Memorandum submitted by the Association
of Conservation of Energy (ACE)
INTRODUCTION TO
THE VIEWS
OF ACE
The Association for the Conservation of Energy
is a lobbying, campaigning and policy research organisation, and
has worked in the field of energy efficiency since 1981. Our lobbying
and campaigning work represents the interests of our membership:
major manufacturers and distributors of energy saving equipment
in the United Kingdom. Our policy research is funded independently,
and is focused on three key themes: policies and programmes to
encourage increased energy efficiency; the environmental, social
and economic benefits of increased energy efficiency; and organisational
roles in the process of implementing energy efficiency policy.
SUMMARY
— The Intended budget should be adopted
irrespective of a global deal on climate change being reached.
— ACE is concerned that the budgets will
be legally binding except in "exceptional circumstances"—it
is vital that all targets and budgets remain statutorily binding.
— All budgets need to take into account
of the latest climate science and need to be constantly reviewed.
— Emissions from international aviation
and shipping should be included in carbon budgets.
— All existing Government aims and aspirations
need to be made mandatory.
— The Committee for Climate Change should
set targets for the residential, commercial and public services
sectors as well as for Combined Heat and Power, Microgeneration
and renewable energy.
The Committee on Climate Change has produced
two sets of budgets: the Intended budget (emissions reduction
of 42% in 2020), which should apply following a global deal on
climate change and the Interim budget (emissions reduction of
34% in 2020), to apply before a global deal is reached.
ACE believes that the Intended budget should
be adopted irrespective of a global deal on climate change being
reached. The UK needs to reach an 80% reduction in carbon emissions
by 2050 regardless of whether a global deal is reached or not.
The earlier the UK starts on a path to a low-carbon future, the
easier it will be to reach our 2050 target. We advocate strong
early targets as we cannot rely on new technologies becoming available
in the future. The UK must lead by example to demonstrate unequivocally
that it is serious about leading the way in the fight against
climate change. Setting tough early targets, without waiting for
others, will do just this.
We are concerned that the budgets will be legally
binding except in "exceptional circumstances". The Warm
Homes Act 2000 set a legally binding target to end fuel poverty
by 2016 and in vulnerable homes by 2010. However, a recent High
Court judgment ruled that the targets were merely "aspirations"
meaning that these targets can now be missed with impunity.
It is vital that the targets and budgets as
set out by Government will remain statutorily binding—whatever
the cost.
The Tyndall Centre for Climate Change Research
has warned that current carbon budgets may not go far enough[13]
and ACE believes that all budgets need to take into account of
the latest climate science and need to be constantly reviewed.
ACE believes that emissions from international
aviation and shipping should be included in carbon budgets.
Current Government policies need to go further
in order to ensure that the overall budget is met. All existing
Government aims and aspirations need to be made mandatory as,
unless these aims are made mandatory, the Association has limited
confidence that they will be met.
In order for the budgets to be easily met, it
is essential that statutory targets are set for emissions at the
sectoral level. To this end, ACE is promoting the Climate Change
(Sectoral Targets) Bill tabled by Martin Caton MP in February.
Sectoral targets will not only give direction
to Government but will also give business the certainty it needs
to make the appropriate investment decisions. If each sector is
not given specific targets upon which they must report, individual
companies and businesses will present excuses as to why they should
not have to reduce their emissions. Businesses will state that
Government needs to concentrate instead on heavy industry, transport
or aviation, and may try to demonstrate that any cuts they make
will be negligible. Each sector will try to pass the responsibility
for reducing emissions on to the other.
We therefore recommend that the Committee for
Climate Change sets targets for the residential, commercial and
public services sectors.
In order to ensure that the UK's energy needs
are satisfied and to facilitate a move to low-carbon energy sources,
ACE also recommends that the Committee for Climate Change develops
targets for different technologies such as Combined Heat and Power,
Microgeneration and renewable energy.
At the very least, these targets should be no
less ambitious than those to which the Government has already
committed itself, albeit non-statutorily. These targets should
be kept under constant review, to ensure that they remain sufficiently
stretching and ambitious.
27 April 2009
13 BBC News, 20 April 2009, http://news.bbc.co.uk/1/hi/business/7997817.stm Back
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