Memorandum submitted by the Mayor of London
(CCB 32)
SUMMARY
The Mayor strongly supports the publication of
the Government's draft Climate Change Bill. The Bill represents
a landmark piece of legislation in combating climate change, and
the Government should be commended for its publication. However,
the Mayor's view is that the Bill needs to be strengthened in
terms of targets, enabling powers and the role of the Committee
on Climate Change
1. The Mayor strongly welcomed the Government's
recent announcement to bring forth a Climate Change Bill, setting
both short and longer-term carbon reduction targets, for this
first time, on a statutory basis. However, the Mayor's view is
that the Bill needs to be strengthened both in terms of the carbon
dioxide reduction targets set, and the scope of the enabling powers
introduced, to ensure that Government works effectively to tackle
climate change.
2. The Mayor supports the Government's statement
that the Bill will "put the UK at the very front of global
efforts to tackle climate change", however, this goal
will only be achieved if UK actually significantly reduces its
own carbon dioxide emissions. The latest statistics published
by Defra in March 2007 show that UK CO2 emissions now
stand at their highest level for 10 years.[25]
3. In line with the Mayor's recently released
Climate Change Action Plan, the Mayor also calls on Government
to take into account the recent analysis from the Intergovernmental
Panel on Climate Change (IPCC) and others, that a faster trajectory
for the reduction in carbon emissions needs to be achieved and
therefore a 60% carbon reduction (baseline 1990 emissions) needs
to be achieved by 2025. This is the goal set with the Mayor's
CCAP and should be the target set within the Climate Change Bill.
The London Climate Change Action Plan not only set this more ambitious
goal, but set out a delivery programme showing how it could be
achieved.
4. The carbon budget concept put forward
by the Climate Change Bill mirrors the proposal put forward by
the Mayor within the Climate Change Action Plan (CCAP). This states
that, to stabilise global carbon emissions at 450 ppm on a contraction
and convergence basis, London has to set a limit for the total
amount of carbon dioxide between now and 2025 to about 600 million
tonnes.
5. The rolling five-year budget system proposed
by Government is a practical way forward. Banking and borrowing
of a limited number of allowances across each of the years within
a budget period is acceptable. Borrowing of allowances from future
budget periods, should, however, not be allowed.
6. The Mayor is, however, concerned with
the proposal that international carbon allowances can be purchased
by Government to meet its carbon budget targets. The Government
seeks authority in the Bill to "spend money on overseas
credits and allowances to help the UK remain within budget if
necessary".[26]
However, no indication with regard to the limit of allowances
is given in the Bill or supporting documents. In terms of these
credits, the Government states that it will issue guidance in
terms of "supplementarity"—this is a further issue
of key importance which needs to be considered by Government if
allowed to purchase overseas credits to meet its targets.
7. The first budget period needs to reflect
the Government's commitment to its manifesto target of 20% carbon
dioxide reduction by 2010. The target should not be "smeared"
across the budget timeline. This is a longstanding Government
target of key importance and needs to remain a cornerstone of
the Government's commitment to carbon reduction.
8. The Mayor, whilst mindful that the proposed
Committee on Climate Change will not practically be able to advise
on the overall budget for the first commitment period this year,
strongly supports that the forthcoming Energy White Paper sets
out robust policies to achieve deep carbon dioxide cuts now. Government
should not be waiting for the Committee's initial advice, which
is not anticipated until Summer 2008.
9. The Government's National Allocation
Plan (NAP) under Phase II of the EU Emissions Trading Scheme (EUETS)
has already set a "budget" of allowances for the traded
sector, which represents, approximately, 50% of UK carbon dioxide
emissions. This, therefore, sets a much clearer scope for the
Government's energy policies in terms of the remaining sectors
of the economy that need to be tackled in terms of reducing carbon
(ie broadly, transport, including aviation, domestic and the non-EUETS
commercial and industrial activities).
10. The proposed make-up of the Committee
strongly represents scientific and economic disciplines. Whilst
recognising that significant technical expertise is required in
setting the carbon budgets, the Mayor is concerned that, at present,
there lacks representation in ensuring that appropriate policy
mechanisms are put forward to ensure that carbon reduction delivery
mechanisms are introduced as necessary.
11. The Committee also lacks any regional
representation. The Mayor believes this is a significant oversight
in terms of the Committee's make-up, as regional bodies are key
delivery vehicles for the Government's carbon reduction policies.
Cities are, in fact, the largest emitters of carbon emissions
and there is definite scope to repeat the Climate Change Action
Plan preparation for London in other regions and cities, both
nationally and internationally.
12. The Mayor is concerned that, as currently
proposed, the Committee will have limited ability to influence
Government policy. Government's failure to date in terms of carbon
reduction has not been in terms of target-setting, but in introducing
real, long-term and effective energy policies to create a successful
low-carbon economy. The Committee's annual reporting requirements
appear, at present, to be analogous to those of a Parliamentary
Select Committee, with the requirement on Government limited to
responding to the Committee's recommendations. The Committee must
not only provide advice on the carbon budget targets, and update
Government on the overall trajectory it should undertake to achieve,
but also identify where Government policy is conflicting in achieving
the UK's carbon goals.
13. The Committee needs to include within
its scope carbon emissions in areas of the economy not covered
at present, such as shipping and aviation.
14. The Mayor looks forward to the Government's
recommendations within the forthcoming Energy White Paper. The
enabling powers within the Bill should reflect the scale of the
challenge to reduce UK carbon emissions and help create the framework
to ensure that all sectors of the economy can play their role
in reducing emissions. New areas of policy need to be rapidly
progressed: the energy sector is already calling for significant
change in the way its market is regulated in order to combat climate
change;[27]
the key role of planning in helping reduce carbon emissions is
only now being addressed; significant new targets for the growth
of renewable energy have recently been agreed upon, and the role
of supplying heat sustainably is only now being studied. The Committee
should be able to supply strong signals to Government in terms
of the regulatory and other changes needed, and the enabling powers
required, in order to enact these changes.
15. The Mayor welcomes the commitment by
Government within the Bill on the more regular reporting on Climate
Change adaptation. This issue has, to date, been poorly focussed
on. The Mayor, however, believes that the proposal within the
Bill of a quinquennial review of adaptation policies is too long,
and that they should be reviewed every two years.
Mayor of London
May 2007
25 Provisional 2006 greenhouse gas emissions figures,
Defra 29 March 2007. Back
26
Section 5.33 page 32 of the Climate Change Bill consultation
paper. Back
27
Help us sell less power, National Grid tells regulators, Financial
Times 8 May 2007. Back
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