Review of the UK Climate Change Programme

Consultation Response
by Andrew Basden

This is a response to the UK Government's Consultation on its Climate Change Review, which may be found at


It is placed here because it expounds a number of principles that are of more general interest, especially in the realms of government planning. Please feel free to make use of it and link to it. Here is a summary of the main principles:

Section (click) The principle it espouses
ToR.1 The eventual 60% Target The necessity of achieving the 60% reduction and how that should be reflected in all policy. The key principle.
ToR.2 Aspirations of Less Developed Nations People in 'less developed nations' aspire to our way of living. To 'make poverty history' might be self-defeating unless we urgently set the example of CCE reduction now.
Q2.1 Problems with Relying on Technological Advance Technology seldom delivers all its early promise nor what the early adopters expect. So it is unwise to rely on technology to achieve a 60% reduction.
Q5.1 On Signals and Example-setting We in the U.K. must set an example, and give clear signals that we mean business.
Q6.1 A comment on ETS Some reasons why Emissions Trading Schemes are likely to be counter-productive.
Q7.1 How to calculate targets Targets tend to get missed (e.g. the U.K.'s target of 20% will be 30% out). So take this tendency into account and set more stringent targets.
Q7.2 Targets should be plan-led, not demand-led If we predict demand and provide for it, our climate change emissions will rocket.
Q8.1 Lifestyle: Ways of Living and Working Our lifestyle -assumptions, habits, expectations and aspirations - is the real problem. We must change them. This Programme ignores this important issue.
Q9.1 Ensure Measures do not Mislead We in the UK seem to be meeting our Kyoto targets - but only by shifting emissions to other parts of the world. Our measures should be for global, not UK, reductions.
Q9.2 An Integrated Approach Climate change is not the only environmental problem we face.
Q9.3 Attitude and Responsibility We should show a attitude of responsibility, not of competition or defensiveness.
S6.1 Additional Preliminary Comment on Energy This section should focus on energy use, not energy supply. Reduce use, and then supply will reduce too.
S7.1 Additional Comment: Indirect Impacts and Pull-Through It's all very well making business processes more efficient. But if more products or services are sought, then the total emissions will still rise. We must recognise indirect pull-through effects.
S8.1 Additional Comment: Questioning Mobility and Demand for Travel The government assumes we need mobility for a prosperous economy. We do not. We must cut mobility.
Q28.1 Transport: A Deceitful, Misleading Section The only figure in this section has a large 'lie factor'. And the important issues are studiously avoided. Why?
Q29.1 Fuel Duty Escalator The fuel duty escalator was making a significant contribution to reducing road use. It sent an important signal. But it was scrapped for political reasons.
Q33.1 Aviation Air transport is even worse than the car. Yet flights are being encouraged. Why?
S12.1 Measurements and Structural Mechanisms r.t. Actions We need action, not merely measurement.
S12.2 Global Adaptation 200 million refugees are likely when climate change really gets going; what are we going to do with them?
Q51.1 Stakeholder-led Adaptation, Enforcement and Leadership The government should lead.
OC.1 Religion and Theology of Climate Change Religion is important to most parts of the world outside Europe; we need a theology of climate change.

Now comes the text as sent to the Government ...



ToR.1 The eventual 60% Target

ToR.2 Aspirations of Less Developed Nations


Q1, pg 18. What lessons have been learned since we published the Climate Change Programme in 2000?

Q2, pg 18. How well are existing measures to reduce emissions working? How might these be improved? Should any of these measures be dropped?

Q2.1 Problems with Relying on Technological Advance

Q3, pg 18. Do you agree with the overall analysis of projections and impact of existing measures?

Q4, pg 18. Sectoral targets can reduce flexibility but may help motivate action. What are the advantages and disadvantages of setting sectoral targets?

Q5, pg 18. We expect to achieve the emission levels needed to meet our Kyoto commitment through action to reduce emissions in the UK. Although it would be open to the UK to make use of the Kyoto project mechanisms to contribute to the commitment, current emission levels and our projections suggest that we will comfortably achieve the 12.5 per cent reduction in greenhouse gas emissions below base year levels by 2008-12 through national action. What views do you have on this?

Q5.1 On Signals and Example-setting

Q6, pg 18. The EU Emissions Trading Scheme will be a significant measure in moving us beyond our Kyoto commitment towards our more ambitious national goal to reduce emissions of carbon dioxide by 20 per cent below 1990 levels by 2010. Participants in the EU scheme are able to make use of credits from project mechanisms for compliance in the scheme. These credits can relate to projects which involve reductions of both carbon dioxide or the other greenhouse gases. How should we reconcile the inclusion of credits for non-carbon dioxide greenhouse gases with our carbon dioxide emission reduction goal?

Q6.1 A comment on ETS

Q7, pg 18. How should we describe our domestic emission reduction goals in future? Should they be expressed as a percentage reduction averaged over a number of years, in the same way as targets are described under the Kyoto Protocol, or as a percentage reduction in a specified year?

Q7.1 How to calculate targets

Q7.2 Targets should be plan-led, not demand-led

Q8, pg 18. What new measures for reducing carbon dioxide emissions might be considered?

Q8.1 Lifestyle: Ways of Living and Working

Q9, pg 18. On what basis should new measures be decided? How should we assess the practicality, cost-effectiveness and distributional implications of possible measures to ensure a balanced and equitable programme?

Q9.1 Ensure Measures do not Mislead

Q9.2 An Integrated Approach

Q9.3 Attitude and Responsibility

Q10, pg 18. What should the UK do with its expected surplus, and what considerations should inform our decision? When would it be sensible for us to take a decision?


Additional comment:

Q11, pg 38. Through this consultation we would welcome feedback on whether the UK should consider expanding the Scheme to include other sectors and / or gases at a national level. In particular, do you think the Scheme should be expanded in the following ways:

Q12, pg 38. While harmonised expansion of the Scheme would be desirable, the Commission may not bring forward proposals for amending the Directive. We would welcome views on whether the UK should then consider unilateral inclusion or joint expansion with other Member States.

Determination of the cap for phase II

Q13, pg 38. The Government has stated that the overall number of allowances to be allocated for phase II should be consistent with the trading sector s contribution to the achievement of our goal to reduce carbon dioxide emissions by 20 per cent below 1990 levels by 2010. How should this contribution be determined? How should this contribution be distributed between the different sectors covered by the Scheme?

Q14, pg 38. How should emissions projections be used in considering the level of the total allocation or allocations at sector level?

Q15, Pg 39 Should a national limit be set on the extent to which credits generated through the Kyoto mechanisms (clean development mechanism and joint implementation) can be used by UK companies to meet their EU ETS targets and if so what limit would be appropriate?

Q16, pg 39 Given the revised Climate Change Programme will be published around a year in advance of the deadline for submission of the UK's NAP, what should the Government say in the revised programme about the contribution it is expecting from phase II from installations within the existing scope of the Scheme? Should the revised programme announce the overall number of allowances to be allocated?

Harmonisation of the Scheme

Q17, pg 39 Do you have views on whether the Government should push for further harmonisation of any elements of the Scheme (other than expansion, which is covered in the specific questions above)?


S6.1 Additional Preliminary Comment on Energy

Q18, pg 46 Overall, considering a) the contribution already and that expected from the energy supply industry and b) the possible impact on the three other key goals of energy policy (fuel poverty, competitive markets and security of supply) what scope is there for additional emissions reductions from the energy supply sector to 2010, and to 2020?

Q19, pg 46 What further initiatives might the Government consider at the EU, national, regional or local level to deliver further carbon savings to 2010, and to 2020? In particular, what cost effective steps can Government take to promote the wider uptake of micro-generation (such as micro-CHP and embedded renewables)? What would be a realistic level of CHP capacity by 2020 and how should the Government set about achieving it?

Q20, pg 46 What additional measures might the Government introduce to support existing policies to deliver carbon savings to 2010? In particular, what further cost effective measures could we take to promote CHP through the revised Climate Change Programme, to make achieving our 2010 target of 10GW more likely?

Q21, pg 46 What more should the Government be doing to ensure new technologies are available to maximise further cost effective carbon savings for the energy supply sector up to 2020?

Q22, pg 46 What contribution can renewable heat make to our emission reduction goals and how?


S7.1 Additional Comment: Indirect Impacts and Pull-Through

Q23, pg 55 The Government would welcome views on whether changes are needed to existing policy measures affecting business in the light of the introduction of the EU emissions trading scheme.


  • The government sets the ethical agenda for the nation, and especially for business. As discussed in Q9.3, the message that the government's CCP should give to business is:

    "Take responsibility".

  • Sadly, the message that ETS gives is "You do not need to take responsibility because everything will be taken care of by the trading mechanism. All you need do is seek your own self-interest."

    Q24, pg 55 What scope is there for introducing or strengthening existing regulatory, planning or market-based instruments to achieve a higher proportion of the potential carbon savings in non-energy intensive business sectors, such as by reducing electricity use in the commercial sector?


  • A small practical suggestion: A law requiring all PCs to be able to be switched off without a tedious Shutdown process would mean that PCs are no longer left on overnight. This is an example of small measures that could be repeated many times in many sectors which, though individually small, when taken together could have a sizeable CCE impact.

    Q25, pg 55 How might we realise further energy efficiency improvements, and therefore carbon savings, in the small business sector?


  • Increase energy prices. Remember the 'rebound effect' [3.21] by which, as energy prices fall people use more of it.

  • [7.4] speaks of "high and increasing use of electricity" for air conditioning, space heating, etc. The increased use of air conditioning is due to The government needs to tackle such root causes. These are part of the lifestyle issues (habits, expectations, etc.) that are mentioned in Q8.1, Q9.3. To tackle these requires a change in perception. The drink-drive campaign shows it is possible to change public perceptions, expectations, habits.

  • [7.4] recognises some energy uses in the commercial sector but not others. A major consumer of energy in small businesses is use of cars, whether for employees to get to work or salesmen touring up and down the country looking for customers. Much service industry also depends on high road use. While much of this is obviously necessary, there is evidence that there is considerable unnecessary road use - earlier we gave the examples of salesmen who increase their journey mileage because they fail to plan, and of similar goods being shipped to distant sites rather than being sourced locally.

  • Obviously, the issue is complex. But we would expect to see at least an acknowledgement of such obvious savings in the CP. We do not see any.

    Q26, pg 55 What is the potential for continuing the UK emissions trading scheme beyond 2006? What would be the objectives? Would there be merit in moving from a voluntary to a mandatory scheme? If voluntary, how do we encourage people to participate without incentive money?

    Q27, pg 55 Which sectors are not affected by international or European competition and could potentially participate in a non-incentivised UK scheme? Would the transport, healthcare, education, leisure, catering and retail sectors fall into this category? Are there any other sectors we have missed or are there any particularly good examples in this list? Could the UK trading scheme be used to achieve emission reductions and energy efficiency improvements beyond existing targets? For example, the public sector already has energy efficiency and CHP targets in place.


    S8.1 Additional Comment: Questioning Mobility and Demand for Travel

    Q28, pg 62 Do you agree with our emissions projections for the transport sector?

    Q28.1 Transport: A Deceitful, Misleading Section

    Q29, pg 62 Which existing policies are working well? How might they be further improved?

    Q29.1 Fuel Duty Escalator

    Q30, pg 62 What new measures might we consider at the EU, national, regional or local level to develop cleaner, greener transport and reduce reliance on fossil fuels?

    Q31, pg 62 What should be the role of industry and other stakeholders in developing and implementing low carbon vehicle and fuel technologies?

    Q32, pg 62 How can we get the best out of our transport system without an unacceptable increase in carbon dioxide emissions?

    Q33, pg 62 How can we encourage and help people to make smarter choices about the way they travel?

    Q33.1 Aviation


    Q34, pg 74 What further measures could be introduced to stimulate further carbon savings from improving energy efficiency in households in the period through to 2010?

    Q35, pg 74 What more could we do to support existing policies or to overcome the barriers that remain to the take-up of energy efficiency measures by households?

    Q36, pg 74 Given that many householders benefit directly from energy efficiency measures through lower bills, how can the Government best encourage or incentivise them to improve their own homes?

    Q37, pg 74 What measures would work best in the rented sector, where the landlord-tenant divide means that there is often little incentive to invest in the energy performance of the dwelling?

    Q38, pg 74 Can the environmental and economic benefits of community heating be delivered other than through the Community Energy programme?

    Q39, pg 74 To what extent could EU and international product standards and industry agreements deliver carbon savings?


    Q40, pg 79 What changes will there be in agriculture in response to CAP reform that will impact on climate change?

    Q41, pg 79 What measures would be most effective in reducing emissions from agriculture beyond current projections?

    Q42, pg 79 Are cost-effective measures likely to be available now or in the future that would further reduce emissions from livestock production and nitrogen application to land?

    Q43, pg 79 What is the potential for using biomass as a renewable source of fuel and energy, and for using crops for other non-food uses? Is there further potential for using agricultural waste products for these purposes, such as methane for energy production? What are the constraints, and how might they be overcome?

    Q44, pg 79 What is the scope for or restraint on increases in carbon sinks through forestry?


    Q45, pg 84 What more should the Government be doing through the management of its own estates, procurement and operations to provide a lead and contribute to emissions reductions?

    Q46, pg 84, How can we better quantify the contribution of local and regional bodies through existing activities to climate change objectives? How can greater synergies be delivered between activity at local, regional and national level?

    Q47, pg 84 Can local and regional bodies contribute more to UK climate change objectives in 2010 and 2020 in terms of driving further significant, cost effective emissions reductions? What measures could the Government put in place to deliver these savings?


    S12.1 Measurements and Structural Mechanisms r.t. Actions

    S12.2 Global Adaptation

    Q48, pg 87 What further evidence of the impacts of climate change is needed to enable effective adaptation, in government, at regional and local levels, and in the private sector? Who should be responsible for producing this information?

    Q49, pg 87 With regard to the natural environment, how should we develop our approach to evidence gathering, strategic prioritisation and adaptation action?

    Q50, pg 87 How should responsibilities for adaptation be partitioned between the different tiers of government, the wider public and private sectors, and society at large?

    Q51, pg 87 Some stakeholders have suggested that a Government enforcement mechanism is needed if we are to make any real advances in adaptation action. The Government s present thinking is that effective and appropriate adaptation must be thoroughly "stakeholder-led", and is therefore not best served by enforcement. In what ways might legislation and regulation serve either as barriers to, or incentives for, progress in adaptation action?

    Q51.1 Stakeholder-led Adaptation, Enforcement and Leadership


    Q52, pg 104 What more can devolved administrations contribute to UK climate change objectives?

    Q53, pg 104 Should the devolved administrations have their own targets for measuring progress in delivering greenhouse gas emissions reductions and, if so, what form should these take?


    OC.1 Religion and Theology of Climate Change

    ENDS. Andrew Basden, 2 March 2005.
    Copyright (c) Andrew Basden 2005.

    Last updated: 22 March 2005 16 May 2011 link to andrew.html repaired.