Carbon Calculator for Wind Farms on Scottish Peatland: EIR release

Information requested

1. “Update and Version History –
a) A complete version history of the Calculator, including dates on which any component of the model's methodology or empirical inputs was reviewed, revised, or updated since its original publication. The version currently being provided to applicants as a spreadsheet by the Energy Consents Unit, including its release date.

2. Empirical Input Review –
a) Any internal or commissioned review, audit, or assessment conducted since 2014 examining whether the following inputs remain scientifically current:

• Turbine lifecycle embodied carbon emission factors
• Peat carbon sequestration and fixation rates
• Grid carbon counterfactual methodology
• Back-up capacity emission assumptions
• Forestry and infrastructure emission factors (including concrete foundations)

3. Response to ClimateXChange 2025 Review –
a) Any internal correspondence, briefing notes, action plans, or ministerial submissions produced since January 2025 in response to the ClimateXChange independent review, including any decisions made regarding whether and when to update the Calculator.
b) Any roadmap, programme of work, or commissioned research arising from that review

4. Governance and Oversight –

a) Details of any formal governance structure, named responsible officer(s), or periodic review schedule that has applied to the Calculator since 2014.
b) Any communications between the Scottish Government and SEPA since 2016 regarding the scientific currency or fitness for purpose of the Calculator.

5. Current Use in Planning –
a) Confirmation of whether the Calculator remains a mandatory or recommended tool in planning applications currently processed by the Energy Consents Unit.
b) Any caveats or qualifications the Energy Consents Unit has issued to applicants or planning authorities regarding reliance on the Calculator's outputs pending any update”

Response

As the information you have requested is 'environmental information' for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Response to your request

I shall address each of your points in turn:

Point 1 - The spreadsheet we currently provide to developers is enclosed in Annex A.
The final sheet in this file outlines all changes made to the various versions over the years.

Point 2 - Relevant information is available at the following link, which provides detailed background, supporting analysis, and associated review work: Carbon Calculator for wind farms on Scottish peatlands | ClimateXChange

Point 3 & 4b - Please find enclosed a copy of some of the information you requested, entitled Annex B. While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because:

• An exception under regulation 11(2) of the EIRs (personal information) applies to some of the information.
• An exception under regulation 10(4)(e) of the EIRs (internal communication) applies to some of the information.
• An exception under regulation 10(5)(e) of the EIRs (commercially sensitive) applies to some of the information.
• An exception under regulation 6(1)b of the EIRs (publicly available information) applies as some of the information is already accessible. Relevant material can be found in Peatland Expert Advisory Group minutes: October 2025 - gov.scot

​​​​​​An exception under regulation 11(2) of the EIRs (personal information) applies to some of the information requested because it is personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exception is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exception.

An exception under regulation 10(4)(e) of the EIRs (internal communication) applies to some of the information requested. In this case, the information relates to internal discussions between Ministers and officials concerning energy consenting decisions. There is a greater public interest in preserving the integrity of the decision-making process and ensuring that policies are properly considered and implemented. Disclosure at this stage would risk undermining the Government’s ability to conduct rigorous and candid internal deliberations. Ministers and officials must be able to explore all available options and assess their implications in a protected space, based on the best available advice. If such discussions were routinely disclosed, it could inhibit frank exchanges and compromise the quality of future decisions. This is particularly relevant in statutory consenting processes, where Ministers are required to reach impartial and legally sound decisions following full consultation. Protecting the confidentiality of internal communications in this context supports robust and fair decision-making, which ultimately serves the wider public interest.

Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception.

An exception under regulation 10(5)(e) of the EIRs (confidentiality of commercial or industrial information) applies to some of the information requested because disclosure would or would be likely to prejudice substantially the confidentiality of commercial or industrial information where such confidentiality is provided for by law to protect a legitimate economic interest. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception.

An exception 6(1)(b) of the EIRs (information already available) is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception, as the information is already publicly available.

Point 4a - While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested.

Since 2014, the Carbon Calculator has not operated under a formal governance structure, nor has it had a designated responsible officer or a defined periodic review schedule. Oversight has instead been undertaken by the relevant Scottish Government policy teams responsible for peatland, planning, and energy consenting. These teams have collectively monitored the need for updates and engaged with stakeholders as required. No structured governance framework or scheduled review programme has been in place during the period referenced.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have.

This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in this information, but clearly, we cannot provide information which we do not hold.

Point 5 - The Scottish Government’s Carbon Calculator for wind farm developments on Scottish peatlands was developed in 2008 to support decision‑making on wind farm proposals in Scotland by assessing the site‑specific carbon impact of individual developments. Use of the Calculator is not mandatory, as there is no statutory requirement for its use. Under previous national planning policy (SPP 2014 – Policy 169), impacts on carbon‑rich soils were required to be assessed using the Carbon Calculator. While current NPF4 planning policies do not specify use of the Calculator, NPF4 Policy 5(d)(iii) requires an assessment of the likely net effects of development on climate emissions and carbon loss where proposals are located on peatland, carbon‑rich soils, or priority peatland habitat. In line with this, the Energy Consents Unit continues to require completion of the Carbon Calculator for relevant wind farm applications submitted to Scottish Ministers under the Electricity Act 1989.

No formal guidance has been issued to applicants or planning authorities regarding use of the Calculator pending its review. However, our position with industry and stakeholders has been that, until an updated version is available, the current Calculator should continue to be used, as it remains the best available tool for providing carbon calculations in a consistent and comparable format.​​​​​​​

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

EIR 202600511024 - Information Released - Annex A

File type

Excel document

File size

4.7 MB

EIR 202600511024 - Information Released - Annex B

File type

PDF

File size

5.3 MB