Draft bioenergy policy statement: consultation analysis

Executive summary

The Scottish Government’s public consultation on the ‘Draft Bioenergy Policy Statement’ (BPS) ran from 20 March 2024 to 12 June 2024. In total, 59 consultation responses were received - 41 were from organisations and 18 from individuals. In total, there were 14 open questions and 4 closed questions, where the closed questions also offered a space for further information.

Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct or known interest. This self-selection means the views of respondents do not necessarily represent the views of the entire population.

Overarching themes

A few overarching themes were identified from many responses across the different questions, including the need for strategic policy, rural considerations and better support for anaerobic digestion (AD).

Many commented on the need for policy to be clear with long-term ambitions and targets. Similarly, there was also a call for policy alignment, both internally within the Scottish Government and externally with the UK Government and the European Union.

Another prominent theme was around ensuring bioenergy uses and processes in rural contexts are taken into consideration when developing any new policy. Respondents also urged for policy to be sufficiently flexible to avoid penalising end users in rural areas who already rely upon local and sustainable biomass feedstock.

Many respondents repeatedly expressed the need to better support the AD industry. They called upon Government to remove barriers and develop supportive policy going forward.

Principles for use and priorities uses of bioenergy

There was strong support for the principles for bioenergy use, as set out in the Draft BPS, with some nuances emerging under each principle and requests for additional information to be included.

There was also, to a lesser extent, general support for the priority uses of bioenergy. Whilst many respondents referenced bioenergy with carbon capture and storage (BECCS) across the sectoral priority uses, BECCS also emerged as a theme in its own right. Some respondents also highlighted that long-term uses should build on existing arrangements so that hard-to-decarbonise sectors, including heat and industry, are supported to continue in their decarbonisation efforts. There was also a call for additional details across the priorities.

Bioenergy with carbon capture and storage

Whilst there was agreement with the intention to phase out unabated combustion of biomass, some respondents noted scenarios where this would not be possible and barriers to integrating BECCS technology.

Similarly, there was mixed support on introducing a minimum threshold at which carbon capture should be considered for bioenergy technologies in addition to differing views on which size or configuration of plants should be considered and whether refurbishment of plants should also be included.

In response to setting a date for mandating plants to consider carbon capture technologies, a variety of dates were suggested with most respondents outlining specific challenges that must first be addressed. Most respondents agreed that other decarbonisation options, in addition to carbon capture and storage technology, should be considered as decarbonisation requirements for plants.

Perennial energy crops

The Climate Change Committee (CCC) advised that 700,000 hectares of perennial energy crops (PECs) will be required by 2050. In response to Scotland’s potential contribution to this figure, suggestions ranged from 70,000 – 700,000 hectares, with more support for figures on the lower end of the range. Some additional themes raised were around balancing competing demands for land use and land optimisation.

Many respondents believed that they would be encouraged to use biomass from domestic perennial energy crops (PECs) as a feedstock through financial incentives, value and market certainty, wider environmental benefits and product consistency.

In terms of opportunities and challenges for growing PECs, the most prominent themes identified were environmental considerations, economic and financial considerations and land use.

Generally, best practice examples for integrating PECs and promoting biodiversity that were suggested by respondents related to holistic land approaches, following regenerative farming principles and establishing best practice guidance.