Friends of the Earth Cymru response to the Committee on Climate Change Welsh Carbon Budgets – Call for Evidence


Friends of the Earth Cymru is part of Friends of the Earth England, Wales and Northern

Ireland, and supports a unique network of local campaigning groups working in communities

throughout Wales. Friends of the Earth Cymru inspires the local and national action needed

to protect the environment for current and future generations, and believe that the well-being

of people and planet go hand in hand.

We campaigned for a statutory framework for reducing emissions in Wales since the

Assembly acquired legislative powers, were involved in the legislative progress of Part 2 of

the Environment (Wales) Act 2016 and welcomed its introduction. We responded to the

Stage 1 call for evidence earlier in the year and are now pleased to respond to this call for

evidence. We look forward to continue working with the UK Committee on Climate Change

as the designated advisory body under the Act in developing its advice, and with the Welsh

Government and Assembly in preparing the regulations which are crucial to the setting up of

the statutory framework.

We realise that a substantial amount of work needs to take place in order to set up these

new systems and ensure that the right data is collected and analysed, but hope that

progress will be as swift as possible given that we are now within the first carbon budget

period (2016-2020) and the urgency of tackling climate change.

Our principles in responding to these specific questions are;

1) That the Paris Agreement has changed the political landscape and the global carbon

budget that we must all live within – budgets and targets in Wales must reflect that, to

“pursue efforts” to limit temperature increase to 1.5°C and to hold the increase to

“well below” 2°C.

2) That the global carbon budget must be divided equitably and fairly rather than purely

on a 2050 per capita basis, taking account Wales’ historic responsibilities as an early

industrialised nation and the 7

th well-being goal of being a globally responsible


a. Climate science and international circumstances

Question 1: Does the Paris Agreement mean that Welsh emissions targets should

keep open a deeper reduction in emissions than 80% by 2050? Are there implications

for nearer-term targets?

The 80% target is based on around a 50% chance of exceeding 2 degrees, whereas the

Paris Agreement, which the UK has ratified and National Assembly for Wales has

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unanimously endorsed, has an aim to keep warming “well below” 2 degrees, and pursue

efforts to keep warming to 1.5 degrees. Paris is clearly a stronger commitment than a 50%

chance of 2 degrees, and rightly so, given the increasingly devastating impacts of climate

change we are seeing at just 1 degree of warming.

The Committee on Climate Change has accepted that the Paris Agreement describes a

higher level of ambition than the one which formed the basis of the UK’s existing legislated

emission reduction targets, including that set in the Environment (Wales) Act. On a UK level

however it has argued that now is not the time to strengthen targets, as in its view there is

not yet a credible policy package to deliver tougher targets, and that indeed focus should be

primarily on making up the shortfall in policies on existing targets. However Wales is in a

different position, with the first report on proposals and policies to meet a carbon budget

currently in the process of being prepared by the Welsh Government and required by the

end of 2018, to be in line with the first carbon budget and interim target. At the beginning of

the process, when plans are not yet in place is the best time to set the realistic and

necessary expectation of emission reduction to 2050.

We’d also set out two other grounds for changing the target now. First, climate change is

desperately urgent. Indeed we will not get the policies we need to deliver the Paris goals if

politicians, policy makers and the public are unaware of the real scale of the challenge. Set

the necessary target, then work out how to meet it. Second, time is not on our side. Climate

impacts are a product of cumulative emissions, and time is running out extremely rapidly for

meeting either a 1.5 or 2 degree global carbon budget. For the “area under the curve”

cumulative approach it is basic maths that it is the early years that matter most – any delay

in setting a 1.5 degree compatible budget makes it likely that it will mathematically

impossible to keep to such a budget.

In addition, the UK target is the product of two main factors – the global goal, and then an

appropriate and fair contribution towards that goal for the UK. On the latter factor, the CCC’s

2008 advice appropriates a far more than fair share of the available global carbon budget to

2050, which in our opinion does not reflect the “differentiated responsibility” principle at the

heart of the UNFCCC.

The CCC has recently published new work looking in more depth at this issue of fair national

contributions, which imply far stronger targets for the UK. We believe the next step should be

to reflect this analysis in new, stronger targets and tight budgets. This is particularly relevant

for Wales – issues of global equity and fairness must be included in this assessment in line

with Wales’ commitment to be a globally responsible nation in the Well-being of Future

Generations Act.

In summary, a tighter target to reflect the Paris goal, and a fairer contribution to meeting that

goal, represent a double ratchet down on the existing target, to be of the order of an 80% cut

by 2030, and 100% by 2050. We stress that such a ratchet is compatible with the

Environment (Wales) Act, which has the 2050 target at “at least 80%” (our emphasis).

We also argue that Welsh approach should extend the CCC’s use of carbon budgets. It is

the total cumulative emissions that matter not just the final target. The individual budgets

should be complemented by a clear TOTAL carbon budget to 2050, which is calculated

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using the Paris goals, and a fairer contribution to meeting them. This approach would better

ensure that the trajectory to 2050 is one which means that the Paris goals are met. It implies

that the carbon reductions in Wales need to be steep and deep rather than leaving greater

action for later decades. The interim targets for 2020, 2030 & 2040 need to reflect this.

Such an approach would be in line with the five ways of working set out in the Well-being of

Future Generations Act. A long term approach to decision making is required, including in

setting these targets and the actions to deliver on them. The implication of this for nearerterm

targets are to emphasise the need for a steep trajectory for the sake of long term wellbeing.

Question 2: Do you think that leaving the EU has an impact on the targets or how they

can be met?

The prospect of the UK leaving the EU does impact the setting of targets and how they are

met to some extent.

First of all it confirms that the CCCC’s advice to set a Welsh carbon account on gross

emissions from Wales rather than the EU ETS system is wisest given the uncertainty around

the future of such a system.

The Welsh Government has stated that it does not want to see a regression on

commitments made in EU environmental law and this would include policies relating to

emission reduction e.g. energy efficiency and waste. This should be respected.

Individual country responsibility for reducing their emissions will also be much more

important when the UK leaves the EU as we cannot rely on other countries and states to

meet the EU’s overall commitments on our behalf, including international commitments such

as the Paris Agreement which the National Assembly for Wales has unanimously endorsed.

In replacing EU laws and the treaties the Well-being of Future Generations Act (the WFG

Act) must be the key framework for operating in Wales and deciding on a future direction.

There are issue of civil service and government capacity for making the major changes

necessary to meet the Paris Agreement given the additional and overwhelming burden of

Brexit. There is also a danger that leaving the EU could bring pressure for deregulation and

returning to the UK’s old reputation as the ‘dirty man of Europe’. The Welsh Government has

indicated that they do not want this to happen in Wales and there is clear political

commitment to not reducing environmental protections and indeed to strengthen them where

possible, but there may be decisions made by the UK Government and issues of devolved

powers which undermines this intention. This makes the provision of the Environment Act

Part 2 and forthcoming regulations even more important, and it is crucial to ensure that there

are no unnecessary loopholes that could be misinterpreted in light of these pressures.

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b. The path to 2050

Question 3: In the area(s) of your expertise, what are the opportunities and challenges

in reducing Welsh emissions in the nearer term (e.g. to 2030)?

With the introduction of the duties under the WFG Act and the changes to ways of working

this requires there is a great opportunity to integrate decarbonisation into the decisions of all

public bodies in the coming years. It is a time of transformational change in the Welsh public

sector and knock on impacts throughout sectors and therefore a good time to embrace the

transformational change necessary to stop dangerous climate change.

There are opportunities to develop new sustainable sectors of employment, skills and

business in Wales – getting ahead of the game and ensuring a well-planned and just

transition to a resilient low-carbon economy and just society.

Some of the opportunities to reduce emissions which have social and economic as well as

environmental benefits in the nearer term are a national infrastructure project of retrofitting

homes to meet high energy efficiency, moving away from fossil fuels and developing

renewable energy technologies, and divesting public funds, directly and indirectly, from fossil

fuels. There has to be a swift decarbonisation of the electricity system, a reduction in energy

demand and improved efficiency.

As well as specific policies there are structural changes needed across decision making

institutions – such as introducing carbon impact assessments of major proposals,

infrastructure and spending.

There are also challenges – to ensure that this necessary transition is just and that areas of

high carbon industry which will face significant changes and job losses are supported to

adapt and create alternative employment.

It is also a challenge to undertake significant change at the same time as a process for

leaving the EU.

Question 4: What is required by 2030 to prepare for the 2050 target for an emissions

reduction of at least 80% on 1990 levels, recognising that this may require that

emissions in some areas are reduced close to zero? Is there any impact of the need to

go beyond 80%, either in 2050 or subsequently?

In order to prepare for emission reduction at a scale necessary by 2050 the first two budgets

and interim targets should be what’s actually needed to put us on the right trajectory, not

what might be politically acceptable for ‘business as usual’ to continue. There needs to be

clear signals to drive policy and progress at the appropriate rate and level.

This will also help developing low carbon markets and technologies who need certainty for

investment and growth. Those countries which adapt early and innovate in new low carbon

technologies and markets will also gain the most economic advantage and job creation.

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Some of the changes needed for this long term planning will require cultural and behavioural

changes – including awareness of the implications of decision making and cumulative


Question 5: What are the respective roles of UK Government, Welsh Government, the

wider public sector, business, third sector and individual or household behaviour in

delivering emissions reductions between now and 2030? And, separately, between

2030 and 2050?

Leadership needs to come from the Welsh Government – as an exemplar itself and as the

authority responsible for the preparation of proposals and policies for meeting the carbon

budget. They have consistently been clear that Wales should be at the forefront of tackling

climate change, are part of The Climate Group, actively engaging in COP meetings and

making regular statement about Wales leading the way with climate action and legislation.

This has been exemplified in actions such as funding home energy efficiency and the

moratorium on fracking as well as the WFG Act and Environment Act. But there is not yet an

action plan for delivering emission reduction across the board, and it is not yet reflected in

the actions of the whole government or delivered across “each of the Welsh Ministers” as is

required under the Environment Act.

Behaviour change is a crucial part of cutting emissions and the emission reductions

necessary cannot be achieved by technical solutions only. This is particularly importance

once the more structural changes of decarbonisation have taken place e.g. a major shift

from private car use to integrated public transport and active travel.

In Wales public bodies also have specific duties under the WFG Act to maximise their

actions to achieve sustainable development and act according to the Well-being goals. It is

important, in particular given the five ways of working, that civil society is fully involved and

participate in preparing and delivering decarbonisation plans.

The UK Government remains responsible for significant levers of policy, regulation, law and

finance which impact on Wales’ emissions such as industrial policy, large scale energy

infrastructure, some transport and taxation. The UK Government must understand that either

these powers and the corresponding funding should be devolved to Wales, or that they

cooperate with Welsh Government in order to enable them to deliver on their responsibilities

c. Emissions targets and action

Question 7: In your area(s) of expertise, what specific circumstances need to be

considered when setting targets and budgets for Wales and how could these be

reflected in the targets?

Wales has a ground-breaking Well-being of Future Generations Act which clearly states our

direction of travel in the 7 well-being goals. These include having a prosperous low carbon

society using resources efficiently and proportionately, enhancing a biodiverse natural

environment and being a globally responsible Wales. This unique Act and its ambition for

Wales needs to be reflected in the targets and budgets.

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In particular, goal 7 states: A globally responsible Wales. A nation which, when doing

anything to improve the economic, social, environmental and cultural well-being of Wales,

takes account of whether doing such a thing may make a positive contribution to global wellbeing.

We interpret this as introducing the need for equity – particularly the need to consider lower

future emissions allowances to countries with high past emissions and wealthier countries,

when taking into account Wales' budgets. We would therefore expect the CCC to at least

outline how it has taken account of this equity issue for Wales' carbon budgets.

Wales has a historic role as the cradle of the industrial revolution and the responsibility for

these emissions should be taken into account when considering what our share of the global

carbon budget should be.

We have a track record of doing things differently in Wales since devolution, for example the

jump up in recycling rates to third in the world. There is potential for innovation and the

political will and natural resources suitable for transformational change.

Question 8: The power and industry sectors in Wales are dominated by a small

number of large emitters. What are the key challenges and opportunities that this

presents in setting the levels of carbon budgets and how should the process of

setting them reflect these?

The steel industry in Wales is a major emitter which nevertheless produces a valuable

resource which is vital to every-day life. The steel industry in the UK provides high-quality

jobs and security for tens of thousands of people. We do not wish to see this industry

outsourced to countries which may well have lower environmental standards and would

require more shipping of steel into Wales for low carbon infrastructure projects such as wind

turbines and tidal lagoons. There is a role for more government support and investment

through the Green Investment Bank to upgrade plants and make them ultra energy-efficient

and low carbon as part of a wider industrial strategy. Please see our report for further details


In terms of power, Aberthaw coal-fired power station will close in the coming years, which

will be a great stride towards decarbonisation of power production in Wales and improved air

quality. The budgets need to be prepared for a major change in circumstances such as this –

so that other sectors aren’t let off the hook and don’t need to make such efforts to

decarbonise as a result of this happening. The budgets need to be tight to take into account

the high likelihood of this happening in the first or second budget period, and there needs to

be flexibility to reduce the absolute carbon budget or take this into account when it happens.

Another element that would help balance out the impact of our territorial emissions is the

consideration given to consumption emissions or our carbon footprint and other footprint

measurements – to consider what’s used in Wales as well as what’s created here. The

National Indicators for Wales include measurements of emissions of greenhouse gases

attributed to the consumption of global goods and services in Wales (Wales’ carbon

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footprint) as well as emissions of greenhouse gases within Wales. The indicators are the

main measure of progress towards the achievement of Wales’ well-being goals and will be

reported on annually. The consumption indicator will help give a more complete picture of

emissions for which Wales is responsible, for example the embedded emissions of importing

steel or other materials as opposed to producing them in Wales. Taking this indicator into

account could help reduce competitiveness implications for industry in particular.

d. Wider considerations

Question 10: What evidence regarding future trends as identified and analysed in the

future trends report should the Committee draw on in assessing the impacts of the


There are a number of sections in the Future Trends Report which would be useful to take

into account.

Page 7 refers to economic changes, including a shift away from manufacturing, and

untapped potential to generate renewable energy.

Page 9 section on Climate Change is all relevant, including the assessment that two degrees

threshold will be exceeded unless significant and rapid action is taken, and highlights the

significant impacts to Wales from exceeding two degrees. These include flooding, health

risks of high temperatures, water shortages and natural capital. It also highlights climate

hazards for infrastructure.

Page 10 on Land Use & Natural Resources highlights pressures on biodiversity and species,

causes of air pollution, groundwater and housing.

Part B makes references to de-globalisation (p.12), technological development in low carbon

energy, and warnings about the unknown effects of bio-engineering (p.13). Page 13 also

emphasises the importance of the Paris Agreement and the need for major decarbonisation

of energy generation, transportation infrastructure and behaviour shifts. The section on

environmental factors (p.14) focused on the risks of climate change impacts.

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