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. 

Save Loch Lomond – open letter

In this post Scot.E3 activist Ann Morgan shares the letter she has written to Fiona Hyslop, Cabinet Secretary for Economy, Fair work and Culture. Add your voices to Ann’s.

Loch Lomond by Pete Cannell CC0

Dear Fiona Hyslop, 

I have lived in West Dunbartonshire mostly all my life (I am now retired and live in Govan) and retain links with family, friends and community organisations. I have followed and participated in the Save Loch Lomond campaign.  The campaign currently highlights the possibility of a planning application by Lomond Banks, subsidiary of Flamingo Land and the extension of the exclusivity agreement, effectively excluding alternative community led proposals for the site and for job creation. 

I wish to comment both on the ecological impact on the site and provide examples of sustainable climate jobs.

I do so as a participant in SCOT.E3 (Employment, Energy, Environment) and as a member of Unite the Union (retired members). I am active in a number of local community projects including food -growing and provision and I am keen to share the successes of initiatives with other communities, including the Leamy Foundation /Growing West Dunbartonshire Project. I am not commenting on behalf of these agencies but draw on my research and activism within them to outline objections and alternatives to the proposed developments at the lochside.

The Scottish Government declared a Climate Emergency in April 2019. Emissions reductions targets include reductions of 70% by 2030.  This declaration must be followed by action.

Allan McQuade of Scottish Enterprise, in reference to the proposal, talks of sustainability and syas that the fight against climate change as ‘central to everything we do.’

Action must be two-fold, Protective and proactive.

Protection around biodiversity is of paramount importance. The State of Nature Report (a collaboration between conservation and research organisations) reported in 2019.The report contains the best available data on Scotland’s biodiversity.  Key findings show 49% of species have decreases in abundance with 11% threatened with extinction.  The First Minister in response states that Scotland must lead the way in facing the challenges to biodiversity.

With the above in mind, I request that the cabinet minister considers the impact on biodiversity on the National Park environment. Specifically, on the impact on Drumkinnin Woods within the West Riverside site. This is erroneously referred to as a Brownfield Site.  It is part of the National Park.  The stated aim of the designated Loch Lomond and the Trossachs National Park is to conserve and enhance the natural and cultural heritage of the area.

The proposed development is at odds with the Scottish Government and National Park aims.  The ecological impact would 

  • Endanger wildlife-insects, birds, trees and water species.  Woodlands and rivers are especially vulnerable.
  • The impacts arise from noise, light, traffic emissions and increased pollution. 
  • The above are exacerbated when there is a high concentration of visitors in the one area.  Sustainable Tourism encourages movement, public transport use with rover tickets and electric people carrier hire.  Single car use and enabling by large car parking space must be disincentivised.

The FM also describes in the annual Programme for Government that it is a key aim of the Scottish Government to empower communities.  The retention of the exclusivity agreement contradicts this aim.  Under the Nature Conservation (Scotland)Act 2004 public bodies in Scotland have a duty to further conservation in biodiversity.

My involvement with Scot.E3 has given me insight into the potential for Climate Jobs (see 1 million Jobs pamphlet).  Specific to Scotland a just transition could include advancing regional specific renewables energy, district heating and a programme of retro fitting and new build housing and public building with apprenticeship skills in insulation, joinery, roofing, glazing and heating, linking with schools and further education. My perspective, shared with environmental groups, is that this type of job creation is both more sustainable and career focused than many jobs in the hospitality sector, often minimum waged or even zero hours contracts and seasonal. That said, there are ways to encourage sustainable and responsible tourism with quality training for those seeking careers in the tourism.  It is of concern that the original proposal carried none of these assurances.  Any development with employment opportunities must adhere to the principles outlined in the Fair Work Convention.

Finally, the experience of the pandemic has greatly impacted on local and global tourism. There are scientists, ecologists, biologists, economists and epidemiologists (David Attenborough included) who are warning of future pandemics, with potential of more virulent strains. The current variant is concerning with increased contagion /transmission.

Rob Wallace, evolutionary biologist, charts the link between habitat destruction, biodiversity loss and the increase in zoonotic transmission of infection.  Again, this points to the important of biodiversity protection.  Tourism is of course both impacted by and causal in transmission.  Therefore, a rethink on safety in travel and transit will be required for tourist dependent development.  Linked with emission reduction this presents as an opportunity to put environmental protection as Allan McQuade asserts, central in Scottish Enterprise approval.

The fragility of tourism as well as its importance to the Scottish Economy is recognised. Within this perspective, social justice with environmental integrity is required. 

Yours sincerely 

Annie Morgan 

Action notes and an appeal for help

The minutes and action points from our March organising meeting are now available for viewing or download.

There were two particular actions that we would really appreciate your help with.

We have taken out a subscription to the Zoom online conferencing platform and we plan to hold regular online public events. Please email suggestions for topics and for speakers to triple.e.scot@gmail.com.  If you would like to offer to do a presentation yourself do let us know.  We’re aware that online meetings may be a new experience for some people or you may not be familiar with Zoom. There is a now a simple guide to accessing Zoom meetings on this site.

We have five new briefings in production

  • The role of Hydrogen in a sustainable economy
  • Organising at work
  • The COPs and COP 26 – a guide
  • Is nuclear part of a sustainable solution?
  • Decarbonising Transport.

If you know of good resources on any of these topics and can share links or references that would be really helpful.  Our aim when we produce briefings is to develop a concise summary of the issues on 2 sides of A4 with links to further readings and resources via the website.  If you’ve an interest in one or more of the topics and would like to link up with 2 or three others to help write the briefing and collate the web links do let us know. You can just email us at triple.e.scot@gmail.com

Finally if you have ideas for other topics that would work in the briefing format or for updates to existing briefings do get in touch.


Towards Net Zero?

On the 7th February 2019 Edinburgh City Council resolved to declare a climate emergency. On the 25th October Edinburgh City Council’s Policy and Sustainability met to consider a draft report from the Place-Based Climate Action Network (P-CAN) research project on Achieving Net Zero in the City of Edinburgh. The report will form the basis for discussion of an action plan at the February 2020 meeting of the committee.

In this post Pete Cannell gives a personal response to the report. We hope to publish further contributions on this important topic and we welcome comments, responses to the questions he poses and further contributions.

It’s important and encouraging that, in response to pressure from the School Student strikers, XR and the wider movement, Edinburgh City Council is set to discus actions to reduce carbon emissions. This post takes a critical look at the report that forms the basis for the council’s discussions.

‘Achieving Net Zero in the City of Edinburgh’ is a technical report that summarises research undertaken by the Edinburgh Centre for Carbon Innovation (ECCI), drawing on expertise from the University of Edinburgh and the University of Leeds. Net zero means that carbon emissions from activity in Edinburgh are balanced by an equal amount of carbon being removed from the atmosphere. The net zero target applies to emissions from within the local authority boundaries. Critically, however, some emissions, most notably those from aviation are not included.

The cost-benefit analysis used by the research team is based on the same methodology that was used in the Stern Review on the Economics of Climate Change that was published in 2006.

The report notes that Edinburgh’s baseline emissions have declined by 40.3% since 2001. This reduction is almost entirely a result of changes in the way that Scotland’s electricity is generated with coal fired power stations closing down and replacement by renewables – primarily wind. Renewables are now such an important part of the grid that there is little scope for further reduction from this source.

The report models three scenarios for how much energy use and emissions could be reduced by 2030:

1. A 56% reduction in carbon emissions as a result of ‘cost effective’ investments amounting to £3.976 billion over the next 11 years. The savings resulting from these investments would repay the investment in 7.5 years and continue to generate savings thereafter.

2. A 62% reduction as a result of ‘cost neutral’ investments of £7.492 billion over the 11 years to 2030 that would be paid back in savings over 12.5 years.

3. A 67% reduction exploiting the full technical potential of the different mitigation measures proposed. This is estimated to require investment of at least £8.135 billion with the cost neutral pay back extending to 16.1 years.

The figures aggregate emission reduction strategies across multiple sectors – commercial, transport, domestic and industrial and the report provides some detailed proposals for the kinds of investment that needs to be made in each of these.

The report is honest about the scale of the technical and investment challenge but confines consideration of politics and strategy to the observation that:

Whilst the opportunities outlined here are all feasible and ‘win-wins’ for stakeholder groups across the city, they will require near-immediate and unequivocal support from institutions and the public.

Will the City Council’s action plan be framed in a way that faces up to the urgency of the crisis and wins unequivocal support? And will it address the gap between the reductions proposed in the report and net zero? Climate campaigners have a critical role to play here. We have a responsibility to build a movement embedded in working class communities across the city that is active, restless, rebellious and probes, questions and criticizes at every stage and every step. And we need to develop a collective understanding of how actions to reduce emissions and the unequivocal support of the mass of the population are achieved and built through democratic engagement and a focus on social justice.

There are a host of questions that we need to address. In the hope of starting a debate I’ll mention just a few!

The activities of the city council are responsible for only a small percentage of Edinburgh’s emissions. So how does an effective action plan ensure that the investment into emissions reductions envisaged by ‘Towards Net Zero’ take place across all areas of energy consumption? How does a council action plan leverage action across the whole city? Clearly there’s a role for regulation – for example imposing building regulations that mandate carbon neutral new builds. There’s also a case for investment in large-scale public initiatives – for example building insulation.

‘Towards Net Zero’ focuses on a cost benefit approach together with the implementation of existing low carbon technologies – and holds out the promise that in future emerging technologies will bridge the gap to net zero. Is this an appropriate methodology in the face of an existential crisis? Can it actually work? It’s not business as usual but it suggests that conventional methods together with technology can achieve net zero. So is net zero achievable without system change? And if it’s not, what does system change look like?

Treating carbon reduction as an issue about investment and technology may also hide real issues of policy. So for example business and tourism planning in Edinburgh have both had huge impact on how and where we live, the distances we travel to work and how we travel. As Edinburgh’s workforce is pushed further outside the city boundaries to find affordable accommodation the carbon footprint of our daily working lives has grown. But the ‘Towards Net Zero’ effectively excludes these issues, as it does the massive rise in aviation emissions, which are so strongly linked to current planning priorities. So while we can commend the City Council’s steps towards an action plan there is a powerful case for integrated planning across the region and for new policy frameworks for housing, health, work, transport and tourism that centre on zero carbon and social justice.

2018-07-04 12.45.17

Image: Pete Cannell, CC0

There is an opportunity to discuss the issues raised in this post at the  Scot.E3 conference that takes place on 16th November.  Book for the conference on Eventbrite and email triple.e.scot@gmail.com if you want to book one or more crèche places.


An Energy Policy Consultation paper – A shock to the system – the case for a publicly owned and democratically accountable Scottish energy company

In 2014 the Scottish government initiated an energy policy review. The purpose of this review was to examine the present state of Scotland’s energy economy and consider future options in the light of both a looming climate crisis and also the optimum strategy for replacing ageing fossil fuel and nuclear generating capacity with a range of renewable technologies.

In 2017 in order to ensure employment and fuel poverty issues were taken into account in this review, an infant SCOT.E3 decided to submit its own paper in an attempt to ensure that a full spectrum of related energy and environmental issues were incorporated into a memorandum of evidence.

Yet five years on and despite an almost universal acknowledgement of an accelerating climate crisis, little has been done- in practical terms- to address an impending environmental disaster and its related social and economic consequences. Also, within the intervening period, we have seen the commercial collapse of the BiFab renewable power technology company at Burntisland as well as the continued interest of the petro-chemical company Ineos in activating its shale gas fracking options to the point that it will feel confident to test the validity of the current Scottish governments ‘anti-fracking’ moratorium.

So it is against this present uncertainty that SCOT.E3 is now initiating another energy policy review to which it invites all interested parties to participate. The aim of this exercise is to re-examine the range of issues needed to be addressed; a renewable energy economy and the availability of appropriate technologies, the issue of fuel poverty and affordability of energy, energy efficiency, energy related employment and just transition possibilities regarding current energy and defence related employment, improvement of housing stock and carbon neutral public transport systems- to name but a few.

And as can be seen from the attached paper, SCOT.E3 have made a start in outlining the historical record of electricity generation and supply in Scotland in order to reinforce the case for a major stage in meeting Scotland’s forthcoming energy and environmental needs- a long promised Scottish state owned energy company.

We are therefore inviting you to participate in this exercise by adding your comments and/or contributions under the section headings so far left blank. This is to ensure that any report fully takes into account the range of opinions that truly reflect the technical and scientific know-how- as well as the concerns of environmental, community and trade union campaigns and interests engaged in these vital and urgent issues.

In order to ensure that this exercise is properly democratic, it is our intention to hold a consultative meeting for all consultees in the near future, as well as a major workshop type conference in the autumn.

We hope that you find the introductory notes both useful and of interest and we look forward to hearing from you in the near future. For any further information please contact:

SCOT.E3 at www.scote3.wordpress.com, email triple.e.scot@gmail.com