Carbon Budgets - Environmental Audit Committee Contents

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 budgets.

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.


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 as well.

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.


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, May 2011).

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 mitigation strategy.


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, Dec. 2010).

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.


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

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Prepared 11 October 2011