Memorandum submitted by the Institution
of Mechanical Engineers
SUMMARY
In response the Committee's inquiry into carbon
budgets, the Institution of Mechanical Engineers would like to
emphasise two concerns. These are in response to:
— The validity of the assumptions used
by the Committee on Climate Change in setting the budgets. There
assumptions are based on little engineering evidence and take
no account of the UK's capacity to deliver the changes necessary
to achieve the stated goals. This arbitrary method of setting
targets without engineering advice results in significant uncertainty.—
The compatibility of current Government policies with achievement
of the overall budget. In general, we do not believe that current
Government policies will be sufficient to achieve the overall
carbon budgets suggested by the Committee on Climate Change—regardless
of whether they are based on engineering evidence or not.
"the validity of the assumptions used by
the Committee on Climate Change in setting carbon budgets"
1.1 The Committee recommended the overall
emissions target to 2050 as an 80% reduction relative to 1990
and budgets for the periods 2008-12, 2013-17 and 2018-22 leading
to at least a 34% cut in greenhouse gas emissions by 2020. The
overall target has already been accepted by Government and is
legally binding under the Climate Change Act. If the budgets are
also accepted these will become legally binding and have far reaching
implications for the UK's economy, citizens and industries, calling
upon them to meet targets that are groundbreaking in an international
context.
1.2 In this context, the Institution of Mechanical
Engineers is concerned that in coming to its recommendations the
Committee does not carry out a rigorous and detailed analysis
of the feasibility of achieving the overall target and budgets,
in either policy or engineering capability terms. Instead it undertakes
a high level view of what might be possible from an understanding
of currently available technologies. Indeed, these concerns were
echoed by the Innovation, Universities, Science and Skills Select
Committee Inquiry, Engineering: Turning Ideas into reality,
which argued that engineering advice is lacking in the formulation
of important policies and targets. As such the Committee on Climate
Change's recommendations are based on significant uncertainty.
1.3 The UK has a limited current and potential
resource of money, appropriately skilled people and industrial
capacity available to meet the challenge of climate change and
the Institution is particularly concerned that:
— Significant effort on the part of the UK's
engineering community will be required to design, deliver, implement
and maintain the technological infrastructure, systems and devices
needed to meet the overall target and budgets. However the work
of the Committee does not include the undertaking of detailed
studies to determine what is feasible in engineering terms.
— There is no detailed consideration of
the industrial capacity and skills base available, or likely to
be available, in the UK's engineering community to actually deliver
the infrastructure, systems and devices required to meet the budgets.
— There is an over-reliance on immature
technologies to meet the budgets without any rigorous assessment
of how these technologies can be delivered, by when and at what
cost.
— The issue of how emissions of the Kyoto
recognised greenhouse gases will be measured consistently and
fairly across all sectors has not been satisfactorily addressed
to date.
1.4 The Institution therefore recommends
that the Environmental Audit Committee urges Government to:
— Give a wider remit to the Committee on
Climate Change, and sufficient time, to develop and recommend
detailed specific national plans based on a thorough analysis
of what is realistically achievable and measurable. These plans
should recommend the targets and budgets and define the timescale
of delivery (adopting targets and budgets for which detailed analysis
of how they are going to be achieved, by whom and by when, has
not been undertaken is a recipe for failure).
— Work with the engineering profession
to put in place national plans across all sectors, on the basis
of engineering feasibility, capacity and skills, to ensure that
the UK has the ability to meet targets and budgets that become
legally binding.
— Not unduly push the UK's economy, citizens
and industry too far by aspiring to lead on the setting of binding
theoretical targets and timescales possibly beyond our ability
to deliver.
"the compatibility of current Government
policies with achievement of the overall budget"
2.1 In general, we do not believe that current
Government policies will be sufficient to achieve the overall
carbon budgets suggested by the Committee on Climate Change—regardless
of whether they are based on engineering evidence or not. We are
particularly concerned that:
— Too much faith is placed in market mechanisms,
particularly the EU ETS. Neither of the first two phases of the
ETS has produced carbon prices high enough to incentivise the
scale of investment in low-carbon technologies that will be needed,
nor have they provided any long-term certainty over carbon prices
to investors. Without significant reform, future phases of the
ETS are unlikely to be any different.
— There is too much Government emphasis on
large-scale, centralised supply-side solutions, especially for
electricity (eg coal & CCS, nuclear and offshore wind). While
these do offer the prospect of large carbon savings in the longer
term, their complexity and high capital costs inevitably mean
they will take many years to build. Focus on demand-side savings
and smaller-scale, de-centralised supply options is needed to
make significant cuts in emissions between now and 2020.
— There is a lack of real Government leadership
in developing low-carbon solutions. We have no shortage of ministerial
statements and consultation papers; what's needed is action in
support of the goals and objectives set. Public sector procurement
and the tax system are vital components of reducing total carbon
emissions but are not yet being used effectively. The current
appetite for economic stimulus and the public ownership of large
sections of the banking industry provide a real opportunity to
deliver a low-carbon future with much more urgency than might
have been considered prudent when, for example, the 2007 Energy
White Paper was written.
2.2 The Institution therefore recommends
that the Committee urge Government to:
— Instigate a wide-ranging programme to
progressively, but urgently convert existing buildings to higher
standards of energy efficiency. Priority areas include leveraging
the public sector's power as a procurer of commercial buildings,
to build markets and supply chains for energy efficient refurbishment
in the sector.
— Promote and incentivise investment in
district and community heating projects with local "waste"
being used as the fuel resource.
— Introduce a statutory national target
on energy conservation in support of the EU primary energy savings
commitment of over 20% below projected business-as-usual levels
by 2020.
— Provide a long-term framework giving
investment signals for businesses to deliver major energy system
change. Consumers, industry, commerce and government should be
rewarded for becoming "part of the solution".
22 April 2009
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