Bioenergy in Scotland – Scottish Government’s Draft Policy Statement focusses on sustainability and resilience



The Scottish Government (“SG”) has launched a consultation on its draft Bioenergy Policy (the “SG Bioenergy Policy”), with responses to be submitted by 12th June 2024. This article provides a brief overview of the SG Bioenergy Policy’s main features and how it compares with its counterpart, the “Biomass Policy Statement” which was published by the UK Government in November 2021, subsequently laying the foundation for the Biomass Strategy released in 2023.


The draft SG Bioenergy Policy sets out the role SG envisages bioenergy playing in the journey to reaching net zero by 2045, from a short-, medium- and long-term perspective. 

Bioenergy is a form of renewable energy that is derived from biomass (plants and algae-based material) which can be used to produce electricity, heat and transportation fuels, as well as other products. Bioenergy is already a key component of Scotland’s energy system.  The SG Bioenergy Policy looks to enhance what could be an invaluable resource by recognising its flexibility, and, acknowledging that bioenergy can contribute to a more circular economy by turning waste into a valuable resource such as electricity or heat and, arguably the most important, having the ability to act as a replacement for fossil fuels.  When coupled with other advancing schemes and technologies, such as Carbon Capture and Storage Technologies, the use of bioenergy has the potential to significantly assist with the reduction of emissions across the economy.

Principles and Priorities


SG has identified the following principles which should underpin the use of bioenergy in Scotland.  These principles essentially mirror those which have been published by the UK Government as part of its Biomass Strategy: 

  • The use of biomass must comply with stringent sustainability criteria.
  • The use of biomass must comply with the principles of a circular bioeconomy and a cascading use of biomass – reuse and recycling of wood should be sought before its use in bioenergy applications.
  • The use of biomass must support Scotland’s ambitions of emissions reduction reaching net-zero.
  • The use of biomass must comply with all environmental regulations which have been set out by the Scottish Environment Protection Agency.
  • The use of biomass feedstock production and use of bioenergy technologies should align with and contribute towards Scotland’s sustainable development goals which include Scotland being a world leader in affordable and clean energy.


The SG Bioenergy Policy also outlines what the SG view as the short-, medium- and long-term priorities of the use of bioenergy in Scotland.  Such priorities, like the principles, align with what was highlighted as important by the UK Government in its Bioenergy Strategy.

  • It is recognised that in the short term there will continue to be high demand and continued use of bioenergy and biomass in the power, heat and transport sectors.   Where possible early adoption of Carbon Capture Utilisation and Storage paired with bioenergy applications will be supported.
  • In the medium-term, the use of bioenergy should start to move away from unabated uses of biomass and, if possible, to other uses including Bioenergy with Carbon Capture and Storage (“BECCS”). 
  • In the longer-term, BECCS is expected to play a key role in the journey to, and achieving, net zero.  The SG Bioenergy Policy acknowledges that the use of BECCS will not be appropriate in every sector.

Bioenergy Supply and Production

The SG Bioenergy Policy focuses on the sustainability of biomass and the competition for supply.  It recognises the initiatives by various countries, through incentives and subsidies to support bioenergy technologies, which together with commitments to reduce emissions are likely to increase global demand for sustainable biomass, pushing prices up.  The war in Ukraine (from where a significant volume of biomass pellets was previously imported) underlines the need to ensure resilience and diversification in the energy system. 

The SG Bioenergy Policy emphasises the need for development of a stable and sustainable domestic supply of biomass. It also considers the potential use of perennial energy crops in the supply and production of bioenergy in Scotland.

SG commissioned a report in 2020 into perennial energy crops and their potential in Scotland. The SG Bioenergy Policy explores this further, outlining a number of actions which must be taken before such initiative could be adopted highlighting the need to balance sustainable production of domestic biomass with Scotland’s land use policy, agricultural policy and biodiversity strategy.

Scottish Government policy compared to UK Government policy

The draft Scottish Bioenergy Policy Statement is similar in content and approach to that of the Biomass Policy Statement, released by the UK Government in 2021 and the subsequent UK Bioenergy Strategy of 2023.  Such policies align in their priorities and approach. The policies are particularly aligned in recognising the value that Carbon Capture Technologies can bring in the journey to net-zero.


Whilst the SG Bioenergy Policy is closely aligned to the Biomass Policy Statement released by the UK Government in 2021, current world affairs have brought the resilience and security of supply of bioenergy feedstock into sharp relief.  A careful balancing act between the desire to encourage the use of bioenergy and the implications for a resilient and certain domestic supply chain for production and processing of feedstock with land use, agricultural and environmental policy objectives will be required.

The consultation closes on 12th June 2024.  You can respond to the consultation here: Draft Bioenergy Policy Statement: Consultation - Scottish Government consultations - Citizen Space

Article co-authored by Katie Timmins, Trainee Solicitor at CMS.