visit was organised by PRASEG, the Associate
Parliamentary Renewable and Sustainable Energy Group, which is the cross party group for
UK politicians and senior industry stakeholders that exists to promote sustainable energy
issues in Parliament and the wider political community.
Earlier this year, the Government
consulted on its Climate Change Review. My response is below and I have also
provided a link to the consutlation document.
Consultation on the review of the UK Climate Change Programme
Response to Review of the UK Climate
Change Programme Consultation Paper
Lynne Jones MP
Recommendations and Supporting Comments
to Section 2 Introduction
Targets must be legally binding; these
should include existing CO2 emissions targets,
and such sectoral targets as, for example, on renewable energy and CHP.
There should be a guaranteed annual
debate on the findings of the Environmental Audit Committee, which should be charged with
auditing the Governments performance against targets.
and assurances are insufficient to achieve reductions in greenhouse gas emissions. Targets must be made a legal duty in order to
produce the required policy priority to ensure achievement, and mechanisms must be
introduced to ensure that the duty is complied with.
made a specific election manifesto pledge to reduce emissions by 20% by 2010 based on 1990
levels. This was reinforced by the personal
commitment of the Prime Minister. Table 1 of
the review shows that the likely reduction in CO2
relative to 1990 levels will be 14% in 2010 and 12.8% by 2020. This means that not only will the Government not
achieve its target of reducing CO2
emissions by 20% by 2010 but it will be even further away from this target in 2020!
Government now appears to be backsliding on its commitments in paragraph 2.16, which
states that The government is committed to moving
towards our national goal to
carbon dioxide emissions by 20 per cent below 1990 levels by 2010.1 A projected 12.8% reduction in CO2
emissions by 2020 would clearly not be real progress
on a path to cut
emissions by some 60 per cent by about 2050.
the long time-scales involved, it is important that future governments continue to
prioritise reduction of greenhouse gas emissions. Legal
targets, the avoidance of which would require repeal of an Act of Parliament, would help
to bind future governments. Targets missed in
2010 will enable future governments to claim, quite legitimately, that, as a consequence
of this, they are unable to meet targets in 2020 or 2050.
overall clarity is needed in reporting: in particular in identifying overall which sectors
are letting down the Climate Change Programme, and how this should be addressed over the
long-term to 2050.
The review includes detailed
discussion and questions in some areas whilst skating over others and gives the overriding
impression of a review designed to frame the debate. For
example, Tables 3 to 6 give the
projected sectoral emissions by source and end-user to 2020, but there is no sense at all
of what the Government would like to see overall.
there is simply not enough discussion of how total
emissions reductions of 60% by 2050 will be achieved.
This would suggest a need for a much clearer overall strategy.
circumstances, such as the restructuring of industry, the liberalization of the energy
market and subsequent changes in the choice of fuel used in electricity production from
oil and coal to gas, account for about 50 % of emission reductions for all six greenhouse
gases while specific policies and measures account for the remaining 50 %.2 If
targets can be fortuitously achieved, there
is equally a danger that targets can be badly blown off course by other intrinsic factors.
This could lead to the loss of support for specific policies from those sectors and
industries that are implementing them, often at some considerable cost. For example, any shortfall in greenhouse gas emissions
reductions related to the
phasing out of nuclear power must be anticipated by policies which ensure this shortfall
is made up from renewable energy sources (see my comments under Section 6 on Energy
Supply: Nuclear power).
while the emissions from the UK-related share of international air transport are not part
of the Kyoto Protocol targets and are therefore left out of the UK CCP Review, their no
less real contribution to CO2
emissions (predicted in paragraph 8.20 as likely to be 97% of the 16 to 18MtC attributed
to total UK aviation by 2030) will negate the total reductions in CO2
all other sectors projected for 2020 of -21.2 MtC (shown in Table 5). This completely undermines the progress made in
other sectors. It is disappointing, therefore,
that the Government is giving the go-ahead to the construction of new runways and not
considering alternative means of providing for demand for international travel, such as
improved rail links.
should be driven by sectoral targets to ensure that the overall strategy is kept on course
and an equitable balance maintained;
The Government considers
that sectoral targets could take away the flexibility to pursue the most cost-effective
overall mix of policies and measures. However,
they would help to ensure that measures to reduce greenhouse gas emissions are balanced
equitably across sectors and activities, and perceived to be so. Transport, the second largest source of UK end-user
emissions (paragraph 8.1), is a gaping hole in the Governments strategy. Two-thirds of people now understand
that transport emissions are a major factor contributing to climate change (Source:
Department for Transport Transport Trends 2002), and yet the Government appears to
be running scared of tackling the problem (see my comments under Section 8 on Transport).
to Section 6
Change policies should be implemented in the context of wider sustainability.
should be done to promote small-scale projects and embedded micro-power systems to
generate renewable energy.
Government should set a new target for 10% of all household electricity end-use to be
self-generated by 2010.3
Carbon dioxide projections (paragraph 3.11) embody
a steady rundown in nuclear output - falling from 82 TWh in 2003, to 65 TWh in 2010 and 27
TWh in 2020 as existing stations reach the end of their lives. However, in this section, instead of advocating
proactive policies to anticipate the rundown of nuclear output and lead-times for putting
in place alternatives to enable emission reduction goals to be met, paragraph 6.31 conveys
the distinct impression that nuclear power may have to be re-introduced by default, as a
fire-fighting measure to rescue targets!
I am strongly in favour of phasing out nuclear power because the
production of nuclear waste is not sustainable and, if we are to achieve joined-up
thinking, I think it is important to put forward policies for mitigating climate
change in the context of overall sustainability
energy. The Governments commitment to 10% renewable
energy by 2010 and 20% by 2020 is welcome, but must be part of a portfolio of strategies to mitigate climate change. As a recent German Government Energy Agency
report has highlighted, making houses more energy efficient is the most cost-efficient
method of reducing CO2
onshore wind power projects, financial incentives and planning policies should be weighted
towards embedded microgeneration (see below) and smaller-scale, community-based
projects, where the turbines are integrated, in small groups, preferably on brownfield
sites. Communities and not just landowners
must benefit from planning consents for wind turbines and industrial-scale onshore farms
should not be permitted in the UKs last remaining wilderness
areas, sensitive landscape areas, or where they could adversely affect SSSIs and EU Natura
2000 sites. The Government needs to
invest in marine transmission lines for the long-distance transmission of renewable power,
and not in new overland routes.
am concerned that the guidance of the Draft Planning Policy Statement 22: Renewable Energy
- Key Principle 4 says that the wider environmental and economic benefits of renewable
energy generation proposals should be given significant weight, but does not
provide clear guidance on the weight that should be given to other issues, such as other
environmental issues, that may conflict with such proposals.
Key Principle 6 emphasises the need for community involvement in the
process, but does not acknowledge that local communities may have legitimate concerns
about the impact of proposals on their local environment and amenity, which should be
taken seriously. There is no reference to Scheduled
or other nationally important archaeological remains; and there is insufficient guidance
on how to deal with renewable energy developments in areas covered by Local Designations
systems. I would like to see much greater emphasis placed on
encouraging the use of micro-power systems, including micro-CHP, small wind turbines,
photovoltaic systems and ground source heat pumps, in both domestic and commercial
am very concerned at the DTIs decision to end the Governments 2002-2012 solar
PV demonstration programme prematurely in March 2006; that grant allocations are ending
this summer for domestic and other small installations, and this November for large-scale
installations. This decision goes against the
Energy White Paper commitment, and comes at a critical time in the development of the UKs
fledgling industry. Solar PV prices have
fallen by an average 30% since the start of the programme.
Photovoltaics can make a significant contribution to the Governments
medium term renewables and energy efficiency targets, but the uncertainly over the
2002-2012 programme is now undermining investment.
22 specifically excludes Combined Heat and Power (CHP), a serious omission, given the
contribution that CHP can make towards renewable energy supply.
Government target for 10% of all household electricity end-use to be self-generated by
2010 would help to create the right conditions for investment in micropower systems, and
ensure that all Government departments pull together.
to Section 7
incentives and regulations to improve energy efficiency should be extended to the
use in the commercial and services sector has increased by nearly
70% over the last 30 years (paragraph
7.4). This needs to be addressed:
requirement for public sector buildings to display an energy performance certificate
should also apply to the commercial sector.
interest free loan scheme for SMEs that install energy efficiency measures should no
longer be cash-limited in England
gases should also be included in the EU Emissions Trading System.
Government is right to be concerned about the upward trend in emissions of
Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulphur
Sulphur hexafluoride is of particular concern in view of its very high 100-year global
warming potential and the increase in SF6
in the UK of over 50% in the period 1990 to 2002 (UN greenhouse gas emissions figures4),
and the general perception of its industrial usefulness. The EU Emissions Trading System
could be the most effective way to control emissions of these gases.
to Section 8
Government must ensure that Transport makes its full contribution to reductions in
greenhouse gas emissions.
Government should enable properly-planned and attractively-priced public transport
an entire chapter (8) on the Transport sector, there is not a single mention of the words
public transport or rail (albeit public transport gets a mention
in the Executive Summary). Under
Transport strategy (paragraph 8.3), there is simply a bland statement to the
effect that the Governments transport strategy, set out in the 2003 White Paper5
; makes clear that we must balance the increasing demand for travel against our goal
of protecting the environment effectively. However,
the White Paper makes no proposal of what mix of transport it would like to see to ensure
that Transport makes its full contribution to reducing CO2
emissions. For example, there is no target for growth of the rail network. While the White Paper contains many positive
themes, these are not being implemented at anything like an adequate pace in the context
of Climate Change mitigation.
traffic and aviation are the fastest growing sources of climate change gasses; CO2
emissions from road transport are projected to grow by 19% by 2020 (paragraph 8.2),
and yet, for example, the only fiscal measures (paragraph 8.7) introduced are all
intra-car sector specific. There are presented no policy measures specifically
to encourage the public to cut their use of cars and aviation and to promote instead the
use of rail and other public transport or cycling and walking.6 A possible exception is road-pricing (paragraph
8.18) and I welcome the statement that the
time has come to consider the role that could be played by some form of road pricing
policy. Greater progress could have
been made in developing a serious road pricing policy by now and it is urgent that the
Government really grasps the nettle on this
issue. Interestingly under Action in Scotland,
the Review states a commitment to promoting public transport, and rail over road, among
key measures to reduce greenhouse gas emissions (13.14-13.15). Why only in Scotland?
the Government concedes (paragraph 8.5) that the UK is not currently on track to meet the
EU-wide new car fuel efficiency target of 140 g/km for 2008, there is no mention of the
relative environmental friendliness of various modes of transport in terms of carbon
emissions, thereby avoiding the logical conclusion that policies should reflect these
modes relative contributions to climate change7. Given the example of European cities and towns, it
is very disappointing that, at both government and local authority level, there is little
attempt to tap the potential of cycling - another policy area where Government targets
have not been achieved.
The Review trumpets the promotion of innovation and technology
in mitigating Climate Change, but appears to be entirely blinkered in its view of where
technological innovation can take place, restricting its discussion to road fuels. Rail is already the least environmentally damaging
form of powered transport. Further work
needs to be done on electrification and development of hydrogen fuel-cell power plants.
should take account of the needs of people in rural areas, particularly, for example, if
surface transport was to be included in the European Union Emissions Trading Scheme: Where
attractive alternatives are not available, it is not acceptable simply to make car
transport unaffordable for some people. Cross
subsidy from income from road pricing could help provide attractive and affordable
alternatives to road transport.
As Transport 2000 have said, the Government cannot
claim to be serious about tackling climate change until it looks openly and honestly at
transport in the UK.
Governments active pursuit of the inclusion of intra-EU aviation in the EU
Emissions Trading System and intention to make
this a priority for the UK Presidency of the EU in 2005 is very welcome.
Response to section 9 Households
fiscal incentives should be used to encourage householders and landlords to invest in
emphasis should be given to public education; the public needs to be part of the Climate
welcoming the initiatives in the area of households, I would like to see more done to
encourage energy conservation efforts by householders and by landlords, for the following
are responsible for about 30% of total UK
energy use (paragraph 9.1). 70% of
householders are owner-occupiers, most of whom are not in fuel poverty;
learning should not be neglected: it is important
that the general public identifies with and morally buys in to energy conservation in
order to reduce greenhouse gasses.
I would like to see further fiscal incentives introduced, such as:
interest relief on investment in creating sustainable homes
extension of the 5% reduced VAT rate to other energy-saving products, such as A-rated
windows, A- and B-rated condensing boilers, low energy lighting and DIY energy efficient
guidance of the Draft Planning Policy Statement 22: Renewable Energy does not refer to the
importance of energy reduction and energy efficiency measures, even though these are an
important strand in the Energy White Paper. This
is a serious omission, given that more efficient use of existing energy sources, whether
renewable or not, can make a significant contribution towards reducing carbon dioxide
emissions. My own (Birmingham)
City Councils policies seek to encourage developers to design buildings to maximise
solar gain and to use low energy systems but local authorities need national backing in
Stamp-Duty rebate for the installation of energy saving products at the time of home
planning guidance which gives weight to the benefits of building designs which incorporate
energy generation, for example, photovoltaics, wind turbines, and other embedded systems,
and efficiency systems.
Government should provide sufficient investment ito bring all social housing up to SAP 65,
where it is practicable to do so.
Office of the Deputy Prime Minister estimates that it would cost £8.5 billion to bring up
to SAP 65 all social housing for which that level of thermal efficiency is achievable by
means of improvement works. To demolish and
rebuild the social sector homes that could not otherwise be brought up to SAP 65 would
cost an estimated additional £20 billion. (Answer to Parliamentary Question 216476.)
it is not practicable to bring social sector homes up to SAP 65, corresponding reductions
should be achieved by investment in renewable energy.
2 Eichhammer et al (2001),
quoted in Greenhouse gas emission trends and
projections in Europe 2003, European Environment Agency, p11.)