A game is being played where the CCC assumes the government has the capacity to deliver the NDC and the government pretends to have this capacity.
It is well known that the UK is committed to a target of net zero greenhouse gas emissions by 2050. This is considered to be sufficient to ensure compliance with the 2015 Paris Agreement to limit global warming to within 1.5 degrees Celsius above pre-industrial temperatures.
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There is wide scientific consensus that just two degrees of warming involves substantial environmental harms and also risks tipping the world into catastrophic climate change.
In line with the agreement, the UK has committed to what is known as a Nationally Determined Contribution (NDC), interpreted as a cut in its emissions of 68 per cent by 2030 compared with 1990 levels.
Path
What is perhaps less well known is that the UK has no clear plan to achieve either its NDC target in 2030 or its net zero target in 2050.
This failing was originally established in the High Court in July 2022 as a result of action by Client Earth, Friends of the Earth and Good Law Project. In response to the court’s ruling, the UK government published its Carbon Budget Delivery Plan (CBDP) in March 2023.
However, a report by Friends of the Earth published in March 2024 concluded that the government’s plans would cut emissions from October 2023 to the end of 2030 by only 92 MtCO2e - much less than the 170 MtCO2e that the Committee on Climate Change says is required over this period to meet the NDC target.
Accordingly, the CBDP was challenged by the three environmental charities and again found wanting by the High Court on 3rd May 2024, on the grounds that the government failed to show that its proposed policies would be likely to achieve its intended emissions cuts. The government is now expected to submit a revised plan by May 2025.
The Committee on Climate Change (CCC) is primarily responsible for developing the carbon budgets intended to ensure that the UK keeps on the path to net zero.
Rollbacks
The committee has become even more concerned over recent years that the UK is increasingly off track - and not merely failing to get back on track but actually taking steps that have the effect of moving the UK backwards rather than forwards.
In its latest progress report 2024, it notes a few positives, such as the closure of the last coal-fired power station, a significant fall in emissions over the previous year, confirmation of the zero-emission vehicle mandate, leaving the Energy Charter Treaty, and the increased heat pump grant (£7,500).
A game is being played where the CCC assumes the government has the capacity to deliver the NDC and the government pretends to have this capacity.
The overwhelming message, however, is negative: only a third of the emissions reduction required to reach the 2030 target is covered by credible plans, and just about everything is off track: offshore wind, onshore wind, solar installations, heat pumps, low-carbon technologies, tree planting, peatland restoration, methane reduction, and energy efficiency measures.
The CCC is especially critical of the decision to exempt 20 per cent of households from the phase-out of fossil fuel boilers by 2035, and of the failure to address the issue of transport demand.
The CCC has a certain mode of evaluation, in that it points out where the UK is or is not on track to meet its targets, but it only exceptionally - as in the case of policy rollbacks - explains exactly how the UK can get back on track if it is failing.
Embodied
Most often we are told how much additional emissions need to be cut each year, how much annual renewable capacity needs to be increased, how much new woodland needs to be created each year, how much peatland needs to be restored each year, and so on. But the CCC rarely tells the government how any of this could be done.
Effectively, a game is being played here, in which the CCC assumes that the government has the administrative, technical and financial capacity to deliver the NDC by 2030 and net zero by 2050, and the government pretends to have this capacity.
A good example of this relates to the issue of carbon budgets. These five-year budgets started in 2008 and are intended to take the UK safely through the energy transition. The first five budgets, however, were set on a trajectory to only 80 per cent emissions reduction by 2050, and they have not been revised in line with the 100 per cent target that was set in 2019. Partly for this reason, the CCC has been dubbed "the non-committal committee".
The only budget so far that has been based on the new target of 100 per cent emissions reduction by 2050 is the sixth carbon budget, which will not come into force until 2033. The problem here is that the earlier budgets were set far too loosely, so that they have to be substantially overachieved in order to reach the UK’s NDC in 2030.
The CCC admits this, and yet it has made no attempt to revise its advice in the light of this reality. What is more, emissions from international aviation and shipping are not required to be included in the National Inventory Report until 2033, and emissions embodied in imports are not included at all.
Gigafactories
Therefore, the CCC must bear some of the blame for what I have called the continuing failure of UK climate change mitigation policy, by colluding with the government in attempting to lull the world into a false sense of security.
The new Labour government has been passed a poison chalice. Yet it has no clear plan of its own, and has not yet responded to the CCC’s progress report.
It has policies that are bound to increase emissions, at least in the short term, as well as policies to reduce them. Its overriding emphasis on growth ignores the fact that growth is correlated with increasing emissions: the CCC reported in 2019 that a one per cent change in GDP is associated with 0.3 per cent change in emissions.
Its proposed National Wealth Fund - £7.3 billion over this parliament - reflects its emphasis on growth. Tellingly, its manifesto makes no mention of the increased emissions that will inevitably result from the fund’s investments in ports and supply chains; gigafactories; steel; carbon capture, usage and storage; and green hydrogen. Some of these investments could generate emissions savings in the longer term, but this seems unlikely to happen before 2030.
The key to early progress here is the decarbonisation of electricity but the significance of this has not been fully recognised.
Investment
The previous government was perhaps just beginning to see the light, appointing what is now called the National Energy System Operator, publishing a Connections Action Plan and a Transmission Acceleration Action Plan, setting up a Connections Delivery Board, and at least recognising the need for a Strategic Spatial Energy Plan.
However, the latter plan has not yet materialised, the proposed Energy System Delivery Board does not yet appear to exist, and most recently (June 2024) the Connections Delivery Board reports that the capacity waiting to be connected to the grid has actually increased from 500GW to 714GW since last year, with an average increase in waiting time from five to 5.5 years.
This is without mentioning that the Transmission Acceleration Action Plan aimed only to halve the build time for new transmission infrastructure from about 12-14 to seven years.
This means that even after 2030 electricity would still sometimes fail to get from wind turbines in parts of Scotland to where it is most needed in parts of England (see Gone with the wind? - Carbon Tracker Initiative) and we would continue to rely on gas power stations to keep the lights on.
Staggeringly, it appears that we now have enough low-carbon power to meet electricity demand up to 2030, including for electric vehicles and heat pumps. Without massive investment in the network, however, the system will remain unable to supply that electricity to all the places where and at all the times when it is demanded.
Powered
Aside from the crucial energy sector, the main sectors for climate change mitigation in the UK are transport, buildings, industry and agriculture.
On surface transport the CCC requires a four-fold increase in emissions reduction from 2023 to 2030, largely by replacing fossil-fuelled vehicles with electric ones.
The CCC sees this as occurring incrementally up to 80 per cent of new cars by 2030. The Conservative government went beyond this in 2020 by mandating 100 per cent replacement by 2030 but then in 2023 reverted to the CCC position of 80 per cent by 2030 and phase-out by 2035.
Labour’s 2024 manifesto has now pledged to restore the 100 per cent phase-out date of 2030 but this restoration remains to be confirmed and its impact on emissions reduction assessed.
It is encouraging to note that already, following the 2024 general election, the new chancellor has deferred the A27 bypass and withdrawn the funding for the Stonehenge Tunnel. The latter in particular has saved £3 billion of public money and untold carbon emissions from increased use of petrol/diesel powered vehicles.
Serious
These actions now need to be followed by a cancellation of the ruinously expensive and hugely greenhouse gas emitting Lower Thames Crossing - with costs now estimated at £10 billion.
More generally, the new government needs to make a wider commitment to reducing private transport use and electrifying public transport.
Bringing the railways into public ownership, as promised in the manifesto, should be seen as a means to these ends. Much more than this needs to be done to put surface transport emissions reduction back on track by 2030.
Aviation policy remains inadequate, with no commitment to reducing or even stabilising demand; instead, it seems that airports may be allowed to continue to expand, with increasing numbers of flights over increasing distances.
There is a long-term commitment in the manifesto to the use of so-called ‘sustainable aviation fuel’, but this would still comprise only 10 per cent of total aviation fuel in 2030. This makes it certain that aviation emissions will increase rather than diminish by 2030 - an increasingly serious problem, requiring a multi-pronged solution.
Installed
On buildings, the commitment in Labour’s manifesto to build new homes is similar to that of the previous government before 2022, namely an average of 300,000 homes a year over a five-year parliamentary term, and a presumption in the planning system in favour of new housing development and brownfield sites.
Homes are still not being built to a low-carbon standard, with the inevitable implication of increasing greenhouse gas emissions, but this lack of policy is due to change with the introduction of the Future Homes Standard in 2025; a consultation has been carried out earlier in 2024 but the results have not yet been published.
On existing homes, Labour’s manifesto pledges £6.6 billion to upgrade five million ‘British’ homes over the current parliament (2024-2028). If continued at this rate to 2050, this would lead to the upgrading of the entire housing stock of Britain.
However, the funding pledged here works out at only £1,300 per home, so can hardly be expected to provide an adequate upgrade in most cases, even if it is supplemented by a heat pump grant.
Labour promises that: "Nobody will be forced to rip out their boiler as a result of our plans." To keep to this promise, however, the government will need to reverse the previous government’s exemption of 20 per cent of households from the 2035 phase out of fossil fuel boiler installations - because otherwise, to reach net zero, boilers installed after 2035 will need to be ‘ripped out’ before they have reached the end of their useful life.
Homes
What is not mentioned in the manifesto is what is to happen to the existing schemes in England and Wales for building decarbonisation, which are all due to run until 2028:
First, the Boiler Upgrade Scheme provides a grant of £7,500 to help buy a heat pump to replace a gas or oil domestic boiler, with total funding of £1.5 billion for 2025-28.
The number of installations is increasing but falls well short of the 600,000 a year that the government expects by 2028 - which is hardly surprising since, by my calculation, £1.5 billion will fund only 200,000 heat pump grants.
Second, the Social Housing Decarbonisation Fund is likely to have upgraded around 200,000 social housing homes at a cost of around £2.1 billion by 2028 - again, only a small minority of the homes that need an upgrade.
Third, by 2028 the Public Sector Decarbonisation Scheme will have upgraded tens of thousands of public buildings at a cost of around £3.67 billion.
Piecemeal
Overall, these schemes look like a considerable investment, but actually they still leave most homes and public buildings in England and Wales untouched, and Labour has as yet no policy to extend them beyond 2028. It seems, therefore, that we will just have to wait to hear what the chancellor has to say on 30 October 2024.
Also not mentioned in Labour’s manifesto is the Clean heat market mechanism. Under the previous government, this was due to be introduced in the UK in April 2024 but at the last minute was postponed to April 2025.
If Labour agrees, it will impose a requirement for heat pumps to make up a minimum percentage of each boiler manufacturer’s sales each year, starting at six per cent in 2025 - similar to the electric vehicle mandate mentioned above.
Increases in this percentage will be by agreement, but presumably up to 100 per cent heat pumps by 2035 - so long as it doesn't force some households to rip out their boiler?
The overall approach to decarbonising buildings looks piecemeal when arguably what is required is a national retrofitting plan, with greater clarity on what is to be achieved in terms of energy efficiency standards and emissions reductions by 2030 and beyond.
Technologies
On industry, there are some clear positives, such as the decommissioning of Tata Steel’s two blast furnaces, although the government has not yet approved funding for British Steel’s plans to replace its blast furnace with two electric arc furnaces.
More generally, however, investment in infrastructure, though sorely needed in many cases, is more likely to increase emissions than reduce them.
What is required here is thorough assessment of the environmental impact of every project seeking funding from the proposed National Wealth Fund, and a requirement to show that any negative impact is outweighed by the project’s climate and nature benefits.
It cannot be assumed that all investment is ‘good’ investment, and even ‘good’ investment may not be straightforwardly climate-positive.
The government needs to provide greater clarity on this crucial issue, especially in relation to controversial technologies such as carbon capture and storage.
Sink
Consideration could be given, for example, to introducing a mandate, similar to those for electrification of vehicles and heating systems, for companies to progressively reduce the carbon footprint of their activities.
Another possible option would be an annually increasing carbon tax, although this risks incurring higher prices rather than decarbonisation.
Agriculture represents the weakest policy area of all. One has only to consider the fact that methane, the most powerful greenhouse gas, is emitted largely by ruminants - that is, cows and sheep, to conclude that climate change mitigation policy should focus particularly on animal agriculture.
The Environment Agency claims to have an Action Plan to deal with the problem but unfortunately there don’t appear to be any specific actions in it.
Following the ending of the EU’s Common Agricultural Policy for the UK, there was a unique opportunity to transform agriculture from a carbon source into a carbon sink.
Priority
The government has provided funding to incentivise sustainable farming under the Environmental Land Management Scheme - ELMS in place of the former policy of hand-outs based on farm size with the Basic Payment Scheme. But business has continued more or less as usual.
There are welcome signs of a move towards agroecological practices, especially agroforestry, no-till, cover cropping, and so on. But not yet on the scale required. This has been usefully discussed by B Nogrady in their paper ‘Farming techniques that protect the planet’ published by Nature.
The CCC expects a shift away from animal-based diets and towards more plant-based diets, thus not only reducing methane emissions but also freeing up a certain amount of land currently used for growing animal feed.
The CCC also thinks that much of this land could be used for growing bioenergy crops. Up to now, however, governments have tended to ignore the CCC on the whole issue of food and farming, and have no policy to encourage a major change in people’s diets or even to increase bioenergy crops.
The new Labour government seems little different here. There is no mention of agriculture in the King’s Speech, confirming that it is not a priority for this government.
Subsidy
The CCC has seen tree planting and peatland restoration as particularly important, for absorbing carbon as well as for reducing emissions. A complication here, however, is that policy is devolved to England, Scotland, Wales and Northern Ireland.
For England, at least, a target was set in 2020 to plant 7,500 Ha a year of trees by 2024-25. After a slow start, the number of hectares planted increased sharply from around 2,000 Ha in 2020 to reach 5,529 Ha in 2023-24, with an estimated 7.1 million trees planted in the latter year. The target of 7,500 Ha therefore now looks within reach.
In Scotland, where traditionally more trees are planted (around 10,000 Ha a year), a target was set in 2020 to plant 18,000 Ha of trees in 2024-25. This target also now looks within reach, with 15,000 Ha being planted in 2023-24 - an estimated 30 million trees.
So it seems that the CCC may have got it wrong when they said the UK as a whole was off track to reach its target of 30,000 Ha of tree planting by 2025 - at least in the cases of Scotland and England.
At the risk of stating the obvious here, an emphasis on increasing the number of trees is not compatible with a practice of mass burning of clearly felled trees such as carried out by Drax for the purpose of generating electricity - an estimated 25 million trees a year emitting 13MtCO2, with the help of billions of pounds of government subsidy.
Investment
Peatland can be of great value for absorbing carbon. However, much of it is so degraded that it emits carbon instead - as much as 15 per cent of Scotland’s total emissions.
Two-thirds of the UK’s peatland is in Scotland, and nearly three-quarters of this is damaged, which amounts to 1.5 million Ha. Scotland’s Peatland Action programme restored a record 10,360 Ha of damaged peatland in 2023-24, with the help of £250 million investment. At this rate, however, total restoration would take around 145 years.
The CCC’s target for the UK of 32,000 Ha a year by 2026 looks less daunting, but to meet even this target would require a step change in restoration efforts across the UK.
In England, DEFRA recently provided £50 million to restore 35,000 ha of peatland, but, given that 87 per cent of England’s peatland is degraded, even at this rate per year a full restoration would take up to 25 years.
It can therefore be concluded that current policies on peatland restoration are not sufficiently ambitious and a much higher level of public investment is required.
Viable
The lack of a sense of political urgency on peatland restoration is exemplified by the government’s continuing failure to implement a ban on selling peat, even if only for amateur horticultural use.
Unsurprisingly, perhaps, Labour has not explicitly committed to such a ban. Indeed, it does not seem to recognise the importance of peatland for the future of our climate. Its manifesto states: "Labour will expand nature-rich habitats such as wetlands, peat bogs and forests so families can explore and wildlife can thrive".
This suggests that Labour sees nature as only a resource to be consumed - as in the case of Drax’s tree-burning - rather than as the foundation of our very existence.
Technologies of carbon capture, usage and storage (CCUS) and of engineered carbon dioxide removals have always featured in the climate change mitigation policies of the CCC and UK government, not to mention the UNFCCC.
As the climate crisis worsens, and as progress in solving it becomes increasingly off-track, the emphasis on these technologies has grown. At the same time, however, they remain stubbornly under-developed, costly, and heavily dependent on government subsidy in order to be economically viable.
Progress
Recent research has now shown that CCS reduces greenhouse gas emissions much less than has been claimed by its advocates, meaning that gas firing with CCS is not a low-carbon process so cannot help us to decarbonise.
Nevertheless, Labour’s manifesto commits to an investment of £1 billion for CCUS over the next five years. This is money that could be more usefully spent elsewhere: on boosting renewable energy generation, improving the electricity network, electrifying industry and public transport, retrofitting homes, and on any other measures that are shown to drive forward the energy transition.
To end on a positive note, Labour’s manifesto promises to mandate financial institutions and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5℃ goal of the Paris Agreement. We can but look forward to such a mandate - a deadline of end of 2026 would not be unreasonable.
Taken as a whole, UK climate change mitigation policy is not a complete failure but is simply not making sufficient progress, even to meet some of the relatively conservative goals set by the CCC. The UK continues to lack a fully credible plan to reach either its NDC goal for 2030 or its net zero goal for 2050.
This Author
Professor Peter Somerville is emeritus professor of social policy at the College of Social Science, University of Lincoln.