Climate Change Plan: monitoring report 2025
The fifth annual monitoring progress report on the Climate Change Plan update (CCPu) which updated the 2018 Climate Change Plan (CCP) and was finalised in March 2021. The report is a statutory requirement set out in the Climate Change (Scotland) Act 2009.
9. Chapter 8: NETs
9.1 Part A – Overview of sector
Negative Emissions Technologies (NETs) are yet to be deployed in Scotland as they rely on carbon capture and storage (CCS) to deliver negative emissions. Whilst some technologies that could deliver negative emissions are currently deployed, such as energy from waste, these facilities would require retrofitting with carbon capture technology and a clear route to storage, to be considered a negative emissions technology.
The Climate Change Plan update (CCPu) includes policies and proposals for supporting and enabling early deployment from 2029 onwards. We currently do not track progress against the NETs envelope in the CCPu. In our last CCP (Climate Change Plan) Monitoring report, we committed to undertaking a feasibility study on NETs deployment in Scotland. This was published November 2023 and will help inform the development of our NETs policy going forward. The results of this study demonstrated the reliance of NETs deployment in Scotland on the UK Government’s policies regarding carbon capture, usage, and storage (CCUS) Cluster Sequencing, in particular on delivering the Scottish CCUS cluster at pace, as well as the possible benefits of including removals in the UK ETS (Emissions Trading Scheme).
The CCPu sets out the following policy outcomes for the sector. Given that this sector chapter appeared first in the CCPu (2020), there are no indicators for these outcomes. In the next CCP we will update the policy outcomes and include indicators to track progress against these updated outcomes.
Detailed feasibility study on NETs will assess the opportunities for negative emissions in Scotland, and identify applications with the greatest potential, including specific sites where possible.
CCUS: the continued development of CCUS technologies and systems is prioritised to ensure these can be rolled out commercially and at scale by the late 2020s.
Bioenergy: a cross-sectoral approach for the appropriate and sustainable use of biomass in energy applications is agreed and implemented (taking into account competing land and feedstock uses).
Just Transition and Cross Economy Impacts
We wish to understand and report on the broader just transition and cross-economy impacts of our emissions reduction activities in addition to these sector specific policy outcomes and indicators. To do this, in this report we use data from the Office of National Statistics (ONS): Low Carbon Renewable Energy Economy (LCREE) publication. The LCREE data presented in this report is based on survey data of businesses which perform economic activities that deliver goods and services that are likely to help generate lower emissions of greenhouse gases, for example low carbon electricity, low emission vehicles and low carbon services. The LCREE indicator is narrowly defined and, while useful within its limited scope, does not give us the full picture of the impacts on workforce, employers and communities and progress towards a just transition. Over the next year, we will work to develop a more meaningful set of success outcomes and indicators aimed at tracking the impacts of our policies on a just transition to net zero, which will inform our next CCP.
Sector commentary on progress
The CCPu included Negative Emissions Technologies (NETs) as a sector chapter for the first time, recognising the important role that emissions removals will need to play in reaching net zero, as highlighted by the IPCC Working Group 3 report. The ‘learning by doing’ approach set out in the CCPu more widely was also identified as being particularly important in the case of this sector, given uncertainties around technological development and critical dependencies on UK Government action, particularly with regard to carbon capture and storage.Policies included in the NETs chapter recognised these challenges and uncertainties and sought to develop an evidence base to allow for further policy development. We have since undertaken an initial review of evidence.
The review indicated that NETs in Scotland can deliver at scale in due course but not at the pace assumed in the CCPu. This is due to shifts in some evidence and key policy decisions since the time of the CCPu, including:
- The previous UK Government’s decision in October 2021 not to award the Acorn Project during the Track-1 phase has delayed the deployment timeline for the carbon capture and storage system required for NETs.
- While the previous UK Government’s Powering Up Britain announcements on 30 March 2023 reconfirmed their commitment to four UK CCUS clusters by 2030, the current UK Government has confirmed that ‘ambition is no longer achievable’
- Despite updates from the UK Government on Track-2 there is still no timeline for a final decision on the Acorn project.
- It is important to note that no NETS projects were included in Track-1.
- The availability of home-grown sustainable biomass to supply large scale power bioenergy with CCS (BECCS); and
- No public commitment to date by a commercial operator to employ a NETs model for a single large power station in Scotland.
Given lead in times for development of such a facility and proposals for CCS deployment for the Peterhead Combined Cycle Gas Turbine (CCGT) power project (which is subject to a live planning application), it is unlikely that a new NETs power facility will be developed within the next decade. We have since gained further knowledge and evidence of what scale of NETs can be delivered in Scotland and to what timescale, through undertaking a NETs feasibility study. The authors examined existing sites in Scotland which emit biogenic carbon and could deliver negative emissions if paired with CCS infrastructure, as well as biochar production. The study then explored the potential for new sites, including Direct Air Capture. To determine the feasible deployment of these technologies, the study modelled three pathways for NETs deployment, all of which assumed that the Acorn Project and Scottish Cluster would be able to permanently store CO2 by 2030. The pathways differed in the level of government action, such as policy supports, market design, or funding to support NETs.
This study estimated that the maximum Negative Emissions potential achievable in Scotland in 2030 is 2.2 MtCO2/year (60% of the available biogenic CO2 emissions), based on existing and future potential sites and given technical, economic, and other constraints. This is significantly lower than the stated NETs ambition in the CCPu of 5.7 MtCO2/year by 2032. With additional policy interventions from both the UK and Scottish Governments, the study suggests this figure could potentially reach 6.8 MtCO2/year by 2045 with technologies such as direct air carbon capture and storage (DACCS), bioenergy CCS (BECCS), energy from waste (EfW) and biomethane and distillery sites all playing a role.
As noted in the 2022 and 2023 monitoring reports, it is possible for NETs in Scotland to deliver at scale in due course, assuming that some of the obstacles for deployment are overcome – including high energy pricing, routes to commercialisation and access to storage.
Developments in Monitoring Arrangements Since Last Report:
No changes.
9.2 Part B – Progress to Policy Outcome Indicators
Policy Outcome: Cross-sectoral social and economic
Indicator: Full-time equivalent (FTE) employment in Low Carbon Renewable Energy Economy Indicator
On-Track Assessment (Milestones/Targets): Year to year change
Most Recent Data: 2022
Data Source(s): Low Carbon and Renewable Energy Estimates, Office of National Statistics
Assessment: Too early to say
Commentary:
- In 2022, the Scottish low carbon renewable energy economy (LCREE) sectors were estimated to provide 25,700 FTE jobs.
- The estimates of LCREE are based on a relatively small sample of businesses and hence are subject to a wide confidence interval.
- Scottish LCREE employment in 2022 is lower than in 2021, but the difference is not statistically significant. Caution should be exercised when interpreting year on year changes due to a high degree of uncertainty in estimates.

Source: Office of National Statistics (ONS) Low Carbon and Renewable Energy Economy Estimates
The estimates of LCREE are based on a relatively small sample of businesses and hence are subject to a wide confidence interval. Scottish LCREE employment in 2022 is above the average of previous years but the difference is not statistically significant.
9.3 Part C – Information Implementation of Individual Policies
Outcome 1: Detailed feasibility studies on NETs will assess the opportunities for negative emissions in Scotland, and identify applications with the greatest potential, including specific sites where possible.
Policy: In 2021-22 carry out a detailed feasibility study of opportunities for developing NETs in Scotland ready for the early 2030s. This will identify specific sites and applications of NETs, including developing work to support policy on Direct Air Capture and its role within NETs in our future energy system.
Date announced: CCPu
Progress on implementation since time of last report / CCPu: Studies to build our evidence on NETs and inform the scope of a detailed feasibility study have been commissioned and published within 2021-22. These outputs include research on bioenergy feedstock availability (Available here) and a horizon scan of international deployment of NETs (Available here). A detailed NETs feasibility study was published in November 2023, containing recommendations to government and proposed NETs implementation pathways. A study investigating the cost and profitability of DAC in Scotland will be published in April 2025.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: We will use the suite of research undertaken to inform the next CCP.
Policy: From 2022, based on the outcomes of the feasibility work, we will provide support for commercial partners to develop NETs proposals
Date announced:CCPu
Progress on implementation since time of last report / CCPu: We have continued to build our evidence of NETs feasibility through the detailed feasibility study, and engagement following the conclusion of this work, including with industry. We are engaging with those key stakeholders which have the ability to implement NETs in Scotland to better understand the support that the Scottish Government may be able to offer, and early opportunities for NETs in Scotland.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: We are investigating support measures for commercial partners which support NETs deployment. We will publish research looking at cost and profitability scenarios for Direct Air Capture deployment in Scotland in April 2025. Further research will be undertaken to understand the opportunities of early deployment of NETs to meet carbon demand for utilisation.
Policy: Put in place a continual process to review the development of NETs and progress against its envelope.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: This is assured by internal governance boards.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: Timing and arrangements to be confirmed in the next CCP.
Policy: We will work with UK Government to encourage that they bring forward suitable mechanisms to support the development of NETs business cases in relevant sectors.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: Recognising that many NETs support mechanisms are reserved to the UK Government, we are working with relevant departments, including the Department for Energy Security and Net Zero (DESNZ), to ensure support for prospective NETs developers in Scotland. In particular and following the outcome of the UK Government’s cluster sequencing process in which the Acorn Project was unsuccessful in its bid to secure Track-1 status in October 2021 we have championed the timely deployment of CCS as being essential to enabling development of NETs. Work with the UK has further involved membership of a working group on GGR standards and engaging with relevant consultations, including responding to the Call for Evidence on greenhouse gas removals (GGRs) and the Business model for power bioenergy with carbon capture and storage (Power BECCS) consultation.
The UK Government is expected to bring forward further details on GGR support throughout 2025.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: We will work with UK Government to encourage they bring forward suitable mechanisms to support the development of NETs business cases in relevant sectors, including via the UK ETS.
Outcome 2: CCUS: the continued development of CCUS technologies and systems is prioritised to ensure these can be rolled out commercially and at scale by the late 2020s.
Policy: Support the development of NETs technologies within Scotland.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: CCS is an essential part of NETs, and without a commitment from the UK Government on progressing Acorn via Track 2, it has been particularly difficult to provide any level of certainly to the NETs industry in Scotland. That said, while we wait for UK Government commitment on Acorn, the Scottish Government continues to work with NETs stakeholders to identify opportunities to support the early deployment of NETs including the viability of captured carbon as a commodity.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: N/A
Policy: Support the inclusion of NETs in the development of strategic, industry lead pathways for CCUS infrastructure in Scotland.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: As above.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: N/A
Policy: Funding through the Scottish Industrial Energy Transformation Fund to consider the development of NETs demonstrators.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: The programme continues to deliver and review the number and value of projects supported, projected emissions and energy productivity savings, and consider impacts against policy objectives within public sector financial constraints.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: N/A
Outcome 3: Bioenergy: a cross-sectoral approach for the appropriate and sustainable use of biomass in energy applications is agreed and implemented (taking into account competing land and feedstock uses).
Policy: We will publish a Bioenergy Update in early 2021, laying out our current position and understanding of the role of bioenergy in the energy system and setting out in more detail how we will move forward.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: We published the Bioenergy Update on 24 March 2021.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: None
Policy: In 2021, building on the Bioenergy Update, we will establish a cross sectoral Bioenergy Expert Working Group to consider and identify the most appropriate and sustainable use for bioenergy resources across Scotland. It will also assess the volume of bioenergy resources that we can grow or produce within Scotland and confirm the level of import that we believe is compatible with a sustainable global trade in bioenergy.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: We have published research which forecast the availability of domestic bioresources out until 2045. We will consider the impacts and interactions of increasing biomass production on existing agricultural land. We will publish a draft Bioenergy Policy Statement in advance of the next draft CCP. Following publication, we will establish an expert panel to review policy and suggest routes for developing the bioenergy sector.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: We will establish an expert panel to review policy and suggest routes for developing the bioenergy sector following publication of the draft Bioenergy Policy Statement.
Policy: By 2023, in time to inform the next CCP, we will publish a draft Bioenergy Action Plan, incorporating the learning developed by the expert working group and our understanding of the options to use Bioenergy in both NETs and other applications.
Date announced:CCPu
Progress on implementation since time of last report / CCPu: We published a draft Bioenergy Policy Statement for consultation in March 2024. This draft Policy Statement was developed though a cross-sectoral approach. It was driven forward by a Bioenergy Policy Working Group which brought together officials from across government. The consultation sought views on the principles for use and priority uses for bioenergy; the integration of carbon capture technology for bioenergy plants; and the potential to scale up the domestic biomass supply by planting perennial energy crops. The consultation closed in mid-June 2024 and the responses are currently being analysed. This evidence will be used to inform the development of the final Bioenergy Policy Statement.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these:
- The publication of the analysis report
- the publication of the final Bioenergy Policy Statement
Timeframe and expected next steps: As above [33]
Contact
Email: climatechangeplan@gov.scot