Memorandum submitted by the City of London
Corporation (CCB 33)
This letter follows the Committee's recent announcement
of plans to undertake pre-legislative scrutiny of the Government's
draft Climate Change Bill.
The City Corporation welcomes the Committee's
interest in climate change mitigation and the draft Bill's objective
to address climate change planning and adaptation from a national
perspective by, for example, the proposed national carbon emission
trading schemes by which the UK will operate within its "carbon
budget". The Committee may be aware that, in 1999, the City
along with others established the UK Emissions Trading Group (UK
ETG) which laid the foundations on which the UK, and then the
EU, Emission Trading Schemes have been built. The City has, as
a result, accrued significant expertise in the design and execution
of such schemes and, given its role in their genesis, the City
Corporation naturally welcomes the draft Bill's focus on domestic
emissions trading schemes as one way to tackle climate change.
In light of the draft Bill's assumption that
carbon emission reductions should be evaluated nationally, with
efforts focused on a UK-based target, the Committee might like
to note the achievements which can be secured at a local level.
The City Corporation has taken voluntary steps to reduce its carbon
"footprint". The Lord Mayor's official travel has, for
instance, been offset for the last five years and for the last
four years the City has voluntarily offset the CO2
produced by the Lord Mayor's Show. This will happen again in 2007.
Further, since 2004 the City Corporation has made considerable
use of expertise in the emerging carbon offset sector, including
CO2e.com, a subsidiary of global financial services firm Cantor
Fitzgerald which operates in the European Emissions Trading Market.
Moreover, through the CarbonNeutral Company, the City Corporation
has invested in a variety of forestry and development projects.
In 2006 the City purchased its carbon offsets through CO2e.com
and participated in a project which manufactures high efficiency
wood burning stoves for use by South African communities. These
schemes, along with the purchase of renewable "green"
energy, have enabled the City to cut its own CO2 emissions
by 35% based on a 1997 baseline. While some valid questions do
remain about the unregulated voluntary offset market, the City
accepts that carbon trading can have a positive environmental
impact and can bring wider social and economic benefits.
While, therefore, the City Corporation appreciates
the advantages inherent in the draft Bill's approach, the City's
experience suggests that carbon offsetting can also play a vital
part in the carbon reduction effort at a local, as well as national,
level. Future, bolder use of carbon offsetting could bring economic
and social rewards to London and elsewhere and, to this end, it
is surprising that no mention is made in the draft Bill of the
role of governmental bodies below the national level in relation
to carbon dioxide removal. In particular, it is not clear at present
how local offset projects, as already undertaken by the City,
are intended to integrate with the national legislative scheme.
If this is not clarified, there is a risk that the national scheme
could hinder support, and engagement, with the aims of the legislation.
Moreover, in the context of the duty which the
draft Bill would impose on the Secretary of State to report periodically
on adaptation, it is perhaps worth pointing out that the City
Corporation was the first UK local government authority to develop
a Climate Change Adaptation Strategy.[28]
Produced in co-operation with climate risk management consultants
Acclimatise, Rising to the Challenge employs the UKCIP02
climate change scenarios.[29]
This strategy has identified the priority risks associated with
climate change and proposes adaptation measures which are designed
to ensure that the City infrastructure and services cope with
a changing climate. It might be argued that the draft Bill ought
to present a more robust vision of well-developed adaptation schemes
than it does at present. The Bill's approach is welcome as far
as it goes, but the Committee might want to consider whether,
as the progenitor of a comprehensive climate change policy, the
draft Bill should contain measures which encourage mitigation
schemes at a sub-national level where, arguably, they can most
efficiently be put in place. To this end, the City Corporation
would welcome a clearer steer on the Government's present thinking
on how essential local adaptation planning, such as that taking
place in the City, should work alongside national mitigation measures
proposed in the draft Bill.
It is also recognised that there could be new
business opportunities in the carbon emission marketplace for
those who are willing to innovate. Recent City Corporation research[30]
has, indeed, highlighted the potential scope offered by carbon
emissions trading and offsetting and has sought to identify the
next generation of trading opportunities. The Committee might,
therefore, want to give thought to whether this draft Bill should
also promote and encourage effective climate change planning at
the same time as putting necessary mitigation measures in place.
City of London Corporation
May 2007
28 Rising to the Challenge-The City of London Corporation's
Climate Adaptation Strategy. January 2007. Accessible online at
http://213.86.34.248/NR/rdonlyres/7347D392-3CF3-4344-8B2D-9AF9315E8801/0/SUS-climateadapt.pdf Back
29
Which provide, for example, that by 2040, the average annual
temperature for the UK is expected to rise by between 0.5 and
1°C, depending on region. There is expected to be greater
warming in the south and east than in the north and west. Back
30
Emissions Trading and the City of London. September 2006. Back
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