Main Text of Response to Consultation by the Department for Environment, Food and Rural Affairs on the draft Climate Change Bill, 12 June 2007
(Further information about the Draft Climate Change Bill can be found here.)
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.
3. Should the UK move to a system of carbon management based upon statutory five-year carbon budgets set in secondary legislation?
4. Do you agree there should be at least three budget periods in statute at any one time?
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?
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.
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.
9. Do you agree that limited borrowing between budget periods should be allowed?
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?
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?
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?
13. Do you agree with the proposal that the Committee on Climate Change should have a strongly analytical role?
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?
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?
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?
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?
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?