20060701_SDC_submission_to_EAC_on_CCP_2006

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sustainabledevelopmentcommission

SDC submission to theEnvironmental Audit Committee

Climate Change The UKProgramme 2006: SDCresponse

July 2006


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www.sd-commission.org.uk Climate Change The UK Programme 2006: SDC response2


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Table of contentsSDC input into the Review process.......................................................................................................5SDC position on climate change............................................................................................................5SDC submission to EAC inquiry .............................................................................................................. 6Targets.................................................................................................................................................... 7Business.................................................................................................................................................8Households.............................................................................................................................................9Transport ..............................................................................................................................................12Public sector.........................................................................................................................................14Agriculture, forestry and land management......................................................................................14



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SDC input into the Review process1. The UK Government1 published a

consultation document on the Review ofthe Climate Change Programme (CCP) inDecember 2004. This identified a

shortfall of around 10 million tonnes ofcarbon (MtC) between projected carbonemissions and the domestic target for a20% cut in emissions by 2010. SDCinput was therefore designed around a10 MtC shortfall, although this was laterrevealed to be an under-estimate.

2. The Sustainable DevelopmentCommission (SDC) prepared a detailedsubmission to this Review, which waspublished in May 20052. This drew onwork from across our energy, transportand buildings work programmes andcontained a wide range of detailedpolicy recommendations.

3. SDC Commissioners held regularmeetings with Ministers and high-ranking officials throughout the Reviewprocess, pointing out areas of concernand lending support to new policyproposals.

4. The SDC Secretariat played an activerole in the Inter-department AnalystsGroup (IAG), attending meetings,commenting on policy appraisals, andmaking further suggestions.Unfortunately the SDCs participation inthis group was restricted towards theend of the Review process, whichlimited our ability to comment on thefinal range of policies that wasannounced.

5. The SDC Secretariat was also part of theDefra-led Stakeholder Group, which heldthree meetings over the course of 2005.

6. In February 2006 the SDC prepared abrief summary for Ministers on what we

t

1 The term Government is used to refer to theUK Government in this document unlessotherwise stated.2 SDC (2005). Climate Change Programme

Review: he submission of the SustainableDevelopment Commission.

believed were the key measures to getthe CCP back on track.

SDC position on climate change7. There is increasing recognition that thelong-term target for a 60% cut in

carbon emissions by 2050 will not besufficient to avoid dangerous climatechange. The SDC will be looking at thisissue over the summer and will publisha position paper on climate change indue course.

8. Furthermore, it is now very clear thatclimate change is not a long-termproblem that can be deferred for future

generations to deal with. Climatechange impacts are already beingobserved, and the threat to globalpopulations and ecosystems is real andimmediate.

9. In light of this fact, the target for a 20%cut in emissions by 2010 may not besufficiently ambitious when viewedfrom a scientific perspective. The SDCtherefore sees the 2010 target as anabsolute minimum considering thelikelihood that much greater cuts will berequired over the following 20 years.

10. However, the SDC recognises the strongleadership shown by the Governmentwhen setting the 20% target, and thefact that UK action on climate changemust be part of a much greaterinternational effort. It is on this basisthat we support the 20% target, and wehave assessed the CCP 2006accordingly.

11. It is increasingly clear that currentpolicies on climate change are notdelivering absolute cuts in carbonemissions. This is highlighted by the factthat the 10 MtC projected shortfall fromthe 2010 target at the beginning of theReview process became 15 MtC by thetime the revised CCP was published inMarch 2006.

12. This presents problems when

undertaking an analysis of the CCP2006, as many of the measures we



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originally recommended are nowinsufficient to deliver the carbonreductions required.

13. This lends added weight to ourargument that current methods ofdealing with climate change areincompatible with the task at hand.

14. Climate change is a cross-departmentalissue with huge implications for allareas of public policy. The currentsystem puts very little responsibility fortackling climate change with finalconsumers, which positions Governmentdepartments against each other as theytry to achieve a cross-departmental goalwith as little pain as possible for their

own constituents.

15. In addition, there is lit tle incentive forlocal or regional consideration ofclimate change issues. This leads topatchy performance between localauthorities, and a RegionalDevelopment Agency system that isheavily focused on economic growthabove all else, even when this could bedetrimental to climate changeobjectives.

16. Continuation of this approach willultimately fail to deliver the emissionsreductions required. This is why the SDChas recommended that economy-wideemissions trading should be the policyframework within which action onclimate change takes place. This is mostrecently explained in our Energy Reviewsubmission.

17. We are also interested in the role that

personal carbon trading could play aspart of an economy-wide emissionstrading scheme. The SDC will return tothis issue in our forthcoming positionpaper on climate change.

SDC submission to EAC inquiry18. The Environmental Audit Committee

(EAC) announced its intention to hold aninquiry into the Climate Change

Programme 2006 on 27th

April 2006.

19. This submission is based on the threequestions posed by the EAC inquiry,along with an analysis of the success ofthe CCP 2006 in relation to therecommendations made by the SDC in

May 2005. We have not addressedevery SDC recommendation in detail,but have focused on those areas whereaction is critical.

The three questions from the EAC inquiry are:

The Prime Minister continues toidentify climate change as probablythe greatest long-term challengefacing the human race. Does the

2006 Climate Change Programmerepresent a realistic strategy toprepare the UK to meet thischallenge?

Does the Government need to domore, and if so what, to try toensure that it meets the 20%reduction in carbon dioxideemissions by 2010?

To what extent, if at all, will theoutcome of the Energy Review affect

the implementation of the ClimateChange Programme?

20. Question 1: Does the 2006 ClimateChange Programme represent a realisticstrategy to prepare the UK to meet thischallenge?The SDC does not believethat the CCP 2006 is a sufficient set ofpolicies to prepare the UK to meet thechallenge of climate change.

21. Current f igures suggest that the UK willonly achieve 16.2% cut in carbonemissions from 1990 levels, and this isafter five years of concerted efforts bythe UK Government and the DevolvedAdministrations. Indeed, the picture ismuch worse than this: carbon emissionsin 2004 were 3.5 MtC higher than in1995, and it was the period between1990 and 1995 where substantialreductions were made.

22. It is therefore clear that the CCP hasfailed to deliver absolute cuts in carbon



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emissions and has only succeeded inslowing the growth in emissions thatwould otherwise have occurred.

23. The Government stands to meet itsKyoto obligations solely through carbon

reductions achieved up to 1995 (largelythrough fuel switching in the powersector and deindustrialisation) alongwith sustained reductions in emissionsfrom other greenhouse gases, primarilymethane and hydrofluorocarbons.

24. These trends represent a completelyinadequate preparation for the muchlarger cuts in carbon emissions that willbe required over the next 20 years orso. This delay enhances the prospectthat more painful and costly actions willbe required in the longer term tocorrect the mistakes currently beingcommitted. For example, the emissionsimplications of new buildings andpower plants, both of which have longlifetimes.

25. The SDC recognises that reductions in UKcarbon emissions will have only a smalleffect on global emissions, and that inthe longer term an international effortof momentous proportions is required.26. However, it is also our belief that the

large majority of near-term emissionssavings can be made at net benefit tothe UK economy through savings inlifetime energy costs and throughinnovation and export benefits. Forexample, domestic measures in theClimate Change Programme 2000(mainly energy efficiency) wereevaluated as having a net benefit ofover 400/ tCe3.

27. Furthermore, the UK is seen as a leaderon climate change issues and thisconfers a responsibility to show thatsubstantial emissions reductions arepossible without sacrif icing peoplesquality of life.

3

Defra (2006). Synthesis of Climate ChangePolicy Evaluations, p. 23.

28. Question 2: Does the Government needto do more, and if so what, to try toensure that it meets the 20% reductionin carbon dioxide emissions by 2010?The Government will need to do muchmore to ensure it meets the 2010target, particularly after allowing forfurther leakage in existing measures.The following sections deal with theSDCs recommendations to theGovernment prior to the Review of theCCP and more recently.

29. Question 3: to what extent, if at all, willthe outcome of the Energy Reviewaffect the implementation of theClimate Change Programme? The SDC

believes that the 2006 Energy Review isa unique opportunity for theGovernment to show how it intends tomanage the transition to a low carbonenergy supply over the long-term. TheSDC presented a detailed submission tothe Department of Trade & Industrys(DTI) Energy Review team in April20064, which built on our earlier workon nuclear power5.

Targets30. As noted in paragraph 10 the SDC

strongly supports the domestic targetfor a 20% cut in carbon emissions by2010. We also recommended that theGovernment adopt three other goals:

a 60% cut in carbon emissions frombuildings (over 1990 levels) by 2050

a 50% cut in carbon emissions fromroad transport by 2025 (over 1990levels) through a combination oftechnological and behaviouralchange

a carbon neutral public sector by2020

31. The aim of these goals was to provide aclear framework for long-term action in

f l

4 SDC (2006). Meeting the challenge: energypolicy for the 21stCentury.5

SDC (2006). The role o nucear power in a lowcarbon economy.



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the household and transport sectors,with clear leadership through the publicsector and through the proposedgrowth areas.

32. Of these, the Government has gone

some way towards ourrecommendation for a carbon neutralpublic sector by 2020 with theannouncement on 12th June 2006 thatthe Government Estate would be carbonneutral by 2012. However, we remainparticularly concerned at the absence ofany long-term strategy to targetemissions from transport and existingbuildings.

Business33. The SDC was strongly support ive of the

EU Emissions Trading Scheme (EUETS) asa central plank of the GovernmentsClimate Change Programme. However,we were critical of the process by whichNational Allocation Plans (NAPs) wereset in the first phase (2005-7), whichencouraged departmental wranglingand led to the confusion over the UKslegal challenge to the EU.

34. The SDC recommended a NAP in phasetwo (2008-12) that was commensurateto the contribution of the EUETS sectorto the 20% carbon reduction target(46%). This led to a recommendationfor a cap 3 MtC/ year less than phaseone. However, by March 2006 therewas an additional 5 MtC gap in theemissions projections, and theGovernment had ruled out many of the

other measures suggested to it duringthe consultation process on costeffectiveness grounds.

35. The SDC therefore welcomed theannouncement on 29th June 2006 thatthe Government has set the NAP toachieve 8 MtC of carbon savings fromthe EUETS during 2008-12. We believethe UK Government has set abenchmark which other countries willhave to live up to, and we call on theUK Government and the European

Commission to ensure that othercountries NAPs are equally ambitious.

36. The SDC recommended that as part of apackage of support for renewables,10% of the emissions permits for phasetwo of EUETS should be auctioned. Wesuggested that the proceeds should beallocated to a carbon-saving fund aimedat technologies and measures unlikelyto benefit from market-basedinstruments. We also suggested that therevenue built up from Non-Fossil FuelObligation (NFFO) payments, estimatedto be worth around 880m by 2010,should be invested in the same fund.

37. We therefore welcome theGovernments announcement that 7%of EUETS permits will be auctioned, andthe intention to create anEnvironmental Transformation Fund. Wehope that the funds allocated will beequal to, or greater than, the revenueraised from the auctioning of EUETSpermits. We await further details onhow the Government intends to spendthe 880m windfall from the NFFO.

38. The SDC recognises that coal wil lcontinue to be used for electricitygeneration for sometime, despite thelimiting forces of the EUETS and theLarge Combustion Plants Directive. Wetherefore recommended in May 2005,and again in April 2006, that theGovernment give serious considerationto the role that carbon capture andstorage (CCS) could play in eliminatingcarbon emissions from fossil fuelcombustion, as a bridge to a moresustainable low carbon future.

39. There is a strong internationalimperative to develop CCS technologiesso that the carbon effects of coal-baseddevelopments in countries such as Chinacan be reduced. The SDC wil l be lookingto the Energy Review to bring forwardenabling policies on CCS.

40. On combined heat and power (CHP), theSDC remains very disappointed by theGovernments apparent lack ofenthusiasm for meeting its own target



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for 10GWe of good quality CHP by 2010.Capacity at the end of 2004 stood at5.6GW6.

41. We believe there is inadequate resourcein Defra for the necessary CHP analysis

and policy development. The EnergyReview consultation documentdismissed CHPs potential contributionas limited. In fact, the absence of moreCHP is a serious market and policyfailure when viewed from a climatechange and energy security perspective,and the Government has beensingularly lacking in realising andaddressing this reality.

42. Currently, 65% of energy is wasted

before it even reaches our homes dueto the inherent inefficiency ofcentralised electricity generation. Amore decentralised energy system usingCHP would dramatically reduce thiswastage, thus reducing carbonemissions and gas use.

43. Action on CHP is needed as a matter ofurgency. There are currently seven gas-fired CCGT projects await ing consentfrom the DTI. Their combined capacityonce operational will be 8.1GW. Thisequates to a huge carbon lock-in, andwhile these plant will in part bedisplacing inefficient coal output (with asubstantial carbon saving), there willstill be huge amounts of wasted energywhen compared to using the same gasin CHP plant. In addition, there isunlikely to be any requirement thatthey be made CCS-ready to enable zerocarbon output in the future.

44. On the Climate Change Levy (CCL), theSDC recommended that this should beraised in line with inflation, andadditionally for those sectors notcovered by the EUETS.

45. This latter recommendation has beenovertaken by the proposal (initially fromthe Carbon Trust, but taken on by theGovernment) for a new UK-basedemissions trading scheme, now called

t6 DTI (2005). Digest of UK Energy Sta istics.

the Energy Performance Commitment(EPC), which the SDC strongly supportedthrough the analytical process. It wouldcover those large corporate and publicsector emitters not covered by the

EUETS.46. The SDC has made strongrepresentations in favour of theproposed Energy PerformanceCommitment and we support itsintroduction as soon as is practicallypossible.47. The SDC welcomes the announcementin Budget 2006 that the CCL will rise inline with inflation. The CCL would be

unnecessary if economy-wide emissions

trading existed, but it plays a valuablerole in the intervening period.

48. On Climate Change Agreements (CCAs),the SDC has been support ive of thispolicy measure, which the Governmentestimates will save 2.9 MtC by 2010.

49. However, our recommendation thatCCAs could be tightened and widened tocover other businesses has not beentaken up, and the introduction of the

EPC may overtake this recommendation.There is concern at the level of overlapwith other measures (specifically theEUETS and the proposed EPC) and weaccept that CCAs (which rely on the CCL)may not be the preferred policymeasure in the longer term.

Households50. The SDC believes that there needs to be

a step change in householderengagement on energy and climatechange issues to motivate action onreducing carbon emissions. Werecommended in our submission thatthe Energy Efficiency Commitment inphase 3 (EEC3) should be tripled fromthe level in EEC1, with specific effortsmade to increase take-up of the offersavailable, through schemes such asCouncil Tax rebates.

51. However, in light of recent datashowing the success of the EEC



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programme, and the continuing rise inhousehold carbon emissions, werecommended in our Energy Reviewsubmission that EEC3 should now beraised by four times the level in EEC1 todeliver 1.5 MtC of savings by 2010.

52. We are pleased to note theGovernments announcement that EEC3will be raised to deliver between 0.9 to1.2 MtC per year by 2010, which at theupper level is equal to a tripling of EEC1.However, we hope that the EnergyReview will announce a further push onEEC3 to deliver the addit ional savingswe have recommended. TheGovernment also intends to introduce

further flexibility into EEC, which wesupport.

53. We believe that the Government nowneeds to seriously consider alternativesto EEC which would deliver absolutereductions in energy use. The proposalfor an Energy Saving Obligation (whichwould place a cap on suppliers) is onesuch option, and the SDC is interested inseeing how this might work in practice.54. We are also interested to hear how the

Government intends to encourage thedomestic energy services model,particularly in light of ourrecommendations to the Energy Reviewfor greater decentralised energyprovision.

55. On market transformation of consumerappliances, the SDC highlighted thesuccess of EEC in stimulating demand forA-rated appliances and we lent oursupport to the use of enhanced energylabelling.

56. However, we also pointed to the role ofregulation in helping to remove certainproducts from the market. This has beenfurther explored by the SustainableConsumption Roundtable, whointroduced the concept of choiceediting to help consumers make theright decisions.

57. The SDC is concerned that sustainable

development criteria have not been

systematically included throughout theDTIs work on innovation. For example,a number of opportunities have beenmissed to reduce carbon emissionsthrough technological innovation for

example, with digital set-top boxes.With the number of boxes expected torise from 13m to 85m by 2020, theenergy wastage could amount to280m, leading to 0.4 MtC of carbonemissions by year.

58. We are therefore pleased to note theGovernments commitment (made atGleneagles in 2005) to a 1-WattInitiative for consumer electronics andthe announcement of voluntary

schemes in the retail sector toencourage take-up of more efficientdevices.

59. However, we still believe that theGovernment should consider removingthe worst offending products from themarket when there are cost-effectivealternatives. We have alsorecommended in our submission to theComprehensive Spending Review (CSR)that HM Treasury and the DTI agree a

Public Service Agreement (PSA) whichensures that future innovation fundingdelivers on sustainable developmentobjectives.

60. The SDC was very supportive of noveldemand-side solutions to reducingcarbon emissions such as thoseproposed by Dynamic Demand7. We areplease to note that the Climate Changeand Sustainable Energy Bill includes arequirement for the Government to

conduct a formal assessment offrequency response technologies andreport back to Parliament.

61. Building regulations are an essentialtool in ensuring a level playing field onthe road to zero carbon buildings. Thelong life of buildings makes delays in

7 Dynamic Demand is a not-for-profit organisation

supported by a charitable grant from the EsmeFairbairn Foundation.



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this area very costly, by adding to theretrofit burden in the future.

62. The SDC recommended that theGovernment give an indication of thedirection of building regulations, toprovide certainty to the constructionindustry and facilitate forward planning.We indicated that the long-term aimshould be virtually zero carbon buildingsby 2015, incorporating a zero heatstandard, and self-generation of a largeproportion of electricity needs.

63. In our submission to the Energy Reviewthe SDC has gone one step further as aresult of our continuing work in thisarea. We now recommend that theGovernment announce a zero heatstandard from 2010, and a zero carbonstandard from 2015.

64. We also recommend that the Code forSustainable Homes be used as a way toset the future direction of buildingregulations. So, publicly-funded housingwould need to reach a zero heatstandard immediately, and a zerocarbon standard by 2010.

65. We are very disappointed to note thatthe CCP 2006 makes no reference to along-term aim for building regulations.We believe that the Government needsto address this issue as a matter ofurgency.66. The SDC criticised the Sustainable

Communities Plan and the DecentHomes programme for failing toadequately incorporate environmentalsustainability and carbon reduction

measures. For example, the DecentHomes programme has energyefficiency standards that are well belowthose for new-build.67. The SDC has more recently

recommended that the Governmentextend the Code for Sustainable Homesto existing buildings8. This could be8 Detailed recommendations can be found in our

publication Stock Take: delivering improvementsto existing housing (2006); a summary can also

integrated into existing and forthcomingpolicies, such as the Home ConditionReport (owner-occupiers), the DecentHomes Standard (social housing), andthe Green Landlords Scheme (private

rented sector).68. Unfortunately, the shortcomings we

have identified with the SustainableCommunities Plan and the DecentHomes Standard have not yet beenaddressed by Government. The SDC iscarrying out an in-depth review of theSustainable Communities Plan whichwill report in late 2006.

69. On the new growth areas (announcedas part of the Sustainable Communities

Plan), the SDC recommended that thesebe made carbon neutral by offsettingthe projected additional carbonemissions over the next two decadeswith energy efficiency programmes inexisting housing stock.

70. The Government has announced afeasibility study on making the ThamesGateway a low or zero carbondevelopment. This would go some wayto meeting our recommendations, andwe encourage the Government to beambitious in its final proposals.

71. Our 2005 submission to the CCP Reviewincluded a recommendation for theGovernment to formally consider, by2007, the role that Domestic TradableQuotas (DTQs) might play in achievingthe deep cuts in carbon emissionsrequired in the longer term. Variationsof the DTQ concept have taken manyterms, and more recently the SDC hastaken to using the term personalcarbon trading to describe this strand ofthinking.

72. We were disappointed to note that theClimate Change Programme 2006contained no reference to DTQs orpersonal carbon trading, despite strongMinisterial interest. This absence offormal recognition limits the extent to

be found in our submission to the 2006 EnergyReview.



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83. Transport emissions would increase by10.3% assuming the CCP 2006 saves 1.7MtC.

84. It is therefore clear that even with theproposed new measures, the increased

contribution from the transport sector issubstantial and this does not includethe contribution from internationalaviation. The SDC is therefore surprisedthat greater consideration was not giveto further reductions, as outlined in our2005 submission. We consider thesebelow.

85. We recommended that a clear nationalstrategy on traffic reduction must bedeveloped, which should includedemand management and behaviouralchange measures. Our analysissuggested that around 0.5 MtC/ yearcould be saved. The cost-benefitanalysis was very favourable. Furtherbenefits include reductions incongestion, improvements in air qualityand increased levels of physical activity.

86. We were very disappointed by thelimited consideration given in theReview process to behavioural changemeasures, and the lack of quantificationof the significant benefits that could beachieved with the right impetus. Werecommend, as a matter of urgency,that the Government increases policyinterventions to stimulate behaviouralchange.

87. Adjusting road speed limits would alsoreduce carbon emissions (our estimatewas 1.5 MtC) and the SDC suggestedthat a full assessment should beconducted across all road types. Therewas no mention of the impact of speedon vehicle efficiency during the Reviewprocess and we, again, recommend thatthe Government gives this much greaterconsideration in the future.

88. We welcome the mention of roadpricing in the CCP 2006 document.However, it is essential that road pricinghelps reduce emissions as well ascongestion. Therefore, the scheme must

also consider distance travelled andvehicle efficiencies.

Aviation89. The CCP 2006 document highlights that

UK aviation could contribute some 16 to18 MtC per year by 2030, and that theclimate change impact of aircraftemissions are 2-4 times greater thanthat of carbon dioxide emissions alone.

90. There is a serious risk that, leftunconstrained, the growth in aviationemissions will eliminate any reductionsin carbon emissions elsewhere in theeconomy.91. The SDC recognises that progress has

been made on efforts to includeaviation into the EUETS. However, weare concerned over the possibility ofdelay, and as a result aviation not beingincluded in the EUETS until 2012. Thiswould be a very serious policy failure six more years of inaction on aviation issimply unjustifiable.

92. We are also concerned over thetreatment of non-CO2 emissions,particularly the impact of cirrus cloudsand contrails. Greenhouse gas emissionsfrom international aviation are notassigned under the Kyoto Protocol, andthis could make aviation's inclusion inphase two of EUETS (2008-2012) difficult.

93. One solution, which the SDC fullysupports, is a separate, closed tradingscheme for aviation emissions. Thiscould operate as a test trialduring 2008-2012. Aviation's inclusionin the wider EUETS could then beconsidered when decisions on the nextphase of the Kyoto Protocol are beingmade.

94. If attempts to include aviation in theEUETS fail, we recommend immediateintroduction of an emissions charge ondomestic and international flights.

95. Recognising that there are substantial

climate change impacts associated with



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non-CO2 emissions, the precautionaryprinciple means that scientificuncertainty should not be used as areason for inaction. Demandmanagement measures are needed

immediately. Waiting for quantif icationof non-CO2 impacts to whilst continuingwith aviation expansion isnot acceptable.

96. Therefore, the Governmentmust reconsider its aviation expansionplans. It should also consider theremoval of the all subsidies to theairline industry. For example, includingVAT on domestic flights and putting anend to duty free goods for flights

outside the EU.97. The SDC will be doing further work on

aviation during 2006 as part of ourcontribution to the GovernmentsProgress Report on the Aviation WhitePaper.

Public sector98. Our central recommendation in this area

was for a carbon neutral public sector

by 2020. However, we now believe thatwith the use of offsetting it would bepossible for the Government to achievecarbon neutrality across the wholepublic sector by 2015, and 2012 for thecentral Government estate. Similarrecommendations were made by theSustainable Consumption Roundtable inMay 2006. Offsetting would attach aprice to carbon consumption, whichshould help stimulate public sector

organisations into reducing theiremissions.

99. The SDCs goal for the public sector isone of leadership, where public moneyis used to help encourage moresustainable products and servicesthrough engaged procurement.

100. We are therefore pleased to note theGovernments acceptance of our 2012recommendation for a carbon neutralGovernment estate. However, there isstill no commitment to extend carbon

neutrality to the whole of the publicsector, such as schools, hospitals, andthe Armed Forces.101. The Government also announced that

the central Government estate would

be expected to deliver a 30% reductionin carbon emissions by 2020. The SDCbelieves that this target is notcommensurate with the challenge athand, and could end up being lowerthan the carbon reductions requiredfrom the economy overall. It thereforefails the leadership test.

Agriculture, forestry and landmanagement102. The SDC made only a limited input in

this area due to the absence of anyspecialist resource. This has since beenrectified with the arrival of our NaturalResources team.

103. The SDC welcomes the increasingGovernment recognition that landmanagement, in particular with regardto agriculture and forestry, has asignificant role to play within the

climate change agenda.

104. It is now imperative that this istranslated into concrete actions, withgreater clarity on the responsibility ofdifferent parties in delivering these.

105.The polluter pays principle follows thatfarmers should be responsible forreducing their greenhouse gasemissions. However, as with othersectors the Government has an

important role to play in identifying theextent to which this is possible and inhelping the industry to adopt goodpractice that is affordable and effective.Moreover, where the land managergoes beyond their required greenhousegas reductions and provides a publicgood, for example through soil carbonstorage, this service must be fullyrecognised and rewarded.

106.Quantified information on the extent towhich greenhouse gas emissions can be



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reduced and the specific land usemeasures that can achieve this remainslimited. Where uncertainty exists, forexample around soil carbon, thenresearch in this area and clear

communication of the results must be apriority.

107.The new England Rural Delivery Planmust include measures to tackle climatechange at the earliest possible stage. Inaccordance with the precautionaryprinciple, it is better to include animperfect set of measures within theenvironmental stewardship schemesnow and to refine these later, than towait for perfect knowledge before

introducing the theme. It is alsoimperative that Government sends theright signals that it is serious about allsectors playing their role to address thechallenges posed by climate change.

108. The SDC believes that all fiscal,regulatory and voluntary options foraddressing climate change should beexplored. However, as stated inparagraph 16, we believe thateconomy-wide emissions trading is the

policy framework within which actionon climate change should take place.

109. We therefore believe that the inclusionof the agriculture sector in emissionstrading should be a top priority,whether as part of the EUETS or the UK-based Energy Performance Commitmentscheme.

110. Biomass has the potential to play asignificant role in the UKs efforts toaddress our energy needs sustainably.We see a clear role for Government infacilitating the release of this potentialand we welcome the Governmentsresponse to the Biomass Taskforce andlook forward to rapid implementation.

111. However, energy crops must not beoverly promoted so as to disincentivisefood production. The SDC firmly believesthat UK agriculture still has a role toplay in food provision, particularly whenconsidering the global ecological

footprint associated with the alternativeof importing all our food.

112.The Government needs to ensure thatwhen considering the potential value ofenergy crops it gives properconsideration to all aspects of theirsustainability. Our recent work onbiofuels9 sets out a number of concernswe have in this respect. In particular,detailed consideration needs to begiven to the social and biodiversityimpacts of energy crops.

113.Whilst energy crops will have a role toplay, these must not be promoted atthe expense of energy efficiency anddemand management measures whichmust continue to be the ultimate goal.Similarly, we must use waste productswhere possible as a source of feedstock.

114. Government must also give regard tothe use of the energy crops as some, forexample local heat production, will bemore sustainable than others. Theremust be clear links made between theuse of energy crops and the carbonsavings made, based upon a full lifecycle analysis.

115. The SDC is keen to remain involved inaddressing the challenges posed by theclimate change and land use agenda,and we view the Rural Climate ChangeForum as a good means through whichto do this.

9SDCs response to the Department for Transporton Biofuels and the Renewable Transport FuelsObligation, May 2006


20060701_SDC_submission_to_EAC_on_CCP_2006

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