Our response to the Scottish Government energy consultation

This is our response to the Scottish Government’s consultation on a draft energy plan. The deadline for the consultation is 9th May 2023.

Response to the energy consultation from Scot.E3

Scot.E3 campaigns for a worker led just transition that would require at least 100,000 new climate jobs in Scotland.  In our view the draft plan contains material that is useful and will be necessary as part of the energy transition that is needed. We particularly welcome the draft plan’s suggestion that the Scottish Government should not support any further exploration or development of oil and gas fields – this is vital and needs to be followed through. But overall, the draft plan aims for too little and too slowly, and it fails to provide a coherent strategy to reduce emissions and reshape the Scottish economy.

The plan is flawed in several fundamental ways:

  1. It relies on the private sector to a achieve its ambitions.
  2. It follows the strategy outlined in Offshore UK’s North Sea Transition deal which aims for net zero emissions achieved through the large-scale implementation of carbon capture and storage.
  3. It accepts the hype around hydrogen uncritically.
  4. Mass scale retrofitting and decarbonising domestic heating and cooking is not given enough priority.
  5. There is no clear plan for expanding public transport systems.
  6. There is no strategy for creating a resilient smart energy grid that would integrate local community energy initiatives with large scale wind, tidal, hydro, and solar.
  7. It accepts the concept of net zero when we the climate science tells us we should be aiming for real zero.
  8. It fails to consider how a national energy company (Scottish Climate Service) could drive forward a strategy for zero emissions and harness the skills and creativity of the energy sector’s current workforce or the many thousands of young people who are required to make a sustainable energy sector a reality.


Points 1 and 8.  Public versus private.  As a campaign Scot.E3 believes that the oil and gas industry aim to extract the maximum profit from its existing business and to maintain the power and influence which it established through the 20th century and into the 21st.  The infrastructure and practices of what Andreas Malm calls Fossil Capital are incompatible with a sustainable renewable economy.  We understand that not everyone would agree with this analysis.  However, the scale and scope of the economic transition that is required is unprecedented.  The nearest comparisons – transitions to war economies in the UK and the US between 1939 and 1945, and the US New Deal in the 1930’s, depended on strategic planning, public control and high degrees of regulation over the private sector.   The Scottish government’s objectives for a just transition can only be met by a much higher level of public investment, democratic control, and regulation than the energy plan proposes.

Points 2 and 3.  Rejecting the false solutions contained in the North Sea Transition Deal. In brief the North Sea transition deal (written by the oil and gas industry and endorsed by Holyrood, Westminster, and the Offshore trade unions) is a plan to maintain oil and gas production from the North Sea for as long as possible, and certainly beyond 2050.   Carbon capture and a hydrogen economy are central to the plan.  There is place for carbon capture when we’ve ended fossil fuel emissions and can focus on repairing the damage created by global temperature rise.  And there is a place for hydrogen as a fuel in a small number of important but specialised applications.  However, the energy plan’s proposals for prioritising carbon capture, and for making Scotland a world leader in hydrogen production, direct the focus of the plan away from the necessary investment into decarbonising energy production and use right now, and make it much more difficult to achieve the energy transition that we need.  Carbon capture at large scale is an unproven technology, while producing green hydrogen is highly inefficient and requires very large amounts of green electricity.  A recent report, The Future of Home Heating by the Imperial College Energy Futures Lab notes that ‘Hydrogen production would be best used strategically and its deployment prioritised in sectors which are hard to electrify or decarbonise such as heavy industry, shipping, aviation and heavy transport.’ 

Point 4. Retrofitting.  Energy for domestic heating and cooking in Scotland is mainly supplied via the natural gas network and currently accounts for more than 20% of emissions.  The level of emissions could be significantly reduced through improving standards of insulation.  Action on building regulations for new builds is possible straight away and amendments to guidance and regulations for the insulation of the existing housing stock to include the new breathable insulation materials that are now available (for example the hemp based materials produced in the Scottish Borders) could also be made very rapidly.  A mass campaign of retrofitting requires coordinated action and investment that involves the development of skilled direct works teams in every council area and the resourcing of Further Education Colleges to provide good quality training.   At the same time the transition from gas to electricity needs to be coordinated with the timescale for the rundown of North Sea gas production.  Retrofitting creates new jobs and has the potential to enhance the health and well-being of the Scottish population.  Action now, with investment designed to ensure that no one is excluded is a critical part of a just transition and can win hearts and minds to the project of transforming the economy.

Point 5. Public Transport.  Simply replacing petrol and diesel vehicles by electric vehicles will not remove all emissions, will increase demand for scarce and environmentally damaging resources and perpetuate inequality.  A sustainable energy plan requires large-scale improvements in public transport networks. 

Point 6.  Developing a smart grid.  This is a surprising omission from the draft plan.  A smart grid that includes large scale wind, solar, hydro and tidal energy sources combined with a network of community-based energy schemes and storage that includes local district heating schemes is technically feasible and would ensure that the system is resilient in the face of varying climatic conditions and demand.

Point 7. Net Zero.  In practice net zero has become part of the set of false solutions used by the fossil fuel industries to delay real action on emissions.  It is bound up with arguments for carbon capture and carbon offsetting.  The latter has done almost nothing to actually reduce emissions (see for example Dyke, Watson and Knorr – ‘Climate Scientists: Net Zero is a dangerous trap) and often creates social problems in the private takeover of land for monoculture forests or other crops.  We would argue that an effective energy plan requires a critical position on net zero and setting the objective as absolute zero emissions.  The only way to achieve real zero in the context of the climate emergency is to phase out oil and gas quickly, starting now, and to invest heavily in renewable sources of energy. 

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