Please use this
proforma to answer the questions in the above document. The closing date for
the submission of responses is 12 June 2007.
The email address
may also be used for general queries relating to this consultation. Please
mark the subject field Consultation on the draft Climate Change Bill.
To help us analyse
responses, please provide details of yourself or your organisation (* if appropriate)
below.
Targets
and Budgets |
Setting
statutory targets |
| 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%? |
| We
support a unilateral, long-term legal target. This is necessary, both
to set an example for other industrialised countries to follow, and
to provide a clear policy framework for industry/ business. However,
we would advocate deeper reductions than proposed. In mitigation scenarios
reported in the latest IPCC report (Working Group III), a 50-80% reduction
in global GHG emissions is estimated to be required by 2050 to limit
the mean temperature rise to about 2.0-2.4°C. Temperature rises
beyond about 2.0°C are likely to lead to huge global impacts. Given
that the UK's emissions per head are approximately 2.5 times higher
than the global average, equity concerns dictate that the UK should
therefore take on a larger emissions cut. Hence we advocate a cut in
the region of 80%-90% by 2050. We believe that, with appropriate infrastructure,
technology, and economic and social developments, reductions of this
magnitude are both possible and desirable, and could be achieved along
with an improvement in quality of life. |
| 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? |
| Yes.
It is important to focus on CO2 as the main GHG and the one
most deeply connected with our way of life. Separate targets should
be considered for other GHGs, to ensure that the overall greenhouse
effect reduction is at least as stringent as the target for CO2. |
Carbon budgeting |
| 3.
Should the UK move to a
system of carbon management based upon statutory five-year carbon budgets
set in secondary legislation? |
| Yes,
but these should be supplemented by annual non-binding targets, set
in advance of each budget period, against which progress should be reported
to Parliament. |
| 4.
Do you agree there should
be at least three budget periods in statute at any one time? |
| Yes |
Reviewing
targets and budgets |
| 5.
Do you agree there should
be a power to review targets through secondary legislation, to ensure
there is sufficient flexibility in the system? |
| There
should be a power to review targets to take account of developments
in climate science, and to make the UK targets more stringent as international
agreements are strengthened. This should not be a let-out clause if
a future government feels that GHG mitigation is too costly. |
| 6.
Are there any factors in
addition to, or instead of, those already set out that should enable
a review of targets and budgets? |
| Yes.
International aviation and shipping should be included in emission allocations. |
Counting
overseas credits towards the budgets and targets |
| 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? |
| Any
credit from international emissions trading should be very limited.
The government should set a high minimum level for the proportion of
the targets to be achieved by domestic action. Unlimited emissions trading
could lead to the cost of some basic necessities being increased for
poor people, by the price of emissions being pushed up by, for example,
air travel by the wealthy. |
Banking |
| 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? |
| In
general, banking should be allowed. However, the option to revise future
targets downwards should be retained if banking reaches a level so high
that it jeopardises the functioning of or confidence in the system. |
Borrowing |
| 9.
Do you agree that limited
borrowing between budget periods should be allowed? |
| No
borrowing should be allowed. It is not allowed under the Kyoto Protocol
because of the potential for abuse, and this lead should be followed. |
Compliance
with carbon budgets and targets |
| 10.
Is it right that the Government
should have a legal duty to stay within the limits of its carbon budgets? |
| Yes |
The Committee
on Climate Change |
The need
for an independent analytical organisation |
| 11.
Do you agree that establishing
an independent body will improve the institutional framework for managing
carbon in the economy? |
| Yes |
Functions
of the Committee on Climate Change |
| 12.
Do you agree that the Committee
on Climate Change should have an advisory function regarding the pathway
to 2050? |
| Yes |
| 13.
Do you agree with the proposal
that the Committee on Climate Change should have a strongly analytical
role? |
| Yes |
Factors
for the Committee on Climate Change to consider |
| 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? |
| The
Committee should also take account of factors which can affect people's
behaviour and social change. |
Membership
and composition |
| 15.
Do you agree the Committee
on Climate Change should be comprised of technical experts rather than
representatives of stakeholder groups? |
| The
Committee should be derived from technical experts, taking due account
of the differences of opinion within any given field. Technical expertise
exists both within industry and NGOs, hence there should be equal numbers
of representatives from each to provide balance. Financial support from
government should be available in order to ensure the necessary level
of NGO participation.The chair of the Committee should be an academic. |
| 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? |
| Economic,
technological and industrial concerns are over-represented. Expertise
should also be included on the human dimensions of mitigation, including
psychology, culture, ethics and social change. |
Enabling
powers |
Extending
the suite of domestic trading schemes |
| 17.
Do you agree with the principle
of taking enabling powers to introduce new trading schemes? |
| We
agree with establishing the power to set limits on the emissions of
particular groups of organisations and individuals. The possibility
of introducing personal carbon allowances at some stage should be kept
open. |
Benefits
and structure of enabling powers |
| 18.
Do you consider that these
powers are sufficient to introduce effective new policies via secondary
legislation? If not, what changes would you make? |
|
|
Reporting |
The need
for regular, independent monitoring of the UK's progress |
| 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.
The committee should also report to Parliament on the adequacy of current
policies to achieve the targets, and advise it on options for strengthening
policies. |
Adaptation |
| 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? |
| Statutory
reporting should be seen only as part of the development of the strategy
for adaptation. |
