Friends of the Earth Northern Ireland
Inquiry Submission

1. Introduction

1.1 Friends of the Earth would like to thank the Environment Committee for holding this inquiry into climate change and for inviting us to make a submission. We are heartened by the fact the Committee has accepted the reality of climate change and the inquiry does not include an exploration of the science or a call for a public debate. The debate is settled and further debating the issue merely postpones action when action is urgently needed.

1.2 Friends of the Earth believes the single most important action the Committee can take is to press the Executive to bring forward a Northern Ireland Climate Change Bill. While the Assembly has opted into the UK Climate Change Act, the targets in the Act are not disaggregated for the devolved administrations and the Committee on Climate Change has no authority to enforce the targets. For Northern Ireland to play its part fully in reducing greenhouse gas emissions, therefore, legally binding targets should be adopted in order to provide a clear for businesses, individuals and future Assemblies.

2. The terms of reference

To identify initial commitments for Northern Ireland that will ensure it plays a fair and proportionate role as part of the UK in meeting climate change targets.

2.1 The global fair share of per capita carbon emissions has been calculated at about 1.65 tonnes per year. Northern Ireland’s per capita emissions are about 13 tonnes per year, compared to a UK average of just under 10.5 tonnes. Plainly Northern Ireland is not currently playing a fair and proportionate role, either globally or as part of the UK.

2.2 There is scientific consensus that in order to prevent catastrophic climate change temperature rise must be limited to no more than 2 oC above pre-industrial levels which corresponds to greenhouse gas concentrations of about 450 part per million by volume of CO 2 equivalent (ppmve). Current concentrations are around 430 ppmve.

2.3 Furthermore, research from the Tyndall Centre for Climate Change Research suggests that if current emission trends continue a global average temperature rise of around 4 oC is likely with a 6 oC rise being a distinct possibility. In the distant past temperature rises of this magnitude were associated with mass extinctions. Needless to say it is unlikely civilization as we know could continue under such circumstances.

2.4 The Committee on Climate Change recommended, and the UK Government accepted, a reduction of 80 per cent on 1990 emissions levels by 2050.

2.5 In order for Northern Ireland to do its fair share in meeting the targets set out in the Climate Change Act the Executive should introduce a Northern Ireland specific Climate Change Bill. Such a Bill should follow the precedent set in the UK Act and include a legally binding target to reduce our carbon dioxide emissions by 80 per cent from 1990 levels by 2050. This is the minimum requirement that will be necessary to play our part in the global attempt to avoid dangerous climate change.

2.6 To ensure we achieve an immediate and sustained decline in Northern Ireland’s greenhouse gas emissions the Executive should set an intermediate target for emissions in 2020, a series of legally binding 5 year carbon budgets and an annual carbon reduction target at an average of at least 3 per cent per year. Combining indicative annual milestones with the legal framework of the budget periods should offer flexibility but with a firm steer.

2.7 The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting of Northern Ireland specific budgets and action plans. The Committee on Climate Change’s reports on progress and action plans to achieve the targets should be delivered to the Assembly and responded to by the Executive.

2.8 The Committee on Climate Change should help ensure co-ordination of emissions reduction efforts across the UK. Carbon emissions in Northern Ireland and the Republic of Ireland are closely interlinked. Therefore, provisions to enable joint achievement of emissions reduction goals should be made.

2.9 All plans, programmes and policies should be subject to full Climate Impact Assessments before implementation. If they do not contribute to carbon reduce policies they should be redesigned.

2.10 A supplement to Planning Policy Statement 1for England and Wales was published in 2007 which sets out the principles that the Government should observe in formulating planning policies, making development plans and exercising its development powers in order to tackle climate change. A Northern Ireland planning Policy Statement on climate change would put tackling climate change at the heart of Assembly policy and provide a clear steer to both planners and energy companies.

To consider the necessary actions and a route map for each significant sector in Northern Ireland (energy, transport, agriculture and land use, business, domestic, public sector etc).

2.11 The Committee on Climate Change’s statutory duty to Northern Ireland includes:

‘To provide advice on the sectors of the economy in which there are particular opportunities for contributions to be made towards meeting the budgets through reductions in emissions.’

2.12 The Committee on Climate Change’s first report was released in December 2008. It includes an analysis of what opportunities exist for making emission reductions in Northern Ireland. It states Northern Ireland could contribute emissions reductions of over 2MtCO²e (Million tonnes of carbon dioxide equivalent) in 2020:
Emissions from buildings and industry could be reduced by up to 1 MTCO 2 in 2020 by using energy more efficiently;
More efficient vehicles and new transport fuels could deliver reductions of up to 1 MTCO 2 in 2020;
Emissions from agriculture, land use and forestry and waste management sectors could be reduced by up to 0.5 MtCO 2e in 2020.

2.13 The actions outlined above do not go far enough to keep Northern Ireland on target to achieve its own 80 per cent emissions reduction target. The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting of Northern Ireland specific budgets and action plans.

2.14 Energy : The current electricity generation system wastes about ⅔ of the energy produced, either as waste heat or through transmission losses. A decentralised grid using small-scale generators close to the end user minimises transmission losses and also enables the waste heat to be utilised. Such a decentralised grid should be based around small-scale Combined Heat and Power.

2.15 Micro-renewables, such as solar thermal, heat pumps and biomass burners, should constitute a significant element of a decentralised network. The high upfront costs of installing micro-renewables mean uptake is likely to be small. To facilitate the adoption of micro-renewables the Reconnect grants should be re-instated.

2.16 Northern Ireland has some of the best renewable energy resources in Europe and they are currently under-utilised. On-shore wind is well developed, though there is room for further development, but off-shore wind remains undeveloped and marine technologies are still in the test stage. A sustainable energy infrastructure should include a range of renewable technologies sited to maximise exploitation of the resource. By using a range of renewables, intermittency problems can be eliminated.

2.17 It is likely that a greater proportion of our energy needs will be met by electricity as fossil fuel use for space and water heating decreases. It is important, therefore, that the inefficiency inherent in a large-scale centralised system are minimised and greater use is made of decentralised grids. There is also potential for using off-peak renewables for generating electric heat for storage, or for recharging electric vehicles. The use of off-peak electricity should therefore be encouraged and the Department of Enterprise, Trade and Investment’s target of reducing electricity use by 1 per cent annually until 2012 could be problematic unless it is targeted at fossil fuel derived electricity.

2.18 A sustainable energy infrastructure will require significant new development in decentralised grid and renewable technologies and effective use of the planning system will be required to facilitate the necessary level of development. A Planning Policy Statement on climate change would create the necessary policy context and place action on climate change at the heart of planning policy.

2.19 It is regrettable that the proposal to amend Building Regulations to include mandatory renewables for new build developments was dropped by the Department of Finance and Personnel. Such amendments would provide clear guidance to the building sector and facilitate the development of renewable energy technologies.

2.20 The Energy Act, which became law in November 2008, includes a provision to introduce a feed-in tariff (FIT) for renewable electricity and renewable heat incentives. These, if implemented correctly, will give a long-term guaranteed payment to homes, businesses and communities for installing renewable electricity and heat technologies. Such a provision should be extended to Northern Ireland. A similar system operates in parts of Europe the and, more importantly, in Republic of Ireland. If the Single Electricity Market is to function there must be compatible incentive systems north and south of the border.

2.21 It is likely that a European supergrid will be developed to facilitate greater use of renewables and to enable sharing of renewable energy resources. For example, a supergrid could include German photovoltaics, Icelandic geothermal and Spanish concentrated solar. Enhanced electricity interconnection would enable Northern Ireland to tap into, and contribute to, a European supergrid.

2.22 Transport: investment in public transport is essential if cuts in transport emissions are to be realised. Other measures to encourage a modal shift from the private care include walking and cycling. The balance of transport is currently about 80 per cent roads and 20 per cent for other measures. Such a balance is likely to lead to higher transport emissions rather than achieving cuts.

2.23 Emissions from transport are closely linked to land-use planning. How our villages, towns and cities are planned will dictate what method of transport will be most convenient, and most used. A PPS on climate change would put climate considerations at the heart of the planning system.

2.24 Electric vehicles offer the potential for reducing carbon emissions associated with transport, but only if electricity generation is de-carbonised. Assuming there will be a significant increase in the use of renewables, greater efficiency in electricity generation and a conversion to gas for large power-stations still using fossil fuels then electric vehicles will be a viable low-carbon option.

2.25 Agriculture : modern food production is very resource and energy intensive. The single most significant source of emissions is the production of chemicals such as fertilisers and pesticides. Organic and other low input farming methods have significantly lower carbon emissions associated with them. They also tend to be more labour intensive than conventional agriculture so there are also job creation opportunities with low input farming.

2.26 A focus upon the localisation of food and farming implies the development of local food economies. Local food economies emphasise the importance of shorter, less centralised food chains, and subsequently lower emissions, involving much closer and greater contact between farmers and the consumers, processors, retailers and caterers that they serve. They deliver an integrated suite of benefits and are unique as agents of sustainable development by occupying a point of convergence between four main issues – economic development and regeneration; environment and climate change; social cohesion and community development; and health.

2.27 Meat and dairy production has a particularly large environmental footprint. Intensive farming methods in Europe, which rely on high-protein animal feeds, have created a global food chain in which Northern Ireland poultry, pigs and cattle depend on feed crops from the other side of the world. The livestock sector is responsible for an estimated 18 per cent of global greenhouse gas emissions and deforestation is a significant source. Reducing the impact of the livestock sector is critical if we are to prevent dangerous climate change. Friends of the Earth is not advocating a vegetarian diet, but a reduction in meat consumption must be part of any coherent plan to tackle climate change.

2.28 It should be possible to satisfy the twin demands of agricultural waste management and greenhouse gas reductions through the use of anaerobic digestion (AD) of biodegradable waste linked to small-scale combined heat and power (CHP). Such a combination can vary in size from very small on-farm units to larger units suitable for food processing plants.

2.29 Business : According to the Carbon Trust report Climate Change – a business revolution report, implementing measures which are compatible with the need to tackle climate change has the potential to increase a company value by up to 80 per cent. Conversely, failure to position itself for a low-carbon future could devalue a company by 65 per cent. Saving can be made in energy efficiency in much the same way as for the domestic sector. In addition, industry should be encouraged to invest in modern, efficient motors.

2.30 The shift to a low-carbon economy is likely to create the environment in which low-carbon businesses succeed at the expense of inflexible, high-carbon industries. The biggest winner is likely to be the building insulation industry.

2.31 There is much scope for the development of businesses designing, constructing and fitting green technologies. Harland and Wolff may have missed the initial phase of wind power development but are now assembling turbines and are developing wave power devices. The Assembly should actively encourage the development of green businesses.

2.32 Micro-renewables offer businesses the opportunity to cut energy bills and, if Feed-in Tariffs are extended to Northern Ireland, to make additional money by supply excess electricity to the grid. The Energy Act, which became law in November 2008, includes a provision to introduce a feed-in tariff (FIT) for renewable electricity and renewable heat incentives. Such a provision should be extended to Northern Ireland. A similar system operates in parts of Europe and, more importantly, in the Republic of Ireland. If the Single Electricity Market is to function there must be compatible incentive systems north and south of the border.

2.33 Domestic : Energy efficiency is the single most cost effective way of reducing domestic carbon emissions. There is great potential to bring Northern Ireland’s housing stock up to very high standards of energy efficiency through insulation, use of efficient appliances and simple lifestyle changes. The average SAP rating in Northern Ireland’s housing stock is 50 points out of a possible 100. The technology and techniques already exist which would enable significant efficiency gains to be made. The Carbon Trust Northern Ireland Vision Study (2005) concluded it is possible to achieve 60 per cent reduction in emissions from households by 2050 with energy efficiency being key component. High upfront costs can discourage home-owners from fitting insulation materials though. A wholly or partially funded programme of improving energy efficiency should be introduced. Such a programme would save people money, create good quality skilled and semi-skilled jobs and help to stimulate the market in energy efficiency measures.

2.34 Micro-renewables, such as solar thermal, heat pumps and biomass burners, should constitute a significant element of a decentralised network. As with energy efficiency, the high upfront costs of installing micro-renewables mean uptake is likely to be small. To facilitate the adoption of micro-renewables the Reconnect grants should be re-instated.

2.35 Householders and landlords should be encouraged to install key-pad electricity meters. One in four already use the NIE keypad meter, supplied free by the utility, for prepayment purposes. But the meter also allows consumption to be monitored. Households with keypads use 5 per cent less electricity on average than those without.

2.36 It is regrettable that the proposal to amend Building Regulations to include mandatory renewables for new build developments was dropped. Such amendments would provide clear guidance to the building sector and facilitate the development of renewable energy technologies. Although this is not an area the Environment Committee has responsibility for, it should recommend the proposed amendments be adopted.

2.37 Public sector : the Assembly could be showing leadership and stimulating the market by improving the energy performance of the public sector. The civil service estate has a target to be carbon neutral by 2015. This target should be met through tangible carbon reduction measures such as insulation, micro-renewables and behaviour changes rather than through offsetting schemes. In addition, the target should be extended to the entire public sector.

2.38 Public sector buildings are often large traffic generators. The Stormont estate, for example, has thousands of visitors each day and most come by car. Public transport provision to the estate is infrequent and free car-parking makes driving an attractive option. The Assembly should encourage public servants to use sustainable means of transport such as public transport, walking and cycling. Remove free car-parking spaces along with enhanced public transport would facilitate such a shift.

To identify the costs associated with meeting these obligations and compare them with the costs that will be incurred if they are not achieved.

2.39 The Stern Review calculated that the dangers of unabated climate change would be equivalent to at least 5 per cent of GDP each year. However, when more recent scientific evidence is included in the models, the Review estimates that the dangers could be equivalent to 20 per cent of GDP or more. In contrast, the costs of action to reduce greenhouse gas emissions to avoid the worst impacts of climate change can be limited to around 1 per cent of global GDP each year. The central message is that reducing emissions today will make us better off in the future: one model predicts benefits of up to $2.5 trillion each year if the world shifts to a low carbon path.

2.40 The renewable sector in Germany supports 170,000 people and existing German government support measures promoting renewable energy could create 130,000 new jobs by 2020 according to the German environment ministry.

2.41 The Prime Minister stated that the overall added value of the low carbon energy sector by 2050 could be as high as $3 trillion per year worldwide and that it could employ more than 25 million people.

2.42 The Carbon Trust estimates that more than 70,000 jobs could be created in the UK by investing in and developing offshore wind technology. Action Renewables estimate that almost 6,000 short term and 400 long term jobs could be sustained in Northern Ireland, exclusively by developing renewable energy within the region.

2.43 Government should see investment in a low carbon future as a way to stimulate the local economy, as recommended in the New Economics Foundation’s Green New Deal report. President Obama has already established a plan to kick start the economy which includes significant investment in green technologies. The move to renewable fuels may help develop industries that will provide economic opportunities and jobs. Given the huge potential that exists around our shores for wind power there are sound economic and environmental reasons for ensuring that a significant proportion of these jobs are developed in Northern Ireland.

2.44 The SNIFFER report on the impacts of climate change on Northern Ireland identified a number of direct effects, mostly negative, on human health, the economy, natural habitats and water resources, for example, the extent of flood risk to existing settlements remains unquantified compared with the situation in Great Britain.

To identify a formal cost effective mechanism for assessing the potential impact of new policies on climate change / CO 2 emissions. (Akin to Regulatory Impact Assessments/Rural Proofing).

2.45 All plans, programmes and policies should be subject to strict Climate Change Impact Assessments to determine their contribution to or impact on achieving carbon budgets. The process should be initiated at the start of policy design to maximise outcomes and minimise costs and would be similar to equality screening.

2.46 The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting of Northern Ireland specific budgets and action plans: sharing this resource with the rest of the UK should help minimise costs.

To make recommendations for appropriate targets/actions that could be included in the new Northern Ireland Sustainable Development Implementation Plan.

2.47 The key climate targets that the Sustainable Development Strategy should deliver are those identified in a future Northern Ireland Climate Bill.

2.48 The Sustainable Development Strategy should also help deliver the recommendations from the Committee on Climate Change.

To make recommendations on a public service agreement for the DOE Climate Change Unit’s commitments in the second Programme for Government that will ensure Northern Ireland will meet its climate change obligations.

2.49 A public service agreement should be drafted for the Department of the Environment which would include a commitment to provide information and support to the other departments to help deliver the targets set in a Northern Ireland Climate Change Act and in the carbon budgets.

2.50 Specific responsibilities to deliver the targets set in the Climate Act and in the carbon budgets should be identified in public service agreements for each Northern Ireland department.

2.51 To consider what secondary legislation raising powers within the UK Climate Change Act would contribute to Northern Ireland’s commitment to the UK Climate Change Act.

2.52 The Northern Ireland Assembly should introduce its own primary legislation in the form of a Climate Change Bill with binding carbon dioxide gas reduction target of at 80 per cent on 1990 levels by 2050; 5 year carbon budgets and an annual carbon reduction target at an average of at least 3 per cent per year.

To express views on if and how the Assembly might conduct more effective scrutiny of climate change responsibilities across all relevant departments.

2.53 The Assembly should consider c oncentrating climate change related responsibilities in one department in a similar way to how the UK Government created the Department for Energy and Climate Change.

2.54 The Environment Committee should share responsibility to scrutinise progress towards achieving the targets in the Act and within budgets with all other departments.

2.55 The ability of the Committees and the Assembly as a whole to scrutinise progress will be greatly enhanced by ensuring the Committee on Climate Change report to the Executive and the Assembly and that the Executive respond to their reports in the Assembly.