Climate Change Response

1 March 2005

Lisa Stratford
National Climate Change Policy Division

3/F3 Ashdown House
123 Victoria Street
London
SW1E 6DE
Dear Lisa

UK CLIMATE CHANGE PROGRAMME

Thank you for the opportunity to comment on this document. We have reserved more detailed comment for those areas which we would perceive having the greatest relevance to Northern Ireland and will be in direct communication with DOE (NI) on those aspects.

General

Council recommends that the UK wide framework for climate change action set within the context of the international agreement must first be established and this should set the framework for the regional strategies. We recommend that the regional strategies should have mandatory targets for reduction of GHG emissions and that a mandatory plan of actions is adopted.

Transport

It is apparent from the projections carried forward that the GHG emissions from the transport sector is increasing and that efficiency measures will not counteract the growth in traffic emissions from both air and surface transport. We would recommend that policies addressing this sector undergoing Cost Benefit Analysis should take into account the health, social and nature conservation gains emerging from incentives or options for people to undertake a more active mode of transport. Loss of revenue to the Exchequer should not be considered on a par with these other benefits. Indeed, the example set by ROI in forgoing Exchequer gain in favour of a health centred policy forbidding smoking in public places shows what is possible.

Harmonisation

The impact of the land border with ROI must be given due consideration when fiscal policies are used to encourage changed behaviour. Distortion of markets across borders can have serious environmental consequences as indeed has been seen in the movement of waste, illegal dumping, as well as the aggregates levy concerns.

Energy

Electricity supply could be challenged with increasing use of renewables. We would welcome a review addressing the integrated impact of the different options of future provision of electricity incorporating all forms of supply from nuclear, fossil fuels and renewables.

Renewable Energy

We believe this sector must embrace all forms of renewable energy. It is of interest to note that the document specifically talks about non-thermal renewable energy and yet lack of heat is one of the prime sources of fuel poverty. Renewable energy, where possible, should be sited near point of use and due consideration given to all forms of renewables.

Agriculture

Under CAP reform, subsidies are shifting from food to environmental gain. If subsidies are also introduced on biofuel crops then this should be within a framework that will ensure sustainable farming methods ensuring the cultural and ecological preservation of land. Germany with a guaranteed price for renewable energies encouraged farmers to diversify from livestock to mixed farming of arable and livestock thus allowing for biodiversity gains as well as renewable energy.

Biodiversity

Council is of the view that Climate Change has been acknowledged as one of the greatest threats to the human race and also to the Biodiversity which we seek to conserve, and in meeting this challenge it is important to ensure that protected areas, woodlands, environmentally sensitive habitats are more than areas set aside for wildlife . They need to be part of ecologically functional landscapes and will require the creation of further semi natural habitats for both woodland and open ground encouraging agriculture that is sympathetic to wildlife

Comments specific to Northern Ireland

Council is aware that other regions in the UK have embraced Climate Change programmes as part of sustainable development to a greater degree than NI. Energy consumption, and car dependency is increasing, and waste risings growing.

Waste

Implementation and enforcement of the European Community's landfill directive will help reduce emissions and Council recommends that the Waste Management Strategy is implemented in full, lack of action is not an option. We would also ask that an agricultural waste strategy is adopted as soon as possible exploiting both recycling, reuse and energy generating opportunities with other waste sectors.

Renewables

We would recommend a strategic environment assessment of renewable energy provision within NI taking into account the true Cost Benefit Analysis of all energy provisions and utilizing synergies with other strategies such as waste. Targets of 12% including gains from the introduction of natural gas appear to be considerably less than the Scottish target which already includes the natural gas gain in its base line A coordinated strategy can ensure that all opportunities would be exploited instead of a rash of developments in environmentally or economically unsuitable locations.

Transport

Northern Ireland still has not addressed the increasing demand for travel. In comparison to Scotland and Wales the 77% increase in C emissions from transport between 1999 and 2002 is very great and a further increase of 8% on the already high base figure of 2001 is not acceptable, especially given that the increase quoted in table 9 for the period 2001 to 2002 is already 23%. Land use policy should support the minimisation of transport emissions, the location of land for development should aim to reduce the need to travel, to reduce car dependency by relating development to existing settlements and to networks for public transport and walking and cycling. PP3 and 13 have recently been published and should be implemented rigorously within the plan led system of development control. The Regional Transportation Strategy addresses the planned development of our transport needs within the Regional Development Strategy (through the operational area plans). All plans need to be implemented in synchronisation with each other; reduction in times of journeys should not lead to increased traffic on the road nor increased planning pressures on sensitive areas, but rather to greater intermodality of transport and more active transport modes thus ensuring other health, social and environmental benefits. Actions agreed within daughter strategies such as the physical activity, walking and cycling strategies should be properly resourced, integrated and implemented across government departments, and working agreements need to be arranged with the private and voluntary sectors. Council would recommend a review of these targets

Biodiversity and Agriculture

Climate Change has been cited as one of the major threats to global biodiversity, even within our own regions, montane habitats are at greater threat from global warming, their associated species will not have the option of translocation. Species threatened from climate change elsewhere may need to establish in other regions. Consequently, a review of policies relating to alien species, favourable conservation status of protected areas and indeed, their boundaries would be necessary with reference to climate change. Sensitive habitats must be part of ecologically functional landscapes. CAP reform should allow for the creation of further semi natural habitats that would be more sympathetic to the changing need of wildlife. We would recommend that DARD, in liaison with EHS, provides an overarching document defining an agri-environment policy that will underpin sustainable agriculture in Northern Ireland for the next 10-20 years and which will integrate the protection, management, enhancement and restoration of habitats and species within a catchment management framework and to move nature conservation and countryside protection into a significant new phase i.e. one which encourages co-operative agri-environment schemes between farmers and helps move environmental protection toward the management of local and regional habitats and landscapes. Earlier in 2004, the Northern Ireland Biodiversity Group was re-established, together with the setting up of an Interdepartmental Group to co-ordinate delivery of Government Departments' responsibilities under the Strategy. Biodiversity strategies should embrace impact of climate change. If biodiversity loss is to be halted in this part of the EU by 2010, a major upgrade for biodiversity in resourcing, priority and commitment is needed within Northern Ireland's Government, local authorities and interest groups. Without it, there is little chance of meeting our targets or addressing the underlying issues. Council recommends that a regional action plan within the UK wide Climate Action Programmes should include mandatory targets and these be set in context with other local strategies such as transport, waste, agri-environment and energy. Government must not compromise these actions by its own lack of integrated thinking and its unwillingness to tackle Climate Change within a holistic and long term vision. Although Climate Change is the result of cumulative action of many there is need for moral leadership by Government. There should be a review of how Government actions impact on Climate Change. Council has recommended that there are clear targets set for Government on sustainable development and that these should also embrace Climate Change. Consequently we would recommend that:

1) All government departments submit
i. Work transport plans
ii. Energy plans
iii.Green procurement with targets for secondary material
iv. Waste management plans
v. Sustainability audit of plans and programmes
vi. Environment Management Systems

2) The Programme for Government is submitted to sustainability audit.

3) The Sustainable Development Strategy should include indicators for climate change.

4) Mandatory targets for Climate Change are agreed for regional action plans.

Council would like to further discuss the development of a Climate Action Plan for NI and how actions from Government could be used to influence the business and community sectors.

Yours Sincerely

Dr Lucinda Blakiston Houston
Chairman

c.c Mr R Lightbody , DOE(NI)