9th May 2007

Green party District councillors in Stroud have responded to the Government's Consultation regarding the Draft Climate Change Bill. The District Council will be considering this initial response from us as part of their own submission which will come to Cabinet later this month.

Response to Draft Climate Change Bill for Stroud District Council

By Cllr Philip Booth 9th May 2007

1. Introduction
2. Key points
3. Specific responses to questions
4. Additional points regarding the consultation document

1. Introduction

We welcome the Climate Change Bill's introduction. Our responses to the specific questions are below and we hope they will inform the response by Stroud District Council.

2. Key points

- the target of 60% cut in CO2 by 2050 is not enough when looking at all the latest evidence. Research by the Tyndall Centre for Climate Change note the targets are not sufficient to limit global average temperatures to no more than 2 °C above pre-industrial levels: even with the Bill’s current neglect of aviation and shipping, the emission pathway it describes correlates approximately with an 80% and 60% chance of exceeding 2°C and 3°C warming respectively. Friends of the Earth and others are calling for a cut of at least 80% by 2050.

- it is satisfactory for the Government to focus on CO2 to start with - but it is essential to include international flights and shipping.

- five year targets for CO2 are unsatisfactory - we need targets for CO2 cuts set every year like Stroud District Councils' Environment Strategy.

- very deep cuts in human emissions and the restoration of natural sinks are needed globally, quickly and organised in a globally rational and equitable mechanism. The only emissions reduction mechanism that can be deployed to this purpose is Contraction and Convergence as devised by the Global Commons Institute. It already has enormous support, including businesses, environmental groups and the All-Party Climate Change Group who note that "Contraction and Convergence is the only credible global framework within which we can organise to do enough soon enough to avert the worst of global changes already underway.” This Bill should show the Government's support for this approach.

3. Specific responses to questions

Question 1: Is the Government right to set unilaterally a long-term legal target for reducing CO2 emissions through domestic and international action by 60% by 2050 and a further interim legal target for 2020 of 26-32%?

- The government is right to set a unilaterally long term legal target. However, 60% is likely to be too low. The IPCC shows that 2 deg C of global warming is expected by 2050 if we continue business as usual. This will lead to catastrophic environmental damage. Thus a target of a 60% reduction by 2050 will be far too late, especially as so much CO2 has been introduced into the atmosphere over the last 10 years (see comment above).

- The targets must also include all emissions that the UK is responsible for. International aviation and shipping must be included.

- The government needs to decide on what actions will be taken if it finds itself in breach of these targets. In extreme, would airports be shut? Would motorways be closed? Would power stations be taken off line?


Question 2: Is the Government right to keep under review the question of moving to a broader system of greenhouse gas targets and budgets, and to maintain the focus at this stage on CO2?

- Basically yes but as noted above we need to take account of all carbon dioxide.

Question 3: Should the UK move to a system of carbon management based upon statutory five-year carbon budgets set in secondary legislation?

Yes but the problem with a five year budget means that it is almost always the responsibility of more than one Government. Therefore, as noted above, we also need targets for each year.

Question 4: Do you agree there should be at least three budget periods in statute at any one time?

Budgets need to be set with respect to restricting emissions over next 50 years: otherwise generous early budgets will lead to problems later.

Question 5: Do you agree there should be a power to review targets through secondary legislation, to ensure there is sufficient flexibility in the system?

Targets should be reviewed if our scientific understanding of climate change develops and makes it clear that existing targets are inadequate. The 60% target by 2050 tis already now viewed as inadequate – the science has moved on since 2000 when this target was first proposed.    

However there are concerns. A footnote for example suggests that targets could be increased if aviation was to be admitted into the EU carbon trading scheme. This would clearly make a mockery of any target setting and demonstrate that the targets being set are subservient to short term economic growth.

Question 6: Are there any factors in addition to, or instead of, those already set out that should enable a review of targets and budgets?

Targets need to be scientifically based and equitable between countries.

Question 7: Do you agree that, in line with the analysis in the Stern Review and with the operation of the Kyoto Protocol and EU ETS, effort purchased by the UK from other countries should be eligible in contributing towards UK emissions reductions, within the limits set under international law?

Carbon trading has failed to deliver cuts in carbon emissions and the system is full of loop holes and open to abuse. It faces widespread criticism from MPs as being "inefficient, ineffective and unambitious". The Financial Times recently uncovered widespread failings in the new carbon credits markets, suggesting some organisations are paying for emissions reductions that do not take place, while others are making big profits from carbon trading for very small expenditure and in some cases for clean-ups that they would have made anyway.

A properly designed emissions trading scheme could have an important role to play in reducing Europe's CO2 emissions, but it should be flanked by a range of other measures including mandatory national emissions targets.

Question 8: Do you agree it should be permissible to carry over any surplus in the budget? Are there any specific circumstances where you consider this provision should be withdrawn?

No. It is extremely difficult to see how the required downward trajectory in CO2 emissions can be managed if 'banking' were allowed. If the saving of one year were to be banked, then it implies that the following year the incentive for improvements will be reduced. Again, the IPCC report is unequivocal in its call for significant carbon reductions and this needs to be the main objective.

Question 9: Do you agree that limited borrowing between budget periods should be allowed?

No - the targets should be set to include the risk of exceptional circumstances such as cold winters. The CO2 reduction strategy should be set accordingly and be ambitious enough to ensure that these targets are achieved.

Question 10: Is it right that the Government should have a legal duty to stay within the limits of its carbon budgets?

Yes it is critical - however it is important with any law to consider how it would be enforced. If a government breaches its targets what would happen? Would the judicial review have the power to shut airports, close motor ways, take power stations off line, raise fuel taxes, etc. If the judicial review does not have these powers, then how can it be enforced?

Question 11: Do you agree that establishing an independent body will improve the institutional framework for managing carbon in the economy?

Yes, but the Committee needs to be truly independent and given the task to state what is required to prevent climate change, rather than what politicians might want to achieve. A body other than the Government should appoint at least some of the members, and appointments should be scrutinised and approved by the Environmental Audit Committee.

Question 12: Do you agree that the Committee on Climate Change should have an advisory function regarding the pathway to 2050?

There is already an Government Environmental Audit Committee, which has made various key recommendations which the government has largely ignored. The Committee on Climate Change is likely to some extent be duplicating the role of the existing committee, however its independent advice will be welcomed.

In reality the pathway is likely to be determined by what are the most cost-effective measures. The decisions that need to be taken to tackle climate change will require significant political courage to implement. This will be government’s job, not an unelected committee.

Question 13: Do you agree with the proposal that the Committee on Climate Change should have a strongly analytical role?

Yes but it needs to be born in mind that the science and mathematics behind climate change is extremely complicated and is not something that can expected to be easily analysed by this committee.

Question 14: Are these the right factors for the Committee on Climate Change to take into account in assessing the emissions reduction pathway? Do you consider there are further factors that the Committee should take into account?

Issues of international equity are not included on the list of factors and needs to be. Assessments of the levels of cuts required in the UK depend heavily on how responsibility for global cuts is shared out between nation states.

Question 15: Do you agree the Committee on Climate Change should be comprised of technical experts rather than representatives of stakeholder groups?

Yes otherwise conflicts of interest would emerge. However, the question suggests that a committee is the main way forward, and implicit in the scope of membership is that the carbon trading systems are the best way forward. Many other routes are possible: the government could for example increase taxation and limit the development of carbon sources, such as airports.

Question 16: Are these the appropriate areas of expertise which should be considered? Do you consider there are further areas that should be considered or any areas that are less important?

The issue of international equity needs to be included (see question 14).

Question 17: Do you agree with the principle of taking enabling powers to introduce new trading schemes?

This would depend considerably on the proposals arising.

Question 19: Do you agree that the Committee on Climate Change should be responsible for an independent annual report on the UK’s progress towards its targets which would incorporate reporting on a completed budget period every five years?

Yes.  It should also go further in requiring the annual report to be against what the Government has said its policies should achieve each year. 

Question 20: Is statutory reporting the best way to drive forward progress on adaptation while at the same time ensuring Government is able to develop flexible and appropriate measures reflecting developments in key policy areas?

The policies are what matters but a regular report will be useful. The report on adaptation should also include what the Government is doing to assist the developing world to adapt to climate impacts through trade and aid programmes.

4. Additional points regarding the consultation document

4.1. Page 10 Section 1.9: “All four countries of the UK are committed to working in partnership to combat climate change and to achieve the existing (non statutory) target of 60% reduction in carbon dioxide emissions by 2050.”

The bill needs to be clear on what the 60% refers to. It is generally understood that this is to be 60% of the 1990 CO2 emissions. This however is a weak commitment. It would be more appropriate to see a 60% reduction on the average person’s total carbon emissions. This would then include international air travel and purchase of foreign made goods. This prevents the scenario of the UK emissions appearing to go down, when in reality all that is happening is that energy intensive manufacturing processes are simply relocated overseas to developing nations that are exempt from carbon limits under the Kyoto agreement.

4.2. Page 11, Section 2 Generally:

Section 2 of the report understates the overall level of risk that has been identified in other scientific research. There is for example no mention of the increasing likelihood of a runaway global warming scenario developing. All scenarios within the IPCC report indicated rapid and continual warming until the end of the analysis period. No scenario indicated any significant plateauing of the warming trend.

4.3. Page 13 Section 3.5: “In the European context, the EU Emissions Trading Scheme (EU ETS) is a key plank of EU climate and energy policy, which tackles emissions from large point sources of emissions such as the electricity generation sector.”

There is nothing in the EU ETS mechanism to stop energy intensive manufacturing companies from relocating to other countries in the event that they reach their ceiling and their business’s become constrained.

4.4. Page 14 Section 3.7: "EU Ministers have already said that developed countries should consider greenhouse gas emissions reductions in the order of 15-30% by 2008. The UK Government is now pushing for the EU to go further. At the launch of the Stern Review the Chancellor of the Exchequer announced the UK’s proposal for a new European-wide emissions reduction target of 30% by 2020 and then at least 60% by 2050."

It is widely recognised that it will be impossible to achieve these targets whilst the government pursues a policy of airport expansion. It is also worth noting that the open skies policy between the US and EU will lead to a further 50,000 additional flights between the two countries. Also International aviation emissions are not included in any countries CO2 emission targets. Further to this, the impact of other emissions need to be included within the targets such as high altitude NOx emissions from aircraft, and other industrial chemicals which have significantly higher warming impacts that CO2 alone.

4.5. Page 14 Section 3.8: “Ensure that a minimum of 10% of EU transport petrol and diesel consumption comes from bio-fuels by 2020”

The environmental impact of bio fuels needs to be fully considered: if their production isn't properly monitored and controlled, it could spell disaster for rainforests, our own food and water supplies and even climate change. Most of the crops are grown in tropical areas, sometimes cleared rainforest. So instead of growing food for themselves, poorer countries will grow crops to keep our cars on the road, with food prices pushed up as a result. There are also impacts on climate change: as the forests are burnt, both the trees and the peat they sit on are turned into CO2. A report by the Dutch consultancy Delft Hydraulics shows that every tonne of palm oil results in 33 tonnes of carbon dioxide emissions, or ten times as much as petroleum produces – so palm oil is ten times worse than petrol! The link between deforestation and accelerated climate change is well-established, not least in the Stern Review which said that 18 per cent of emissions are as a result of forest destruction. The Daily Telegraph reports (27 April) that the European Commission now admits that their recent EU biofuel targets, which aim to cut carbon dioxide emissions, may have the unintended consequence of speeding up the destruction of tropical rainforests and peatlands in South-East Asia – a process which would increase the rate of global warming. We urgently need proper regulation of biofuels and removal of subsidies that are distorting the market and doing very little if anything to reduce our CO2 emissions.

4.6. Page 14 Section 3.9: "Adaptation is also being addressed at the international level. While it is expected that adaptation will be more prominent in any agreement on how to tackle climate change post-2012, it is currently unclear what form this should take. The question of whether adaptation, which is best delivered at a local level, can be administered by a global, top-down instrument has yet to be tackled."

While adaptation is important it should not be given the prominence of actually reducing CO2 emissions. If it is, then there is the danger that the attitude that sticks is that to do nothing about CO2 emissions is acceptable because we can develop strategies to cope. In reality, the effectiveness of adaptation strategies are limited in the medium to long term. For example, it is not possible to see how we will cope with disrupted food supplies, flooded cities and increased wars being fought over scare resources.

4.7. Page 16 Section 3.13: "The Government would therefore like to enshrine the commitments in the Energy White Paper 200314 to reduce CO2 emissions by 60% on 1990 levels by 2050; and to achieve “real progress” by 2020 (which would equate to reductions of 26-32%) towards the long-term goal within a new legal carbon management framework (outlined in Section 5)."

This statement is incompatible with the government’s road building and airport expansion programmes. The bill makes no reference to the necessity of cutting back these carbon sources.

4.8. Page 16 Section 3.15: "The UK is currently responsible for 2% of global GHG emissions and therefore is clearly unable to address the global problem of climate change alone."

In reality the UK is responsible for much more. International aviation from the UK is not counted. Shipping to and from the UK is not counted. Much of our food is grown abroad in energy intensive and unsustainable methods. Much of our energy intensive manufacturing has relocated to overseas developing countries. Thus we enjoy the benefit of cheaper goods but the pollution associated with their manufacture is accounted for elsewhere.

4.9. Page 22 Section 5.8: “The emissions reduction targets do not currently apply to carbon dioxide emissions from international aviation and shipping. These emissions are not part of the Government’s existing targets, nor are they part of the current Kyoto Protocol target or EU ETS. And there is currently no international agreement on how to include these emissions in national inventories. However, there is scope in the Bill to include these sectors in the legislative framework should international policy change.“

It is imperative that the government includes aviation within its targets and makes a firm statement on this. Aviation is the fastest growing source of emissions. In addition, the high altitude of the emissions significantly increases the radiative forcing impact.

4.10. Page 23 Section 5.10: “Climate change mitigation will not be possible without specific actions focused on reducing CO2 emissions. This means moving to lower carbon technologies across the economy. It is intended that this Bill relates to CO2 rather than other GHGs in order that this focus is maximised.”

Taking action on climate change will also require significant changes in lifestyle and expectation. The past experience on lower carbon technologies has not resulted in an overall reduction of CO2 emissions. Cars engines are more efficient that 20 years ago, but now they are bigger, they travel further and there are more of them.

4.11. Page 28, section 5.28: “In addition, it is imperative that a sustainable emissions reduction pathway is associated with continued strong economic growth and opportunities for all.”

Though this would be the case in an ideal world that environmental and economic concerns should have equal ranking, the fact of the matter is that with severe environmental degradation that will come with global warming the global economy world wide will collapse. A prime and current example is the impact that the continuing drought is having in Australia. Environmental stewardship has therefore got to take priority over economic concerns.

Ends