Memorandum submitted by the Natural Environment
Research Council (CCB 38)
1. The Natural Environment Research Council
(NERC) is one of the UK's seven Research Councils. It funds and
carries out impartial scientific research in the sciences of the
environment. NERC trains the next generation of independent environmental
scientists. Its three strategic research priority areas are: Earth's
life-support systems, climate change, and sustainable economies.
2. Details of NERC's Research and Collaborative
Centres are available at www.nerc.ac.uk. NERC supports, jointly
with the EPSRC and ESRC, the Tyndall Centre for Climate Change
Research, and many of NERC's other Research and Collaborative
Centres conduct research in this area.
3. NERC's comments are based on input from
Swindon Office staff.
INTRODUCTION
4. NERC welcomes the opportunity to contribute
to the Committee's scrutiny of the draft Climate Change Bill published
by Defra on 13 March 2007. As an independent Non-Departmental
Public Body (NDPB) with a primary remit to fund and carry out
research, and a linked remit to ensure that research findings
are made available to policy makers, we are not able to comment
on all the issues raised.
TARGETS
(1) The validity of the Government's domestic
targets to:
(a) reduce CO2 emissions by
60% below 1990 baseline levels by 2050, and
(b) reduce CO2 emissions by
26-32% below 1990 baseline levels by 2020.
5. NERC welcomes the inclusion in the Bill
of power to amend the percentage emissions reduction targets in
the light of developments in the scientific knowledge about climate
change (or in international law or policy). However, there does
not appear to be any obligation on the Secretary of State to consider
or react to such developments, even when it would be appropriate
to do so. Nor, it seems, would the Climate Change Committee necessarily
be asked to advise on the targets. Its remit (unless asked for
more) appears to be restricted to providing advice on the pathway
to those targets, not on the targets themselves.
6. In view of this, it appears all the more
important to ensure that the targets in the final legislation
reflect current scientific evidence. The IPCC Fourth Assessment
Report Working Group III Summary for Policymakers, published on
4 May 2007,[31]
includes a table (Table SPM.5) of scenarios which indicates that
a 50-85% cut in global CO2 emissions (relative to 2000
emissions—which in the UK were only slightly below those
in 1990) by 2050 would have a reasonable chance of keeping the
global average temperature increase to 2.4-2.0°C only if
global CO2 emissions peak by 2015. Despite the uncertainty
in the predictions, it would appear that a more ambitious target
is almost certainly necessary. Tyndall Centre researchers have
calculated that a 30% chance of not exceeding the 2oC threshold
(widely agreed to be critical) would require the UK to cut its
total carbon emissions by 70% by 2030 and by about 90% by 2050.[32]
7. Of particular concern is the exclusion
of international aviation and shipping emissions from the current
targets (paragraph 5.8 of the Defra consultation document; Clause
15(1) of the Draft Bill). Again, researchers at the Tyndall Centre
have argued strongly that these emissions should be included.
(2) Why the carbon budget for the period including
the year 2020 cannot exceed 32%.
8. A reduction in CO2 emissions
by 32% below 1990 emissions in the budgetary period including
the year 2020 would be significantly off the trajectory suggested
by the need for a cut by 70% by 2030 and 90% by 2050 (Tyndall
centre calculation above).
(3) The rationale for a five-year budgetary
period.
9. The Draft Bill includes only two targets,
and although there would be scope in the secondary legislation
to specify a carbon budget trajectory consistent with those targets,
there would also be scope to allow emissions to remain high in
the early periods, resulting in much higher cumulative emissions
than the Tyndall's calculation allows for if the atmospheric CO2
concentration is to remain within "safe" limits. See
also point 6 below.
(4) Monitoring and early warning systems to
ensure achievement of targets is on track.
10. NERC recognises the importance of monitoring
programmes, and the need to improve the accuracy of predictions
made through modelling scenarios, and is keen to work with Defra
in this area.
(5) Accountability and enforcement mechanisms
to ensure compliance with targets, and sanctions in cases of non-compliance.
11. Not within NERC's remit.
CARBON BUDGETING
(6) The facility-in any given budgetary period-to
"borrow" emissions rights from a subsequent period,
or to "bank" any "surplus" emissions reductions
for use in the next budgetary period.
12. The facility to carry forward the whole
or part of any amount by which the carbon budget for a budgetary
period exceeds the next UK carbon account for the period (Clause
8(3)) could lead to a temptation to set higher budgets in the
periods before 2018-22 than would be consistent with a straight-line
trajectory, resulting in much higher cumulative emissions that
those suggested (schematically) by Figure 4 of the consultation
document. If a large amount were carried forward into the 2018-22
period, would the 2020 target still be regarded as having been
met?
(7) The facility to purchase carbon credits
from outside the UK to meet domestic targets, in terms of their
overall quantity and sources.
13. It is not within NERC's remit to comment
in detail. However, there are arguments that because the UK's
trading and consumption patterns result in substantial "externalisation"
of GHG emissions (and of other environmental impacts), such that
we are probably responsible for more than the claimed 2% of global
GHG emissions (paragraph 3.15 of the consultation document), the
UK should in any case be working to reduce emissions outside the
UK—as well as domestic emissions.
(8) The range and validity of changes in circumstances
in which budgets can be subject to review and revision.
14. No comment.
(9) The reporting procedure and Parliamentary
accountability.
15. Not within NERC's remit.
ADAPTATION
(10) Whether adequate provision is made within
the Bill to address adaptation to climate change.
16. NERC's new strategy will include the
Living With Environmental Change (LWEC) initiative, an interdisciplinary
research programme in partnership with most of the other Research
Councils and a number of Government Departments and Agencies,
led by NERC. The ten-year programme will provide the scientific
knowledge and tools to speed mitigation of, and adaptation to,
environmental change, and information to help decision makers
manage and protect ecosystem services.
17. For appropriate adaptation measures
to be adopted, those involved in planning need to receive accurate
information about the mitigation measures that will be taken and
their probable outcome in the long term—in terms of regional
temperature increases, for example.
18. We welcome the news that the Government
is currently developing a cross-Government framework regarding
adaptation, to be published later this year (paragraph 3.16 of
the consultation document), and would support an obligation on
the Government to report regularly in this area (Clause 37 of
the Draft Bill). We wonder whether the suggested frequency
(every five years) is adequate. It will be interesting to see
whether the forthcoming EU green paper on impacts and adaptation
will influence requirements in the UK (paragraph 3.10 of the consultation
document).
COMMITTEE ON
CLIMATE CHANGE
(11) Its composition and appointment, including
length of tenure and degree of independence.
19. Schedule 1 indicates that the Secretary
of State would appoint the chair and (after consulting with the
chair) appoint the other members. Nothing appears to be said about
the involvement of non-Government parties or other stakeholders
in the selection of members; NERC would welcome an opportunity
to comment. There is also no obvious mention of a regular turnover
in membership, as would be standard for most advisory committees.
20. Schedule 1 lists the experience and
knowledge that would be desirable in the Committee. NERC thinks
that expertise in climate modeling (as a specific component of
climate science), risk assessment, carbon budgeting, ecosystem
services and resource valuation, sustainable development, and
international affairs, should be included on the Committee. The
reference to energy production and supply could helpfully emphasise
energy efficiency and use reduction; there might also be a case
for specific knowledge of transportation, construction, agriculture
and other industry. An understanding of behavioural psychology
in many of these areas (and those listed in Schedule 1) could
be beneficial. Provision could be made to capture expertise in
some of these areas on sub-committees rather than the main Committee.
21. We welcome the implication that the
work and advice of the Committee would be transparent.
(12) Its function and responsibilities.
(13) Its powers in
determining carbon budgets and the provisions within each budget.
(14) The adequacy of its range of functions
in overseeing the targets.
22. As we comment under point 1 above, the
Committee's remit (unless asked for more) appears to be restricted
to providing advice on the pathway to achieving the targets already
set in the Bill, not on the targets themselves. This is surprising,
especially given the inclusion of climate science in the list
of desirable knowledge.
23. The Draft Bill states that "In
making any decision as to the level of the carbon budget for a
budgetary period, the Secretary of State must take into account
the advice of the Committee on Climate Change" (Clause 4
(3)). Similar clauses are included regarding carrying an amount
back or forward from one budgetary period to another (Clause 8(4)),
and regarding alterations to carbon budgets (Clause 13(2)). However,
Paragraph 5.2.6 of the Partial RIA confirms the impression that
"obtaining and taking into account the advice" does
not mean accepting the advice; it is therefore particularly important
that the advice be made public.
(15) The resources available to the Committee.
24. NERC welcomes the proposal to provide
resources for the Committee to, for example, carry out or commission
research (Clause 23(2)). We hope that the Committee and its Secretariat
would, like Defra, seek to build links with all parts of the research
community relevant to the advice and reporting with which the
Committee is tasked.
ENABLING POWERS
(16) The adequacy and implications of the
proposed enabling powers allowing the Secretary of State to establish
greenhouse gas emission trading schemes by means of secondary
legislation.
25. Not in NERC's remit.
INTERNATIONAL IMPLICATIONS
(17) The validity of the Government's view
that the Bill will act as an effective example to drive international
climate change policy post-2012.
26. No comment.
GENERAL
(18) Whether there are other domestic climate
change issues which it would be appropriate to include in the
Bill.
27. None that we are in a position to comment
on.
The Natural Environment Research Council (NERC)
May 2007
31 Climate Change 2007: Mitigation of Climate Change
www.ipcc.ch/SPM040507.pdf Back
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Tyndall Briefing Note March 2007 www.tyndall.ac.uk/publications/briefing-notes/bn17.pdf Back
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