Earlier this year, the Government consulted on its Climate Change Review.  My response is below and I have also provided a link to the consutlation document.

DEFRA consultation document:
Consultation on the review of the UK Climate Change Programme

Response to Review of the UK Climate Change Programme Consultation Paper

by

Lynne Jones MP

February 2005

Recommendations and Supporting Comments

·                     Targets must be legally binding; these should include existing CO2 emissions targets, and such sectoral targets as, for example, on renewable energy and CHP.

·                     There should be a guaranteed annual debate on the findings of the Environmental Audit Committee, which should be charged with auditing the Government’s performance against targets.

Commitments and assurances are insufficient to achieve reductions in greenhouse gas emissions.  Targets must be made a legal duty in order to produce the required policy priority to ensure achievement, and mechanisms must be introduced to ensure that the duty is complied with.

Labour made a specific election manifesto pledge to reduce emissions by 20% by 2010 based on 1990 levels.  This was reinforced by the personal commitment of the Prime Minister.  Table 1 of the review shows that the likely reduction in CO2 levels relative to 1990 levels will be 14% in 2010 and 12.8% by 2020.  This means that not only will the Government not achieve its target of reducing CO2 emissions by 20% by 2010 but it will be even further away from this target in 2020! 

The Government now appears to be backsliding on its commitments in paragraph 2.16, which states that “The government is committed to moving… towards our national goal to reduce UK carbon dioxide emissions by 20 per cent below 1990 levels by 2010.”¹  A projected 12.8% reduction in CO2 emissions by 2020 would clearly not be “real progress… on a path to cut the UK’s CO2 emissions by some 60 per cent by about 2050”. 

Given the long time-scales involved, it is important that future governments continue to prioritise reduction of greenhouse gas emissions.  Legal targets, the avoidance of which would require repeal of an Act of Parliament, would help to bind future governments.  Targets missed in 2010 will enable future governments to claim, quite legitimately, that, as a consequence of this, they are unable to meet targets in 2020 or 2050.

·                    Greater overall clarity is needed in reporting: in particular in identifying overall which sectors are letting down the Climate Change Programme, and how this should be addressed over the long-term to 2050. 

The review includes detailed discussion and questions in some areas whilst skating over others and gives the overriding impression of a review designed to frame the debate.  For example, Tables 3 to 6 give the projected sectoral emissions by source and end-user to 2020, but there is no sense at all of what the Government would like to see overall.    Furthermore, there is simply not enough discussion of how total emissions reductions of 60% by 2050 will be achieved.    This would suggest a need for a much clearer overall strategy. 

Fortuitous special circumstances, such as the restructuring of industry, the liberalization of the energy market and subsequent changes in the choice of fuel used in electricity production from oil and coal to gas, account for about 50 % of emission reductions for all six greenhouse gases while specific policies and measures account for the remaining 50 %.²  If targets can be fortuitously achieved, there is equally a danger that targets can be badly blown off course by other intrinsic factors. This could lead to the loss of support for specific policies from those sectors and industries that are implementing them, often at some considerable cost.  For example, any shortfall in greenhouse gas emissions reductions related to the phasing out of nuclear power must be anticipated by policies which ensure this shortfall is made up from renewable energy sources (see my comments under Section 6 on Energy Supply: Nuclear power).

Similarly, while the emissions from the UK-related share of international air transport are not part of the Kyoto Protocol targets and are therefore left out of the UK CCP Review, their no less real contribution to CO2 emissions (predicted in paragraph 8.20 as likely to be 97% of the 16 to 18MtC attributed to total UK aviation by 2030) will negate the total reductions in CO2 across all other sectors projected for 2020 of -21.2 MtC (shown in Table 5).  This completely undermines the progress made in other sectors.  It is disappointing, therefore, that the Government is giving the go-ahead to the construction of new runways and not considering alternative means of providing for demand for international travel, such as improved rail links.

·                    Policies should be driven by sectoral targets to ensure that the overall strategy is kept on course and an equitable balance maintained;

The Government considers that sectoral targets could take away the flexibility to pursue the most cost-effective overall mix of policies and measures.  However, they would help to ensure that measures to reduce greenhouse gas emissions are balanced equitably across sectors and activities, and perceived to be so.  Transport, the second largest source of UK end-user emissions (paragraph 8.1), is a gaping hole in the Government’s strategy.    Two-thirds of people now understand that transport emissions are a major factor contributing to climate change (Source: Department for Transport – Transport Trends 2002), and yet the Government appears to be running scared of tackling the problem (see my comments under Section 8 on Transport).

• Climate Change policies should be implemented in the context of wider sustainability.

• More should be done to promote small-scale projects and embedded micro-power systems to generate renewable energy.  

• The Government should set a new target for 10% of all household electricity end-use to be self-generated by 2010.³

Nuclear power. Carbon dioxide projections (paragraph 3.11) “embody a steady rundown in nuclear output - falling from 82 TWh in 2003, to 65 TWh in 2010 and 27 TWh in 2020 – as existing stations reach the end of their lives”.  However, in this section, instead of advocating proactive policies to anticipate the rundown of nuclear output and lead-times for putting in place alternatives to enable emission reduction goals to be met, paragraph 6.31 conveys the distinct impression that nuclear power may have to be re-introduced by default, as a ‘fire-fighting’ measure to rescue targets!    I am strongly in favour of phasing out nuclear power because the production of nuclear waste is not sustainable and, if we are to achieve ‘joined-up thinking’, I think it is important to put forward policies for mitigating climate change in the context of overall sustainability

Renewable energy.  The Government’s commitment to 10% renewable energy by 2010 and 20% by 2020 is welcome, but must be part of a portfolio of strategies to mitigate climate change.   As a recent German Government Energy Agency report has highlighted, making houses more energy efficient is the most cost-efficient method of reducing CO2 emissions.

With regard to onshore wind power projects, financial incentives and planning policies should be weighted towards embedded microgeneration (see below) and smaller-scale, community-based projects, where the turbines are integrated, in small groups, preferably on brownfield sites.  Communities and not just landowners must benefit from planning consents for wind turbines and industrial-scale onshore farms should not be permitted in the UK’s last remaining wilderness areas, sensitive landscape areas, or where they could adversely affect SSSIs and EU Natura 2000 sites.   The Government needs to invest in marine transmission lines for the long-distance transmission of renewable power, and not in new overland routes.

I am concerned that the guidance of the Draft Planning Policy Statement 22: Renewable Energy - Key Principle 4 says that the wider environmental and economic benefits of renewable energy generation proposals should be given “significant weight”, but does not provide clear guidance on the weight that should be given to other issues, such as other environmental issues, that may conflict with such proposals.   Key Principle 6 emphasises the need for community involvement in the process, but does not acknowledge that local communities may have legitimate concerns about the impact of proposals on their local environment and amenity, which should be taken seriously.  There is no reference to Scheduled Ancient Monuments or other nationally important archaeological remains; and there is insufficient guidance on how to deal with renewable energy developments in areas covered by Local Designations for conservation.

Micropower systems.  I would like to see much greater emphasis placed on encouraging the use of micro-power systems, including micro-CHP, small wind turbines, photovoltaic systems and ground source heat pumps, in both domestic and commercial premises.   

I am very concerned at the DTI’s decision to end the Government’s 2002-2012 solar PV demonstration programme prematurely in March 2006; that grant allocations are ending this summer for domestic and other small installations, and this November for large-scale installations.  This decision goes against the Energy White Paper commitment, and comes at a critical time in the development of the UK’s fledgling industry.  Solar PV prices have fallen by an average 30% since the start of the programme.   Photovoltaics can make a significant contribution to the Government’s medium term renewables and energy efficiency targets, but the uncertainly over the 2002-2012 programme is now undermining investment. 

PPGuidance 22 specifically excludes Combined Heat and Power (CHP), a serious omission, given the contribution that CHP can make towards renewable energy supply. 

A Government target for 10% of all household electricity end-use to be self-generated by 2010 would help to create the right conditions for investment in micropower systems, and ensure that all Government departments pull together.

·                     Fiscal incentives and regulations to improve energy efficiency should be extended to the commercial sector.

Energy use in the commercial and services’ sector has increased by nearly 70% over the last 30 years (paragraph 7.4).   This needs to be addressed: 

(Q 23)

• The requirement for public sector buildings to display an energy performance certificate should also apply to the commercial sector.

(Q25)

• The interest free loan scheme for SMEs that install energy efficiency measures should no longer be cash-limited in England & Wales

·                     Non-CO2 greenhouse gases should also be included in the EU Emissions Trading System. 

The Government is right to be concerned about the upward trend in emissions of Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulphur hexafluoride (SF6). Sulphur hexafluoride is of particular concern in view of its very high 100-year global warming potential and the increase in SF6 emissions in the UK of over 50% in the period 1990 to 2002 (UN greenhouse gas emissions figures⁴), and the general perception of its industrial usefulness. The EU Emissions Trading System could be the most effective way to control emissions of these gases. 

·                     The Government must ensure that Transport makes its full contribution to reductions in greenhouse gas emissions.

·                     The Government should enable properly-planned and attractively-priced public transport networks.

In an entire chapter (8) on the Transport sector, there is not a single mention of the words “public transport” or “rail” (albeit public transport gets a mention in the Executive Summary).  Under “Transport strategy” (paragraph 8.3), there is simply a bland statement to the effect that the Government’s transport strategy, set out in the 2003 White Paper⁵ ; makes clear that “we must balance the increasing demand for travel against our goal of protecting the environment effectively”.  However, the White Paper makes no proposal of what mix of transport it would like to see to ensure that Transport makes its full contribution to reducing CO2 emissions. For example, there is no target for growth of the rail network.  While the White Paper contains many positive themes, these are not being implemented at anything like an adequate pace in the context of Climate Change mitigation.

Road traffic and aviation are the fastest growing sources of climate change gasses; CO2 emissions from road transport are projected to grow by 19% by 2020 (paragraph 8.2), and yet, for example, the only fiscal measures (paragraph 8.7) introduced are all intra-car sector specific.  There are presented no policy measures specifically to encourage the public to cut their use of cars and aviation and to promote instead the use of rail and other public transport or cycling and walking.⁶  A possible exception is road-pricing (paragraph 8.18) and I welcome the statement that “the time has come to consider the role that could be played by some form of road pricing policy”.  Greater progress could have been made in developing a serious road pricing policy by now and it is urgent that the Government  really grasps the nettle on this issue.  Interestingly under Action in Scotland, Transport, the Review states a commitment to promoting public transport, and rail over road, among key measures to reduce greenhouse gas emissions (13.14-13.15).  Why only in Scotland?

While the Government concedes (paragraph 8.5) that the UK is not currently on track to meet the EU-wide new car fuel efficiency target of 140 g/km for 2008, there is no mention of the relative environmental friendliness of various modes of transport in terms of carbon emissions, thereby avoiding the logical conclusion that policies should reflect these modes’ relative contributions to climate change⁷.  Given the example of European cities and towns, it is very disappointing that, at both government and local authority level, there is little attempt to tap the potential of cycling - another policy area where Government targets have not been achieved. 

The Review trumpets the promotion of innovation and technology in mitigating Climate Change, but appears to be entirely blinkered in its view of where technological innovation can take place, restricting its discussion to road fuels.  Rail is already the least environmentally damaging form of powered transport.   Further work needs to be done on electrification and development of hydrogen fuel-cell power plants.

Policies should take account of the needs of people in rural areas, particularly, for example, if surface transport was to be included in the European Union Emissions Trading Scheme: Where attractive alternatives are not available, it is not acceptable simply to make car transport unaffordable for some people.  Cross subsidy from income from road pricing could help provide attractive and affordable alternatives to road transport.

As Transport 2000 have said, the Government cannot claim to be serious about tackling climate change until it looks openly and honestly at transport in the UK.  

The Government’s active pursuit of the inclusion of intra-EU aviation in the EU Emissions Trading System and intention to make this a priority for the UK Presidency of the EU in 2005 is very welcome.

Q 35-37

·                     Further fiscal incentives should be used to encourage householders and landlords to invest in energy conservation;

·                     Greater emphasis should be given to public education; the public needs to be part of the Climate Change Programme.

While welcoming the initiatives in the area of households, I would like to see more done to encourage energy conservation efforts by householders and by landlords, for the following reasons:

• Households are responsible for about 30% of total UK energy use (paragraph 9.1).  70% of householders are owner-occupiers, most of whom are not in fuel poverty;

• Social learning should not be neglected: it is important that the general public identifies with and morally buys in to energy conservation in order to reduce greenhouse gasses.

Therefore, I would like to see further fiscal incentives introduced, such as:

• Mortgage interest relief on investment in creating sustainable homes

• An extension of the 5% reduced VAT rate to other energy-saving products, such as A-rated windows, A- and B-rated condensing boilers, low energy lighting and DIY energy efficient material.

The guidance of the Draft Planning Policy Statement 22: Renewable Energy does not refer to the importance of energy reduction and energy efficiency measures, even though these are an important strand in the Energy White Paper.  This is a serious omission, given that more efficient use of existing energy sources, whether renewable or not, can make a significant contribution towards reducing carbon dioxide emissions.  My own (Birmingham) City Council’s policies seek to encourage developers to design buildings to maximise solar gain and to use low energy systems but local authorities need national backing in this aim.

·                     A Stamp-Duty rebate for the installation of energy saving products at the time of home purchase.

·                     Explicit planning guidance which gives weight to the benefits of building designs which incorporate energy generation, for example, photovoltaics, wind turbines, and other embedded systems, and efficiency systems.

·                     The Government should provide sufficient investment ito bring all social housing up to SAP 65, where it is practicable to do so.

The Office of the Deputy Prime Minister estimates that it would cost £8.5 billion to bring up to SAP 65 all social housing for which that level of thermal efficiency is achievable by means of improvement works.  To demolish and rebuild the social sector homes that could not otherwise be brought up to SAP 65 would cost an estimated additional £20 billion. (Answer to Parliamentary Question 216476.)

Where it is not practicable to bring social sector homes up to SAP 65, corresponding reductions in CO2 emissions should be achieved by investment in renewable energy.

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