UK Climate Change Strategy: SGR/AESR response

Main text of SGR/AESR Response to the Consultation on the UK Climate Change Programme, 1 March 2005

Architects and Engineers for Social Responsibility (AESR) and Scientists for Global Responsibility (SGR) are organisations of professionals working to ensure that science and technology are used for the benefit of humankind and to maintain an environment in which life can continue to flourish. We believe that strong action is needed to tackle the major problem of global climate change, and hence welcome this opportunity to comment on the UK Climate Change Programme.

As requested in the consultation document, we give the response to the questions first, and other comments follow.

Q15 Credits from Joint Implementation and the Clean Development Mechanism should contribute no more than 50% to any given company’s ETS targets. This would be consistent with the EU position on ‘supplementarity’ as put forward in negotiations on the implementation of the Kyoto Protocol. Ideally, a lower limit should be set, eg 30%, to reflect the importance of reducing emissions domestically within industrialised countries.

Q18 In assessing the viability of alternative non-fossil energy supplies, in addition to the benefits of reduced CO2 emissions and increased security due to reduction in dependence of fuel from potentially unstable parts of the world, the benefits to the balance of payments of energy sources within the UK should be considered.

Q19. Micro CHP will have the best chance of a useful share of the energy market if there is a highly trained workforce able to ensure installation and maintenance is of a high standard, to avoid the problems that have occurred with the introduction of some other technologies (eg condensing boilers). To encourage CHP, it should be mandatory when major housing schemes are being built to make provision for future distribution pipework for supplying heat from CHP (or other renewable sources)

Q21 There is a general need to make further, larger expansions in funding for research, development and demonstration of renewable energy and energy efficiency technologies to order to help speed up progress in this area. There is also a need to ensure an adequate skills supply to these growing industries.

One possible way of increasing finance is to redirect some of the very high levels of public funding currently directed to military R&D (currently in the region of £2.5 billion per annum) to sustainable energy areas. This would lead to a redirection of scientific and technical personnel (currently in short supply in the UK) to helping to tackle climate change. From a security perspective this would makes sense, both reducing the UK’s dependence on imported fuels and reducing factors which can fuel international instability and conflict, for example the creation of environmental refugees because of increased flooding, loss of freshwater supplies and productive land.

A further important measure would be to make it mandatory for all grant schemes for innovation (as outlined in the Government’s recently launched 10y Science and innovation investment framework) to consider whether the new technologies supported would assist or hinder attempts to tackle climate change, and thus those most beneficial could be prioritised. The government should consider greater support for technologies which could have long term benefit but which do not appear attractive to commercial firms having shorter economic time-frames.

One technology which could help the integration of a significant proportion of intermittent renewables onto the electricity grid is large scale electricity storage. It is unfortunate that such a technology that was being developed in the UK (Regenesys) has been sold to Canada. The UK should monitor progress in this area.

A set of technologies which could make a contribution to reducing carbon dioxide emissions is carbon capture and storage in geological formations. AESR has responded to the consultation on the Carbon Abatement Technology Strategy. It is very important that such technologies should be independently assessed to ensure that any geological carbon storage is secure and long-term. Carbon storage in the ocean, we strongly recommend, should not be pursued because of the serious risks of other environmental impacts.

Q24. In addition to improved standards for building lighting, heating and cooling and for appliances, facility managers and customers in the commercial and public sectors, particularly hotels and leisure facilities, should be encouraged not to maintain high levels of lighting in all areas regardless of the level of usage. There is a strong case for expanding the UK Emissions Trading Scheme to include the non-energy intensive sectors, obviously starting with those which make the largest contributions to greenhouse gas emissions.

Q28 The forecast that road transport CO2 emissions will continue to rise is worrying. We fear that the projections of increased emissions from transport will come about unless much more vigorous measures to limit these emissions are taken. In addition to vehicle excise duty and the company car tax regime, the duty on fuel should be at a level to fund a significant Renewable Transport Fuels Obligation (see Q30) as well as providing some incentive for economising on fuel use. In terms of social exclusion policies, there should be more support for rural economies and local facilities and for workers on low incomes who of necessity have to travel long distances.

Q29 Introducing higher rates of vehicle excise duty and company car tax for vehicles with higher CO2 emissions has been a useful first step, but the differentials between high and low emissions vehicles need to be several times greater, such that they become a very strong incentive on purchase of a fuel-efficient car/ car fleet. Eco-labelling of cars will also be very helpful.

Q30 A renewable transport fuels obligation of at least 5% should be instituted. We support the need to include intra-EU aviation in EU emissions trading scheme, and to strong push for global controls on aviation emissions.

Q33 Providing better facilities for walking and cycling should be a priority to encourage these modes of transport for shorter journeys – particularly safe routes to school schemes. Facilitating better access requires good land use planning. Maintaining local services (shops, post offices schools etc) should be seen as part of an overall joined up policy.

Educating and motivating the public on the importance of reducing greenhouse gas emissions is vital.
At the time of the petrol price crisis a few years ago, the government failed to bring home the fact that some of the fuel tax (due to the previous duty "escalator") had an environmental motive. Particularly if a renewable transport fuels obligation were to be implemented, the environmental motivation needs to be made clear.

Q34 It should be mandatory for all house-buyer surveys to include an energy-efficiency rating.
When existing homes are sold, it should be mandatory to install all cost effective energy efficiency measures, ie measures whose cost when repaid over the life of the equipment (or say 15 years for long life measures such as insulation) with interest at building society rates is less than the saving on energy bills. No very elaborate energy survey would be required in most cases as measures like loft insulation, cavity wall insulation and draught proofing are cost effective in virtually all situations.

Q36 Energy companies’ tariffs which give discounts to customers with high energy use should be banned.

Comments on individual sections of the document

Section 2 Introduction

2.18 The studies showing relatively small economic impact of quite major reductions in greenhouse gas emissions (reinforced by the Dutch study presented at the Hadley Centre conference in February) should be widely publicised, particularly in the USA, where grossly exaggerated estimates of the effect on the economy were used as one reason for their rejection of the Kyoto Protocol.

2.20 While we agree that advances in technology will be vital in achieving the major reductions in greenhouse gas emissions required, it is inevitable that changes in lifestyle will also be needed. While many sectors of the economy could continue to grow, ever increasing road and air transport will not be compatible with the greenhouse gas reductions needed.

2.28 G8 Presidency: We accept the importance of the issues mentioned, but in view of the intransigence of the USA at the recent UNFCCC CoP meeting in Buenos Aires, we believe it is also necessary to make it clear to the USA that it will be unacceptable in the post Kyoto timeframe for counties with very high per capita greenhouse gas emissions to not take part in an agreed international framework to limit emissions. Some assessments have shown that it could be within WTO rules to impose economic penalties on countries which gain an unfair trading advantage by ignoring reasonable environmental measures – such penalties could be in the form of duties on imports of goods with high embodied energy. Further, within the generally accepted framework of international law, countries which are significantly damaged by climate change could claim damages from other countries with very large emissions.

Section 3. UK Emission trends and projections

Para 3.5 and Table 1. It is disturbing that baseline CO2 emissions are predicted to rise between 2010 and 2020. This is mainly due to increasing transport emissions. This clearly demonstrates the pressing need for greater efforts in the transport sector to reduce its impact, particularly in bringing aviation into an international framework. (See comments on Section 8)

3.9 (Page 25) There is still much scope for improvement for improvements in vehicle efficiency between 2010 and 2020 beyond the targets currently agreed with the various motor manufacturing associations. (See also Chapter 8)

3.16 Much of the pressure to reduce emissions has been placed on industry. While the climate change levy and associated measures appear quite successful, other sectors of the economy should bear a greater proportion of the effort, to avoid industries migrating to countries with less constraints on industrial emissions

3.19 The use of GDP as a measure of success is often not very useful. Some economic activities which count towards GDP do not add to people's well being. In this particular context, some of the growth in transport (fig 7) is due to people having to commute further because of poor land use planning and shortage of affordable housing within reasonable distance of workplaces. The Government’s other sustainable development indicators, which give a fuller picture of "Quality of Life", should be given greater prominence in policy formation.

Section 4 Policies to reduce emissions

4.5 Any estimate of the social costs of climate change are likely to be very partial and limited. If global greenhouse gas emissions globally are not severely reduced, there is the likelihood of irreversible damage to the earth's life support systems, whose cost cannot be properly quantified in monetary terms. Even assessments of likely impacts on the UK are incomplete if global effects cause major conflicts and flows of environmental refugees.

Section 6 Energy supply

6.12 Revised planning guidance alone is unlikely to make it easy to gain acceptance of onshore wind farms in the face of well organised opposition groups. DEFRA’s climate change communication strategy for a major programme of raising public awareness of the significance of climate change for this and future generations is needed to highlight the importance of reducing greenhouse gas emissions together with accurate information on the role that renewable energy, energy efficiency and other measures can play in reducing greenhouse gas emissions.

6.30/6.31 As well as issues of nuclear waste that it would be necessary to show had been adequately resolved before any new nuclear power programme could be considered, the potential threat from terrorism to nuclear installations and the nuclear fuel cycle would need to be addressed and shown to be addressed.

Section 8 Transport

8.2 The assumption that there will be a fall in the real price of transport fuels appears doubtful. Many analysts have predicted that globally, low cost oil supplies will fall short of potential demand in the relatively near future. This possibility should be an additional reason for reducing fossil fuel use in the transport sector which is almost entirely reliant on oil products.

8.5 Customer choice, currently in the UK directed towards more fuel profligate vehicles than elsewhere in Europe, can be influenced by publicity. If the Voluntary Agreements with motor manufacturers were to be made more stringent after 2008/9, this could encourage manufacturers to positively promote economical vehicles rather than glamorise large cars and SUVs.

If road pricing or congestion charging were to be introduced on a wide scale, the charges should be such as to penalise fuel profligate vehicles. (see also response to para 8.18)

8.9 The fuel duty incentives for alternative fuels should reflect more closely the CO2 reduction benefits of the different fuels. This would lead to a higher incentive for bio-fuels and a lower incentive for LPG than at present (particularly noting that technical advances have greatly reduced the pollutants from petrol and diesel fuels that were the major driver for favouring LPG)

8.13 As well as supporting the development of new vehicle technologies, it is important in the relatively near term to make sure that vehicles using existing technologies that can achieve very good levels of fuel economy are introduced on a wide scale. Cars achieving emissions of less than 100gm/km of CO2 are already available. As the average fuel economy of the vehicle fleet improves, fuel duty should be increased at least so that the cost per km driven does not fall. More ambitious targets for the voluntary agreements with the car manufacturers (ACEA, JAMA and KAMA) should follow the present agreement with the European Commission – the technology to achieve major reductions in emissions exist and could be introduced without significant impact on the price of vehicles. (see also Q29 above)

8.16 AESR responded to the 2004 government consultation on biofuels strategy. We believe that the EU should be the unit for promoting the wider use of transport biofuels, given the greater potential for biofuel production in some countries with larger less intensively used land areas than the UK. Also a wider range of crops than considered in the strategy could both increase the potential quantity of biofuels that could be produced and reduce the costs relative to the rather high cost crops assumed.
At least two processes for producing transport fuels from woody matter or ligno-cellulosics are at an advanced stage of development, and support should be given for the introduction of such fuels. (See 10.11 below)

8.17 Given the potential for reducing CO2 emissions by use of bio-fuels in a relatively short time-scale, introduction of a renewable transport fuels obligation seems desirable. The feasibility of introducing more than 5% biofuel in bio-diesel in the existing vehicle fleet needs fully investigating. It should be noted that in the USA, all the major manufacturers produce vehicles that can run on 85% bio-ethanol.

8.18 (page 60) One suggestion for road pricing is that it should partly replace fuel duty. Any scheme that is introduced should not reduce the economic incentive to minimise fuel use (and hence CO2 emissions). Thus road pricing should be in addition to present levels of fuel duty, or the charge should bear a close relationship to the assessed fuel consumption of the particular vehicle in the relevant road conditions.

8.21 We support the idea of bringing aviation emissions into any climate change framework, and initially into an EU Emissions Trading scheme. Any cap agreed for aviation emissions however must be tight as much air travel is for luxury purposes.

Section 9 Households

9. 17 In relation to the policy goal of reducing fuel poverty, this should be addressed by major programmes to improve energy efficiency of the homes of people on low incomes and by ensuring adequate levels of income benefits to vulnerable people, rather than seeking to maintain low energy costs for all customers, which could limit the scope for reducing emissions, for example through use of renewables which may be more expensive than conventional fuels.

9.33 It is vital that micro-CHP installers and maintenance staff should be well trained to avoid the teething troubles that have damaged the reputation of some other technologies as they were introduced.
Building control departments should make sure that all new buildings, as built, meet the specification on energy relating matters – this is not always the case.

All new houses should have solar hot-water systems installed – installation at time of construction of standard units produced in large numbers would reduce costs significantly.

As part of the landlords’ energy saving allowance scheme, whenever a tenancy changes, it should be mandatory to install cost effective measures – with the incentive for the landlord that any revised rent could take account of lower outgoings on fuel bills.

Section 10 Agriculture, Forestry and Land Use

10.11 AESR has responded to the government consultation on biofuels, and encouraged greater production of energy crops

Processes which could produce liquid biofuels in greater quantity and with a more favourable energy ratio than the sugars, oils and starches, using lignocellulosics (ie woody, leafy or other fibrous plant material) are at an advanced stage of development. The UK and EU should support these developments as a means of increasing the potential for transport biofuels.

Given the larger land area available in other EU countries, especially the new accession states in Central and Eastern Europe, it would seem sensible for the promotion of biofuels to be done on a European scale, using emissions trading if appropriate if transporting such fuels long distances is non-optimum.

Section 11 Public sector

11.6 We fully support programmes in schools to encourage a good understanding of climate change issues and the relation to energy use. However, as well as in schools, a major effort is needed to provide the public with good information on the issues, and in particular what are the most effective measures people as individuals and in households can take. Whatever efforts the government makes, they will not succeed without the active support of the public. This is particularly important in face of a well funded campaign to discredit climate change science.

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