Memorandum submitted by Operation Noah
(CCB 19)
EXECUTIVE SUMMARY
Operation Noah is the churches' climate change
campaign, based at Churches Together in Britain and Ireland (CTBI).
It is a project of the Environmental Issues Network of CTBI and
Christian Ecology Link.
The leaders and campaigners of Operation Noah
welcome the Government's recognition of climate change as one
of the greatest challenges facing the world. However, we believe
that the proposals contained in the draft Bill do not go far enough
to provide credible and meaningful leadership domestically or
internationally on this most urgent of issues.
Our main points of concern are as follows:
— the binding targets for emissions
reduction should be bold in order to reflect the latest scientific
evidence, and should not be subject to revision except in the
light of the evolving science;
— there appear to be contradictions
between government departments on policy approaches to climate
change. The Bill should be clear about the commitment of all government
departments to the targets; and policy across government must
be consistent with reducing CO2 emissions across the
economy, in order to be effective, fair and transparent;
— the UK has a moral responsibility
to reduce emissions within the UK itself and should not pay others
abroad to compensate for our environmentally expensive lifestyles
and inaction at home; and
— both those factors for consideration
in setting the carbon budgets, and the composition of the Committee
on Climate Change should place the greatest emphasis on climate
change science and policy above the economic imperative for British
industries to remain internationally competitive.
Operation Noah places the sustainability of
the British economy and the environment above the need for British
industry to remain internationally competitive. We believe that
there is a contradiction between serious efforts to tackle climate
change and the current growth-driven economic paradigm. We are
calling for a recognition that the world's economic subsystem
is limited by the fixed, finite and closed ecosystem, which is
easily disrupted as the economic subsystem grows relative to the
total ecosystem.
As a recognition of these limits, Operation
Noah is calling for a reduction in individual emissions in the
UK from around 9.5 tonnes a year at present, to 1.2 tonnes a year.
We are considering calling for this reduction to be achieved by
2020.
TARGETS
1. The Government's target of a 60% reduction
in CO2 emissions by 2050 is too weak and does not reflect
current scientific understanding. The respected Tyndall Centre
for Climate Change Research has found that the UK would need to
cut its emissions by 90% by 2050 to have even a 30% chance of
keeping the global temperature rise to within 2°C.[20]
Tyndall's analysis found that the Government's Draft Bill, rather
than supporting a 2°C warming, was at best in keeping with
a 50% chance of exceeding 4°C warming.
2. Even with a more realistic target for
emissions reduction by 2050, action to curb emissions needs to
start now. This is partly so that there is a greater chance of
achieving the long-term target and so avoiding more dangerous
temperature rises, and partly in order to give economic, social
and political systems the maximum adjustment time, within a framework
of certainty. The interim target is therefore crucial. Providing
a reduction range rather than a specified target is unhelpful
because it effectively sets the bar at the lower end of the range,
when we should be aiming for the highest possible reduction.
3. The draft Bill fixes a ceiling on the
amount of emissions reductions by 2020 of 32% on 1990 levels.
There is no explanation for why this is included, but there should
clearly be no statutory limit on emissions reductions given the
risk of catastrophic damage if too little is achieved, too late.
4. The draft Bill allows for interim and
long-term targets to be revised in the light of scientific knowledge
and international law. Operation Noah believes that arrangements
enshrined in international law could allow the UK targets to be
weakened. We believe that UK Government should stand firm and
only revise targets in the light of scientific developments.
5. One of the biggest flaws of the draft
Bill is that it excludes the aviation and shipping sectors from
the target reductions in CO2 emissions. Aviation is
the fastest growing source of emissions and is identified by scientists
as a key driver of emissions in the future. It is therefore disingenuous
to exclude it, even if it is not included in international agreements.
CARBON BUDGETING
6. Operation Noah believes that the UK has
a moral imperative to reduce its own emissions rather than use
its relative wealth to pay others to achieve its targets. The
business of limitless consumption in countries like the UK cannot
proceed as usual if we are to solve the global problem of climate
change. It is time to recognise that the Earth's natural resources
and its capacity to absorb and process wastes such as CO2
are finite. If our way of life and our institutions are not sensitive
to this understanding then for the sake of today's fleeting consumption,
we compromise the very survival of future generations.
7. Government's proactive support for expanding
UK air and road travel capacity are examples of how policies are
inconsistent with emissions reduction efforts. Operation Noah
believes that the Climate Change Bill should include wording which
expresses a commitment to achieving policy consistency across
all areas of government with respect to emissions reductions,
and that this commitment should be such that the Government can
be held to account on this point.
8. Consideration of each of the seven factors
to be taken into account in setting the carbon budgets could lead
to a conflict of priorities. For example, evolving scientific
knowledge could indicate the need for stringent action on emissions
in a particular sector which could compromise Britain's competitiveness.
The Government's proposals do not explain how such conflicts of
interest would be resolved. It is clear to Operation Noah, however,
that with the overarching threat from global warming, scientific
knowledge should take precedence.
COMMITTEE ON
CLIMATE CHANGE
9. In the proposed composition of the Committee
on Climate Change, the disciplines of climate change science and
policy are subordinated to economic analysis, business competitiveness
and financial investment. Action on climate change has to be principally
determined by well-grounded, defensible scientific evidence, not
by economic or financial interests, otherwise the long-term environmental,
economic and social costs are likely to be catastrophic—including
for those with overarching economic and financial interests.
INTERNATIONAL IMPLICATIONS
10. Operation Noah believes that the Climate
Change Bill can act as an effective example to lead and inform
international policy, but only if the opportunity is seized to
make the Bill meaningful and credible, by setting scientifically
realistic targets across the whole sphere of policy and the economy.
Operation Noah
May 2007
20 Tyndall Briefing Note 17, March 2007, by Dr K
Anderson and Dr A Bowes, A response to the draft Climate Change
Bill's carbon reduction targets. http://tyndall.webapp1.uea.ac.uk/publications/briefing_notes/bn17.pdf Back
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