Northern Ireland Environment Link (NIEL)
20 February 2009
Northern Ireland Environment Link (NIEL) is the networking and forum body for non-statutory organisations concerned with the environment of Northern Ireland. Its 53 Full Members represent over 90,000 individuals, 262 subsidiary groups, have an annual turnover of £70 million and manage over 314,000 acres of land. Members are involved in environmental issues of all types and at all levels from the local community to the global environment.
These comments are agreed by Members, but some members may be providing independent comments as well. If you would like to discuss these comments we would be delighted to do so.
Prof Sue Christie, Director
Northern Ireland Environment Link
89 Loopland Drive
Belfast , BT6 9DW
P: 028 9045 5770
E: Sue@nienvironmentlink.org
W: www.nienvironmentlink.org
Northern Ireland Environment Link is a Company limited by guarantee No NI034988 and a Charity registered with Inland Revenue No XR19598
1. Summary Points
1.1 NIEL believes that written submissions should be considered as initial thoughts which can be added to and developed throughout the inquiry. NIEL requests the opportunity to speak directly with the Committee and would also be happy to facilitate a meeting/seminar involving NIEL members and the Committee.
1.2 The Northern Ireland Assembly should categorically state its support for an international climate change agreement to limit global warming to no more than 2° Celsius above pre-industrial temperatures.
1.3 The UK Act does not set specific, legally binding emissions reduction targets for the devolved administrations. The Executive and Assembly should urgently make commitments to introduce a Northern Ireland Climate Change Act setting a legally binding regional target to reduce our carbon dioxide emissions by 80% from 1990 levels by 2050.
1.4 To ensure we achieve an immediate and sustained decline in Northern Ireland’s greenhouse gas the Executive should set an “intermediate” target for emissions in 2020 (42% below 1990 levels), a series of legally binding 5 year “carbon budgets” and an annual carbon reduction target at an average of at least 3% per annum.
1.5 The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting and monitoring of Northern Ireland specific budgets and action plans.
1.6 The energy (efficiency and renewable) and transport sectors should be targeted for initial emissions reductions.
1.7 All plans, programmes and policies should be assessed to determine their contribution to or impact on achieving carbon budgets.
1.8 Each government department should investigate the opportunities and obstacles to carbon reductions within their competency areas and develop departmental and sectoral action plans to achieve reduction targets.
1.9 The Public Sector procurement budget should be used as a tool to deliver significant emissions reductions.
1.10 Government should invest in emissions reductions and low carbon infrastructure now; the Stern Review concludes this is the economically prudent path to follow.
1.11 The legal responsibility to deliver the targets set in a Northern Ireland Climate Change Act, and through the carbon budgets, should fall collectively on the Executive.
1.12 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.
1.13 The Environment Committee should share responsibility for scrutinising progress towards achieving the targets in the Act and within budgets with all other departments.
2. Introduction
2.1 Northern Ireland Environment Link is a member of the Climate Change Coalition Northern Ireland (CCC NI). NIEL supports the CCC NI submission.
2.2 NIEL welcomes the Environment Committee’s decision to conduct an Inquiry into Climate Change. Climate change is an issue that must be addressed urgently at the local, regional, national and international levels.
2.3 The Committee is right to focus its Inquiry at identifying how Northern Ireland can play its part in tackling climate change. The scientific and economic rationales for addressing human impact on climate change is well established and widely accepted.
2.4 The Intergovernmental Panel on Climate Change (IPCC), a group containing over 2500 scientists, reported in 2007 that ‘warming of the climate is unequivocal’ and that ‘most of the observed increase in temperature is very likely (90%) due to human activity’. The findings of the IPCC are also supported by the Academies of Science of the 11 largest countries in the world, including the Royal Society of London.
2.5 The Stern Review calculated that the dangers of unabated climate change would be equivalent to at least 5% 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% 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% 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.
2.6 The people of Northern Ireland are asking for leadership from the Assembly. A survey conducted in 2008 by Sustainable Northern Ireland for the Northern Ireland Climate Change Impacts Programme revealed that, “92% of respondents were willing to make changes to their lifestyles, especially if encouraged to do so by strong government leadership.” The Committee should provide this leadership.
2.7 There is a great deal of expertise on climate change available in Northern Ireland and many groups are willing to play their part in facilitating moves towards a low carbon economy. The Committee should engage widely and openly.
2.8 The call for submissions allowed interested parties only a short response time. NIEL understands the urgency for action and commend the Committee in its efforts to publish its findings quickly. Therefore, NIEL believes that written submissions should be considered as initial thoughts which can be added to and developed throughout the inquiry.
2.9 NIEL would welcome the opportunity to make an oral presentation to the Committee Inquiry.
3. Submission of Evidence
3.1. 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.
3.1.1 Climate change must be addressed urgently at the local, regional, national and international levels.
3.1.2 The Assembly should ensure that its voice is heard at the national and international level. It should categorically state its support for an international climate change agreement to limit global warming to no more than 2° Celsius above pre-industrial temperatures (most scientists accept that ‘dangerous climate change’ is much more likely above this temperature increase).
3.1.3 To limit global temperature rise to no more than 2ºC the IPCC suggests that atmospheric carbon dioxide levels should be limited to a maximum of 450 parts per million.
3.1.4 As carbon dioxide persists in the atmosphere for many years, the determinant of the severity of climate change is total cumulative emissions by 2050. The Tyndall Centre has estimated that global carbon emissions need to peak by 2015 and then decrease by up to 6.5% each year if atmospheric CO 2 levels are to stabilise at 450ppm.
3.1.5 Industrialised countries have an historical responsibility for causing climate change and as a matter of fairness and justice should bear the leading responsibility for tackling the problem, both by reducing their emissions and by assisting developing countries to adapt to the changes that are already occurring.
3.1.6 Professor James Hansen, Director of NASA’s Goddard Institute, has calculated that the UK has contributed the most greenhouse gas emissions to the atmosphere of any country in the world when historical emissions are totalled.
3.1.7 The Committee on Climate Change recommended, and the UK Government has accepted that a reduction of 80% by 2050 - based on 1990 emissions levels - would be an "appropriate" UK contribution to global aims to cut emissions by 50%.
3.1.8 The Assembly has accepted that the provisions of the UK Climate Act will be extended to Northern Ireland. However, the UK Act does not set specific emission reduction targets for the devolved administrations.
3.1.9 Northern Ireland’s per capita emissions of 12.83 tonnes per annum compares badly with the UK average of 10.48 tonnes, the global average of 4 tonnes and the global fair share of 1.65 tonnes.
3.1.10 The Executive and Assembly should urgently make commitments to introduce a Northern Ireland Climate Change Actwith a legally binding regional target to reduce our carbon dioxide emissions by 80% 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.
3.1.11 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 annum. Combining indicative annual milestones with the legal framework of the budget periods should offer flexibility without compromising longer term targets.
3.1.12 The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting and monitoring of Northern Ireland specific budgets and action plans. The Committee on Climate Change’s reports on progress and action plans should be delivered to the Assembly and responded to by the Executive.
3.1.13 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.
3.1.14 All plans, programmes and policies should be assessed (Climate Impact Assessments) to determine their contribution to or impact on achieving carbon budgets.
3.1.15 Adaptation is intrinsically linked to mitigation, and it is essential that both be addressed as a matter of urgency. The Northern Ireland Assembly should introduce cross-departmental policies and measures which will allow people, infrastructure, biodiversity and natural systems to adapt to changing climatic conditions.
3.1.16 An adaptation strategy to detail how human infrastructure and natural systems will be managed to help them adapt to a range of climate change scenarios should be developed. It is particularly important that climate change impacts are a strong consideration in all decisions relating to nature conservation and archaeological sites. New ways of looking at designated sites (e.g. buffer zones, corridors, low intensity networks and landscape scale actions) will be required for wildlife to adapt to changing climatic conditions. Archaeological sites which may be affected by the impacts of climate change should be assessed and managed accordingly.
3.2. 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)
3.2.1 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.
3.2.2 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 2MtCO 2e (Million tonnes of carbon dioxide equivalent) per year 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 .
3.2.3 The actions outlined above do not go far enough to keep Northern Ireland on target to achieve an 80% 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.
3.2.4 Each government department should investigate the opportunities for and obstacles to carbon reductions within their areas of responsibility.
3.2.5 The Public Sector procurement budget should be used as a tool to deliver significant emissions reductions.
3.2.6 Improved energy efficiency and rapid deployment of renewable energy are mentioned by the Carbon Trust, Stern, WWF, RSPB, etc as key areas to target early in the decarbonisation plans.
3.2.7 Approximately 500,000 homes in Northern Ireland have either no loft insulation or have insulation below the recommended levels of 270mm while some 70,000 homes would benefit from cavity wall insulation. The Assembly should set annual targets to upgrade the existing housing stock to recommended insulation levels: all new homes should be zero carbon by 2016.
3.2.8 A Strategic Energy Framework target of sourcing 15% of all our energy (electricity, transport and heat) from renewable sources by 2020 (this is the target set for the UK in the EU Climate and Energy Package) will act as the driving forces towards a low carbon society.
3.2.9 To achieve the energy target it is estimated over 40% of electricity would have to be produced from renewable sources and renewable sources would also have to provide a significant source (5-10%) of energy for heating purposes. It is estimated that by 2050 micro-generation could supply 30-40% of the UK’s electricity needs. Government will have to provide additional support to renewable technologies to achieve the 15% target. This may include:
- investing in large scale projects, facilitating large projects (NIEL welcomes the recent announcement to undertake a Strategic Environmental Assessment of offshore energy generation in Northern Ireland);
- ensuring that renewables are included in the design requirements for all new public buildings;
- providing funding packages for smaller scale technologies (such as extending the Environment and Renewable Energy Fund);
- requiring energy companies to generate an increased percentage of their energy from renewable sources (by increasing the NIRO; the obligation in the rest of the UK is significantly higher);
- by guaranteeing good long term prices for units of energy generated from renewable sources to encourage greater uptake of microgeneration schemes (provisions to implement a system of feed-in tariffs for small renewable energy producers by 2010 are included in the UK Energy Bill, which was given Royal Assent on 26 November 2008); and/or,
- introduce mandatory micro-generation, including community heating schemes.
3.2.10 Transport was responsible for around 30% of Northern Ireland's CO 2 emissions in 2004, highlighting the need for tailored transport solutions in Northern Ireland. At the moment highway measures have been allocated 80% of the transport spend. Only by increasing the share of the budget for other transport modes (walking, cycling and public transport) will significant strides be taken towards ending this reliance.
3.2.11 Spatial and land-use planners have a key role to play in delivering a low-carbon economy and a resilient environment and society. Planners should only make decisions after they have considered how the development will contribute to mitigation efforts and whether the site and design is appropriate given the predicted impacts of climate change in Northern Ireland.
3.3. To identify the costs associated with meeting these obligations and compare them with the costs that will be incurred if they are not achieved.
3.3.1 The Stern Review calculated that the dangers of unabated climate change would be equivalent to at least 5% 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% 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% 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.
3.3.2 The significant emissions reductions proposed for the UK in the Committee on Climate Change’s first report can be achieved without harming the economy and at a cost less than 1% of GDP in 2020. In other words, an economy that might grow by 30% in the period to 2020 would instead grow by 29%. The Committee on Climate Change advises that this is a price worth paying, given the long-term costs of inaction on climate change.
3.3.3 The All Island Grid Study suggested that 42% of power generation could come from renewable sources in 2020 without a debilitating increase in cost (7%) compared to continuing with our current energy mix. The cost differential will lessen as fossil fuel prices increase.
3.3.4 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.
3.3.5 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.
3.3.6 The Carbon Trust estimates that more than 70,000 jobs could be created in the UK by investing in and developing offshore wind technology.
3.3.7 Government should see investment in a low carbon future as a way to stimulate the local economy (as President Obama has in the USA). 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.
3.3.8 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.
3.3.9 Invest NI’s Maximising Business Opportunities fromSustainable Energy recommends that Northern Ireland should focus its sustainable energy efforts on four technology areas:
- Integrated Building Technologies (as buildings account for around 40% of all energy usage in most countries)
- Offshore Energy (including wind, tidal and wave – GB backing for 7000 offshore wind turbines to generate 33GW of power at an estimated cost of £64 billion. RoI has formally committed 2000 MW of offshore wind turbine generation at a cost of €4 billion over the next 5 years. £36 million spent in the UK on Marine Current Turbine research in the last 5 years [50% of the world total]. £50 million spent on wave power research in the UK [90% of the world total])
- Bioenergy (including anaerobic digestion [AD] and biofuels from waste and sustainable sources. A DARD report estimates Northern Ireland has an AD potential of 292 MW heat + 146 MW electricity; DOE indicated 747,000 tonnes of biodegradable municipal waste was collected in 2004. A Republic of Ireland study indicates the potential for 1590 MW heat + 530 MW electricity in the Republic of Ireland)
- Energy Storage (to help smooth out fluctuations in demand, intermittent supply, and quality of supply. This developing technology is seen as being a significant factor once renewables exceed 10% of the grid supply). The current annual £21 billion global energy storage market is set to grow by 55% to £33 billion by 2012.
3.3.10 NIEL believes that there are strong moral imperatives for Northern Ireland to contribute its fair share of global emissions cuts in order to combat global climate change. Hundreds of millions of people across the globe could lose their lives and livelihoods, up to a third of land-based species may become extinct, immense political instability will occur as people migrate to avoid droughts and floods and compete for scarce resources, and great economic damage will be caused by increasingly extreme weather.
3.3.11 Climate change is one of the biggest threats to development: it could undo decades of progress in fighting poverty and compromise the achievement of the Millennium Development Goals (MDGs) which aim to reduce poverty and promote sustainable development by 2015.
3.3.12 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.
3.3.13 Northern Ireland ’s Chief Medical Officer Michael McBride has said, “Current predictions on climate change suggest greater long-term impacts on health than any current public health priority. To preserve health in a changing climate, we need to modify and strengthen the systems we have to adapt to the likely future impacts of global warming. We must tackle this issue on all fronts, reducing our contribution to the problem and responding to the effects of climate change is a shared international responsibility.”
3.4. 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)
3.4.1 NIEL believes that long term plans, supported by a strong legislative framework, are the best way to promote efficiency and innovation in policy and technology design and thus the best mechanism to minimise costs.
3.4.2 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.
3.4.3 All plans, programmes and policies should be assessed using Climate Impact Assessments to determine their contribution to or impact on achieving carbon budgets. The process should be akin to equality screening and should be initiated at the start of policy design to maximise outcomes and minimise costs.
3.5. To make recommendations for appropriate targets/actions that could be included in the new Northern Ireland Sustainable Development Implementation Plan.
3.5.1 The key climate targets that the SD Strategy should deliver are those identified in a Northern Ireland Climate Act, carbon budgets and annual targets.
3.5.2 The SD Strategy should also help deliver the recommendations on how to achieve emissions reductions put forward by the Committee on Climate Change.
3.5.3 The SD Strategy could play an important role in helping to inform and empower individuals to take action to tackle climate change.
3.6. 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.
3.6.1 The Executive and Assembly should urgently make commitments to introduce a Northern Ireland Climate Change Actwith a legally binding regional target to reduce our carbon dioxide emissions by 80% 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.
3.6.2 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 annum.
3.6.3 The legal responsibility to deliver the targets set in a Northern Ireland Climate Change Act, and through the carbon budgets, should fall collectively on the Executive.
3.6.4 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. Departments should prepare action plans on how they intend to deliver their reduction targets.
3.6.5 Sharing responsibility to meet targets across the Executive and departments is the only way to ensure that all parts of government play their part in delivering the targets.
3.6.6 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.
3.7. 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 Bill.
3.7.1 NIEL believes that the secondary legislation in the UK Bill should not be the basis of Northern Ireland’s climate change regulation. Instead, Northern Ireland should introduce its own primary legislation.
3.7.2 The Executive and Assembly should urgently make commitments to introduce a Northern Ireland Climate Change Act with a legally binding regional target to reduce our carbon dioxide emissions by 80% from 1990 levels by 2050.
3.7.3 The introduction of primary legislation in Northern Ireland will enable secondary legislation to be introduced to set 5-year carbon budgets and annual carbon targets (3% annual emissions reductions is a minimum) for the region.
3.7.4 Secondary legislation under a Northern Ireland Act should be used to impose public sector duties to deliver targets and to set sectoral targets for emissions reductions.
3.7.5 The role of the Committee on Climate Change should also be set and amended via secondary legislation.
3.7.6 The UK Act enables targets to be reviewed and amended but the 2020 and 2050 targets should only be amended based on the best available scientific advice.
3.8. To express views on if and how the Assembly might conduct more effective scrutiny of climate change responsibilities across all relevant departments.
3.8.1 The Environment Committee should scrutinise progress towards achieving the targets in the Act and within budgets. The Minister should be asked to explain progress and outline plans to achieve the targets to the Committee
3.8.2 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.
3.9. To produce a report on the findings and recommendations of the inquiry by September 2009.
3.9.1 The longer Northern Ireland delays significant and decisive action on climate change, the larger the task will become. Stern has concluded that early action makes economic sense. The greatest opportunities for job creation and market share in emerging technologies will also be delivered by responding early to the challenges we know we face. Therefore, the Committee should use its influence to encourage action now. Waiting until September to recommend that Northern Ireland should act on climate change, is only delaying the inevitable.
3.9.2 New multinational climate agreements being developed by the United Nations (the post Kyoto climate agreement should be finalised in Copenhagen in December 2009) and the European Union (the Energy and Climate Package was endorsed by the European Parliament in December 2008) will require the United Kingdom and ultimately Northern Ireland to significantly reduce emissions. Attempts to delay action on climate change will only make achieving the new responsibilities more difficult and costly.