APPENDIX 26
Memorandum from WWF-UK
SUMMARY
Although WWF is delighted by the
long term aspirations and key solutions identified in the White
Paper, we are concerned that policy commitment is not clearly
demonstrated. The Government's vision of a 60% reduction in carbon
dioxide emissions by 2050 is particularly commendable, but now
the Government needs to increase policy and action to bring about
the changes that can make it happen. For the excellent ambitions
of the Government to be met, the White Paper should have made
clear the incentives for business and the public to bring about
such changes.
The White Paper fails in three main
ways to ensure that its vision for a lower carbon economy will
be met:
First, the Government fails to commit
itself to any interim targets. Instead, it states that it has
"ambitions" regarding CO2 emissions reductions and an
aspiration for 20% of electricity to be generated from renewable
energy by 2020.
Second, the White Paper postpones
many decisions necessary for defining a clear framework for increasing
the use of renewable energy and CHP in the economy, and does not
establish the high profile, integrated strategy necessary for
taking forward these sustainable energy technologies.
Third, although the White Paper highlights
energy efficiency as a key component of achieving emission reductions,
it fails to set the basis for a high priority energy efficiency
drive. It sets no targets, and merely states that reductions of
10-12 MtC annually could be achieved by 2020.
We are also concerned that since
the Government has not ruled out nuclear energy for the future
and its policy to develop energy efficiency and renewable energy
is insufficient, there may be investment in nuclear energy in
the future. Keeping the "nuclear option open" for the
future should not mean that Government adopts a half-hearted approach
to renewable energy and energy efficiency.
ENERGY EFFICIENCY
WWF is concerned that the White Paper
fails to take forward some of the sensible suggestions in the
PIU Energy Review. Most of these will be essential to delivering
the aspirations of the White Paper. For example, the PIU report
recommended that the Government develop a Strategy for Home Energy
Efficiency that sets out a clear, long-term coordinated framework
for delivering a 20% energy efficiency target. The White Paper
has not officially adopted the target and does not mention any
intention to develop a Home Energy Efficiency Strategy. The Government's
current rather sparse and disparate energy efficiency policies
will not deliver the "step-change" in energy efficiency
that the White Paper calls for.
The White Paper states the Government's
intentions to ". . . raise (building) standards over the
next decade, learning lessons from the standards achieved in other
comparable European countries". And "we will start work
immediately on the next major revision of the building regulations,
which we will aim to bring into effect in 2005."
What level of energy efficiency standard
is the Government thinking of? After the last Building Regulations
review many efficiency experts were very disappointed with the
outcomeeven if it did lead to significant improvements
compared to the very poor previous standards.
WWF's Sustainable Homes campaign
calls for housing standards to be substantially improved to the
Eco-Homes "Very Good" or "Excellent" standard
and we would hope that Government aims for minimum energy efficiency
standards compatible with this in its next review of the building
regulations. A new home built to EcoHomes "Very Good"
standard represents an average CO2 saving of 26%, or nearly one
tonne, each year over a typical new house built to 2002 building
regulations[50]
The "2020 vision" outlined
in the introductory chapter to the White Paper states that "New
homes will be designed to need very little energy and will perhaps
even achieve zero carbon emissions". However, the White Paper
does not make it clear whether the Government is committed to
this visionand so it is not clear whether the Government
will aim for highly energy efficient or zero carbon homes. The
White Paper does not outline solid plans for developing a strategy
for delivering highly energy efficient or zero-carbon homes.
Cross-government consistencyWWF
was disappointed that the Sustainable Communities Plan (published
just a month before the White Paper) did not go further in specifying
minimum sustainable construction standards for all new and refurbished
homes.
March 2003
50 Buildings Research Establishment, March 2003. Back
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