SC(3) CR-R9
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Residential Carbon Reduction
Response from National Park Authorities collaborating as Welsh Association of National Park Authorities (WANPA)
Dear Mr Bates,
Re: Carbon Reduction Inquiry
The three National Park Authorities (NPAs) in Wales - collaborating as the Welsh Association of National Park Authorities (WANPA) - are grateful for this opportunity to comment on Carbon Reduction in Wales - residential carbon reduction.
Background
WANPA is the corporate body of the three National Park Authorities in Wales and exists in response to the political and policy divergence bought about by the 1999 devolution settlement.
The National Parks have two statutory purposes in the 1995 Environment Act:-
Conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park.
Promote opportunities for the understanding and enjoyment of the special qualities of the Park by the public.
In fulfilling these purposes, the National Park Authority has a duty to :-
Seek to foster the economic and social well being of the local communities within the National Parks. The 3 National Park Authorities in Wales
The special qualities of the 3 National Parks are recognised and admired both by local residents and external users and the National Park Authorities are rightly regarded as leaders in landscape management. Climate change is correctly regarded as a significant challenge to those working in the protected landscape sector and we hope to utilise our experience for the benefit of your Committee.
1 Is the proposed 3% annual reduction target by 2011 'in areas of devolved competence’ sufficient to enable Wales to make its full contribution to meeting UK-wide targets? If not what targets should be put in place?
We assume the reduction would be set on 1990 base year, when Wales’ emissions were 13.4 Million tonnes of Carbon (MtC) Global warming potential (1). Given the UK’s 20% reduction target by 2010 we need to reach a Wales emissions level of 10.7 MtC GWP by 2010, and 5.36 MtC GWP by 2050.
The figure for 2003 (1) is approx 12.3 MtC GWP (2). We cannot locate the 2007 figure but if we assume this is also 12.3 then a 3% year on year reduction even from now would we calculate bring us to the 20% target in about 2012 (late), and to the 60% target in about 2035 (ahead of schedule).
On this basis the target in the question is insufficient; 5% year on year (y.o.y). from now until 2010 is needed to meet the 2010 target, although a lower subsequent rate: 3% y.o.y. from 2010 would result in achievement of the possible 32% Climate Change Bill target by 2020.
The Climate Change Bill proposes 15-year carbon budgets; working with these as well as to the above trendline may afford a more practical way forward given that (a) emissions reductions are perhaps likely to progress stepwise i.e. with periods of sudden progress and periods where there is less change, and that (b) greater reductions are needed early on if we are to achieve the 20% reduction from 1990 base by 2010.
We would add that "peak oil and gas” gives an even greater urgency, were one needed, to carbon reduction - an issue which is usually couched in terms of climate change.
2 Should the emission reduction target be based on Welsh consumption, or production, or both (i.e. should it take into consideration the CO2 generated in Wales (production), or the CO2 emissions that Wales’ residents are responsible for, regardless of their source (consumption))?
Targets should apply to both consumption and production (under the definition given in the question, consumption will include some production). Our reason for this is that both are components of Wales’ economic footprint and carbon emissions are a global issue.
While partners should focus on where quick gains are to be had we need at the same time to put measures in place for longer term reductions across all sectors.
3 What particular challenges does Wales face in reducing CO2 emissions from households and how can they be overcome?
Some challenges related to householder reductions, in the approximate order that they may be encountered:
Householders can't/don’t see the benefit of energy reduction/have other priorities
Ignorance of technologies or suspicion of new technologies
Time/cost/effort of planning consent
Time/effort to access grants
Lack of accredited installers
Wide variations in quotes
Installation cost/time/effort
Servicing costs and availability of qualified maintenance engineers
Some solutions are:
Continued education of all audiences and compulsory standards e.g. BREEAM in new build and refurb. All 'green’ messages can be complementary and build on each other - e.g. recycling is popular and energy saving is just another form of waste awareness - let’s build and capitalise on a growing green mindset.
Reconnect people with their energy usage (and wastage) through appropriate scaled and sited community/domestic RE - make it the norm. Higher output turbines may mean they no longer have to be sited in such prominent (wind rich) areas.
Finance independent advisors to help householders make the right choices
Make available easy access to grants for microgeneration in Wales. Paralleling the DTI Low Carbon Buildings Programme.
Central funding of large scale community/domestic scale efficiency/RE programs
However even if the problems are overcome there is the phenomenon of households acquiring additional energy-using appliances or running them longer etc precisely because they cost less to run - i.e. net energy use remains the same. Enabling householders to sell surplus to the grid might or might not help reduce this, and there may be implications for government in terms of electricity/fuel taxation and other incentives to reduce consumption.
4 To what extent has WAG been successful in utilising the powers available to it in order to reduce household CO2 emissions?
WAG has provided leadership and support on the issue and through targeted measures such as the Home Energy Efficiency Scheme and support of the Energy Saving Wales and Targeting Energy Efficiency in Wales websites. The Microgeneration Action Plan, within the evolving context of Wales’ Energy Route Map, will help complement those efficiency measures, as well as raising the profile of small scale renewables and reducing reliance on centralised, fossil fuel based energy sources.
WAG has tried creating an incentive framework with local authorities to get them to roll out wide scale energy saving measures scheme. The Policy Agreements and in particular 7b attempted to set targets, upon whose completion there was a financial reward. However, there was no corresponding penalty for not achieving the targets. HECA has been similarly ineffective at achieving a 30% reduction over ten years. (see Wales Audit Commission report into HECA).
Advice to householders has been provided via the Energy Saving Trust's Energy Efficiency Advice Centre programme - funded directly by DEFRA and therefore not subject to intervention by WAG. So the successes here cannot be ascribed to WAG.
There is a nascent Climate Change awareness programme now, but until that point WAG has not done much in the way of highlighting the issues (in the same way as it has done with waste reduction and recycling for example).
Climate change and carbon reduction have turned up in many strategies and consultations but there always lacked the link between strategy and implementation. Latterly the Microgeneration Action Plan has made a commitment to supporting a Sustainable Energy Network in Wales to provide advice and leadership for households and communities, it has ambitious targets for microgeneration installation but perhaps represents the best effort made by WAG so far.
It could be argued that indirectly WAG has supported projects through its funding mechanisms - SDF, CCW etc. But this doesn't form part of a coherent plan and largely depends on the effectiveness of the projects that are funded.
5 Could alternative targeting of WAG financial resources lead to greater household emissions reduction than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence.)
There are a number of energy efficiency measures schemes around. Mostly run by the utilities under their EEC obligation. This provides discount measures to the able- to-pay sector and free measures to priority groups. These measures however are the common and cost effective ones, cavity wall insulation and loft insulation. Some councils run there own schemes e.g Powys run the CO2i scheme and Flintshire run the FlintsUlate scheme, which provide additional grants to householders. The WAG funds the HEES scheme which is more about relieving fuel poverty than saving energy - sometimes one can compliment and improve the other.
Research has been done on the number and location of solid walled and off gas homes (http://www.energyefficiencywales.org.uk/) It shows that there is a significant number of hard to treat properties which fall outside of all the common schemes. Such homes require measures such as internal or external wall cladding, insulation panels placed in pitches, generally more high tech and high cost measures that no scheme manager wants to fund. In order to make an impact on the existing housing stock, certainly in rural Wales, funds could be made available for these measures.
New standards for new builds could make a big, lasting, impact, although the proportion of the housing stock that is new is negligible at the moment. But enforcement of higher standards in new build and development would be a start. There is a commitment to seek devolution of the building regulations, but this should be matched by the means to enforce. Planning issues have already been covered elsewhere.
Microgeneration, as already pointed out, people can make a more obvious link between supply of energy and the need to reduce demand. A Welsh Low Carbon Building Programme would be welcome. This would assist the expansion of the renewable energy market at the small scale. Additionally, it would need to be matched with investment in an accreditation scheme and a training scheme in order to ensure a robust and quality market. We would not want any expansion in demand to create a vacuum filled by 'cowboys' and predatory companies.
The main challenge to this is that the saving is pretty small, even if all potential microgeneration sites were used. But it serves the purpose of weaning the population off its reliance on fossil fuels, which is absolutely key for a number of reasons. Not least, general sustainability issues and the prospect of Peak Oil and an ensuing energy and economic crisis.
6 What example from other administrations (devolved, UK and overseas) where other means have been used to achieve reductions in household CO2 emissions, could be adopted in Wales under current powers?
Tradable energy quotas (3) (which would cover all domestic carbon expenditure (e.g. including flights) not just household emissions) - a system like this (similar to credit card system) is worth considering since the educational/voluntary approach may not have the desired impact in the desired timeframe. TEQs have the advantage of being able to cap households’ collective carbon expenditure, and would be consistent with EU ETS and proposals in the Climate Change Bill.
7 In the context of the Government of Wales 2006, which further means of reducing CO2 emissions from households could only be achieved with the introduction of further legislative competence for the NAW?.
The design and planning system would ensure that any new builds/estates/developments have a minimum percentage of energy from alternative sources of energy.
Use the Wales Spatial Plan to establish distributed energy networks - perhaps based initially on "Transition Towns”, where there would be existing public support and champion/s.
8 If specific CO2 emissions targets are to be set for Wales, should those targets be subdivided into shares by sector? If so what share of the total should reductions by households comprise?
Shares should be allocated by consideration of overall emissions and potential gains. It might be more equitable to set sectoral targets at a UK level. Sectors will have different scope for immediate (as opposed to 3/5/10 year) reductions.
We consider that the household sector is one where quick wins may be had; it is in the top four of Wales’ biggest contributing sectors (4) and small gains in every household will add up. We are not able to suggest what such a reduction allocation should be. Any measures implemented should of course protect the vulnerable e.g. the fuel poor, and in fact measures could be targeted (as funds have been through the HEES) to make the vulnerable amongst the first beneficiaries.
Once again, thank you for the opportunity to comment. WANPA’s response to the White Paper is a collaborative effort between all of the National Park Authorities in Wales. If you require further information related to any of the answers above, please feel free to contact me in the first instance.
Yours sincerely,
Greg Pycroft
Welsh Policy Officer
Welsh Association of National Park Authorities
References:
(1)www.countryside.wales.gov.uk/fe/fileupload_getfile.asp?filePathPrefix=391&fileLanguage=e.pdf
(2) Environment Strategy for Wales p23
(3)http://en.wikipedia.org/wiki/Personal_carbon_trading
(4) http://www.airquality.co.uk/archive/reports/cat07/0709180907_DA_GHGI_report_2005.pdf
