Conclusions and recommendations
Purpose of the draft Bill
1. Target
setting alone cannot deliver policy objectives. However, enshrining
one in law will strengthen the Government's resolve to achieve
it, subject it to greater public accountability if it fails, and
crucially give confidence and certainty to the business community
whose mid- and long-term investment decisions are central to meeting
the target. (Paragraph 10)
Terminology
2. There
is inconsistency in the language within the Bill. Terms such as
"UK carbon account" and "UK carbon dioxide emissions"
are used seemingly interchangeably. We recommend that the Bill
only use two terms, "carbon dioxide" or "carbon
dioxide equivalent". To do otherwise will cause confusion.
Not all greenhouse gases—as defined by the Kyoto Protocol—are
carbon-based. Use of the word "carbon" in the Bill should
be avoided to remove any further ambiguity. (Paragraph 19)
Cumulative emissions
3. We
recommend that the Government should also incorporate within the
Bill targets relating to cumulative emissions. These should address
overall budgets to 2020 and to 2050 in quantitative terms (tonnes
of CO2eq) rather than only using annualised percentage reductions.
This addition to target setting would help set the framework for
each of the five-year budgets required by the Bill. (Paragraph
26)
2020 and 2050 targets
4. The
Government sets much store by the Bill. We emphasise, however,
that the Bill alone will not deliver the necessary emission reductions
and note that CO2 emissions in 2006 were a mere 5% below 1990
levels. As such, whilst we agree with the substantial amount of
evidence calling for the 2050 target to be higher than 60%, we
recognise that this target itself is still extremely ambitious.
We are not in a position to suggest whether the 2050 target should
be higher than 60%. However, we recommend that the first task
of the Committee on Climate Change should be to assess the current
state of knowledge regarding climate science in order to determine
what the 2050 target should be and the trajectory for achieving
it. (Paragraph 32)
5. We are not convinced
by the Secretary of State's arguments for designing a 'ball park'
target. Whilst we agree that the target to reduce emissions by
26% below 1990 baseline levels by 2020 will be challenging, and
welcome the medium-term indication of progress that the Government
expects, we believe the Government is being unnecessarily prescriptive
in placing an upper limit on the 2020 target. Having an upper
limit serves no practical purpose. We recommend that Clause 3(1)(a)
be amended by leaving out the words ", but no more than 32%,".
This will bring it in line with the 2050 target to reduce emissions
by "at least 60%". (Paragraph 38)
6. The Bill must make
provision for the 2020 and 2050 targets to be revised, but we
recommend that this provision be limited to an upwards revision
only. We also recommend that the Committee on Climate Change be
empowered to propose revisions to the mid- and long-term targets
whenever it believes an amendment may be appropriate. (Paragraph
43)
Budgetary periods
7. We
remain unconvinced that annual statutory targets should be used
owing to inevitable fluctuations in energy demand and the unavoidable
lag in reporting on progress. We accept the case for five-year
budgetary periods, but we recommend that clear annual 'milestones'
are set—and published—by the Committee on Climate
Change in order that it may become apparent well before the end
of a budgetary period whether or not policies are working. This
also reflects the fundamental significance of cumulative emissions,
and the trajectory involved, by which the five-year budgets are
reached. (Paragraph 51)
8. We recommend that
once the Bill becomes law, the Government should publish a sectoral
breakdown of its national emission reduction targets to help different
sectors of the economy and society—including Government,
businesses, communities, households and individuals—appreciate
what action they will have to take if the UK as a whole is to
achieve its emission reduction objectives. (Paragraph 52)
9. The provision to
amend a budget more than a year after the end of a budgetary period
makes a nonsense of the entire concept of budgetary periods, and
would render any sanctions completely unworkable. This is simply
wrong. Subsection (5) of Clause 13 should be removed in its entirety.
(Paragraph 55)
Purchasing credits from overseas
10. We
recommend that the facility to purchase credits from overseas
should only be exercised as a last resort. The Government should
ensure that any purchases of credits from overseas do not prejudice
a country's attempts to meet its own environmental objectives.
Because of the serious implications of over-utilising this facility
in terms of the UK's credibility on the international stage, combined
with the potential for unforeseen consequences and the importance
of pubic opinion, we recommend that this provision be strictly
limited to a quantifiable amount to be advised by the Committee
on Climate Change for each budgetary period. It should be for
the Committee on Climate Change to determine if and when the purchase
of overseas credits is appropriate. (Paragraph 64)
Enforcement
11. Although
sanctions may not be either likely or real, we recognise that
having an Act of Parliament has its own merits. By institutionalising
the targets, the political pressure to achieve them will be increased.
The Government of the day will also be subject to 'the court of
public opinion'. (Paragraph 72)
12. If a target is
missed, we recommend that a debate on a remedial action plan is
held on the Floor of the House on an amendable Government motion
subsequent to the publication of the Government's response to
the annual progress report by the Committee on Climate Change.
(Paragraph 73)
The Committee on Climate Change
13. The
Committee on Climate Change should not be a policy-making or delivery
body. It should be focussed on the provision of advice with regard
to the budgets, and the publication of progress reports, but it
must not be prevented from advising the Government on any policy
matters that may come to its attention while carrying out its
duties. (Paragraph 85)
14. In order to establish
the independence of the Committee on Climate Change, the Secretary
of State should be required to accept its recommendations without
further debate. This would position the Committee's advice alongside
that of the Monetary Policy Committee whose interest rate decisions
are not challengeable by the Chancellor of the Exchequer except
under very extreme circumstances. (Paragraph 86)
15. We do not see
that the Bill prevents the Committee on Climate Change from recommending
the mid- and long-term targets, but it is not clear that the Committee
will have this power. We recommend that by 2009 the Committee
should review and recommend to the Secretary of State what the
2020 and 2050 target should be. We would not expect these to be
less than 26% and 60%, respectively, below 1990 levels. In addition,
the Committee should have the power and responsibility to make
recommendations to the Secretary of State at any time regarding
the mid- and long-term targets. (Paragraph 88)
16. It is right that
the Committee on Climate Change should be composed of experts
rather than representatives. Although the essential expertise
required of the Committee is not explicitly listed in order of
importance, the way it is listed in the Bill appears to suggest
that economic interests are going to be more heavily represented
than environmental ones. The schedule should be redrafted to dispel
this impression (for example, by using alphabetical order). We
also recommend that the impact of climate change upon biodiversity
be added. (Paragraph 93)
17. It is not in anybody's
interest to have a strict fixed-term appointment of five years
such that the entire Committee on Climate Change is potentially
replaced at the end of every budgetary period. We recommend that
appointments are for five years at least, and could be longer
to allow their contracts to expire at different times. The Government
should make them non-renewable so as to underpin members' independence
of Government. (Paragraph 95)
Resources
18. It
is imperative that the staff and information resources available
to the Committee on Climate Change are completely independent
of Government. We recommend that independent consultants be asked
by the Government to recommend the correct level of resources
available to the Committee in order to establish that it is properly
resourced. This should ensure that it can be truly independent
of Government interests in conducting the analysis and research
which it believes necessary to help ensure that the targets set
out in the Bill are met. (Paragraph 101)
19. Given that the
emissions forecasting model used by the DTI is adapted from its
energy model, and the delays experienced in publishing the Government's
Review of the Climate Change Programme, we question whether the
current forecasting model is suitable for use by the Committee
on Climate Change in drawing up budgets three budgetary periods
(15 years) in advance. Our evidence suggests that the resources
proposed for the Committee on Climate Change may quickly prove
to be inadequate. We recommend that adequate resources are made
available to the Committee on Climate Change for a 'bespoke' emissions
forecasting model to be developed. Given the importance that Defra
attaches to climate change, we are sure the Department will be
able to find the relatively small sums involved by reprioritising
from elsewhere within its budget. (Paragraph 106)
20. We recommend that
the work of the Committee on Climate Change—including its
minutes and advice given—should be posted on its website
within one month of transmission to the Secretary of State. (Paragraph
112)
21. We strongly recommend
that the Government commits to holding an annual debate on a substantive
amendable motion on the Floor of the House, subsequent to the
publication of the Government's response to the annual report
produced by the Committee on Climate Change. (Paragraph 113)
Trading schemes
22. We
recommend that the Government explains more clearly—prior
to the final version of the Bill being produced—which trading
schemes will be introduced using the enabling powers within the
legislation. (Paragraph 117)
23. We recommend that
the requirement for allowances to be allocated free (Schedule
2, Section 5 (3)) be removed from the Bill so as to avoid any
unnecessary confusion, particularly for those industries and sectors
that will be subject to these schemes. (Paragraph 121)
International aviation and shipping
24. The
inclusion of the UK's share of emissions from international aviation
and shipping will have significant implications for the validity
of the 2050 target. We recommend that the Committee on Climate
Change should be required to report on the UK's emissions from
international aviation and shipping, whether or not they are counted
as part of the statutory target, in order more accurately to inform
its recommendations regarding budgets and targets which will affect
all other sectors of the economy. Pursuant to this, the Government
must make every effort to achieve international agreement as soon
as possible on allocation mechanisms so that the powers provided
for in Clause 15 (3) can be exercised. We further recommend that
once international agreement is reached, the Committee on Climate
Change should include the UK's share of emissions from international
aviation and shipping in its recommendations for the targets.
(Paragraph 128)
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