Memorandum submitted by Friends of the
Earth
INTRODUCTION
Friends of the Earth welcomes the publication
of the draft Climate Change Bill, and the announcement of a period
of pre-legislative scrutiny. We have long argued and campaigned
for a legal framework to manage and reduce UK carbon dioxide emissions.
We have further argued that the aim of such a framework should
be to limit UK emissions the fair share of the total emissions
the global community can afford without causing warming of more
than two degrees Celsius.
We welcome the draft Bill because it would make
the principle of a legal framework for carbon emissions a reality.
However, the ambition of the Bill (in terms of the reductions
in carbon dioxide it currently requires) is far short of the two
degrees Celsius test set out above (see section 1 of the response
below). This is compounded by the fact that important sources
of carbon are not included in the targets that are set—those
from the UK's share of international aviation and shipping (see
Section 2).
We also do not yet believe that the framework
contained in the draft Bill is yet sufficiently robust to give
enough confidence that even the targets it does contain will be
met (see Section 3 below).
Finally we have concerns at the reliance in
the Bill on trading of carbon. We fully recognise the very real
difficulty for the Government in this that is caused by the UK
being ahead of many other countries. Were all countries to have
a legally binding budget as proposed for the UK in this Bill,
trading could help. But with the lack of "caps" in many
countries, the inadequacy of caps in others (ie the EU ETS so
far) and the existence of so-called "hot-air" in a third
tranche mean great care is required before credits from such schemes
should be allowed to replace cuts in UK emissions (see section
4).
1. Scale of cuts required by the Bill
1.1 The Bill would require cuts in carbon
dioxide emissions of between 26-32% by 2020 and 60% by 2050, based
on 1990 levels.[21]
Effectively therefore, the Bill simply gives legal force, and
provides a management framework for existing Government targets,
rather than establishing new ones. It is therefore worth reminding
ourselves of the origins of these targets.
1.2 The target for a 60% cut by 2050 became
Government policy (and indeed became supported as policy by other
parties) after it was recommended by the Royal Commission on Environmental
Pollution in their twentysecond Report Energy—The Changing
Climate which was published in June 2000. A key recommendation
of that report was:
"The government should now adopt a strategy
which puts the UK on a path to reducing carbon dioxide emissions
by some 60% from current levels by about 2050. This would be in
line with a global agreement based on contraction and convergence
which set an upper limit for the carbon dioxide concentration
in the atmosphere of some 550 ppmv and a convergence date of 2050"
1.3 At the time, stabilisation of atmospheric
concentrations of carbon dioxide at 550 parts per million by volume
(ppmv) was seen as broadly in line with existing EU policy of
limiting the temperature rise to no more than a two degree Celsius
increase above pre-industrial levels. With the benefit of further
studies and advances in scientific understanding, it no longer
is.
1.4 Indeed, the Governments climate policy,
as set out in "Climate Change—The UK's programme 2006"
says:
"in the mid-1990s the EU proposed that
the aim should be to limit global temperature rise to no more
than 2°C to avoid dangerous climate change... At that time,
it was thought that this equated to atmospheric carbon dioxide
levels below approximately 550 ppm. The more recent work of the
IPCC suggests that a limit closer to 450 ppm or even lower, might
be more appropriate to meet a 2°C stabilisation limit."
1.5 The Tyndall Centre has recently published
a briefing note on the Bill. The researchers have estimated that
the targets imply atmospheric concentrations upwards of 600 ppm,
and maybe in excess of 750 ppm, contributing to a world warmer
by four or five degrees.[22]
Such a level of warming would be catastrophic.
1.6 Therefore the whole basis for including
a target for a 60% cut by 2050 is—and has been accepted
by the Government to be—out of date. We do not therefore
believe this target should be included in the Bill.
1.7 We acknowledge there are powers to amend
this target in the light of "significant developments...
in scientific knowledge about climate change".[23]
The principle of allowing the target to be altered to reflect
our scientific understanding is of course the correct one. But
this wording requires further developments in understanding after
the passing of the Bill, so the current scientific view that the
60% target and the 550 ppmv concentration it implies are insufficient
to prevent dangerous climate change may not be considered a new
development.
1.8 Friends of the Earth therefore recommends
that the targets on the face of the Bill should reflect current
scientific opinion of the cuts necessary to keep the UK within
its "fair share" of global emissions compatible with
keeping temperature rise below two degrees Celsius. This means
at least an 80% cut by 2050.
1.9 The Bill should further require that
the target is based on the latest understanding of the science
of climate change.
2. Inclusion of international aviation and
shipping
2.1 The Bill specifically excludes emissions
from international aviation and shipping in Section 15. It does,
however, grant powers to the Secretary of State to make regulations
defining how such emissions can be included at a future point,
if there is a change in international reporting practice.
2.2 The UK's share of international aviation
and shipping emissions could add around 10% to the UK's total
carbon emissions. Analysis by the Tyndall Centre has found that
in 2004, when the Government reported emissions at 150 MtC on
the basis of excluding these emissions, the UKs share of international
aviation would have added a further nine MtC and international
shipping, a further five MtC.[24]
Since 2004 emissions from these sectors are likely to have grown
significantly faster than other sectors.
2.3 Clearly the ultimate goal should be
to arrive at a common, international agreement on how emissions
from international aviation and shipping are to be allocated,
so that all emissions are accounted for. However, the fact that
reaching such international agreement is providing a difficult
and lengthy process is no excuse for simply ignoring emissions
from international aviation and shipping. Indeed a "carbon
management system" that simply leaves these emissions out
is a rather like a calorie-controlled diet that opts to exclude
calories from chocolate.
2.4 It is also important to recognise that
while different proposals for the allocation of these emissions
to countries have been put forward for discussion, the Government
already have a methodology which they use to report these emissions
as a "memo item" (ie not included in the targets) under
the Kyoto protocol.[25]
At the very least, this existing methodology should be used as
a "stop-gap" to ensure Government programmes from the
very first carbon budget period cover all areas of emissions,
and do not have an apparent "blind spot" to international
aviation and shipping.
3. Robustness of carbon management framework
3.1. Friends of the Earth has now been calling
for a legal framework for managing carbon emissions for several
years. It has long been our view that despite carbon dioxide targets
appearing with great regularity in manifestos and policy papers,
they have not been taken anywhere near seriously enough. When
doubts have raised about whether Government's were on track to
meet targets, they have been largely ignored by Ministers simply
restating the targets. As the Guardian noted in a leader
in December 2004:
"the Government has invested so much
of its credibility in attempting to keep to its golden rules of
finance, even though the sky is hardly going to fall if the exchequer
ends up a billion or two short. In comparison, global warming
and climate change are infinitely more serious. Yet for public
finances the rules are made of gold, while for the environment,
rules crumble to dust."
3.2 The introduction of the Bill is a serious
and much needed step towards rectifying this, and Friends of the
Earth welcomes this. But to be fully robust and effective, the
Bill needs to ensure its structure helps to overcome some of the
major barriers to Government's acting on climate change.
3.3 High on the list of these barriers is
the long-term nature of the climate change problem. For a start,
climate change require a Government to act now to bring benefits
(or avoid problems) at a point long after it has left office.
And to make matters worse, no Government will be able to be the
"one who stopped climate change"—it requires Government
after Government to keep up the effort.
3.4 The Bill must therefore ensure that
every Government is held to account, and cannot pass the buck
to a future Government—or blame a previous one. There is
a very real danger that as drafted—with five year budget
periods that will almost inevitably overlap with two Parliaments—the
Bill will fail to do this. Even the very first proposed budget
period will take in two Parliaments: the period will run from
January 2008 to January 2012—an election in May 2010 would
fall almost precisely in the middle of this period.
3.5 It is far from impossible to imagine
a situation where a Government approaching an election might duck
some tricky decisions, or opt for tax cuts rather than investment
in necessary low-carbon infrastructure or technology. The temptation
to do this when approaching a difficult election—or even
one they believe difficult to win—would be even stronger.
After all, in such cases the blame for missing the budget would
actually taken by the successor Government. But the successor
Government may feel it can get away with using the flexibility
in the Bill to amend the budget, while blaming the previous Government
who did too little to get on track for the budget that every wanted
to see met. Everyone blames each other—but crucially our
carbon emissions are not cut as required.
3.6 Friends of the Earth's original proposal
for annual targets was intended to prevent this buck-passing.
Since our proposal, much nonsense has been said about annual targets—including
ridiculous claims such as they would lead to the closure of airports
if our emissions were off track. To our knowledge no person or
organisation has ever proposed such rigid targets, other than
people who have been arguing against annual targets. However,
the argument does (albeit crudely) highlight the challenge of
allowing some flexibility to take account of short-term fluctuations
in weather, relative fuel costs, etc with a firm steer that keeps
Governments on track.
3.7 The proposed five year budget system
allows the flexibility, but the buck-passing loophole means it
fails to provide the firm steer. It has been argued that the Committee
on Climate Change will do this through annual reports on progress,
which of course to an extent it will. But unless a Government
is clear about its intentions in any year, it is hard for the
Committee to fully scrutinise progress. The Committee may assume
that meeting the budget implies a linear fall across the period,
and report on that basis—Government policies may be aimed
at making greater cuts at the start (or end) of the period.
3.8 Friends of the Earth believes that every
Government responsible for a part of a budget period will best
be held to account if they have stated clearly what they intend
emissions to be in each year. The Committee can then judge progress
against what was planned. The Committee can, if appropriate, take
account of inclement weather, or price shocks, in reaching its
assessment. But the basis of the assessment should be whether
it matches up to what Ministers were trying to achieve.
4. The Bill and international trading
4.1 The Bill allows a very heavy emphasis
on trading in carbon as a mechanism to deliver the most cost effective
way to reduce carbon emissions—based on the principle that
a tonne of carbon emitted has the same effect whether emitted
in Birmingham or Bangalore.
4.2 The difficulty is that while this principle
is true of carbon emitted, it is much harder to be certain that
a tonne saved in the UK is actually equivalent to a tonne saved
elsewhere in the world. This depends on a multiplicity of factors—such
as assessment of whether that tonne would have been (at least
partially) saved anyway, whether it measured as a reduction on
current emissions, or from a projection of future demand. It is
a problem that bedevils carbon offsetting schemes as well as trading
schemes.
4.3 We are therefore concerned that the
Bill should not allow the total freedom to trade carbon credits
to meet carbon budgets until the frameworks that such trading
takes place within are sufficiently robust to be moving us on
the correct trajectory to the carbon cuts we need to see. Until
that time we believe serious consideration should be given to
restricting the use of trading as a mechanism to meet the budgets,
perhaps by:
— Setting a strict limit for the
amount of effort to be made to meet budgets domestically, and
the amount that can be "bought in".
— Operating a kind of "exchange
rate" where independent assessment judges a tonne of carbon
saved domestically to be equivalent to, say, just half a tonne
under a trading scheme. In such cases, credits for two tonnes
would be needed to have the same effect on the budget.
— Restricting trading to only
robust schemes.
4.4 We will be working to further develop
ideas to solve this problem.
March 2007
21 The "carbon budget" actually means average
emissions for the five years around these points would be at these
levels, rather than this being precisely the emissions cuts in
those years. Back
22
Tyndall Briefing Note 17, March 2007. A response to the Draft
Climate Change Bill's carbon. Back
23
Section 1(4)(a) of the Draft Bill. Back
24
Living within a carbon budget, p 18, Tyndall Centre, Manchester,
www.foe.co.uk/resource/reports/living_carbon_budget.pdf Back
25
Latest figures are available here: www.defra.gov.uk/environment/statistics/globatmos/gagccukem.htm Back
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