Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by The Royal Society for the Protection of Birds (U31)


  It is increasingly clear that the measures in the UK Climate Change Programme (CCP) are insufficient to achieve the UK's target to cut carbon dioxide emissions by 20% from 1990 levels by 2010.  To achieve our 20% target we need to cut carbon dioxide emissions by 33 MtCarbon per year in 2010 but we are likely to be about eight MtC short of this figure. This shortfall needs to be addressed in the forthcoming review of the UK CCP.

  The EU will be even further from its target with a projected 2.9% reduction by 2010, as opposed to 8%. The UK Presidency should address this issue by initiating a review of the adequacy of EU policies and measures.

  Road transport and aviation emissions are rising especially rapidly and thus need to be limited as a matter of urgency. Further cuts should also be made in other sectors, especially those covered by the EU emissions trading scheme (EU ETS) for which the first phase UK National Allocation Plan (NAP) was very weak, as were NAPs from other EU countries. The RSPB believes that measures that should be strengthened or newly introduced in the UK Climate Change Programme include:

    —  strengthen the EU voluntary agreements with motor manufacturers;

    —  introduce an EU-wide emissions charge on aviation and later opt aviation into the EU ETS;

    —  introduce a well-to-wheel carbon tax on road vehicle fuels, preferably across the EU but certainly in the UK, replacing existing fuel taxes over time;

    —  strengthen the 2005-08 Energy Efficiency Commitment (EEC) to 200 from 130 TWh and plan to strengthen the 2008-11 EEC; and

    —  set a much higher target in the UK NAP for 2008-12, at least five MtC per year, and, as EU President, harmonise target setting for all EU NAPs.

  For the UK's Chairmanship of the G8, by far the biggest single issue is starting international talks on how to limit emissions after 2012, the end of the Kyoto Protocol's first commitment period. To be effective in the longer term, the G8 must focus on this issue and not be distracted by side issues. The G8 and rapidly industrialising developing countries should together initiate the review of the adequacy of the commitments in the Climate Change Convention.


  1.  The RSPB is Europe's largest wildlife charity with over one million members, and is part of the BirdLife International partnership, a global alliance of independent national conservation organisations working in more than 100 countries worldwide.

  2.  We consider that human-induced climate change poses the biggest long-term threat to global biodiversity. A recent paper in Nature by a large group of scientists indicates that in a sample region covering about 20% of the Earth's land surface "15 to 37% of species . . . will be `committed to extinction' as a result of mid-range climate warming scenarios for 2050."[77]

  3.  To avoid such a catastrophe, greenhouse gas emissions need to be cut hard and rapidly. We therefore support policies and measures which reduce the anthropogenic greenhouse gas emissions that cause climate change. We strongly support the large raft of measures that the Government has put in place to achieve this end as part of the UK Climate Change Programme (CCP).

  4.  However, it is increasingly clear that the current CCP measures are insufficient to achieve the UK's target to cut carbon dioxide emissions by 20% from 1990 levels by 2010, even with the new Climate Change Agreements (CCAs), the strengthened Energy Efficiency Commitment (EEC) and the first phase of the EU Emissions Trading Scheme (EU ETS). Indeed, new projections suggest we are moving away from, not towards, our target. This shortfall needs to be addressed in the forthcoming review of the UK CCP.

  5.  The UK's Presidency of the EU and Chairmanship of the G8 in 2005 present excellent opportunities for the UK to re-invigorate the international talks on climate change and to strengthen the EU's increasingly wavering commitment to taking action. We thus welcome the Prime Minister's intention to make climate change a central theme of both. However, initiatives within the G8, in particular, need to be highly focused on a few key issues, notably the resumption of negotiations on what action to take post-2012.  There is a danger that a host of well-meaning but comparatively less important agenda items will be tabled, ultimately leading nowhere and detracting from more important issue.


Emission projections

  6.  The Government is currently revising its emission projections but it is clear from the latest DTI figures (developed and used to draw up the UK National Allocation Plan for the EU ETS) that the UK will miss its 20% target by more than previously thought. The latest published forecasts indicate that, with all existing and planned measures including the first phase of the EU ETS, the UK will only reduce its carbon dioxide emissions by 15.2%, as opposed to previous forecasts of 16.3%.[78]

  7.  In other words, to achieve our 20% target we need to cut carbon dioxide emissions by 33 MtCarbon per year in 2010, from 1990 levels, yet we are likely to be about 8 MtC short of this figure.[79] Eight MtC is a large amount of carbon. For comparison, the emission reduction from the first phase of the EU ETS will be just 1.5 MtC per year. The review of the UK Climate Change Programme thus needs to either strengthen existing measures considerably, or introduce new measures or, possibly, both.

  8.  Some potential candidates for increased measures to reduce emissions are obvious from the figure below (from table 6 of the DTI working paper on updated energy projections, May 2004). Road transport is a rapidly growing emission sector, with air transport growing even more rapidly. The residential sector also stands out as having a flat, rather declining emission profile. In addition, although emissions from power stations and industry have declined there remain far more gains that could be made in these sectors, and the phase II NAP must reflect this.

Strengthening and adding to climate change measures

Road transport

  9.  Road transport emissions have proved hard to constrain, in spite of efforts by successive governments. Vehicle fuel is heavily taxed, vehicle excise duty (VED) is graduated according to carbon dioxide emissions, the 10 Year Transport Plan aimed to make more use of public transport, an increasing number of towns are introducing congestion charging, and the voluntary agreement between the EU and car manufacturers in the EU, Japan and Korea to lower fleet emissions appears to be working—yet emissions continue to rise.

  10.  The Government is currently pinning its hopes for constraining, if not reducing emissions, mainly on road user charging, more switching to public transport (at least in major towns) and strengthening the EU voluntary agreements with motor manufacturers. We would be supportive of both road user charging and, especially, extending the EU voluntary agreements. Currently their effect is estimated to be a saving of 2.6 MtC (including the comparatively minor effects of VED and company car taxation). A significant revision of the agreements could yield reduction of a similar magnitude, and is technically and economically entirely possible. VED differentials could also be increased significantly.

  11.  A difficulty is, however, that the present timetable for introducing road user charging is too slow to achieve significant emission reductions by the 2010 target date, so should be accelerated. It is anyway a blunt and uncertain instrument for achieving emissions reductions and must be used with caution for that purpose and only as an ancillary measure. Although they are likely to be more effective in reducing emissions, a difficulty with the voluntary agreements is that they run until 2008 and so any new agreements would be unlikely to have a significant effect by the UK's target date of 2010.  

  12.  Additional measures are thus needed. One that could have a large effect on emissions is a well-to-wheel carbon tax. This would tax vehicle fuel on the basis not only of its own, inherent carbon content but also take into account emissions from processing and, as far as possible, transportation. It would have several advantages. It would encourage many different types of "green" fuels, from biofuels to hydrogen, as opposed to the Government proposal for a biofuels obligation that would be fuel-specific. It would also be perceived of as fair, because it would be levied in direct proportion to pollution, with zero carbon fuels attracting no tax and high carbon fuels a high tax. In addition, a carbon tax could replace the complex system of fuel taxation currently in place which give tax breaks to some fuels of uncertain environmental benefit, such as liquid petroleum gas (LPG). If structured correctly, it could result in no loss of revenue to the Treasury. While it would be strongly preferable to introduce such an instrument at EU level, it could be introduced, without significant competitiveness implications, within the UK. No transportation fuel should be certified for vehicle use if the direct and indirect environmental impacts of its production and use are unacceptable.

  13.  Introducing a well-to-wheel carbon tax would clearly represent a major revision of the current system of vehicle fuel taxation but it could be phased in over time as current taxes were made, first, less distorting in carbon terms and then phased out.

  14.  A further measure that would be easy to introduce would be to impose an upper limit on emissions from new cars. Whilst this would not have a large effect immediately it would send a clear signal that personal vehicles with extremely heavy fuel consumption are not acceptable.

  15.  We understand that, in anticipation of the introduction of an EU car-labelling scheme, agreement has been reached to introduce a voluntary labelling scheme in the UK, a move we strongly support.


  16.  Aviation emissions are forecast to rise by 7.32 MtC per year between 1998 and 2010, a rate that would swamp emissions savings from the Renewables Obligation by roughly three times.[80] Indeed, the situation is actually worse that this because carbon dioxide emissions at high altitude are about three times more damaging than those released from the ground.[81] In terms of the effect of emissions on climate change, the rise in emissions from aviation by 1990 is thus likely to nullify not only the Renewables Obligation but most of the other measures taken so far in the business sector, such as the CCAs and the EU ETS.

  17.  Currently, the only tax on aviation is the Air Passenger Duty (APD). Aviation fuels are duty free and, more generally, aviation receives a number of indirect subsidies. An obvious means of limiting demand for aviation is thus by taxing fuel, particularly as the DfT's own sensitivity analysis on their Air Traffic Forecasts 2000 indicate that merely keeping air fares constant would halve forecast demand. (The forecasts assume an annual price fall of 1% per year.)

  18.  However, tax on aviation fuel used in international flights is prohibited by the 1944 Chicago Convention and by a host of bilateral "Air Service Agreements" that the UK has with other countries. The best way to tackle the problem globally would thus be via a cap and trade scheme that included aviation emissions, ideally within the Kyoto trading regime but this would be strongly opposed by some countries, notably the USA. It would thus take some time, perhaps a decade or more, to put a comprehensive, international cap and trade scheme in place.

  19.  In the meantime, other measures should therefore be considered at the UK and EU levels. These should include an emissions charge on EU internal flights and, in the longer term, opting aviation emissions into the EU cap and trade scheme in its second phase from 2008 to 2012.  (Neither emissions trading nor an emissions charge are prohibited by the Chicago Convention because neither had been thought of in 1944 when the treaty was concluded.) Such measures should be accompanied by other indirect ones, such as auctioning take-off and landing "slots", the introduction of a "dual till" approach at airports and increased, emissions-related APD.

Domestic emissions

  20.  The Building Regulations (England and Wales) and the Energy Efficiency Commitment (EEC) are currently being revised. Both could be strengthened considerably more than is envisaged in the government consultations associated with them.

  21.  For example, the target envisaged for the EEC in the period 2005 to 2008 is 130 TWhr, representing a further saving from the EEC of 0.7 MtC, in addition to the 0.4 MtC from the 2002-05 EEC. This should be strengthened to at least 200 TWhr, yielding a carbon saving of about 1 MtC per year, which should be achievable at net financial benefit. (Defra's original intention was to treble, rather than double, the obligation.) The next, 2008-11, EEC should be strengthened further and, potentially, extended to the small business sector.

Emissions from power stations and industry

  22.  The sectors included in the EU ETS encompass nearly half of all UK carbon dioxide emissions. The trading scheme is thus the prime candidate measure for cutting UK emissions. Moreover, the industries covered by the scheme came off very lightly in terms of emission cuts in the first UK National Allocation Plan (NAP). In fact, all other EU member states set lax NAPs and the UK's plan was little better. Carbon prices are thus certain to be so low as to make lack of competitiveness a trivial consideration for most industries, except some very energy intensive ones.[82]

  23.  In the UK plan, all sectors except electricity generation were allocated emission allowances on the basis of business as usual projections which, in some cases, may have been inflated. Electricity generation was singled out for a cut of 1.5 MtC from business as usual, on the grounds that it is not subject to international competition, as some other sectors are, and would consequently not lose competitiveness if other countries set lax NAPs.

  24.  For the second period of the EU ETS it is imperative that both the UK and other EU states set far larger targets in their NAPs. The UK could easily double or triple the emission reduction. 5MtC rather than the current 1.5 MtC would seem a reasonable reduction if we are to have any hope of reaching our 20% carbon dioxide target. It is also politically more straightforward, and probably cheaper, to target further reductions from the industrial sector, than from the domestic and transport sectors.

UK presidency of the EU

  25.  The latest available data for 2002 shows that the EU 15 has achieved only a 2.9% reduction in greenhouse gas emissions from 1990 levels. As a result, the EU is not on course to meet its Kyoto target of 8% by 2010, let alone a 21% target, and clearly needs to do much more if it is to achieve it, both by strengthening existing policies and measures and introducing new ones. The figure below, from the European Environmental Agency, shows how well, or badly, the EU 15 countries were performing in attaining their burden-sharing targets in 2001.[83]

  26.  A key task for the UK's Presidency of the EU is thus to review its progress towards meeting its emission reduction targets and initiate a process for ensuring that existing EU policies and measures are fully implemented in member states, strengthening those measures and developing new ones.

  27.  The UK will have strong legal grounds for conducting a thorough review of policies and measures during the Presidency. By 2005, the developed country parties to the Kyoto Protocol are obliged to have made "demonstrable progress" in achieving their commitments under the protocol. A review of both implementation and of the adequacy of policies and measures is clearly essential in demonstrating progress, or not. (The EU inserted the "demonstrable progress" text (Article 3.2) into the Protocol and so it is particularly important that the EU shows leadership in implementing it.)

  28.  Measures that require strengthening and adding to at the EU level are similar, or in some case the same, as those at UK level. In particular, a key task will be to ensure that methods used in drawing up National Allocation Plans for the EU ETS are far better harmonised, firmly set cap so as to ensure that competitiveness concerns are minimised and more challenging NAPs are set for the second phase of the scheme. (The Emissions Trading Directive already allows for such harmonisation.)

  29.  As at home, the UK should also do much more to restrict transport-related emissions during its presidency of the EU. The UK should work to put in place an EU-wide emissions charge on aviation and set in train a process for opting aviation emissions into the EU ETS. They should also strive to put in place an EU-wide well-to-wheel carbon tax on all road vehicle fuels.

UK chairmanship of the G8

  30.  The Prime Minister has already announced that his priorities for the G8 will be climate change and Africa. We strongly support this choice but are concerned that the G8 agenda will fill up with numerous worthwhile but ultimately less important matters, diverting attention from the big issues.

  31.  On climate change, by far the biggest single issue is starting international talks on how to limit emissions after 2012, the end of the Kyoto Protocol's first commitment period. To be effective in the longer term, the G8 must focus on this issue and not be distracted by side issues, such as a further renewables conference with voluntary targets, linking emission trading schemes, encouraging biofuels as part of WTO and CAP reform, and a host of other worthy but less important matters.

  32.  To make progress on tackling climate change a binding international agreement to cut emissions is essential. Without such an agreement, countries will always pull back from making substantial emission cuts because of fears of loss of competitiveness, as we have recently seen in the race to the bottom by EU countries in setting targets for the EU ETS. Also, even to begin to stabilize atmospheric concentrations of greenhouse gases, and hence limit global temperature rise, all countries need constrain their emissions, certainly the larger emitters, as the figure below illustrates.[84] The USA and China, for example, clearly have to be part of any solution.

Political background

  33.  Involving all countries in a global agreement may be essential but it will be hard to achieve, as is shown by experience of the Kyoto Protocol. Not only has the USA left the Protocol but none of the developing countries, including the rapidly industrialising ones, have commitments to limit their emissions. Ethically, it is right to say (as the UN Climate Change Convention does) that developed countries have a historical responsibility for causing the problem of climate change and that they should take the lead in clearing it up. However, this does not solve the practical problem of limiting climate change. If developed country emissions are not cut hard and developing country emissions at least constrained, climate change will continue indefinitely and catastrophically.

  34.  In the USA, much opprobrium has been heaped upon the Bush Administration for pulling out of Kyoto but it is sometimes forgotten that even if the President asked the Senate to ratify the agreement then the Senate would probably refuse. The Byrd-Hagel Senate Resolution of 1997 clearly stated, just prior to the Kyoto meeting which led to the Protocol, that the Senate would not ratify a treaty on climate change that did not include "meaningful participation" by at least some, more developed, developing countries. The Senate passed the resolution by a vote of 95 to 0.  The issue of rapidly industrialising country participation is therefore not simply a practical matter of reducing emissions but it is of key importance in achieving US engagement in any agreement.

  35.  Moreover, since 1997, the USA has done very little to limit its emissions and they have continued to climb steeply under both the Clinton and Bush Administrations. It is thus arguable whether it is now possible for the USA to achieve its Kyoto targets, and any US administration, and probably any Senate too, would argue that it is not.

  36.  It is also extremely unlikely that any developing country will take on legally binding emission reductions in the near future. All of the major, rapidly industrialising countries are parties to the Kyoto Protocol, under which they have no obligations to limit emissions, certainly before 2012.  Moreover, the developing country negotiating bloc (the G77 and China) firmly adheres to the position that developed countries should take the lead in reducing emissions.

  37.  Until 2012, the end of the first Kyoto Commitment period, the prospects of either the USA or major developing countries agreeing to limit their emissions under an international treaty are therefore slim. It has been argued that an agreement other than Kyoto might be set up, in the form of a "coalition of the willing", but this has a number of serious disadvantages. It could potentially undermine both the Protocol and, more importantly, its parent convention, the UN Framework Convention on Climate Change (UNFCCC) to which almost all countries belong, including the USA. Also, a coalition of the willing is, by its nature, likely to achieve little more than its members would do anyway. It is the unwilling that need to be persuaded into agreement.

  38.  For the post 2012 period, however, the prospects of agreement look better. Most US politicians from both parties now accept that climate change is a serious problem, as is shown by the climate-related measures being taken by Governor Pataki in New York State, Governor Schwarzeneger in California and by Senator McCain (Republican, Arizona) and Senator Leiberman (Democrat, Conneticut) who tabled the "Climate Stewardship Act" that narrowly failed to pass through the Senate by 43 to 55 votes in October 2003.  (McCain and Lieberman will resubmit the Bill.)

  39.  Rapidly industrialising countries, especially China, also take climate change increasingly seriously. Qin Dahe, head of China's Meteorological Administration, recently told the Chinese Academy of Sciences that "global warming brought about [an] unbearable, irreversible and sustained effect to the Chinese economic and social development."[85]

Initiating post-2012 negotiations

  40.  Next year's G8 meeting is an almost ideal time to initiate talks about action on climate change post-2012.  That date is still a long way off in terms of the typical governmental timescale of four or five years and so even wary governments may be willing to start talks as long as there are no preconditions about commitments. A climate-skeptical US Administration and major developing country governments that fear taking on emission reduction targets could, at a high level, agree to start talks.

  41.  The high level commitment is, however, important because, without it, executive officials are likely remain mired in their present, "do nothing" positions as they have for three or four years now. It is also vital that the UK Chair of the G8 engages not only the G8 members but also major developing countries in any G8 decision. A G8 resolution without the active involvement of at least some major developing countries is likely to raise suspicion and antagonism. One idea is to hold a "G-10" or ideally "G12" meeting of the G8 leaders together with those from China, India, Brazil and South Africa.

  42.  A G8 and developing country decision should not be complex. At its most basic, it need only call upon the parties to the UNFCCC (to which all G8 members and all major developing countries belong) to conduct a review of the adequacy of the commitments in the Convention. The Convention specifically provides for such a review. Indeed, it is overdue. Article 4.2.d. of the Convention says that it "shall take place no later than 31 December 1998". The review, even if based only slightly in reality, should conclude that the commitments in the Convention are inadequate and act accordingly to take corrective action. (The first review of the adequacy of commitments in 1994 concluded that the commitments were inadequate and led directly to the process that concluded with the Kyoto Protocol. It would be inconsistent to conclude that the commitments were adequate now when they were not in 1994.)

  43.  It is particularly important that no attempt should be made by the G8 to impose preconditions on the negotiations, especially in the form of organising principles, such as "contraction and convergence". These should emerge during negotiations, not before them, and preferably from developing countries rather than the G8.  The only guiding principle that should be employed is one that is already agreed as the ultimate objective of the Convention which is:

    . . . stabilisation of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. Such a level should be achieved within a time-frame sufficient to allow ecosystems to adapt naturally to climate change, to ensure that food production is not threatened and to enable economic development to proceed in a sustainable manner."

  44.  At present, it seems unlikely that this globally agreed objective will be met. As may be seen from the figure on emission projections for major countries, stabilsation of atmospheric concentrations at any level at all is clearly not going to occur without significant global cuts emissions. According to the Intergovernmental Panel on Climate Change:

    "natural systems can be especially vulnerable to climate change and some will be irreversibly damaged or lost, and [there will be] a general reduction in crop yields in most tropic, sub-tropical and mid-latitude regions."

4 October 2004

77   Chris D Thomas et al, Extinction risk from climate change, Nature, 8 January 2004. Back

78   Working Paper on Updated UK Energy Projections, DTI, May 2004. Back

79   In this paper, all emission estimates are given in MTCarbon, rather than MtCarbon dioxide because these are the units used in the UK forecasts. To convert for MtC to MtCO2 multiply by 44/12. Back

80   Figures on aviation from the DfT's Air Traffic Forecasts 2000 and for the Renewables Obligation from the UK Climate Change Programme. Back

81   2.7 times is the average value quoted by the Royal Commission on Environmental Pollution in their latest report on aviation. Back

82   For further information on competitiveness in the EU ETS see, The European Emissions Trading scheme: Implications for Industrial Competitiveness, The Carbon Trust, 2004. Back

83   Greenhouse gas emission trends and projections in Europe 2003, European Environment Agency, 2003. Back

84   From World Energy Outlook 2002, International Energy Agency, OECD/IEA, Paris, 2002. Back

85   "Scientist suggests to set up national policy on climate change", People's Daily Online, 7 June 2004, Back

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