Written evidence submitted by the Global
Commons Institute |
1. The UK's ambitious carbon budgets must be
considered in the context of the necessary global budgets that
have already been set in the UK Climate Act by UK government.
The four carbon budgets are governed by that.
2. Little has yet been achieved at the global
level. For as long as this is the case, the UK will be exposed
to as yet unquantifiable economic pressures and furthermore, like
other parties to the UNFCCC, will be hostage to the worsening
rates of global climate change that will result in incalculable
economic pressures as well.
3. There is an urgent requirement for the government
to develop a clear strategy for achieving UNFCCC compliance in
the international arena, taking a lead in the wider creation and
adoption of that strategy and setting commensurate global emissions
4. Until this is achieved, the Climate Act and
its budgets remain speculative.
5. The Global Commons Institute is a London based
policy think tank. The Institute is the author of the UNFCCC-compliant
Contraction and Convergence framework for a global agreement on
climate change mitigation.
6. This memorandum focuses on the global commitments
required to avoid dangerous climate change without which UK ambitions
will disintegrate. Those requirements form the foundation for
the budgets made law within the Climate Change Act. To date, there
has been little agreement on emissions reduction budgets at the
UNFCCC level, although the UK carbon budgets are considered to
be consistent with the European Commission's proposed reduction
trajectory as far as it goes.
7. In its Policy Statement of May 2011, the government
stated: "The proposed level of the fourth carbon budget is
consistent with what the UK needs to do to play its part in international
efforts to limit the expected increase in global temperature above
pre-industrial levels to two degrees Celsius, consistent with
scientific advice on avoiding the dangerous effects of climate
change. Our analysis confirms that the proposed level of the fourth
carbon budget is also consistent with the trajectory set out by
the European Commission in its March 2011 Roadmap".
8. Here, we comment on the limitations of the
UK Act and its budgets in the absence of an overarching global
agreement on international carbon budgets.
2. GLOBAL CARBON
9. The UNFCCC entered into force
in March 1994. It committed signatory nations to achieve a safe
and stable level of greenhouse gas concentrations in the atmosphere
according to the principles of equity and precaution.
10. The Kyoto Protocol of 1997 committed
Annex 1 nations under the UNFCCC to reduce greenhouse gas levels
by 5% of 1990 levels in the period 2008-12.
11. The European Commission established
the European Climate Change Programme (ECCP) in 2000 to help identify
the most environmentally effective and most cost-effective policies
and measures that can be taken at European level to cut greenhouse
gas emissions. The immediate goal was to help ensure that the
EU meets its target for reducing emissions under the Kyoto Protocol.
This requires the countries that were EU members before 2004 to
cut their combined emissions of greenhouse gases to 8% below the
1990 level by 2012. A resolution on 24 May 2011 set the EU goals
to 30% by 2020 with the aim of achieving 60-80 per cent by 2050.
It also states that the EU should take on a leadership role in
international climate issues.
12. Bali road map 2007 agreed enhanced
national/international action on mitigation of climate change,
including, inter alia, consideration of measurable, reportable
and verifiable nationally appropriate mitigation commitments or
actions, including quantified emission limitation and reduction
objectives, by all developed country Parties, while ensuring the
comparability of efforts among them, taking into account differences
in their national circumstances. No specific numbers were agreed
for emissions reduction. It recognized that there was a need for
"deep cuts in global emissions" and that "developed
country emissions must fall 10-40% by 2020".
13. The UK Climate Act 2008: The Act aims
to encourage the transition to a low-carbon economy in the UK
through unilateral legally binding emissions reduction targets.
This means a reduction of at least 34 percent in greenhouse gas
emissions by 2020 and at least 80% by 2050. Each carbon budget
covers a five-year period, with three budgets set at a time. The
first three carbon budgets will run from 2008-12, 2013-17 and
2018-22. The fourth carbon budget, covering the period 2023-27,
must be set by 30 June 2011.
14. The Copenhagen Accord 2009: member
states agreed that: "To achieve the ultimate objective of
the Convention to stabilise greenhouse gas concentration in the
atmosphere at a level that would prevent dangerous anthropogenic
interference with the climate system, we shall, recognizing the
scientific view that the increase in global temperature should
be below 2 degrees Celsius, on the basis of equity and in the
context of sustainable development, enhance our long-term cooperative
action to combat climate change". The Accord implies that
a consensus has been reached among climate scientists, although
how this has been measured is not known. There is no mention of
the UNFCCC principle of precaution.
15. COP 16 in Cancun 2010: Deep
cuts in global greenhouse gas emissions are required, with a view
to reducing global greenhouse gas emissions so as to hold the
increase in global average temperature below 2°C above pre-industrial
levels, and that Parties should take urgent action to meet this
long-term goal. Rich countries were called on to reduce their
greenhouse gas emissions as pledged in the Copenhagen Accord,
and for developing countries to plan to reduce their emissions
16. The UK Fourth Carbon Budget 2011:
The Fourth Carbon Budget (2023-27) and the three previous
budgets continue to be based on the calculation of global emissions
reductions contained in the report "Building a low carbon
economy" published by the Committee on Climate Change
in December 2007. Section 3 of the report states: "It is
not now possible to ensure with high likelihood that a temperature
rise of more than 2°C is avoided. There is a significant
probability that the world will enter the danger zone of increasing
human welfare impact. We therefore recommend that the objective
should be to limit our central expectation of temperature rise
to 2°C, or as close as possible".
17. The global emissions reduction scenario selected
by the CCC was 2016 4% Low. This was given a 44% probability for
staying within 2oC. Since those calculations were made
in 2007, there have been developments in the science that give
even greater cause for concern. In "Beyond 'dangerous' climate
change: emission scenarios for a new world" by Anderson and
Bows (Phil. Trans. R. Soc. A, 2011, 369) is the
conclusion: "there is now little to no
chance of maintaining the global mean surface temperature at or
below 2°C. Moreover, the impacts associated with 2°C
have been revised upwards, sufficiently so that 2°C now more
appropriately represents the threshold between 'dangerous' and
'extremely dangerous' climate change." This is also the view
held by a number of government appointed advisors.
18. There has been no substantive and sufficient
agreement on global emissions reduction since 1994 when UNFCCC
signatories committed themselves to achieve a safe and stable
level of greenhouse gas concentrations in the atmosphere according
to the principles of equity and precaution. No such agreement
is in prospect and Kyoto, for what it is worth, expires next year.
3. RISK AND
19. The government has said that "the fourth
carbon budget is significantly further ahead in the future so
there is greater uncertainty about technical feasibility and risks.
However, the decision to set an ambitious fourth carbon budget
now, on the basis of the best available evidence, is a critical
one for the UK climate and energy policy framework and will help
drive the innovation, technological development and entrepreneurship
in the UK that we need to deliver a dynamic, low carbon economy
that is internationally competitive". (Policy Statement,
20. Risk and uncertainty also exists in the science
and in the methods and tools of the scientists. This has led to
confusion in the international policymaking process which itself
has been complicated by time consuming debates about justice and
how to apply the UNFCCC's principle of equity.
21. Climate uncertainty is a characteristic of
the climate system. As our knowledge of climate science increases,
perceptions of the types and levels of uncertainty may increase
or decrease. But risk and uncertainty in climate change involve
a large degree of subjective judgement and erring on the side
of the UNFCCC's principle of precaution.
22. Future emissions are a product of complex
dynamic systems, determined by driving forces such as demographic
and socio-economic development and technological change. However,
in order to achieve and maintain safe levels of greenhouse gas
[ghg] concentration and temperature, there are two things we can
do: reduce ghg emissions and protect the land and ocean sinks.
To guide this we need to estimate future global emissions contraction
that is consistent with the two degree limit and agree terms for
how this is to be shared.
23. The IPCC emissions scenarios developed for
climate modelling are approximations of future emissions and the
various models that process them usually arrive at different conclusions
for a given scenario. A new generation of scenarios for the Fifth
Assessment Report offers some improvement. The climate models
that process them are in a continuing state of development, but
policy makers are obliged to make decisions in time and cannot
wait for perfection.
24. The principle of precaution should have profound
influence on matters in this context of complexity and uncertainty.
Article 3.3 of the Convention makes specific reference to this:
"The Parties should take precautionary measures to anticipate,
prevent or minimize the causes of climate change and mitigate
its adverse effects. Where there are threats of serious or irreversible
damage, lack of full scientific certainty should not be used as
a reason for postponing such measures".
25. We must openly recognise uncertainty in all
its forms and respond to it rationally and in a precautionary
manner. Knowledge of the science and its uncertainties must be
distilled to support the quantification of limits on temperature,
concentrations and emissions as a first step in defining a global
4. UK UNCOMPETITIVENESS
26. The government recognises that there are
economic risks associated with adopting a unilateral carbon emissions
reduction plan, although it plays down the potential impact of
the Fourth Budget:
27. "Signing up to an ambitious Fourth Carbon
Budget will result in no additional costs to consumers during
this parliament. We will undertake a review of progress in early
2014 to ensure our own carbon targets are in line with the EU's.
And we are working up a package of measures to be announced by
the end of the year to help energy intensive industries adjust
to the low-carbon industrial transformation while remaining competitive".
(DECC Secretary of State, 17 May 2011)
28. A longer term view was taken by the Committee
on Climate Change in its Fourth Carbon Budget Report:
29. "The assessment of competitiveness impacts
in our 2008 report showed that there were risks of leakage for
a limited number of sectors subject to a combination of high energy
costs and significant exposure to international competition, accounting
for less than 1% of GDP nationally, but significantly more at
the local level. We argued that it would be important to address
these impacts, as recognised by the EU in granting free allowances
to firms in the EU ETS in sectors potentially subject to competitiveness
risks. If a global deal for the 2020s were to result in carbon
constraints for some but not all countries, there would be the
risk of leakage, particularly as regards energy-intensive industries.
This could be addressed either through sectoral agreements or
through the imposition of border carbon price levies, with the
specific policy instrument to be determined as any competitiveness
risks are better understood." (The Fourth Carbon Budget,
30. However, business leaders and others have
pointed out that UK business will become increasingly uncompetitive
under the existing four carbon budgets for as long as it is not
operating on a level playing field. The only way to create this
level playing field is to achieve and implement a UNFCCC-compliant
global agreement. There is little chance of achieving this before
expiry of the current Kyoto targets in 2012.
31. The government also recognises that there
is a need to be able to respond flexibly to unforeseen economic
developments: "the Committee on Climate Change advised that
we should aim to meet the Budget through emissions reductions
in the UK rather than relying on carbon trading, such as under
the EU Emissions Trading System or the purchase of international
credits from projects abroad. We will aim to reduce emissions
domestically as far as is practical and affordable. But we also
intend to keep our carbon trading options open - to maintain maximum
flexibility, and minimise costs in the medium-long term. Given
the uncertainty of looking so far ahead, this is a pragmatic approach."
(DECC Secretary of State, 17 May 2011).
32. There would seem to be serious exposures
for UK business and the economy in general that cannot be accommodated
without a global agreement. Implementation of a global (multi-regional)
carbon cap and trade arrangement would provide a very effective
driver for global emissions reduction.
5. UNFCCC COMPLIANCEWHAT
33. Any UNFCCC-compliant policy framework will
require policy makers to agree trajectories for global emissions
reduction to meet the agreed temperature limit of two degrees
centigrade. This requires decisions to be made on the concentration
level of ghg's to be targeted and the rate and time period of
global emissions reductions to achieve the two degree limit. Each
of these three choices, temperature, concentrations and emissions,
bears considerable risk and uncertainty.
34. The C&C framework has already been used
to lay out the UK's global prescription in the UK Climate Act.
In their international strategy for the negotiation of this they
should note that negotiating a C&C deal globally means that
if for reasons of "urgency" the global contraction rate
has to be accelerated, then the international convergence rate
has to be accelerated relative to that.
35. The government has made clear its intention
to take a leading role in achieving UNFCCC compliance:
36. "The Government's goal is to stabilise
atmospheric greenhouse gas concentrations to avoid the dangerous
effects of climate change, and to adapt to those effects that
have become irreversible. The UK has a vital role to play as a
leader in the global initiative to tackle climate change and is
working through the European Union and the United Nations Framework
Convention on Climate Change (UNFCCC) to reach a global agreement
on action to mitigate climate change. Without urgent and coordinated
action across the world, the risks of climate change will become
a dangerous reality for the whole planet." (Implementing
the Climate Change Act 2008: Policy Statement, May 2011).
37. It should lead by putting forward proposals
for a rational and scalable global framework for climate mitigation.
Within this framework, the UNFCCC principle of precaution should
have profound influence. Article 3.3 of the Convention makes specific
reference to uncertainty and the need for precaution:
38. "The Parties should take precautionary
measures to anticipate, prevent or minimize the causes of climate
change and mitigate its adverse effects. Where there are threats
of serious or irreversible damage, lack of full scientific certainty
should not be used as a reason for postponing such measures".
39. UK carbon budgets would be subject to this
agreement and would then be fit for purpose.
13 June 2011