Scotland Against Spin’s take on “Scotland’s Climate Change Plan – 2026-2040”: the ScotGov Consultation

 

The Scottish Government’s Consultation on its latest “Climate Change Plan” can be found here:

 

https://www.gov.scot/publications/scotlands-climate-change-plan-2026-2040/

 

The Consultation questions are to be found here:

 

https://www.gov.scot/publications/scotlands-climate-change-plan-2026-2040/pages/15/

 

Consultees are invited to respond online here:

https://consult.gov.scot/energy-and-climate-change-directorate/draft-climate-change-plan/

However, there is no obligation to respond in this way, and responses may also be sent by email to this email address:

 

climatechangeplan@gov.scot

 

As the consultation makes clear, respondents may answer as much or as little as they like:

 

“The consultation questions are divided by sector and theme, you may skip individual questions or whole sections if you do not believe they are relevant to you. The consultation is designed for a mix of respondents and there is no obligation to respond to all questions.”

 

The closing date for responses is 29^th January 2026.

 

We set out below the questions with our views on them.   These are offered as a means to assist communities and individuals affected by the plans to respond to the questions.   They are for guidance only, and everyone is of course completely free to answer as they wish.   However, we hope our views may be helpful.

 

1. What are your views on our approach to delivering a just transition for people and communities?

The evidence is that to date, this is not a just transition to Net Zero for a large proportion of Scotland’s citizens and communities:

 

– the adverse impacts of renewable energy infrastructure (wind, solar, BESS, grid expansion) affect almost entirely rural vs. urban citizens

– the transition to Net Zero has resulted in significant job losses – particularly to NE Scotland and Fife,  which have not been replaced in number by much touted ‘green’ jobs.

– Loss of fishing grounds in the North sea in particular.

– Loss of agricultural lands and jobs to renewable energy developments.

– Loss of rural housing and businesses directly and indirectly affected by renewable industry developments.

– Communities destroyed and divided by landowners and others getting rich from renewable incomes at the expense of their neighbours suffering adverse effects and devaluation of their homes.

 

2. We recognise that workers face particular impacts from the Plan and we have outlined our approach to supporting the transition of the workforce, including skills for jobs. What skills, training and qualification provisions will be most important in a net zero future and what more could be done to support them?

 

It is not within our self-imposed remit to comment specifically on questions such as this, but we do note that while the jobs of Scottish workers in relation to North Sea Oil and gas are being destroyed by the Net Zero commitment, they do not seem to be replaced by jobs for Scottish workers in the renewables industry.   A recent Scottish TUC Report (https://www.stuc.org.uk/resources/ons-analysis-final-2023-data.pdf) suggests that “For every million pounds of turnover around 1 job is created in offshore and onshore wind. By contrast, every £1 million of investment by the oil and gas industry generated 14.2 jobs in 2022 and 13.4 jobs in 2023”.   As GMB Scotland Secretary Louise Gilmour said: “Too many energy and manufacturing workers believe the transition to renewables is being done to them and not with them.”

 

3. The Plan will bring opportunities and challenges for businesses and employers. How can we best support employers across the private, public and third sectors to make the changes needed and seize the benefits of net zero?

Again, this is beyond our remit.   We merely note that Scottish employers are suffering from some of the most expensive electricity in the world (in spite of ScotGov’s claims that renewable energy is cheap) and therefore we would question the underlying assumption regarding the extent of the claimed “benefits” of net zero.

 

Scottish Government economic figures (https://www.gov.scot/publications/scottish-annual-business-statistics-2023/pages/main-sectors/) show that between 2022 and 2023 alone, approximate Gross Value Added for the non-financial business economy decreased by £3.9 billion (-3.1%), driven by a fall in primary industries which includes the oil and gas sector, a collapse which mirrors the reduction in Scotland’s territorial (but not consumption) greenhouse gas emissions.
Economic figures show Scotland’s GDP now more reliant on a services industry, as well as more traditional agriculture, fishing and forestry.
The loss of North sea Oil and Gas revenue due to Net Zero goals, along with the associated direct and indirect employment and spending will continue to have significant negative impacts.
There is desperate need for inexpensive and reliable electricity, which cannot be met by imposition of expensive and intermittent renewable generation if Scotland is to return to having a sustainable industry and manufacturing base and lower unemployment.
Support is needed to reverse the manufacturing decline associated with political Net Zero policies.

 

 

4. Our approach recognises that some of the Plan’s impacts will have greater implications for particular regions of Scotland. What are your views on our approach to supporting places where the transition presents particular regional impacts?

 

Our response is (as above) that rural Scotland is suffering disproportionately from the Scottish government’s obsession with consenting more and more renewable energy and associated projects.   We believe that the government’s approach in doing this while ignoring the wishes of local communities is completely wrong.   No amount of talk regarding community benefits and a just transition can compensate for the blighting of lives and the destruction of Scotland’s wild places.   Our view is that this represents ecocide, a crime which should be stopped forthwith.

 

5. How can we decarbonise homes and buildings in a way that is fair and leaves no one behind?

 

Once again, this is beyond our remit.

 

However, it is a well established fact that Scotland endures lower average temperatures than the rest of the UK. The need to keep homes warm and people alive should take priority over decarbonisation of homes.  Heat pumps, entirely dependent on sometimes fragile and intermittent very expensive electricity supplies are recognised to be ineffective in Scotland’s older housing stock. Heat pumps should therefore not be made mandatory in either new or old housing stock.  Consumers will naturally choose what is most cost-effective for their circumstances. Forcing citizens into debt and fuel poverty with cold homes will not engender support for Net Zero policies.  Instead of subsiding generation of renewable energy, VAT should be removed on insulation products, and non means-tested grants awarded to improve domestic insulation.

 

 

And we note the difficulty (if not impossibility) of “decarbonising” tenement blocks; we question the wisdom of putting all eggs in the single basket of reliance on electricity for all of our needs (noting that every winter swathes of Scotland are left without electricity supply for days on end in the aftermath of storms which we are told will be made worse by climate change).

 

6. How can clean heating systems (such as heat pumps) be made more affordable for everyone?

 

See 5.  The issue in Scotland should not be to decarbonise at all cost, but to ensure that in the 21st Century homes are warm enough.

 

Questions 7-10 deal with transport and waste, and are not within our remit, but the next question certainly is:

 

11. What are your views on Scotland generating more electricity from renewable sources?

 

 Scotland has already met and exceeded its target for renewable electricity generation: ScotGov’s net zero consultation notes that “In 2023, 70% of electricity generated in Scotland was from renewable sources, and Scotland is a net exporter of electricity to the rest of the UK: in 2024, there were 19.7 Twh of net electricity exports to other UK nations” our view is that seeking to generate more electricity from “renewable” sources is an expensive fool’s errand.

 

Given the adverse effects outlined in answer to 1., further increase in renewable generation will increase still further unacceptable impacts whilst profiting largely foreign companies seeking to exploit Scotland’s resources with little or no benefit to the populace and potentially still higher electricity costs due to increasing publicly-funded constraint and other renewable generation subsidies.

 

The flip side of massive renewable energy capacity is the inability of the grid to cope with peak periods of “renewable” generation, with the result that huge payments are being made in the form of constraints payments to (mostly foreign-owned) “renewable” energy companies not to produce electricity for use by the grid.   Perhaps the most extreme example of this folly is the Viking Energy wind farm on Shetland.

 

Despite not coming online until August 2024, it made £9,294,018 in constraints payments in just five months that year, including a staggering £2,732,682 in October 2024, a figure which was almost matched in its first month of “operation” (£2,502,479). By the middle of November 2025, not surprisingly, more MWh had been constrained (897,326 -v- 464,320 in 2024) but with an average price of £8 per MWh constrained (-v- £20 in 2024), sitting idle for lengthy periods hasn’t proved to be quite so profitable for SSE in 2025. Still, £7,520,342 to that point in 2025, for doing nothing, isn’t to be sniffed at. In each of three months in 2025 (June, September and October) SSE received well over £1 million for its Viking Energy Wind Farm to sit idle.   According to NESO, constraints payments across the UK (the bulk of which will relate to renewables in Scotland) could reach £8bn by 2030.  Taxing the poor to pay these sums to fund dividends (often for wealthy foreign shareholders) isn’t our idea of a “just transition”, nor of basic economic sense.

 

Then there’s the flip side of too much renewable energy.   During a dunkelflaute (sadly, all too common), “renewable” sources in the form of wind and solar produce very little electricity.   Increasing renewable capacity doesn’t solve this problem.   On the contrary, ten times zero is still zero.   In our view, a sensible energy policy is one which relies on various sources of energy in order to reduce risk of shortfall or excessive costs arising with regard to any one energy source.   Increasing reliance on an essentially unreliable and unpredictable source of energy offers the opposite of energy security and will inevitably increase, not reduce, electricity prices, given the increasing need for expensive forms of back-up.

 

12. What support do industries need to reduce their carbon emissions while remaining competitive?

 

Industries, especially energy-intensive ones, need cheap energy in order to remain competitive.   To date the drive towards net zero seems to be delivering the opposite, with the UK having among the highest industrial electricity prices in the world.

 

See comment to 3.  If electricity became the cheapest energy source, industries would naturally move to use it. That is the nature of successful business.  As it is, Net Zero policies penalise the use of cheaper fossil fuels and eventually this results in the loss of that energy-intensive industry altogether – potentially to another country with cheaper energy and less regulation, but which shares our same climate.

 

 

13. How can the Scottish Government encourage sustainable land use, that is also productive for local communities?

 

Traditional agriculture and forestry provide sustainable land use and rural employment with inclusive sustainable communities.  Loss of land to renewable infrastructure destroys rural societal cohesion and productivity.

 

14. What do you think about our proposals for planting trees and restoring natural habitats like peatlands?

 

This appears to be a retrospective window-dressing policy by the Scottish Government.  It is patently obvious to the public how many hectares of forestry, including native woodlands, are felled (according to the Scottish government’s own figures, something of the order of 17 million trees between 2000 and 2024) to accommodate onshore windfarms and related renewable infrastructure . It is also patently obvious how much virgin peat has been destroyed to host onshore windfarms and other ‘green’ renewable generation infrastructure.

 

It is misleading to suggest that restoring  peat bogs in selected areas (as a consequence of drainage for agricultural use) will mitigate for the more widespread environmental damage which has occurred, but which continues to be sanctioned by NPF4 in the name of mitigating the climate crisis.

Whilst there are some successful and welcome government funded projects to increase planting of native trees in riparian zones to improve water quality, the adverse water quality effects of increased run-off due to increased forest felling for windfarms is now clearly evidenced in several scientific papers.

 

 

 

15. How can the Scottish Government support farming to become more climate-friendly while continuing to support food production and improve biodiversity?

 

In our view, the best thing the Scottish Government can do in this regard is “get out of the way”.   Stop granting planning permission for solar farms that take up valuable farmland that could otherwise be used for food production.   Stop granting planning permission for unnecessary solar and wind farms that damage biodiversity.

Allow Scottish people to decide for themselves what they wish to eat and drink, whether that be a plant-based or meat-based diet.  Interference with people’s personal choices will build resentment against Net Zero policies, e.g. banning cows, or taxing bovine products to reduce methane emissions will make no difference to climate change, but will only cause further societal inequality in Scotland.  Scotland’s record on biodiversity is woeful.  The most recent Biodiversity Intactness Index for Scotland is 45%, which is similar to other UK countries but far lower than other European countries. In the assessment, which looks at more than 240 countries and territories across the world, Scotland ranks 28th from bottom.
State of Nature, the most precise scientific report on Scotland’s nature, shows a 15% decline in average species abundance across closely monitored wildlife since 1994. In the last decade alone, 43% (172) of the species have declined strongly. The decline of seabird populations (pre avian flu) is especially worrying.

That last decade corresponds with the greatest industrialisation of rural and marine Scotland to meet Net Zero targets.
It is not just farming destroying biodiversity, it is Net Zero policies.

 

 

16. Which groups or communities do you think will be most affected by the transition to net zero, and in what ways?

 

Serious short- and long-term job losses in Scotland have not replaced by renewables jobs for Scottish workers.  Robert Gordon University predicts losses of more than 50,000 oil and gas jobs in the North East of Scotland by 2030.

The UK Labour government’s much-heralded GB Energy has 69 employees of which only 13 are in Aberdeen and 31 are based in London. GBE promises 200-300 jobs by 2030 (doing what?).   Its Chief Executive works in Manchester.

Examples of adverse effects are the loss of Ineos Grangemouth (oil refinery and petro-chemicals): direct losses 400 and indirect job losses 2,800.   The loss of 400 direct jobs at Mossmorran ethylene factory in Fife, which relies on North Sea gas.

Foreign workers are often employed in windfarm construction. Use of local accommodation for these foreign workers is used in Government statistics to seek to demonstrate no commensurate loss of Scotland’s tourist income, but this is very short-lived use.
Rural business owners e.g. in the Highlands, are already reporting loss of tourism income.

 

Clearly, then, the transition to net zero involves winners and losers.   To date the winners seem to be energy suppliers and (largely) foreign “renewable” energy companies and the (largely foreign) workers employed by them.  The Chinese Communist Party also seems to be a major beneficiary.  The losers are Scottish consumers of electricity, both domestic and industrial; Scottish workers in fossil fuel industries who are being thrown on the scrap heap; Scottish businesses being rendered uneconomic and uncompetitive, due to electricity prices which are among the highest in the world; owners of homes across Scotland blighted by industrial-scale “renewable” energy developments and associated industrial-scale infrastructure; owners of small businesses in the tourist trade across Scotland adversely affected by the negative effect of large-scale “renewable” energy developments on tourism; and possibly trawlermen adversely affected by offshore wind farms.   There are many losers and few winners, though a number of politicians gliding seamlessly from politics to some of the few “green” jobs (in academia and on the boards of “renewable” energy companies) are among the winners.

 

17. How do you think the Climate Change Plan aligns with existing local, regional, or national priorities that you are aware of or involved in?

 

Net Zero policies implemented by Local Authorities (LAs) have undoubtedly increased their expenditure with no apparent value to local residents. E.g. abandoned schemes for energy campuses, (to create green jobs and education), exclusive use of a fleet of green vehicles, which cost more in wages whilst employees are idle waiting for cars/vans to charge. This is  not a good use of money and council tax – especially in rural areas where populations are dispersed and it costs LAs more to maintain essential services. The CPP undoubtedly influences and aligns with LA policies at multiple levels, including planning and the delivery of services that local communities would wish to see. These are not always positive influences but restrict the choices of communities in influencing what they think would be appropriate developments and services for their area.

 

Given that “The Climate Change Plan focuses primarily on reduction of our territorial emissions”, and given the irrelevance of Scotland’s territorial emissions to climate change (the threat it is aimed at “dealing with”), it is difficult to understand the “logic” behind the Climate Change Plan.

 

18. If you identified there could be negative impacts of the Climate Change Plan, are there any ways you think we could reduce that negative impact and if so, what would you recommend?

 

It is difficult to see that the many negative impacts of the Climate Change Plan can be reduced other than by changing the Plan.   First and foremost, the rubber-stamping of planning applications for “renewable” energy developments and associated industrial-scale infrastructure, often against the wishes of local residents and Councils, should cease.   Democracy should be restored to the planning process.   The Scottish Government and all Scottish Local Authorities should comply with their international obligations pursuant to the Aarhus Convention.

 

The SG only pays lip service to Aarhus – despite recognising its obligations.   For example, this flippant non-answer to a serious question:

SCOTTISH PARLIAMENT

WRITTEN ANSWER

7 November 2012

Index Heading: Enterprise & Environment

 Graeme Pearson (South Scotland) (Scottish Labour): To ask the Scottish Government  what steps it has taken to implement the Aarhus Convention and what guidance it has given to local authorities to ensure that they meet their obligations under the convention in relation to planning issues.

(S4W-10543)

Mr Derek Mackay MSP:

The Scottish Government considers that current arrangements ensure compliance with the terms of the Aarhus Convention in respect of the dissemination of environmental information, public participation and access to justice in environmental decision making. There are statutory frameworks in place to ensure that local authorities comply with the terms of the Aarhus Convention.

 

 

19. Please share any other quantitative data, or sources of this, to assist in developing the impact assessments?

 

There is plenty of data to be found on the Scotland Against Spin website.   Several of them can be found here: https://scotlandagainstspin.org/media-resource/

 

20. Are there any previous examples or case studies we should consider when assessing potential impacts?

 

We would refer to the FAQ section of the Scotland Against Spin website, here: https://scotlandagainstspin.org/wind-energy-faqs/

 

21. Can you think of any further positive or negative impacts, that are not covered in the impact assessments, that may result from the Climate Change Plan?

 

Information regarding accidents, impacts on health, and environmental damage associated with wind farm developments can be found at this section of the Scotland Against Spin website: https://scotlandagainstspin.org/turbine-accident-statistics/

 

22. What are your views on the accuracy and scope of the environmental baseline set out in the environmental report? Are you aware of further information that could be used to inform the assessment findings?

 

In our view the environmental baseline contains a lot of fine words, but little, if any, recognition of the contradiction between the urgent need to enhance biodiversity, protect landscapes, etc and the damage to both caused by unsuitable renewable energy (together with massive associated infrastructure) developments in inappropriate locations.   A few obvious examples:

 

Paragraph 3.6.1. says “Landscape objectives, including those from the European Landscape Convention, recognise and protect special landscapes but also aim to improve degraded landscapes and highlight the importance of all landscapes.”   Then paragraph 3.6.6. recognises that “the rapid growth of the renewable energy sector, is likely to place pressure on our valued landscapes”, yet that rapid ongoing growth is an integral part of your plan.

 

Para 3.7.4. says “In 2019/20, there were an estimated 123 million visits to Scottish woodlands, reflecting their importance for recreation, health, and wellbeing.”   Yet the Scottish government’s figures confirm that 17 million trees were cut down between 2000 and 2024 to make way for wind turbines.

 

Para 3.7.7. says “Globally, cement manufacturing is responsible for 8% of CO2 emissions”.   Yet wind turbine foundations use a significant amount of concrete, typically ranging from 500 to over 1,000 cubic meters (or 1,000 to 2,000+ tonnes) for a single onshore turbine, with larger, newer turbines requiring even more. The volume varies by turbine size and design, but it’s a substantial mass, often involving tons of steel reinforcement, making the concrete foundation a major material component.

And so on.   In short, the environmental baseline is a word salad which nods towards the importance of these matters, while the Climate Change Plan directly contradicts and undermines many of them.

 

23. What in your view are the most significant environmental effects which should be taken into account as the Draft Climate Change Plan is finalised?

 

We are concerned by an ongoing implicit assumption by those in positions of authority that the “climate crisis” and the “nature crisis” are intertwined in such a way that the “nature crisis” can be resolved (or eased) only by “dealing with” the “climate crisis” within Scotland (a hubristic and unrealistic notion, if ever there was one).   The simple fact of the matter is that the industrialisation of the Scottish countryside by the construction of ever-more renewable energy projects (and associated industrial-scale infrastructure) cannot “deal with” the “climate crisis”, but it most certainly exacerbates the “nature crisis”.   The one most important change that we would like to see is a fundamental recognition on the part of Scottish politicians and bureacurats of this simple truth.

 

24. What are your views on the predicted environmental effects as set out in the environmental report? Please share any other useful sources.

 

Please see response to question 22.

 

25. What are your views on the proposals for mitigation, enhancement and monitoring of the environmental effects set out in the environmental report?

 

As with our response to question 22, we believe that the Scottish government’s environmental and climate change plans are mutually contradictory.

 

26. What are your views on the proposed approach to reporting annual emissions output and how this could support public understanding of Scotland’s progress towards achieving our Carbon Budgets?

 

Given that it is folly of the highest order to assume that Scotland’s Carbon Budgets achieve anything at all in global terms or with regard to climate change, we have no view on this question, other than to suggest that the best thing that could be done with regard to Carbon Budgets is to drop them.

 

27. How useful do you think reporting emissions statistics at a more detailed level (including at the sub-sectoral level), would be in helping people understand key sources of emissions, and our progress in reducing them?

 

It probably would be helpful regarding the stated objective, but to what purpose?   In our opinion, this is simply an expensive exercise in futility.

 

28. How might the use of timely indicators, as proposed, help people to understand what needs to be delivered to achieve our Carbon budgets, and to understand whether progress is on track?

 

Please refer to our answer to question 27.

 

29. Please detail any specific changes that would improve any of the 14 proposed indicators, including any data sources not currently included within this framework that could provide a useful indicator of progress towards a just transition in Scotland on an annual basis.

This is beyond Scotland Against Spin’s remit.

 

30. What are the most appropriate indicators for judging whether we are achieving meaningful public participation in decisions related to the climate? This includes both the quality of the participatory process itself, and the impact of that participation on the decision-making process.

 

This is also beyond Scotland Against Spin’s remit.

 

 

31. What indicator would provide the best measure of the impact of net zero development in local communities across Scotland? For example, the impact of the installation of renewable energy infrastructure or other land use changes (e.g. through peatland restoration or tree planting).

 

The best indicator of the impact of the installation of renewable energy infrastructure in local communities across Scotland is simply the response of the communities affected by the developments when they are still at the planning stage.   Time and again residents object to such developments in large numbers, despite the complexity of a process which works against them, and which many find difficult to negotiate (unlike the developers, with their legions of expensive lawyers, planning consultants and other experts).   Time and again planning consent is given, whether at Council level, or by or on appeal to the Scottish government.   Time and again such decisions are made in the face of substantial opposition.   We find it difficult to understand that the Scottish government finds it necessary to ask question 31.   The answer is obvious.   Listen to, and take note of, the concerns of the people affected.   Stop riding roughshod over them.

 

32. Ensuring positive outcomes for workers who have transitioned from jobs within high-carbon industries is central to delivering a just transition. What specific data or indicators could we use to monitor the extent to which workers in high-carbon industries are securing alternative employment?

 

This is beyond the remit of Scotland Against Spin.

 

33. What specific data or indicators could we use to meaningfully monitor the impact of the transition to net zero on the environment and biodiversity across Scotland on an annual basis?

 

This is a very wide-ranging question.   It ought to be obvious that large-scale industrial developments in Scotland’s wild places will have a negative, rather than a positive, impact on the environment and on biodiversity.   As a minimum, however, the Scottish government should be tracking fatalities from collisions (birds/bats with wind turbines or power lines) or electrocution and assessing the impact on insect populations; eDNA monitoring should be put in place to detect “invisible” shifts in species presence or the arrival of invasive species; attempts should be made to assess whether altered migration routes (barrier effects) and shifts in breeding success are being caused by operational noise, shadow flicker and habitat loss; the effect of light pollution from aviation lights should be monitored; the British Trust for Ornithology should be consulted and data from its surveys scrutinised; assessment should take place as to the effect  infrastructure such as solar arrays or access roads have on breaking up wildlife corridors and resultant disruption to protected species; numbers of trees cut down or adversely affected during the construction process should be monitored; changes in soil health (erosion, groundwater replenishment) and water quality (runoff patterns from large-scale panel cleaning or turbine foundations) should be monitored, as should disruption to private water supplies; the cumulative regional adverse impacts of such developments should be taken more seriously; life-cycle factors should be taken more seriously also, by evaluating the environmental footprint from “cradle to grave,” including the CO2 emitted in producing the concrete for the massive foundations, the steel used in “renewable” developments, damage caused to peat, the lengthy roads driven through the wild places to service the developments; the mining of critical minerals for panels/batteries and eventual decommissioning; associated infrastructure that is essential with regard to “renewable” energy developments – BESS, hundreds of miles of pylons, etc.   We suspect the payback time calculations currently in use are seriously inadequate with regard to their intended purpose, being tilted in favour of “renewable” energy developments.  The above probably does no more than scratch the surface of the environmental damage and negative effects on biodiversity associated with “renewable” energy developments.   This list alone should suffice to persuade policy-makers to pause, then abandon, the continuation of the “renewable” energy plan.