Memorandum submitted by Greenpeace (U40)
INTRODUCTION
1. Greenpeace thanks the Environment Food
and Rural Affairs Select Committee for the opportunity to contribute
to their review of the policies of the United Kingdom Government
to address the challenge of climate change, and also the Government's
activities in the international arena to drive forward the international
response to the issue.
2. Greenpeace is an independent non-profit
global campaigning organisation that uses non-violent, creative
confrontation to expose global environmental problems and their
causes. We research the solutions and alternatives to help provide
a path for a green and peaceful future.
3. Our submission examines the opportunities
for alternatives to carbon fuels and concludes that the fiscal
regime for energy production needs to support the development
and use of renewable energy, while carbon sequestration and nuclear
power do not have the potential to combat serious climate change.
Sequestration and nuclear are needless distractions in the climate
change debate. The UK Presidencies of the G8 and EU in 2005 offer
immense opportunities for advancing climate change policy internationally.
4. While the review of the UK Government
Climate Change Programme has been scheduled for some time, recent
developments in both the areas of climate politics and climate
science makes this review especially significant. The decision
of the Russian Government to forward the Kyoto Protocol to the
Duma for ratification, as well the Prime Minister's renewed commitment
to take action on climate change add to the urgency of the review
both in the global and the national context. Russian ratification
will mean that the protocol will come into force and the 11th
meeting of the parties will also be the first Conference of the
Parties of a legally binding protocol to reduce emissions of greenhouse
gases.
5. In the meantime, the renewed and intensifying
interest of the Prime Minister in climate change is reflected
in the activities of the Government's Chief Scientific Adviser,
who has publicly indicated that climate change is a "greater
threat than global terrorism"[115].
In his recent speech on climate change the Prime Minister robustly
expressed his strengthening views on the threat of climate change:
he described it as "a challenge so far-reaching in its impact
and irreversible in its destructive power, that it alters radically
human existence"[116].
6. What is the extent of this threat? The
history of the political processes to mitigate human impact on
the climate has been dogged by two significant failures: the first
is the failure to engage effectively the United States in the
multilateral process to reduce carbon emissions (we will return
to this challenge later in this document). The second challenge
has been to define adequately "dangerous climate change".
This is the objective of the United Nations Framework Convention
on Climate Change, as expressed (but not defined) in article 2.[117]
7. The ongoing work of the Intergovernmental
Panel on Climate Change (IPCC) has however increased the global
understanding of the causes and impacts of climate change. While
a global political consensus on what constitutes dangerous interference
with the climate system may still be some way off, both the European
Union as a whole and Margaret Beckett, the UK Secretary of State
for Environment Food and Rural Affairs[118]
have accepted a definition of dangerous climate change. Accepting
such a definition effectively sets a cap on global emissions[119].
8. Global average mean surface temperature
increases must be kept below the threshold of 2ºC above pre-industrial
levels and reduced as fast as possible thereafter. To exceed this
threshold would have dramatic implications for people, ecosystems
and species across the world.
9. An increase of just 2ºC could, by
the 2050s, result in an additional[120]:
228 million people at risk from malaria;
12 million at risk from hunger as
crop yields fall;
2,240 million at risk from water
shortages, particularly in the sub-tropics; and
20 million at risk from coastal flooding.
10. To stay within this 2º limit, dramatic
reductions in emissions of carbon dioxide and other greenhouse
gases from the developed world are necessary: reductions in the
order of 30% need to be achieved by 2018. While this target is
ambitious, it does fit within the context of another ambitious
target identified by the Royal Commission on Environmental Pollution
(RCEP) already endorsed by the Government in the Energy White
Paper of 2003.[121]
The RCEP has identified a doubling of atmospheric carbon as the
limits of acceptable human impact on the climate. While this represents
a target that may exceed the 2º limit (depending on climate
sensitivity), the emission cuts required to achieve such an objective
are similar: such a target will "imply a reduction of 60%
from current annual carbon dioxide emissions by 2050 and perhaps
of 80% by 2100".[122]
Such reductions indicate the inadequacy of the current Kyoto protocol
commitment to reduce emissions from the developed world by just
5.2% by 2012.
11. The UK Government has been proud of
its position as a "market leader" in the global political
process to protect the climate. The role of the UK government
in the negotiation of the Kyoto protocol in 1997 and the current
UK Climate Change Programme[123]designed
to produce emissions reductions of 20% by 2010 (a commitment beyond
the call of Kyoto) have been used by Government to justify this
claim. While this positioning around the issue of climate change
is welcome, an examination of current performance raises serious
questions about the capacity of the UK to meet its obligations
on climate change. In this context the review of the UK Climate
Change Programme is not just a timely opportunity but necessary
for a fundamental re-assessment of UK action on climate change.
12. Emission trends within the UK are not
promising for meeting the challenging future emissions reductions
necessary to avoid dangerous climate change. Even meeting the
self-imposed target of 20% carbon reduction by 2010 is not assured.
Reductions since 1990 have been achieved largely because of the
switch of electricity generating capacity to gas from coal fired
stations. Other sectors have not been as successful in exploiting
potential reductions in emissions, and UK performance on climate
change and related issues must be considered in this context.
13. The list of areas where UK aspiration must
be higher is significant. The failure to exploit the huge potential
resource of energy efficiency, a moratorium on new gas stations,
the slow progress in developing wind power (and other renewable
energy resources) in the UK, combined with the failure to control
the growth in the road and air transport sectors has meant that
UK carbon emissions actually rose from 2002-03.[124]
At the same time, the UK must be robust when considering some
of the huge potential opportunity costs in the climate change
policy area. In this context it is important to examine the real
potential of the nuclear industry to play a role in responding
to climate change as well as the relatively new issue of carbon
sequestration.
14. The Prime Minister has set out an ambitious
agenda for UK leadership in all areas of climate change. The UK
Climate Change Programme can potentially deliver enormous social
and economic benefits in the medium term for the UKbased
on exploiting both the UK's abundant renewable energy resources
and the capacity within the UK for industrial and business innovation
and delivery. The aggressive pursuit of this sector could deliver
significantly to job creation and industrial development, but
little has been done so far to develop that potential.[125]
15. The Prime Minister has also laid out
an ambition to take a lead in the international community, both
at the EU and G8 level. Realising these ambitions will not be
easy, and will require significant investment of both financial
and political capital. But in addition to committing appropriate
resources to meet this challenge, the Prime Minister and the Government
will need to assess the political and social challenges presented
by climate change.
16. To be successful in leading both the
G8 and EU processes over the next year:
The UK must aggressively pursue domestic
reduction targets, as well as laying the groundwork for future
ambitious cuts into the second decade of the century.
At the G8, the UK must ensure agreement
on a definition of dangerous human interference with the climate
(as required by the UNFCC)and go far beyond the demands
of the Kyoto Protocol. This must be a commitment to limit global
warming to 2 degrees above pre-industrial levels, linked to emission
reductions that will meet that objective. The G8 can't (and in
any case should not) determine the future emissions of the developing
world, but can provide resources to make sure that everything
possible to promote development there without making the climate
situation worse.
The UK must commit to ensuring EU
leadershipboth at the G8 meeting and throughout the EU
presidency following the G8 meetingon climate issues. Successful
action on climate change is dependent upon engaging the United
Statesthe largest emitter of greenhouse gases, with a relatively
small percentage of global populationin the political and
technical processes that will address the challenges of climate
change. This will only be possible if the EU is robust in response
to ongoing US refusal to reduce its emissions of greenhouse gases
and to engage the global political processes responding to climate
change.
17. Additionally, Greenpeace would like
to submit analysis of and recommendations for several specific
areas of UK climate and energy policy:
Renewable Energyan overview
of potential pathways (paragraphs 20-40).
An examination of the role nuclear
energy in responding to climate change (paragraphs 41-58).
The implications and drawbacks of
dependence on carbon sequestration technology (paragraphs 59-62).
18. It is now almost a truism that climate
change is the most challenging and potentially catastrophic environmental
problem facing the world. It is also an opportunity for genuine
leadership from the UK in political and commercial/industrial
terms. The most pressing question now faced by the UK is how we
address that challenge and whether or not we make the most of
the opportunities that are part of that challenge.
19. Energy generation within the UK is at
a crossroads. In order to make our contribution to keeping the
global temperature increase below two degrees, we have a limited
period in which to undertake the radical overhaul of UK energy
generation required to reduce carbon emissions at the rate and
extent necessary without jeopardising security of energy supply.
20. The following comments must be viewed
in light of the lack of development in other sectors where significant
carbon reduction potential remains untapped. Government efforts
to implement an effective programme of demand reduction in both
domestic and commercial sectors, as well as future action to curb
increases in emissions from both aviation and road transport will
have an impact on the scale of intervention necessary in the electricity
generation sector. If there is a massive uptake of energy efficiency
measures combined with significant reductions in transport emissions,
the burden of action on electricity generation will be reduced.
To date action on both demand reduction and transport has been
extremely limited, so the bulk of cuts in greenhouse gas emissions
will continue to fall on the electricity supply sector.
RENEWABLE ENERGY:
AN OVERVIEW
OF POTENTIAL
PATHWAYS
21. The UK boasts possibly the best renewable
resources of any country in Europe. By exploiting just 15% of
the total offshore wind strategic resource identified by the DTI[126],
energy equivalent to the UK's entire electricity needs could be
generated. Factors influencing whether or not we will meet the
Government's renewable energy targets of 10% by 2010 and the aspirational
target of 20% by 2020 (which hardly reflect the scale of the task
ahead) do not concern the scope of potential. The potential is
vast. The barriers that stand in the way are a series of inter-related
social, regulatory, technical and economic problems. The key to
unlocking these barriers remains concerted political action that
takes a long-term view of how a sustainable energy system can
be achieved.
22. After the failure of the Non Fossil
Fuel Obligation to foster greater renewable development, the Government
has made some efforts to improve the deployment of renewables.
The introduction of the Renewables Obligation (RO), as well as
increased funding for Research & Development and capital grants
schemes have gone some way to increasing the ability of generators
to build new renewable energy capacity.
23. However, looking further ahead there
are significant barriers to the renewables industry meeting the
challenge of climate change. The measures taken have served to
sustain the status quo that favours large generating utilities
over smaller more independent generators that do not have a diverse
portfolio or an integrated supply chain to protect them against
a volatile electricity market. Also, the emphasis on costs within
the RO has only really served to increase the divide between the
commercial viability of onshore wind (and landfill gas, supply
of which is not likely to significantly increase) and other technologies
struggling to become established.
24. As a result, action taken to date is
failing to support the development of a diverse range of renewable
technologies argued for in the Energy White Paper and which will
be needed to achieve the target of 60% carbon reductions by 2050.
RECOMMENDATIONS
25. In order to achieve a sustainable generation
mix that offers a diverse, flexible and secure energy supply,
the Government must move as quickly as possible to a genuinely
radical approach to develop an energy system based on smaller
more dispersed generating units. Such action might include:
26. Redeveloping the UK transmission/distribution
grids both to support micro generation and major renewables centres.
Grid investment needs to take place now to upgrade the transmission
grid and distribution network for use in the long term by a variety
of sustainable renewable energy sources that offer safe and secure
energy. Areas rich in renewable potential, such as the West Coast
of Scotland, require grid development where access is currently
inadequate. Development of new grid connections that link the
source of primary renewable energy such as offshore wind to demand
is expensive for individual developers but may represent good
public value and an exceptional economic opportunity in the longer
term.
27. The current grid is not suitable for
the kind of diverse energy mix necessary to meet the demands of
climate change. The centralised model is outdated and does not
represent the optimum model of supply and distribution. In particular
a sustainable energy system should foster more decentralised centres
of production, which enables heat capture and which is supportive
of the characteristics of renewable technologies. Households (and
businesses) should be enabled to become small scale generators
themselves, which will require Distribution Network Operators
radically to transform their business model to one of active,
rather than passive, managers of local distribution networks.
Greenpeace particularly regrets the lack of emphasis given to
facilitating decentralised energy and microgeneration, given the
high political priority currently placed on the Sustainable Communities
agenda. There are now also strong security drivers for a more
decentralised energy model, both in terms of delivering inherent
network security and reducing overall dependence on fossil-fuel
supplies.
RESEARCH AND
DEVELOPMENT
28. A significant increase in research and
development must take place if renewables are to become the mainstay
of UK energy generation in the future. Although there has been
a significant increase in renewable funding from Government over
the last few years, expected R & D funding from the DTI from
2003-06 is still less than £60 million[127].
Compare this to the £5 billion that will be provided to the
UK's failed private nuclear generator over the next 10 years to
pay for its waste and decommissioning legacy. In this context,
renewable energy is severely under-supported.
29. In order to assist developing renewables,
we would also advocate amendments to the RO and possible additional
mechanisms, such as:
30. Developing mechanisms outside the RO
to assist the technologies other than onshore wind that are not
currently well supported. Particular help is needed to support
sustainable heat production, given heat is the primary energy
use in the UK, and could possibly take the form of a heat obligation
similar to the existing RO. Greenpeace believes a feed-in tariff
or net metering may be required to expedite the growth in micro-renewables.
Given the tiny proportion of micro renewables currently connected
to local grids, Greenpeace believes that these costs could be
readily absorbed by network operators in the short term.
31. Changing the currently uniform value
of ROCs to a grading system that differentiates between the developed
renewable technology of onshore wind and developing technologies
like wind, wave and biomass. By re-valuing the price of ROCs to
reflect the stage of development of the technology that generated
the power, the Government will be fostering an environment of
"learning by doing" in that a developing technology
can take part in the market and reduce its overall cost/KWh through
accelerated research and development.
32. We also see particular barriers hampering
renewables in the regulatory structures outlined below:
33. The local/regional planning system :
Although public acceptance of wind power continues to show high
levels of public support (a recent ICM poll shows support for
wind power at around 80%[128])
the opposition of a vocal few continues to attract disproportionate
press coverage which in turn influences local decision-makers.
34. PPS22 is a positive step towards making
clear to local authorities the need to take account of the wider
threat from climate change, but applications still take too long
to come to a decision. In part this is because of the resource
shortages planning has faced and the increasingly complex demands
that sustainable development places on planners. It is important
that the additional resources now being delivered by Government
to improve planning performance and recruitment prove adequate.
Regional spatial development strategies could be obliged to identify
areas where there would be a presumption in favour of wind. This
proactive planning approach would ensure community ownership is
secured early on and environmentally contentious geographic areas
are identified and excluded from development opportunities from
the outset.
OFFICE OF
GAS AND
ELECTRICITY MARKETS
(OFGEM)
35. Another barrier has been the narrow
way in which OFGEM has interpreted its remit. Greenpeace is concerned
that OFGEM's consultations are characterised by short-term cost-benefit
assessments that fail to recognise both existing environmental/social
costs which are currently externalised, and the immense costs
to consumers posed by climate change in the longer term if emission
reductions are not made now. Many of OFGEM's consultations are
highly technical and engage only the "usual suspects".
There is a concerning lack of vision and forward thinking at OFGEM
which raises questions about OFGEM's ability to instigate the
radical reconfiguration of networks and regulation required to
achieve ambitious emissions reductions. Given the long term nature
of investments in energy infrastructure, it is critical that OFGEM
works to a longer term horizon than at present.
36. The requirements under Section 83 of
the recent Energy Act 2004 (for OFGEM to pursue sustainable development
for the benefit of consumers as a key part of its statutory purposes)
offers the opportunity for a reinvigorated response from OFGEM
to the environmental imperative.
NEW ELECTRICITY
TRADING ARRANGEMENTS
(NETA)
37. A further barrier to renewables has
been the introduction of NETA which at one point brought wholesale
prices below the cost of production, increasing the need for renewables
support. NETA is designed to encourage the cheapest form of generation
and does not offer any incentive to increase the efficiency of
electricity production. Of particular concern to Greenpeace is
the massive waste of primary energy associated with the regulatory
regime's failure to value heat energy, whether wasted or captured.
The plight of CHP under NETA illustrates this point. NETA has
served to reinforce the dominance of the existing grid by large,
wasteful centralised units of conventional generation sources
in the primary energy market. This has served to undermine the
effectiveness of secondary mechanisms such as the RO or carbon
emissions trading scheme.
38. In addition, NETA penalises generators
for generating either above or below their agreed output, which
is a particular problem for variable sources of power such as
wind. This adds to the risk taken when investing in intermittent
renewable sources such as wind power and therefore detracts from
the attractiveness of wind as an investment.
39. NETA also discourages renewable development
because of the huge transaction costs involved simply to participate
in the market. This means disproportionate costs are incurred
by small-scale renewable generators.
CONCLUSIONS
40. The Government has made efforts to increase
the capacity of renewable energy on the grid. It is imperative
however that the Government remains focused on its primary motivation
for bringing about this uptake in renewables. Namely, the need
to combat climate change by reducing carbon emissions by 60% by
2050. The role of the energy generation sector in meeting this
target has become increasingly important as effective transport
and demand reduction measures have failed to materialise. As was
made clear at the beginning of this submission, it is the view
of Greenpeace that the barriers identified (particularly the regulatory
obstacles that have come about through NETA and OFGEM) can and
should be fully addressed through decisive political action from
Government.
41. The Government's task therefore is not
simply to encourage an increase in the capacity of renewable energy
from which ever type of technology comes forward under the existing
regulatory and economic parameters. Rather, it is to foster a
renewables industry where a number of different technologies are
capable of commercial deployment on the scale that we are currently
seeing with wind power. This diverse portfolio of renewable technologies
that are small scale, flexible and safely responsive to demand
represents the future of sustainable energy generation in the
UK. It is the responsibility of the UK Government to take the
necessary steps now in order to bring about this long-term future.
NUCLEAR POWER
AND CLIMATE
CHANGE
42. The present discussion of new build
for nuclear plants in the UK is not about utilising nuclear power
to significantly offset CO2 emissions, but to replace
the current fleet of reactors in order for nuclear power to maintain
its current market share in terms of electricity produced (and
therefore possibly maintain the same level of CO2 offset
at present).
43. Greenpeace believes that Government
should not make any intervention in the energy framework that
acts as an explicit or implicit support to new nuclear power.
One of the objectives of the Government White Paper is that functioning
markets should be an objective of energy policy and these are
completely undermined if nuclear power is given the sort of support
that has been given to British Energy. Obviously Government has
to have a role in regulation, safety, ensuring proper waste disposal
etc but nuclear power has had 50 years of substantial government
support in many countries worldwide support to develop. It is
a nonsense to have functioning energy markets which are still
biased by support to nuclear power. Greenpeace will oppose all
new nuclear power stations for reasons of radioactive discharges,
waste, and danger of catastrophic accident. But even within the
Government's own terms of reference, new nuclear power should
receive no support whatsoever.
44. Nuclear power provides roughly 22% of
the UK's electricity and currently offsets approximately 7% of
the UK's CO2 emissions (6% of total greenhouse gas
emissions). Most of the offset is achieved through operation of
British Energy's reactors (which have a capacity of 9,600 MW).
All but one of BE's reactors are due to close by 2020. All of
BNFL's reactors will close by 2010.
45.The figure of 7% CO2 offset from
nuclear power is lower than the 9% CO2 offset based
on information in British Energy's 2001 submission to the Energy
Review (which covered BE and BNFL plants). That is because the
actual output from BE's reactors over the past three years has
not met the company's projections.
46. By 2010, due to changes in fuel mix
and nuclear plant closures, it is estimated that the CO2
offset from nuclear power in the UK will be around 4-5%.
47. For the UK's nuclear industry to maintain
a) its market share as an electricity producer and b) to act as
a source of energy to offset CO2 emissions it will
have to replace its current fleet of reactors and then build many
more.
48. In order to replace the existing electricity
output from existing reactors BNFL/Westinghouse has proposed building
a fleet of 10 AP1,000MWe (or AP1,1000MWe) reactors. The AP1000
design has yet been tested (ie constructed and operated) and is
not yet licensed anywhere in the world.
49. Industry figures are based on a modular
production line design specifically in order to reduce costs.[129]
This carries two major risks:
Modular design increases the risk
of generic faults whichas with reactors systems in Japan
and Francecan lead to a lot of reactors being closed at
once if a major fault is found.
A program of reactor construction
on a modular design basisto reduce costswould mean
a significant financial commitment to an as yet untested design.
50. As can be seen below, there can be massive
differences given for capital costs for reactors. Similarly, massive
uncertainty exists over waste costs. This is particularly true
for the UK as a there is no final waste disposal route with the
result there is no final cost for intermediate level waste, high
level waste or spent nuclear fuel disposition.
51. Costs: The lowest cost estimates, provided
by the nuclear industry, put the cost between US$1.1billion-$1.5
billion per AP1,1000MWe plant.[130]
The Congressional Budget Office (CBO) in the US has challenged
these figures, saying that construction costs would be 60% higher
than industry estimates.[131]
52. It should be noted that BNFL/Westinghouse
claim that by the time of construction of the fourth reactor,
construction costs would be significantly less than for the first
and second reactors. The costs given below assume all the reactors
will cost the same. Estimates should be undertaken to assess reactor
costsusing both industry estimates and independent costings
on unit prices for a ten reactor construction program (this should
also take into account externalities of setting up production
centres, staff training etc).
53. Using the currently available range
of figures, based on today's prices and current exchange rates,
we can however provide rough estimate the costs for a new build
program:
10 AP1,100 reactors, to replace most
of existing reactors, would entail capital expenditure of £.6.14
billion-£8.37 billion (industry figures) or £9.82 billion-£13.39
billion (CBO's figures, using 60% increase over industry costs
as the basis).
20 plantsto offset 10% of
CO2 (depending on fuel mix at the time) would cost
£12.28 billion-£16.74 billion (industry figures) or
£19.64 billion-£26.79 billion (CBO figures).
To build 40 plants would costs £24.56
billion-£33.48 billion (industry figures) or £39.28
billion-£53.58 billion (CBO figures). To put this in perspective,
the whole Trident missile and submarine program is estimated to
have cost £30 billion.
54. A program of "only" 10 reactors
would involve huge capital outlay. Private investors would not
want to expose themselves to such a massive risk. Indeed, at the
recent Annual Utilities Market Convention, organised by the Energy
Information Centre (Birmingham, 5 October 2004), senior city analysts
and market advisers said that the city would not be prepared to
invest in new build and this would have to be undertaken by the
Government.
55. Financial Risks: The CBO report (see
Annex 3) states that there is a high risk of a company involved
in construction of a new reactor defaulting on government loans,
such as the amount of finance involved in capital expenditure.
The CBO's concern is somewhat analogous to concerns raised by
environment groups over the recently passed Energy Act, which
would allow for the Government to bailout private operators if
they failed to provide fully for their liabilities. Despite concerns
raised by the Trade and Industry Committee on this issue, the
final version of the Energy Act contained no obligation on the
future private operators to fully fund their waste costs. Knowing
this could lead plant builders/operators to run a plant and profit
strip, leaving liabilities to be paid for by the taxpayer. New
legislation would be needed (or current legislation amended) to
place a legal obligation on future private operators to fully
fund their liabilities before paying dividends etc.
56. CO2 offset from the whole
fuel cycle: In order to fully assess the CO2 offset
from a program of 10 new reactors calculations would have to be
done on the energy neededand CO2 producedfrom
uranium mining, processing and enriching, fuel fabrication (using
both fresh uranium and reprocessed uranium), reactor construction,
spent fuel storage and disposal options.
57. Timing: To achieve replacement one plant
would have to be built every one and half years between 2010 (when
licensing may have finished) and 2025. It is expected that the
first new reactor will not come on line until 2018-20. It is not
known how long it would take for a replacement program of 10 reactors.
58. Radioactive waste: The industry proposal
for a new nuclear fleet proposes that spent nuclear fuel arisings
could remain on site with the closed reactor for up to 100 years.
On sites housing a number of facilities (eg a decommissioned plant
and/or an existing waste store) a new reactor could significantly
add to the overall site hazard. In the case of Sizewell B, for
example, where spent fuel will be stored from the current reactor,
new build plus a store could significantly add to the long term
risk for that site. As noted earlier, there is currently no final
disposal option and, according to NIREX, it is not expected that
a radioactive waste dump would be available for at least the next
25-40 years.
59. Terrorism: Apart from the risk of a
major accident leading to either plant shutdown and/or serious
off-site contamination, another major risk from nuclear facilities
is the potential for them to be used as terrorist targets. (For
more detail, please see: Assessing the Risk of Terrorist Attacks
on Nuclear Facilities (July 2004) which contains detailed information
on this issue. Greenpeace information on terrorism and the nuclear
industry is referenced in the report http://www.parliament.uk/documents/upload/POSTpn222.pdf).
CARBON SEQUESTRATION
60. The Prime Minister has suggested that
carbon sequestrationthe act of capturing and storing CO2
either below ground, on or below sea bedsis "a low
carbon technology" and should be considered an environmentally
acceptable method of controlling CO2 emissions. Others
have suggested that absorption by vegetation above ground or the
use of techniques such as iron fertilisation of Southern Oceans
or placing liquid CO2 on the sea bed should be considered
as viable options. In the first instance, the use of the environment
as a dump for carbon dioxide in this way presents an unacceptable
risk to already threatened environments; and does so with no guarantee
of success. Indeed in the case of "tree planting" to
"absorb" carbon dioxide emissions this is a dangerous
option because there is no way to guarantee long-term removal
of CO2 from the biosphere.
61. More importantly however, even technically
feasible options for carbon capture cannot be described as low
carbon technology. It does not reduce carbon dioxide production
or replace capacity that does, unlike energy efficiency technologies
or the capacity to generate renewable energy. It is in fact an
imperfect "end of pipe" disposal solution to a problem
that needs to be solved at a "systems" level. There
ispossiblystill a real opportunity to reduce global
greenhouse gas emissions. This must be done at the rate required
keep global temperature increase within the 2º widely accepted
as the upper limit of the climate's tolerance before catastrophic
occurs. The danger is that the pursuit of carbon sequestration
at this point could prove a distraction from these fundamental
challenges.
62. Significantly, applications for carbon
capture and storage are limited. In the first instance, of course,
it would only be applicable for fixed emissions sources, conveniently
located near a suitably depleted saline water aquifer or depleted
oil or gas field. (This rules out for the foreseeable future road
transport or aviation, the two fastest growing areas of carbon
emissions world-wide.) Further, the projected growth in demand
for energy, especially in the developing world, means that dependence
on carbon sequestration will lock future energy development into
a conventional, fossil fuel trajectory. Every fossil-fuel power
station constructed now in India means CO2 emissions
for a further 40 years. Finally there is a distinct possibility,
subject to further evaluation, that capacity for carbon storage
will be overwhelmed by the projected increase demand for energy
services in the developed and developing world. Given the substantial
uncertainties over guarantees of effective storage, an energy
strategy that relied upon fossil-fuel generation coupled with
carbon sequestration could be a gamble that could go badly wrong.
63. With a significant range of technical
and political options to develop genuinely sustainable energy
still available, governments have a duty to concentrate all resources
in the design and implementation of a truly sustainable energy
system. This must be based upon the speedy development of renewable
energy combined with effective measures to curb energy use in
all sectors. Resources spent on chasing disposal technologies
such as carbon sequestration represent wasted resources, and would
undermine the success of efforts to combat climate change.
12 October 2004
115 King, David A. 9 January 2004. In: Science: Policy
Forum: Climate Change Science: Adapt, Mitigate or Ignore. Vol
303, p 176-177. Back
116
Speech by Prime Minister The Rt Hon Tony Blair, MP 14 September
2005 to Prince of Wales' Business and Environment Programme. http://www.number10.gov.uk/output/page6333.asp Back
117
http://unfccc.int/resource/docs/convkp/conveng.pdf Back
118
iv-Speech from Margaret Beckett to the Earth Institute, Columbia
University-May 2004.
http://www.defra.gov.uk/corporate/ministers/speeches/mb040503.htm Back
119
The relationship of global average temperature rise and total
global emissions is complex, in part because of climate sensitivity-the
sensitivity of the temperature to rising levels of carbon in the
atmosphere. However the IPCC TAR (is this true?) is robust enough
in its understanding of this relationship to identify the 2
threshold as the basis for future action. http://www.grida.no/climate/ipcc_tar/ Back
120
"Millions at risk: Defining critical climate change threats
and targets"-Jackson Environment Institute-Parry and Livermore,
2001. Back
121
DEFRA 2003. The scientific case for setting a long-term emission
reduction target (paper published 24 February 2003 to accompany
the Energy White Paper). http://www.defra.gov.uk/environment/ Back
122
Royal Commission on Environmental Pollution 2000. The 22nd Report.
Energy: the Changing Climate. London. Back
123
Department for Environment, Food & Rural Affairs 2000. Climate
Change The UK Programme. November, 2000. Back
124
DEFRA 2004. Statistical release: 2002 UK air emission estimates
and climate change sustainable development indicator. http://www.defra.gov.uk/news/2004/040325a.htm Back
125
Find attached as an annex to this submission, two Greenpeace
reports: Seawind East and Seawind Europe on the potential for
job creation and economic development and the renewable energy
industry. Back
126
Robert Gross "Technologies and innovation for system change
in the UK: status, prospects and system requirements of some leading
renewable energy options" Energy Policy-November 2004. Back
127
Catherine Mitchell "Renewable Energy Policy in the UK"
1990-2000 Energy Policy-November 2004. Back
128
A copy of the poll can be found at http://www.icmresearch.co.uk/reviews/2004/Greenpeace-windfarms/greenpeace-windfarms-aug.asp Back
129
Nuclear Power and the Characteristics of "Ordinariness"-the
Case of UK Energy Policy, McKerron, NERA, September 2004. Back
130
WESTINGHOUSE EXPECTS TO RECEIVE NRC CERTIFICATION FOR ITS
AP1000 ADVANCED Platts Nuclear News Flashes 3 September 2004.
This gave Westinghouse costs of US$2.2-2.7 billion for two reactors.
The International Herald Tribune, (2/9/04) "China looks
abroad for nuclear help" quoted Westinghouse as giving
a figure of US$1.5 billion per reactor. Back
131
Congressional Budget Office Cost Estimate 7 May 2003 S 14 Energy
Policy Act of 2003 As introduced on 30 April 2003 The CBO puts
the cost of the first reactor at US$2.5 billion. http://www.cbo.gov/showdoc.cfm?index=4206&sequence=0 Back
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