October 2023.
In the CCC pathway the capacity of variable renewables in Scotland (including offshore and onshore wind and solar) more than triples from 15 GW in 2023 to 49 GW by 2035, increasing to 66 GW by 2045. Of all electricity generated in Scotland in 2035, 98% comes from variable renewables (94% from onshore and offshore wind; 123 TWh out of 131 TWh). The remaining 2% is from EfW and combined heat and power sites.
Alongside generation, there are plans for more electricity storage in Scotland i.e. pumped-hydro, and battery storage (BESS). As of June 2025 there was 0.7GW of pumped hydro and 0.5GW of BESS. While there is an estimated 35GW of these kinds of storage in planning, or under construction (26GW of which are BESS and 9GW hydro), the CCC model for there to be roughly 5GW by 2035. Of this 5GW, only 0.8GW is modelled to potentially be more pumped hydro, with the rest envisaged as BESS. The CCP makes reference to influencing the UK Government to ensure that storage is properly incentivised but does not include figures of how much there might be.
Alongside changes in the supply of energy there are also predicted to be substantial changes in electricity demand. Although the CCP makes reference to the need to grow renewables in order to ‘match the growth in the demand for electricity that will arise as we decarbonise other sectors’ it does not set out by how much demand is expected to grow. The CCC meanwhile set out a near tripling of electricity demand in Scotland between 2025-2045 (Table 3.12 in the CCC advice). The supporting data for this analysis shows demand for electricity from homes roughly doubling between 2025-50, and a thirteen-fold increase in demand from surface transport. An emerging source of increased demand that is also not mentioned in the CCP is that of data centres with many GW of capacity currently in planning in Scotland.
As highlighted by the CCC in their evidence to the NZET committee on 2 September 2025, even with the increase in electricity demand:
“Scotland will have far more generation than Scotland demands, and, in our model, Scotland is a vast net exporter of electricity to the rest of Great Britain—you would have to have really extreme conditions for Scotland to be unable to meet its needs from renewables’ and in that scenario ‘electricity would flow back the other way on the transmission lines that would normally take it from north to south; it would go from south to north”
It is also worth noting, that while currently the GB electricity system is a net importer of electricity (via interconnectors to France, Norway etc.), the National Energy System Operator, model the GB system to be ‘a net exporter of electricity post-2030 and retains this position to 2050’.
As highlighted in the sector summary blog, previous CCPs have placed the Scottish Government’s role in deploying renewable energy front and centre of the Plan. The primary policy outcome for this sector, as set out in previous annual CCP Monitoring Reports was that ‘electricity system will be powered by a high penetration of renewables’. This outcome is not included in this draft CCP.
Fuel Supply
There has been a 58% fall in emissions from fuel supply between 1990 – 2023. Fuel supply relates to oil and gas extraction and processing (it does not relate the eventual combustion of these fuels) with reductions in oil and gas flaring and venting and a near cessation of emissions from coal mining bringing down emissions here. It is worth noting that emission data is currently published up to 2023, and does not, therefore, include the recent closure (in Q2 2025) of the Grangemouth oil refinery.
Of the remaining emissions, processes like refining crude oil and operating terminals led to 2.85MtCO2e in 2023. These emissions will, however, be substantially reduced by the closure of the Grangemouth oil refinery. The refinery was responsible for 0.8Mt of emission in 2022. The emission pathways for fuel (oil and gas) supply were:
Emissions source | 2026-30 | 2031-35 | 2036-40 |
CCP | 4.7 | 0.9 | 0.9 |
CCC | 7.7 | 3.4 | 2.6 |
Note: CCP figures from Table 34 Annex 3 of CCP. CCC data from Scotland Target Advice Full Data Set)
The CCC report (pg. 80) states that by 2035, 56% off reductions come from fuel switching, 22% from electrification and the rest from reducing methane leaks and flaring. The CCP attributes the decline of emissions in this sector to less refining of crude oil and less imports of refined products due to declining domestic demand, and the decline of North Sea oil and gas production (Annex 3, pg. 51/52).
Notes on the analytical approach in the CCP
For those looking to understand the content of the CCP it is worthwhile setting out the approach to the analysis taken within the document. One important consideration throughout the CCP is the extent to which changes in emissions result from SG policy and the extent to which they result from expected future changes in the baseline. An explanation of the approach to defining the baseline is given in Annex 3:
- “Baseline: The CCP comprises a package of measures adopted or proposed by the Scottish Government to mitigate climate change, including policies already in force but under continuing Ministerial discretion. These are assessed against and in addition to a baseline position in which such policies are assumed to have not been enacted, and all policies are assessed on this basis. The baseline takes account of expected wider actions by the private sector and by the UK Government which, while outside the scope of the CCP, are expected to influence Scottish Emissions.”
Roughly, this means that in the CCP there are assumed changes that result from Scottish Government policy and then there are changes that result for other factors e.g. the actions of the private sector and the UK Government. The projected emissions for Energy Supply are presented in the table below with the projected future baseline scenario, the scenario where the CCP is implemented, and then the reduction that is assumed within the baseline and that which is assumed to result from CCP policy.
Energy Supply emissions* | 2021-25 | 2026-30 | 2031-35 | 2036-40 |
Baseline emissions | 20.3 | 9.9 | 4.8 | 4.4 |
CCP emissions | 20.3 | 9.9 | 3.5 | 2.7 |
Reduction within the future baseline | – | (20.3 – 9.9=) 10.4 | (9.9 – 4.8=) 5.1 | (4.8 – 4.4=) 0.4 |
Reduction that results from CCP policies | – | (9.9 – 9.9=) 0 | (4.8 – 3.5=) 1.3 | (4.4 – 2.7=) 1.7 |
*with Non-Road Mobile Machinery (NRMM) abatement removed
The table shows that significant changes in emissions take place as a result of the assumptions that make up the baseline as well as from the assumed changes that result from CCP policies. While the changes in the baseline result from policies and actions from the UK Government and the private sector, they contribute to the overall achievement of the carbon budgets in the same way that the CCP policies do. As highlighted earlier, this is a sector where there is a split in reserved and devolved powers.
It is also worthwhile considering the assumptions on the costs and benefits in this sector. This is the first CCP that is required to set out costs and benefits of action. In Table 35 in Annex 3, these are set out for Energy Supply as all being zero, as ‘all emissions reductions are expected to be market driven.’ This raises the question of how some emission reductions result from policy (as in the Table above) but no costs and benefits do.
Conclusion
The Scottish Parliament increased Scottish emission reduction ambitions in 2019 to net zero by 2045 and set new interim targets for 2030 and 2040. The Scottish Government published a CCP update shortly after, setting out how they thought the ambition would be achieved. In 2024, after accepting that some of the previous ambitions were no longer credible they re-drew their ambitions. This CCP, in 2025/26, is meant to present a new chapter in emission reduction policy. This blog sets out that in the CCP, Energy Supply is a mixture of reducing the remaining emissions from a gas plant and energy from waste sites, and increasing deployment of low carbon energy sources. It also involves projecting the reduction in emissions from the supply of oil and gas in Scotland. In these areas, like in many other parts of climate policy, activity is a complex mix of effort from the Scottish and UK Government and the wider industry.
Niall Kerr, SPICe