Northern Ireland Assembly Flax Flower Logo

Environment Committee

Inquiry into Climate Change

World Wide Fund for Nature (WWF) Northern Ireland response to the Terms of Reference of the
Environment Committee Inquiry into Climate Change

27th February 2009

(a) 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

WWF Northern Ireland believes that Northern Ireland needs to set mandatory targets to reduce energy demand in absolute terms, reduce the overall contribution of fossil fuels, increase the contribution of renewables and reduce Carbon Dioxide (CO 2) emissions by 80% from 1990 levels by 2050 and to plan appropriately, with targets, for the investment necessary to meet those energy targets set. The above key principles overlap and so a long term integrated approach needs to be taken, preferably via a long term energy strategy.

WWF Northern Ireland is therefore delighted that the Environment Committee has previously expressed support for Northern Ireland targets, for example in the Committee’s response dated 7 th September 2008 to the UK Climate Change Bill.

WWF Northern Ireland is further encouraged by previous comments in January 2008, in relation to the North South study on renewable energy and the grid, made by the former Minister for Enterprise Trade and Investment, Nigel Dodds who said that Northern Ireland,

“can make a significant contribution to the UK’s climate change goals by enhancing the amount of electricity generated from local renewable sources”

and that,

“it is clear that we must be more ambitious in setting future renewable energy targets.”

WWF Northern Ireland also supports the comments made by the current Minister for Enterprise Trade and Investment Arlene Foster at the launch of the pre scoping consultation on the Strategic Energy Framework in November 2008 that there is a need for Northern Ireland to plan,

“for a sustainable energy future that will also deliver on EU climate change targets and increase security of energy supplies for domestic and business use”

and that,

"The objective for us all is to achieve a successful, sustainable, long-term future for energy in Northern Ireland, through innovative and ambitious actions, involving a shared vision with industry and partners throughout the rest of the United Kingdom and the Republic of Ireland."

The targets set in Northern Ireland should at the very least match, but preferably surpass, the relevant UK targets in order to ensure it (Northern Ireland) plays a fair and proportionate role as part of the UK in meeting climate change targets, for example those targets in the Climate Change Act of 2008 and the UK targets in the EU Energy package of 2008, as endorsed for example, by the Minister for Enterprise Trade and Investment.

Tackling climate change and meeting Northern Ireland specific targets will, as things stand at present, require cross departmental co-operation, since many of the issues referred to above including energy, transport and agricultural policy are not the responsibility of the Department of Environment. As such there is a need for much greater levels of interdepartmental co-operation on climate change and energy issues. However, one possible option which WWF Northern Ireland supports is the establishment of an integrated sustainable energy agency for Northern Ireland, as a means of assisting the integration and better delivery of renewable energy policy and tackling many of the problems caused by the lack of a central department with responsibility for renewable energy. This was supported by recommendation number 38 in the ETI Committee’s “Report on the Energy Inquiry” published in March 2002 which said

“The Committee recommends the consideration of the establishment of a Renewable Energy agency.”

This agency could operate on a similar basis to the existing agencies in Denmark, the Netherlands and Australia which have shown marked success in promoting the development of renewable energy in their respective countries. The agency, or body, should be responsible for inputs to policy and implementation. It should also have the political power to generate a public profile. The most appropriate option is for this body to be modelled closely or exactly along the lines of the Department of Climate Change and Energy (DECC) in Great Britain for facilitate greater UK wide cooperation.

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

As stated above, some of the wide range of actions necessary to tackle climate change are beyond the remit of the Department of Environment and Environment Committee and the and as such the administrative/governance structures may need to be reviewed and amended if all these issues are to be tackled in more integrated fashion.

Overall, there is a clear need for Northern Ireland to move to a low carbon economy and WWF Northern Ireland believes ultimately, to a zero carbon economy. This needs to be the ultimate goal. Achieving such a transition will require urgent action in many sectors. The question of how various sectors including energy, transport, the domestic and public sector could contribute to tackling climate change in Northern Ireland was explored in the Carbon Trust Vision Study (CTVS) of 2005. The CTVS looked at how Northern Ireland could reduce its CO 2 emissions by 60% by 2050 and estimated the cost of this at £775 million. Though both the level of CO 2 reductions and the price of achieving them outlined in the CTVS are likely to now be out of date, with even greater reductions needed and an associated likely increase in cost, the fundamentals of the CTVS should still apply. In the absence of any long term strategic energy strategy in Northern Ireland the CTVS could provide a very useful foundation for a long term strategy. More detail on some of the main actions needed in relation to some of the sectors mentioned and on some of the main findings of the CTVS is given below.

It is worth noting that the Committee on Climate Change’s first report, released in December 2008, also 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) in 2020. Specifically,

Though the timescales are different many of these figures are very close to the conclusions in the CTVS

Basically there is a need to decarbonise, ultimately totally, the energy system. One of the key factors is the nature of the system for supplying/transmitting energy as the centralized grid is highly inefficient with two thirds of the energy generated wasted before it even reaches the consumer. There is then even further wastage at this point (of approximately 13%) resulting in a total cumulative loss of approximately 78%.

While WWF Northern Ireland recognises that the existing grid system will remain the primary vehicle for transmission and distribution of energy for much of Northern Ireland’s energy needs for the foreseeable

future and that further investment for amongst other things, reinforcement of the grid will be necessary, this shocking and avoidable waste of energy can be significantly reduced by greater use of distributed or decentralised energy. WWF Northern Ireland supports greater development of decentralised or distributed generation, which already provides over 50% of electricity supplies in Denmark and over 40% in the Netherlands and see decentralised energy as a key component of a lower carbon future for Northern Ireland.

Decentralised energy is also conducive to greater deployment of renewable heat e.g. through Combined Heat and Power (CHP) plants, which operate at very high efficiencies of approximately 80%, because they also use the heat generated in the course of the electricity production process. Kilroot by contrast operates at around 30% efficiency, or less. Greater use of CHP can significantly reduce the amount of energy consumed and CO 2 emissions – being, on average, twice as efficient as other plants, a CHP plant will, on average, produce approximately half the CO 2 emissions of a conventional power plant. Though no new power plants are need, as Northern Ireland currently exports electricity any future power stations built should be CHP where possible.

Anaerobic Digestion (AD) offers a means of generating energy, in the form of natural gas, from animal and vegetable waste. According to AFBI in Hillsborough, the 9.7 tonnes of manure generated annually by housed livestock has the potential to produce 73MW electricity (10% of Northern Ireland demand) and 60 MW heat. Greater development of both CHP and AD in a more decentralised system would make a significant contribution to reducing our energy demands.

In the meantime, on the basis that the existing grid system will remain the primary vehicle for transmission and distribution of energy for much of Northern Ireland’s energy needs for the foreseeable future, WWF Northern Ireland would like to see mandatory priority access to the grid for renewables ahead of fossil fuel power plants.

The UK Government has acknowledged (1) that the nature of the current grid does pose challenges for renewable energy and CHP industries. The 2002 House of Commons Trade and Industry Committee (TIC) Security of Supply report says,

“The Government agrees with the TIC’s view that the current design of the electricity distribution networks present a number of challenges to the connection of renewable and other small generation .”

Over 27% of the UK’s CO 2 emissions come from the residential sector. This needs to be reduced and the Government’s National Energy Efficiency Action Plan (NEEAP) has a target to reduce emissions from the domestic housing stock by 31% by 2020. However, WWF’s “How Low Can You Go?” report concluded that the UK can reduce CO 2 emissions in the domestic housing sector by 80% by 2050 and this is the level of cutback we need to see achieved. The energy demand of houses also needs to be reduced, in line with Government targets for zero carbon housing

E missions from road transport represented 29.4% of Northern Ireland’s CO 2 emissions in 2006, an increase of 49.5% since 1990, and second only to energy production (35%) (2). By comparison transport emissions in England increased by only 10% since 1990 so it seems clear that Northern Ireland has a disproportionate problem in relation to transport which needs to be tackled.

The use of alternative fuel sources, electricity in particular, for vehicles could help reduce these emissions, especially if the electricity were generated from a renewable source, such as wind power, thereby offering a completely green cycle for the fuel. WWF’s book “Plugged In: The End of the Oil Age” focuses on solutions to our reliance on oil for transportation needs, in particular the electrification of transport. As electric vehicles make use of up to 75% of electricity taken from the grid, they are up to 4 times more efficient than conventional mechanical vehicles where only 18-23% of the energy contained in the fuel is converted into motion.

The Presidency Conclusions of the Brussels European Council in June 2008 (3) supported the greater use of electric cars – see paragraph 39 which said

“Other measures should be rapidly examined, in particular to promote competition in energy markets, promote modernisation of transport systems including the development of alternative technologies, inter alia electric cars”

Some European countries have already set targets for either the number or percentage of electric cars - Spain (1 million by 2014), Japan (50% by 2020) and the Republic of Ireland (10% by 2020). Gordon Brown has outlined his intention to have all new cars sold in Britain to be electric or hybrid vehicles producing less than 100 g/km of CO 2 by 2020. In light of this push for more electric vehicles and the huge potential that exists in Northern Ireland for wind power, Northern Ireland really needs to grasp the opportunity offered by the electrification of the transport network as a matter of urgency and the development of an appropriate recharging network will be fundamental to any such expansion.

Hydrogen is another alternative fuel. Though hydrogen powered vehicles that use fuel cells have a lower efficiency (of approximately 40%) they emit only water. Hydrogen buses have been running in Chicago since the mid 1990s.

The Department of Finance and Personnel has a very important role, particularly in relation to the strategic investment plans for Northern Ireland’s transport system which are exacerbating rather than ameliorating the existing problems. T he draft Investment Strategy says (page 12) that there will be £195.3 million spent on public transport 2008-11 and £611.8 million spent on roads 2008-11. According to the indicative budgets for the period 2011/12-2017/18 a total of £3,095 million will be spent on roads and £725 million on public transport. WWF Northern Ireland views this balance, whereby approximately three quarters of all of money is allocated for road building and approximately one third allocated for public transport as, at best, inappropriate as it compounds an existing problem, namely the inadequate provision of alternatives to car use, and is likely to make the achievement of Northern Ireland’s target to reduce GHG emissions by 25% by 2025 much more difficult to achieve.

There is a sharp contrast with the plans announced by the Danish government in December 2008 of a "green traffic initiative" featuring infrastructure investments and transport measures costing DKr150bn (E20bn) over the next decade. According to the Danish plan, about two-thirds of the total will be spent on "renovating, improving and developing the railway network" with the aim of converting motorists to public transport. High emissions charges, road pricing, and financial incentives for fuel-efficiency are among a raft of additional measures. Similar strategic thinking and investment in greater public transport would be welcome in Northern Ireland.

Northern Ireland also has tremendous potential for the production of bioenergy, which could be used in the generation of electricity, a heating fuel and/or a transport fuel as discussed in greater detail below in the section on agriculture

In the course of 2008 both DARD and the ARD committee have explored how the agricultural sector and renewable energy may develop in the near future – DARD through the review of their Renewable Energy Action Plan (REAP) and the ARD Committee through their Inquiry into Renewables and Alternative Land Use. WWF Northern Ireland recommends that greater interdepartmental and inter committee collaboration is needed to tackle the issue of energy

The Northern Ireland Rural Development Programme does offer potential funding opportunities that can help contribute to the greater development of renewable energy in Northern Ireland thereby also contributing to the aims and objectives of other departments. A key underpinning rationale for the 2007-2013 Rural Development Programme is addressing climate change and WWF Northern Ireland is pleased that the Commission has guided Member States to include measures that will contribute to this objective under all axes of their programmes and not simply be considered as an Axis II priority.

In the Community Strategic Guidelines for Rural Development for the 2007-2013 Programming Period, Member States are encouraged to focus support on ‘development of new outlets for agricultural and forestry products, which includes “support for investment and training in the field of non-food production …by …helping the development of renewable energy materials, biofuels and processing capacity”, under Axis I, ‘Improving the competitiveness of the agricultural and forestry sectors’. Also, by “developing the provision and innovative use of renewable energy sources”, under Axis III, ‘Improving the quality of life in rural areas and encouraging diversification’. In addition to the more obvious ‘combating climate change’ element of Axis II these offer the potential for the NIRDP to make a significant contribution to Climate Change objectives. There is a need now that the programme is in place, for DARD to ensure that these measures are readily available to farmers, rural businesses and communities and positively incentivised with clear monitoring target associated to their delivery.

The potential role for AD has already been referred to. On top of that, biofuel production offers the rural and agricultural community another potential alternative means of contributing to future climate change, energy and emission reduction targets. Land use strategies also have an important role to play through the preservation of existing carbon stores or sinks, primarily peatlands but also forests, as well as developing new carbon sinks through planting native trees and woodlands.

While WWF Northern Ireland recognises the potential for renewable bioenergy sources to be grown in Northern Ireland it believes the broader impact of their production must be considered and acceptable levels of social and environmental performance in the production of bioenergy among supply chain actors, from growers to end users should all be factored in. For example, there is a risk, especially on a small island, that a biofuel processing plant would create a market demand that cannot be met locally. This would put pressure for biofuel to be imported. This risks creating a demand for importing biofuels that may not have been produced sustainably and this could have significant, long term detrimental consequences for people and nature, as exemplified by the biofuels produced from the palm oil plantations that have been planted on former rainforest in Indonesia. The changes in land use for biofuel production in the US and subsequent changes in wheat prices demonstrates how global changes in policy and demand can affect commodity prices.

In WWF’s view, the following environmental principles need to be addressed by any standard as a minimum both for crops produced in Northern Ireland and as a requirement for imported fuel sources

Ireland has the greatest potential in Europe for growing biomass, which through the use of CHP offers the possibility of a much more efficient renewables based energy system.

There is clear role for government, not least in relation to meeting the target in the NI SDS for the government estate to be carbon neutral by 2015. In order to meet this target WWF Northern Ireland believes each government department should investigate the opportunities and obstacles to carbon reductions within their competency areas. The Public Sector procurement budget should be targeted as a tool to deliver significant emissions reductions.

(c) To identify the costs associated with meeting these obligations and compare then with the costs that will be incurred if they are not achieved

There are two distinct but related parts to this section. The first deals with the predicted costs of inaction and/or delay in tackling climate change while the second part deals with the predicted benefits of tackling climate change by moving to a low/zero carbon future by reducing energy consumption and investing in low carbon/renewable energy sources.

It is important to state that not only will tackling climate change be less expensive now than in the future, but costs of the impacts of climate change are also like to increase significantly the longer the delay in tackling climate change, as highlighted by the Stern Review of the Economics of Climate Change (2006) which said tackling climate change could cost 1% GDP each year but,

“if we don’t act it the overall costs and risks of climate change will be equivalent to losing at least 5% of global GDP each year now and forever. If a wider range of risks and impacts is taken into account, the estimates of damage could rise to 20% of GDP or more.”

This makes a very clear and persuasive argument in economic terms alone that climate change must be tackled urgently and the sooner the better. The increasing costs associated with a delay in addressing the issue were highlighted in an article in the Guardian on 26th June 2008 by Lord Stern in which he claimed that the costs of tackling climate change have already doubled since his 2006 report and estimated that £28bn may be need to tackle climate change. It is clear then that climate change must be tackled urgently.

It appears likely that there will be additional costs from climate change across a range of sectors including, but not limited to public health, biodiversity and loss of ecosystem goods and services, increased cost of extreme weather, including flooding and other associated insurance losses and impacts on agricultural production.

The European heatwave of 2003 was responsible for 35,000 extra deaths across Europe as a result of heat stress, bad air quality, and high levels of air pollutants such as ozone. A report commissioned by the Health and Environment Alliance (HEAL), Climate Action Network Europe (CAN-E) and WWF claims that health savings of up to €25 billion could be achieved every year in Europe if the EU raised its 2020 target for domestic greenhouse gas emissions from 20 to 30%, based on economic evaluations of loss of life and health, working days lots and hospital costs: they show reductions in hospital admissions of 8,000 per year and 2 million fewer work days lost per year by raising the target to 30%. (4) A European Commission impact assessment estimated that currently every year 369,000 people die prematurely in Europe due to air pollution and that premature deaths, health care and medication associated with air pollution amount to 3-9% of EU GDP (4). According to Northern Ireland’s Chief Medical Officer Michael McBride,

“Current predictions on climate change suggest greater long-term impacts on health than any current public health priority” (5)

The projected shift in precipitation patterns and distribution predicted for Ireland is likely to have a number of impacts. According to Sweeny et al (6) large parts of the south east of Ireland and Wicklow, Dublin, Louth and Down could receive less than half their current summer rainfall. On this basis the summer flow of the Boyne is predicted to drop by as much as 20% by the 2020s and up to 40% by the end of the century. The decrease in summer rainfall predicted may no longer suit the growing of potatoes, and as a result the report predicts,

“It is likely that potatoes will no longer be a commercially viable crop over much of Ireland”.

Evidence for a change in potato growing was provided by Hickey 2008 (7) who stated that in 2001, perhaps 15% of Ireland’s potato crop was being irrigated. Agriculture may change in other ways and increased warming as well as increased storminess could have a negative impact on the Orchard County’s most famous agricultural product, as apples need a certain amount of cold to complete their development.

There is also a risk of more extreme weather resulting in higher numbers of larges insurance claims and/or losses. In 2004 Swiss Re predicted that economic costs of global warming could reach $150 billion a year in ten years though in 2005 weather-related insurance losses around the world totalled $200 billion.

Projections from the Association of British Insurers suggest that by 2050 the annual cost of weather claims will double to €3.3 billion while an extreme year might cost €20 billion.

According to the WWF report “Stormy Europe” the UK is likely to see the most drastic increase in storm activity if CO 2 emissions rise unabated. 3 out of 4 models show the number of severe storms would likely increase by up to 25% by the end of the century - an increase of up to nearly 10 more storms over the 30 year period 2071-2100. This provides grounds for concern because winter storms are the cause of nearly 70% of all insured losses in Europe, costing an average of over €2 billion in financial losses a year (8)

Given that the two principal strands of tackling climate change will be reducing our energy demand in absolute terms and decreasing the amount of energy used and generated from fossil fuels while increasing the amount of energy used and generated from renewable sources, there are likely to be very significant economic advantages from this move to a low/zero carbon future - it will be a win-win situation.

A HSBC evaluation (9) of the various economic stimuli packages from around the world highlighted the benefits of tackling climate change and noted that amongst the arguments for a low carbon stimulus,

“The low-carbon economy can also be a job rich economy at a time of soaring unemployment, particularly through enhancing building efficiency, either via retrofit or new construction, and improving mass transit.”

The New Economics Foundation have advocated the need for a green new deal (10) to deal with what they referred to as the ‘triple crunch’ of a credit fuelled financial crisis, accelerating climate change and soaring energy prices underpinned by an encroaching peak in oil production. Similarly, an evaluation of the case for a ‘green’ stimulus co-authored by Nicholas Stern concluded (11),

“this is the right time to be spending on measures to promote energy efficiency and low-carbon technologies”

This report evaluated and ranked 23 specific proposals in terms of economic benefit and climate benefit and energy efficiency measures were consistently the top performers across all sectors. Though the benefits were not taken into account in the formal scoring the authors acknowledged that energy efficiency measures,

“also enhance energy security and help the less well off with their fuel bills”

Research in California (12) found that well documented household energy savings of $56 billion 1972-2006 energy efficiency measures have enabled California households to redirect their expenditure toward other household goods and services creating about 1.5 million FTE jobs with a payroll of $45 billion. Similarly, the potential economic and environmental benefits of reducing demand, was outlined by the Performance and Innovation Unit (13) who said,

“The current, apparently cost effective, potential for energy efficiency is approximately 30% of final energy demand. The potential financial benefits in reduced costs to customers (net of taxes) are £12 billion annually. And the potential carbon reductions are 40 Mtc/year…”

The importance of energy efficiency was clearly highlighted by DETI who said that (14),

“Reducing overall energy demand offers the potential for the most social, environmental and economic gains”

and that

“The Northern Ireland Authority for Utility Regulation (NIAUR) also recommends energy efficiency as the best opportunity to reduce emissions and energy bills in the near to medium term”

The target to reduce Northern Ireland’s energy consumption by 1% annually between 2007 and 2012, was outlined in DETI’s 2004 Strategic Energy Framework (SEF). However, a review of the sustainable energy market done by Arthur D Little Limited of electricity consumption in Northern Ireland between 1992 and 2007 in conjunction with NIE historic data shows the standard growth in electricity consumption to be 1.8% per annum between 1992 and 2007. The discrepancy between the target of 1% annual reduction in consumption and the reported 1.8% annual growth in consumption (1992-2007) is disappointing and needs to be turned around as a matter of urgency if this already weak and unambitious target is to be met. Given the target in the 2008-2011 Programme for Government (PfG) to reduce our carbon footprint by at least 25% by 2025, the level of reduction in energy consumption needs to be much higher than the 2004 SEF target, if this target is to be met. WWF Northern Ireland believes that in line with the emerging science, Northern Ireland should aim to reduce its CO 2 emissions by at least 40% by 2020 and at least 80% by 2050.

Overall, the energy supply system needs to be decarbonised as much as possible and ultimately completely - WWF has previously advocated EU energy supplies should and can be completely decarbonised by 2050. The 2008 report “80% Challenge – delivering a low carbon UK” (copy attached for reference) commissioned by WWF UK, ippr and RSPB, concluded that it is feasible to reduce the UK’s emissions by 80% by 2050, without new nuclear build, including emissions from aviation and shipping and at costs that are not prohibitive, estimated to be between 2% and 3% of projected GDP in 2050, though energy efficiency could markedly reduce these costs to approximately 1.5% to 2% of GDP. This study used the MARKAL-MACRO model used by the Government for the 2007 Energy White Paper and a model developed by Professor Dennis Anderson at Imperial College, employed by the Stern Review on the economics of climate change and

The very significant benefits in terms of job creation potential from greater investment in renewables should make this a priority area for investment in Northern Ireland. According to the terms of the EU Energy package announced in January 2008, one of the UK’s legally binding targets is to achieve a 15% share of renewables in the final energy demand by 2020. A series of interim targets were also agreed by the EU on the following basis: member states must achieve a 25% of their 2005-2020 renewables increase by 2012, 35% by 2014, 45% by 2016, and 65% by 2018. Together these targets would make up an "indicative trajectory" that each member states would be expected to follow. Northern Ireland at present generates approximately only 1.8% of its energy from renewables (a total of 0.74 TWh). WWF Northern Ireland believes that Northern Ireland should at least match the UK level target of generating 15% of energy from renewables by 2015. On that basis and the basis that energy consumption does not increase beyond the current level of 40.7 TWh, in order to meet this EU target Northern Ireland energy production from renewables will need to increase by approximately by 731% by 2015 to approximately 6.16 TWh (15% of 40.7 TWh). This is a very significant increase and will require significant investment. Even if only a relatively small percentage of this investment is inward investment in Northern Ireland based industries there is enormous potential for both job creation and economic development as a result.

There have been many studies which show the economic benefits of investing in renewables, only some of which are referred to here, and the enormous potential that exists across the island for wind power is well known. According to the European Wind Energy Association, wind energy direct employment has increased from 48,363 in 2002 to 108,600 in 2007. In terms of direct jobs alone, on an average of 33 new people have been employed every day, seven days a week in the wind energy sector during that time period. .(15) Including indirect employment the wind energy sector employs more than 150,000 in the EU.

A study by European Foundation for the Improvement of Living and Working Conditions found that the adoption of best available energy conservation technologies could create 500,000 extra jobs in the EU. (16)

A 2008 report by WWF France concluded that a 30% reduction in CO 2 emissions by 2020 would create around 684,000 new net jobs in France. (17)

Even on a regional the scale the economic opportunities are significant. The Yorkshire Regional Economic Strategy 2006-2015 found that meeting the regions targets to reduce GHGs by at least 30% by 2020 and 80% by 2050 and have 22% renewable electricity by 2010 could generate 13,000 new jobs.

The benefits of developing a low carbon/renewables based economy are well illustrated by the example of the Austrian town of Güssing which has been transformed by the initiative of the townspeople themselves, led by the Mayor, from one of the poorest towns in Austria, to one of the wealthiest, based upon the development of a 100% renewable supply of energy for the town, which has reduced its CO 2 emissions by 95% since 1991 and is now exporting renewable energy to the grid shows how a transformation from a fossil fuel based energy system to a renewables based system can also generate significant economic benefits.

The potential for job creation from investing in renewable energy technologies was also highlighted by the Northern Ireland Manufacturing (NIM) group who have called on the Executive to accept the

challenges and opportunities presented by climate change. NIM have said climate change (18),

“creates significant value creation opportunities for proactive companies and puts significant value at risk for companies that fail to adapt”

and that,

“There is huge potential for Northern Ireland industry as a whole to be proactive, to establish itself at the cutting edge of these new technologies, bringing major opportunities and new markets.”

Similarly the CBI have stated argued that delivering an investment framework to decarbonise the UK’s energy supply should be one of the UK Government’s priorities for 2009 (19) and that,

“We must not allow the global economic crisis become an excuse for inaction on climate change” (20)

According to the CBI, (21) evidence suggests that over time dangerous climate change,

“would inflict damage to the UK economy of over £75 billion annually”.

Denmark has shown how an economy can thrive while developing clean energy and cutting carbon emissions. Between 1980 and 2004, the country's GDP rose 56% while CO 2 emissions dropped 35%. (22)

(d) To identify a formal cost effective mechanism for assessing the potential impact of new policies on climate change/CO2 emissions (akin to regulatory impact assessments/rural proofing)

WWF Northern Ireland is unclear what the Committee means as regards identifying a mechanism for assessing the potential impact of new policies on climate change/CO 2 emissions. Given that CO 2 emissions all across the UK are monitored, collated and published every year, at present by AEA Technology PLC on behalf of England, Scotland, Wales and Northern Ireland, there may be no need for any additional mechanism to assess the potential impact of new policies on CO 2 emissions as any reduction or increase in CO 2 emissions will be measured annually as a matter of course.

Similarly while climate change is a global phenomenon, there has been some work done on assessing the impact of climate change in Northern Ireland for example by SNIFFER (23) and MONARCH (24). However, WWF Northern Ireland does believe that improving the level and frequency of environmental monitoring would be useful and should help provide better evaluation of any new policies. On the basis that the State of the Environment report will be an annual publication it should help provide some evaluation of how Northern Ireland’s environment is being affected by and is responding to climate change. As such there may be no need for any additional mechanism to assess the potential impact of new policies.

In relation to policies, WWF Northern Ireland 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 and calls upon the Committee to support WWF’s call for a long term energy strategy.

(e) To make recommendations for appropriate targets/actions that could be included in the new NI Sustainable Development Implementation plan

As regards appropriate targets for Northern Ireland, WWF Northern Ireland believes that given the huge potential that exists in Northern Ireland for renewable energy Northern Ireland should, as a minimum, commit to matching the standards and/or targets that apply to the UK as a whole. This means for example, that Northern Ireland should also adopt the targets set in the UK Climate Change Act of 2008 to reduce GHG emissions by at least 26% by 2020 and 80% by 2050, with annual reductions of at least 3%. In 2008 the UK Climate Change Committee recommended cuts of 34% below 1990 levels by 2020 without a global deal on emissions reductions, and 42% with a global deal. WWF Northern Ireland believes that Northern Ireland should set a target of a 42% reduction, to be delivered through domestic action. Similarly WWF Northern Ireland believes that Northern Ireland should at least match the target, to generate 15% of its energy from renewables, set for the UK as part of the EU Energy Package in 2008, which is likely to be one of the most important factors in the immediate future and in the medium term.

Unfortunately though, this far the Northern Ireland Executive has lacked ambition. The 2008 Programme for Government (PfG) for example, was not more ambitious than any of the existing strategies and only restated existing targets. For example, though welcome the target to reduce Northern Ireland’s carbon footprint by 25% by 2025, was a pre-existing target from the Northern Ireland Sustainable Development Strategy (NI SDS). WWF Northern Ireland is disappointed that the 2008-2011 PfG did not raise existing targets in the NI SDS. Given that the interim target in the UK Climate Change Bill is to reduce greenhouse gas emissions by at least 26% by 2020 against a 1990 baseline, a target to reduce Northern Ireland’s carbon footprint by 25% by 2025 again compares poorly with the UK target, in terms of both the level of reduction and the time by which this has to be achieved, again reflective of a lack of ambition in Northern Ireland. WWF Northern Ireland recommends that in line with the emerging science, that Northern Ireland aims to reduce its CO 2 emissions by at least 40% by 2020 and at least 80% by 2050, with annual reduction sof at least 3%. Meeting the target previously outlined in the NI SDS for 40% of electricity consumed to be generated from indigenous renewable sources by 2025 is likely to prove challenging but is achievable, as demonstrated by the findings of the 2008 All Island Grid Study which found that up to 42% of power generation could be from renewable sources, a figure WWF Northern Ireland regards as more appropriate, minimum level for future targets.

However WWF Northern Ireland would encourage Northern Ireland to set even higher targets in relation to electricity as both the Welsh and Scottish administrations have done. For reference, the Welsh Assembly Government’s (WAG’s) Renewable Energy Route Map targets include generating 100% of Wales’ electricity demand from renewable sources by 2025, that demand should not exceed the electricity consumption level of 2007, that all new buildings should be zero carbon by 2011 and supporting the development of distributed generation and energy supply companies.

It is important to point out that a recent analysis by Poyry “Closing the Energy Gap”, (electronic copy of summary attached), commissioned in 2008 jointly by WWF-UK and Greenpeace, which looked at the implications for the UK electricity sector of meeting the UK’s share of the EU renewable energy target found that if the UK government meets its own energy efficiency and renewable targets, new baseload electricity generation capacity will not be needed until the period beyond 2020. By this time (2020) other low carbon technologies will be close to commercialisation. In addition, in the scenarios developed, the combination of renewable energy generation and energy efficiency results in up to 42% reduction in gas use, so reducing UK dependency on gas imports and strengthening energy security and carbon dioxide (CO 2) emissions are reduced by up to 37% (from 1990 levels) by 2020, beyond the target in the Climate Change Bill for that time.

This analysis shows that in contrast to the views of government and industry, there is no need to build new fossil-fuelled power generation to keep the lights on in the UK. Instead, the focus should be on delivering existing targets and commitments for energy efficiency and renewable energy. Knowing that no investment in fossil fuel power stations in the UK will be necessary before 2020 is a hugely significant message. This very significant finding applies to the UK as a whole but in light of the fact that since 2005 Northern Ireland has been an exporter of electricity, WWF Northern Ireland believes there is no need for any new fossil fuelled power station to be built in Northern Ireland before 2020.

(f) 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 NI will meet its climate change obligations.

It is likely to be very difficult for the DoE Climate Change Unit to ensure that Northern Ireland will meet its climate change obligations because as things currently stand many climate change and energy policy related policy responsibilities lie with and consequently can only be delivered by other Government departments. For example building regulations are the responsibility of DfP, housing policy is the responsibility of DSD, transport policy is the responsibility of DRD, while bioenergy development is primarily the responsibility of DARD. As such while DoE can and most likely will continue to have a scrutiny role as regards meeting any climate change commitments Northern Ireland might have, the very nature of the departmental structure makes it unlikely that DoE can ensure that other Government departments will meet their responsibilities and/or obligations under any future climate change targets.

As such, i t may be advantageous for Northern Ireland to adopt a model of governance that is closer to, if not exactly like, that of the Department of Energy and Climate Change or DECC in England and Wales. This should ensure greater cohesion and facilitate better integration across the UK.

(g) To consider what secondary legislation raising powers within the UK Climate Change Act would contribute to NI’s commitments to the UK Climate change Act.

WWF Northern Ireland believes that establishing mandatory targets to reduce energy demand in absolute terms, reduce the overall contribution of fossil fuels, increase the contribution of renewables and reduce Carbon Dioxide (CO 2) emissions, by 80% from 1990 levels by 2050 would be best achieved by introducing primary legislation, though some of the specific issues referred to in this submission, for example mandatory priority access to the grid for renewables ahead of fossil fuel power plants, may be best dealt with by other mechanisms including secondary legislation. WWF Northern Ireland is not best placed to advise on the legislative path that must be followed for each of these options.

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

The potential change to the departmental structure previously outlined, along the lines of a Northern Ireland DECC, may make the scrutiny of the Northern Ireland’s climate change responsibilities easier as collating and scrutinising information from one department is likely to be much easier than trying to collate and scrutinise information held by a number of different departments.

In the meantime, as is the case with so much of Northern Ireland policy and legislation, there is a key role for the Executive, and in relation to climate change policy specifically for the chair of the Environment committee. WWF Northern Ireland believes greater liaison and collaboration between the chair of the Environment committee and the chairs of other relevant committees including the Enterprise Trade and Investment committee, the Agriculture and Rural Development committee, Regional Development committee and Finance and Personnel committee, mirrored by similar liaison and collaboration between the same departments, should ensure better and more effective scrutiny of climate change responsibilities across all relevant departments. Such co-operation should also facilitate achieving the targets in the Act and within budget with all other departments.

Committee on Climate Change report to the Executive and the Assembly and that the Executive respond to their reports in the Assembly.

(i) To produce a report on the findings and recommendations of the inquiry by September 2009

In WWF Northern Ireland’s view this inquiry will provide a welcome contribution to the debate. WWF Northern Ireland would be happy to help the committee in any way possible in the course of this inquiry and the production of this report and would be interested to learn more about how the Committee anticipate this report will be used, and what role it will play, once published.

M Campbell, Policy Officer, WWF Northern Ireland February 2009
References

(1) Third Special Report of Session 2001-02 of the House of Commons Trade and Industry Committee (TIC) “Security of Supply: Government Reply to the Second Report of Session 2001-02 from the Trade and Industry Committee” (May 2002)
(2) AEA’s Greenhouse Gas Inventories for England Scotland Wales and Northern Ireland 1990-2006
(3) Presidency Conclusions of the Brussels European Council 19/20 June 2008
(4) Holland, M. “The co-benefits to health of a strong EU climate change policy” October 2008 HEAL, CAN-E WWF
(5) Department of Health press release http://www.northernireland.gov.uk/news/news-dhssps/news-dhssps-april-2008/news-dhssps-070408-protecting-health-from.htm
(6) Sweeny, K., Fealy R., McElwain L., Siggins L., and Sweeny J. (2008) Changing shades of green : “Changing shades of green: The Environmental and Cultural impacts of Climate change in Ireland” Irish American Climate Project Berkeley USA
(7) Kieran Hickey “Five Minutes to Midnight? Ireland and Climate Change ” White Row Press 2008
(8) Munich Re 2000: Climate Risk Management Ltd., 2005
(9) HSBC A Climate for Recovery Climate Change Global February 2009
(10) New Economics Foundation A Green New Deal July 2008
(11) A. Bowen, S. Frankhauser, N. Stern and D Zenghelis An outline of the case for a ‘green’ stimulus Policy Brief February 2009, London School of Economics
(12) Roland-Holst, D. (2008) Energy efficiency, innovation, and job creation in California Center for Energy, Resources and Economic Sustainability, University of California, Berkley
(13) Performance and Innovation Unit, Energy Review, 2002, (page 182)
(14) DETI “Delivering Northern Ireland’s 1% Energy Efficiency Target An Overview”
(15) EWEA Wind at work: wind energy and job creation in the EU 2009
(16) Ecotec (1994) The Potential for Employment Opportunities from Pursuing Sustainable Development, report to the European Foundation for the Improvement of Living and Working Conditions, Birmingham/Brussels: Ecotec.
(17) WWF France “-30% CO2 = + 684,000 emplois pour la France, l’equation gagnante pour la France” or “- 30% CO2 = + 684,000 jobs, France’s wining formula”. At the time of writing only the French version of this report was available via the WWF France website see http://www.wwf.fr/s_informer/nos_missions/changement_climatique but an English version is expected
(18) NI Manufacturing Group Manufacturing Counts available at http://www.nimanufacturing.org/
(19) CBI Climate change tracker 2008 available at http://climatechange.cbi.org.uk/reports/00081/
(20) CBI Director-General Richard Lambert speaking at CBI’s Climate Change Summit in London 2 December 2008, see - http://climatechange.cbi.org.uk/press_release/00091/
(21) CBI Opportunity knocks:business expectations for a global climate change agreement in 2009 Brief 2008 - http://climatechange.cbi.org.uk/reports/00099/
(22) TIME magazine Feb 05 2009 see http://www.time.com/time/health/article/0,8599,1876647,00.html
(23) SNIFFER Preparing for a changing climate in Northern Ireland 2007
(24) C.A. Walmsley, R.J. Smithers, P.M. Berry, M. Harley, M.J. Stevenson, R Catchpole MONARCH A synthesis for biodiversity conservation 2007