Sustainability Committee

Inquiry into Carbon Reduction in Wales: Residential Carbon Reduction

Response from Pembrokeshire Coast National Park Authority

Sustainability Committee
National Assembly for Wales
Assembly Parliamentary Service
Assembly Offices
Cardiff Bay
CF99 1NA

By email 8^th October, 2007

Dear Ms Hawkins

Carbon Reduction in Wales: Residential Carbon Reduction

Pembrokeshire Coast National Park Authority is grateful for this opportunity to comment on Carbon Reduction in Wales - Residential Carbon Reduction.

We have submitted comments via the Wales Association of National Park Authorities, which you will have received separately. However we are sending also our comments (and I appreciate that your deadline has passed) for information. Please find our response below.

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 MtC Global warming potential (1). Given the UK’s 20% reduction target by 2010 we calculate that 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 a 2007 emission figure for Wales but if we assume this is also 12.3 then a 3% year on year reduction even from now would we calculate (with a rough and ready spreadsheet) 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% 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

(1) www.countryside.wales.gov.uk/fe/fileupload_getfile.asp?filePathPrefix=391&fileLanguage=e.pdf

(2) Environment Strategy for Wales p23

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’ give an even greater urgency, were one needed, to carbon reduction - an issue which is usually couched in terms of climate change but which applies as immediately to economic and indeed social stability.

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 these challenges 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 refurbishment. 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 renewables - make it the norm. Higher output/more efficient 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 easy access to grants for microgeneration in Wales available paralleling the DTI Low Carbon Buildings Programme
Central funding of large scale community/domestic scale efficiency/renewables programmes

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 or greater (Jevons’ Paradox). 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 the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce household CO2 emissions?

Welsh Assembly Government has provided leadership and support on climate change and also through targeted measures such as the Home Energy Efficiency Scheme (HEES) and support of the Energy Saving Wales and Targeting Energy Efficiency in Wales websites, but while climate change and carbon reduction are prominent in strategy the links to implementation have not always been as clear.

The Microgeneration Action Plan has committed to supporting a Sustainable Energy Network in Wales to provide advice and leadership for households and communities; it has ambitious targets for microgen installation and is commended. Within the evolving context of Wales’ Energy Route Map, the Action Plan will help complement efficiency measures, as well as raising the profile of small scale renewables and reducing reliance on centralised, fossil fuel based energy sources.

The Policy Agreements with local authorities (in particular 7b) attempted to set targets with a financial reward for completion. However, there was no corresponding penalty for not achieving the targets. The Home Energy Conservation Act has had variable success (Wales Audit Commission report into HECA).

The Welsh Assembly Government has supported projects through its funding mechanisms for example Sustainable Development Fund, through the CCW etc. These are excellent for encouraging innovation and filling gaps at the local level but do not of course apply evenly pan-Wales, and carbon reduction outcomes depend on the nature and effectiveness of the projects that are funded.

The conclusion is that the Welsh Assembly Government has enjoyed notable successes but that momentum needs to be increased as the urgency of the issues grows ever more apparent.

5 Could alternative targeting of Welsh Assembly Government 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, principally run by the utilities under their EEC obligation. These provide discount measures to the able-to-pay sector and free measures to priority groups. These measures however are the common and cost effective ones, such as cavity wall and loft insulation. Some councils run their own schemes providing additional grants to householders. The Welsh Assembly Government itself funds the HEES scheme.

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 existing schemes are reluctant to fund. In order to make an impact on the existing housing stock, certainly in rural Wales, funds could be made available for these sorts of measures.

New build and new standards could make a big impact, although the proportion of the housing stock that is new is negligible at the moment. Enforcement of higher standards in new build and development would be welcomed. Commitment to seek devolution of the building regulations should be matched by the means to enforce.

Microgeneration can help people make the link between supply of energy and the need to reduce demand. A Welsh Low Carbon Building Programme would be welcome as it would assist the expansion of the renewable energy market at the small scale. This would need to be matched with investment in an accreditation scheme and a training scheme in order to ensure a robust and quality market. The main challenge to this is that the saving is relatively small, even if all potential microgen sites were used; however it has huge potential in terms of communication and awareness.

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.

Through design and planning procedure - ensuring that any new builds/estates/developments have a minimum percentage of energy from alternative sources of energy.

Using the Wales Spatial Plan to establish distributed energy networks - perhaps based initially on Transition Towns, where there will 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.

(3) http://en.wikipedia.org/wiki/Personal_carbon_trading

(4) http://www.airquality.co.uk/archive/reports/cat07/0709180907_DA_GHGI_report_2005.pdf

We are not in a position 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.

Thank you again for consulting the Pembrokeshire Coast National Park Authority. If there are any clarifications needed please do not hesitate to contact me.

Yours sincerely

Nic Wheeler
Chief Executive (National Park Officer)