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Response to the government's consultation on the draft climate change bill.

Response sent jointly with the Centre for Policy Studies


Targets and Budgets

Setting statutory targets

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

The government's policy is misguided in view of the lack of direct evidence of a climate driven primarily by atmospheric carbon dioxide level. In light of this, whether or not policy should be set unilaterally becomes immaterial.


We would support policies which:

a) encourage energy efficiency

b) assure energy security and affordability

c) facilitate the development of new technologies and broaden and diversify the UK's power generation base

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

The government is right to keep all policies under review in light of accumulating scientific evidence, climate records and policies instituted by other states. Since we believe the focus on carbon to be misguided in any case, the review should take account of a much wider range of options.

Carbon budgeting

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

No. Not only is this a policy designed to address an unproven problem, but central planning is certain to result in complexity, rigidity and inefficiency.

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

The concept of setting provisional standards on this basis is sound. The target in this case is not.

Reviewing targets and budgets

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

Yes. Flexibility should be retained as far as possible. If a policy with which we disagree is introduced, it is essential that the scope exists to change or abandon it as appropriate.

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

a) Evidence which contradicts the anthropogenic CO2 hypothesis.

b) Evidence which supports alternative hypotheses (for example, the influence of solar cycles and influence of cosmic ray-induced cloud formation via variations in the sun's magnetic field).

Counting overseas credits towards the budgets and targets

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

In principle, yes. We would rather see a proportion of the budget spent on projects which can clearly be shown to benefit the populations of developing countries than on those which impact negatively on the UK. However, there must be an effective and transparent mechanism to ensure that the UK does not simply fund activities which would have taken place in any case, or which are of no benefit to the receiving country.


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

Yes. Any and all remaining degrees of flexibility should be retained.


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

Yes. As for question 8.

Compliance with carbon budgets and targets

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

Given our view of the scientific uncertainties, we see no reason why the Government should be under a legal obligation to comply with a flawed policy. In practice, we see no advantage to statutory obligations in any case, unless Government has full control of the means to achieve them.

The Committee on Climate Change

The need for an independent analytical organisation

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

Independent oversight is always to be welcomed.

Functions of the Committee on Climate Change

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


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

Yes, but its remit must be set broadly so that it does not merely consider the extent to which targets are being met, but also the vailidity of and need for the targets.

Factors for the Committee on Climate Change to consider

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

This is an appropriate list of factors for the committee to take into account. However, it is currently predicated on the understanding that the presently-accepted view of climate science is valid and that carbon emission reductions will continue for many decades. We believe strongly that the committee must have a remit which includes the right to challenge the direction of policy based on the factors it considers.

Membership and composition

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

We agree that committee appointments should be made on the basis of expertise rather than representativeness. It is particularly important that the members do not have links with campaigning or lobbying groups and have not themselves engaged in such activities. Nevertheless, past or current employment should not in itself disqualify candidates.

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

The areas of expertise are appropriate, but we do not think it is sufficient merely to have one "climate scientist". Climate is governed by a range of influences, and is important to have on the committee members whose individual expertise covers the full range.

Enabling powers

Extending the suite of domestic trading schemes

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

Given the potentially large economic and social effects that new trading schemes may have, we think it is undesirable for the Government to have such enabling powers.

Benefits and structure of enabling powers

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

See answer to question 17.


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

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

Yes. However, the scope of the report should be broadened sufficiently to allow the committee to report on changes in the factors on which the initial policy was based, and to make recommendations regarding policy changes.


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

It is essential that a comprehensive adapatation plan is developed and progress towards its implementation monitored. Whatever may or may not happen to climate in coming decades, sea levels are rising, building on flood plains continues, regional water shortages occur during unforecastable periods of drought, and some coastal communities are threatened by rapid erosion. Adapting to these and other threats must be a high priority for any government.

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