Select Committee on Trade and Industry Written Evidence


Memorandum by the Royal Society for the Protection of Birds


  1.  The RSPB is Europe's largest wildlife charity with over one million members. We manage one of the largest conservation estates in the UK with 188 nature reserves, covering more than 127,000 hectares. The RSPB is part of the BirdLife International partnership, a global alliance of independent national conservation organisations working in more than 100 countries worldwide.

  2.  We consider that human-induced climate change poses the biggest long-term threat to global biodiversity. A paper in Nature by a large group of scientists (including one from the RSPB) indicates that in sample regions covering about 20% of the Earth's land surface "15-37% of species in our sample of regions and taxa will be `committed to extinction' as a result of mid-range climate warming scenarios for 2050." [116]

  3.  Indeed, papers presented at the scientific conference convened by DEFRA, at the Hadley Centre in February 2005, indicated that the impacts of climate change on both people and wildlife are likely to be worse than anticipated, and occur at lower levels of change than previously thought. These findings were compounded by reports that cataclysmic events, such as melting of the Greenland ice sheet, the West Antarctic ice sheets and turn-off of the North Atlantic thermohaline circulation, appear more likely. Furthermore, there was widespread agreement that the climate sensitivity is likely to be higher than previously anticipated and that terrestrial sinks for carbon dioxide were likely to become sources at lower temperatures.

  4.  Therefore, whilst we have supported the UK's emissions reduction target for 2050, announced in the 2003 Energy White Paper, we are concerned that recent scientific evidence indicates that a more stringent target may be needed. The UK may need to reduce emissions by as much as 80% by 2050. The Government's Energy Review should recognise this fact.

  5.  Whether the UK's 2050 target is a 60% cut in carbon dioxide emissions by 2050 or more, the anthropogenic greenhouse gas emissions that cause climate change need to be cut hard and rapidly and we support policies and measures that do so. UK energy policy clearly has the central role in ensuring that we cut emissions to the extent required by the science.

  6.  We welcomed the 2003 Energy White Paper, especially the fact that it placed mitigation of climate change as the central objective of UK energy policy. The analysis behind, and reflected in, the 2003 White Paper was thorough and gave a clear, well-researched view of the way forward to achieving the UK's long term target. Therefore, although we agree with the Government's assertion in the 2006 Energy Review consultation that some energy trends have changed since 2003, we think that most of these changes were foreseen and dealt with by the 2003 Energy Review. We did not believe then that competition alone, either in the UK or Europe, would deliver either low prices, or energy security, or adequate levels of carbon reduction. On the contrary, it was clear then, and is demonstrated now, that competition would deliver the "right" prices, which might spike very high, owing to energy insecurities caused by constraints or shocks on both the supply and demand sides. Supply constraints were inevitable in a market context where price signals are too weak, or rise too suddenly, to enable risk-averse actors to respond with the timely provision of new generation plant or transmission infrastructure. Demand shocks were inevitable in a world undergoing rapid economic growth, especially in China and India. At the same time, it was inevitable in a market where carbon was priced only partially and in a rudimentary fashion, that carbon reductions of the levels needed would not be achieved. Paradoxically, the recent, steep rises in fossil fuel prices partially correct this situation, tending to lower carbon dioxide emissions.

  7.  Here we make some of the general points about the new consultation, its assumptions, and the way in which we see energy policy developing. In general, our view is that, rather than adopting a radically different approach to achieving existing energy policy objectives, the UK should seek to strengthen the existing suite of policies to make them more effective. We believe that this view would be supported by full and objective analysis of the environmental, social and economic evidence, of the kind that was conducted by the Performance and Innovation Unit in preparation for the 2003 Energy White Paper, and which led to the establishment of the current suite of policies. We are concerned that the timetable for the current Energy Review will not allow for such analysis, and that it would be imprudent to consider changing policy without it.

  8.  As a general point, the progressive strengthening of existing policies, rather than the introduction of new support measures for particular technologies, will have the effect not only of increasing energy efficiency and the uptake of renewable technologies, but also of improving both strategic and operational energy security. There is nothing so secure as not using energy in the first place. And for energy that must be used, there is nothing more secure than supplies that are both indigenous and renewable.


  9.  The Energy Review consultation appears to suggest that the UK should be prescriptive about supporting particular electricity generation technologies, notably nuclear power. This would be in contrast to the Government's general position that market mechanisms are the preferred type of policy instrument and that markets should be framed so as give the most cost effective, "technology-blind" solutions, as in the case of the EU Emissions Trading Scheme (EU ETS). Indeed, the 2003 Energy White Paper put the EU ETS at the heart of UK energy policy. In this context, we consider that deliberately singling out any specific technology for special treatment, particularly if it is expensive and potentially dangerous, would be unjustifiable, not just in economic terms but in broader policy terms too. For this and a number of other reasons, we do not consider that new nuclear generation should be offered special treatment by government.

  10.  In our opinion, the mix of generating technologies, and the balance of effort between energy saving and reduced-carbon generation, should be driven by the EU ETS (or other generalised policy instrument) and by policies focused specifically on energy efficiency (eg the energy efficiency commitment) and renewable energy (eg the Renewables Obligation). Indeed, because the EU ETS covers all large generating plant, it should ultimately drive all generating technologies, including renewables, down the most economic low carbon path. If particular technologies are cost competitive or nearly so, then the EU ETS should encourage them. That is the point of the instrument.

  11.  We appreciate that currently, in the early life of the EU ETS and with a very lax cap on the traded sector, the instrument is likely to encourage little carbon reduction. However, this a problem of policy delivery, not of policy. The defect can be rectified by significantly tightening the cap in successive phases of the scheme and perhaps by lengthening the duration of each phase, or at least flagging in advance the likely allocations for successive phases, so as to give greater investment certainty, as has been done with the Renewables Obligation. Renewables and energy efficiency policies could also be strengthened.

  12.  In the shorter term, before the EU ETS begins to have a large effect, there might be a case for support mechanisms to bring on groups of technologies, notably carbon capture and sequestration (CCS), just as the Renewables Obligation is intended to promote a wide range of renewable technologies. We have not been supportive of CCS, in part because we fear that money used to support the development and deployment of such technologies would be diverted away from truly renewable technologies, potentially slowing their development and deployment. Nevertheless, we appreciate that there could be a case for CCS as an interim measure and that there might therefore be a need to support it.

  13.  We note, however, that the Intergovernmental Panel on Climate Change's (IPCC) authoritative report on CCS published late in 2005, estimates that "CCS systems begin to deploy at a significant level when CO2 prices begin to reach approximately 25-30 US$/tCO2". In this case, the EU ETS, even with its current cap, should support CCS because the current EU allowance price is in this price range, at about €27/tCO2. In the next phase of the EU ETS, assuming the cap is tighter, CCS should be completely economically viable and a large-scale support measure for it thus seems unnecessary, although limited support might be appropriate. One means of providing such limited support might be that recommended by the House of Commons Science & Technology Committee in February 2006 which proposed that: "Government makes capture readiness a requirement for statutory licensing of all new fossil fuel plant. This would compel the developer to demonstrate that consideration has been given in the planning and design of the plant to facilitating subsequent addition of suitable carbon dioxide capture technology, as and when it becomes available and economic". This course of action has the advantage that it would not necessarily divert resources away from renewable technologies.


  14.  An underlying assumption in the Energy Review consultation appears to be that demand for energy will rise inexorably if UK GDP continues to increase. Particularly given the ongoing shift in our economy away from heavy industry and towards the commercial and service sectors, we see no good reason why overall energy demand should necessarily grow in direct proportion to GDP, even with continuing growth in living standards. Indeed, some parts of the consultation bear out this presumption, for example the observation that energy consumption has increased by just 2% since 1997 despite a 21% increase in GDP. At present, projections are based on underlying oil prices assumed at $20-$50/bbl. These ranges are clearly in appropriate for scenarios extending to 2020 or beyond. Oil prices of at least $200/bbl must be considered.

  15.  In addition, we consider that demand-side management of energy could and should be employed to reverse the forecast, increasing trend in energy consumption. We consider that the central tenet of any energy policy aimed a limiting carbon dioxide emissions and maximising energy security at the lowest cost should be the conservation of energy and the limitation of demand.

  16.  We note that although demand for energy has increased since 1990 this growth has been restricted to two main sectors (transport and domestic) with a decline in industrial demand and a small increase in the service sector. (see table below, from the 2006 updated energy projections) This data clearly indicates where the main focus of demand management should be: the transport and domestic sectors.

DomesticTransport ServicesIndustry
19904149 1938
19954350 2136
20004755 2233
20044958 2133
Change from 199019.6% 18.1%8.0%-13.9%

  Source: UK Energy and CO2 emission projections, Updated projections to 2010, DTI, February 2006.


  17.  Although much of the Energy Review rightly focuses on electricity generation, one third of our energy comes from oil, of which 70% is used for transport. Indeed, transport is the largest emissions sector (by end user). It is the only sector that has grown consistently since 1990 and it is forecast to continue to grow, at roughly 1% per year for road transport and between 5% and 6% for aviation, in spite of continuous and significant improvements in aircraft energy efficiency. Any effective longer-term energy policy must therefore pay much more attention to transport. If we are to cut UK carbon dioxide emissions by 60%, or more, by 2050 with little or no cut in transport-related emissions then other sectors, including electricity generation, will need to cut their emissions to almost zero.


  18.  Successive UK governments have set carbon reduction targets for individual policy instruments. Currently, the government sets the targets for almost all instruments on the basis of projections. Emissions or activities that give rise to them, such as energy use, are forecast and then an absolute amount is subtracted from the projection. This is a fundamentally different basis for target setting than that used to determine our 20% national and 12.5% international targets, which are couched in terms of a percentage emission reduction from a fixed level of emissions in a base year. In other words, science-based targets require reductions to lower absolute levels of emissions, which is what matters for tackling climate change.

  19.  Whilst setting targets on the basis of projections has a number of practical, administrative advantages, it also has a number of fundamental disadvantages. In particular, because it is determined in a different way, it does not necessarily deliver percentage emission reductions from a fixed baseline and it is thus an unreliable way of meeting our overall national and international targets. Clearly, if projections are revised upwards and the absolute emission reduction subtracted from them remain the same then neither the percentage target cuts nor, therefore, the lower absolute levels of emissions will be met. This difficultly was highlighted recently in determining the UK's first National Allocation Plan for the EU ETS when projections were revised upwards twice in the traded sector, eventually leading to a much higher absolute allocation (that will lead to more emissions) but which could rightly, if rather misleadingly, be claimed to represent a bigger percentage reduction from business-as-usual emissions. Since, from the point of view of tackling climate change, it is the absolute level of carbon emissions that counts, absolute deductions from movable baselines are ineffective and misleading.

  20.  An additional difficulty with employing projections as a basis for setting targets for particular policy instruments is that they are inherently unreliable and subject to significant uncertainty, again making it hard to determine their effect upon percentage targets. Another difficulty with employing movable projections as baselines is that it is quite simply impossible, even for experts, to communicate clearly about what has happened or is likely to happen. Never in our experience has an environmental policy instrument created more confusion than the first UK National Allocation Plan.

  21.  We therefore consider that it is essential for government to adopt a better means of setting both short and long-term targets which gives much greater confidence in their being attained. In our view, the best way of doing so would be to set absolute limits on the amount of carbon that can be released over a given period of time, either by sector or for the economy as a whole, and to design policies to meet those targets (stay within those limits).

  22.  To meet the overall EU target of staying below a two degrees Celsius mean global temperature rise, it will be necessary to be on one of a limited number of emissions pathways that define a global carbon budget. This concept should be extended downwards to regional and national levels. The budgets would be informed by projections but not defined by them. They would be set on the basis of the target that, from a scientific point of view, needs to be attained. For example, because UK emissions of carbon dioxide were 161.4 MtC in 1990, the UK budget for 2010 would be 129.1 MtC (a 20% reduction) and the budget for 2050 would be 64.6 MtC (a 60%) reduction. To be effective, an annual, declining budget should be set, probably with trading being allowed between annual budgets.

  23.  This is not a new concept. Indeed, both the Kyoto Protocol's cap and trade scheme and the EU Emissions Trading Scheme employ annual emission budgets, averaged over a period of time. Constraining all emissions in this way will, however, require a shift in the way in which we all think about our use of energy and poses a significant political challenge. On the other hand, if we do not keep within an emission budget we will not avoid dangerous climate change.


  24.  Finally, we consider that the UK's long term emission reduction target, or a more stringent one, can be met by a combination of demand side action coupled with renewable technologies, perhaps augmented in the medium term by carbon capture and storage. There are compelling analyses from many sources that support this view, including from the Carbon Trust and studies conducted for the DTI for the 2003 Energy White Paper.

  25.  Considerations of security and diversity of energy supply support this position. Energy efficiency and demand management are undertaken locally, there are many diverse renewable technologies that can be deployed within the UK, and the declining amount of fossil fuels that we require could come primarily either from the UK or from countries that are, and are likely to remain, reliable suppliers, such as Norway.

  26.  Studies by the Carbon Trust indicate how the 60% target could be attained employing the type of approach outlined above. A crucial conclusion of these studies is that, while emissions reductions of 60% or more require both energy efficiency (and demand reduction) and renewable supply, they do not require new nuclear power. Research conducted for the DTI during the preparation of the Energy White Paper suggested that system costs for achieving a 60% carbon reduction target by 2050 without new nuclear power were no higher than those to achieve the same cuts with it. [117]We have seen no evidence to suggest that this situation has changed.

  27.  The RSPB believes that the UK already has in place a suite of policies and measures that forms a sound basis both for meeting our long-term (2050) emission reduction target and achieving security and diversity of supply. The main flaw in government policy to date has not been a reluctance to enact potentially effective policies but a failure to make them effective by providing them with large enough targets. Before resorting to a radically new strategy we believe that time should be allowed for existing policies to be incrementally strengthened.


  28.  Whilst we consider that climate change poses a potentially catastrophic threat to wildlife, we are also concerned that, inappropriately sited and deployed, some climate change mitigation measures can harm wildlife, for example some forms of renewable energy. Our view is that there need be no conflict between achieving a low carbon future and the conservation of wildlife.

  29.  It is important, however, that the UK Government takes action to ensure that conflict is avoided in practice. In particular, the UK Government's commitments towards biodiversity conservation and international obligations under the Birds and Habitats Directives must not be undermined in delivering renewables if a sustainable approach to carbon reduction is to be achieved.


March 2006

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

117   Marsh G, et al, Options for a Low-Carbon Future (AEA Technology and Imperial College, 2002). Back

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