Memorandum submitted by Natural England
(CCB 29)
1. INTRODUCTION
Natural England was established under the Natural
Environment and Rural Communities Act 2006 with the purpose of
ensuring that the natural environment is conserved, enhanced,
and managed for the benefit of present and future generations,
thereby contributing to sustainable development.
2. KEY ISSUES
Proactive approach to adaptation
Natural England accepts the scientific evidence
presented this year by IPCC which affirms the need for the climate
mitigation policy goal to restrict global temperature rise to
no more than 2°C above pre-industrial levels. On the basis
of the available evidence, the proposed 60% reduction target for
CO2 emissions by 2050 seems appropriate.
We support the proactive approach taken in setting
emission reduction targets. However, we have significant concerns
about the approach to adaptation; this is reactive, with no clear
statutory requirement to establish measures against which performance
can be assessed.
Regardless of the robustness of emission reduction
targets, we will be committed to several decades of climate change
which cannot be prevented. This is due to the residence times
of greenhouse gases once in the atmosphere—including those
which have already been emitted in recent decades and those which
will be emitted in the future.
It is therefore essential that, in parallel
with setting emission reduction targets, the Bill includes statutory
mechanisms which will firstly identify the impacts of unavoidable
climate change and then develop adaptation response strategies
to minimise these impacts. The establishment of appropriate measures
could be a role for the Committee on Climate Change and its terms
of reference and the expertise of its membership would need to
reflect this.
It is essential that the proposed quinquennial
review of the risks posed by climate change to the UK includes
an assessment of the impacts on the natural environment. This
will help to ensure that adaptation for the natural environment
is one of the Government's policy priorities and that measures
to deliver adaptation are included in the statutory framework.
Multi-gas approach
The proposal that emission reduction targets
will only apply to CO2 and not other greenhouse gases
is a shortcoming of the draft Bill. IPCC's Working Group III report
on Mitigation (May 2007) states conclusively that "a multi-gas
approach and inclusion of carbon sinks generally reduces costs
[of mitigation] substantially compared to CO2 emission
abatement only".
International approaches to climate change mitigation
and emissions reduction have taken a multi-gas approach. For example,
the Kyoto Protocol set legally binding targets for all major greenhouse
gases, non-CO2 gases are likely to be brought into
the EU Emissions Trading Scheme (EUETS) post-2012 and the approach
of the Stern Review is to include the total stock of greenhouse
gases.
The UK's domestic action on emission reductions
should be consistent with international multi-gas approaches.
Such an approach would enhance synergies between the UK's domestic
and international efforts to reduce emissions and offer improved
opportunities for overall emission reductions. As the UK has demonstrated
successfully through its Kyoto commitment, it is possible to achieve
emission reductions for all greenhouse gases and not just for
CO2.
Strong enabling powers
Natural England strongly supports the enabling
powers proposed in the draft Bill. Such powers will provide the
necessary incentives and regulation required for the Agriculture,
Forestry and Land Management sector to make a significant contribution
to climate mitigation. As agriculture is responsible for two-thirds
of the UK's nitrous oxide emissions and over a third of methane,
inclusion of these gases in the statutory target would give the
sector a clear incentive to further reduce its emissions.
Furthermore, farmers and land managers are uniquely
placed to enhance the natural absorption of carbon in soils and
vegetation, so helping to maintain and strengthen carbon sinks.
In a UK context, this is particularly the case for peaty soils,
which store an estimated 3 billion tonnes of carbon and could
become major sources of CO2. As the scientific understanding of
these systems becomes clearer, enabling powers could help deliver
conservation and restoration measures to secure and sequester
significant amounts of carbon.
There are at present no economic instruments
that directly encourage or reward land managers for mitigation
activities and the draft Bill presents an important opportunity
to address this.
Natural England
May 2007
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