Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction by Industry and Public Bodies

Response from Wales Environment Link

27 Heol y Wig / 27 Pier Street, Aberystwyth, SY23 2LN ( : 01970 611621 (: enquiry@waleslink.org

Cadeirydd / Chair : Geraint Hopkins Cyfarwyddwraig / Director : Susan Evans www.waleslink.org

Wales Environment Link (WEL) is a network for environmental third sector organisations in Wales, most of whom have an all-Wales remit. WEL is officially designated the Intermediary Body between the government and the environmental third sector in Wales. Our vision is to increase the effectiveness of the sector in its ability to protect and improve the environment through facilitating and articulating the voice of the sector.

How WEL has come to agree this response

The production of consultation responses within the WEL network is an inclusive and comprehensive process. Whilst WEL recognises that all consultation responses must be given equal treatment, we would ask the Committee to note WEL’s protocol for writing consultation responses, as well as the number of organisations that have signed up to this response.

1. WEL’s Energy and Transport Working Group met to discuss and agree common positions within the group.

2. Attendees were asked to contribute to drafting the response.

3. Co-ordinator circulated first draft around WEL members via email, members provided comments and suggested improvements to wording.

4. Any point over which there was disagreement was further discussed via email.

5. A second draft was sent around the relevant WEL e-groups and Council, inviting further comments and sign-up.

6. The final draft was circulated to WEL Council and relevant e-groups offering a final chance to sign up.

WEL is pleased to be given this opportunity to respond to the consultation document of the Assembly Sustainability Committee concerning carbon reduction by industry and public bodies. WEL has decided to focus its response on question 4, as we believe it is fundamental to the whole inquiry. Please note however, that WEL has previously answered questions 1, 2 and 9 in our responses to the consultations on household and transport emissions.

Question 4: Do the current Welsh Assembly Government economic development policies give sufficient emphasis to carbon reduction?

The Assembly’s Sustainable Development Scheme states that it is "the National Assembly’s overarching strategic framework…all other strategies sit beneath this framework, their role being to underpin the delivery of a sustainable Wales”.
WEL agrees that sustainable development should be the driver of all policy and was therefore extremely disappointed, when the Welsh Assembly Government’s strategic framework for economic development - Wales: A Vibrant Economy (WAVE) - was published, to find it to be driven by a conventional, 'business as usual’ economic philosophy, without due regard either to WAG’s sustainable development obligations or to the sustainable development principles set out by the UK Government.
By disregarding the Sustainable Development Scheme, and the duty from which it originated, WAVE fails to give due regard to carbon reduction.
Instead WAVE states that "developing a low carbon economy in all its aspects, including transport, will become of increasing importance” - implying that we can defer any action to some point in the future.
WEL believes that we live in an age which demands a radical, and more realistic economic philosophy that recognises the finite resources available to us. WEL asks that WAG faces up to the reality that long-term economic development for Wales depends on the attainment of a low-carbon and low-resource economy.
If WAG was not convinced of the reality of these issues at the time of writing WAVE - despite the pleas of environmental NGOs and others who responded to the consultation -but surely there is now enough evidence to convince them otherwise, examples being the 'Limits to Growth 30-Year Update’ and the 4^th Assessment Report of the IPCC.

Timescale

Section 4 of the Assembly’s Sustainable Development Scheme document includes the principle "decisions about the short term should not be contradictory to long-term aims”.
WEL believes that WAVE fails to observe this principle by making no reference to longer term projections, and by focussing instead on short-term conventional economic assumptions and benefits
Whilst recognising the difficulty of reconciling the conventional short-term with a sustainable long-term, WEL believes that WAG needs to develop an economic development Strategy to 2050 and beyond, which takes into account current climate change projections.
The Stern Review estimated that if we do not all act to address climate change, 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. In contrast, the costs of action - reducing greenhouse gas emissions to avoid the worst impacts of climate change - can be limited to around 1% of global GDP each year.
WEL suggests that an economic development strategy that looked ahead to 2050 and beyond, might also be able to identify a set of employment priorities and opportunities that would be truly sustainable. These could be focussed, for example, upon community-based renewable energy technologies or local food production - developing locally-based and long-term jobs.
WEL hopes that the forthcoming Welsh Green Jobs Strategy will promote such employment priorities and opportunities. This Strategy should aim to capitalise on opportunities both for developing new sustainable businesses and jobs, and for greening existing jobs and industries. This dual approach will reduce the carbon impact of the Welsh economy and ensure Wales is on course to having a truly sustainable economy.

The agglomeration approach

WAVE embraces the 'competitive regions’ philosophy, which requires the development of a large city region in the south east of Wales to 'agglomerate’ economic mass, with high-growth business sectors and new transport infrastructures. The per-capita climate-change impacts arising from the infrastructure alone would be astronomical.
WEL believes that Wales will never achieve the 'agglomeration factor’ of regions such as south east England, and therefore, it should develop its economy in a different and greener direction.

Other Welsh Assembly Government Policy

Action 2 of the Environment Strategy for Wales committed WAG to "calculate the carbon emissions, which current and proposed policies generate and use this information to adjust policies to deliver carbon savings”. This Action was due to have been completed by March 2007, and yet WEL is unaware of any adjustments or calculations that have been made.
WEL is of the opinion that, in addition to WAVE, there are a number of other WAG policies that do little to lead us towards - and might even take us further away from - a low carbon economy.
For example, WAG’s analysis tool for transport projects WelTAG (Welsh Transport Appraisal Guidance) favours big expensive schemes in excess of £5m that very often increase carbon emissions, as the process requires considerable detail about the traffic benefits of investment proposals, and promotes the benefits of the traffic generated by road schemes.
Another example is the need to integrate better WAG’s economic development policy with that for rural development so that the management of environmental assets - water, soil, air, biodiversity - delivers benefits including carbon savings. This would give the rural economy a strong foundation based on rewarding land managers for the public benefits they deliver, and could be facilitated by placing a market value on carbon sequestration.

Suggested action

WEL advocates that WAVE is reviewed and revised from a sustainable development perspective as a matter of urgency, so that reduction of CO2 emissions becomes an essential and non-negotiable precondition for everything else in our economic development strategy.
As stated above, WEL recognises the difficulty of reconciling the conventional short term with the sustainable long term, and so would highlight Jonathan Porritt’s suggestion that a twin-track approach be adopted, whereby WAG develop an alternative strategy to WAVE based on a relocalised low-carbon model. Then, with the support of its partners in the Network of Regional Governments for Sustainable Development, Wales could make the transition from the one model to the other.
There are already a number of alternative strategies, models and research papers that can be referred to for the design of a new, low-carbon economic development policy for Wales. These include:
'Our energy future - creating a low carbon economy’ - DTI, February 2003
'One Planet Economy’ - from the UK Government’s Sustainable Development Strategy, 2005
'A Sustainable Economy for Wales’ - Dr Calvin Jones (Cardiff Business School), paper supporting Cynnal Cymru submission to consultation on WAVE, 2006
'Zero Carbon Britain’ - Centre for Alternative Technology, June 2007
'Making the low carbon economy a reality’ - Carbon Trust, August 2007
Re-localisation model - which anticipates that global sustainability will involve a reduction in the movement of goods around the planet and greater economic self-reliance requiring, in response, a more locally based economy for Wales.
In the meantime, within the constraints of the present economic model, all sectors of the economy should be driven towards minimising their CO2 emissions as far as is possible. This could be advanced by the completion and implementation of Action 2 of the Environment Strategy for Wales.

Wales Environment Link values the opportunity to take part in this important consultation process and trusts the above response will be taken into consideration by the Sustainability Committee.

The member organisations of Wales Environment Link that sign up to this consultation response are:

British Mountaineering Council
BTCV Cymru
Butterfly Conservation Wales
Campaign for the Protection of Rural Wales
Coed Cadw (Woodland Trust)
Council for National Parks
Friends of the Earth Cymru
Groundwork Wales
The National Trust Wales
Ramblers Cymru
RSPB Cymru
Snowdonia Society
Sustrans Cymru
Wildlife Trusts Wales
WWF Cymru

For further information please contact:
Michele Aitchison
Advocacy Officer for Wales Environment Link
Baltic House
Mount Stuart Square
Cardiff
CF10 5FH
Telephone: 02920 431 716
E-mail: maitchison-wel@wcva.org.uk