Tuesday, May 1, 2007

Comments on the Governments Climate Change Bill

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The following are my in ital comments on the Government's Climate Change Bill. You can access the bill by clicking here

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% will prove to be far too low. Also 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? The bill in its current form suggests that if a target short fall arises, the government should cover this by buying offsets from developing countries. This assumes that the number opportunities for offsetting always exceed the opportunities for polluting. This is a dangerous and ill considered assumption.

The bill does not outline what temperature rise the world would expect if the CO2 emissions where reduced by 60% by 2050. However, government currently talks about keeping the temperature rise to 2 deg C by 2050. Given the data in the IPCC report, an temperature increase of this magnitude could be expected with the proposed targets. Disturbingly, the IPCC report shows that if 2 deg C of global warming occurs by 2050 then we can expect to be on an upward trajectory where the temperature will continue rise rapidly after this date and far beyond the 2 deg C into territories that the planet has no experience of. The most likely scenario in this case is the certain end of civilisation and most life on the planet. Thus a target of a 60% reduction by 2050 will be far too little and too late.

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?

The government should make a bold stance on the question of broader greenhouse gas targets. In general, the global warming effect of a gas in proportional to its molecular weight and density. Some of the gases currently entering the atmosphere such as nitrous oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs) cause global warming either hundreds or thousands on times greater than CO2. The nitrous oxide emissions emitted from aviation at high altitude is a particulary aggresive source of warming and this is likely to continue to increase, despite the best efforts of the engine manufactures to reduce the amount of these emissions.

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

The country needs to be careful about setting budgets. Both the Stern report and the IPCC report highlighted the need to make urgent and significant cuts in CO2 emissions. If a budget is prepared which is subsequently achieved then it will remove the incentive to make further improvements during the period. The objective is simple, 90% CO2 emissions cuts are needed to avoid dangerous climate change.

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

Yes – however the future budgets should be set solely on the basis of the scientific knowledge, and not on the other factors as suggested in section 5.17 of the report.

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?

There should be no powers to review targets through secondary legislation. The climate change bill states in section 5.22 “For reviewing the 2050 and 2020 targets these factors would be: scientific knowledge about climate change.” Current scientific evidence is unequivocal and given the emerging evidence on climate change, it can be concluded that the current predictions will not change unexpectedly for the better. The introduction of powers through secondary legislation to allow “flexibility” in the system will ultimately provide a range of “get out” clauses and opportunities if the targets are not met.

The foot note in referenced in page 29, section 5.24 indicates why secondary legislation should not be considered. The footnote 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?

Yes – there is considerable scientific and economic work ongoing in this country and abroad that is investigating the impact of climate change and its associated impacts. At present the only data sources currently taken into account in this climate change bill are the Stern report and the IPCC climate change study. The time lag taken in preparation of these and other similar reports delays the decision making process. Other data sources that should be monitored closely for advanced warning of change are numerous and include diverse areas such as monitoring acidity of oceans, monitoring ice cap changes, ongoing evaluation of mathematical modelling techniques and computer simulations. All these data sources should be constantly assessed in evaluating the appropriateness of targets. For example, during the consultation period of this document, two seriously concerning reports have been release, one stating that the CO2 level in the Southern Ocean has reached saturation point and the other is that carbon emissions world wide have now accelerated to 3% per annum growth, up from 1% per annum growth before 2000.

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?

No – the emerging evidence on carbon trading is showing it to be a system full loop holes and open to wide abuse. A investigations by both the Financial Times and the Guardian have uncovered widespread failings in the new carbon credit 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. Carbon trading is rapidly proving to be an ineffective and highly artificial market mechanism that adds significant costs for little or no emission reduction. It is worth noting that the climate change bill recognises that it does not even known how carbon trading would work between between sophisticated economies such as California and the EU. It also worth noting that the climate change bill quotes in section 5.27 that the carbon market is currently worth €22.5bn, of which €18bn of this is in Europe. Thus the carbon trading mechanism will not stop energy intensive industries moving to abroad to developing countries that are not part of the mechanism.

The debates within the aviation industry also highlight the difficulties and its ineffectiveness. It is recognised by the Government’s environmental audit committee that if aviation were included within the EU ETS system, it would require the eventual closure of almost all manufacturing industry in the EU to compensate for its emissions.

In addition when questioned by the Environement Audit Committee, the transport sectretary (Douglas Alexander) said of the European Carbon Trading Scheme:-

"In terms of where we are in those negotiations, the evidence from the public statements of Lufthansa, even in the last 48 hours, evidences that the argument is not yet won within the aviation community. It is also no secret that some of our international partners are less than convinced of the merits even of a European scheme, never mind a wider scheme given the global nature of air travel."

It is therefore an act of total folly to base the carbon reduction strategy of somewthing as ill considered and failing as the European Trading Scheme.

The government will far more effectively signal its intent on global warming by significantly raising fuel taxes and restricting supply in carbon producing activities, such as stopping further airport expansion and road building.

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 could 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 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. The objective needs to be to achieve a 90% emissions cut.

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

Yes - 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 it is meaningless.

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

Yes – However the effectiveness of this independent body would be improved if it was international. The government should consider liaison with other countries in developing an international body for monitoring carbon in the economy. This is potentially a role for the United Nations, thus limiting the risk of government influence. In this scenario, the risk of oil producing countries subverting the analysis and conclusions would have to be managed. Thus any participants would have to declare a conflict of interest in advance. This situation has already risen with the current round of IPCC reports, where Saudi Arabian officials successfully lobbied to have contentious parts of the report removed.

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

Any well thought out professional advice will be useful to ministers. However, the question asks only if the committee should have an advisory function. Ultimately, anyone is at liberty to give anyone else advice. Thus the committee would not be any different to anyone else in the street.

It is up to recipient of the advice to determine what to do. Currently the government receives huge amounts of advice on this subject from scientists, pressure group and the existing committees. For example, the environmental audit committee has made various recommendations and critiqued the ideas on carbon trading. The government has not listened to any of the recommendations of this committee. The Committee on Climate Change is likely to be duplicating the role of the existing committee. As the government does not listen to the existing committee's recommendations, there is not much chance of it listening to the new committee.

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

There is role for the committee on climate change with regard to collection and dissemination of data. However, it terms of detailed analysis and strategy development this is better handled with the existing research institutions that are already in operation in our universities and other institutions. Many of these are acknowledged as world leading. Regrettably their research has not been listened to. It would be more cost effective, quicker and robust to develop a more arterial route into the existing tried and tested knowledge centres rather than to attempt expensive and unreliable duplication.

It needs to be remembered that the science and mathematics behind climate change is extremely complicated and is not something that can expected to be successfully analysed by an ad hoc committee which is unlikely to have the strength in depth and computing power to conduct meaningful analysis.

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?

This question presupposes that it has already been decided to instigate the Climate Change Committee. If the climate change committee were to take into account the factors outlined, it would result in a conflict of interests and general confusion. As stated in a previous answer, the management of climate change will require painful decisions to be made and this is best done an elected government, rather than an unelected committee. The most appropriate policing of government policy would be an international committee, perhaps under the auspices of the United Nations.

Question 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 comprised of technical experts rather than representatives of stake holders, otherwise conflicts of interest would emerge. However, the question presupposes that a committee is the best way forward, and implicit in the scope of membership is that the carbon trading systems are the best way forward.

If the government had the courage to increased taxation and to limiting the development of carbon sources, such as airports and roads, much of the committee’s functions would be eliminated.

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?

There is no need for an emissions trading representative. This is a flawed system and anyone taking on this role, will be doomed to failure.

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

No – better by far to manage demand through taxation and supply side restrictions rather than introduce even more artificial markets.

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 - this should be the sole task of the committee.

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?

Statutory reporting is one way to driver forward progress. However the best way is to lead by example and start making the cuts into the economy that are necessary to reduce CO2 emissions.

Other comments on the bill::

Page 7 Section vi

“The Bill proposes to create a new institutional framework within which to manage the transition to a lower carbon economy, through establishing a new independent body, the “Committee on Climate Change”, to advise Government on how to reduce emissions over time and across the economy. This expert body will advise on the optimum trajectory to 2050 by giving advice on the level of carbon budgets, on how much effort should be made in the UK and overseas and how much effort should be made by sectors of the economy covered by cap and trade schemes and by other sectors.”

It would appear that this committee does not have any statuary powers and is only able to offer advice. What is intended on its remit on overseas emissions? Is this to advise developing nations how to reduce their emissions, or is limit the emissions that they produce by their manufacturing of our energy intensive products.

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.

Page 11, Section 2 Generally

Section 2 of the report understates the overall level of risk that has been identified in other scientific research. Namely, there is 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. None of the likely scenarios indicates any significant plateauing of the warming trend.

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.

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 20208. 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 and motor way building. It is also worth noting that the open skies policy currently being negotiated 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.

Page 14 Section 3.8

“Ensure that a minimum of 10% of EU transport petrol and diesel consumption comes from bio-fuels by 2020”

What is the rational for the 10% and has any work been done into trying to equate this into required land?

The environmental impact of bio fuels needs to be fully considered. Huge areas of land are needed to produce meaningful amounts of fuel. The crops require enormous amounts of fertiliser, transport, farm machinery and processing. All of which is negates their benefit. The area needed then encroaches on scarce environmentally unspoilt land, which is needed to reduce the CO2 in the atmosphere.

Also, the planets food supplies are likely to be under stress in the future as agricultural productivity decreases in a warming world and the world's population continues to grow to its expected maximum of 9.5 billion. Already riots have broken out in Mexico due to the increased corn prices which have been driven upwards by the demand for bio fuels in the US. Targets for increasing bio fuels will inevitably lead to further disturbances.

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, especially when all these problems come at once.

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 emitting sources.

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. This statement is therefore misleading and leads to the view that there is no point in making significant cuts and changes to life styles.

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.

It is also worth considering that the UK has some of the busiest airport in the world, and so is in a strong position to apply leverage on this source.

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, a limited amount can be achieved with efficiency improvements. 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.

It is also vital that proposals for reductions in other none CO2 green house gases are incorporated into the bill.

Page 27 Section 5.17

“It is proposed that carbon budgets should be set with regard to a number of factors. They should provide a trajectory to meeting our 2050 target and 2020 interim target28, whilst being consistent with international law. They should also be set by taking into account a number of factors, including:

(a) scientific knowledge about climate change;
(b) technology relevant to climate change;
(c) economic circumstances, and in particular the likely impact of the decision on the economy and the competitiveness of particular sectors of the economy;
(d) fiscal circumstances, and in particular the likely impact of the decision on taxation, public spending and public borrowing;
(e) social circumstances, and in particular the likely impact of the decision on fuel poverty;
(f) energy policy, and in particular the likely impact of the decision on energy supplies and the carbon and energy intensity of the UK; and,
(g) international circumstances.”

There are far too many get out clauses within this section to which will allow targets to be relaxed. The only important point is scientific knowledge about climate change. As the bill states, this is now unequivocal. Fundamentally, carbon budgets should be set with regard to the scientific knowledge only.

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.

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