Memorandum submitted by the Sustainable
Development Commission
SDC INPUT INTO
THE REVIEW
PROCESS
1. The UK Government[1]
published a consultation document on the Review of the Climate
Change Programme (CCP) in December 2004. This identified a shortfall
of around 10 million tonnes of carbon (MtC) between projected
carbon emissions and the domestic target for a 20% cut in emissions
by 2010. SDC input was therefore designed around a 10 MtC shortfall,
although this was later revealed to be an under-estimate.
2. The Sustainable Development Commission
(SDC) prepared a detailed submission to this Review, which was
published in May 2005.[2]
This drew on work from across our energy, transport and buildings
work programmes and contained a wide range of detailed policy
recommendations.
3. SDC Commissioners held regular meetings
with Ministers and high-ranking officials throughout the Review
process, pointing out areas of concern and lending support to
new policy proposals.
4. The SDC Secretariat played an active
role in the Inter-department Analysts Group (IAG), attending meetings,
commenting on policy appraisals, and making further suggestions.
Unfortunately the SDC's participation in this group was restricted
towards the end of the Review process, which limited our ability
to comment on the final range of policies that was announced.
5. The SDC Secretariat was also part of
the Defra-led Stakeholder Group, which held three meetings over
the course of 2005.
6. In February 2006 the SDC prepared a brief
summary for Ministers on what we believed were the key measures
to get the CCP back on track.
SDC POSITION ON
CLIMATE CHANGE
7. There is increasing recognition that
the long-term target for a 60% cut in carbon emissions by 2050
will not be sufficient to avoid "dangerous climate change".
The SDC will be looking at this issue over the summer and will
publish a position paper on climate change in due course.
8. Furthermore, it is now very clear that
climate change is not a "long-term" problem that can
be deferred for future generations to deal with. Climate change
impacts are already being observed, and the threat to global populations
and ecosystems is real and immediate.
9. In light of this fact, the target for
a 20% cut in emissions by 2010 may not be sufficiently ambitious
when viewed from a scientific perspective. The SDC therefore sees
the 2010 target as an absolute minimum considering the likelihood
that much greater cuts will be required over the following 20
years.
10. However, the SDC recognises the strong
leadership shown by the Government when setting the 20% target,
and the fact that UK action on climate change must be part of
a much greater international effort. It is on this basis that
we support the 20% target, and we have assessed the CCP 2006 accordingly.
11. It is increasingly clear that current
policies on climate change are not delivering absolute cuts in
carbon emissions. This is highlighted by the fact that the 10
MtC projected shortfall from the 2010 target at the beginning
of the Review process became 15 MtC by the time the revised CCP
was published in March 2006.
12. This presents problems when undertaking
an analysis of the CCP 2006, as many of the measures we originally
recommended are now insufficient to deliver the carbon reductions
required.
13. This lends added weight to our argument
that current methods of dealing with climate change are incompatible
with the task at hand.
14. Climate change is a cross-departmental
issue with huge implications for all areas of public policy. The
current system puts very little responsibility for tackling climate
change with final consumers, which positions Government departments
against each other as they try to achieve a cross-departmental
goal with as little pain as possible for their own constituents.
15. In addition, there is little incentive
for local or regional consideration of climate change issues.
This leads to patchy performance between local authorities, and
a Regional Development Agency system that is heavily focused on
economic growth above all else, even when this could be detrimental
to climate change objectives.
16. Continuation of this approach will ultimately
fail to deliver the emissions reductions required. This is why
the SDC has recommended that economy-wide emissions trading should
be the policy framework within which action on climate change
takes place. This is most recently explained in our Energy Review
submission.
17. We are also interested in the role that
"personal carbon trading" could play as part of an economy-wide
emissions trading scheme. The SDC will return to this issue in
our forthcoming position paper on climate change.
SDC SUBMISSION TO
EAC INQUIRY
18. The Environmental Audit Committee (EAC)
announced its intention to hold an inquiry into the Climate Change
Programme 2006 on 27 April 2006.
19. This submission is based on the three
questions posed by the EAC inquiry, along with an analysis of
the success of the CCP 2006 in relation to the recommendations
made by the SDC in May 2005. We have not addressed every SDC recommendation
in detail, but have focused on those areas where action is critical.
The three questions from the EAC inquiry are:
— The Prime Minister continues to identify
climate change as "probably the greatest long-term challenge
facing the human race". Does the 2006 Climate Change Programme
represent a realistic strategy to prepare the UK to meet this
challenge?
— Does the Government need to do more,
and if so what, to try to ensure that it meets the 20% reduction
in carbon dioxide emissions by 2010?
— To what extent, if at all, will the
outcome of the Energy Review affect the implementation of the
Climate Change Programme?
20. Question 1: Does the 2006 Climate
Change Programme represent a realistic strategy to prepare the
UK to meet this challenge? The SDC does not believe that the CCP
2006 is a sufficient set of policies to prepare the UK to meet
the challenge of climate change.
21. Current figures suggest that the UK
will only achieve 16.2% cut in carbon emissions from 1990 levels,
and this is after five years of concerted efforts by the UK Government
and the Devolved Administrations. Indeed, the picture is much
worse than this: carbon emissions in 2004 were 3.5 MtC higher
than in 1995, and it was the period between 1990 and 1995 where
substantial reductions were made.
22. It is therefore clear that the CCP has
failed to deliver absolute cuts in carbon emissions and has only
succeeded in slowing the growth in emissions that would otherwise
have occurred.
23. The Government stands to meet its Kyoto
obligations solely through carbon reductions achieved up to 1995
(largely through fuel switching in the power sector and deindustrialisation)
along with sustained reductions in emissions from other greenhouse
gases, primarily methane and hydrofluorocarbons.
24. These trends represent a completely
inadequate preparation for the much larger cuts in carbon emissions
that will be required over the next 20 years or so. This delay
enhances the prospect that more painful and costly actions will
be required in the longer term to correct the mistakes currently
being committed. For example, the emissions implications of new
buildings and power plants, both of which have long lifetimes.
25. The SDC recognises that reductions in
UK carbon emissions will have only a small effect on global emissions,
and that in the longer term an international effort of momentous
proportions is required.
26. However, it is also our belief that
the large majority of near-term emissions savings can be made
at net benefit to the UK economy through savings in lifetime energy
costs and through innovation and export benefits. For example,
domestic measures in the Climate Change Programme 2000 (mainly
energy efficiency) were evaluated as having a net benefit of over
£400/tCe[3].
27. Furthermore, the UK is seen as a leader
on climate change issues and this confers a responsibility to
show that substantial emissions reductions are possible without
sacrificing peoples' quality of life.
28. Question 2: Does the Government need
to do more, and if so what, to try to ensure that it meets the
20% reduction in carbon dioxide emissions by 2010? The Government
will need to do much more to ensure it meets the 2010 target,
particularly after allowing for further leakage in existing measures.
The following sections deal with the SDC's recommendations to
the Government prior to the Review of the CCP and more recently.
29. Question 3: to what extent, if at
all, will the outcome of the Energy Review affect the implementation
of the Climate Change Programme? The SDC believes that the 2006
Energy Review is a unique opportunity for the Government to show
how it intends to manage the transition to a low carbon energy
supply over the long-term. The SDC presented a detailed submission
to the Department of Trade & Industry's (DTI) Energy Review
team in April 2006[4],
which built on our earlier work on nuclear power[5].
TARGETS
30. As noted in paragraph 10 the SDC strongly
supports the domestic target for a 20% cut in carbon emissions
by 2010. We also recommended that the Government adopt three other
goals:
— a 60% cut in carbon emissions from
buildings (over 1990 levels) by 2050;
— a 50% cut in carbon emissions from
road transport by 2025 (over 1990 levels) through a combination
of technological and behavioural change; and
— a carbon neutral public sector by
2020.
31. The aim of these goals was to provide
a clear framework for long-term action in the household and transport
sectors, with clear leadership through the public sector and through
the proposed "growth areas".
32. Of these, the Government has gone some
way towards our recommendation for a carbon neutral public sector
by 2020 with the announcement on 12 June 2006 that the Government
Estate would be carbon neutral by 2012. However, we remain particularly
concerned at the absence of any long-term strategy to target emissions
from transport and existing buildings.
BUSINESS
33. The SDC was strongly supportive of the
EU Emissions Trading Scheme (EUETS) as a central plank of the
Government's Climate Change Programme. However, we were critical
of the process by which National Allocation Plans (NAPs) were
set in the first phase (2005-07), which encouraged departmental
wrangling and led to the confusion over the UK's legal challenge
to the EU.
34. The SDC recommended a NAP in phase two
(2008-12) that was commensurate to the contribution of the EUETS
sector to the 20% carbon reduction target (46%). This led to a
recommendation for a cap 3 MtC/year less than phase one. However,
by March 2006 there was an additional 5 MtC gap in the emissions
projections, and the Government had ruled out many of the other
measures suggested to it during the consultation process on cost
effectiveness grounds.
35. The SDC therefore welcomed the announcement
on 29 June 2006 that the Government has set the NAP to achieve
8 MtC of carbon savings from the EUETS during 2008-12. We believe
the UK Government has set a benchmark which other countries will
have to live up to, and we call on the UK Government and the European
Commission to ensure that other countries' NAPs are equally ambitious.
36. The SDC recommended that as part of
a package of support for renewables, 10% of the emissions permits
for phase two of EUETS should be auctioned. We suggested that
the proceeds should be allocated to a carbon-saving fund aimed
at technologies and measures unlikely to benefit from market-based
instruments. We also suggested that the revenue built up from
Non-Fossil Fuel Obligation (NFFO) payments, estimated to be worth
around £880 million by 2010, should be invested in the same
fund.
37. We therefore welcome the Government's
announcement that 7% of EUETS permits will be auctioned, and the
intention to create an Environmental Transformation Fund. We hope
that the funds allocated will be equal to, or greater than, the
revenue raised from the auctioning of EUETS permits. We await
further details on how the Government intends to spend the £880
million windfall from the NFFO.
38. The SDC recognises that coal will continue
to be used for electricity generation for sometime, despite the
limiting forces of the EUETS and the Large Combustion Plants Directive.
We therefore recommended in May 2005, and again in April 2006,
that the Government give serious consideration to the role that
carbon capture and storage (CCS) could play in eliminating carbon
emissions from fossil fuel combustion, as a bridge to a more sustainable
low carbon future.
39. There is a strong international imperative
to develop CCS technologies so that the carbon effects of coal-based
developments in countries such as China can be reduced. The SDC
will be looking to the Energy Review to bring forward enabling
policies on CCS.
40. On combined heat and power (CHP), the
SDC remains very disappointed by the Government's apparent lack
of enthusiasm for meeting its own target for 10GWe of good quality
CHP by 2010. Capacity at the end of 2004 stood at 5.6 GW[6].
41. We believe there is inadequate resource
in Defra for the necessary CHP analysis and policy development.
The Energy Review consultation document dismissed CHP's potential
contribution as limited. In fact, the absence of more CHP is a
serious market and policy failure when viewed from a climate change
and energy security perspective, and the Government has been singularly
lacking in realising and addressing this reality.
42. Currently, 65% of energy is wasted before
it even reaches our homes due to the inherent inefficiency of
centralised electricity generation. A more decentralised energy
system using CHP would dramatically reduce this wastage, thus
reducing carbon emissions and gas use.
43. Action on CHP is needed as a matter
of urgency. There are currently seven gas-fired CCGT projects
awaiting consent from the DTI. Their combined capacity once operational
will be 8.1 GW. This equates to a huge carbon lock-in, and while
these plant will in part be displacing inefficient coal output
(with a substantial carbon saving), there will still be huge amounts
of wasted energy when compared to using the same gas in CHP plant.
In addition, there is unlikely to be any requirement that they
be made CCS-ready to enable zero carbon output in the future.
44. On the Climate Change Levy (CCL), the
SDC recommended that this should be raised in line with inflation,
and additionally for those sectors not covered by the EUETS.
45. This latter recommendation has been
overtaken by the proposal (initially from the Carbon Trust, but
taken on by the Government) for a new UK-based emissions trading
scheme, now called the Energy Performance Commitment (EPC), which
the SDC strongly supported through the analytical process. It
would cover those large corporate and public sector emitters not
covered by the EUETS.
46. The SDC has made strong representations
in favour of the proposed Energy Performance Commitment and we
support its introduction as soon as is practically possible.
47. The SDC welcomes the announcement in
Budget 2006 that the CCL will rise in line with inflation. The
CCL would be unnecessary if economy-wide emissions trading existed,
but it plays a valuable role in the intervening period.
48. On Climate Change Agreements (CCAs),
the SDC has been supportive of this policy measure, which the
Government estimates will save 2.9 MtC by 2010.
49. However, our recommendation that CCAs
could be tightened and widened to cover other businesses has not
been taken up, and the introduction of the EPC may overtake this
recommendation. There is concern at the level of overlap with
other measures (specifically the EUETS and the proposed EPC) and
we accept that CCAs (which rely on the CCL) may not be the preferred
policy measure in the longer term.
HOUSEHOLDS
50. The SDC believes that there needs to
be a step change in householder engagement on energy and climate
change issues to motivate action on reducing carbon emissions.
We recommended in our submission that the Energy Efficiency Commitment
in phase 3 (EEC3) should be tripled from the level in EEC1, with
specific efforts made to increase take-up of the offers available,
through schemes such as Council Tax rebates.
51. However, in light of recent data showing
the success of the EEC programme, and the continuing rise in household
carbon emissions, we recommended in our Energy Review submission
that EEC3 should now be raised by four times the level in EEC1
to deliver 1.5 MtC of savings by 2010.
52. We are pleased to note the Government's
announcement that EEC3 will be raised to deliver between 0.9 to
1.2 MtC per year by 2010, which at the upper level is equal to
a tripling of EEC1. However, we hope that the Energy Review will
announce a further push on EEC3 to deliver the additional savings
we have recommended. The Government also intends to introduce
further flexibility into EEC, which we support.
53. We believe that the Government now needs
to seriously consider alternatives to EEC which would deliver
absolute reductions in energy use. The proposal for an Energy
Saving Obligation (which would place a cap on suppliers) is one
such option, and the SDC is interested in seeing how this might
work in practice.
54. We are also interested to hear how the
Government intends to encourage the domestic energy services model,
particularly in light of our recommendations to the Energy Review
for greater decentralised energy provision.
55. On market transformation of consumer
appliances, the SDC highlighted the success of EEC in stimulating
demand for A-rated appliances and we lent our support to the use
of enhanced energy labelling.
56. However, we also pointed to the role
of regulation in helping to remove certain products from the market.
This has been further explored by the Sustainable Consumption
Roundtable, who introduced the concept of "choice editing"
to help consumers make the right decisions.
57. The SDC is concerned that sustainable
development criteria have not been systematically included throughout
the DTI's work on innovation. For example, a number of opportunities
have been missed to reduce carbon emissions through technological
innovation—for example, with digital set-top boxes. With
the number of boxes expected to rise from 13 million to 85 million
by 2020, the energy wastage could amount to £280 million,
leading to 0.4 MtC of carbon emissions by year.
58. We are therefore pleased to note the
Government's commitment (made at Gleneagles in 2005) to a 1-Watt
Initiative for consumer electronics and the announcement of voluntary
schemes in the retail sector to encourage take-up of more efficient
devices.
59. However, we still believe that the Government
should consider removing the worst offending products from the
market when there are cost-effective alternatives. We have also
recommended in our submission to the Comprehensive Spending Review
(CSR) that HM Treasury and the DTI agree a Public Service Agreement
(PSA) which ensures that future innovation funding delivers on
sustainable development objectives.
60. The SDC was very supportive of novel
demand-side solutions to reducing carbon emissions such as those
proposed by Dynamic Demand.[7]
We are please to note that the Climate Change and Sustainable
Energy Bill includes a requirement for the Government to conduct
a formal assessment of frequency response technologies and report
back to Parliament.
61. Building regulations are an essential
tool in ensuring a level playing field on the road to zero carbon
buildings. The long life of buildings makes delays in this area
very costly, by adding to the retrofit burden in the future.
62. The SDC recommended that the Government
give an indication of the direction of building regulations, to
provide certainty to the construction industry and facilitate
forward planning. We indicated that the long-term aim should be
virtually zero carbon buildings by 2015, incorporating a zero
heat standard, and self-generation of a large proportion of electricity
needs.
63. In our submission to the Energy Review
the SDC has gone one step further as a result of our continuing
work in this area. We now recommend that the Government announce
a zero heat standard from 2010, and a zero carbon standard from
2015.
64. We also recommend that the Code for
Sustainable Homes be used as a way to set the future direction
of building regulations. So, publicly-funded housing would need
to reach a zero heat standard immediately, and a zero carbon standard
by 2010.
65. We are very disappointed to note that
the CCP 2006 makes no reference to a long-term aim for building
regulations. We believe that the Government needs to address this
issue as a matter of urgency.
66. The SDC criticised the Sustainable Communities
Plan and the Decent Homes programme for failing to adequately
incorporate environmental sustainability and carbon reduction
measures. For example, the Decent Homes programme has energy efficiency
standards that are well below those for new-build.
67. The SDC has more recently recommended
that the Government extend the Code for Sustainable Homes to existing
buildings[8].
This could be integrated into existing and forthcoming policies,
such as the Home Condition Report (owner-occupiers), the Decent
Homes Standard (social housing), and the Green Landlords Scheme
(private rented sector).
68. Unfortunately, the shortcomings we have
identified with the Sustainable Communities Plan and the Decent
Homes Standard have not yet been addressed by Government. The
SDC is carrying out an in-depth review of the Sustainable Communities
Plan which will report in late 2006.
69. On the new "growth areas"
(announced as part of the Sustainable Communities Plan), the SDC
recommended that these be made carbon neutral by offsetting the
projected additional carbon emissions over the next two decades
with energy efficiency programmes in existing housing stock.
70. The Government has announced a feasibility
study on making the Thames Gateway a low or zero carbon development.
This would go some way to meeting our recommendations, and we
encourage the Government to be ambitious in its final proposals.
71. Our 2005 submission to the CCP Review
included a recommendation for the Government to formally consider,
by 2007, the role that Domestic Tradable Quotas (DTQs) might play
in achieving the deep cuts in carbon emissions required in the
longer term. Variations of the DTQ concept have taken many terms,
and more recently the SDC has taken to using the term `personal
carbon trading' to describe this strand of thinking.
72. We were disappointed to note that the
Climate Change Programme 2006 contained no reference to DTQs or
personal carbon trading, despite strong Ministerial interest.
This absence of formal recognition limits the extent to which
the research community can investigate this concept in more detail.
73. The SDC has reiterated its support for
a more detailed consideration of downstream personal carbon trading
as part of our submission to the Energy Review, and we continue
to take an active interest in this area. We are hoping to commission
some work looking at terminology, and how the concept can be better
communicated.
TRANSPORT
74. The SDC was cautiously optimistic of
the proposal for including both aviation and surface transport
in the EUETS. This would be a big step towards an economy-wide
emissions trading scheme.
75. However, we expressed concern that efforts
to secure this change would divert attention from the immediate
action that was require to limit growth in aviation and reduce
emissions from the transport sector. This concern has been validated
by the Government's reluctance to tackle these sectors in the
Review process.
76. The CCP 2006 document shows that greenhouse
gas emissions from the transport sector have increased by 12%
between 1990 and 2004. This increase is expected to continue—in
the absence of new measures greenhouse gas emissions are forecast
to be 15.6% above 1990 levels in 2010.
77. The CCP 2006 document included two new,
quantified transport measures:
— the Renewable Transport Fuel Obligation
(RTFO) (saves between 1-1.6 MtC depending on assumptions);
— further improvements to the fuel
efficiency of new vehicles (expected to save 0.1 MtC).
78. Existing measures include:
— Voluntary Agreement package including
graduated VED (estimated to save 2.3 MtC);
— Fuel duty escalator (in place between
1993 and 1999 and estimated to save 1.9 MtC).
New measures
79. The SDC supports the need to increase
the proportion of biofuels in the UK fuel mix in line with the
current proposals for the RTFO, provided three main safeguards
are in place:
— The verification procedures, which
accompany the mandatory reporting and proposed standards associated
with the RTFO, must be rigorous;
— They must cover complex issues such
as the potential for deforestation and societal impacts;
— The RTFO should be designed with
graduated incentives for lower carbon fuels from the outset to
provide an incentive for maximum carbon savings.
Change to existing measures
80. The SDC is pleased that Budget 2006
introduced a new higher band of VED for the most polluting new
vehicles. However, while the Government has widened the differential
between each band, the changes are completely insufficient to
stimulate the required level of behavioural change.
81. Research undertaken by the SDC as part
of our 2005 submission proposed a £300 gap should be created
between each band. We estimated that this would achieve carbon
savings of around 0.4-0.8 MtC, a substantial contribution to carbon
reduction targets.
82. The SDC therefore hopes to see a much
greater widening of the differential between VED bands in Budget
2007.
The need for further measures
83. Transport emissions would increase by
10.3% assuming the CCP 2006 saves 1.7 MtC.
84. It is therefore clear that even with
the proposed new measures, the increased contribution from the
transport sector is substantial—and this does not include
the contribution from international aviation. The SDC is therefore
surprised that greater consideration was not give to further reductions,
as outlined in our 2005 submission. We consider these below.
85. We recommended that a clear national
strategy on traffic reduction must be developed, which should
include demand management and behavioural change measures. Our
analysis suggested that around 0.5 MtC/year could be saved. The
cost-benefit analysis was very favourable. Further benefits include
reductions in congestion, improvements in air quality and increased
levels of physical activity.
86. We were very disappointed by the limited
consideration given in the Review process to behavioural change
measures, and the lack of quantification of the significant benefits
that could be achieved with the right impetus. We recommend, as
a matter of urgency, that the Government increases policy interventions
to stimulate behavioural change.
87. Adjusting road speed limits would also
reduce carbon emissions (our estimate was 1.5 MtC) and the SDC
suggested that a full assessment should be conducted across all
road types. There was no mention of the impact of speed on vehicle
efficiency during the Review process and we, again, recommend
that the Government gives this much greater consideration in the
future.
88. We welcome the mention of road pricing
in the CCP 2006 document. However, it is essential that road pricing
helps reduce emissions as well as congestion. Therefore, the scheme
must also consider distance travelled and vehicle efficiencies.
Aviation
89. The CCP 2006 document highlights that
UK aviation could contribute some 16 to 18 MtC per year by 2030,
and that the climate change impact of aircraft emissions are 2-4
times greater than that of carbon dioxide emissions alone.
90. There is a serious risk that, left unconstrained,
the growth in aviation emissions will eliminate any reductions
in carbon emissions elsewhere in the economy.
91. The SDC recognises that progress has
been made on efforts to include aviation into the EUETS. However,
we are concerned over the possibility of delay, and as a result
aviation not being included in the EUETS until 2012. This would
be a very serious policy failure—six more years of inaction
on aviation is simply unjustifiable.
92. We are also concerned over the treatment
of non-CO2 emissions, particularly the impact of cirrus
clouds and contrails. Greenhouse gas emissions from international
aviation are not assigned under the Kyoto Protocol, and this could
make aviation's inclusion in phase two of EUETS (2008-12) difficult.
93. One solution, which the SDC fully supports,
is a separate, closed trading scheme for aviation emissions. This
could operate as a test trial during 2008-12. Aviation's inclusion
in the wider EUETS could then be considered when decisions on
the next phase of the Kyoto Protocol are being made.
94. If attempts to include aviation in the
EUETS fail, we recommend immediate introduction of an emissions
charge on domestic and international flights.
95. Recognising that there are substantial
climate change impacts associated with non-CO2 emissions,
the precautionary principle means that scientific uncertainty
should not be used as a reason for inaction. Demand management
measures are needed immediately. Waiting for quantification of
non-CO2 impacts to whilst continuing with aviation
expansion is not acceptable.
96. Therefore, the Government must reconsider
its aviation expansion plans. It should also consider the removal
of the all subsidies to the airline industry. For example, including
VAT on domestic flights and putting an end to duty free goods
for flights outside the EU.
97. The SDC will be doing further work on
aviation during 2006 as part of our contribution to the Government's
Progress Report on the Aviation White Paper.
PUBLIC SECTOR
98. Our central recommendation in this area
was for a carbon neutral public sector by 2020. However, we now
believe that with the use of offsetting it would be possible for
the Government to achieve carbon neutrality across the whole public
sector by 2015, and 2012 for the central Government estate. Similar
recommendations were made by the Sustainable Consumption Roundtable
in May 2006. Offsetting would attach a price to carbon consumption,
which should help stimulate public sector organisations into reducing
their emissions.
99. The SDC's goal for the public sector
is one of leadership, where public money is used to help encourage
more sustainable products and services through engaged procurement.
100. We are therefore pleased to note the
Government's acceptance of our 2012 recommendation for a carbon
neutral Government estate. However, there is still no commitment
to extend carbon neutrality to the whole of the public sector,
such as schools, hospitals, and the Armed Forces.
101. The Government also announced that
the central Government estate would be expected to deliver a 30%
reduction in carbon emissions by 2020. The SDC believes that this
target is not commensurate with the challenge at hand, and could
end up being lower than the carbon reductions required from the
economy overall. It therefore fails the leadership test.
AGRICULTURE, FORESTRY
AND LAND
MANAGEMENT
102. The SDC made only a limited input in
this area due to the absence of any specialist resource. This
has since been rectified with the arrival of our Natural Resources
team.
103. The SDC welcomes the increasing Government
recognition that land management, in particular with regard to
agriculture and forestry, has a significant role to play within
the climate change agenda.
104. It is now imperative that this is translated
into concrete actions, with greater clarity on the responsibility
of different parties in delivering these.
105. The "polluter pays principle"
follows that farmers should be responsible for reducing their
greenhouse gas emissions. However, as with other sectors the Government
has an important role to play in identifying the extent to which
this is possible and in helping the industry to adopt good practice
that is affordable and effective. Moreover, where the land manager
goes beyond their required greenhouse gas reductions and provides
a public "good", for example through soil carbon storage,
this service must be fully recognised and rewarded.
106. Quantified information on the extent
to which greenhouse gas emissions can be reduced and the specific
land use measures that can achieve this remains limited. Where
uncertainty exists, for example around soil carbon, then research
in this area and clear communication of the results must be a
priority.
107. The new England Rural Delivery Plan
must include measures to tackle climate change at the earliest
possible stage. In accordance with the "precautionary principle",
it is better to include an imperfect set of measures within the
environmental stewardship schemes now and to refine these later,
than to wait for perfect knowledge before introducing the theme.
It is also imperative that Government sends the right signals
that it is serious about all sectors playing their role to address
the challenges posed by climate change.
108. The SDC believes that all fiscal, regulatory
and voluntary options for addressing climate change should be
explored. However, as stated in paragraph 16, we believe that
economy-wide emissions trading is the policy framework within
which action on climate change should take place.
109. We therefore believe that the inclusion
of the agriculture sector in emissions trading should be a top
priority, whether as part of the EUETS or the UK-based Energy
Performance Commitment scheme.
110. Biomass has the potential to play a
significant role in the UK's efforts to address our energy needs
sustainably. We see a clear role for Government in facilitating
the release of this potential and we welcome the Government's
response to the Biomass Taskforce and look forward to rapid implementation.
111. However, energy crops must not be overly
promoted so as to disincentivise food production. The SDC firmly
believes that UK agriculture still has a role to play in food
provision, particularly when considering the global ecologicalfootprint
associated with the alternative of importing all our food.
- The Government needs to ensure that when considering
the potential value of energy crops it gives proper consideration
to all aspects of their sustainability. Our recent work on biofuels*
sets out a number of concerns we have in this respect. In particular,
detailed consideration needs to be given to the social and biodiversity
impacts of energy crops.
*SDC's response to the Department for Transport on
Biofuels and the Renewable Transport Fuels Obligation, May 2006.
113. Whilst energy crops will have a role
to play, these must not be promoted at the expense of energy efficiency
and demand management measures which must continue to be the ultimate
goal. Similarly, we must use waste products where possible as
a source of feedstock.
114. Government must also give regard to
the use of the energy crops as some, for example local heat production,
will be more sustainable than others. There must be clear links
made between the use of energy crops and the carbon savings made,
based upon a full life cycle analysis.
115. The SDC is keen to remain involved
in addressing the challenges posed by the climate change and land
use agenda, and we view the Rural Climate Change Forum as a good
means through which to do this.
July 2006
1 The term "Government" is used to refer
to the UK Government in this document unless otherwise stated. Back
2
SDC (2005). Climate Change Programme Review: the submission
of the Sustainable Development Commission. Back
3
Defra (2006). Synthesis of Climate Change Policy Evaluations,
p 23. Back
4
SDC (2006). Meeting the challenge: energy policy for the 21st
Century. Back
5
SDC (2006). The role of nuclear power in a low carbon economy. Back
6
DTI (2005). Digest of UK Energy Statistics. Back
7
Dynamic Demand is a not-for-profit organisation supported by a
charitable grant from the Esmée Fairbairn Foundation. Back
8
Detailed recommendations can be found in our publication "Stock
Take: delivering improvements to existing housing" (2006);
a summary can also be found in our submission to the 2006 Energy
Review. Back
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