Response to Draft Climate Change Bill
From Brent Friends of the Earth

Welcome for a bill
We welcome the fact that a climate change bill has at last been published, at least in draft form, by the government.  This is an essential first step in the necessary process of establishing legislation to ensure that emissions of greenhouse gases are reduced sufficiently to limit climate change to below catastrophic levels.
We have comments to make in relation to:

·the level of cuts in greenhouse gases demanded by the draft
·the periodic targets indicated and whether they will be effective enough
·the exemption given to emissions from aviation and shipping
·the priority currently being given to the bill in the legislative process.

Level of cuts
A cut of 60% in greenhouse gas emissions from the United Kingdom and the other richer countries by 2050 is not going to be enough to limit climate change to reasonable levels, unless it is assumed that the poorer countries are not entitled to their fair share of the available emissions.  By “reasonable levels” of climate change we mean limiting the rise in global mean temperatures to 2 degrees Celsius above pre-industrial levels.
The current debates are about:

· whether 80% or 90% cuts in emissions are required to prevent dangerous climate change.
·whether such reductions are needed by 2050 or earlier (e.g. 2030).

Targets- the process for getting there
The use of 5-year reporting periods provides insufficient opportunities for accountable monitoring.
Annual target would be much better because they would lead to more effective feedback on the success or failure of climate change policy and, consequently, more appropriate and useful accountability for the government.  These factors would make it more likely that the objectives of limiting climate change would be achieved.
The so-called “drawbacks” of annual targets can (and should) be overcome.  For example, anomalous annual results due to weather patterns etc are manageable because:

·the reasons for them can be quantified and inevitably will be taken into account in presentation of annual figures for carbon emissions
·in the longer term such annual variations from the overall pattern of carbon emissions are likely to be small compared with the overall level of cuts in emissions required by this process (or inevitable growth in emissions if we don’t act)
·after the first year or two annual progress on cuts in emissions will be reported in the context of the record of such cuts from previous years, and so will be interpreted in this context
·a year of unexpectedly high carbon emissions, whatever the reason for it, will anyway need to be compensated for by bigger cuts in emissions in the following years in order to achieve the objective of this bill or any other plan to limit climate change.

Aviation and shipping
Aviation and shipping must be included in any system of “carbon budgeting” for that system to be credible.  This is because the emissions from aviation and shipping contribute to climate change in exactly the same way as any other emissions.  The global climate system does not distinguish between warming effects caused by different modes of transport and is unable to respect whatever political or other reasons are given for making the distinction.
Current failure to reach international agreements on these sources should not be a reason for inaction in the UK.  Quite the reverse - we should make our commitment and then use that to motivate us to sort out our international relationships accordingly.
With respect to aircraft emissions these are, if anything, more important for inclusion in any system of “carbon budgeting” than the rest because:
·on current trends, the predicted and planned increases in air transport are likely to negate all the savings in carbon emissions made in other sectors
·aircraft emissions, because of the heights at which they occur, have a greater per-unit climate impact than those in other sectors.

Priority given
Climate change is the most important social, political and environmental issue facing us today, over the next decade and beyond.  This been argued by campaigning groups such as Friends of the Earth and acknowledge by the government itself on may occasions.
Lowering its status to “draft legislation” is not helpful in this context and sends the wrong signal.