SC(3) CR-I&PB13
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Carbon Reduction by Industry and Public Bodies
Response from the RICS Wales
With nearly 4000 members, RICS Wales is the leading professional body involved in all aspects of land, property, construction and increasingly environmental matters in Wales. Under the terms of its Royal Charter the Institution is required at all times to act in the public interest. RICS Wales welcomes the opportunity to respond to this questionnaire which deals with one of the most important and pressing issues of our time.
Introduction
The Royal Institution of Chartered Surveyors (RICS) is an international organisation. RICS Wales has access to sustainability issues via its counterparts in the UK and overseas. As an organisation we are fully committed to the urgency and importance of this subject which lies at the heart of the current and future work of our members. We believe that we have reached a vital stage in how we tackle the challenge of climate change and move beyond the rhetoric to positive action based on a firm understanding of what we mean by carbon reduction and the implications of the actions in reducing it.
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?
This is a fundamental question. We must understand what we mean by carbon emissions, the implications of a 3% reduction and how it is to be measured? Is the 3% annual reduction compatible with the latest UK and EU targets for 2020? The target needs clarification in establishing when it comes into effect. If it is by 2011, what will happen before that date?
It is important to get a grasp of the 'Where are we now’? Despite considerable debate about the subject we are still in the early stages of actively reducing carbon emissions but if we accept the overwhelming evidence of climate change the time has come to convert words into action. It is accepted that Wales can only influence those areas where it has devolved powers but in practical terms it may be difficult to apportion carbon emissions between areas of devolved competence and emissions as a whole.
Thus, we should be clear about what we mean by devolved competence?
2. Should the emission reduction target be based on Welsh consumption, or production, or both (i.e. should it take into consideration the carbon dioxide generated in Wales (production), or the carbon dioxide emissions that Wales’ residents are responsible for, regardless of their source (consumption)?
Equally, this is a fundamental question. Some contributions to carbon emissions are easy to recognise e.g. energy production but there needs to be more understanding of how carbon dioxide emissions are calculated and the implications of reduction. At present the process is shrouded in scientific jargon which distracts from its importance. In terms of measurement there should be common measurements aligned with targets within the rest of the UK and the world. The important consideration here is consistency and ensuring that all emissions are counted but not double counted. It is probably the case that all targets (UK, England and Wales) should be based on consumption in order to ensure that this is the case i.e. emissions that individuals or organisations are responsible for regardless of their source.
The trend of answers will refer to data collection and analysis. This is a major task in itself but unless we can identify and understand the scale of the task, climate change will remain an insurmountable problem.
3. What particular challenges does Wales face in reducing carbon dioxide emissions from industry and public bodies and how can these challenges be overcome?
Wales is one of the few countries in the world that has a duty to provide and ensure sustainable development. It has a legacy of heavy industry and still has a high proportion of energy intensive industry. It is reported that 150 companies account for most of our industrial energy consumption. Wales also has a large percentage of contaminated areas and a number of deprived areas with a large stock of older houses. It also has a difficult geography but also large areas of outstanding natural beauty. Collectively, this means that Wales has a particular set of challenges.
There is no single solution. Technological solutions alone will not deliver the cuts required. There must be behaviour change. Consumption must be reduced. Waste reprocessing will have to increase significantly. There should be more research on the use of renewable sources of energy and the result translated into practical implications. Generally, there should be a combination of funding to incentivise sustainability, a determined effort to create alternative sources of energy, a link up of knowledge and information and pro-active education of carbon reduction and the tools available to produce reduction.
In recent years the Carbon Trust has initiated a number of research projects in order to enable the UK to move towards a low carbon economy. These include the Carbon Vision Building project aimed at reducing emissions in all UK buildings. The same organisation has formed the Carbon Vision Building Engagement Group made up of leading industrialists and decision makers in the area of emissions associated with UK buildings. The Carbon Trust is working on these projects in conjunction with the Engineering and Physical Sciences Research Council (EPSRC). The emphasis is very much on turning the research into real benefits for industry and utilising the capability of University Research and Development departments to deliver on low carbon techniques. In the 2005 press release issued jointly by the EPSRC and Carbon Trust a key objective was to reduce the carbon emissions of all UK buildings by 2030.
4. Do the current Welsh Assembly Government economic development policies give sufficient emphasis to carbon reduction?
Partially. 'One Wales - a progressive agenda for the government of Wales’ gives a strong emphasis to the sustainable environment and includes a section entitled 'Tackling climate change’. The assembly pledges to:
1) Establish a Climate Change Commission for Wales.
2) Aims to achieve the target of annual carbon reductions of 3% per annum by 2011 in 'areas of devolved competence’ (see earlier comment).
3) Set specific sectoral targets in relation to residential, public and transport areas.
4) Work with the heavy industry/power generation industries to reduce emissions in those sectors.
5) Will set out and achieve targets on the carbon neutrality of public buildings
6) Draw up an energy strategy which will be integrated with a planning framework.
It is alarming to note press reports last year (Wales on Sunday) that Wales has the 12th worst carbon emissions footprint in the world, considerably greater than England, Scotland and Ireland, despite considerable rhetoric and action to improve the situation. Wales clearly has some specific problems but there needs to be greater clarity about carbon emissions and much greater urgency in bringing about change. The new Climate Change Commission will have an enormous job on its hands especially if it is tasked with a monitoring role.
Most Assembly documents include the word sustainable. For example, under section 4 of 'One Wales’ entitled 'A Prosperous Society’ there is a mention of 'sustainability principles’ (p.13), Green Job strategy (p.14) without explaining what is meant by these terms.
A theme of this response is the need for clarity in definitions and targets. How does the 3% reduction fit within the UK target of 60% reduction by 2050, the minimum target? In its report ’A Green Profession?’ published by the RICS in June 2007 concerns were expressed about the lack of common standards and benchmarking.
5. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce carbon dioxide emissions from industry and public bodies?
Partial success. Wales has consistently pressed for the principles of sustainability, but devolution is limited. Building regulations are not devolved limiting the Assembly’s power to control the built environment. This is crucial if Wales is to control the move to carbon neutral buildings. There are examples of good practice, e.g. Further Education Colleges in Wales are progressive in moving to energy efficiency. They report that over the next 12 - 18 months they will be able to provide a 'measurable’ demonstration of carbon reduction. But this again proves that data collection and analysis of buildings is notoriously difficult and requires time and dedication to collect on a consistent basis.
A number of good practice examples are to be found in the public estate in Wales such as a biomass heating system in Llandrindod High School, a water turbine and two small wind turbines at Glamorgan University and biomass boilers in new hospitals. Flintshire County Council has formed an energy team responsible for implementing their energy action plan. However, much more needs to be done and whilst work can be done to improve the design and insulation qualities of new buildings this only represents a small portion of the stock. Existing buildings needs a lot of adaptation. The introduction of Energy Performance Certificates this year is likely to put an increased focus on energy efficiency.
6. Could alternative targeting of Welsh Assembly Government financial resources lead to greater emissions reduction from industry and public bodies than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence)
The CBI’s Climate Change task force demonstrated that moving to low carbon sources of detecting and improving energy use in buildings can deliver about 30% of the additional cuts needed, with the remaining 40% coming from transport and industry. The report calls for a shift to recognising carbon as a new currency. (Climate change: Everyone’s business, Nov 2007). RICS Wales supports (in this report) reward for greener behaviour, carbon neutral tax reform, more resource to Research and Development to finance technologies and solutions to reducing carbon emissions. For Example:
Introduce a compulsory code for sustainable buildings.
A significant step-up in the rate of insulating existing stock.
Reduction of VAT on building refurbishment and retrofit.
Introduce tax relief to make buildings more energy efficient.
Collection and analysis of data is vital in the whole process.
The consumer must understand the consequence of his actions.
Information and communication of the information must be clear and concise especially as we move from policy to implementation. In this respect there should be an emphasis on transport and buildings. RICS Wales is currently undertaking a study of the implications of energy use, transport and the built environment in Swansea, Bangor and Cardiff respectively. This report will follow up work already published in Scotland. The results are expected in the spring and are expected to show the dramatic implications of the steps referred to in this response.
7. What examples from other administrations (devolved, UK and overseas), where other means have been used to achieve reductions in carbon dioxide emissions from industry and public bodies, could be adopted in Wales under current powers?
"Building and construction account for the largest single share in global resource use and pollution emission and amongst all industry sectors they have the largest potential for cutting global greenhouse gas emissions” (RICS EU advisory Group on sustainable property investment management). The Group has been set up to overlook the whole of Sustainable Property Investment Management.
The RICS in Scotland has produced a report (The City Climate Challenge for 2050: Your city - your responsibility). This report draws attention to the lack of clarity in data and particularly the implications of climate change. "So while we know, for example, that renewable technologies or by making fewer journeys by car are good things to do, much less is known about how many renewable technologies are required or how much less we need to drive”. The report also drew attention to the need for a substantial change in behaviour and the need for UK targets to be translated to the urban levels through reduction strategies covering key areas such as waste, the built environment, energy and transport.
8. In the context of the Government of Wales Act 2006, which further means of reducing carbon dioxide emissions from industry and public bodies could only be achieved with the introduction of further legislative competence for the National Assembly for Wales.
The absence of building regulations being devolved means that Wales is restricted in controlling new development. The thresholds being imposed in the Planning Act currently going through Parliament are a further restriction. Within the current legislation going through Parliament, National Policy statements will be produced by UK Government Departments (the Assembly will be a consultee). It is essential for spatial planning to take account of the link between transport and the developed community. There is a risk that Wales could be restricted by the thresholds included in the Act whereby e.g. power stations over 50 megawatts would ultimately be decided by Westminster rather than the Assembly. 'Devolved competencies’ restrict the Assembly and therefore in this case it can only move as fast as it is allowed.
9. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector? If some, what share of the total should reductions by industry and public bodies comprise?
Care is needed here. The data needs to be advanced before the headline reduction is further sub-divided. Some sectors are more advanced in collection and have more data than others. There are no common benchmarks. However, industry and public bodies are major contributors and the above comments should not be taken that RICS Wales opposes shares being introduced in the future. There is a case for priority to be focussed on those sectors or parts of sectors which produce high carbon emissions and where 'quick wins’ can be obtained.
10. How will the Carbon Reduction Commitment affect you business? Should the proposed Commitment be amended in any way?
The RICS is actively involved in promoting sustainability in its practices and procedures. In a rapidly changing market, environmental work in all its forms is fast becoming an important part of the surveyor’s skill base. Chartered surveyors offer the cross skills to look at both the commercial and environmental issues. In the context of these changes the institution is reviewing its qualification routes, courses and cognate conversion to ensure there will be a sufficient supply of suitable graduates with the skills that will increasingly be needed.
Currently, our members have a key role to play in dealing with energy issues, in particular, the importance of building control surveyors in ensuring that new building meets the new building regulations and in the delivery of Energy Performance Certificates which will come into effect this year. Our members will welcome the opportunity to engage with the Assembly on the important matters raised in this paper and employ their expertise in finding practical solutions to tackling climate change.
J. C. Harper
February 2008
