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

"http://www.defra.gov.uk/corporate/consult/ukccp-review/index.htm"

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.

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 ...

INTRODUCTORY NOTES

Abbreviations used: CCE = climate change emissions CCP = Climate Change Programme CP = Consultation Paper 'Review of the UK Climate Change Programme' ETS = Emission Trading Scheme
Some of the argument below is repeated in several places. This is deliberate, to enable the argument to be understood where it is relevant in each question, without the reader having to turn pages to other parts. It is also partly for the convenience of the consultants who will split this up question by question.
Principles. However, some major issues are separated out under their own headings and referred to in various places. Most of these are general principles, but are included under discussions about certain questions and labelled accordingly with 'Q' or at the start of a new section, labelled 'S'. They are as follows:
But we start with a major discussion over the Terms of Reference, about which no questions were posed.

ADDITIONAL COMMENT ON TERMS OF REFERENCE

ToR.1 The eventual 60% Target

we are pleased that the Terms of Reference recognise that we should reduce climate change emissions by 60% by 2050. (In fact, one could argue for more than 60% reduction, but we are content to accept the 60% reduction as an absolute for the time being.)
This means the initial Kyoto target and the UK domestic target and their various mechanisms should be seen as steps to reach the 60% reduction, rather than as ends in themselves. So the whole Climate Change Programme should be devised in the light of, and always aware of, the need to achieve 60% reduction.
But it seems, on the whole, to treat the Kyoto and domestic targets as ends in themselves, without much reference to the need eventually to achieve 60%. The CP nowhere discusses strategy for reaching the eventual 60% reduction.
- Action: Rethink the whole in the light of the need to achieve 60%. Also rewrite every measure, mechanism, policy, etc. to add a note to each to say how it relates to the eventual 60% goal.
Global nature of 60%. Scientists tell us that the 60% reduction is needed globally, not just by the U.K. To achieve 60% reduction when developing countries are coming out of poverty will be extremely challenging.
- Example: It is recognised that some of the reduction we have already achieved is due to decline in manufacturing industries such as steel [7.7]. However, this does not constitute a global reduction in steel-making, because steel-making (and even more energy-intensive processes such as aluminium) is growing in other countries. Therefore, we must take this into account. Under Measures Improvement (Q2) we suggest that the government must differentiate between measures that respresent a genuine global reduction in CCE, and those that put UK in a good light but ignore the shift in emissions to other places in the world.
- Example: The bulk of current levels of CCE are generated by the lifestyles of those living in highly developed nations (20% of the world's population). But there are signs that the other 80% aspires to our lifestyle. Should this happen, rather than a 60% cut in CCE, we might face (at worst) an up to 400% increase in CCE. Defra has recently (see ToR.2 below) admitted that "demand for road fuels is growing dramatically in many developing countries, in line with rising incomes and infrastructure development." See ToR.2 below for discussion of this.
- Even if the 400% increase in CCE is a massive over-estimate, it should at least alert the government to the difficulty of achieving a global 60% reduction.
- Flaw in CP: We do not see enough of recognition of the global dimension in the CP. See also S12.2 on global adaptation below.
Easy now, difficult later. At the start (i.e. now) we have the leisure of picking off the easily achieved actions. It is tempting to do just that. But if we do, then later, once these have all been achieved, it will be necessary for our children to take the much more difficult, dangerous and challenging actions, to achieve 60% reduction by 2050.
- Example: Once we have switched from coal to gas once, we cannot do it again. (In fact, gas will soon run out.) Likewise, increase in technological efficiency suffers under the law of diminishing returns.
Unless we are to sell our children (and those of China, India, Africa) down the river, we should take some of the more challenging actions now.
Therefore, the government should rethink the whole CCP in the light of the need to achieve 60%.
- Action: To this end, it should rewrite every measure, mechanism, policy, etc. to add a note to each to say how it relates to the eventual 60% goal.
to start this debate, we make the following initial comments on strategy for reaching 60% reduction.
As discussed in Q6.1 below, Emission Trading Schemes can act against achieving this 60%. ETS presupposes the notion of a surplus that may be traded. But there is no true surplus until we have achieved 60% reduction. Any so-called surplus is only relative to an arbitrarily chosen interim target. While we recognise that ETS can have a pragmatic benefits, we do not believe that the ETS should be the keystone of the government's (nor the EU's) approach.
Improvements in technology cannot on their own achieve this overall 60% reduction. For example, it is recognised (the rebound effect, [3.21]) that technical improvements can often be self-defeating because they lead to greater comfort or convenience, which leads to us consuming and wasting more than we used to.
Change in lifestyle. To achieve 60% reduction, therefore, we must achieve a change in lifestyle, world view, expectations, habits and assumptions. By 'lifestyle' we mean not only in the private life, but also in the way we do business. See Q8.1 and Q9.3.
We must set an example. If the less developed nations are to eschew the path we have taken over the past 200 years of ever increasing CCE, then we must set a genuine example, especially in policy that affects lifestyle, either changing or bolstering current our high-CCE lifestyles. This is discussed in Q5.1.

ToR.2 Aspirations of Less Developed Nations

The Chancellor's aim to 'make poverty history' is laudable. But the inevitable effect will be that people in Africa and other places will consume more and thus, indirectly, generate more CCE. [And this will lead to devastation in Africa and other less developed nations, increasing poverty and destitution - so it would be completely counter-productive. Unless we find a way of reducing poverty that does NOT lead to CCE.]
This is because a stronger economy allows them to better fulfil their aspirations. The problem is that, at present, very many people in developing nations aspire to our way of living, and our levels of convenience, comfort and car use. This must be taken into account in our attempts to reach 60% reduction, but it appears not to have been.
Information from Defra. The author recently received a reply from Lord Whitty of Defra, dated 22nd February 2005, in answer to his question about the effect on CCE of increased levels of car usage in less developed countries, and whether the government has taken this into account.
The reply admits that "demand for road fuels is growing dramatically in many developing countries, in line with rising incomes and infrastructure development. The passenger-car fleet in China, for example, grew by more than 9% per year in the five years to 2002, compared to just over 3% in the world as a whole. The IEA project a tripling of total vehicle stock in non-OECD countries, to about 550 million by 2030." Apparently this nearly reaches the level of that of OECD countries by that point in time.
Lord Whitty tries to allay fears by suggesting that this might not lead to a tripling of CCE in these countries because of "lower incomes and uptake of less fuel-intensive technologies" and because "oil demand for transport .. is also affected by local fuel taxes." But, as we argue later (Q2.1) technological advance is usually less effective than hoped initially, and Lord Whitty did not explain why he expects local fuel taxes in China to remain higher than they are in the UK right through to 2030, let alone 2050.
Further, he is content with projections to 2030. The setting in chain of high-CCE lifestyle expectations and aspirations of people in less developed nations is a great cause for concern, and its effect will not suddenly stop at 2030. The increase in car usage in less developed nations follows an exponential rather than linear trajectory, which means that the increase from 2030 to 2050 will be far higher than that from, say, 2010 to 2030.
It is therefore with considerable alarm to us that Lord Whitty begins his reply with "My Department has not commissioned research that looks specifically at the potential increase global greenhouse gas emissions resulting from increased car usage in less developed countries."
Deeper Issue: The example effect (see Q5.1). People in less developed nations do, and will, aspire to our standard of living, comfort, material pleasure and convenience. Politicians and business in less developed nations will aspire to a growing GDP, and to growing road use. See the information from Defra above.
Action: Government should estimate realistically the effect of poverty reduction on the lifestyles and levels of consumption and thus of CCE by currently developing countries, and factor this into the long-term equation of achieving a 60% global reduction in CCE by 2050.

SECTION 2: INTRODUCTION

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

Here are a few lessons that should be learned, and seem obvious to anyone except the government and the self-centred anti-environmentalists.
- Restore the fuel duty escalator.
- Place VAT on aircraft fuel.
- No more expansion of airports.
- No more expansion of major roads.
However, we doubt if such an answer is helpful. In the remainder of this response we try to argue more fully.

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

They are not working well. For example:
- They omit international air transport, which is far more serious a problem than domestic air transport (which is included). See Q8.
- Though they might measure how well UK is doing, many measures fail to express how well we are doing globally. See Q9.1.

Q2.1 Problems with Relying on Technological Advance

However, we notice that many of the measures that are proposed for reducing emissions are of a technical nature. It is assumed that technological advances can help us reach our targets, whether this be low-carbon cars, biofuels, renewable energies, changing from coal to gas, greater energy efficiency, and so on.
While technological advance must be part of the solution, and is particularly culturally suited to the British mentality of inventiveness.
But technological advance cannot be the whole solution, for several reasons:
- The rate of improvement due to technological advance reduces after an initial period, yet it is during this initial period of optimism that projections of its effectiveness in solving problems are made.
  - Example: nuclear power would be 'too cheap to meter'.
  - Example: North Sea gas, would likewise be 'too cheap to meter'.
  - Example: the 'paperless office' that was predicted in the 1970s.
  - Example: progress towards low-carbon cars [8.13] is less than hoped.
- The difficulties of applying new technologies to problems are underestimated. Many of these are human, social or economic, and become apparent only a decade or more into widespread use of the technology.
- The impact of the technology on the problem is over-estimated, partly because those who make the early estimates are keen advocates of the technology rather than dispassionate observers.
- The rebound effect, mentioned in [3.21]. As we make homes more energy efficient, we tend to heat our homes more rather than simply using less energy.
Therefore, while in the early, optimistic stages, technological advance might produce a 10% reduction in various sectors of CCE, it is unlikely to be able to deliver a 60% reduction, even if we waited beyond 2050.
This means that we need more than technological advance to achieve a 60% reduction. As we discuss in Q8.1 and Q9.3, this demands a change in lifestyle and attitude.

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

We have serious questions about the overall projections. To what extent do they take into account:
- The example effect. This is the effect of setting a good example, in spite of apparent jeopardy to our perceived competitive position, which leads to other (often reluctant) countries and businesses taking similar action.
- Lifestyle expectations, assumptions and habits, and the possibility of changing these; see Q8.1.

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

We should not see reduction in flexibility as always detrimental. It can also be a positive factor. Conversely, flexibility can be detrimental, especially in today's culture, which competes on monetary measures and on little else.

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?

As mentioned in the introductory comments on the Terms of Reference, we should be considering this in the context of achieving a 60% reduction by 2050.
If we achieve a 12.5% reduction by 2012 (an average, since 1990, means 0.5 % points reduction per year), then we have to achieve the remaining 47.5% in 38 years, an average of 1.3 % point reduction per year thereafter.
A increase in rate of reduction from 0.5% per year to 1.3% per year requires a 160% increase in rate of reduction from 2012. This is a severe challenge for several reasons.
- It will be difficult to sustain current rates of reduction after 2012 because many options for how to reduce CCE will have been 'used up' - for example, switching from coal to gas can only happen once. Many other measures, such as increases in technology, will suffer under the laws of diminishing returns.
- As argued elsewhere, changes in technology will not be enough without also major changes in lifestyle expectations, habits, aspirations, etc. (see Q8.1) among us.
- Momentum of lifestyle expectations and habits is very difficult and slow to reverse.
- To make matters far worse, the less developed nations will have developed stronger economies based on the Western capitalist model of ever increasing consumption. 1.5bn people in China, 1bn India, 0.6bn Africa, etc., who aspire to our levels of consumption, will generate an enormous increase in CCE, which we in the U.K., Europe, USA, etc. must offset by an even more severe cuts in CCE.
- Therefore a mere 12.5% or even 14% reduction by 2012 should not be seen as a cause for complacency or self-congratulation.
It will be much more difficult to reverse the newly whetted appetites for consumption and energy-rich lifestyles in these nations than to change our own lifestyle appetites.

Q5.1 On Signals and Example-setting

It is said several times in the CP that the government wants Britain to set a good example, by achieving a greater reduction than its Kyoto requirement. It is not only laudable, but important that developed and leading nations of the world like the UK set an example.
But effective example-setting requires more than slightly exceeding our Kyoto requirement. Effective example-setting requires that the leaders are seen not to guard their own interests but to release some of them for the common good. It requires more than directing some of our scientific effort towards solving CCE problems by technical means; it requires that the government takes seriously the need for the lifestyle of British people to change. See Q8.1 on Lifestyles.
The lifestyle we adopt and protect and provide for betrays what we really believe. The government's refusal to relinquish our high-energy, wasteful, high-road-usage lifestyles betrays to the developing nations that we do not take climate change that seriously.
However, if the government boldly recognises the need to change our lifestyle habits, expectations and aspirations then we stand a chance of influencing the rest of the world by setting an example.
Therefore, the conclusion seems inescapable that the UK government should urgently plan for changes in lifestyle. Sadly, the CP does not do this, but assumes that our targets can be achieved by mere changes in technology and trading schemes.
Example is a signal that other nations take notice of. But policy also gives signals.
- Example: Road Use. It is reported recently that, far from road usage decreasing as the government made us believe it would in 1997, road use has increased by 9%. This seems in no small measure to be due to the removal of the Fuel Duty Escalator. That removal - in the face of a complete lack of public support for the fuel protestors in November 2000, after huge storms in October 2000 had convinced most of us that climate change is a reality - gave the signal "We, government, do not take climate change seriously; we bend over backwards to appease the road lobby." So it is no wonder that road usage has increased.

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?

"How should we reconcile ..." is the wrong question. Or, rather it is a trivially insignificant question when compared with the question of whether ETS should be a "key component" or "central plank" [5.1] of our reduction policy.

Q6.1 A comment on ETS

We admit that ETS might have some merit, for example in bringing reluctant business people on board by offering them a mechanism with which they are familiar, and in giving incentive to companies and nations to develop expertise in CCE reduction.
But in the long term ETS is likely not only to fail to deliver but to prove counterproductive, for various reasons.
The comments below are made on the basis that [5.17] says that "we intend to use this consultation as a starting point for development of some of the key principles of allocation in phase II" of the ETS. We trust that the comments are helpful for this purpose.
ETS presupposes the notion of a surplus that may be traded. But there is no true surplus until we have achieved 60% reduction. Any so-called surplus is only relative to an arbitrarily chosen interim target.
- To call 'surplus' anything above any figure less than 60% gives the wrong signal. It says "You, partner in ETS, may relax your efforts to reduce CCE."
It seems to us that ETS rests on shaky and questionable assumptions, and that for ETS to work, all the following need to be true. (If any of the below show a misunderstanding of ETS, please ignore them, but take account of those that are valid. We note that [4.9] welcomes our questioning of assumptions.)
- That the fixed total of allowances will never be allowed to increase: this assumption is explicit in "The environmental impact of the scheme is fixed overall" [5.5]. If the total is allowed to creep up (such as by pressure from strong lobbies), then the global attempt to achieve even the interim target, let alone the true target of 60%, is jeopardised. BUT: the EU can amend the Directive, and thus increase the allowance.
- That, during every unit of trading time, at least as many allowances remain under-used as have been over-used.
  - Suppose that, of 25 partners in ETS each with an allowance of 100 units, one partner achieves an under-use of 10 units, but the remaining 24 partners achieve an over-use of 10 units each. The total usage will be 230 units above the total target. The 10 under-used units cannot compensate for the 240 over-used units.
  What penalty can there be that is effective against a net over-use of allowance? BUT: We cannot envisage a penalty strong enough to be effective against net over-use of allowances.
- That no partner will have its allowance increased. If one partner has its allowance increased, then another must have its allowance decreased. Which partner will be willing to have its allowance decreased? BUT: [5.12] says the UK government is seeking an increase in allowance.
- That the trading price will be high enough to act as incentive. [5.4] incentive depends on this assumption being true.
- That a partner that consistently uses less than its allowance, will continually receive a reward, rather than having its allowance reduced. [5.3] explicitly assumes this in saying "These surplus allowances can be kept for use in future years ...". If there is the chance that consistent under-use of allowance leads to reduction of allowance, then this will act as an incentive against under-use of allowances. In such cases, it is likely that each partner will either over-use or plan to marginally under-use their allowance, to prevent reduction. This means that the pool of unused units to 'sell' will always be small. BUT: In most allowance arrangements (e.g. budgets) a partner that consistently under-uses their allowance by a significant has their allowance reduced.
The size of penalty will determine the trading price, and thus the effectiveness. There will always be a pressure from partners jointly to reduce the penalty, and thus the effectiveness of ETS.
ETS trades, not goods, but problems (i.e. units of CCE). Therefore it is not a market in the usual sense. Are there any cases in which such a problem-trading scheme has ever been tried before and been successful in reducing the problem being traded? If previous precedents can be found, a stringent comparison should be made with both the EU and the UK ETS.
But the impression that some goods or currency are being traded will lull partners into a false sense of security, each intent on maximizing their own trading advantage (by pressing for an increase in their allowances if not by reducing CCE), and oblivious to the overall total CCE of all partners.
Moreover, ETS gives the whole scenario a competitive rather than collaborative spirit. This relates to the need to engender an attitude of self-giving if we are to reach the 60% reduction that is needed; see Q9.3.
We note that UK ETS has delivered some benefits. These are to be welcomed. But these benefits should be examined to see which of them are
- temporary
- one-off,
- likely to suffer from the rebound or comfort effect [3.21].
The problems we have outlined above have not had time to build up.
It is most likely, in this real world, that ETS will eventually fail to deliver sufficient effective CCE reductions.
Therefore, it is very dangerous to make ETS a "central plank of our future reductions emissions policy" [5.1].

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?

This question, as put, is hardly significant when compared with the far more important question of how to set targets and what targets to set in the first place.

Q7.1 How to calculate targets

When setting targets, the government should expect them to be missed.
- For example, the domestic target of 20% reduction is now seen as 'unattainable', and is revised down to 14% (a massive 35% lowering of the target figure).
There are several reasons why targets of this kind will be missed:
- Over-optimism in the original setting of the target (and perhaps a desire to please politically either the public or officials)
- Under-estimating the difficulties of achieving it
- Initial over-estimation of our success in reaching our targets. (See [3.12,13] for examples of initial over-estimate of reduction of CCE.)
- Under-estimating the problem of CC itself (which, according to the government's CC conference in Exeter in 2005, is proceeding faster than previously expected)
- Pressure from those who do not want to achieve it, especially (as in this case) it affects the most powerful lobbies
- Targets that have an ethical element and based on collaboration are more difficult to achieve than those based entirely on immediate self-interest and competition
- and so on.
These should all be taken into account when setting targets.

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

Targets and measures should be plan-led and not demand-led, because it is the fulfilling of most demands that creates CCE.
[3.20] points out that energy consumption has risen less than demand growth would suggest. But - partly because of the rebound effect [3.21]:
- In [3.16], though the energy ratio has fallen by 45% since 1990, the GDP has risen and energy consumption has risen overall.
- The decline in energy ratio is not likely to continue at this rate until 2050. It is acknowledged in [3.16] and [3.20] to be partly due to structural changes in the economy, including the decline in energy-intensive industries like steel. This can only happen once, and will not continue.
- Given that there is a limit to the increase in carbon efficiency with which energy can be produced to 2050, this means that energy consumption must reduce by a large part of 60% by 2050.
But in fact the government seems to be more demand-led than the previous administration, especially in relation to the two sectors that are increasing their CCE most rapidly ([3.4] Figure 4): air and road transport.
This means that demand must be actively decreased. The government must plan to reduce demand, not accede to its increase. The targets that are set should be designed to reduce demand for and in those human activities that cause CCE. In particular, road and air transport.
Reducing demand can have additional benefits.
- Example: The goal of energy security [5.7] is better served by reducing demand than by increasing supply.
- Example: It is cheaper to save a unit of electricity than to generate an extra one.
- Note: In [5.7], it is assumed that 'environmental goals' must be 'balanced' against 'energy security' and 'competitiveness of industry'. But in fact, these need not be mutually antipathetic. Fulfilling environmental goals actually leads to greater competitiveness and security, rather than working against them.
- Note: The Director General of the CBI recently could not name a single firm that had abandoned, or refused to come to, the U.K. on grounds of environmental legislation.

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

Does the question mean measures as metrics or measures as actions to be taken? We will answer for both, then address an important new set of measures that should be considered (both metric and action) - to do with lifestyle.
New measures as Metrics that might be considered include:
- International air transport must be included, despite not being part of the Kyoto protocol [3.5]. This is because it will become a huge contributor to CCE. At some 32 times larger than domestic air transport by 2030 [8.20], it will swamp the measures used in [3.4].
- As mentioned elsewhere, measures that indicate who well the whole world is doing should be distinguished clearly from those that indicate how well the UK is doing but have little impact on the world due CCE-creating activities being moved from the UK to elsewhere in the world (e.g. steel and much manufacturing industry [7.7]).
New Measures as Actions that might be considered include:
- New mechanism. Britain has some of the leading expertise in CCE reduction ([7.15]). This could be
  - sold around the world
  - developed further, so we come down the 'learning curve' more quickly.
  The government should make a sustained investment in helping our companies to do both these things. British companies are good at thinking up new ideas but notoriously bad at selling those ideas widely around the world. Note that investment in this would also bring benefits in reputation.

Q8.1 Lifestyle: Ways of Living and Working

(This is an important section, frequently referred to from elsewhere, and it links with Attitudes and Responsibility discussed in Q9.3.)
A major set of new measures as actions is required to achieve a change in world view and lifestyle. World view and lifestyle include:
- habits,
- expectations,
- aspirations and taken-for-granted desires,
- assumptions about what is 'true' and 'reasonable'.
They are things that are usually taken for granted and determine what how we live and work. They are components of attitude, which is discussed in Q9.3.
Lifestyle and world view determine what we do from day to day, minute by minute:
- Habits: We tend to keep on doing what we have always done, without thinking. It is difficult to consider alternative courses of action. Habits determine what we continue to do without thinking.
  - Example: we jump in the car without thinking, even perhaps to go a mere quarter of a mile.
- Expectations: We have certain expectations that we take for granted are due to us. (We can tell what these are by what angers us.) Because they are due to us, we assume we are perfectly justified in creating CCE (or doing any other activity that happens to be harmful) in fulfilment of them. We do not question our expectations, and resist anyone who does. Expectations determine what we get angry over and what pressure we put on government and others to (allow business to) provide for us. A major expectation in the affluent societies of the world is convenience.
  - Example: we expect to be able to drive easily, cheaply, without congestion, and to have a parking space at our convenience when we get there.
- Aspirations: We aspire to certain things, without questioning whether what we aspire to is harmful or even justified. Aspirations are often generated by the media and peer pressure. We exert effort and consume energy to meet our aspirations - and hence generate CCE. Aspirations determine the direction in which CCE will move: up or down.
- Assumptions: We make assumptions about what is 'normal' or 'true'. These are fed by the media, surreptitiously. We do not question them. Our assumptions provide us with arguments if anyone questions our habits, expectations or aspirations.
As discussed in Q2.1, we need to attend to these because technological advances are unlikely to be sufficient to achieve a 60% reduction by 2050. On the contrary, technological advance, such as energy efficiency, means:
- Habits: We do more of what we did before, because technology enables it.
- Expectations: We expect more, because technology encourages us to do so.
- Aspirations: We aspire to new things that technology dangles in front of us.
- Assumptions: We come to assume that technology is the answer.
By 'lifestyle' we mean not only in the private life, but also in the way we do business.
- Example: Do we jump in the car without thinking, if we have to go somewhere, or do we think first about other modes? To send something, does business use a road courier without thinking, or do they consider whether there is a less damaging option?
The lifestyles of people and business in the U.K. - our habits, expectations, aspirations and assumptions - all point in the direction of increasing CCE.
We can see this in [3.4], where it is clear that the three factors that have increased in comparison with the average of all sectors (Fig. 2) or, in absolute terms the three that have either increased or hardly decreased (Fig. 4) are those most closely connected with lifestyle (private or business):
- domestic air transport up by 40% (up by 67% relative to average of sectors)
- road transport up by 12% (up by 30% relative to average)
- residential down by only 3% (up by 16% relative to average).
This alone should show that lifestyle is an important issue for the CCP to face up to.
The government should consider lifestyle as something that needs direct attention rather than hoping that it will be indirectly affected.
- Flaw in CP: The CP does not seem to take the importance of lifestyle seriously.
But action to change lifestyle is difficult, largely because these four lifestyle things - habits, expectations, aspirations, assumptions - are all taken for granted, seldom questioned. And some people will be angered when change threatens them, perhaps because we do not like our habits threatened or our expectations and aspirations questioned.
But it is possible to change them, if a serious and considered attempt is made to do so. Though there will always be some who will resist change, the majority of people are reasonable when the issues are clearly explained and have an ethical sense of what is right and are willing to sacrifice some of their habits, expectations, aspirations for the sake of that right.
But, to change lifestyle things takes:
- Sensitivity - to the feelings of all involved
- Clarity - in the case made and the logic thereof
- Expertise - in the planning of the change
- Communication and discourse - to engage and listen
- Friendliness - that treats others as full human beings rather than as sub-human consumers
- Frugality - in the careful use of resources
- Allusiveness - in keeping a sense of fun in harmony with seriousness
- Responsibility and a sense of what is due - to all involved or affected
- Honesty - about the case being made and problems we face
- Legislation - that will reward good lifestyle choices and penalise poor ones
- Humility - in our presentation of the case and the plans
- Self-giving and vulnerability - in no longer being over-protective of our own interests
- Leadership - setting the direction for all to take
- Commitment - to the change and to God to whom we are ultimately responsible.
These are all aspects of setting a genuine example (Q5.1) - statesmanship that people will follow. (The particular aspects are derived from those suggested by the Dutch thinker, the late Herman Dooyeweerd, who delineated aspects of the lifeworld as part of his 'New Critique of Theoretical Thought' [Mellen Press, 1997].)
Policy decisions have an important impact on lifestyle. Example of Poor Policy: Removal of Fuel Duty Escalator, which has led to an increase of 9% in road use. See Q29.1.
The obvious riposte to this approach is that seeking to change lifestyle smacks of interference with people's freedom to live as they choose. Though this has some validity, this should not debar the government from addressing the need for lifestyle to change. This is discussed at greater length later in Q51.1. There are ways to change lifestyle that are not draconian and that retain people's freedom.
One way to do this is to differentiate varying degrees of necessity in what we do. Most people would agree that it is appropriate to target those things that are more harmful and less necessary.
- Example: In [7.31] it points out that sulphur hexafluoride is used in training shoes and as a cover-gas in magnesium casting. It seems to this contributor, at least, that SF6 has high necessity as a cover-gas for magnesium casting, but a very low necessity in training shoes. (In that training shoes can be made without SF6, and even if not there is no absolute necessity for training shoes.) Therefore, the use of SF6 in training shoes could be completely banned without serious damage to people's human rights or the economy, while it might not be banned in Mg casting.
- Example: Products could be sourced more locally. The famous example is of two lorries passing each other on the M6, one carrying rich tea biscuits from London to Glasgow, the other carrying rich tea biscuits from Glasgow to London.
- For example, with slightly better planning, total journey length to visit a given set of customers, clients, etc. could be shortened.
Therefore, in answer to Q8, we need a whole set of new measures to change people's lifestyles.
- Action: To find out what contribution is needed from changes to lifestyle, the government should realistically estimate the total percentage reduction in CCE that can come from technological advances and increases in efficiency, taking into account both greater efficiency and the rebound effect, subtract that from 60%, and the result is the minimum reduction that must be sought via change in lifestyle.

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

We must differentiate between measures that express (metrics) or generate (action) a genuine global reduction in CCE, from those that might put UK in a good light but ignore the shift in emissions to other places in the world.
- For example, we congratulate ourselves over reductions achieved already. we are glad to see that it is recognised that some of this is due to decline in manufacturing industries such as steel [7.7]. However, this does not constitute a global reduction in steel-making. Rather, steel-making (and even more energy-intensive processes such as aluminium) is growing in other countries, and it is likely that these are growing globally, or will grow as 'poverty becomes history'. Therefore we must take this into account.
Action: Each measure should be labelled according to whether it contributes to global CCE reduction or merely UK CCE reduction.

Q9.2 An Integrated Approach

Climate change is only one of several environmental and social problems that inter-relate. For example:
- the global water problem
- the reduction of the ability of seas to produce
- deforestation
- reduction in biodiversity and habitat,
- extinction of species, globally or locally
- light pollution of sky, and noise pollution
- over-consumption
- health problems of the affluent
- health problems of the impoverished
- over-use of road transport.
The same lifestyle attitudes, habits, aspirations, expectations, assumptions (see Q8.1) and ways of working that generate these is also what generates CCE: an attitude that is content to ignore or even shirk responsibility for problems outside our immediate ken. See Q9.3.
It is likely that were we to effectively tackle and reduce one environmental problem then other social and environmental would also be reduced, because doing so engenders an awareness of responsibility and the dignity of taking responsibility.
- Example: Reducing total road usage because of climate change will also reduce:
  - pollution that causes asthma,
  - road deaths and injuries
  - health problems due to lack of exercise
  - and hence NHS bills
  - disruption of business life from deaths, injuries, etc.
  - damage to property and wildlife
  - and so on.
Therefore,
- If we take other environmental problems into account as we tackle CCE we will gain additional benefits
- If we ignore them, our measures will be less effective than we hoped.
Therefore,
- CC should not be considered in isolation from these other environmental problems but in conjunction with those problems
- this mutual reinforcement should be a stronger incentive to reduce CCE even if there might seem to be immediate economic barriers to so doing.
Measures of CCE reduction (metrics) or for it (actions) can either narrow the thinking to CCE alone or can widen our thinking to be cognisant of other environmental problems. Measures of the first kind will, overall, be less effective than measures of the second kind, because the latter will benefit from mutual reinforcement.
We suggest that each and every measure (both metrics and actions) be examined to whether it tends to make us neglect or actively consider other environmental problems.
- Example: we are glad to see that such an integrative approach seems to be present in [4.7,8] and in [12.10] - but there are perhaps too few of these, and they are relatively weak because they focus too narrowly on direct impacts and ignore indirect impacts.
- Example: ETS is in danger of narrowing the focus by isolating CCE from other environmental issues, and converts it into the form of quantified units that relate only to themselves and to a trading price.

Q9.3 Attitude and Responsibility

(This links with Lifestyle issues in Q8.1 and the Integrated Approach in Q9.2.)
All of us cause CCE by the way we live and work. As argued in Q8.1, there is a need to change the way we live and work. However, this can be effected by two means:
- by externally imposed rules, systems, targets, measures (metrics and planned actions)
- by an internal change of attitude.
By 'internal change of attitude' we mean the dignity of being aware of responsibility and a willingness to make sacrifices for the common good. (Compare with list of aspects of changing lifestyle in Q8.1.)
While externally imposed rules, systems or targets can play their part, internal change of attitude is the more effective in the long term. This is because those with a responsible attitude will tend to act responsibly whatever the circumstances and whatever external rules or systems are imposed, and they will also not seek to find loopholes in the rules. By contrast, those who do not have such an attitude will not act with responsibility unless robust rules and systems are imposed, and many of them will always be seeking to take advantage of loopholes therein.
Internal attitude is fairly stable and persists over the longer term and throughout different contexts, while external systems, rules, policies change. Therefore, in the case of CCE, since we need to look to the long term (2050 and beyond), the most effective action the government could take would be that which engenders an internal responsible attitude among us. It is not government alone that can do this (for example, media, opinion formers, religious bodies, education can help), but we are here concerned with what government can do.
The government cannot legislate for attitude and responsibility. The CCP comprises formal apparatus of rules, systems, targets, measures, etc. But the nature of this formal apparatus can make attitude more or less effective, and can encourage the development of certain attitudes. Some formal apparatus tend to engender responsibility while others make it more difficult to take responsibility and thus deter it.
- Unfortunately, most competitive measures and targets are of this kind. As a system, ETS is likely to discourage responsibility and an attitude of self-giving, as argued under Q6.1.
Therefore, in partial answer to Q9, we can at least suggest propose the following guide to the formulation of rules, systems, targets and measures: they should be such as to encourage, not deter, an attitude of responsibility and self-giving.
- Action: Each action, metric, target, policy, etc. should be scrutinized for its likely effect on attitudes of responsibility and self-giving in both business and the home.

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?

Do not consider it a 'surplus' until we have achieved a full 60% reduction in global CCE. See above, Q6.1, Comments on ETS.
The notion of a surplus presupposes the notion of being rewarded for doing better than others do. This presupposition is misleading and should be abandoned. Because it leads us to relax our effort at reducing CCE before the full 60% is achieved.

SECTION 5: EU EMISSIONS TRADING SCHEME

Additional comment:

There is no question here on whether the ETS should be a "central plank of our future reductions emissions policy" [5.1]. There should have been. We seriously question (a) the effectiveness (b) the desirability of ETS as a way of achieving the eventual 60% reduction that is needed. Since there is no question here in which to place the argument, it has been placed in Q6 above. Please refer to Q6.1 comments here.

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:

Inclusion of process emissions from sectors whose combustion emissions may already be covered (e.g. the chemicals, food and drink, aluminium and engineering and vehicles sectors);
Expansion of the scheme to other sectors;
Inclusion of emissions of greenhouse gases other than carbon dioxide?

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.

It should be able to act unilaterally if need be.

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?

See Q6.1 comment on ETS, which explicitly aims to inform phase II.
Given that with the current scheme and allowances it is likely that the UK will miss its original 20% target by 6 % points (i.e. reach only a 14% reduction, if that, the allowances for phase II should be much more stringent than those in phase I.
If you aim an arrow directly at a target, it will fall short. To hit the target you always have to aim high.

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

The allocations should decided on the basis of our need to reach a 60% reduction globally by 2050.

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)?

Beware that 'harmonisation' does become a euphemism for 'watering down'.

SECTION 6: ENERGY SUPPLY

S6.1 Additional Preliminary Comment on Energy

This section 6 is misdirected. It should focus on energy use in the UK, of which supply is one part, and not energy supply as such. Then there are three major ways to reduce CCE:
1. a) to reduce our tendency to use or need energy in the first place
2. b) to reduce our waste in the energy we use (increase energy efficiency)
3. c) to reduce the amount of carbon used in supplying energy.
Focusing on energy supply, as this section does, directs our attention towards (c) and perhaps (b) but at the expense of (a).
(a) concerns our belief and assumption that we need energy to power our living and working, and our tendency, by habit and expectation, to consume energy.
- By habit, we often opt for the more energy-intensive action without a second thought.
- By expectation, we assume that energy is available conveniently at the flick of a switch, 24 hours per day.
- By belief, we assume we need energy and cannot live without it (see example of power tools below).
Under (a) the following can be discussed (as examples):
- Doing less of the energy-consuming activities, and more of the activities that consume less energy.
  - Example: because of high levels of marketing over the last 30 years, we have come to believe that we need power tools rather than hand or manually driven tools. But the latter not only consume less energy (albeit making only a small contribution) but they give us more exercise and remind us that there is a different way of living.
- Heating homes to slightly lower temperatures
  - Note: Many homes are over-heated, which is detrimental to health as well as CCE.
- Finding ways of doing without, or reducing need for, air conditioning (e.g. by better design of both buildings and equipment to allow good air flow)
  - Example: City of Davis, California planted trees in car parks to shade cars, so that cars no longer needed to keep their engines running while parked to drive their air conditioning systems.
- Reducing the habit of leaving computers switched on overnight
  - Example: The very design of Microsoft Windows, in which you need to go through a cumbersome Shutdown process, mitigates against just switching off; by contrast, the Amiga and Linux platforms can be switched off without 'Shutdown'.
- Reducing use in agriculture of fertilizers, which are energy-intensive in their production.
  - Note: This would move towards less intensive agriculture and even more organic farming, which has other environmental benefits which should be taken into account; see Q9.2.
- Switching off street lights at night (which would also assist the environmental problem of light pollution in Q9.2).
If we are to ever reach our 60% reduction then we must need, and tend to use, less energy in the first place. As should be clear, this is a lifestyle issue, dealt with more fully in Q8.1.
The advantage of addressing (a), the use of energy, directly is that it focuses on what we, as citizens and business people, can do, as action and as a way of taking responsibility (see Q9.3), whereas addressing (c) and to some extent (b) shifts attention to "Oh, it's their problem, not mine; I don't need to do anything because it's already taken care of."

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?

This question should also keep 2050 in mind, because 2010 and 2020 are only interim steps to that eventual, necessary 60% reduction.
However, in answer to Q18, additional emission reductions can come if we reduce our need for energy in the first place, our tendency by habit and expectation to consume energy. See the Additional Comment S6.1 at the start of Section 6.

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?

This author, personally, would like to have a small windmill on his house (in a housing estate), to generate his own electricity, since it receives a lot of wind.
It is important that micro-generation is helped to get down its learning curve. By this we mean that the technology and techniques are tried out widely, mistakes are made (and allowed to be made), and ways are found of reducing costs. Learning curves can take 10 years or more, but with judicious government investment this can be speeded up.
Of course, government investment would be needed, but consider the following ...
A 'Booker-Prize' for Micro-Generation. A useful way of getting the public and SMEs to get into a new thing like micro-generation is to set up presigious and well-publicised competitions for micro-generation facilities (such as the 'most effective', 'most productive', 'most inventive', 'most integrated', 'most artistic'). People - whether private residents or owners of small businesses - respond much better to such competitions - fun-with-a-bit-of-reward - than to mere boring government investment or strictures.

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?

2010? 2020? Does the government have any idea how we might get to a global 60% reduction by 2050? Has it even discussed this? The CP gives no indication that it has done either.
To answer Q20 and Q21: At least at the strategic level, measures to achieve the 60% reduction of 2050 should be being considered right now. Measures to 2010 and 2020 should be considered in the light of the strategy to 2050 and not isolated from it.
As mentioned above, the government should not be thinking only about new technologies (which contribute to (b) and (c) above, reducing waste and reducing CCE of energy supply), but also about (a) above, how to reduce our need for, and our tendency by habit and expectation to consume, energy.

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

SECTION 7: BUSINESS

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

We notice that most of this section concerns the CCE that are a direct result of the way business operates - such as the energy efficiency of its processes. But there are also indirect effects, which are often more important.
For example, a business that markets and sells energy-intensive equipment might be very efficient in its own production processes, yet each and every piece of equipment it sells will lead to the customer using a considerable amount of energy and thus generating CCEs. The same may be said of a company that markets and sells CCE-generating processes or consultancy advice. Of course, it may be that a certain amount of such equipment, process or advice is needed and unavoidable.
But the irresponsible activity is market-generation, when this creates a new market, or expands an existing market, for CCE-generating goods, processes or advice.
- Example: The current massive expansion of cheap air flights. The advertising that EasyJet undertakes might itself generate much CCE; but once people have become used to flying to Spain every other weekend, CCE will rise enormously. (c.f. Q8.1 on Lifestyle habits, expectations.)
Many such examples may be found - of new markets of high-CCE activities or goods. As we discuss elsewhere, such new markets are not necessary, because other markets, less CCE-intensive, may be found instead.
These are indirect CCE impacts, generated by pull-through. This is something that the CP ignores but the CCP should take seriously.

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.

Response:

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?

Response:

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?

Response:

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

it becoming fashionable and a 'selling point'
it is seen as an easy way of removing opening windows (uncritically seen as 'expensive and a security risk').

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?

See Q6.1: problems with ETS. However, we do not say that ETS should be abandoned in 2006, because it does provide a few benefits. Rather, we say that a better scheme should be devised to replace it, which engenders responsibility and self-giving (see Q9.3) and does not rest of the questionable assumptions that ETS rests on.

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.

We have some concern that the CCP is broken down into 'sectors', because this makes it more difficult to see clearly the link between the decisions each person or business makes and the CCE that result from that decision.
- For example, as we mention later, not insignificant CCE is generated during the manufacture of Nitrogen fertilizers because of the large amounts of energy consumed. The decision that results in this CCE is that of the farmer when they decide to apply fertilizer. But the 'sector' within which this CCE is generated is the energy supply, or maybe business, sector. The link between the decision that results in CCE on the farm and the actual generation of CCE is hidden.
It would be preferable if the cake were cut differently, in such a way that the links between decision and generation were made more visible.
Moreover, making such links more visible would aid in the taking of responsibility (Q9.3).

SECTION 8: TRANSPORT

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

[8.3] says that the current transport strategy to take us to 2030 is that "though good transport is central to a prosperous economy, facilitating better access and greater mobility, we must balance the increasing demand for travel against our goal of protecting the environment effectively and improving the quality of life for everyone - whether they are travelling or not."
We question the sincerity of this statement when it speaks of 'balance' between "demand for travel" and "protecting the environment effectively". True balance implies a reduction in both sides. But there is no discussion at all about the possibility of reducing demand for travel (road usage which generates CCE) in the Transport Section. So it is clear that the government's actual attitude is not to 'balance' these, but to prioritize "better access and greater mobility" over "protecting the environment effectively" and to satisfy "demand for travel" with little let or hindrance. They hope that the measures they had set in place would achieve the CCE reduction targets without the need to reduce mobility.
But, as [8.13] make clear, the CCE targets for transport are far from being met. Worse, if even the easy, interim targets cannot be met, the eventual 60% reduction by 2050 stands no chance of being met, if the government continues in the same vein, giving way to CCE-generating 'demand for travel'.
Road usage and demand for travel must be reduced. That means that mobility must be reduced.
There is an urgent need to question the assumption implicit in [8.3] that greater mobility and better access are necessary for a prosperous economy.
- Note: In the 1970s it was believed that a prosperous economy depended on every increasing usage of energy. But, as Figure 6 [3.15] shows, and as we now know 30 years later, this proved not to be the case. A way was found to have a prosperous economy with lowered energy ratio.
In the same way, it is most likely that we can find a way to have a prosperous economy without greater mobility.
But this time we cannot afford to wait 30 years to find out that this is so. Instead, we must act NOW to find a way to have a prosperous economy with lowered mobility.
The presumed links between mobility and prosperity are not absolute but rest on a number of assumptions, many of which should be questioned. Some of them are dependent on a society in which consumption is maximized and an ever smaller number of ever larger businesses dominate the economy. There is good quality work among several types of economic thinking that demonstrates that real prosperity can be achieved even with lower mobility.
- Action: The government, especially the Treasury and DTI, should immediately explore types of economy that can be prosperous without every increasing mobility.

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

No. Figure 9 is misleading, as is the lack of certain other graphs. See the following more general point: the whole section is misleading.

Q28.1 Transport: A Deceitful, Misleading Section

Road transport is, according to [3.4], a serious problem, being the third highest contributor to CCE currently and, apart from air transport, the only sector that is growing. In view of this, we would expect there to be a graph showing the rise in road usage and its rising contribution to CCE, together with a substantial discussion about the rise in road transport. But we find no such graph and no such discussion. It is almost as though the writers of the Transport Section deliberately hid the important issue of the rising mobility and demand for road travel.
Instead, the only graph is Figure 9, which shows reductions in CCE from new cars. The visual effect of this graph, obtained from looking at the graph but not the numbers, is that CO2 emissions from new cars have reduced by 60% in the UK and by a massive 85% in the EU since 1990. This surely gives hope that we will achieve easily not only our domestic target of 20% but even the more important target of 60%.
But wait! Look at the figures, which do not actually start at zero on the Y axis. In the UK, CO2 from new cars in the UK reduces from 192 to 173 - a fall of only 10%. And only 12% for the EU.
The noted graphic design theorist, Edward Tufte speaks about a 'lie factor' in graphics, which he defines, in 'The Visual Display of Quantitative Information' [1983, p.57], as:
```
	Size of visual effect
	---------------------
	Size of data effect.
```
The lie factor is 6 for the UK and 7 for the EU. Because of this, it is not inappropriate to call this diagram deceitful.
We might add to this (see Q29.1) the lack of any mention at all of a possible measure that could be taken, namely a Fuel Duty Escalator, which had been proving effective in reducing traffic and thus reducing CCE up to 2000. More about this below.
Thus we have, in this section,
- a deceitful graph, which gives the casual reader the idea that advances in car technology are sufficient to achieve major CCE reductions when in fact they are not,
- a complete omission of any discussion about the rise of CCE from road usage,
- absolutely no mention of a proven effective measure to reduce CCE by making it unattractive to travel.
Instead, the majority of the discussion is restricted to the narrowly scoped topics of various technologies such as biofuels, low-carbon cars, etc. and fiscal measures such as VED and road pricing. But it is admitted that these measures are not enough:
- [8.13], for new vehicle technologies: "We will need to do more if PFV targets are to be met."
- [8.8]: "VED has had a less significant impact"
- [8.18], on road pricing: "the impact is not entirely clear-cut" - which is wording from the Road Pricing Feasibility Study (July 2004, para 4.30), which makes clear that in fact, "in pricing terms it is the overall level of the cost of driving which affects carbon emissions rather than the differentiation in price according to time and place that road pricing makes possible."
No wonder that even achieving the modest domestic target of 20% is proving difficult (which it has been admitted will be missed by 6 % points). (Fuel Duty Escalator was effective because it did directly affect the "overall level of the cost of driving".)
While these are an important part of the solution, they are only part, and indeed only a small part if we are to seriously consider how a global 60% reduction in CCE by 2050 is to be achieved. Most technological advances slow down after an initial promising phase. As has been argued in Q2.1 and Q8.1, it is not sufficient to change vehicle technologies; to achieve 60% reduction in CCE there must be an accompanying change in lifestyle. In the case of transport means reduction in the amount of road and air transport - a reduction in mobility and the demand for travel.
Thus we can only conclude that the Transport Section was written, not to encourage a genuine review, but to try to pull the wool over our eyes, by directing our thinking away from the possibility of reducing road usage and by trying to give the false message that advances in car technology would be sufficient. This is a deceitful section.
In view of the seriousness of climate change and the need to seriously work towards a 60% reduction in CCE, there are few words in the English language too strong to condemn this deceit. However, we will not use such words, and will respond to the remaining questions without reference to it.

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

Q29.1 Fuel Duty Escalator

"Fiscal measures are a key tool" [8.7]. Why then is there no mention of such fiscal measures as a Fuel Duty Escalator? Given its proven effectiveness in reducing CCE from road transport (see below), arguments should be at least be presented as to why it is not being proposed?
By its own admission, in [8.8], VED is relatively ineffective, and in [8.18], Road Pricing is not unconditionally effective in reducing CCE. But Fuel Duty Escalator was proving effective. The Defra publication, Climate Change UK Programme, published in 2001 shows clearly how successful the Fuel Duty Escalator was (chapter 5):
"38. One measure which has already delivered reductions in emissions from road transport is the fuel duty escalator - annual fuel duty increases above the rate of inflation. The escalator was introduced in 1993, first at an annual rate of 3% above inflation and then at 5%. It was increased to 6% in July 1997 and has been very successful. It sent a clear signal to manufacturers to design more fuel efficient vehicles, and to motorists to avoid unnecessary journeys and to consider alternatives to the car. Taken in isolation, increases in duties between 1996 and 1999 are estimated to have produced annual carbon savings of between 1 and 2.5 MtC by 2010."
Furthermore, on 6th July 1999, Patricia Hewitt, Economic Secretary to the Treasury, said in Parliament:
"Our environmental assessment is that if the road fuel duty escalator is continued until 2002, it will, by 2010, save between 2 million and 5 million tonnes of carbon--an extremely significant contribution towards our Kyoto targets."
So, if we are not mistaken in our interpretation of these figures, the effect of the escalator at 2010 would have been double its actual effect had it been continued to 2002.
In the absence of government calculations, let us use these figures to calculate what the effect of the FDE would be until 2050. 3.5 MtC (the average of 2 - 5 MtC) is over 10% of the 1990 contribution from transport (34.1 MtC in [3.14] table 3). This would have been achieved from less than 10 years' application of the FDE (1993 to 3003). If we were to apply the FDE from now until 2050, five decades, we could expect five more 10% reductions each decade from 2002. This is six 10% reductions in total from 1990, reducing CCE to 53% of its 1990 level for road transport (calculated as 0.9 (90%) multiplied 6 times).
This is a 47% reduction in road transport CCEs by 2050 from the Fuel Duty Escalator alone. It is likely that our simplified calculations are in error; even so, it still suggests that the Fuel Duty Escalator would be a very powerful weapon against CCE.
Further, Ms. Hewitt said that the FDE was having other beneficial environmental impacts: "the contribution that the fuel duty escalator makes, by constraining the growth in demand for road transport that would otherwise take place, to improving local air quality and thus people's health." This is in line with the principle of an integrated approach (Q9.2).
The Fuel Duty Escalator was working well, and is likely to continue working well. So why was the Fuel Duty Escalator dropped?
There was considerable pressure on the government from the road lobby, and it seemed the government caved in and appeased them. But they did not need to do so. Consider first the historical order of events:
- Sep 2000: Fuel protests surprised us all. Seemingly massive support.
- Oct 2000: Huge storms swept the country. People became aware climate change is real.
- Nov 2000: Fuel protestors tried again, but found they had lost all their support.
There was absolutely no need to remove the Fuel Duty Escalator. The public would have supported the government at the time if it had clearly enunciated the view that the Fuel Duty Escalator was necessary for the sake of CCE.
But the government ignored this, and seemed to bend over backwards to appease the fuel protestors by removing the Fuel Duty Escalator. The results of this action show the effect of policy decisions on lifestyle:
- The cost of motoring has reduced in real terms since 1997 in comparison with the cost of rail travel increasing.
- Consistent with this message, the Chancellor of the Exchequer has stubbornly refused to increase fuel duty by any meaningful amount since then. As a result, while rail fares have increased in real terms by around 5%, the cost of road transport has fallen in real terms.
- As a result, Wisconsin pulled out of EWS, saying that its projections of conversion of freight to rail were now in tatters.
- Message given by the government by this action: "We don't really care about climate change; we want to appease the road lobby."
- And road use has climbed steadily since then, to 9% above 1997 levels.
John Prescott said around 1997 "If there are not far fewer journeys by car in 5 years, I will have failed." The government not only failed, they made it worse. This is the very opposite of what is needed if we are to reduce CCE.
The Fuel Duty Escalator - or something similar - should be reinstated without delay.
It so happens that we include the Fuel Duty Escalator in the answer to most of the questions below. This is not merely blowing the same tune on the trumpet, but rather because it is a genuine answer to each question. We give the reasons specific to each question.

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?

In addition to any measures to develop cleaner, greener transport, there should be measures to reduce the total volume of road-use miles. This in turn requires action to change our lifestyle habits and expectations of driving and our majority assumptions that car is the only way to travel.
An important way to achieve what this question asks about is: reinstate the Fuel Duty Escalator. This will make fuel more expensive (reversing its fall in cost in real terms) and provide greater incentive to find alternatives or increase efficiency.
- As Defra said (quoted above), "It [Fuel Duty Escalator] sent a clear signal to manufacturers to design more fuel efficient vehicles ... "

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

As argued in S8.1, the additional comment on the Transport Section, and in Q2.1, such technological advances are not as effective as their proponents in the government had hoped. It is necessary to change the way people live and do business - their habits, expectations, aspirations and assumptions. See Q8.1.

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

Reinstate the Fuel Duty Escalator, as discussed in Q29.1. This will reduce the amount of road usage, by
- reducing the need to travel
- shifting passengers and freight from road to rail
  - Note: Winsoncin pulled out of EWS when the government removed the Fuel Duty Escalator because it meant that their estimates of growth in rail freight would no longer be valid.
- motivating people to walk or cycle more
and thus make better use of our transport system.

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

Reinstate the Fuel Duty Escalator, as discussed in Q29.1. This will
- give the message that car usage must be reduced for reasons of CCE and other environmental reasons; as Defra said (quoted above) the Fuel Duty Escalator "sent a clear signal to manufacturers ... to motorists to avoid unnecessary journeys and to consider alternatives to the car"
- and raise the cost of petrol and diesel in real terms and gradually turn people away from the less necessary road journeys.
But an additional important measure to take is to put tax on aircraft fuel and halt all airport extensions. This will reduce the number of flights, especially cheap flights available. This is now discussed.

Q33.1 Aviation

It is recognised [8.20] that air transport is likely by 2030 to contribute 18MtC, one quarter to our CCE. And that international flights will contribute 97% of this. If we are to have any hope of achieving a 60% reduction, then this must not be allowed to happen.
It is, after all, a prediction. Therefore measures can be taken to subvert this prediction and prevent it becoming true. And these measures *must* be taken.
The rise in air transport is driven by a number of factors, including, for example:
- the relatively low cost of aircraft fuel, devoid of tax
- the expansion of airports
- the availability of seemingly low-cost flights
- the strenuous advertising by low cost airlines.
The latter is changing people's lifestyles (see Q8.1). In partciular, such advertising:
- stimulates people's aspirations towards more frequent air travel
- lays down people's expectations that air travel should be cheap and available for them several times a year whenever they fancy it
- changes people's habits of holidaying, weekends and other leisure, away from local non-energy-consuming activities to high-energy-consuming air flights
- changes people's assumptions about what is normal and acceptable as a way to use their money.
This change in lifestyle based on air travel is very, VERY dangerous. It welds people into a higher-CCE lifestyle than is the case even currently. So, rather than reducing CCE, it will increase it. And, since it is a lifestyle effect, it will be very difficult to change it by external rules, systems, etc. (see Q8.1, Q9.3).
The 50% reduction in CCE from new aircraft by 2020 mentioned in [8.23] is, of course, useful. But if the number of passengers more than doubles by 2020 (as it will certainly do!) then that reduction is wiped out. Instead, the raw material that of the CCE - the fuel - should be taxed and made more expensive.
And - note the global connection - if, while we are preaching to the rest of the world that climate change is important, we allow and even encourage British people to get into even higher-CCE lifestyles than currently, then the developing nations will not believe us. They will aspire to follow where we lead. The result could be catastrophic.
THIS SHOULD NOT BE ALLOWED TO HAPPEN.
And there is still time to stop it happening.
Current government policies not only allow but actively encourage people towards more air travel (see the factors leading to increased air travel above).
Instead, the government should:
- immediately and unilaterally place tax on aircraft fuel (see below)
- put all airport expansions on hold, if not abandon them,
- cease all subsidies to aircraft manufacturers and airlines
- get into discussion with cheap airlines to make them aware of what damage they are doing,
- at the same time, create a level playing field by placing special taxes on all external cheap-flight companies, so our businesses do not lose out,
- as well as various other measures.
- (Remember, as quoted earlier, the Director General of the CBI could not name a single company that had left or refused to come to the UK due to environmental legislation. Though companies complain when the government threatens environmental action, their complaints have no substance.)
Expanding airports will increase flying, and hence contribute to this massive damaging CCE increase. According to a Parliamentary answer given during the debate on expansion of Heathrow Airport, the one reason given for the expansion by the Secretary of State for Transport was that it would enable Heathrow to 'compete' with Amsterdam and Paris as a hub airport.
- BUT - is it valid to use the desire to compete for hub status as a reason to ignore CCE?!
- Remember: China and India are watching to see whether we are really taking CCE seriously. They are looking at our example. And, as Q5.1 made clear, this requires that we, wealthy and leading nation that we are, no longer seek to protect every one of our interests selfishly.
- Therefore, there should be a change of Attitude by Government: stop the futile competition with Amsterdam and Paris to be 'leading hub airport'.
It has been claimed that it is not possible to impose tax on aircraft fuel, because of an ancient international agreement (agreed in the 1930s, if we are not mistaken) that this would not happen. Therefore:
- Action 1: This does not stop the government from holding urgent talks with the relevant body to amend or rescind this ancient agreement. [7.31-34] shows that the government is willing to push for international agreements on fluorocarbons, which seem to generate fewer CCEs than air transport will. So it should not be beyond the bounds of possibility to get agreement on aircraft fuel duty.
- Action 2: But if such agreement is not forthcoming, the government should act unilaterally or in conjunction with partners of like mind. [8.22] mentions the government's willingness to act unilaterally if necessary on certain issues concerning aviation; in view of the aircraft fuel tax agreement being so out of date and so harmful in its effects, it is reasonable to act unilaterally.
The government should immediately give a clear message that air travel must not be allowed to increase any further, and indeed must be reduced.

SECTION 9 HOUSEHOLDS

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?

See Q9.3, Attitude and Responsibility.

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?

See Q9.3, Attitude and Responsibility. A inner attitude orientated towards responsibility means that people will tend to take responsibility whatever their situation, rather than shirking or ignoring it.

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?

SECTION 10: AGRICULTURE, FORESTRY & LAND USE

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?

The importance of indirect effects, discussed in S7.1 at the start of the Business section, extends to agriculture. Not only should we be concerned (rightly so) with the actual emissions from the direct practice of agriculture, but we should be concerned with emissions that result indirectly from such practice.
One important and large source of such emissions is the production of Nitrogen fertilizer, which consumes huge amounts of energy in its manufacture. This means that each tonne of fertilizer placed on British soil involves the expenditure of a large amount of energy, and thus a large emission of CC gases. And that reduction of fertilizer use leads directly to a reduction in CCE.
- We have not been able to secure figures for this, but ask that the Review process obtains and considers such figures.
This means that a useful way to reduce overall CCE is to reduce the amount of fertilizer used.
- Suggestion: An increase in the investment in, and encouragement of, organic farming, and in the marketing of organic food and the entire organic 'brand', would therefore have useful implications for climate change.
This would also fulfil the principle of an integrated approach, Q9.2, because other environmental problems would also be reduced, including the harm that intensive farming has done to biodiversity and wildlife.

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?

Take account of the possibility of a colder climate if the Gulf Stream were to diminish, up to 5 degrees colder (see S12.1). This would hinder tree growth and reduce the effectiveness of carbon sinking.

SECTION 11: PUBLIC SECTOR

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?

SECTION 12: CLIMATE CHANGE IMPACTS AND ADAPTATION

This section considers how Britain might adapt to climate change. We agree that it is necessary to consider carefully how to adapt to climate change - but not if by doing so we allow our efforts at prevention to become less strenuous.
The section is disappointing however on several counts.
- It focuses on measurements and structural mechanisms and fails to discuss possible remedial or adaptive actions.
- It focuses on the UK and ignores the rest of the world.
The latter is the more problematic.

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

Of course, it is necessary to improve measurements (Q48, Q49) and develop structural mechanisms (Q50, Q51), but a CCP Review should discuss at least some remedial or adaptive actions. ([12.10] does mention the publication of 'Future Flooding' but does not even outline its conclusions, so there can be no consultation over the actual proposals.)
It is not even clear that the government has attempted to delineate all the possible impacts of CC, some of which we need to adapt to, while others we cannot adapt to. Though [12.11] does mention a document, 'Impacts of Climate Change: Implications for Defra', it does not say what these implications are, and it does not give implications in other sectors.
- For example: According to a contribution to the government' Exeter Conference in February 2005, it is more than 50% likely that the Atlantic Conveyor (Gulf Stream) will switch off. If this were to happen, UK agriculture would be severely disrupted by much colder climate (5 degree C lower, see below). Even if it were possible in principle to adapt to this by (for example) moving to a colder type of agriculture, this would have enormous problems, including, for example:
  - training all farmers and other growers with the requisite knowledge
  - doing the research fast enough to tailor cold-agriculture skills from other countries to the UK
  - the huge monetary investment in new crops, machinery, machinery manufacturers, agrochemical manufacturers, etc. (since the current ones would lose their markets)
  - and so on.
  In addition, the rest of Europe might also be affected and suffer in the same way, so the U.K. could not look to the E.U. for help.
Gulf Stream Collapse. Via his MP the author asked the Treasury whether they had made any calculations of the impact on the UK economy of the switching off of the Gulf Stream. The answer (in 2004) was "No. We don't believe it will happen." With the results that emerged from the Exeter Conference (that it is 50% likely), he asked again, in the hope that doing so might stimulate such work. The reply from Paul Boateng, just received, dated 23 February 2005, is instructive.
- Re. the 50% probability of switch-off. "Estimates using a simplified model with a business as usual emissions scenario generated a 2 in 3 chance of a THC [Gulf Stream] collapse in the next 200 years. However, the Hadley Centre climate model, a more complex model ... predicts that the Gulf Stream would slowdown by 20% by the middle of the century rather than switch off, even with emissions projections at the highest end of the range."
  - Comment: If, with the fulfilled aspirations of less developed nations, we can expect a net increase, rather than 60% decrease, in CCE, then perhaps the 'business as usual' scenario is more likely than the current emissions projections (which are already proving to be under-estimates: we projected a 20% cut for the UK, but this has been revised to a mere 14% cut).
- "Hadley Centre computer models show that if the THC did switch off, the UK annual temperature would cool by up to 5 dec C within a few decades."
  - Comment: This means severe disruption to British farming.
- "Some recent measurements from research ships in the Arctic seem to indicate that changes are already taking place."
  - Comment: We have little cause for complacency.
- "This wide range of predictions of THC behaviou shows that there is no single robust conclusion, reflecting our lack of understanding of ocean currents and their apparent stability, and the need for further study in this area. ... Defra is funding research at the Hadley Centre ..."
  - Comment: We are glad to hear that research is underway, but there must also be research into the social and economic aspect as well as physical.
One problem is that no list of possible impacts of climate change is available that is widely agreed upon, that covers not just physical and biological aspects but also social and economic, and that is kept under review. How can adaptation be meaningfully discussed without such an agreed list?
- Action: A widely agreed list of CC impacts should be devised without delay, which covers social and economic as well as physical and biological impacts, with detailed study of each. Then it will be possible to have a more meaningful consultation. Also, it would provide something on which to ground discussion of measurements and mechanisms.

S12.2 Global Adaptation

However, perhaps the more serious deficiency in this section is that it focuses on how the UK might adapt and ignores how the rest of the world might adapt.
Example 1: Displaced People
- It is expected that 100 million people are likely to be displaced from low-lying areas of the globe.
- If much of Sub-Saharan Africa becomes completely unlivable for human beings (as we have heard is likely) then another 100 million people will be displaced.
How are we going to adapt to 200 million displaced people? We can see only the following options:
- Ignore them and let them perish
- Give (not lend!) those nations enormous financial help to adapt (e.g. physical and social defences) to CC
- Accept a large number of them as immigrants.
There appears to be no serious discussion of these three options, yet we should be beginning now to lay plans for this tragedy happening. (An alternative, of course, is to take more serious action than this CCP is currently proposing, in order to prevent the above problem!)
Example 2: Global food production. Climate change is likely to disrupt the biological processes of the whole globe. This will mean that the complex ecological interrelationships that are so important for food production and other things might break down. If this happens then there will be global starvation. How are we going to adapt to that?
These are just two examples. Has the government undertaken any study of the possible specific global impacts on a country by country basis, such as could be used to plan actual adaptation related to those countries? Has it attempted to gain an overall reasonable picture of what would happen to such things as global food production, water resources, global economy, etc.? Has it explored seriously how the world could adapt to each such impact?
- Action: Such a study should be undertaken without delay. It involves more than just a study of weather patterns, and requires serious consideration of social, economic, juridical and religious aspects.

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?

See above: an agreed list of possible impacts - not just physical or biological but social, economic and religious - should be drawn up and kept under review.

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

The government opposes stakeholder-led adaptation to enforcement. The basis of such an opposition is questionable, and maintaining it leads to lack of the type of leadership that is required.
The benefits of, and justification for, a stakeholder-led approach are not set out in the CP but are believed to be:
- It can provide greater motivation if stakeholders feel they are in control of their own direction, and thus greater commitment to the direction they choose.
- Likewise, it can engender greater participation among stakeholders.
- It can, if a wide range of stakeholders are allowed to become involved, result in a wider range of views being taken seriously in the debate.
- Likewise, the more stakeholders that are involved in a committed way, the more good ideas can be generated that might not have arisen otherwise.
These benefits can be especially important for actions to adapt to CC, because adaptation will require both creativity in ideas and commitment to act.
However, in considering wider issues than adaptation, a purely stakeholder-led approach can have serious deficiencies, including:
- Stakeholders tend to elucidate and defend their own interests, against the interests of others or of the common good.
- As a result, this can engender an adversarial approach, in which stakeholders end up fighting each other rather than coming to common agreement, with a resultant diminishing of effectiveness of action and of the range of ideas.
- Also, as a result, there is often a tendency for debate and decisions to be led by the most eloquent, or the most persuasive or the most forceful stakeholders.
- Often these are the best-resourced stakeholders who are comfortably established in powerful positions, and are angered by a threat to their privileged position to which they have become accustomed.
  - According to the account of the furious attack on the Fuel Duty Escalator in Parliament on 6 June 1999, mentioned above, it seems that this is what led to a change in the government's mind and the unwise abandonment of the FDE. Well-resourced, privileged road-lobby MPs were able to bring enough pressure to bear to destroy one of the most effective measures to reduce CCE.
- UNDER-REPRESENTED STAKEHOLDERS. Perhaps even more seriously, in a stakeholder-led approach, stakeholders who cannot express their positions cogently have no real influence, and their interests are overlooked. In the case of CCE, this includes:
  - people in the UK who do not share the prevailing world view (world view is what determines what is deemed meaningful or important)
  - people of less developed nations
  - people yet unborn - but who have an enormous stake in what is happening
  - animals
  - the planet itself.
- Finally, a stakeholder-led approach can lead to an abrogation of the government's duty to lead and set the ethical and legal agenda.
Therefore, though a stakeholder-led approach may be useful when considering adaptation, it is not appropriate when considering the whole issue of CCE, including preventative measures and longer-term strategy.
To ensure that the real interests of unrepresented stakeholders are given due weight and consideration, the government must show leadership based on an ethical stance that transcends the stakeholders who happen to be represented in the discussions. It might also even require some enforcement of decisions that are taken, even though the nature of leadership should be non-dictatorial.
Therefore, the government should show moral leadership which is non-dictatorial in its nature. We identified a list of aspects of good leadership in Q8.1.

SECTION 13: ACTION BY THE DEVOLVED ADMINISTRATIONS

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?

OTHER COMMENTS

OC.1 Religion and Theology of Climate Change

It is assumed, in under the world view derived from the European Enlightenment, that religion and politics must have absolutely nothing to do with each other. Both those in the secular and the religious life tacitly agree and keep to this dictum.
But this view is out of step both with the rest of the world and with other cultures at other times. In most cultures throughout the world, religion, politics, economics, family life, and all else are and should be intertwined.
If climate change is a global problem that calls for a global solution, then it will be necessary to acknowledge and engage with its religious aspect. Religious commitment is the strongest motivating factor - for both good and ill - that humanity knows. Religion should be harnessed in the service of tackling CCE - or, to put it the other way round, the 'proper' way round, CCE should be seen as a fundamentally religious matter, not merely a physical, biological, social, economic or political matter.
In the mid 1980s, steered by HRH the Duke of Edinburgh, the Worldwide Fund for Nature recognised this and hosted a conference at Assissi at which five of the world's major religions were invited to set out their attitude to nature. The Duke of Edinburgh was disappointed to find that the Christian presentation was little different from the Jewish one, "God created it; so we are responsible." As a result, he convened two consultations on 'A Christian Attitude to Nature' in the late 1980s (to which this author was invited), and a more distinctively Christian approach emerged, which, unlike the Jewish approach, had a distinct and important place for both the other members of the Trinity, Jesus Christ and the Holy Spirit.
- Specifically, it is the Holy Spirit of God who makes changes to the inner attitude of people, discussed in Q9.3. Galatians 5:22-23 in the Christian Scriptures says (with application to nature added): "The fruit of the Spirit is:
  - love - for nature
  - joy - in nature
  - peace - with nature
  - patience - with the speed at which nature operates
  - kindness - in our dealing with nature
  - goodness - in our attitude towards nature
  - faithfulness - in our covenant with nature
  - gentleness - in what we do to nature
  - self-control - in our demands on nature."
A similar approach could be made with climate change. Obviously, the fruit of the Spirit within us would make a major difference to CCE - and the claim is made in Galatians 5 that there is never any law against these, which implies that they would be generally agreed upon across all or most religions.
But, further than this, it would be useful for the government to follow the WWF's example of 20 years ago and convene a conference of the major religions to discuss their attitude to climate change.

ENDS. Andrew Basden, 2 March 2005.

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

Review of the UK Climate Change Programme

Consultation Response by Andrew Basden

INTRODUCTORY NOTES

ADDITIONAL COMMENT ON TERMS OF REFERENCE

ToR.1 The eventual 60% Target

ToR.2 Aspirations of Less Developed Nations

SECTION 2: INTRODUCTION

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?

Q5.1 On Signals and Example-setting

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?

SECTION 5: EU EMISSIONS TRADING SCHEME

Additional comment:

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

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?

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)?

SECTION 6: ENERGY SUPPLY

S6.1 Additional Preliminary Comment on Energy

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?

SECTION 7: BUSINESS

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.

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?

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

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?

SECTION 8: TRANSPORT

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

SECTION 9 HOUSEHOLDS

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?

SECTION 10: AGRICULTURE, FORESTRY & LAND USE

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?

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

SECTION 11: PUBLIC SECTOR

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?

SECTION 12: CLIMATE CHANGE IMPACTS AND ADAPTATION

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?

Q51.1 Stakeholder-led Adaptation, Enforcement and Leadership

SECTION 13: ACTION BY THE DEVOLVED ADMINISTRATIONS

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?

OTHER COMMENTS

Consultation Response
by Andrew Basden