APPENDIX 46
Memorandum by the Royal Society for the
Protection of Birds
SUMMARY
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.
TECHNOLOGY PRESCRIPTION
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.
THE ASSUMPTION
OF INCREASING
DEMAND
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.
ENERGY DEMAND BY SECTOR (MTOE) AND GROWTH
IN ENERGY DEMAND SINCE 1990
| | |
| |
| Domestic | Transport
| Services | Industry
|
| | |
| |
| 1990 | 41 | 49
| 19 | 38 |
| 1995 | 43 | 50
| 21 | 36 |
| 2000 | 47 | 55
| 22 | 33 |
| 2004 | 49 | 58
| 21 | 33 |
| Change from 1990 | 19.6% |
18.1% | 8.0% | -13.9%
|
| | |
| |
| | |
| |
Source: UK Energy and CO2 emission projections, Updated
projections to 2010, DTI, February 2006.
EMISSIONS FROM
TRANSPORT
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.
CARBON BUDGETS
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.
MEETING THE
UK'S 2050 TARGET
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.
WILDLIFE CONSIDERATIONS
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.
RSPB
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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