Department for Environment, Food and Rural Affairs

Consultation on the draft Climate Change Bill

Response proforma

Name	Keith Bradshaw
Organisation / company *	Churches Together in Cumbria Social Responsibility Forum - Energy Sub Group
Job title *	Coordinator
Department *
Address	39, Wasdale Park Seascale Cumbria CA20 1PB
Email *	keithabradshaw@tiscali.co.uk
Telephone *	019467 28724
Fax *
Website *	www.churchestogethercumbria.co.uk

Organisation Type	Please mark/give details as appropriate
Non Governmental Organisation (NGO)
Public sector (e.g. local / central government, hospitals, universities) (please give details)
Retail sector (e.g. supermarkets) (please give details)
Service sector (e.g. cinemas, hotel chains, banks) (please give details)
Energy supply industry
Heavy industry / manufacturing
Property management
Trader / verifier
Academic / research
Individual
Other (please give details)		Faith Community with representatives of all the main Christian denominations in Cumbria

NB: on the form below, please leave the response box blank for any questions that you do not wish to answer. Any other comments can be recorded in the box at the end of this form. All boxes may be expanded as required.

Targets and Budgets

Setting statutory targets

1. Is the Government right to set unilaterally a long-term legal target for reducing CO₂ emissions through domestic and international action by 60% by 2050 and a further interim legal target for 2020 of 26-32%?

Setting legal targets that may not be attainable is liable to bring the whole process into contempt. It would be more sensible to get an informed estimate of what could reasonably be achieved, and at what cost (in the broadest possible sense) and then consider what sacrifices the electorate might be induced to make.

We believe these targets could be unrealistically high and failure to achieve them would only open the government to ridicule. It should be borne in mind that the regime of the day will bear no relationship either in personnel or even in kind to that which set the targets in the first place - hence unless successive governments periodically review and redefine targets, the whole process become ridiculous.

2. Is the Government right to keep under review the question of moving to a broader system of greenhouse gas targets and budgets, and to maintain the focus at this stage on CO₂?

Yes, the public has come to recognise CO2 as the main contributor, and the one they can do most to reduce. To divert attention to other, more potent gases,but which have a smaller overall effect, would be counter-productive at this time. The other gases are probably more relevant to emissions by industry and agriculture.

Carbon budgeting

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

Some kind of periodic review would be sensible, bearing in mind my comments on question 1, see also question 5.

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

No view

Reviewing targets and budgets

5. Do you agree there should be a power to review targets through secondary legislation, to ensure there is sufficient flexibility in the system?

If there must be targets, yes.

6. Are there any factors in addition to, or instead of, those already set out that should enable a review of targets and budgets?

Changes to/improvements in technology might make emissions reduction easier, or failure of or shortfalls in some measures might make it harder to achieve reductions:eg wind power is very likely to fall far short of expectation, and we have just heard that the use of bio-fuels in transport may not fulfil its original promise.

Any developments, positive or negative, should be able to be taken into account in a running programme and flexible target setting.

Counting overseas credits towards the budgets and targets

7. Do you agree that, in line with the analysis in the Stern Review and with the operation of the Kyoto Protocol and EU ETS, effort purchased by the UK from other countries should be eligible in contributing towards UK emissions reductions, within the limits set under international law?

No, since it fudges the issue.

Banking

8. Do you agree it should be permissible to carry over any surplus in the budget? Are there any specific circumstances where you consider this provision should be withdrawn?

To the extent that it anticipates ongoing responsibilities, it should be encouraged; and the possibility of withdrawing the provision would be a disincentive to virtue.

Borrowing

9. Do you agree that limited borrowing between budget periods should be allowed?

It is probably inevitable to some extent, but should be subject to penalty.

Compliance with carbon budgets and targets

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

There cannot be a legal duty to do the impossible; penalties for failure should be made clear.

The Committee on Climate Change

The need for an independent analytical organisation

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

Not another quango!

Functions of the Committee on Climate Change

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

Yes

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

Factors for the Committee on Climate Change to consider

14. Are these the right factors for the Committee on Climate Change to take into account in assessing the emissions reduction pathway? Do you consider there are further factors that the Committee should take into account?

An additional factor is the technical feasibility.of measurs proposed.

In general we agree that these are the right factors for the Committtee to take into account. But like any other policy, it is its impact on the most vulnerable that must be given the highest priority. It is therefore important to consider the effect on fuel poverty both in this country and abroad.

The consequences of climate change are predicted to be greatest for those who are least able to deal with them, flooding and prolonged drought will cause even greater suffering amongst the already afflicted communities in the less developed world. There have been predictions that millions of environmental refugees wll be forced to try to enter Europe as conditions worsen. This is a further reason why our policies should favour the most vulnerable.

Membership and composition

15. Do you agree the Committee on Climate Change should be comprised of technical experts rather than representatives of stakeholder groups?

Both should be included.

16. Are these the appropriate areas of expertise which should be considered? Do you consider there are further areas that should be considered or any areas that are less important?

These are appropriate areas of expertise.

There is one additional area which we feel is important.

Since climate change and its man-made causes are a moral and ethical issue, there should be Committee members with expertise in the field of social responsibility, based on ethical and religious backgrounds and commitment.

Churches are well placed to provide such input. They have been involved in ethical and theological reflection on environmental and ecological matters for many years, and indeed have contributed greatly to the increased public awareness of these issues.

Enabling powers

Extending the suite of domestic trading schemes

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

No view

Benefits and structure of enabling powers

18. Do you consider that these powers are sufficient to introduce effective new policies via secondary legislation? If not, what changes would you make?

No view

Reporting

The need for regular, independent monitoring of the UK’s progress

19. Do you agree that the Committee on Climate Change should be responsible for an independent annual report on the UK’s progress towards its targets which would incorporate reporting on a completed budget period every five years?

Yes

Adaptation

20. Is statutory reporting the best way to drive forward progress on adaptation while at the same time ensuring Government is able to develop flexible and appropriate measures reflecting developments in key policy areas?

Other responses or comments

(Please use the following space for any other responses or comments)

The Social Responsibility Forum of Churches Together in Cumbria comprises a broad range of views on energy matters. One of the topics which we have been particularly concerned with is that of the role of nuclear power in the energy mix.

The Energy Sub-group has not reached a consensus on the desirability of further development of civil nuclear power, but a majority is in favour of it.

These members believe that:

1 Nuclear power should be routinely included in any consideration of low-carbon power sources, and its substantial contribution to emissions reduction in electricity production should be recognised.

Both those in favour of and against nuclear power are in overall agreement on a number of fundamental energy and climate change -related questions.

· Energy conservation and wise stewardship of the planet’s resources should be paramount. There is no justification for the profligate use of energy just because the means exist to produce it. The extension of nuclear power, or for that matter, any source of generation or energy production, should not be an excuse for wasting energy and for encouraging lifestyles which threaten environmental, economic and social sustainability;

· Energy conservation is the responsibility not just of individuals but of local and national government. The government needs to match rhetoric to action. For example, the government could match its rhetoric on domestic energy conservation by insisting upon the standards of new house build that are at least as good as the best in Europe and Scandinavia.

· The majority of the world’s population that will suffer most from the consequences of man-made global warming was not been responsible for it in the first place. It is the obligation therefore of the richer world, including the UK, to adopt and encourage energy-saving and appropriate carbon-reduction technologies to minimise future greenhouse gas production;

· We strongly support urgent research into techniques of carbon capture and sequestration, into energy efficiency measures and technical and social developments in methods to reduce emissions from transport;

· The recommendations of the Stern Report need to be carefully reviewed and legislation enacted which moves forward rapidly on energy conservation, transport and car use reduction alongside other fiscal and taxation measures;