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Appendix 1: Officer Response to Defra consultation on Draft Climate Change Bill Patrick Erwin / James Hardy Climate Change Legislation Team Area 4/F5 Ashdown House 123 Victoria Street London SW1E 6DE Contact: Direct Line: Fax: Email: Jared Boow 020 7934 9951 020 7934 9950 [email protected] Our Reference: London Councils response to Defra’s Climate Change Bill consultation Your Reference: Date: 14 June 2007 Dear Mr Erwin/Mr Hardy Re: Defra’s consultation on the draft Climate Change Bill. 1. London Councils is committed to fighting for resources for London and getting the best possible deal for London’s 33 councils. Part think-tank, part lobbying organization, and part service provider, London Councils formulates policies, organises campaigns and runs a range of services all designed to make life better for Londoners. 2. London Councils welcomes the opportunity to make a written submission to Defra’s consultation on the Draft Climate Change Bill. Some overall comments about the draft Bill are made below, and then followed by specific responses to the questions and issues raised in Defra’s consultation document. General comments on the Climate Change Bill: 3. London Councils welcomes the Bill and its overall thrust to commit to reducing carbon emissions and setting up an independent committee to advise on meeting these reduction targets. However, we feel that targets in the Bill may not be far reaching enough, in terms of the UK meeting its required contribution to global reductions. 4. London Councils is concerned that the practicalities of reducing emissions on the ground will require a major role for local government, yet this has not been addressed by the Bill, with not a single reference to local government anywhere in the text. In addition, the proposed membership for the Climate Change Committee does not include a role for local government. 5. The draft Bill does not take into account the effects of aviation on climate change. Although the Kyoto Protocol excludes aviation and shipping, climate change is a global issue and the impacts of a rapidly growing aviation sector is likely to have a significant impact on emissions and the ability of the Government to meet its targets. Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 4 6. There is no clear link made with air quality or the trade offs between climate change and local air quality. They should be considered in tandem, with clear reference being made to air quality in the draft Bill. 7. The Climate Change and Sustainable Energy Act 2006, which will apply from June 2007, also has implications for local authorities in relation to alleviation of fuel poverty, promoting micro-generation and use of heat from renewables. The draft Bill should not contradict the Act, and should rather complement it. Defra’s consultation questions: Targets and Budgets: Setting statutory targets Q1 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%? 8. London Councils notes the main aims and purposes of the Bill, which are to bind Government to CO2 targets in legislation, but considers the Bill needs to be clearer regarding how these targets are to be achieved, and how in particular, local authorities will be expected to help deliver these. 9. In addition, new scientific evidence recently reported in the national press has suggested that greenhouse gas (GHG) emissions will likely need to be reduced by 80% to avoid catastrophic climate change. The consultation document states that: “Last year’s Stern Review of the economics of climate change stated that, in order to achieve a stabilisation of atmospheric greenhouse gases at a level which would avoid the more damaging effects of climate change, the world needs to reduce overall emissions by about 50% (stabilising within the range of 450550ppm CO2), compared to current levels. This means industrialised countries such as the UK reducing their contribution to greenhouse gas emissions by at least 60%”. There is however no rationale given as to why the 60% figure is not proposed to be higher, given it says the UK needs to reduce emissions by “…at least 60%” (emphasis added). The Government needs to improve its rationale for such a target to ensure it is taking into account the appropriate evidence to begin with. 10. The Bill does provides a framework for addressing climate change issues, creating a degree of certainty in the market, but does not stipulate how cuts in emissions should be made or give specific reduction targets for local authorities or individual businesses. Q2 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? 11. CO2 is by far the most prevalent of the GHGs emitted across the UK (over 85% as stated in the consultation). However, as the consultation document also states “The Kyoto protocol, as a global agreement, reflects the fact that it is the combined effect of greenhouse gases which causes global warming, and there may be merit in the UK taking on a wider greenhouse gas target”. Whilst the consultation states that large reductions of other GHGs such as methane have Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 5 occurred and any further reductions would be costly, it would still be sensible to keep under review on a regular basis the inclusion of all GHGs in a target, or to even create separate reduction targets for these. Excluding methane and other GHGs would not give the complete picture as to what the UK’s impact on global warming is, so the Government should at the very least keep this under regular review or set individual GHG targets, based on the costs of reducing them in relation to their impact on our overall GHG ‘footprint’. Carbon budgeting Q3 Should the UK move to a system of carbon management based upon statutory five-year carbon budgets set in secondary legislation? 12. As noted previously, local authorities need to know how Government expects them to help achieve these targets, and whether there will be any punitive action regarding failure to meet targets. Any time-related targets, whether annual, five yearly etc., need to be clearly spelt out by Government, particularly with respect to local government’s role in helping to achieve these. Any changes within the Comprehensive Performance Assessment (CPA) framework that contain a focus on climate change will also have impacts on local authorities, and therefore need to be clearly spelt out in the Bill. 13. Five year carbon budget plans are quite long and may contribute to targets being missed at the end of a five year term. Annual carbon budgets could be more effective and can be monitored more closely. The same principle of ‘banking’ and ‘carrying forward’ carbon reductions being suggested for the five year budgets can be applied to annual targets. Q4 Do you agree there should be at least three budget periods in statute at any one time? 14. As per the above, there should be at the very least, three budget periods, as this equates to one per five year block. As suggested above however, a shorter time period could be more effective, to ensure the Government keeps track of its 60% CO2 reduction commitment. Since the goal is to reduce emissions by 26-32% by 2020, five yearly targets might be too long- a new Government for example, might inherit the need for reductions of up to 11% in a single five year block if the previous five years’ targets failed and no action had been taken during that period. Reviewing targets and budgets Q5 Do you agree there should be a power to review targets through secondary legislation, to ensure there is sufficient flexibility in the system? 15. If the purpose of the Bill is to set statutory targets, details of any such flexibility as suggested above should be built into the primary legislation. The ability to review targets through secondary legislation would appear to allow Government to ‘move the goalposts’ at a later date and therefore compromise the whole purpose of the Bill from the outset. The Government needs to set clear robust targets that local government, business and other stakeholders can work towards meeting. Whilst some flexibility is necessary, due to changing scientific understanding of climate change and the emerging technologies that are appearing to deal with it, Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 6 any secondary legislation should not also be used to water down targets if and when Government fails to meet them. Q6 Are there any factors in addition to, or instead of, those already set out that should enable a review of targets and budgets? 16. No comments. Counting overseas credits towards the budgets and targets Q7 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? 17. No comments. Banking Q8 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? 18. London Councils has no objection to the concept of banking surplus emissions savings if it meets similar requirements of the Kyoto Protocol. Borrowing Q9 Do you agree that limited borrowing between budget periods should be allowed? 19. London Councils agrees that limited borrowing between periods should be allowed along the lines outlined in the consultation. Compliance with carbon budgets and targets Q10 Is it right that the Government should have a legal duty to stay within the limits of its carbon budgets? 20. London Councils are keen to ensure that the consequences of failing to meet targets are clearly set out in the Bill, as well as who those consequences are directed at. The Committee on Climate Change: The need for an independent analytical organisation Q11 Do you agree that establishing an independent body will improve the institutional framework for managing carbon in the economy? 21. Yes, but conditional on taking into account our concerns raised regarding the functions and membership of such a committee. Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 7 Functions of the Committee on Climate Change Q12 Do you agree that the Committee on Climate Change should have an advisory function regarding the pathway to 2050? 22. Yes, if the Committee on Climate Change is independent from Government, it should be allowed to have an advisory function regarding the pathway to 2050. 23. Current reporting requirements on local government over a range of issues are already quite onerous. Therefore, if the Committee requires reporting/monitoring from local government, it would be helpful to build this into existing processes or at least to keep them within similar methodologies to those of existing ones to avoid any additional bureaucracy. Any further requirements on local government will also need to be appropriately resourced. Q13 Do you agree with the proposal that the Committee on Climate Change should have a strongly analytical role? 24. It is important to have technical expertise on this committee. London Councils is however concerned that the suggested membership of the committee does not include membership from any local government organisations (see also Q15 below). London Councils believes that local government will be responsible for a considerable part of the implementation of the Bill’s targets, and, due to the role of local authorities as a tier of Government, that they are more than just ‘ordinary stakeholders’. We therefore believe that there should be a place on the committee to harness the expertise, and represent the concerns and viewpoints of local government. Factors for the Committee on Climate Change to consider Q14 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? 25. Within energy policy, the committee needs to address how decentralised energy and the renewable energy sector can be supported nationally. A possible ‘further factor’ could be a monitoring role, in terms of identifying any key reasons for targets being missed. Membership and composition Q15 Do you agree the Committee on Climate Change should be comprised of technical experts rather than representatives of stakeholder groups? 26. Whilst understanding the role of the committee as being a more technical one and not a policy vehicle for debating various stakeholders’ interests, London Councils believes that the inclusion of the role of local government is critical for the Climate Change Bill to achieve its aims. Local authorities will be one of the key stakeholders responsible for enabling the Government to reach proposed targets. However, the Bill completely omits the role of local government. Local authorities are significant land, building and vehicle owners, as well as major service providers and procurers of products and services. For the Government to achieve its ambitious GHG reduction targets, it needs to provide more certainty to Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 8 local government, as one of the main delivery agents of Government policy, as to what local authorities will be expected to achieve. 27. Many local authorities have taken the lead on this issue to date, whether it be through switching electricity supply to green energy providers, introducing new fleet vehicles with the cleanest engines, or setting local planning requirements to reduce carbon emissions. The lack of acknowledgement of this innovative lead from local authorities fails to recognise the role of local leadership in the efforts to combat climate change. Support from the Government for this progressive approach on the issue can only assist local government in continuing to push ahead with policies and initiatives that will help achieve these targets. 28. Local government finances are also already very constrained. Therefore, any significant new administrative or compliance role for local authorities needs to be appropriately resourced. Q16 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? 29. The areas of expertise listed are appropriate. However, as stated above, expertise at the local government level (being a significant service provider and implementer of central Government policy across a wide range of topic areas) should be included. Enabling Powers: Extending the suite of domestic trading schemes Q17 Do you agree with the principle of taking enabling powers to introduce new trading schemes? 30. No comments. Benefits and structure of enabling powers Q18 Do you consider that these powers are sufficient to introduce effective new policies via secondary legislation? If not, what changes would you make? 31. The nature and extent of the enabling powers must be clearly spelt out and consulted on separately. Reporting: The need for regular, independent monitoring of the UK’s progress Q19 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? 32. As per earlier comments regarding budget periods, an annual report is essential, especially if there are five year periods, to ensure the Government is on track to meet its own targets. Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 9 Adaptation Q20 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? 33. The proposals regarding adaptation do not go far enough. Adaptation has often been the ‘poor cousin’ to mitigation, yet the future risks to human health, biodiversity, property, and infrastructure are becoming increasingly apparent. A ‘quinquennial’ review of adaptation needs may not be often enough to keep up with the dynamic changes that are occurring in both climate science and the actual on-the-ground effects that are becoming apparent. New house building, infrastructure provision etc. needs to be adaptable to future climate conditions. In London, the pace of change within Government and Mayoral policy alone (such as London Plan requirements, changing building regulations, the ‘Code for Sustainable Homes’ etc.) suggests that a five-yearly progress report is too long a time frame. Yours sincerely, Nick Lester Director, Transport, Environment and Planning London Councils Climate Change Bill – Appendix 1 London Councils TEC – 14 June 2007 Agenda Item 14, Page 10