Background
The Scottish Government published the draft of its new Climate Change Plan (CCP) on 6 November 2025. This is a statutory requirement under the Climate Change (Scotland) Act 2009 (as amended). Publishing the draft has kicked off 120 days of parliamentary scrutiny, as required by the legislation.
This Plan outlines how the Government intends to meet emissions reduction targets across all portfolio areas and sectors of the economy. It covers the period 2026-2040 with the goal of being ‘net zero’ in carbon emissions by 2045. Net zero is the point when emissions entering the atmosphere are balanced by removals out of the atmosphere.
Scrutiny of the draft CCP is a cross-parliamentary effort, reflecting the fact that climate change impacts across all sectors, with the Net Zero, Energy and Transport (NZET) Committee taking the lead.
This blog explores the Scottish Government’s policies and proposals in the chapter on ‘land use, land use change and forestry’ (LULUCF) in the new draft Plan. It draws on information received through the NZET Committee’s call for views ahead of the new draft CCP (a summary of views on LULUCF is published). It also compares the LULUCF chapter with the May 2025 advice to the Scottish Government on meeting its carbon budgets published by the Climate Change Committee (CCC), statutory advisor on climate change to the UK and devolved governments.
This blog is published in two parts. The first part discusses the agriculture chapter of the draft CCP.
For more blogs on other topics relating to the draft CCP, visit the SPICe Hub on the Plan.
Headlines in the Land Use, Land Use Change and Forestry chapter
The LULUCF sector includes the emissions and removals from different land uses (apart from agricultural production which is accounted for in the agriculture chapter) and changes between different land uses. A SPICe blog published in July 2024 breaks down emissions in the agriculture and LULUCF sectors in more detail
Since the last Climate Change Plan Update (CCPu) in 2020, headline emissions from LULUCF have not changed. The CCPu projected that LULUCF emissions would be 0.6 MtCO2e in 2020 and fall to 0.2 MtCO2e by 2023. The actual figure in 2020, published in the 2022 emissions inventory, was 0.5 MtCO2e, and emissions in 2023 (our most recent figures) are estimated at 0.5 MtCO2e. The emissions reductions anticipated in 2020 have therefore not happened.
The key policy drivers in this sector are the policies to increase and fund woodland creation and to restore peatlands. These policies are not new, but they have been reframed in the draft CCP.
Forestry
Policies and proposals for forestry relate to woodland creation and the sustainable use of harvested wood products. The latter ensures that carbon continues to be locked up in wood products but does not have a direct emissions impact.
The key forestry policy directly delivering emissions reductions in the draft CCP is to:
“Increase…the annual woodland creation target every year until the end of the decade, hitting 18,000 hectares per year in 2029/30, and with the aim of achieving 21% woodland cover in Scotland by 2032.”
In Annex 2, the CCP further elaborates that approximately 250,000ha of woodland would be created by 2040. This longer-term ambition is new for the draft CCP, while annual planting and national forest cover targets are long-standing. However, the policy represents a reduction in the ambition for 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”. There is a question around the impact of pushing woodland creation into the future, considering that the CCP states that the forest carbon sink is estimated to contract as older woodlands mature and timber is harvested, and that “creating new woodlands now is the main forestry measure to mitigate this decline and rebuild the rate of sequestration capacity”.
The draft CCP states that annual planting rates will increase as follows:
Year | Proposed woodland creation target (hectares) |
2025-6 | 10,000 |
2026-7 | 12,000 |
2027-8 | 14,000 |
2028-9 | 16,000 |
2029-30 | 18,000 |
While not explicitly stated, it is assumed that the intention is for this rate to be maintained to 2040, which would achieve the target to plant 250,000ha by 2040. However, this does not meet the CCC’s recommended 22,000ha/year by 2036. This raises the question of where this difference between the Scottish Government’s plans and the CCC’s advice is compensated for.
Over the last five years, woodland creation has fluctuated between just over 8000ha (2022/23) and 15,000ha (2023/24) in a single year. In 2024/25, 8470ha were created.[1]
The CCP also maintains a target for overall woodland cover. Existing woodland cover is estimated to be 19% according to the draft CCP. The national woodland cover target of 21% has been in place since the CCPu, and the target date of 2032 is unchanged; however, it is unclear how a reduced annual target could still achieve the same national coverage in the same timeframe. The CCP also sets a longer term target for forest cover to expand to 24% by 2040. There is some confusion here however, as the CCC sets a target to expand forest cover to 23% by 2045. It is unclear how the Scottish Government’s lower annual planting target will achieve a higher proportion of woodland cover.
The draft CCP states that, to support the annual planting target, there will be investment in tree nursery production and a continuation of the existing Forestry Grant Scheme, which supports a large proportion of Scotland’s new woodland creation. Beyond this, there is not a lot of detail.
In relation to the Forestry Grant Scheme, the draft CCP references cuts to forestry funding in recent Scottish Government budgets, and states that:
“delivery of the proposed levels of woodland creation will depend on sector confidence and on adequate funding for the Forestry Grant Scheme (FGS) over the next 15 years. Recent cuts to funding undermined forest sector confidence about investing in woodland creation in future and could best be addressed through a multi-annual agreement on funding for the FGS.”
However, it is not clear whether multi-annual funding is a commitment the Scottish Government is making or intends to make in the future.
There is little detail on how much funding is likely to be committed, how planting is expected to be targeted to achieve emissions reductions and other co-benefits, who is expected to deliver (beyond commitments to raise awareness of integrating trees among farmers and crofters), and what the trade-offs might be for other land uses or land users.
This contrasts with the CCC’s advice which includes some specific details in relation to the planting targets. For agroforestry, for example, the CCC includes an assumption that “the transition to agroforestry rises annually by 2,600 hectares, and the extent of hedgerows increases by 19% by 2045.” In its response to the NZET Committee’s call for views, NatureScot stated that “it would welcome the setting of a target for hedgerow expansion along the lines of what the CCC recommends. We would welcome the same on agroforestry”. While the draft CCP states an ambition to “review, update and develop mechanisms, as appropriate” to support trees on farms, there is no specific target or any breakdown of delivery of different types of woodland.
In terms of how planting will achieve emissions reductions, one hectare of woodland created in one location is not the same as another hectare in another location, with potentially different tree species used, planted with different methods on different soil types, replacing different land uses. The species, planting methods and site conditions will influence the sequestration capacity of the woodland, as well as any co-benefits for biodiversity, community benefits, economic returns, and resilience to climate effects, to name a few.
Where trees are planted and how they are planted are important to ensure that there is a net carbon benefit to planting a new woodland. A 2020 research paper by Scottish academics (Matthews et al) found limitations to area-based targets in that there is a range of possible outcomes for any area planting, which affects the resulting sequestration. They argue for “explicit supporting assumptions on the minimum anticipated extent or rate of carbon sequestration delivered across the area of new woodlands.”:
“Otherwise a combination of land manager preferences, budgetary limitations, and the unintended consequences of other land use or agricultural policies can lead to the afforestation of less productive land, on soils with higher organic matter contents, that in the worst cases results in net emissions of carbon for decades.”
The situations where woodland creation may result in a net loss of carbon on timescales that are longer than what is required to reach net zero by 2045 is an area of emerging research (e.g. Friggens et al. 2020; Housego et al. 2025), but where there is continuing scientific uncertainty.
The supporting information in Annex 3 appears to factor in variation in CO2 removals and anticipates that siting new woodlands will improve. As a result, the draft CCP states:
“Scottish Forestry has worked with colleagues in the Scottish Government to prepare forestry’s contribution to the Climate Change Plan. The current policy (Policy 1) is to scale up to 18,000 hectares of new woodland a year by 2029, with a further 10% “stretch” in CO2 removals due to the potential for improved location, species and management of trees”.
It is unclear how planting will be prioritised to ensure optimal sequestration occurs, while balancing trade-offs and maximising other benefits. NatureScot, in its response to the NZET Committee’s call for views on the plan, emphasised that to ensure that woodlands begin to sequester carbon on a relevant timescale –
“we believe that in the next 15 years new woodlands through planting should be directed towards the poorer mineral soils with a lesser proportion planted on organo-mineral soils.”
A further question around forestry, raised by Stop Climate Chaos Scotland in its response to the call for views, is whether the CCP has accounted for potential climate-related risks to woodlands such as pests and diseases, drought, flood or wildfires or changing conditions leading to less favourable growth for some species. The Scottish Government mentions its recent Routemap to Resilience for Scotland’s Forests and Woodlands, which aims to strengthen resilience to climate impacts. However, it is unclear whether there is a margin of error built into the target or otherwise an assumption made within the Scottish emissions pathway to account for woodlands being damaged or destroyed.
Peatlands
The draft CCP also commits to increases in peatland restoration alongside protecting and managing peatlands.
The key policy in the draft CCP which delivers the majority of emissions reductions 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 following table compares existing and new commitments for peatlands:
Existing commitments | Draft CCP commitments |
250,000ha restored by 2030 | 250,000ha restored by 2030; 400,000ha restored by 2040 |
20,000ha of peatlands restored/year (2018 CCP) | Increase peatland restoration by 10% per year to 2030, from 12,000ha in 2025/26 |
The draft CCP states that 90,000 hectares have been restored to date, including 14,860ha in 2024/25. While the 20,000ha per year target has never been met, this is an area where significant progress has been made in recent years. The restoration achieved in 2024/25 represents a large increase in annual restoration, 42% since 2023-24. Over the last four years, the number of hectares restored per year has roughly tripled.
However, looking at the plans in the CCP, the numbers don’t appear to add up. The Scottish Government’s Peatland Action Five Year Partnership Plan, published on 15 December 2025, clarifies that the baseline for the 10% increase is 12,000ha restored in 2025/26. Adding the 90,000ha that have already been restored, a 10% increase in the area of peatland restored per year equates to around 19,300ha per year from 2030/31, and a total of approximately 182,500 hectares by this point, which does not meet the target to restore 250,000ha by 2030.[2] Maintaining the rate of restoration from 2030 will also not meet the target to restore 400,000ha by 2040 (though it will come somewhat close, at 375,849ha).
It appears therefore that while there have been successes in recent years, ambition is pulled back compared with the previous CCP.
Year | Hectares restored |
Restored to date | 90,000 |
2025/26 | 12,000 |
2026/27 | 13,200 |
2027/28 | 14,520 |
2028/29 | 15,972 |
2029/30 | 17,569 |
2030/31 | 19,326 |
Total | 182,587 |
Comparing with the CCC’s pathway, the Scottish Government is more ambitious regarding peatland restoration over the next few years – and the good news is that high levels of restoration over the last few years have surpassed the expectations in the CCC’s balanced pathway.
However, looking beyond the next few years, it appears that the draft CCP’s plans for peatland restoration are significantly less ambitious than the CCC has advised. The CCC’s balanced pathway advises a rapid increase in hectares restored per year to reach 45% of peatlands restored by 2035. To meet this goal, annual restoration will need to be much higher than the CCP’s plateau of just under 20,000ha restored per year from 2030. As with forestry, this is a policy choice but raises the question of where the difference will be made up.
There is one new detail in the draft CCP which may help to bolster emissions reductions from peatland restoration, despite the lower rate of restoration. Annex 2 states that “we will look to increase the proportion of the most highly degraded and emitting peat that is restored.” This raises the question of whether the lower level of restoration compared to the last CCP is still intended to avoid a similar amount of peatland emissions over the same timeframe and whether this closes some of the gap with the CCC’s projections.
However, the plan provides little detail about how funding and capacity will be targeted to reach the most highly degraded and emitting sites. There is no additional information on where these sites are in practice, what land uses currently take place on them, whether there are any barriers to restoration there (e.g. land tenure types, physical access, capacity for contractors) and how to overcome these.
Previous issues with workforce capacity in peatland restoration are well known. Recent research commissioned by NatureScot looking at current and future workforce and skills requirements in the peatland sector found that the existing workforce is around 380 full-time equivalent (FTE) staff. To meet the demand for restoring 20,000ha per year the sector will need to grow to around 750 FTE. This would need to come close by 2030/31 to maintain the restoration pathway set out in the draft CCP. Increasing restoration to 35,000ha per year would require the workforce to more than triple to 1,258 FTE. This includes Peatland ACTION partners, agents, Peatland Code validators (providing the validation to generate carbon credits), ecologists and site surveyors, and contractors.
The research found, among other things, that realising the full potential of the peatland restoration sector “is constrained by short-term funding cycles, seasonal work patterns and fragmented systems” and a “strategic, long-term approach is needed to align workforce planning, investment, and delivery with national restoration and climate targets”.
The CCP acknowledges this research and cites workforce figures but does not provide information on how these issues are intended to be addressed. The Peatland ACTION Partnership Plan sets out a bit more information on ambitions and Peatland Skills Action Plan provides information on peatland restoration training courses that are currently available.
Just transition
As discussed in Part 1 of this blog series, there is a greater focus on a ‘just transition’ to net zero in this draft CCP, following new requirements in the Climate Change (Emissions Reductions Targets) (Scotland) Act 2019.
Ensuring that the transition to net zero is just is particularly important for some sectors; land use and agriculture is one of the sectors where a draft just transition plan has been published and consulted on.
To monitor progress, the draft CCP includes a set of ‘just transition indicators’ which “aim to give an indication of whether we are achieving a just transition alongside progress on our emissions reduction pathways”.
However, while there are two land-use related indicators – the number of hectares of peatland restored or woodland planted per year – these do not appear to be particularly meaningful in this respect. The reason given for using these indicators is that these landscapes can support a wide range of ecosystem services and benefits.
The CCP recognises limitations in that these indicators “will not provide an assessment of the socioeconomic implications…or the degree of local community involvement” and states that the indicators should be used alongside other indicators monitored through the Scottish Climate Survey, which assess participation and public views of changes to the local area as a result of net zero interventions.
However, it is not clear how viewing these together will be able to shed light on whether woodland creation and peatland restoration specifically have been carried out in a just and fair way, or whether multiple benefits have been achieved.
The Scottish Government recognises that some of the indicators are incomplete, stating that
“a project is currently underway to develop a more comprehensive just transition M&E [monitoring and evaluation] framework through a staged process of evidence review, stakeholder engagement and cocreation.”
Will it be enough?
The key question is whether the whole plan adds up to meet Scotland’s carbon budgets in a credible way that is likely to take Scotland to net zero by 2045. In the areas explored in this blog (and in the agriculture sector, as Part 1 of this blog series discusses), the ambition in the draft CCP appears to be lower than the CCC’s balanced pathway expects. The key question is where the difference is made up, and whether it is realistic and equitable for other sectors to take on more emissions reductions as a result.
Anna Brand, Senior Researcher
Featured image by Professor Ed Hawkins, University of Reading.
[1] Source: https://cdn.forestresearch.gov.uk/2025/09/FS2025_Ch1-68d4f71b97f6f.pdf; Forest Research’s forestry statistics state that “Estimates for areas planted without grant aid are believed to be underreported and, as a result, the reported figures are likely to underestimate the true level of planting activity.”
[2] Before the Peatland ACTION Five Year Plan was published, SPICe used the 2024/25 restoration figure (14,860ha) as a baseline. Even with this higher baseline, the 250,000ha by 2030 target is not met, though the 400,000ha by 2040 target is exceeded.