Memorandum submitted by Friends of the
Earth England, Wales and Northern Ireland
Friends of the Earth welcomes the Environmental
Audit Committee's inquiry into this vitally important subject.
Climate change is the greatest threat the world
faces. Friends of the Earth believes that annual cuts of 3% in
the UK's total emissions of carbon dioxide are necessary, as the
UK's contribution to keeping global temperature increases below
2°C. We are leading a campaign for a Climate Change Bill
which would:
— require the Government to put
policies in place to deliver 3% year-on-year cuts in emissions;
— require annual reports to Parliament;
and
— provide for corrective action
if annual targets were not met.
This clear leadership role and clarity over
what will be achieved would provide industry and individuals with
the certainty they need to take action.
Reductions are required from the UK economy
as a whole and, as a key sector, reductions are required from
transport. However with current policies emissions have risen,
and are set to rise further. The Government's Climate Change Programme
review forecasts end-user transport emissions rising by 22% from
1990 to 2020 and by almost 19% from 2000-20.[1]
This is just one of several forecasts from different Government
departments. However two common factors of all the forecasts are
that transport makes a major contribution to total UK emissions,
and that emissions from the sector will rise in the future.
This means that major changes in transport policies
will be vital for achieving the Government's short- and long-term
emissions targets, and for making the 3% year-on-year cuts that
Friends of the Earth believes are necessary.
The key points we make in our submission are:
— There is little evidence to
date of a coherent department-wide strategy to reduce emissions.
— The Department for Transport
(DfT) is falling well short of the targets it has set for reducing
emissions.
— Big cuts in carbon emissions
from transport are possible by 2020-30 provided that action is
taken now to put us on the right path. Major policy change is
needed now so that by 2010, the Government should have both started
to cut emissions and also be on the right path for the longer
term.
IS THE
DFT'S CARBON
REDUCTION TARGET
UNDERPINNED BY
A COHERENT
STRATEGY STRETCHING
ACROSS THE
DEPARTMENT'S
ENTIRE RANGE
OF ACTIVITIES?
The first point to clarify is that we do not
believe that the DfT has a specific carbon reduction target, and
it should be given one. The DfT has joint responsibility for the
Government's Public Service Agreement on reducing carbon emissions
but, like other Whitehall departments, has no department-wide
target to indicate the share of reductions it is expected to deliver.
It is critical that this target should include emissions from
aviation.
The now overdue publication of the Government's
Climate Change Programme Review will give the DfT the opportunity
to demonstrate that it does have a coherent department-wide strategy
to reduce emissions. However at the moment we do not see much
evidence of such a strategy. Three examples of this lack of a
joined-up strategy are:
— the continuing road-building
programme;
— viewing road-pricing simply
as a tool to tackle congestion; and
— the support for aviation expansion.
These are examples either of policies that are
leading to increases in carbon emissions, or of key policies that
are not acting to reduce carbon emissions.
Road building
Despite many statements from the Government,
from the Prime Minister down, that we cannot build our way out
of congestion, the Government is still persisting with a large-scale
road building programme.
Road-building often leads to large increases
in traffic levels, locking us in to a carbon-intensive pattern
of development. Answers to Parliamentary questions last year revealed
that roads in the Government's Targeted Programme of Improvements
(TPI) would result in traffic increases of 23%. However information
on traffic increases was not available for over one-third of schemes.[2]
Traffic increases on this scale will make it much harder to cut
emissions in the future.
The Government seems to have very little information
on the carbon impacts of these schemes: no data on forecast CO2
increases was available for less than half of schemes.[3]
There is also strong pressure for road-building
coming from the English regions. At the end of January, the regions
submitted to the DfT proposals for spending their Regional Funding
Allocation (RFA) for the period 2006-16. Analysis of the submissions
has revealed a very heavy bias towards road-building, with 72%
of the budget earmarked for roads, and only 24% for public transport.
Two regions—the South East and the East Midlands—want
to spend 95% of their budget on roads.
Road pricing
The Secretary of State has made clear on many
occasions his belief in the need to move towards a nationwide
system of road pricing and to make significant progress in the
course of this Parliament. However despite the clear importance
accorded to road pricing, the DfT seems to regard it as a measure
to be used simply to tackle congestion. Achieving environmental
benefits is regarded as almost a by-product. However research
has shown that a revenue-raising road pricing system could reduce
carbon emissions from road transport by 8% whereas a revenue-neutral
system, under which road pricing charges would be offset by reductions
in fuel tax or VED, would increase emissions by 5%.[4]
Clearly design is crucial and so any road-pricing system should
be designed to cut carbon emissions as well as tackle congestion.
The fact that this is not currently the case is further evidence
of the lack of a coherent department-wide strategy to cut emissions.
Support for aviation expansion
Aviation is a rogue sector even within the context
of transport. DfT is pressing ahead with an expansion strategy
which would again lock us into a carbon-intensive pattern of development
and result in huge increases in emissions. As your Committee has
previously noted "if aviation emissions increase on the
scale predicted by the DfT, the UK's 60% carbon emission reduction
target . . . will become meaningless and unachievable".[5]
The scale of the problem was further thrown into relief by research
for Friends of the Earth by the respected Tyndall Centre for Climate
Change Research, published last year. This concluded that, if
the UK was to put itself on a contraction-and-convergence path
to stabilise global carbon dioxide levels at 450 parts per million
by volume (the level currently believed to be necessary to avoid
the worst impacts of climate change) then continuing aviation
growth could see the sector taking up the entire UK carbon budget
by 2037, with all other sectors of the economy having to be carbon-neutral.[6]
The Government's aviation policy is out-of-line
with its climate change policy. The two must be reconciled. When
it published its Air Transport White Paper in December 2003, the
Government stated that it "will monitor and evaluate the
effectiveness and impact of the policies set out in this White
Paper [and] will report in 2006 on progress".[7]
Friends of the Earth believes that the Government should conduct
and publish an aviation policy review, rather than simply a progress
report. However, the Department for Transport is sticking firmly
to the latter.
A distinct flaw of the policy process leading
up to the publication of the White Paper was the failure to adequately
integrate air transport/airport development and climate change
policy into a single coherent approach.
Friends of the Earth is concerned about the
Government's preferred policy approach for responding to aviation
emissions: inclusion within the EU Emissions Trading Scheme (ETS),
and about its impact on policy making. The aviation industry advocates
ETS as its favoured measure because it believes that ETS of all
the possible measures is the one least likely to mean they have
to change. It is already advocating large allocations of emissions
for their own sector, in contradiction with Government policy
that the polluter should pay. There are also considerable uncertainties
surrounding ETS and its potential impact, such as the choice of
base year, the level of the emissions cap, how permits will be
allocated, which flights to and from EU airports should be included.
This uncertainty means that there is a distinct
possibility that the problems of the policy process leading up
to the 2003 White Paper will be repeated this year. That is, the
uncertainty surrounding the actual outcome of its preferred mechanism
to respond to aviation emissions growth (inclusion in the EU ETS)
will be allowed to continue without resolution until after the
White Paper progress report/policy review. It is, of course, much
more likely that the White Paper review will continue to support
the very substantial expansion of air transport and its emissions
if it is not required to identify, and then integrate, the adequacy
or not of the "emissions trading" solution over the
same timescale—to 2030.
Consequently, Friends of the Earth suggests
that the Government be pressed to adequately integrate these two
policy streams within the White Paper review, and that in particular
the government be required, from the various forecasting models
now available to them, to identify what will be the outcome in
terms of direct aviation emissions in 2030 of pursuing their approach
to forecast air passenger demand—in the context of the wider
requirement on the UK to reduce its overall carbon dioxide emissions.
WHAT PROGRESS
IS THE
DEPARTMENT FOR
TRANSPORT MAKING
AGAINST KEY
CARBON REDUCTION
TARGETS OR
FORECASTS?
The Department for Transport (DfT) does have
policies in place to reduce carbon emissions. However, as is explained
below, these are performing less well than expected, and are in
any case swamped by policies or lack of policies elsewhere—the
net effect being carbon increases. The overall impact of this
is that DfT is falling well short of its targets and forecasts
for reducing emissions.
The key predictions and forecasts are:
— 10 Year Plan for Transport
— greener cars: the Government anticipated
cuts of 4MtC from the voluntary agreement between the EU and car
manufacturers;[8]
— behavioural change: the Government
anticipated cuts of 1.6MtC from measures in the 10 Year Plan.
— Powering Future Vehicles—that
by 2012, 10% of new cars sold will have emissions of less than
100 grammes of carbon dioxide per kilometre (g/km CO2)
10 Year Plan forecast for greener cars
The Government anticipated emissions cuts of
4MtC from the voluntary agreement reached between the EU and car
manufacturers. However the then Transport Minister David Jamieson
MP told the Transport Committee in 2004 that this was now regarded
as over-ambitious and that actual emissions cuts were now more
likely to be around 2.6MtC.[9]
He blamed the shortfall on the UK consumer's preference for larger
cars compared to other EU countries.
The target agreed by the EU and car manufacturers
in the late 1990s was that by 2008, new cars sold in Member States
should on average emit no more than 140 grammes of carbon dioxide
per kilometre. Average emissions of new cars sold in the UK have
fallen from 189.8 g/km CO2 in 1997 to 171.4 g/km CO2
in 2004.[10]
It is now widely accepted that the voluntary target will not be
achieved: in the UK we are two-thirds of the way through the target
period, we have made one-third of the progress needed, and the
rate of progress is slowing down.
The failure to reduce emissions reflects in
part the advertising policy of car makers. Analysis carried out
by Friends of the Earth last year showed that over half of the
adverts in national newspapers for the first two weeks of the
new "55" registration in September were for cars in
Vehicle Excise Duty (VED) bands E and F—the most polluting
cars on the road. By contrast, only 3% of the adverts were cars
in VED bands A and B—the least polluting cars on the road.[11]
However the Government could do much more to
influence consumer choice. The current VED bands provide very
little incentive for buyers to choose a less polluting car. The
difference between VED paid for the most and least polluting cars
is £95 for diesels, £100 for petrol cars and £105
for alternative-fuelled cars, with a maximum gap between bands
of £30. In our submission to the 2005 Pre-Budget, Friends
of the Earth recommended cutting VED for the least-polluting cars
to zero immediately, and raising it for the most-polluting cars
to £600 by March 2008.[12]
Changes to VED along these lines are gaining wide support: the
RAC Foundation has recently called for higher tax on gas guzzlers.
The gaps between the bands in March 2008 would be £100. Evidence
from research for the DfT shows that a gap between VED bands of
£100 would persuade 47% of new car buyers to choose a less-polluting
vehicle.[13]
Buying a more fuel-efficient car would save
drivers a great deal in fuel costs. Last year, when fuel prices
reached £1 a litre, Friends of the Earth calculated that,
on the basis of driving 12,000 miles per year:
— a driver wanting a small car
could save up to £460 a year in fuel costs by choosing a
Citroen C2 rather than a Ford Fiesta;
— a driver wanting a family car
could save up to £630 a year in fuel costs by choosing a
Toyota Prius rather than a Ford Mondeo; and
— a driver wanting a 4x4 could
save over £1,500 a year in fuel costs by choosing a Toyota
RAV4 rather than a Land Rover Discovery.
10 Year Plan forecast for behavioural change
The Government estimated that measures in its
10 Year Plan would reduce carbon emissions by around 1.6 MtC by
2010. The then Transport Minister David Jamieson estimated in
2004 that this target would be missed by around 25%, with cuts
of around 1.2 MtC expected.[14]
The main reason for this expected shortfall
is the continuing rise in traffic levels. Despite the Deputy Prime
Minister saying in 1997 that he would have failed if the number
of journeys by car had not fallen within five years, traffic levels
have risen by over 10% since the current Government came to power.
The most recent Government forecasts show continuing traffic growth:
23-29% higher than 2000 levels by 2010; 29-38% higher by 2015
and 38-53% higher by 2025.[15]
Continuing traffic growth will make achieving medium- to long-term
carbon emissions targets very difficult.
Friends of the Earth believes that two key reasons
for this continuing traffic growth are:
— the failure to invest adequately
in reducing the need to travel and in providing high quality alternatives
to car use; and
— continuing trends in the cost
of motoring and public transport use: motoring is still cheaper
in real terms than when the current government came to power,
but bus and train travel is more expensive.
Until action is taken to increase investment
in reducing the need to travel and in improving alternatives to
car use, with funding shifting from road-building which tends
to lead to increased car use, then traffic levels and carbon emissions
will continue to rise. Details of the measures needed are given
below.
Powering Future Vehicles target
In its 2004 Powering Future Vehicles strategy,
the Government set the target that by 2012, 10% of new cars sold
will have emissions of less than 100g CO2/km. It is
too early to assess progress, but the scale of the challenge is
shown by the figures for 2004: a total of 481 vehicles sold had
emissions of less than 100g CO2/km out of total sales
of over 2.5 million—less than 0.02%.[16]
Friends of the Earth believes that tough action will be needed
if the target is to be met including mandatory new EU emissions
targets to force the pace of technological development by car
manufacturers; and greater fiscal incentives for the purchase
of greener cars, as outlined above.
WHAT REALISTICALLY
COULD THE
DFT ACHIEVE
BY 2010 AND
2020 IN TERMS
OF REDUCING
TRANSPORT-RELATED
CARBON EMISSIONS,
AND WHAT
ROLE SHOULD
DEMAND MANAGEMENT
PLAY IN
DOING SO?
WHAT SPECIFIC
STEPS SHOULD
THE DEPARTMENT
NOW TAKE
TO REDUCE
TRANSPORT CARBON
EMISSIONS AND
CONGESTION OVER
THE NEXT
DECADE?
The DfT's ambitions for 2010 and 2020 must be
set within the context of the need for 3% year-on-year cuts in
overall carbon emissions. As explained above, the DfT must play
a key role in delivering these cuts. This must be the department's
priority over the next decade. The measures we advocate to achieve
this will also help cut congestion.
Recent research for the DfT shows the scale
of ambition possible. "Looking over the horizon" produced
by the Bartlett School for Planning and Halcrow Group shows that
carbon emissions from transport can be cut to 60% below 1990 levels
by 2030.[17]
Friends of the Earth believes that the Government
must push to get all the emissions cuts possible from technology,
such as greener cars and improved or alternative fuels. However
this will not be enough on its own, and demand management measures
to change how and how much people travel are also essential. This
is echoed by the "Looking over the horizon" report which
concluded that "the 60% CO2 reduction target
in 2030 can be achieved by a combination of strong behavioural
change and strong technological innovation. But it is in travel
behaviour that the real change must take place, and this should
be implemented at the earliest possible occasion".[18]
This sets a very clear agenda for the Government, and for DfT
in particular, although action will be needed from other departments
as well (notably the Treasury and the Office of the Deputy Prime
Minister). Friends of the Earth believes that the issue is now
whether the Government has the political will to put in place
the measures needed. The Government seems willing to put in place
the technological measures needed, but not to take the action
necessary to get the changes needed in people's travel behaviour.
By 2010 DfT should have put policies in place
which will be:
— firstly, already delivering
emissions reductions; and
— secondly putting us on a path
to make the emissions reductions possible in the longer-term.
Over the next decade, the Department for Transport
must:
— Fully embrace the need for tough
action to reduce carbon emissions, and make this the key determinant
of policy.
— Agree a sectoral target for
reductions to be made from transport.
— Accept that technology alone
will not be enough to deliver the cuts needed, and that measures
to change people's travel behaviour are also needed.
— Work proactively to build public
acceptability of the need for cuts in transport emissions and
of the measures needed.
— Work with other Government departments,
notably the Treasury and ODPM, to ensure that policies to cut
transport emissions are integrated and effective.
Specific measures the DfT should take include:
— Use next year's Comprehensive
Spending Review to ensure that spending on measures to cut carbon
emissions is prioritised. This should focus on measures to reduce
the need to travel, and to provide high-quality alternatives to
private car use. Examples of measures needed are given in the
report "Paying for Better Transport" produced by the
Way to Go campaign for the 2004 Spending Review.[19]
These include:
— a cycle friendly road network and
cycle training for all;
— safe routes to schools;
— lower speed limits: 20mph default
in residential streets;
— increased funding for public transport,
particularly in rural areas;
— streets, lanes and paths in good
condition and pleasant for walking;
— quality standards for bus and rail
services;
— purchase incentives for smaller,
cleaner vehicles;
— funding for rail freight projects;
— services and facilities close to
people so that they don't need to drive; and
— pay-as-you-go road pricing.
The Comprehensive Spending Review should also
identify cuts in expenditure on road-building. "Paying for
Better Transport" identified possible cuts of over £8
billion that could be made.
— Ensure that any national road
pricing scheme that is implemented is designed to cut carbon emissions
rather than simply to tackle congestion. Road pricing should increase
the cost of motoring, with additional revenue ring-fenced for
spending on reducing the need to travel or on improving alternatives
to the car.
— Push for a tough follow-up EU
emissions standard for new vehicles to replace the current voluntary
agreement. Friends of the Earth believes that new cars should
emit no more than an average of 120 g/km CO2 by 2012.
This should be a mandatory target rather than a voluntary agreement,
and should be met entirely by action from the car industry: emissions
cuts from fuel-related measures, such as greater use of biofuels,
should be seen as additional to this, rather than contributing
to it. Figures from the European Federation for Transport &
Environment show that the costs of meeting such a standard would
be outweighed by the savings made by drivers from using less fuel.
Meeting the 120 g/km CO2 standard would cost less than
600 Euros per vehicle, whereas pre-tax fuel savings would be between
625 and 940 Euros per vehicle, depending on the cost of fuel.
The savings to the consumer would be much greater when taxes are
taken into account.[20]
— Continue to promote the use
of biofuels but ensure that a tough accreditation scheme is put
in place to ensure that biofuel producers do not damage the countryside
by intensifying production at the expense of wildlife, destroy
rainforests through imports of palm oil or harm wildlife overseas
by using oils derived from GM-crops.
— Put in place the measures needed
to tackle aviation emissions. The policy changes needed include:
— revision of the Air Transport White
Paper to put a moratorium on new airport capacity;
— the use of fiscal measures to reduce
the growth in demand for flying. As an initial step, Air Passenger
Duty should be increased; and
— ensure that the inclusion of aviation
in ETS is environmentally effective. However this should not be
seen as a substitute for fiscal measures.
March 2006
1 DEFRA (2004) "Review of the UK Climate Change
Programme-consultation paper" section 3 table 6. Back
2
Hansard 13 July 2005. Back
3
Hansard 13 July 2005. Back
4
IPPR (2003) "Putting the brakes on climate change". Back
5
Environmental Audit Committee (2004) "Pre-Budget Report
2003: aviation follow-up" para 50. Back
6
Tyndall Centre for Friends of the Earth Trust (2005) "Growth
scenarios for EU and UK aviation: contradictions with climate
policy". Back
7
Department for Transport (2003) "The Future of Air Transport"
para 12.28. Back
8
DETR (2000) "Transport 2010: the 10 year plan" para
8.9. Back
9
Transport Committee (2004) "Cars of the future" para
26. Back
10
SMMT (2005) "UK new car registrations by CO2
performance-2005 edition". Back
11
See Friends of the Earth press release 10 November 2005
"Government and industry must do more on greener cars". Back
12
Friends of the Earth (2005) "Tackling climate change through
the Budget". Back
13
DfT (2004) "Assessing the impact of graduated Vehicle Excise
Duty-quantitative research" figure 17. Back
14
Transport Committee (2004) "Cars of the future" para
22. Back
15
DfT (2005) "The Future of Transport: Modelling and Analysis"
Note that the figures are for England only. Back
16
DfT (2005) "Powering Future Vehicles strategy: third annual
report" para 2.1. Back
17
Bartlett School for Planning and Halcrow Group for DfT (2006)
"Looking over the horizon". Back
18
Bartlett School for Planning and Halcrow Group for DfT (2006)
"Looking over the horizon" Executive Summary section
7. Back
19
Way to Go campaign (2004) "Paying for Better Transport"
available at http://www.foe.co.uk/resource/reports/paying_for_better_transport.pdf Back
20
European Federation for Transport and Environment (T&E)
(2005) "No regrets: the cost-effectiveness of achieving 120g/km
average CO2 emissions from new cars in Europe by 2012". Back
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