RSE Inquiry Into Facing up to Climate Change Response by Aberdeen City Council 3Rd March 2010

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RSE Inquiry into Facing up to Climate Change Response by Aberdeen City Council 3rd March 2010

Q1: Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

Yes, it is expected that Scotland will have more extreme weather with warmer, wetter winters and sea levels rises of up to 600mm. Aberdeen is situated on the North East Coast of Scotland; therefore such weather patterns would threaten Aberdeen’s coastal areas and present an increased risk of flooding.

In anticipation of such weather events a Flood Appraisal Group has been established in order to look at developing an approach towards prevention of flooding. This group includes officers from the City Council, Aberdeenshire Council and SEPA.

A coastal defence scheme has also been progressed called the Aberdeen Bay Coastal Defence Modelling Study and Final Design to Complement the Dynamic Environment of Aberdeen.

Sustainable Urban Drainage Systems (SUDS) are implemented for the drainage of all new road schemes and developments within the City. Flood studies, relating to capacity of water courses, have been carried out for the Gilcomston Burn, Glashie Burn and Den Burn. In order to meet statutory requirements for flood prevention and land drainage, the Council has considered recruiting additional members of staff to research and model the potential impacts from flooding and coastal erosion.

An increase in severe weather events, such as the snow fall experienced in early 2010 will affect the Councils contingency planning and operational services.

In addition the Council’s Nature Conservation Strategy 2010-2015 proposes to monitor progress in the development of guidance which will help the Council deal with the effects of climate change and future nature conservation. It also aims to conserve nature following current best practice and will be prepared to adapt its procedures based on the influence of Climate Change and associated appropriate direction.

Q2: What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? Aberdeen City Council was an early UK leader in addressing corporate and community climate change matters. It published its Climate Change Action Plan in 2002 and its first Carbon Management Programme (for its own operations) in 2004 when it committed to a CO2 reduction target of 10% by 2010, and a further 15% by 2015 for its buildings, street lighting, fleet and business miles, based on its 2002/03 baseline.

The Council is now undertaking the Carbon Management Programme for the second time and has set further ambitious targets of a 23% reduction in carbon emissions by 2015 and 42% by 2020 based on a 2008-2009 baseline. The Carbon Management plan proposes to account for carbon impacts within all future capital investments. Carbon emissions will be used as one of the measures to gauge the merit of Business Cases.

With the forthcoming introduction of the Carbon Reduction Commitment, the Council realises the importance of carbon management, particularly when a monetary value is placed on carbon. It is anticipated that the CRC will act as a legislative driver to promote investment into the Council’s Carbon Management Plan 2010-2015.

Q3: What do you plan to do in response to these factors over the next 5-10 years? Aberdeen City Council is committed to reducing its carbon footprint in order to contribute to delivery of the Climate Change (Scotland) Act's emissions reduction targets. Therefore, in May 2009 signed up to undertake the Carbon Management Programme for the second time as well as signing up to the 10:10 campaign. The Carbon Management Programme has the benefit of ensuring the Council concentrate efforts on the areas of biggest CO2 reduction gains and is fit for the variety of new legislative requirement to address carbon management for example the Carbon Reduction Commitment (CRC).

Aberdeen City Council qualifies under the CRC and is taking steps to prepare for its introduction. For example in December 2009 the Council was awarded the Carbon Trust Standard which not only acts as an early action metric under the CRC, but proves that the Council have continued to decrease their carbon emissions over the past 3 years.

The Council also has an Energy Strategy (2003) and a Decentralised Energy Programme (2008) which commits to the installation of an onsite energy generation system to all new build Council properties and replacement of heating and hot water systems in existing Council owned buildings as the normal default position as well as adopting an annual target of a 2.5% reduction in fuel purchased on the bulk contracts for properties owned by this Council to apply over the next 10 years.

Future carbon reducing initiatives include: • Combined Heat & Power: discussions are ongoing to extend the Seaton CHP installation by adding another generator to increase the capacity to 3MW electrical output and 4.2MW of heat. As well as plans to change the fuel supply from natural gas to biomass. Further plans include the development of a city centre network to link with other blocks of flats and public buildings. The longer term aim is to develop a ‘ring main’ of multiple CHP stations run on a variety of fuels.

• Low Carbon City Wide Strategy: the Council are planning to develop a Low Carbon City Wide Strategy in order to co-ordinate renewable energy approaches across the City. This strategy will make recommendations on low carbon approaches to be taken in different

areas of the city focusing on such issues as densities, proximity to possible district heating network, type of energy demand (residential or industrial), renewable resource (water, sun, wind).

• Low Emissions Zone in the City Centre. The draft Air Quality Action Plan for Aberdeen has identified that a LEZ will have the most impact for improving air quality in the city centre. Although the LEZ is not expected to reduce carbon emissions it will impact upon particulate matter and nitrates – both of which contribute towards climate change.

Aberdeen City Council is also a signatory to several climate change commitments including:

2009 • Scottish Business in the Community Climate Change Pledge • World Energy Cities Partnership: Calgary Climate Change Accord • Local Authority Carbon Management Programme • EU Covenant of Mayors • 10:10 Pledge 2007 • Scottish Climate Change Declaration 2004 • Aalborg Commitments 2001 • ICLEI Cities for Climate Protection Campaign 1996 • Aalborg Charter for Sustainable Development

Q4: How integrated is your response with other organisations in similar or related fields?

Aberdeen City Council is a member of the North East Climate Change Partnership (a partnership of 17 organisations based in the Grampian area) who are also taking part in the Inquiry.

Q5: What are the main barriers to change for you and/or your organisation?

Meeting targets: such as those set under the Climate Change (Scotland) Act and Carbon Management Plan is going to be the main challenge. The Council’s emissions profile shows that buildings are our biggest emitters. Schools are responsible for 18% of the Council’s carbon footprint. At present the Energy Management Team works with Schools to reduce energy consumption. The Council are also undertaking a project to replace inefficient school buildings with new efficient buildings through PPP’s.

Reporting: issue of using a variety of methods for measuring baselines and performance to meet targets e.g. Carbon Trust Standard, Carbon Reduction Commitment etc all use different reporting techniques.

Funding: issue of lack of own funds to undertake energy efficiency. With competing Council priorities and decreasing budgets (a trend which is set to continue) often operational requirements are prioritised above carbon management. A resolution to this would be to introduce a fund dedicated to implementing carbon reduction projects which we hope to do through the Carbon Management Plan.

Senior Management Support: embedding sustainable development in governance and strategies as well as gaining private sector and public engagement /buy in;

Economic growth: pressure to maintain/increase economic and population growth in the region. In addition the delivery of housing growth and the need for sustainable communities.

Scepticism: disconnect between transport issues and the impact on the environment in the minds of the public, officers, senior management and councillors or apathy due to convenience of the car.

Q6: What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

The CRC has the potential to benefit Aberdeen City Council, as comparisons will be made with large private companies who may not have considered carbon management previously.

Transport: Q: How could the Council’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

A: Given the responsibility of the Council as a major employer in the City and an organisation for leading by example it is virtually impossible to separate out the measures that should be applied across the Council from the approach that should be taken City- wide. It is also true to say that when looking at transport emissions the focus tends to be on improving vehicle technology. There is a real misunderstanding if this is touted as the solution; improvements in technology may reduce transport emissions but they wont solve other problems of congestion, safety and health, which in turn have economic and social implications. Ultimately if everyone had a non-polluting private vehicle the whole transport network would grind to a, albeit cleaner aired, halt. There is a wider requirement to address the issue of modal split and shift which then brings in elementary questions of how this is delivered and funded.

For the Council’s transport emissions to be cut by 30% there would have to be an overhaul of the vehicle fleet to alternatively fuelled vehicles. However this comes with its own implications:

• Finance: AFVs are more expensive to purchase than petrol or diesel vehicles; • Infrastructure and fuel supply: available charging infrastructure and charging points or fuelling stations and questions over whether the national grid can take the pressure of additional drains on the electricity supply if we pursue electric vehicles; • Servicing and expertise; • Journey length: questions of how we would complete longer distance journeys when looking at electric vehicles; • Lifecycle: when considering the lifecycle of AFVs vehicles – from manufacture to ‘retirement’ – the energy required to build the model, whether the vehicle is imported, and the implications of dismantling it – AFVs perform extremely badly with these considerations built in. • Fuel type: fuel used to supply energy to the vehicles – biofuels can have serious implications e.g. rainforests

If not looking at AFVs then there are several other considerations: cleaner engines may have less CO2 emissions, but they are less fuel efficient. In addition the argument appears to focus on carbon emissions – in reality nitrates and particulate matter also contribute towards climate change, but are lost in the overall picture – and are far more relevant to transport, especially when looking at air quality issues. Unfortunately, unlike some of our European neighbours, we have not adopted a full scale system of carbon emissions for vehicles. Whilst any new vehicle must display its carbon credentials on purchase this is not true of older vehicles. This makes it more difficult for local authorities to look at simple schemes that try to influence modal shift and air quality – such as emission based parking charges or access only areas for lower polluting vehicles (charging can apply to residents but not easily transferred to commuter or visitors). Otherwise LA’s have to go down the whole congestion charging route which is extremely capital intensive. In Germany all vehicles have to display their carbon emission type and the most environmentally friendly ones are allowed in LEZ’s or have priority parking.

Whilst transport is the fastest growing source of emissions there is a disconnect with the public. Certainly in Aberdeen people seem to readily identify climate change with turning the thermostat down by one degree, or the environment and recycling, but ask them to consider their transport mode to work and there is a huge amount of resistance. This all then leads to wider questions of whether alternative options are available at a reasonable price and is linked to transport policy and funding. Given the opportunity most Local Authorities appear to advocate a policy of accommodating demand rather than addressing the problem, and use economic arguments to justify the decision. Fundamentally however, transport and the promotion of alternatives is not a statutory requirement for any Local Authority – unlike south of the border. We produce Local Transport Strategy’s to justify spend on transport but there is no wider monitoring of these or necessity to implement. In addition the question of funding has to be considered as part of this. For instance, the Cycling Action Plan for Scotland suggests that 10% of all journeys are by bike by 2020; a laudable target that will contribute towards the climate change ambitions and assist with reducing transport emissions. However no additional funding has been set aside for this – so this is an issue that is reflected at higher levels within the Scottish Government.

The loss of ring-fenced monies through the introduction of the Single Outcome Agreement will likely have an unfortunate effect on the spend on projects that support active or public travel. The loss of Cycling, Walking and Safer Street, the School Travel Plan Coordinator post, the funding allocated to Regional Transport Partnerships and through various bodies like Sustrans are all having an impact on Aberdeen spend on sustainable transport modes. Despite being highly commended for best practice in school travel plans, in March, Aberdeen will become the only local authority without a school travel plan coordinator – although from informal discussions with other local authorities it appears that Aberdeen may in fact be a precursor as other local authorities follow suit.

Compounding some of the issues is the requirement for the Aberdeen City and Shire region to grow. With a total of 56,300 proposed houses in the City and Shire over the next 20 years the likelihood of meeting at 30% reduction in transport emissions is very slim unless significant steps are undertaken to identify how this might be achieved and where the funding is going to come from. Unless there is a statutory requirement to produce transport plans with far reaching air quality targets and with associated budgets for progression of sustainable transport modes it is unlikely that the target will be met in Aberdeen – as any national improvements in technology will no doubt be lost with the increase in population.

Facing up to Climate Change

The UNISON Scotland subm ission to the Royal Society of Edinburgh’s Inquiry: Facing up to Climate Change.

M ay 2010 Introduction This paper constitutes UNISON Scotland’s submission to the major Inquiry by the Royal Society of Edinburgh (RSE), entitled ‘Facing up to Climate Change’.

UNISON Scotland welcomes the opportunity to provide written evidence to the Inquiry. UNISON is Scotland’s largest public service trade union, representing more than 160,000 members working largely in the public sector in Scotland. Many of our members are at the forefront of protecting the environment and the quality of life for everyone in Scotland.

The RSE has said the Inquiry will seek “to raise awareness of the opportunities and the challenges ahead, both from climate change and from a move to a low carbon economy. It will attempt to identify how individuals, communities and industries can turn these challenges into a positive opportunity.”

W e will concentrate on what the public sector could be doing to lead by example on reducing greenhouse gas emissions and adapting to climate change. In doing so, we will touch on the economic crisis and an international trade union response that emphasises a ‘Just Transition’1 to a low carbon economy. The Climate Change (Scotland) Act 2009 UNISON is particularly pleased that the Climate Change (Scotland) Act 2009 sets a statutory climate change duty2 on all public bodies. The new duty says that public bodies, in carrying out their functions, must:

Act in the way best calculated to contribute to the delivery of the greenhouse gas emissions reduction targets in the Act

Act in the way best calculated to help deliver any adaptation programme laid before the Scottish Parliament under the Act

Act in the way they consider is most sustainable.

This duty will help ensure that the entire public sector, including councils and the NHS, plays its part in not just contributing to mitigation and adaptation work, but in the crucial role of leading by example. (Ministers should also set in place proper reporting and monitoring of the duty.) Individuals are limited in what they can do alone. W e need collective action by governments, the public and private sector, communities, families and individuals. Public services are on the frontline in fighting climate change here and internationally. W ell resourced public services can help set an example of sustainable operation and help protect us from those effects of climate change that are already inevitable.

Achieving the targets in the Act The Scottish Parliament unanimously agreed to the ambitious 42% and 80% targets in the Act. That cross-party political support will now have to be reflected in how our politicians work together in the coming years to make the often difficult decisions that must be taken for a just transition to a low-carbon economy.

1 ‘Just Transition’ recognises that support for environmental policies are conditional on a fair distribution of the costs and benefits of those policies across the economy, and on the creation of opportunities for active engagement by those affected in determining the future wellbeing of themselves and their families. TUC Report: www.tuc.org.uk/touchstone/Justtransition/greenfuture.pdf 2 www.scotland.gov.uk/Topics/Environment/climatechange/scotlands-action/climatechangeact/publicsector

These decisions should include major energy efficiency initiatives across all sectors, massive investment in renewable energy, a shift in transport spending from aviation and roads to public and active transport, using procurement to help drive sustainable green policies and initiating green workplace action across Scotland. The public sector is vital in taking a lead and promoting best practice. The considerable employment benefits from these policies should be maximised through a ‘Green New Deal’. This should be not just about creating jobs in new areas such as renewable energy, but about greening the economy as a whole. The jobs potential is enormous but requires government policies that support and encourage that potential instead of the crazy situation last summer when the Vestas factory in the Isle of W ight was closed, leaving the UK with no major wind turbine manufacturing facility, while there is only one of any scale in Scotland.

Trade unions see climate change as an urgent health and safety issue for the planet. W ith the Scottish Trades Union Congress (STUC), we are calling for a comprehensive low carbon industrial strategy for Scotland, a transitional skills strategy, a Just Transition strategy and a green workplaces strategy. These should also take in adaptation measures. W e welcome the May 2009 STUC/Scottish Government Communiqué on Climate Change3, which included agreement that:

Addressing climate change can deliver significant economic, social and environmental benefits to Scotland. The creation of quality jobs through the transition to a low-carbon economy represents a major economic opportunity for Scotland. The transition to a sustainable economy needs to be socially just so that all parts of society partake in the benefits of growth and responsibilities are shared fairly. Addressing the economic, employment and social impacts of the transition to the low-carbon economy and adapting to climate change will be vital to building stakeholder support and delivering the necessary programmes of action.

W e look forward to the partnership working promised in the communiqué and welcome the support for quality secure employment, skills/training, green workplaces, Just Transition and for government policy on climate change contributing to “community cohesion and reducing inequalities”.

UNISON strongly supports a balanced energy strategy, with renewables key, while also including contributions from clean coal (requiring investment in carbon capture and storage) and nuclear power. W e oppose the privatisation or mutualisation of Scottish W ater, which should remain under democratic control. The importance of democratic controls applies in many areas, including over regulation of the banks and the financial markets. This was stressed as part of the ‘Jobs, Justice, Climate’ themes of one of our big campaigns last year with the Put People First coalition. In our conclusion, we stress that action on Climate needs action on Jobs and Justice. They are interlinked and interdependent. These links are exemplified in UNISON’s Food for Good Charter4. It encourages the use of fair trade and locally sourced, organic, sustainable food in schools, hospitals, prisons and across the public sector. Green procurement is effective.

Many of the above policies will require significant behaviour change (as happened in boosting recycling). There is a key role for the public sector here too, in raising awareness and facilitating such change, including in the workplace.

3 www.stuc.org.uk/news/643/stuc-and-scottish-government-issue-joint-communique-on-climate-change 4 www.unison-scotland.org.uk/briefings/foodforgoodcharter.pdf

Green workplaces UNISON has long campaigned on sustainable development and for action to green the workplace. This contributes to greenhouse gas emission reductions both at work and at home as employees bring ideas from home to work and vice versa. The STUC/Scottish Government Communiqué on Climate Change agreed on the need for policies to green the Scottish workplace.

UNISON urges the Royal Society to include in its report the importance of workplace action across the public and private sectors, including on adaptation.

W e would highlight the lessons learned from the TUC Green W orkplaces Project Report 2008-105. These showed the importance of joint initiatives by trade unions and management in securing workforce buy-in and making significant reductions in emissions. The report also stressed the need for the active engagement of senior management and for putting in place formal structures, with time off for green reps to carry out environmental duties. More work on taking this agenda forward is currently being planned by trade unions in Scotland. UNISON’s South Lanarkshire branch has recently secured funding for a trade union climate change project across several employers that could provide lessons for similar work6.

W e want workplace action to also include work on adaptation. The 2009 TUC Report ‘Changing W ork in a Changing Climate’7 shows the need for employers to look at 'inward-facing adaptation' - the impacts on workers of adaptation measures and how they are designed, planned and implemented. M any employers have started, or are starting, to assess the impacts of climate change on their business planning, markets or services - 'outward-facing adaptation'. However, much more must be done on ‘inward’ adaptation, which covers things like: health and safety and climate hazards at work; “issues around statutory responsibilities and funding for dealing with extreme events such as floods: and about indoor and outdoor working conditions including workplace temperatures and equipment, clothing and shift patterns to deal with more gradual changes”.

Financial crisis – a trade union response An apparent obstacle to implementing some of the necessary measures will be the impact on public sector spending of the recent financial crisis and the costs of the bank bailout. However, UNISON, along with many others, believes that the financial and environmental crises can provide the opportunity to lay the foundations for a fairer world instead of the existing systems which reinforce high levels of poverty and inequality and which have exploited the planet’s resources to near breaking point. W e dispute the need for urgent major cuts in public spending8 and the 2006 Stern Review made clear that the cost of strong, early action on climate change is considerably less than the cost of delaying.

Scotland’s Climate Change Delivery Plan, published in June 2009, stated: “The economic costs of transformational change to Scotland’s economy and society to meet our climate change targets are not high relative to total economic output over the next 40 years.” W ith the political will, meeting the Act’s targets is achievable.

5 www.tuc.org.uk/extras/greenworkplacesreport.pdf 6 www.unison-scotland.org.uk/news/2010/marapr/3103.htm 7 www.tuc.org.uk/extras/adaptation.pdf 8 See UNISON’s alternative budget: www.unison.org.uk/acrobat/18887.pdf

W e are campaigning to highlight the need for continued stimulus to prevent a double dip recession, for investment in decent public services and a Green New Deal that will create jobs and deliver significant savings through energy efficiency measures. ‘Spend to save’ funds must be available to ensure energy saving schemes can be started straight away. W e will oppose cuts that threaten important climate change action and monitoring; for example, cuts to Scotland’s National Parks or to the Scottish Environment Protection Agency.

Stimulus funds and financial policies must be used to ensure banks, particularly those that received huge bailouts, make environmentally sound investments locally and internationally. UNISON has called for the bankers’ bonuses tax to be made permanent, for a financial transactions tax, action on tax avoidance and a levy to make banks pay back the full costs of the bailout.

UNISON’s internal green agenda UNISON has a strong internal policy, alongside our external campaigning work and efforts to build a network of environmental representatives. The union has introduced video conferencing, mains water coolers, energy efficiency measures, recycling and green travel to work policies. W e will now be striving to make improvements in all these areas.

Conclusion Action on climate change is necessary for the world to survive as we know it. Action on justice and jobs will create the conditions for building a just society where people in every country are fairly rewarded for their labours, have decent jobs and public services and have hope for their children’s future. Action on jobs without thinking about the climate would risk continuing the damage to the planet caused by high greenhouse gas emissions. Action on climate without looking at which countries have historically had the highest carbon emissions would be unfair to the developing world. Economic policies aimed at boosting jobs and switching to a low-carbon economy will not work without democratic and financial regulatory reforms to move away from the culture of greed, consumerism and exploitation that fuelled the credit crunch and led to massive market failure.

Some argue that going green is a luxury when public finances are tight. The reverse is true. W e cannot afford not to green the economy. Jobs, justice and climate are inter-related and together provide the key to creating a better world.

Scotland’s Climate Change Act has been significant internationally, as will be a legally binding United Nations agreement on climate change. But the most important thing we can all do now is make the changes that will protect the planet for future generations. W e hope the Royal Society’s inquiry will emphasise the need for a Just Transition and for workplace action in delivering those changes.

For further information please contact: Matt Smith, Scottish Secretary UNISON Scotland UNISON House 14, W est Campbell Street, Glasgow G2 6RX Tel 0870 7777 006 Fax 0141-331 1203 e-mail matt.smith@ unison.co.uk

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Carbon Resources and carbon dioxide equivalent abatement for 2009 (tonnes) Abatement Feedstock Factor (tCO2/odt Very high High Low feedstock) feedstock feedstock feedstock Total availability Total CA availability Total CA availability CA Straw 0.84 373,032 313,347 216,797 182,109 0 0 Sawmill Residues 1.17 40,000 46,800 20,000 23,400 10,000 11,700 Forestry Residue Chips 1.24 128,000 158,720 64,000 79,360 32,000 39,680

Softwood-small round wood 1.15 174,000 200,100 87,000 100,050 43,500 50,025 Short Rotation Coppice 1.13 2,500 2,825 1,200 1,356 0 0 Construction, demolition and commercial waste wood 1.15 260,000 299,000 130,000 149,500 65,000 74,750 Sewage sludge 0.732 788,000 576,816 394,000 288,408 197,000 144,204

Garden and green waste 0.848 296,000 251,008 148,000 125,504 74,000 62,752 Food waste 1.012 54,000 54,648 27,000 27,324 13,500 13,662 Distilleries grain waste 1.00 70,000 70,000 35,000 35,000 17,500 17,500 Totals 2,185,532 1,973,264 1,122,997 1,012,011 452,500 414,273

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Carbon Resources and carbon dioxide equivalent abatement for 2030 (tonnes) Abatement Feedstock Factor (tCO2/odt Very high High Low feedstock) feedstock feedstock feedstock availability Total CA availability Total CA availability Total CA Straw 0.84 373,032 313,347 216,797 182,109 0 0 Sawmill Residues 1.17 50,000 58,500 25,000 29,250 12,500 14,625 Forestry Residue Chips 1.24 158,000 195,920 79,000 97,960 39,500 48,980

Softwood-small round wood 1.15 545,756 627,619 512,356 589,209 478,956 550,799 Short Rotation Coppice 1.13 360,000 406,800 180,000 203,400 90,000 101,700 Construction, demolition and commercial waste wood 1.15 752,000 864,800 376,000 432,400 188,000 216,200 Sewage sludge 0.732 1,000,000 732,000 500,000 366,000 250,000 183,000 Garden and green waste 0.848 425,000 360,400 212,500 180,200 106,250 90,100 Food waste 1.012 547,000 553,564 273,500 276,782 136,750 138,391 Distilleries grain waste 1.00 70,000 70,000 35,000 35,000 17,500 17,500 Totals 4,280,788 4,182,950 2,410,153 2,392,311 1,319,456 1,361,295

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Carbon Resources and carbon dioxide equivalent abatement for 2050 (tonnes) Abatement Feedstock Factor (tCO2/odt Very high High Low feedstock) feedstock feedstock feedstock availability Total CA availability Total CA availability Total CA Straw 0.84 373,032 313,347 216,797 182,109 0 0 Sawmill Residues 1.17 58,400 68,328 29,200 34,164 14,600 17,082 Forestry Residue Chips 1.24 187,500 232,500 93,750 116,250 46,875 58,125

Softwood-small round wood 1.15 645,956 742,849 579,156 666,029 512,356 589,209 Short Rotation Coppice 1.13 720,000 813,600 360,000 406,800 180,000 203,400

Construction, demolition and commercial waste wood 1.15 752,000 864,800 376,000 432,400 188,000 216,200 Sewage sludge 0.732 1,000,000 732,000 500,000 366,000 250,000 183,000 Garden and green waste 0.848 425,000 360,400 212,500 180,200 106,250 90,100 Food waste 1.012 547,000 553,564 273,500 276,782 136,750 138,391 Distilleries grain waste 1 70,000 70,000 35,000 35,000 17,500 17,500 Totals 4,778,888 4,751,388 2,675,903 2,695,735 1,452,331 1,513,007

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Response of UK COAL Mining Limited to the Royal Society of Edinburgh Inquiry into Facing up to Climate Change

Introduction

1. UK COAL Mining Limited (UKC) is the UK’s largest coal producer accounting for around 45% of UK production. Around 95% of our annual 8 million tonne production goes to the electricity generation industry. The Group has four deep mines located in Central and Northern England with substantial reserves and employs 3,100 people. UKC has recently secured planning permission to work the Blair House surface mine in Fife.

2. We welcome the invitation to contribute to the Royal Society of Edinburgh (RSE) inquiry into Facing up to Climate Change. UKC is fully committed to reduce its own carbon footprint and was recently awarded the prestigious Carbon Trust Standard for its work in this area. However this response focuses on the need to develop carbon capture and storage as a means to delivering secure, affordable and low carbon supplies of energy.

Coal within the Current UK Energy Mix

3. Energy is a necessary prerequisite of a modern economy, in terms of its development and political stability. In the UK, our energy strategy comprises of three main strands; security, low carbon and affordability.

4. Coal is a major energy source within the UK, accounting for around one third of electricity generated in 2008. In 2008 electricity generators consumed 47.8Mt and this sector accounts for over 80% of UK coal demand.

5. Coal-fired power stations provide security and diversity of supply. They are also able to respond more quickly to peaks in demand on the electricity grid than either gas or nuclear stations. This provides a vital load following capability, which ensures that the National Grid is able to meet fluctuations in electricity demand.

6. The UK is facing energy security challenges presented by a dramatically changing global economic, geopolitical and energy landscape. Global reserves of oil and gas are increasingly concentrated in a limited number of countries and there is a clear risk that global supplies will not keep pace with demand.

7. The current winter cold spell has highlighted our reliance on gas with two national balancing alerts in the first week of January and many industrial consumers having their supply cut off. Future planned gas build will exacerbate this position.

8. Coal generation, therefore is vital to the UK’s diversity and security of energy supplies especially at time of dwindling indigenous gas supplies and volatile international energy markets.

Coal within a Future UK Energy Mix

9. Looking forward coal can contribute to a low carbon future via the introduction of carbon capture and storage (CCS) technology. A fleet of clean coal stations with CCS would allow indigenous coal production to contribute to the UK’s security of

1 energy supply by limiting energy imports from either unstable or potentially unstable countries.

10. CCS technology is the only currently available technology that allows very deep cuts to be made in CO2 emissions to atmosphere from fossil fuels at the scale needed. CCS has been demonstrated in a few small projects around the world but would require to be scaled up to handle emissions from the electricity sector.

11. The Committee for Climate Change (CCC) have stated that ‘any path to an 80% reduction by 2050 requires that electricity generation is almost entirely decarbonised by 2030’, (page 173, Building a Low Carbon Economy December 2008). In order to achieve this we need wide scale CCS deployment as soon as possible.

12. The CCC however goes on to warn of the consequences of only applying CCS to coal fired plant; ‘Investors choose to invest in increasingly expensive gas-fired rather than low-carbon generation through the 2020s, resulting in deviation from the path towards meeting long-term targets’ and ‘These scenarios lead to lock in to high-carbon assets and failure to make sufficient progress with decarbonisation by 2030’.

13. The Chancellor in his Pre Budget Report (December 2009) announced that financial support would be given to fund four demonstration projects. These projects would be at a level (400MW) previously not demonstrated and there would be a requirement on the operator to retrofit to later retrofit CCS on the non abated capacity by 2025. The Government also intend to review progress on CCS in 2018.

14. Current Government policy is that all new fossil fuel generating stations must be constructed carbon capture ready, but new coal stations must in addition demonstrate the full CCS chain on at least 400MW of capacity.

15. Support for four CCS demonstration projects whilst to be welcomed as an important first step, will not maintain coal’s current position in the UK’s future energy mix. There is a danger that all existing coal stations (28GW) will have closed by 2023 because of a combination of the LCPD and IED, leaving only the 4 demonstration CCS stations in existence. This would push coal out to the margins within the UK and make it difficult for continued investment within coal production industry. UKC is facing such problems in trying to reopen Harworth Colliery1.

1 Harworth Colliery is situated in North Nottinghamshire and is currently mothballed following the exhaustion of the reserves in the Deep Soft seam in 2006. Boreholes and seismic exploration have identified up to 54Mt in the Top Hard seam which would be suitable for the local power station market. If the project went ahead the mine would produce in excess of 2 Mt per annum, which would directly replace imports as well as providing employment for 550 employees. The overall cost of the scheme would be around £200m and in the current economic climate UK COAL has approached the European Investment Bank (EIB) as a possible source of finance. UK COAL has been told that although the scheme meets the criteria for funding in terms of creating jobs in an area of high unemployment, security of supply and return on investment; it fails in terms of its ‘low carbon green credentials’. Therefore in order to secure funding from the EIB, they would require coal to be sold to a power station with CCS installed. Hence a further urgent need from a coal producer’s perspective to see CCS up and running within the UK as soon as possible.

2 16. For a number of potential replacement CCS coal stations to be operationally ready by 2023 will require the Government’s CCS review to reach its conclusion much earlier than 2018 planned. This is due to the lengthy time required for design, planning and construction of a new coal plant within the UK.

17. The UK Government needs to map out how it envisages the next tranche of coal stations to be deployed to ensure coal continues to play a meaningful role in the UK’s energy mix.

CCS Worldwide

18. Coal meets just over one quarter of the world’s demand for primary energy, 40% of the world’s electricity and two thirds of the world’s steel and is the fastest growing fuel around the globe.

19. Countries such as China and India are sitting on vast reserves of coal and with little other natural resources it is inconceivable that they will not use these reserves to fuel their ever expanding economy. China already mines around 40% of the world’s coal production and this volume is forecast to double by 2030 to meet internal demand.

20. Current trends in energy supply and use are patently unsustainable – economically, environmentally and socially. Without decisive action, energy- related emissions of CO2 will more than double by 2050. We can and must change our current path, but this will take an energy revolution and low-carbon energy technologies will have a crucial role to play.

21. CCS is an important part of the lowest-cost greenhouse gas (GHG) mitigation portfolio. International Energy Agency (IEA) analysis suggests that without CCS, overall costs to reduce emissions to 2005 levels by 2050 increase by 70%. They have produced a roadmap which includes an ambitious CCS growth path in order to achieve this GHG mitigation potential, envisioning 100 projects globally by 2020 and over 3,000 projects by 2050.

22. This roadmap’s level of project development requires an additional investment of over USD 2.5-3 trillion from 2010 to 2050, which is about 6% of the overall investment needed to achieve a 50% reduction in GHG emissions by 2050. OECD governments will need to increase funding for CCS demonstration projects to an average annual level of USD 3.5 to 4 billion (bn) from 2010 to 2020. In addition, mechanisms need to be established to incentivise commercialisation beyond 2020 in the form of mandates, GHG reduction incentives, tax rebates or other financing mechanisms.

23. Although the developed world must lead the CCS effort in the next decade, CCS technology must also spread rapidly to the developing world,China in particular must widely adopt CCS. This growth will require expanded international collaboration and financing for CCS demonstration in developing countries at an average annual level of USD 1.5 to 2.5 bn from 2010 to 2020. To provide this funding, CCS needs to be approved in the Clean Development Mechanism2 or an alternative financing mechanism.

2 Part of the Kyoto Protocol

3 24. CCS is more than a strategy for “clean coal.” CCS technology must also be adopted by biomass and gas power plants; in the fuel transformation and gas processing sectors; and in emissions-intensive industrial sectors like cement, iron and steel, chemicals, and pulp and paper.

25. CO2 capture technology is available today, but the associated costs need to be lowered and the technology still needs to be demonstrated at commercial scale. Additional research and development is also needed, particularly to address different CO2 streams from industrial sources and to test biomass and hydrogen production with CCS.

26. CO2 transport via pipeline has been proven; the challenge for the future of transport technology is to develop long-term strategies for CO2 source clusters and CO2 pipeline networks that optimise source-to-sink transmission of CO2. To address this challenge, governments need to initiate regional planning exercises and develop incentives for the creation of CO2 transport hubs.

27. There is an urgent need to advance the state of global knowledge of CO2 storage capacity. While depleted oil and gas fields are well mapped and offer promising low cost opportunities, deep saline formations are the most viable option for the long-term. However, only a few regions have adequately mapped the CO2 storage potential of these formations. There is also a need for common international methods for CO2 storage site selection, monitoring and verification, and risk assessment.

Summary

28. Greater emphasis should be placed on indigenous coal as part of a diverse, secure and affordable energy policy.

29. CCS provides a low carbon solution to the continued use of fossil fuels and in particular coal in the UK and around the world.

30. The UK is in a unique position to benefit from the development in CCS technology and become a global leader in this field. Efforts should be made to demonstrate CCS on commercial coal generation plant in a timely manner within the UK.

31. Our geographical situation close to potential storage sites in disused North Sea oil and gas fields and deep saline formations means we have a natural storage site on our doorstep, perhaps sufficient to hold 500 years worth of UK emissions.

32. The UK also has the skill set to take the lead in this field. The expertise within our North Sea oil and gas industry can be transferred, thus maintaining well paid and highly skilled jobs.

33. The UK Government should develop a strategy and support mechanism to ensure CCS is rolled out in a timely manner across all fossil fuels. If gas fired plant is allowed to be built unabated then we will see a further ‘dash for gas’ which will threaten our security of energy, increase the cost to the consumer and result in future carbon lock in over the next 30 years.

4 RSE ‘Inquiry into Facing Up to Climate Change’ Evidence paper from Transform Scotland Friday 30th April

1 Introduction

1.1 Transform Scotland is the national sustainable transport alliance. We are a membership organisation bringing together rail, bus and shipping operators; local authorities; national environment and conservation organisations; local environment and transport campaign groups; and individual supporters. We welcome the opportunity to contribute to the Royal Society of Edinburgh’s inquiry on climate change.

2 Responses to initial questions raised by RSE inquiry

2.1 “Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?”

2.1.1 We firmly believe that changing weather patterns will affect the UK in a significant way. The increasing incidence of severe weather events involving abnormal rain intensity as seen over recent years at Boscastle, Hull, Cockermouth and other locations shows the impact changing weather patterns, caused by rising temperature will have on the country.

2.2 “What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?”

2.2.1 The Climate Change (Scotland) Act will not directly affect Transform Scotland’s activities because our primary role is the promotion of sustainable transport and we demonstrate our commitment to this at staff level by using sustainable transport modes whenever possible and travelling by rail rather than air.

2.3 “What do you plan to do in response to these factors over the next 5-10 years?”

2.3.1 Our plan for the next decade is to continue our campaign to move society to more sustainable transport.

2.4 “How integrated is your response with other organisations in similar or related fields?”

2.4.1 We will continue to closely with the wide range of organisations included in our membership. We also work with transport and government authorities on issues relating to sustainable transport.

2.5 “What are the main barriers to change for you and/or your organisation?”

2.5.1 We see two main barriers: firstly, an increasingly sceptical public; and secondly, government policy promoting unsustainable interventions instead of sustainable ones.

2.5.2 One of the main issues of concern at the moment, we feel, is the degree of public scepticism regarding the reality of climate change, which has been fostered by powerful and well funded industrial lobbying groups. There is genuine concern that significant proportions of the population either do not believe in climate change or that climate change is affected by man and likely to have serious effects on the planet. This is despite the mounting evidence of receding glaciers, melting polar ice, abnormal and increasingly frequent droughts and severe weather events. It is important that the RSE inquiry address these issues by refuting the main sceptic arguments using sound scientific data and analysis but presented in an easily accessible manner for public consumption and debate. Unless the public is brought on-board, it will be difficult for any government to push through fundamental change of sufficient magnitude to achieve significant change.

2.5.3 The second main barrier is a mismatch between government aspiration to reduce carbon emissions (as required by the Climate Change Act) while prioritising expenditure towards expensive and polluting major road schemes (in particular the M74 Northern Extension, Aberdeen western bypass, and the Second Forth Road Bridge) and allowing for airport expansion (as set out in National Planning Framework 2).

2.6 “What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations or performance standards; or incentive schemes?”

2.6.1 We are strong supporters of the use of economic instruments to drive demand reduction. We were involved in drawing up the legislation which allows for local authorities in Scotland to implement local road user charging schemes and were one of the main proponents of the Edinburgh congestion charging scheme which unfortunately was rejected in a referendum in February 2005.

2.6.2 We take the view that there is likely to be little progress in delivering sustainable transport unless and until transport users pay for the damage they inflict on others and society generally (the ‘polluter pays principle’). The University of Leeds’ Institute for Transport Studies report, commissioned by the UK Department for Transport, Surface Transport Costs & Charges,1 in what was probably the most comprehensive report of its kind in the UK, reported that: “For the British road sector as a whole, taxes and charges in 1998 covered between one third to a half of their relevant marginal social and environmental costs, depending on the range of the cost estimates examined. Congestion costs, making up some two-thirds of overall costs, are the most important cost category, followed by environmental costs, accident costs and infrastructure maintenance.”

3 Response to further issues raised by RSE 3.1 Energy generation

3.1.1 Given that energy is one of the main sources of greenhouse gas emissions globally it is essential that the UK decarbonise by moving towards electricity production by hydro, wind, tidal and other renewable sources. Transform Scotland’s view is that this on its own is unlikely to happen swiftly enough.2 This emphasises the need to reduce demand by whatever means possible. Transport, as a major generator of emissions, must have its demand constrained if emission reduction targets are to be met. 3.2 Transport

3.2.1 Our own organisation’s transport emissions are trivially low because no members of staff own cars, and all travel to work on foot, by bicycle, and use public transport, while using rail for travel on work purposes. This type of lifestyle is actually quite painless to adopt and we feel that UK governments have shown a lack of confidence and commitment in promoting changes that would reduce transport emissions while at the same time enhancing the appearance of our cities and the health of the citizens. What is of more importance than our own organisation’s performance are the trends in the transport sector more generally.

3.2.2 In 2006, the Scottish transport sector was responsible for 24.4% of all greenhouse gas emissions.3 It is likely that this underestimates the impact of the Scottish transport sector. As expressed by the UK Department for Transport in 2007, government estimates of the impact of the transport sector “are likely to be an understatement of the full climate impact of UK related transportation [because of] the full climate impact of aviation emissions at high altitudes”.4

3.2.3 Transport is the principal sector where emissions continue to rise. Greenhouse gas emissions from the Scottish transport sector rose by 14.3% between 1990 and 2006, whereas all Scottish emissions fell by 12.3% over this same period.5 Clearly, if the transport sector played its part in reducing emissions then there would be a significantly better chance of hitting future targets.

3.2.4 The current level of emissions from the transport sector alone is currently above the total level of emissions that can be emitted under the 2050 target level. In 2006, total Scottish transport emissions were 4.08 MtCe,6 while the 2050 target will require emissions from all Scottish activity to be below 3.81 MtCe.7 Hence, current transport emissions represent 107% of the total emissions allowable from all Scottish activity in Scotland in 2050 under the target proposed in the Climate Change Act.

3.2.5 Unfortunately, current Scottish transport expenditure priorities are systematically biased towards large infrastructure projects; current priorities are, on the whole, contrary to achievement of greenhouse gas emission reduction in the transport sector. The government’s official advisory body, the Sustainable Development Commission, has scored the Scottish Government badly on transport in each of its recent annual Assessment reports. The 3rd Annual Assessment (08/09) asks government to “ensure better alignment between climate change targets and transport policy.” In very stark terms it states, “This will require a sustained movement of funding away from roads ... and particularly to active travel and demand reduction.” It tells government “to commit 10% of total transport expenditure to active travel.”

3.2.6 Instead of moving in this direction, the Scottish Budget 2009-10 set out a large increase in spending on motorways and trunk roads, whilst support for existing public transport networks is static or in decline, and funding for the most sustainable modes of travel - walking and cycling - remains at the pitifully low level of £20m per annum (around 1% of the entire transport budget).

3.2.7 In December 2008, the Scottish Government published the Strategic Transport Projects Review (STPR) and its National Planning Framework for Scotland 2: Proposed Framework (NPF2). STPR, amongst other things, sets out a £9 billion spending programme on roads, while NPF2 provides for airport expansion and a £2.3 bn Second Forth Road Bridge.

3.2.8 Even if we accept the optimistic claim that the STPR projects will cut emissions (a 1% cut by 2022 on business-as-usual is asserted), this programme is not compatible with the climate change trajectories set out in the Climate Change Act. Current forecasts for the year 2022 indicate that, in the absence of significant technological or behavioural change, total road transport carbon emissions will increase from 2005 levels by some 10%. This is fundamentally at odds with the Government’s climate change ambitions: a 10% increase in emissions from the transport sector (at 2022) is patently not compatible with the acknowledged requirements for deep cuts in total emissions (by 2020).

3.2.9 The UK and Scottish Governments should instead be proactive in providing a framework for local authorities so that they will achieve significant reduction in emissions over time, whilst at the same time improving the look and ambience of our towns and cities and improving public health. There is a multitude of sustainable transport measures that could be implemented, but here are a few:

• Implementing road user charging - a policy which remains within the powers of the Scottish local authorities and the Scottish Parliament; • Converting the car and public transport ﬂeet from fossil fuels to renewable power sources (electric or hydrogen powered buses, tram networks); • Increasing commuter cycling to continental levels (20-30% of all trips); • Reducing urban congestion by a combination of the above measures plus prioritising road space in favour of public transport, walkers and cyclists and reductions in inner city parking; • The greening of cities, whereby investment goes on better public transport and the promotion of walking and cycling in extensively pedestrianised city centres. This will reduce the need to commute by car and yield major carbon dioxide emission reductions. 3.2.10 A recent report by Atkins and Aberdeen University for the Scottish Government looked at a range of options in relation to transport and interestingly came to the conclusion that the most cost-effective measures are, in general, the least expensive and easiest to implement.8 Essentially, these options are those that involve the development of more sustainable lifestyles by a reduction in the need to travel and encouraging a shift from car to public or communal transport systems. The most cost-effective policies identified include the following: (i) Community hubs; (ii) Widespread implementation of travel plans; (iii) Speed reduction on trunk roads; (iv) Introduction or increase in public parking charges; (v) Workplace parking levy; (vi) Bus quality contracts / statutory partnerships; (vii) Urban density increases; (viii) Freight best practice; (ix) Electric car technology & network development; (x) National network of car clubs; and (xi) Cycle infrastructure investment.

4 Summary

4.1 Transform Scotland firmly believes that immediate action needs to be taken on a number of fronts to reduce the emission of greenhouse gases by man from the major sources of energy production and transport. As discussed above however, we are not convinced that energy production can be decarbonised within the required timescale and that the emphasis needs to be placed on demand reduction.

4.2 In our view, the Scottish and UK Governments need to redirect a significant part of the multi-billion road budget to the projects listed above to the development of integrated public transport systems that will include buses, trams, cycle networks and walking facilities.

4.3 Such a major change is necessary not only to achieve reductions in carbon dioxide emissions but also to allow for the massive rise in oil price that is predicted will occur from about 2015 onwards due to rising demand for oil and declining production.

••••• References:

1 University of Leeds Institute of Transport Studies (2001): Surface Transport Costs and Charges: Great Britain 1998. 2 A recent book by Stewart Brand, Whole Earth Discipline (2010), quoting figures by Griffith, illustrates the magnitude of the problem of decarbonising energy production by quantifying the effort required to convert current global energy production of about 16 terawatts to a range of alternative sources in the next 25 years, in addition to the 3 terawatts from current sustainable sources. • 2 terawatts of photovoltaic would require the installation of 100 square metres of 15% efficient solar cells every second for the next 25 years • 2 terawatts of solar thermal (using sunlight to produce steam) would require 50 square metres of mirror every second for 25 years, assuming 30% overall efficiency • 2 terawatts of biofuel – four Olympic sized pools of genetically engineered algae installed every second for 25 years • 2 terawatts of wind – a 300ft diameter wind turbine every 5 minutes for 25 years • 2 terawatts of geothermal – three 100 megawatt steam turbines every day for 25 years • 3 terawatts of nuclear – a 3 gigawatt plant every week for 25 years. 3 NAEI (2008) - and . This figure is for all transport emissions (including, e.g., aviation and shipping). It is calculated as 15001 tCO2e (transport emissions) divided by 61359 tCO2e (total emissions including international emissions). 4 Department for Transport (2007): Low Carbon Transport Innovation Strategy, §2.5. . Note that this quote refers to UK emissions, but the argument holds equally for Scottish aviation emissions. 5 NAEI figures. Transport emissions were 13128 tCO2e in 1990 and 15001 tCO2e in 2006. Total emissions including international emissions were 70002 tCO2e in 1990 and 61359 tCO2e in 2006. 6 NAEI report total Scottish transport emissions in 2006 as 15001 tCO2e, or 4.08 MtCe. 7 NAEI report total Scottish emissions in 1990 as 70002 tCO2e, or 19.07 MtCe. 20% of this baseline figure implies a 2050 target of 3.81 MtCe. 8 Scottish Government (2009) Mitigating Transport’s Climate Change Impact in Scotland: Assessment of Policy Options.

Transform Scotland is the national sustainable transport alliance, campaigning for a more sustainable and socially-just transport system. Our membership includes bus, rail and shipping operators; local authorities; national environment and conservation groups; consultancies; and local transport campaigns.

Transform Scotland 5 Rose Street, Edinburgh, EH2 2PR e: t: 0131 243 2690 w:

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1 +∂™®≥ ™∂¥ ¥ ºµ∞ª∞¨∫ ™®µµ∂ª ™∂¥ ∑¨ª¨ ≠∞µ®µ™∞®≥≥¿ æ ∞ªØ ´¨Ω¨≥∂∑¨π∫ 3Ø∞∫ ∞∫ ∑®πª∞™º≥®π≥¿ ∫∂ æ ∞ªØ ≥∂™®≥ πºπ®≥ ™∂¥ ¥ ºµ∞ª∞¨∫' ªØ¨ Ω¨π¿ ∑≥®™¨∫ æ Ø¨π¨ ´¨Ω¨≥∂∑¨π∫æ ®µªª∂™∂µ∫ªπº™ª∑π∂±¨™ª∫∫º™Ø®∫æ ∞µ´≠®π¥ ∫3Ø¨ ∞µ≠∂π¥ ®ª∞∂µ Æº∞´∞µÆ ªØ¨ ´¨™∞∫∞∂µ)¥ ®≤∞µÆ ∑π∂™¨∫∫ / ®µ´ ªØº∫ ªØ¨ ∑∂æ ¨π'´π∞Ω∞µÆ ªØ∞∫ ∑π∂™¨∫∫ ) ™ºππ¨µª≥¿ ≥∞¨∫ æ ∞ªØ ™∞ª¿ ∞µΩ¨∫ª∂π∫' ©∞Æ ´¨Ω¨≥∂∑¨π∫ ®µ´ ≥∂™®≥ ®ºªØ∂π∞ª∞¨∫'ªØ¨Ω¨π¿∑¨∂∑≥¨æ Ø∂æ ∂µ1ª©¨´∞π¨™ª≥¿®≠≠¨™ª¨´©¿ªØ¨∑π∂∑∂∫®≥∫ 2∂ æ Ø®ª ∞∫ ªØ¨ ∫∂≥ºª∞∂µ2 +∂™®≥™∂¥ ¥ ºµ∞ª∞¨∫'∞ª ∫¨¨¥ ∫'µ¨¨´ ª∂ ©¨ Æ∞Ω¨µ ® ∫ªπ∂µÆ¨π Ω∂∞™¨ ∞µ ªØ¨ ®∫∫¨∫∫¥ ¨µª ∂≠ ®µ¿ ´¨Ω¨≥∂∑¥ ¨µª æ Ø∞™Ø æ ∂º≥´ ∫∞Æµ∞≠∞™®µª≥¿®≠≠¨™ªªØ¨∞π≥∂™®≥®π¨®(µ´¨¨´ªØ¨π¨∞∫®µ$4 # ∞π¨™ª∞Ω¨ªØ®ª∫®¿∫ ®∫¥ º™Ø ªØ¨ ®πØº∫# ∞π¨™ª∞Ω¨ (ª∫¨¨¥ ∫ªØ®ª∫∂¥ ¨≠∂π¥ ∂≠≠ºµ´∫Ø∂º≥´©¨∑π∂Ω∞´¨´æ Ø∞™Ø™®µ©¨º∫¨´©¿ªØ¨ ≥∂™®≥™∂¥ ¥ ºµ∞ª¿ª∂™π¨®ª¨ªØ¨∞π∂æ µ$( ∞≠µ¨™¨∫∫®π¿3Ø∞∫æ ∂º≥´Æº®π®µª¨¨ ≠ºπªØ¨π¨ø®¥ ∞µ®ª∞∂µ∂≠®∫∫¨∫∫¥ ¨µª∫®≥π¨®´¿™®ππ∞¨´∂ºª©¿≥∂™®≥´¨Ω¨≥∂∑¨π∫ª∂ ¨µ∫ºπ¨®≠º≥≥∞µΩ¨∫ª∞Æ®ª∞∂µ∂≠®µ¿∑π∂∑∂∫¨´´¨Ω¨≥∂∑¥ ¨µª ∫º∑∑≥¨¥ ¨µª®π¿ ∂π®≥ª¨πµ®ª∞Ω¨ ®∫∫¨∫∫¥ ¨µª ™®ππ∞¨´ ∂ºª ©¿ ® ≥∂™®≥™∂¥ ¥ ºµ∞ª¿ ¥ ∞ÆØª ∞µ™≥º´¨ π¨Ω∞¨æ ∞µÆ ªØ¨ $( ∞µ≠∂π¥ ®ª∞∂µ'∫¨Ω¨π®≥´®¿∫&≠∞¨≥´ æ ∂π≤'™∂≥≥®ª∞µÆ ªØ¨ ≠∞¨≥´ ´®ª®'æ π∞ª∞µÆªØ¨π¨∑∂πª®µ´¨Ω¨µ®∑∑¨®π∞µÆ®∫®µ$ø∑¨πª6 ∞ªµ¨∫∫®ª®/º©≥∞™ (µ∏º∞π¿(ª¥ ∞ÆØª∞µΩ∂≥Ω¨∞µΩ¨∫ª∞Æ®ª∞∂µ∫∞µª∂∑∂ª¨µª∞®≥∑¨®ª≥®µ´∞¥ ∑®™ª∫®µ´ ∞¥ ∑®™ª∫∂µ ¨™∂∫¿∫ª¨¥ ∫¨πΩ∞™¨∫'©ºª ∞ª ¥ ®¿ ®≥∫∂ ©¨ µ¨™¨∫∫®π¿ ª∂ ™∂µ∫∞´¨πªØ¨ ∫∞ª¨1∫®π™Ø®¨∂≥∂Æ¿'æ ®ª¨π∏º®≥∞ª¿'µ∂∞∫¨®µ´∂πµ∞ªØ∂≥∂Æ¿ ' ∂æ ¨Ω¨π'∞≠∫º™Ø æ ∂π≤ æ ¨π¨ ª∂ ©¨ ∫º∑∑∂πª¨´ ≠π∂¥ ∑º©≥∞™ ≠ºµ´∫ ∞ª ™∂º≥´ ™∂µ∫º¥ ¨ ∫∞Æµ∞≠∞™®µª ®¥ ∂ºµª∫∂≠∑º©≥∞™¥ ∂µ¨¿ 3Ø¨ ≠ºµ´∫™∂º≥´ ∞µ∫ª¨®´ ©¨ ™π¨®ª¨´ªØπ∂ºÆØ®©∂µ´Æ∞Ω¨µ≠π∂¥ ªØ¨´¨Ω¨≥∂∑¨πª∂ªØ¨≥∂™®≥®ºªØ∂π∞ª¿®ªªØ¨ ∫ª®πª∂≠ªØ¨∑π∂±¨™ª∞µ¥ º™ØªØ¨∫®¥ ¨æ ®¿®∫®©∂µ´ ∞∫∂≠ª¨µ®™∂µ´∞ª∞∂µ∂≠ ∑≥®µµ∞µÆ ∞µ π¨∫∑¨™ª ∂≠ ®µ¿ π¨∫ª∂π®ª∞∂µ æ ∂π≤ π¨∏º∞π¨´ ®ª ªØ¨ ¨µ´ ∂≠ ªØ¨ æ ∂π≤∞µÆ ≥∞≠¨ ∂≠ ® ´¨Ω¨≥∂∑¥ ¨µª 3Ø∞∫ µ¨æ 5≥∂™®≥™∂¥ ¥ ºµ∞ª¿ ©∂µ´&™∂º≥´ ∞µ∫ª¨®´©¨®∑∑≥∞¨´ª∂ªØ¨∞µ∞ª∞®≥∑≥®µµ∞µÆ®∑∑≥∞™®ª∞∂µ'®µ´¥ ®´¨®Ω®∞≥®©≥¨ª∂ ≥∂™®≥™∂¥ ¥ ºµ∞ª∞¨∫ª∂ ºµ´¨πª®≤¨ ªØ¨∞π∂æ µ ∞¥ ∑®™ª æ ∂π≤'∞≠ªØ¨¿ ≠¨≥ª ∞ª ª∂ ©¨ µ¨™¨∫∫®π¿ (≠ªØ¨ ™∂¥ ¥ ºµ∞ª¿ ∞∫™∂µª¨µª æ ∞ªØ ªØ¨ ´¨Ω¨≥∂∑¨π&∫$( 'ªØ¨ ©∂µ´ æ ∂º≥´ªØ¨µ©¨π¨ªºπµ¨´ª∂ªØ¨´¨Ω¨≥∂∑¨π∂µÆπ®µª∂≠∑≥®µµ∞µÆ™∂µ∫¨µª3Ø¨ ∫∞¡¨∂≠ªØ¨©∂µ´™∂º≥´©¨©®∫¨´∂µ©∂ªØªØ¨∑Ø¿∫∞™®≥∫™®≥¨∂≠ªØ¨´¨Ω¨≥∂∑¥ ¨µª ®µ´®≥∫∂ªØ¨®µª∞™∞∑®ª¨´¨™∂µ∂¥ ∞™∫™®≥¨∂≠ªØ¨∑π∂∑∂∫®≥®∫®æ Ø∂≥¨ - ∂ª ∂µ≥¿ æ ∂º≥´ ªØ∞∫¨µ®©≥¨ ªØ¨ ≥∂™®≥™∂¥ ¥ ºµ∞ª¿ ª∂ ™∂µªπ∞©ºª¨ ∞µ ®µ ®™ª∞Ω¨ æ ®¿ ª∂ ®µ¿ ´¨Ω¨≥∂∑¥ ¨µª ∑π∂∑∂∫®≥' ∞ª ®≥∫∂ Ø®∫ ªØ¨ ®´´¨´ ©¨µ¨≠∞ª ∂≠ ¨µ™∂ºπ®Æ∞µÆ ´¨Ω¨≥∂∑¨π∫ ª∂ π¨∫¨®π™Ø ªØ∂π∂ºÆØ≥¿ ªØ¨ ∞¥ ∑≥∞™®ª∞∂µ∫ ∂≠ ∫º™Ø ∑π∂∑∂∫®≥∫ ∞µ ªØ¨ ≠∞π∫ª ∑≥®™¨'®µ´ ªØº∫ ∑π∂´º™¨ Æ∂∂´ $( ´∂™º¥ ¨µª∫ æ Ø∞™Ø ≥∂™®≥™∂ºµ™∞≥∫'≥∂™®≥∑¨∂∑≥¨ ®µ´ ∂≠≠∞™∞®≥©∂´∞¨∫ æ ∂º≥´ ©¨ Ø®∑∑¿ ª∂ ®™™¨∑ª æ ∞ªØ∂ºª ≠ºπªØ¨π ∞µΩ¨∫ª∞Æ®ª∞∂µ 3Ø∞∫ æ ∂º≥´ ¨µ™∂ºπ®Æ¨ ® æ ∞µ)æ ∞µ ∫∞ªº®ª∞∂µ æ Ø¨π¨©¿ ´¨Ω¨≥∂∑¨π∫ ∑π∂´º™¨ Ø∞ÆØ ∏º®≥∞ª¿ $( ´∂™º¥ ¨µª∫ ®µ´ ≥∂™®≥

2 ™∂¥ ¥ ºµ∞ª∞¨∫ ≠¨¨≥™∂µª¨µª ªØ®ª ªØ¨ ´∂™º¥ ¨µª∫ ™∂µ∫∞´¨π¨´ ©¿ ªØ¨ ∑≥®µµ∞µÆ ®ºªØ∂π∞ª∞¨∫®´¨∏º®ª¨≥¿π¨∑π¨∫¨µªªØ¨∞π™∂µ™¨πµ∫(µ∫∂´∂∞µÆ'∞ª®≥∫∂ªØ¨π¨≠∂π¨ Ø®∫ªØ¨ ∑∂ª¨µª∞®≥ª∂ π¨´º™¨ ªØ¨ ™ºππ¨µª ª∞¥ ¨)™∂µ∫º¥ ∞µÆ'™∂∫ª≥¿ ®µ´ ™∂µ≠≥∞™ª) π∞´´¨µ∫¿∫ª¨¥ ∑π¨∫¨µª≥¿∞µ∑≥®™¨'æ Ø∞≥¨®™ª∞Ω¨≥¿Ø¨≥∑∞µÆª∂∞µΩ∂≥Ω¨ªØ∂∫¨æ Ø∂ ®ªªØ¨¥ ∂¥ ¨µª≠¨¨≥´∞∫¨µ≠π®µ™Ø∞∫¨´©¿ªØ¨∑≥®µµ∞µÆ∑π∂™¨∫∫ (,- 3(.-6 (#$9.-(-&%.11$-$6 !+$2 /≥®µ∫ª∂´¨Ω¨≥∂∑8æ ∞µ´≠®π¥ ∫∂µªØ¨π¨¥ ∂ª¨# ®Ω®, ∂∂πµ¨®π& π®µª∂æ µ∂µ 2∑¨¿ æ ∞≥≥≥¨®´ ª∂ ªØ¨ ™∂µ∫ªπº™ª∞∂µ ™º¥ º≥®ª∞Ω¨≥¿ ∂≠∂Ω¨π:;; Æ∞®µª ªºπ©∞µ¨∫' ¥ ®≤∞µÆ ªØ¨ ∂Ω¨π®≥≥´¨Ω¨≥∂∑¥ ¨µª ∂µ¨ ∂≠ªØ¨ ≥®πÆ¨∫ª æ ∞µ´≠®π¥ ∫ ∞µ $ºπ∂∑¨ 3Ø¨∫¨ ∑π∂±¨™ª∫ π¨∑π¨∫¨µª ¿¨ª ®µ∂ªØ¨π ∞≥≥)™∂µ∫∞´¨π¨´ µ®∞≥ ∞µ ªØ¨ ™∂≠≠∞µ ≠∂π 2™∂ª≥®µ´&∫∑π∞∫ª∞µ¨≥®µ´∫™®∑¨Ø¨π∞ª®Æ¨®µ´æ ∞≥≥≥¨®´ª∂ªØ¨æ ®µª∂µ´¨∫ªπº™ª∞∂µ ∂≠ ® ∫∑¨™ª®™º≥®π æ ∞≥´¨πµ¨∫∫ ∫∞ª¨ ®µ´ ∞ª∫ ªπ®µ∫≠∂π¥ ®ª∞∂µ ∞µª∂ ®µ ∞µ´º∫ªπ∞®≥ æ ®∫ª¨≥®µ´ 3Ø¨ π®∑¨ ∂≠ # ®Ω® , ∂∂π'≥∞≤¨ ∂ªØ¨π ∫∞¥ ∞≥®π Ω∞∂≥®ª∞∂µ∫ ∂≠ ∂ºπ ™∂ºµªπ¿∫∞´¨ ®™π∂∫∫2™∂ª≥®µ´'Ø®∫©¨¨µ ∑¨π∑¨ªπ®ª¨´ ©¿ ∑∂æ ¨π™∂¥ ∑®µ∞¨∫®µ´ ≥®µ´∂æ µ¨π∫∫¨´º™¨´©¿ªØ¨≥ºπ¨∂≠π∞™Øπ¨ªºπµ∫ªØπ∂ºÆØ∂Ω¨π)Æ¨µ¨π∂º∫1. " ∫ 3Ø¨¿ Ø®Ω¨ ≠∂ºµ´ æ ∞≥≥∞µÆ ®µ´ ™∂¥ ∑≥∞®µª ®≥≥∞¨∫ ∞µ ªØ¨ ª¨¨¥ ∞µÆ π®µ≤∫ ∂≠ ∑∂≥∞ª∞™∞®µ∫®µ´∑≥®µµ¨π∫æ Ø∂≥¨®∑∂µªØ¨™≥∞¥ ®ª¨™Ø®µÆ¨©®µ´æ ®Æ∂µæ ∞ªØ∂ºª ≠∞π∫ª™∂¥ ∑π¨Ø¨µ´∞µÆªØ¨µ¨Æ®ª∞Ω¨∞¥ ∑®™ª∂≠ªØ¨∞π´¨™∞∫∞∂µ∫ (≠∑≥®µµ∞µÆ ™∂µ∫¨µª ∞∫ Æπ®µª¨´ ª∂ ªØ¨ ∫∞ø æ ∞µ´≠®π¥ ∫ ®ª # ®Ω® , ∂∂π ∞ª æ ∞≥≥ ´¨∫ªπ∂¿®Ω®∫ª∑¨®ª©∂Ææ Ø∞™Ø∞∫º∑ª∂<¥ ¨ªπ¨∫´¨¨∑®µ´∂Ω¨π=;;;¿¨®π∫∂≥´ (ªæ ∞≥≥π¨≥¨®∫¨¥ ®∫∫∞Ω¨∏º®µª∞ª∞¨∫∂≠" . =∞µª∂ªØ¨®ª¥ ∂∫∑Ø¨π¨®µ´´∞∫ªºπ©ªØ¨ ≠π®Æ∞≥¨¨™∂∫¿∫ª¨¥ ®µ´Ø¿´π∂≥∂Æ¿∂≠ªØ¨≥∂æ ¨ππ¨Æ∞∂µ∫∂≠ªØ¨%∞µ´Ø∂πµ1 ∞Ω¨π 3Ø∞∫≠®©º≥∂º∫∑®πª ∂≠∂ºπ2™∂ªª∞∫Ø ≥®µ´∫™®∑¨ Ø¨π∞ª®Æ¨'Ø∂¥ ¨ ª∂ ™®∑¨π™®∞≥≥∞¨∫' Æ∂≥´¨µ¨®Æ≥¨∫'∂∫∑π¨¿∫'©º¡¡®π´∫'π¨´ªØπ∂®ª¨´´∞Ω¨π∫'≥®∑æ ∞µÆ∫'∫≤¿≥®π≤∫®µ´ π®Ω¨µ∫'æ ∞≥≥©¨ ∑¨π¥ ®µ¨µª≥¿ ´∞∫≠∞Æºπ¨´ 3Ø∞∫∞∫µ∂ª ªØ¨ æ ®¿ ≠∂πæ ®π´ (ª ∞∫® ™∂ππº∑ª∞∂µ∂≠ªØ¨≠∞ÆØª®Æ®∞µ∫ª™≥∞¥ ®ª¨™Ø®µÆ¨®µ´®´∞∫®∫ª¨π≠∂π2™∂ª≥®µ´ %∂π ¨ø®¥ ∑≥¨' æ ∞µ´≠®π¥ ∑π∂±¨™ª∫ ∫º™Ø ®∫ ªØ¨ ∂µ¨ ®ª 6 Ø∞ª¨≥¨¨' ∫∂ºªØ ∂≠ & ≥®∫Æ∂æ 'Ø®Ω¨≥¨´ª∂8??Ø¨™ª®π¨∫∂≠ªπ¨¨∫©¨∞µÆª∂πµº∑®µ´==∫∏º®π¨¥ ∞≥¨∫ ∂≠´¨¨∑∑¨®ª≥®µ´´¨∫ªπ∂¿¨´'ª∂©º∞≥´$ºπ∂∑¨&∫©∞ÆÆ¨∫ªæ ∞µ´≠®π¥ 'æ ∞ªØ@;≤¥ ∂≠®∫∫∂™∞®ª¨´ π∂®´∫ª∂ ∫¨πΩ∞™¨ :<; Æ∞®µª ªºπ©∞µ¨∫ %∂π¨∫ª∫®µ´ ∑¨®ª ©∂Æ∫®π¨ µ®ªºπ®≥™®π©∂µ ∫º¥ ∑∫ # ¨∫ªπ∂¿∞µÆ ªØ¨¥ ∞∫ ≥∞≤¨ ´¨∫ªπ∂¿∞µÆ ∂ºπ Æ≥∂©®≥®∞π ™∂µ´∞ª∞∂µ∞µÆ∫¿∫ª¨¥ (ª∞∫ªØ¨2™∂ªª∞∫Ø¨∏º∞Ω®≥¨µª∂≠™ºªª∞µÆ´∂æ µπ®∞µ≠∂π¨∫ª∫ ∞µªØ¨ ¥ ®¡∂µ®µ´∞ª∞∫ºµ≠∂πÆ∞Ω®©≥¨ . ≠™∂ºπ∫¨π¨µ¨æ ®©≥¨¨µ¨πÆ¿∞∫∞¥ ∑∂πª®µª®µ´∂≠™∂ºπ∫¨∞ªæ ∞≥≥∑≥®¿®Ω∞ª®≥π∂≥¨ ∞µ∂ºπ¨≠≠∂πªª∂™ºª" . =¨¥ ∞∫∫∞∂µ∫®µ´π¨®™ØªØ¨ª®πÆ¨ª∫∫¨ª©¿ªØ¨$4 ®µ´©¿ ªØ¨ 2™∂ªª∞∫Ø Æ∂Ω¨πµ¥ ¨µª !ºª π¨µ¨æ ®©≥¨ ¨µ¨πÆ¿ ∑π∂±¨™ª∫ ¥ º∫ª ©¨ ™®π¨≠º≥≥¿ ∑≥®µµ¨´®µ´∞¥ ∑≥¨¥ ¨µª¨´®µ´¥ º∫ª©¨∑®πª∂≠®™∂∂π´∞µ®ª¨´∑®™≤®Æ¨®∞¥ ¨´ ®ª π¨´º™∞µÆ " . = ¨¥ ∞∫∫∞∂µ∫ 6 ¨ ™®µµ∂ª ∫∞¥ ∑≥¿ πº∫Ø Ø¨®´≥∂µÆ ∞µª∂ Æπ®µª∞µÆ

3 ®∑∑π∂Ω®≥ª∂ æ ∞µ´≠®π¥ ∫ ≠π∂¥ ∂µ¨ ¨µ´ ∂≠2™∂ª≥®µ´ ª∂ ªØ¨ ∂ªØ¨π (≠æ ¨ ®π¨ ∫¨π∞∂º∫ ®©∂ºª ª®™≤≥∞µÆ ™≥∞¥ ®ª¨ ™Ø®µÆ¨'æ ¨ µ¨¨´ ª∂ π¨∫ª∂π¨ ¨™∂∫¿∫ª¨¥ ∫ ®µ´ ∑≥®™¨ ® Ω®≥º¨ ∂µ ªØ¨ ¨™∂∫¿∫ª¨¥ ∫¨πΩ∞™¨∫∑π∂Ω∞´¨´ ©¿ ∂ºπ≠∂π¨∫ª∫'∑¨®ª ©∂Æ∫' π∞Ω¨π∫' ∂™¨®µ∫ ®µ´ ∫∂∞≥∫ 6 ¨ µ¨¨´ ª∂ ∑ºπ∫º¨ ® π∞Æ∂π∂º∫ ∑≥®µ ∂≠ Ø®©∞ª®ª π¨™∂Ω¨π¿'´¨≥∞Ω¨π∞µÆ¨µΩ∞π∂µ¥ ¨µª®≥∞¥ ∑π∂Ω¨¥ ¨µª∫'∞µ™≥º´∞µÆ™∂µ∫¨πΩ®ª∞∂µ∂≠ ©∞∂´∞Ω¨π∫∞ª¿'æ ®ª¨π®µ´∫∂∞≥ (ª∞∫µ®ËΩ¨≠∂πªØ¨2™∂ªª∞∫Ø& ∂Ω¨πµ¥ ¨µªª∂∑π¨ª¨µ´ªØ®ª≠∂π¨∫ª∫∂≠Æ∞®µªæ ∞µ´ ªºπ©∞µ¨∫ ´∂ªª¨´ ®™π∂∫∫ 2™∂ª≥®µ´&∫ ºµ∞∏º¨ ≥®µ´∫™®∑¨ ™®µ ¥ ¨¨ª ªØ¨∫¨ ™π∞ª¨π∞® 3Ø¨2™∂ªª∞∫Øæ ∞µ´∞µ´º∫ªπ¿∞∫™ºππ¨µª≥¿∫ªπºÆÆ≥∞µÆª∂π¨´º™¨™∂∫ª∫∂≠¨≥¨™ªπ∞™∞ª¿ Æ¨µ¨π®ª∞∂µ≠π∂¥ @∑ª∂C∑∑¨πºµ∞ª'¨Ω¨µ©¨≠∂π¨ªØ¨∫º©∫∞´¿≠∂πªØ¨π¨µ¨æ ®©≥¨ ∂©≥∞Æ®ª∞∂µ™¨πª∞≠∞™®ª¨ 1. " ∞∫ª®≤¨µ∞µª∂®™™∂ºµª®µ´ªØ®ª®´´∫®≠ºπªØ¨πDD∑ ∑¨πºµ∞ª" ∂¥ ∑®π¨ªØ∞∫ª∂ªØ¨∑π∞™¨∂≠µº™≥¨®πÆ¨µ¨π®ª¨´¨≥¨™ªπ∞™∞ª¿∞µ%π®µ™¨' ™ºππ¨µª≥¿ ™∂∫ª∞µÆ ®π∂ºµ´ :E∑ ∑¨πºµ∞ª ®µ´ Ω∞πªº®≥≥¿ " . = ¨¥ ∞∫∫∞∂µ ≠π¨¨ ®µ´ ¿∂º©¨Æ∞µª∂Æ¨ªªØ¨∑∞™ªºπ¨ 2∂≥®π'æ ∞µ´'Ø¿´π∂'Æ¨∂ªØ¨π¥ ®≥'æ ®Ω¨'ª∞´®≥®µ´ ©∞∂¥ ®∫∫®≥≥Ø®Ω¨ ® π∂≥¨ ª∂ ∑≥®¿ ®µ´ 2™∂ª≥®µ´'æ ∞ªØ ∞ª∫ ≥¨µÆªØ¿ ™∂®∫ª≥∞µ¨'™ºªª∞µÆ)¨´Æ¨ ª¨™Øµ∂≥∂Æ¿ ®µ´ æ ∂π≥´)©¨®ª∞µÆ∫™∞¨µª∞∫ª∫™®µ©¨™∂¥ ¨®Æ≥∂©®≥≥¨®´¨π!ºª®µ¿´∞Ω¨π∫¨¨µ¨πÆ¿ ©®∫≤¨ª®∞¥ ¨´®ªπ¨´º™∞µÆ" . =¥ º∫ª∞µ™≥º´¨µº™≥¨®π3Ø¨2- /Æ∂Ω¨πµ¥ ¨µª®π¨ ´¨ª¨π¥ ∞µ¨´ ª∂ º∫¨ ªØ¨∞π∑≥®µµ∞µÆ ∑∂æ ¨π∫ ª∂ ©≥∂™≤ ªØ¨ ™∂µ∫ªπº™ª∞∂µ ∂≠µ¨æ µº™≥¨®π ∑≥®µª ∞µ 2™∂ª≥®µ´'æ Ø∞≥¨ π¨≥¿∞µÆ ∂µ ∞¥ ∑∂πª∫ ∂≠ µº™≥¨®π Æ¨µ¨π®ª¨´ ¨≥¨™ªπ∞™∞ª¿≠π∂¥ ∂ºπµ¨∞ÆØ©∂ºπ∫∫∂ºªØ∂≠ªØ¨©∂π´¨πF (ª∞∫®≥∫∂ªØ¨™®∫¨ªØ®ªªØ¨≥∂®´≠®™ª∂π∂µæ ∞µ´ªºπ©∞µ¨∫∞µ2™∂ª≥®µ´∞∫®π∂ºµ´ =CG 3Ø∞∫¥ ¨®µ∫ªØ®ªæ ¨¥ º∫ªπ¨≥¿∂µ©®∫¨≥∂®´©®™≤º∑¨µ¨πÆ¿∑π∂´º™ª∞∂µª∂ ¥ ®≤¨º∑≠∂πªØ¨∫Ø∂πª≠®≥≥™π¨®ª¨´©¿®µ∂Ω¨π)π¨≥∞®µ™¨∂µ∂µ)∫Ø∂π¨æ ∞µ´(µªØ¨ ®©∫¨µ™¨ ∂≠µº™≥¨®π∑≥®µª'∫º™Ø ©®∫¨≥∂®´ ©®™≤º∑ ∞µ ≠ºªºπ¨ æ ∞≥≥Ø®Ω¨ ª∂ ™∂¥ ¨ ≠π∂¥ ≠∂∫∫∞≥≠º¨≥Æ®∫∂π™∂®≥∑≥®µª∫æ Ø∞™Ø®π¨ Ø∞ÆØ" . =¨¥ ∞ªª¨π∫'ªØº∫™®≥≥∞µÆ ∞µª∂∏º¨∫ª∞∂µªØ¨Ω∞®©∞≥∞ª¿∂≠ªØ¨¨µª∞π¨∫ªπ®ª¨Æ¿ (ª ∞∫¨∫∫¨µª∞®≥ªØ®ª 2™∂ª≥®µ´ ∫Ø∂º≥´ ≠∂≥≥∂æ ªØ¨ ¨ø®¥ ∑≥¨ ∂≠∂ªØ¨π$4 , ¨¥ ©¨π 2ª®ª¨∫∫º™Ø®∫& ¨π¥ ®µ¿'©¿™∂)∂π´∞µ®ª∞µÆ®™®π¨≠º≥≥¿∑≥®µµ¨´¡∂µ®≥∫ªπ®ª¨Æ¿ ≠∂πªØ¨™∂µ∫ªπº™ª∞∂µ∂≠π¨µ¨æ ®©≥¨¨µ¨πÆ¿∑π∂±¨™ª∫+∂™®≥∑≥®µµ∞µÆ®ºªØ∂π∞ª∞¨∫ ∫Ø∂º≥´ ©¨ π¨∏º∞π¨´ ª∂ ¡∂µ¨ ®π¨®∫ æ Ø¨π¨ æ ∞µ´ ≠®π¥ ∫'™®π©∂µ)™®∑ªºπ¨ ®µ´ ∫ª∂π®Æ¨≠®™∞≥∞ª∞¨∫'µº™≥¨®π'Æ®∫∂π™≥¨®µ)™∂®≥∑≥®µª∫™∂º≥´©¨™∂µ∫ªπº™ª¨´2º™Ø ∑≥®µ∫ ∫Ø∂º≥´ ®≥∫∂ ™≥¨®π≥¿ ∞µ´∞™®ª¨ æ Ø¨π¨ µ∂ ∫º™Ø ∑π∂±¨™ª∫ ™∂º≥´ ¨Ω¨π ©¨ ¨µª¨πª®∞µ¨´ ºµ´¨π®µ¿ ™∞π™º¥ ∫ª®µ™¨∫ π¥ ¨´ æ ∞ªØ ∫º™Ø ´¨ª®∞≥'ªØ¨ 2™∂ªª∞∫Ø & ∂Ω¨πµ¥ ¨µª' ∑∂æ ¨π ™∂¥ ∑®µ∞¨∫ ®µ´ ≥®µ´∂æ µ¨π∫ æ ∂º≥´ Ø®Ω¨ ® ™≥¨®π ºµ´¨π∫ª®µ´∞µÆ∂≠æ Ø¨π¨∞ªæ ∂º≥´©¨∑∂∫∫∞©≥¨ª∂®∑∑≥¿≠∂π∑≥®µµ∞µÆ®∑∑π∂Ω®≥ ®µ´æ Ø¨π¨∞ªæ ∂º≥´©¨∑∂∞µª≥¨∫∫ª∂´∂∫∂

4 RSE INQUIRY INTO FACING UP TO CLIMATE CHANGE: STAGECOACH GROUP SUBMISSION

1.0 Introduction

1.1 Stagecoach Group is a leading international public transport company with bus and rail operations in the UK and North America. The Group employs around 30,000 people and runs around 12,000 buses and trains. We operate more than 1,500 buses in Scotland, including the Highlands and Islands of Scotland, Aberdeenshire, Fife, Tayside, Ayrshire and West Scotland. Stagecoach is also the leading provider of inter-city coach travel in Scotland through Scottish Citylink and the budget inter-city coach service megabus.com.

1.2 We are pleased to have been invited to make a submission to the RSE’s inquiry on Facing up to Climate Change. The submission below addresses the following issues: • Transport and climate change • Risks and opportunities • Impact of the Climate Change (Scotland) Act • Transport priorities • Carbon reduction partnerships • Barriers to change • Regulation and incentives

2.0 Transport and climate change

2.1 We believe modal shift from car use to greener, smarter travel on buses and trains is central to tackling the challenge of climate change. While this may ultimately lead to increased carbon emissions from public transport, the overall benefit to society from dramatic reductions elsewhere will be enormous. Road transport accounts for around 22% of carbon emissions in the UK and it is are rising. Commuting and business travel, for example, accounts for nearly 40% of all miles driven by car in the UK. Government, local authorities, businesses, public transport operators and other stakeholders must work in partnership to encourage intelligent car use and create an environment in which it is easy for consumers to make the switch to more carbon efficient options.

2.2 The current global dependence on fossil fuels is also an issue of energy security, with even more urgent timeframe for action than climate change. Stagecoach is a founder member of the UK Industry Taskforce on Peak Oil and Energy Security (ITPOES), which is seeking to engage government more proactively on the peak oil threat, and also to alert the public to the significant impact on consumers. We believe collaborative contingency planning by government, industry, and communities is urgently required to accelerate independent energy supply within the UK and maximise the opportunities from cleaner, alternative energy sources.

2.3 Crucially, meeting the challenge of climate change will require more than technological change through measures such as widespread adoption of electric vehicle technology. Moves towards more sustainable electric cars may cut emissions, but it will not address the problem of congestion, which impacts economic productivity. Government studies show that 8% of UK road traffic is already being affected by heavy congestion and, without action, this will increase by a further 30% by 2025, with the potential to cost business and freight an extra £10 billion a year.

1 Politicians must face up to the fact that it will require lifestyle changes from consumers and we believe this will require a mix of regulation and incentives.

2.4 We also recognise our business has a significant impact on the environment. We are working hard to reduce our own carbon footprint and make our business as sustainable as possible, while offering high-quality, easy-to-use services to attract more passengers and contribute to a virtuous cycle of reduced environmental impact.

3.0 Risks and opportunities

3.1 Climate change is a major factor influencing our business and transport operations, bringing with it both risks and opportunities. These include: • Regulatory risks o Government legislation introducing carbon credits (eg Carbon Reduction Commitment) o Government taxation policy (eg fuel tax) o Environmental criteria to qualify for Government grants (eg Bus Support Operators Grant) o Regulation affecting vehicle emissions (eg European legislation on engine standards) o Low emissions zones introduced by transport authorities • Physical risks o Increasing impact of extreme weather, such as flooding and ice, on transport infrastructure, such as the road and rail networks o Risk to operational facilities and transport fleets located near to rivers or in coastal locations from rising sea levels o Changes in consumer travelling habits due to weather changes o Reduced passenger comfort resulting in public transport being seen as less attractive o Climate change generated modal shift from car to public transport has the potential to increase the weight of buses and trains, leading to reduced fuel efficiency. • Opportunities o Bus and rail have a carbon advantage over car travel that we can use to increase our market share o Involvement in trials and development of new low-carbon technologies that can reduce cost to our business o Government strategies to decrease global carbon emissions from surface transport are supporting public transport growth o Climate change induced modal shift from car to public transport has the potential to free up road space for buses and coaches, leading to reduced congestion, better traffic flows and improved fuel efficiency o Stagecoach research has established that consumers are more likely to travel with a company whose ethics support the environment and that they will pay more for greener public transport. o Taking action to reduce carbon emissions now will reduce long-term costs from compliance, clean-up and purchasing carbon credits

3.2 For those reasons, we believe it is important to look closely at any solution that can improve the efficiency of our operations or reduce our carbon footprint. We are working with a range of stakeholders in Government and transport to minimise the risks of climate change on our business. Through our Carbon Management Programme, we are also raising awareness of these issues with our employees, our customers and other stakeholders.

2 4.0 Impact of the Climate Change (Scotland) Act

4.1 The Climate Change (Scotland) Act is a positive piece of legislation. It will help provide a focus for greenhouse gas reductions and moves towards a low carbon economy through far-reaching carbon reduction targets for 2020 and 2050. However, it is essential these targets are supported by action from the public and private sector, and individual consumers in particular.

4.2 Stagecoach Group is represented on the Scottish Government’s new 2020 Delivery Group, which brings together a wide range of expertise from central and local government, business, trade unions and NGOs to examine in detail the actions needed across Scotland to meet the aspirations of the Act.

4.3 Stakeholders need to build practical and effective partnerships and focus on entrepreneurial and innovative thinking. In terms of transport, we need greater leadership and more bold and imaginative pro-public transport policies from local and national politicians.

4.4 Most importantly, however, the success of the Act will depend on successful engagement with consumers. A Stagecoach survey of more than 13,000 consumers across the UK in 2008 found that consumer environmental concerns are growing, and that changing attitudes are flowing through into signs of changing behaviour. Environmental and health concerns, as well as price and concessionary travel schemes, were key drivers of this trend. Nevertheless, our experience suggests that green marketing messages to consumers are not effective in isolation.

4.5 For that reason, politicians need to pursue policies that will also help deliver a price, speed and accessibility advantage to public transport modes. Continued investment in the quality and capacity of the country's rail and bus networks and infrastructure is essential if we are serious about making Scotland and a more sustainable country in which to live, work and travel. Transport is often combined with walking or cycling as part of an integrated journey by bus or train, providing an opportunity to combine greener and healthier living campaigns.

4.6 Stagecoach’s emphasis on sustainable business pre-dates the Climate Change (Scotland) Act, but is consistent with the principles that underpin the legislation. Our strategy centres on steps to address the risks and opportunities facing our business, how our individual employees can incrementally help deliver change and how we can help our customers lead more sustainable lifestyles.

4.7 Our Group-wide Carbon Management Programme (CMP) provides a strategic approach to assessing the impact of climate change and identifies short, medium and long-term risks and commercial opportunities to the business. We are focused on: • Meeting our regulatory obligations • Investing in more fuel efficient vehicles • Using alternative, renewable fuels • Training our people in more efficient driving techniques • Saving energy at our offices and depots • Conserving and recycling water • Reducing and recycling waste • Reducing business travel • Offering affordable bus and rail travel • Developing green travel plans and incentives for our people, customers and other organisations

3 4.8 The key outputs of the CMP are: • defined Global Carbon Footprint for Stagecoach Group • implementation plans for emissions reduction across the Group • set of agreed tailored carbon reduction targets for each division • robust, consistent system for measuring and monitoring carbon emissions and performance against the targets across the whole business • voluntary disclosure of our carbon footprint to the Carbon Disclosure Project

4.9 We are committed to continuous improvement in environmental management and endeavour to go beyond strict compliance with the law. In addition, we encourage our business partners, suppliers and contractors to manage their own environmental affairs in the spirit of this policy. Stagecoach Group is a signatory to the Copenhagen Communiqué on Climate Change, and wrote to a number of its peers in the transport sector encouraging them to sign up to the Communiqué.

5.0 Transport priorities

5.1 We believe a range of potential carbon reduction technologies should be investigated to ensure Scotland and the UK faces up to two massive converging challenges – oil depletion and climate change – both of which require massive changes. More importantly, modal shift to greener, smarter bus, coach and train travel and measures to support these modes will make or break our efforts to deliver a reduced oil-dependant, low carbon transport future.

5.2 Technology Lower carbon technology for cars is advancing rapidly, with mainstream hybrids and a push for mass-market electric vehicles and a supporting plug-in charging network. Buses and coaches are also benefiting from advances developed for cars and the first hybrids are on the road. Continued focus is required on the development of cleaner engines, trials of sustainable biofuels, fuel-efficient driving training programmes and in-cab technology, as well as steps to cut the weight of vehicles. Rail is already a relatively energy efficient mode of transport, with a lower environmental impact than other modes and a good combination of high speed and efficiency. Ongoing electrification must be a priority, as well as greater use of regenerative braking and designs for more efficient rolling stock.

5.3 Policies to support modal shift Long lead times for rail improvements mean we need to plan ahead now for tomorrow’s railway, including more rolling stock, infrastructure work to lengthen platforms to take longer trains as well as the investigation of the potential for new lines, particularly for high-speed rail. There needs to be a long term strategy which looks beyond the current five-year programme to a timeframe that allows the public and private sectors to invest in increased capacity and enhancements which encourage people to switch from cars and planes. High-speed rail could deliver modal shift from domestic airlines. However, the significant cost and timescale, plus passenger projections pointing to some rail lines being full up by 2020 or 2025, mean we also need actions that deliver quick wins.

5.4 Buses and coaches are a flexible mode of travel that can deliver this quickly with relatively low levels of investment. Even switching to public transport one or two days a week can have a huge collective carbon reduction impact. Policies to support modal shift to bus and coach should include:

• Dedicated bus and coach lanes • Priority for coaches on some of the country’s most congested motorways, including hard shoulder running. • Targets for transport authorities setting minimum bus speeds. This would improve fuel efficiency and have a resultant impact in terms of carbon emissions. • Rewards for transport authorities meeting bus priority targets. This could involve an incentive based system whereby transport authorities meeting targets would qualify for extra central Government funding. The normal approach in such circumstances would be to ring-fence this income for transport. But by giving authorities the freedom to spend it in areas such as health or education, for example, it would encourage far more buy-in. • Consistent car parking pricing to deliver a price advantage to public transport. • Integration of sustainable transport policies with land use planning, rather than developments that encourage high car dependency. • Investment in bus and coach park and ride, which has a proven track record in reducing journey times, a major influence on commuter transport choices. For every 1,000 park and ride spaces, research suggests there are 250,000 less car journeys per year. It is not just a tool for the commute to work market. There is also potential for sites near key motorway junctions. Looking to the future, park and ride facilities present a massive opportunity to act as electric vehicle recharging hubs. These could be used by major fleet operators, and consumers could charge their electric vehicles while using bus park and ride to get to work. • More use of workplace travel plans, which business costs, improve staff retention and reduce commuter car travel by 10 to 30 percent. • Tailored solutions, such as demand responsive transport, for rural and less densely populated areas. • Pro-bus and coach fiscal measures, including: o Bus Scrappage Fund to incentivise operators to switch to newer, greener technologies. o Zero fuel tax for the bus and coach sector. o Better access to Government R&D funding to boost manufacturing in the bus and coach sector. It is innovation in this sector that operators depend on to continue to deliver an environmental advantage over the car.

6.0 Carbon reduction partnerships

6.1 Stagecoach Group firmly believes that a key element of the response to climate change should be the development of “green partnerships” designed to reduce carbon emissions and encourage more sustainable lifestyles. For business there is a commercial opportunity, competitive advantage and reputation benefit. The public sector also faces a major challenge to protect our environment, while the financial imperative to meet targets and regulation is increasing. Below are some examples of how we are working together with other stakeholders.

5 6.2 Greener Journeys Stagecoach Group is a leading member of Greener Journeys, a UK bus and coach industry campaign aimed at encouraging people to switch from cars to buses and coaches. The Greener Journeys campaign has launched a manifesto recommending a raft of policy initiatives to encourage modal shift that would deliver 50% more savings in transport CO2 emissions than currently planned under existing Government policies. Bus and coach operators believe that technological advances alone are not enough to achieve the carbon reductions required to tackle climate change and modal shift must be a key priority. The manifesto, The One Billion Challenge, was launched in October 2009. It demonstrates that if people switch from car to bus or coach for just one journey in 25 it would mean one billion fewer car journeys on UK roads over the next three years.

6.3 Greener Journeys is calling on the Government to: • Set targets for local authorities to encourage modal shift • Introduce a fairer tax regime for bus and coach passengers • Bus scrappage scheme to drive investment in low-carbon buses • Promote bus priority, park and ride and other measures to cut car commuting • Encourage bus travel to reduce “school run” traffic Further information on the campaign is available at www.greener-journeys.com.

6.4 Scottish Government 2020 Delivery Group Brian Souter, CEO Stagecoach Group, is a member of the Scottish Government’s new 2020 Delivery Group. The group brings together a wide range of expertise from central and local government, business, trade unions and NGOs to examine in detail the actions needed across Scotland to meet its ambitious climate change targets and make it a model of international best practice. The group met for the first time in December 2009.

6.5 Scottish Sustainable Transport Group Stagecoach is a member of the Scottish Sustainable Transport Group. The group’s objective is to identify significant projects that have the potential to contribute to Scottish Government targets on sustainable transport, support economic development and establish Scotland as a centre of excellence in this area. Stagecoach is working in partnership with other businesses with expertise in energy provision, vehicle manufacture, battery technology as well as central and local government. Members include Stagecoach Group, Scottish and Southern Energy, Allied Vehicles, Intelligent Energy, Scottish Enterprise, and Scottish Development International.

6.6 Reverse vending project, Aberdeenshire In partnership with Aberdeenshire Council, Stagecoach has launched Scotland’s first reverse vending recycling initiative, offering discounted bus travel in return for used drinks cans and plastic bottles. A hi-tech reverse vending recycling machine has been introduced at Ellon Park and Ride facility which allows commuters to recycle their plastic drinks bottles and drinks cans and get Stagecoach ‘green points’ in return which can then be redeemed for discounted bus travel.

6 6.7 Green travel incentives Stagecoach has partnered with major employers to promote intelligent car use and provide better value public transport. One example is a partnership with The Royal Bank of Scotland Group to offer employees a tax incentive to make more use of public transport and save money on bus travel. Annual bus travel with Stagecoach is available to RBS staff through the bank’s employee benefits scheme RBSelect. The scheme allows RBS employees to receive the bus travel benefit free from income tax and National Insurance. Bus travel can be booked online or via a dedicated Stagecoach/RBS call centre, with employees issued with 12 monthly megarider tickets over the course of a year.

7.0 Barriers to change

7.1 Transport in Scotland is influenced by policy at Scottish Government level, as well as EU regulation and UK Government policies on taxation. There are currently a number of areas where policy is working against public transport and its efforts to tackle climate change and damaging the modal advantage of bus and coach travel. Steps need to be taken to redress the balance of the relative cost/convenience of different transport modes and many of these can be put in place quickly.

7.2 Taxation policies • We have seen some move towards carbon-based taxation for vehicles. There have also been fuel duty increases affecting car travel. However politicians in Scotland and elsewhere in the UK have backed off controversial measures such as road pricing which would benefit public transport. • Buses and coaches pay an element of tax on fuel, while domestic airlines are exempt. Airlines receive a £9billion tax break every year through exemptions in fuel duty, which could be used instead to invest in more carbon-efficient public transport and reduced fares. • Restrictions placed by HMRC on the use of salary sacrifice schemes to cover public transport actively work against the wider take-up of bus travel. HMRC rules state such schemes can only cover home to workplace travel, and specifically exclude bus operator unlimited travel network tickets that encourage more sustainable public transport and less use of cars.

7.3 Public transport operating costs • Bus and coach operators in the UK have faced increases in running costs that are well above retail price inflation. Overall bus and coach operating costs in the UK went up 6.2% for the 12 months to 30 June 2009 and increased by 8.7% in Scotland at a time of low inflation/deflation for consumers. • Regulation on Euro engines has reduced the fuel efficiency of new buses and coaches and added to operator costs, which have already risen significantly. • Movements in the Euro-sterling exchange rate have also pushed the price of spare parts up by a third in the past year. • All of these factors have put pressure on the cost of fares for passengers. It has undermined efforts to attract car users to public transport services, which could reduce their carbon footprint.

7.4 Cost of adopting new technologies • The cost of adopting new technologies is also still prohibitively expensive for bus and coach operators, with hybrids for example 50% more expensive than standard vehicles. As a result, we would support the introduction of a Bus Scrappage Scheme with public funding support for using more carbon- efficient technologies, such as electric vehicles and hybrids.

7.5 Allocation of road space • More focus is needed on the allocation of road space to the most fuel and carbon efficient modes of transport. Measures such as bus priority lanes would make public transport faster, more reliable and a more attractive alternative.

7.6 Capacity and budgetary crunch • Sustained investment in bus coach and rail facilities around the UK will be needed to cope with any significant shift from private car to public transport. Buses and coaches are a flexible mode and have far greater capacity to scale their operations quickly. There is also available capacity in the short term. However, the danger is that rail faces a capacity crunch. Current peak commuter capacity is already being exceeded on some routes and this will become more widespread over the next decade without urgent investment. There is a need for more rolling stock, infrastructure work to lengthen platforms to take longer trains as well as the investigation of the potential for new lines, particularly for high-speed rail. • All of these urgent priorities come as we face an impending squeeze on public sector investment due to the economic downturn that may last years. It is crucial that public transport, with its wider social and economic benefits and crucial role in tackling climate change, is made a priority.

8.0 Regulation and incentives

8.1 We believe a mix of regulation and incentives is required to change behaviours. Our experience suggests incentives are particularly important in engaging consumers, but should also be considered in budget allocation for local authorities (see 5.0 Transport priorities).

8.2 As a core principle, it is crucial regulation tackles greenhouse gas emissions at source and results in genuine reductions. It should not produce perverse outcomes such as the over-availability of allowances as part of emissions trading schemes. Regulation must also take account of the ability of businesses and consumers to access alternative greener technologies and the overall role certain sectors (eg public transport) play in reducing overall carbon emissions.

8.3 We believe there is merit in consideration of a wholesale overhaul of the taxation system to make it carbon-based. This would centre on rewarding low-carbon users and shifting the taxation burden to high carbon users. This carbon-based taxation system could have important social inclusion benefits, including the potential for low income groups (who in general have lower carbon footprints) to be taken out of the income tax system altogether.

Steven Stewart Director of Corporate Communications Stagecoach Group January 2010

Note • Further information on Stagecoach Group’s climate change strategy, our initiatives and our performance, including video case studies, can be found online at http://www.stagecoachgroup.com/scg/csr/environment/

8 Consultation Response

Consultation Title: RSE INQUIRY INTO FACING UP TO CLIMATE CHANGE

Date: 07.05.10

To: Dr Marc Rands The Royal Society of Edinburgh 22-26 George Street Edinburgh EH2 2PQ

From: Janice Cassidy Scottish Rural Property and Business Association Stuart House Eskmills Business Park

Musselburgh

EH21 7PB

Telephone: (0131) 653 5400

E Mail: [email protected]

1 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

Introduction The Scottish Rural Property and Business Association (SRPBA) is a membership organisation that uniquely represents the interests of both land managers and land based businesses in rural Scotland. Our membership, which numbers around 3,000 in total and includes both those directly involved in active land management and professional members who advise clients, accounts for the majority of non-publicly owned land in Scotland. The SRPBA is aware that climate change affects everybody in Scotland and we are particularly interested in how the potential impacts on land managers can be reduced and how the rural sector can contribute towards a low carbon, environmentally sustainable future.

Questions 1. Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation? Changing weather patterns in Scotland and the impacts on land managers The SRPBA is aware that SNIFFER produced a document in 2006 entitled “A Handbook of Climate Trends across Scotland”. This handbook demonstrates that from 1961 to 2004 temperatures have increased in every season and in all parts of Scotland since 1961. Furthermore, in each region and across the country, the change in winter precipitation since 1961 shows a clear upward trend, with a 70% increase in precipitation in northern Scotland. There has been little or no change in average summer precipitation totals in each region. Heavy rainfall events have increased significantly in winter, particularly in northern and western regions. Also, all regions have seen an increase of more than four weeks in the length of the growing season since 1961.

The handbook predicts that irrespective of emissions scenarios, temperatures are expected to rise over Scotland in the future, with increases being greatest during summer and autumn months when a warming of up to 4.0°C (with the medium-high emissions scenario of forcing) is expected over parts of Scotland by the end of the century. Although there is expected to be relatively little change to annual rainfall amounts it is expected that winter months will become wetter, while summers months will be drier than at present. The pattern of change is not predicted to be uniform, with eastern Scotland experiencing the most extreme percentage changes in precipitation, with a winter increase and a summer decrease.

Based on these past trends and future projections identified by SNIFFER (2006) it is clear that land managers in Scotland will have to adapt to climatic changes in the future and that these changes will vary regionally. For example, if rainfall increases in the west of Scotland, this will cause problems for dairy farmers in this area. In contrast, decreases in rainfall in the east of Scotland during the summer months would necessitate the installation of irrigation regimes to ensure crop survival. The SRPBA also expects that land managers will have to prepare for an increase in extreme weather events such as flash floods. In order to prevent/reduce the impacts of such events on crops, livestock and transport systems, land managers will be forced to reconsider how best to use their land given the predicted changes in weather patterns.

Changing weather patterns globally and the impacts on land managers in Scotland Climate change predictions indicate that severe weather events, such as drought, are likely to become increasingly frequent at low latitudes. These extreme weather events could cause a decrease in crop productivity in these areas, potentially leading to food shortages and civil unrest. Scotland would be morally obliged to provide aid for those affected by natural disasters and

2 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

therefore must be prepared to supply resources. Scotland could also be put under migration pressures from people leaving these affected countries. Important decisions may have to be made about what additional areas of Scotland should be used for housing rather than food production in order to accommodate these additional people.

Importance of sound science Although the SRPBA recognises the importance of models in terms of planning for the future we must stress that climate change models are imperfect and there are a number of sources of uncertainty (due to emissions scenarios, scientific uncertainties and natural variability), which should be borne in mind when interpreting the projected future Scottish climate. Therefore, we believe that Scotland should prepare for the changes predicted by models but we should also be ready to act if the climate does not change in the expected manner.

2. What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? Incentives The SRPBA is hopeful that the Climate Change (Scotland) Act will not impose further regulations on land managers but will ensure that targets are met by creating positive incentives for them to reduce greenhouse gas emissions. For example, the SRPBA was encouraged by the introduction of Feed- in Tariffs (FITs) in April 2010 and looks forward to the implementation of the Renewable Heat Incentive (RHI) in April 2011. Together these schemes will incentivise the establishment of small scale renewable electricity installations and renewable heat installations of all sizes. Therefore, the Climate Change (Scotland) Act has a positive impact on land managers in this example because the FITs and RHI would not have been established if the emissions reduction targets and renewable energy targets had not been set.

Regulation History dictates that incentives work better in the rural sector than regulations, therefore the SRPBA is hopeful that the Scottish Government will adopt the former approach when implementing this Act. We have concerns about the potential compulsory implementation of greenhouse gas accounting on all farms in Scotland because this tool is not yet fully developed and if it is used incorrectly it will not provide the public with reliable information and land managers could be forced to comply with restrictions which are neither accurate nor necessary.

Conveying the message The SRPBA envisages that if the Act is promoted to land managers in an appropriate manner, greenhouse gas reductions will take place. For example, if land managers are told that they can contribute to reducing greenhouse gas emissions by practising precision farming when applying fertilisers, which would also reduce their overall costs, they will be more likely to take up this measure than if the message is conveyed in a purely ‘mitigate climate change’ manner.

Furthermore, land managers should be actively encouraged to look after their resources in such a manner that not only reduces net carbon emissions from Scotland but also provides a number of other benefits. For example, land managers should be encouraged to maintain and/or restore peatlands or to plant trees in order to not only store carbon but to also improve soil stability, increase biodiversity, increase the lag time after heavy rainfall events and improve overall water

3 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

quality. Adequate funding must be made available for land managers to carry out these activities since the benefits will not be experienced solely by them but by Scotland as a whole.

3. What do you plan to do in response to these factors over the next 5-10 years? Inform SRPBA Members The SRPBA will inform members about the implications of climate change, new legislation, new guidance documents and new incentives through a variety of media including information sheets, briefing notes, articles in our magazine Land Business, articles in our weekly enewsletter, workshops and seminars.

Development of Environmental Markets The SRPBA has been actively looking into the potential of developing environmental markets in Scotland. The principle of these markets is that land managers would be paid to provide public goods and services, for example maintain or restore peatlands or plant trees in order to sequester carbon, maintain water quality and mitigate flood events. The public would benefit through the reduction in carbon emissions and the land manager would also benefit. Work in this area is ongoing and we are hopeful that these externalities will be valued by the market in the future.

Effective Engagement with Relevant Groups The SRPBA will continue to effectively represent the interests of members on a wide variety of groups, such as the hydro sub-group of FREDS and the 2020 Climate Delivery Group.

4. How integrated is your response with other organisations in similar or related fields? The SRPBA represents a very diverse range of interests including agriculture, forestry, renewable energy, tourism and housing. Consequently, even within the Association we have to strike a balance between what could be viewed as competing land uses. As a result of our varied interests, the SRPBA is strongly linked with other organisations in the rural sector and we engage closely with them.

5. What are the main barriers to change for you and / or your organisation? The SRPBA believes that there are a number of different barriers to change and that they will vary from one member to another. Some of the main barriers include: • Caution of investing in something relatively new and unproven • Cost of innovation and diversification • Keeping up to date with new developments, for example new financial incentives for renewable energy • Planning restrictions in terms of renewable energy developments • Complexities of tenancy arrangements • Caution of changing historical land use to something different.

6. What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes? The development of environmental markets would provide a means of providing financial support to land managers for providing public goods in the form of carbon sequestration or flood management.

4 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

With regards to incentive schemes, historical trends indicate that land managers will respond when appropriate incentives are offered. Therefore, if incentives are given to reduce carbon emissions in the form of restoring peatlands or planting trees, land managers will respond.

Energy Generation 7. What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure? The SRPBA believes that public acceptance of investments in renewable energy should increase in the future as more and more people become familiar with the potential impacts of climate change and the need to ensure security of energy supply. To date, wind farms have aggravated the NIMBY syndrome in some areas of Scotland and concerns have also been raised about the potential impacts on birds. Water quality issues have been expressed regarding small scale hydropower developments and uncertainties prevail regarding air quality and biomass. The SRPBA believes that the public must be properly informed about the benefits of renewable energy and the importance of the Scottish renewable energy targets and climate change targets. It is important that the public is presented with the ‘bigger picture’ and then developments at the local scale should become more acceptable to them.

8. How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020? The SRPBA believes that the ideal scenario for 2020 would be for all new builds to install renewable energy technologies while they are being constructed. It is much easier and more cost effective to incorporate renewable energy into a building while it is being constructed rather than retro-fitting. We believe that the proposed introduction of the RHI in April 2011 will encourage the installation of renewable heating systems in both new builds and in existing properties. However, the SRPBA does believe that special attention must be given to remote rural areas in terms of incentives for installing renewable heat technologies. It is essential that these remote areas receive appropriate rates of incentives for the high costs that they will incur from retro-fitting. It is important that research continues into small scale renewable heat technologies in order that installations occur in an organised manner rather than on an ad hoc basis.

9. What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020? Investment in renewable energy will be greatly influenced by the financial support made available to potential developers and how easily this support can be accessed. Furthermore, it is important that planning regulations and guidance documents enable renewable energy developments to take place and do not hinder the growth of this sector.

10. Is there sufficient action to exploit the potential of micro-renewables? The SRPBA believes that it is quite complicated to find information about grants and other incentives that are available for renewable energy schemes. There are many websites which individually are excellent, for example, the FITs www.fitariffs.co.uk and RHI websites www.rhincentive.co.uk are clear and easy to follow. However, there is a lack of one clear website to pull all renewable energy information together. We appreciate that the Energy Saving Trust website www.energysavingtrust.org.uk does to some degree include information about many different schemes but it does not provide information about SRDP grants available to land managers. It would be better if this website was updated rather than establishing a new website.

5 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

11. What are the obstacles to cutting energy use? The SRPBA believes that there are a number of obstacles to cutting energy use and that these will vary from one member to another. Some of the key obstacles include: • The upfront costs of installing materials which will cut energy use such as insulation • Lack of financial support offered to implement measures which cut energy use • Fuel consumption by machinery, could be reduced by adapting crops to withstand climatic variability and pests therefore not requiring the same extent of fertiliser and pesticide applications.

Land Use 12. How can we use our land most efficiently for energy, agriculture and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity and wildlife habitats? The SRPBA believes that the Land Use Strategy, which is due to be laid before parliament by 31st March 2011, will go some way to answering this question. It is imperative that land use decisions are taken carefully and the SRPBA advocates the approach adopted in the Scottish Forestry Strategy (2006) to get the right trees in the right places at the right time. We believe that this approach should be adopted for all land uses in Scotland.

13. What do you see as the major barriers to changing rural land-use activities in this way? It is important to realise that land may have been used for the same purpose for many years. Therefore, to expect land managers to change the land use of certain areas in a relatively short period of time, for example from food production to forestry or to wildlife habitats, requires a step into the unfamiliar. Some land managers are not prepared to take this step change due to the potential and/or perceived risks involved. Therefore, to encourage them to make this change the SRPBA believes that it will be imperative for financial incentives to be made available.

Transport 14. How could your organisation’s transport emissions be cut by 30% by 2020 and what are the barriers to achieving this? In the future the SRPBA hopes that it will be possible to convert machinery and farm vehicles to biodiesel or other renewable energy fuels. Furthermore, transport fuel consumption could potentially be reduced by developing products with a longer shelf life or disease resistant crops.

6 Scottish Rural Property and Business Association Limited, Stuart House, Eskmills, Musselburgh EH21 7PB Tel: 0131 653 5400 Fax: 0131 653 5401 W: www.srpba.com E: [email protected] Registered in Scotland No. SC 257726. Registered office as above.

Dr Marc Rands Your ref: The Royal Society of Edinburgh 22-26 George Street Our ref: Edinburgh EH2 2PQ Date: 7 April 2010

Dear Marc

FACING UP TO CLIMATE CHANGE

Further to the oral evidence given by Colin Galbraith and Clive Mitchell on 2 December 2009, thank you for inviting our written evidence for this inquiry. As requested by the Committee we have focussed on potential barriers and examples where ecosystem approaches have been invoked as a response to either climate change adaptation or mitigation.

Scottish Natural Heritage (SNH) is a Government agency charged with conserving and enhancing the natural heritage of Scotland, facilitating its enjoyment and understanding, and promoting its sustainable management. Scotland’s natural heritage is its wildlife, habitats, landscapes and natural beauty, and includes the rocks, soils, landforms and waters on which these are based. We view climate change as the most serious threat over coming decades to Scotland’s natural heritage. We aim to understand the effects of climate change on the natural heritage, and to help deliver the contribution that the natural heritage can make in limiting it and adapting to it.

Our response is based on our 2009 publication ‘Climate Change and the Natural Heritage: SNH’s Approach and Action Plan’1. Rather than rehearse the detail provided in this statement and our oral evidence we have concentrated on the questions on land use and potential barriers.

1 I think you have a copy, but just in case, here is a link to it Printed on 100% recycled paper http://www.snh.org.uk/pdfs/publications/corporate/ClimateChange.pdf Scottish Natural Heritage, Great Glen House, Leachkin Road, Inverness IV3 8NW Tel: 01463 725000 Fax: 01463 725067 e-mail: [email protected] www.snh.org.uk

If you would like to discuss our response further, please contact Clive Mitchell (01738 458623 or email [email protected]) in the first instance.

Yours sincerely

Susan Davies Director, Policy & Advice

2 A205281

FACING UP TO CLIMATE CHANGE Evidence from Scottish Natural Heritage April 2010

Organisations • What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

SNH views climate change as the most serious threat over coming decades to Scotland’s natural heritage. We therefore welcome the Act and its associated duties on public bodies. The Act will mean changes to the way that we work, in the way we run our operations, and sharpening our attention to the carbon implications of the advice we give to others on decisions that affect the natural heritage. We have a Carbon Management Plan as an output of our involvement in the first cohort of the Carbon Trust’s carbon-lite programme during 2009. This will help us to reduce emissions in line with our target of 4% per annum. We are also developing a Low Carbon Vision to set out how we will shape the decarbonisation of our operations over the next 10 years and beyond. This will include consideration of how to encourage more carbon-sensitive staff behaviour, where best to locate offices in relation to our customers and how to make better use of public/active transport and reduce travel to work emissions. We are also taking opportunities to climate change–proof our estate, for example in works resulting from a flood last year in one of our offices at Battleby.

It will be increasingly important for us to be able to justify our investment both in fulfilling our statutory duties and contributing to the public sector duty on climate change. Our exposure to risk on climate change is both in terms of climate change risks for the organisation (for which we are undertaking a Climate Risk Assessment) and reputational risk arising if, for example, we are not seen as a leader in this area.

In common with many other public organisations a substantial part of our emissions derives from the use of electricity. It would greatly help our emission reduction planning if standard projected figures were available for the carbon content of electricity which reflect the Scottish situation of an increasing proportion of electricity being generated from renewable sources.

Energy generation • What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

During our oral evidence in discussion on barriers to uptake of renewable energy developments the Committee asked for the latest figures on our objection rate for renewable energy developments.

From 2001 to 2009 inclusive we responded formally to 231 onshore windfarm applications. Our responses can be classified as ‘no objection’, ‘conditioned objection’ or ‘full objection’. SNH supported the majority (78%) in principle, provided certain conditions relating to the natural heritage were met2; we made a ‘full objection’ to only 22%. SNH regularly responds with a ‘conditioned objection’ where we consider that a scheme is acceptable in principle, but where certain conditions, such as mitigation to benefit habitats or species, would have to be observed in order to be

2 34% of these final planning responses were ‘no objections’, 44% were ‘conditioned objections’, and 22% were ‘full objections’ based on significant adverse impacts on the natural heritage. Source: SNH (2009) Renewable Electricity Trends in Scotland: Statistics & Analysis 3 A205281 compatible with natural heritage interests. In the majority of cases, especially more recently, we have been able to work with developers to resolve these issues so that an objection is unnecessary.

SNH has objected to a declining proportion of proposals in recent years as the sector matures and as we have worked closely with others to resolve potential issues at the earliest stage of development proposals. We have also worked closely with industry and other partners to produce technical guidance on the siting and design of windfarms3, including guidance on bird interests4 and landscape guidance5.

SNH supports the Scottish Government’s target that Scotland should supply 50% of electricity from renewables sources by 2020, which translates into a requirement of over 8 GW of generating capacity. At the end of 2009, some 6.5 GW of renewable energy schemes were either installed and consented. In addition a further 4 GW of schemes were at application stage (i.e. with applications for consent lodged), and a further 2.5 GW at each of scoping and pre-application discussion stages. This data demonstrates a potential for renewable electricity generation, largely based on onshore wind and hydro, easily sufficient to exceed the 2020 target. However, cumulative impacts, especially on landscapes in respect of windfarms, are increasing in relevance as the number of developments increases, and the proportion of new applications considered environmentally acceptable may decrease over the coming years.

Land use • How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats? • What do you see as the major barriers to changing rural land-use activities in this way?

We expect the Land Use Strategy, currently in preparation by Scottish Government, to play an important role in setting out how land can be used efficiently for a variety of purposes, and avoiding potential conflicts of interest. A particular challenge is to encourage land uses to deliver multiple benefits (including the public benefits associated with biodiversity and people’s enjoyment of the outdoors), rather than viewing each individual land use as exclusive. We would expect all land uses to deliver benefits in relation to climate change, both in reducing present land use emissions, in maximising carbon storage, and in contributing to adaptation.

The Forestry Commission Scotland has proposed targets for woodland expansion in Scotland (10,000 ha/y or 20 million trees per year6 for a 34% emission reduction by 2020 rising to 15,000 ha/y for a 42% target). We are in discussion with FCS with a view to maximising the multiple benefits of the resulting woodland, for the natural heritage, carbon savings, recreation and other uses. Woodland expansion on deep organic and organo-mineral soils could lead to net increases in emissions, and we understand that planting will be avoided on deep peat (>50 cm depth). Further work is required on the net greenhouse gas emissions or savings associated with planting on thinner organic soils, over timescales relevant to woodland planting and management.

3 http://www.snh.org.uk/strategy/renewable/sr-we00.asp (Accessed 24 March 2010) 4 http://www.snh.org.uk/strategy/renewable/sr-we00a.asp (Accessed 24 March 2010) 5 http://www.snh.org.uk/strategy/renewable/sr-we01.asp (Accessed 24 March 2010) 6 http://www.scotland.gov.uk/News/Releases/2010/03/05131411 (Accessed 24 March 2010) 4 A205281

At present it seems that net emission reductions can be achieved for woodland planting on shallow organo-mineral soils (less than 10 cm deep). Targeting such soils for woodland expansion should allow progress to be made towards the 2020 targets while work continues to reduce uncertainties over the use of deeper soils.

Managing land to retain carbon in vegetation and soils is important - Scottish peatlands alone contain a carbon equivalent of around 180 years of Scottish emissions. Measures to reduce carbon loss and increase the carbon stock in these systems include retaining bogs, wetland and peatlands, avoiding new drainage and raising the water table level in peatlands that were previously drained. Because of the volume of carbon stored in these systems, there are net long term benefits in restoration rather than allowing further deterioration and carbon losses. However, re- wetting can produce a short-term spike in methane emissions and further work is required to determine how long it takes to achieve a positive carbon balance. Although the long-term benefits are clear this could be problematic in terms of contributing to short-term emission reduction targets and annual carbon budgets.

There is a potential conflict arising from the renewable electricity target being currently expressed as an installed capacity for renewable energy generation, rather than in terms of greenhouse gas savings. Where windfarms are proposed on deep peat and where the drainage impacts of the proposed development extend over a large area, the resulting emissions of greenhouse gases can erode some of the windfarm’s carbon-saving benefits. While a methodology to calculate these emissions has been agreed7, there is as yet no clear policy on how such carbon losses should be taken into account in any decision over the windfarm. SNH considers it important that decisions are based on net emissions reductions and take account of the long-term capacity of peatland for ongoing carbon sequestration.

We support the use of biomass (including woodland sources) for heat and power8, provided they lead to net emission reductions. We encourage use of biomass for heating or in Combined Heat and Power plants in preference to its use for electricity production only, as the waste heat from power-only biomass plants represents a highly inefficient use of resources. Potential carbon savings are also reduced if feedstocks are transported from overseas. It is important that any assessment of the effect on emissions takes a life cycle approach and includes associated transport emissions. The current consultation on the Renewable Heat Incentive states that interactions between it and the Renewables Obligation, Feed in Tariffs and Renewable Transport Fuels Obligation will need to be reviewed to make sure they deliver the desired overall outcomes.

These examples suggest a need to extend life cycle analysis methodologies to cover the full range of sectors in the Scottish and UK emissions inventories, including land use, to reduce the likelihood of ‘leakage’ in policies designed to reduce greenhouse gas emissions.

An ecosystem approach considers the interdependence between species, habitats and associated natural processes, and the benefits that people receive from these such as water regulation, coastal protection and food production. It is important to maintain the resilience of ecosystems so that they continue to provide these benefits,

7 http://www.scotland.gov.uk/Publications/2008/06/25114657/0 (Accessed 23 March 2010) 8 SNH (2009) Bioenergy and the natural heritage. http://www.snh.org.uk/pdfs/strategy/Bioenergy.pdf (Accessed 24 March 2010) 5 A205281 as well as to maintain biodiversity. One adaptation aim must be to reduce the vulnerability and increase the resilience of natural systems to the sort of weather- related events associated with climate change.

As well as contributing to the UK Climate Change Risk Assessment and National Ecosystem Assessment, we have started work to clarify conservation priorities in the light of a changing climate and what are the most important actions to take in the immediate future. We also need to improve our understanding of the dependence of species and habitats conventionally viewed as biodiversity on the microscopic organisms that support most ecosystem functions.

Examples where ecosystem approaches have been used as the basis for action on climate change include: • Bog restoration - Flanders Moss is one of the finest examples of raised bog in Scotland and action is being taken to restore the bog by plugging former drainage ditches and removing birch scrub. Similar works are being undertaken on Carnwath Moss. On blanket bog, trees have been removed on Sleach bog next to the River Thurso to allow peatland to flourish. These projects address mitigation by retaining and enhancing the stock of carbon in organic soils, and adaptation by increasing water storage in natural habitats. • Coastal realignment – a small area of formerly-claimed land was given up to managed coastal retreat to compensate in part for loss of coastal habitat at the site of the new Kincardine Bridge. Another example in Nigg Bay (Cromarty Firth) aims to create habitats for wildlife while reducing maintenance requirements for the existing and failing defences. • River management – on the White Cart Water (Glasgow), three flood storage areas upstream of the city have been created by building earth embankments to increase flood water storage, preventing the need for large flood defences in the city which would otherwise have affected residents and local wildlife. Work on the storage areas includes enhancing the wildlife habitat diversity with the creation of woodland, scrub, species-rich wet grasslands and ponds. A similar project on the River Black Devon (Clackmannanshire) involved restoration of wetlands, to act as a sponge to hold water, planting native trees along the riverside to create a ‘leaky barrier’ to slow the flow of water back into the river from the flood plain, and erosion control where livestock have damaged banking. This was one of more than 20 projects reviewed in a report for SEPA in 20089. SNH has is developing its perspective on ‘an ecosystem approach’ including where we might pilot that in a number of areas. The Macaulay Institute is working on a Model Ecosystem Framework for NE Scotland, with an objective of developing an integrated framework for strategic land use decisions10.

Decision-making needs to take a long-term and integrated view, taking account of climate change and the role of underlying ecosystem processes, for example by protecting wetlands and floodplains from built development. The new, more plan-led system of built development in Scotland should help to identify best options. There is

9 Centre for River Ecosystem Science (2008) River restoration at the catchment scale in Scotland: current status and opportunities. http://www.clim-atic.org/documents/P08002-RRScotland- final_draft%20report+app.pdf (accessed 24 March 2010) 10 http://macaulay.ac.uk/publications/24506.pdf (Accessed 25 March 2010) 6 A205281 a similar need for integrated decision-making in relation to other forms of land use, which we hope the forthcoming Land Use Strategy will encourage. The Scottish Government’s Climate Change Adaptation Framework already encourages organisations to include consideration of ecosystem services at an appropriate scale and to involve relevant levels of decision making.

Improving ecological connectivity and avoiding further habitat fragmentation will require action in all land-use sectors including agriculture and forestry, which should be guided by the Scotland Rural Development Programme, and in development and transport planning. At the landscape scale, tools are being developed that use information on species requirements including soil types and capacity to indicate how connectivity can be enhanced when planning habitat creation or restoration11. SNH is also developing guidance on the requirements for habitat networks.

Transport • How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

Reducing emissions from our pool fleet and from work-related staff travel, together with energy use in buildings and use of renewable energy, form our approach to reducing our overall CO2 emissions by 4% per year (over 30% by 2020). Actions on transport include: reducing the need to travel by further use of video conference equipment, better sharing of VC between public bodies, and better use of the web and telephone; applying a travel hierarchy within our travel and subsistence policy so that staff are directed to use the lowest-emission modes for work travel; reducing emissions from our fleet of pool cars by reducing the fleet size, using smaller vehicles with lower emissions ratings and (from April 2010) using a Fleet Administration system to monitor car speed, destinations and emissions to actively manage pool car use, encouraging eco-driving and car sharing etc; providing cycle storage at work places; managing emissions from other work-related travel (air, ferry, train, bus, bike, walking); and, developing carbon budgets for each management unit or office, with allocations reducing year-on-year. ------

11 A computer-based tool has been developed for this purpose – BEETLE – biological and environmental tools for landscape evaluation 7 A205281

Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010

Written evidence – Facing Up to Climate Change I!welcome!the!Scottish!Government’s!commitment!to!reducing!carbon!emissions!and!to! fostering!a!thriving!renewable!energy!sector!in!the!Scottish!economy.!Renewable!energy!is! amply!available!in!Scotland,!in!the!form!of!wind,!wave,!hydro!and!biomass.!But!while!each!of! these!options!can!rightly!be!regarded!as!cleaner!than!conventional!sources,!they!do!not! come!free!of!negative!impacts.!! ! Indeed,!the!current!rush!to!exploit!sustainable!resources!appears!uncoordinated!and! fragmented,!driven!by!large,!and!sometimes!illRfocused,!financial!incentives.!Some!of!the! decisions!that!have!been!made!seem!to!be!insufficiently!supported!by!scientific!evidence,! engineering!judgement,!or!analysis!of!the!!total!systemR!they!are!part!of,!and!so!are!likely!–! indeed!almost!certain!R!to!lead!to!unintended!adverse!consequences.!There!is!a!risk!that! public!investment!will!be!driven!by!dogma!and!shortRterm!expediency,!that!it!will!jeopardise! our!energy!security,!and!damage!our!environment!R!at!worst!to!no!good!effect,!and!at!best,! with!much!waste!of!opportunity.!We!can!and!must!do!better.! ! There!seem!to!be!six!things!that!we!need!to!do!together!to!meet!our!emissions!targets,! improve!our!economy,!and!protect!our!environment!and!our!quality!of!life:! 1. Eliminate!or!greatly!reduce!net!carbon!emissions!into!the!atmosphere! 2. Break!our!dependence!on!nonRrenewable!sources!of!energy!–!coal,!natural!gas,!oil!! 3. Establish!a!resilient!energy!supply!system,!making!effective!use!of!renewable! sources,!balancing!supply!and!demand,!and!guaranteeing!the!baseRload!supply!to! !keep!the!lights!on,!the!trains!running!and!the!factories!openR.! 4. Protect!the!natural!environment!that!makes!Scotland!such!an!attractive!place!to!live! 5. Ensure!that!clean!energy!makes!economic!sense,!and!avoid!using!financial!incentives! that!incentivise!perverse!behaviour!or!cause!unintended!consequences.! 6. Establish!a!thriving,!world!class,!sustainably!competitive!industry!that!will!make! Scotland!a!net!exporter!both!of!clean!power!and!of!clean!energy!technology.! ! The!efforts!the!Scottish!Government!are!making!to!stimulate!clean!energy!and!the!clean! energy!industry!are!mostly!good.!There!are!three!obvious!risks:! Premature!reliance!on!unproven!and!immature!technologies!! o Carbon!Capture!and!Storage!is!not!yet!proven,!and!in!any!case!will!not!be!100%! effective!and!is!not!!sustainableR!–!it!is!merely!a!stop!gap!until!the!fossil!fuels! run!out.!Wave!and!tidal!power!technologies!are!not!yet!proven!at!the!required! scale.!Satisfactory!mechanisms!to!store!energy!from!wind!and!wave!systems! until!it!is!needed!are!not!yet!established.! Unnecessary!damage!to!the!natural!environment!and!loss!of!natural!‘carbon!sinks’! o As!Professor!David!Mackay!points!out,!!renewable!energy!supplies!for!countries! require!country!sized!installationsR.!Unless!we!establish!proper!planning!controls! and!strategies,!renewable!energy!exploitation!could!damage!the!amenity!of! much!of!Scotland’s!remaining!wild!land.!Many!current!landRbased!wind!and!bioR fuel!proposals!would!damage!existing!peatRlands,!which!are!a!huge!–!indeed!a! countryRsized!R!!carbon!sinkR.!! Inability!to!maintain!base!load!when!the!current!nuclear!plants!are!decommissioned! o Nuclear!is!a!proven!way!of!providing!base!load!with!zero!carbon!during! operation.!Ruling!out!nuclear!as!part!of!Scotland’s!medium!term!energy!mix!is! likely!to!lead!to!continued!and!ultimately!unsustainable!use!of!fossil!fuels!for! base!load,!overRdependence!on!imported!gas,!and!reliance!on!the!unproven!CCS! technology!to!reduce!carbon!emissions.! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010

I!endorse!the!John!Muir!Trust’s!position!that!!by!adopting!a!more!strategic!approach!to!land! management!and!sustainable!energy!generation!we!can!avoid!the!need!to!consider! developments!in!sensitive!areas!–!renewable!energy!targets!can!be!met!without! industrialisation!of!our!most!precious!landscapesR.!I!would!add!that!we!should!not!fight!shy! of!imposing!the!highest!environmental,!ethical,!quality!and!economic!efficiency!targets!on! our!emerging!renewable!energy!industry.!German!industry’s!success!has!been!aided,!not! impeded,!by!working!to!the!highest!quality,!ethical!and!environmental!standards.!! ! The!International!Union!for!Conservation!of!Nature!(IUCN)!peatRland!project!estimates!that! deep!peat!covers!12%!of!the!UK’s!landmass,!and!stores!at!least!3,000!million!tonnes!of! carbon!–!twenty!times!as!much!as!is!stored!in!the!whole!of!the!UK’s!forest!biomass.!IUCN! suggests!that!protecting!our!peat!land!and!woodland!is!far!more!costReffective!than!other! forms!of!carbon!management!such!as!renewable!energy!development!and!bioRfuels.! Looking!more!widely,!biomass!projects!use!land!and!water!supplies!that!would!be!more! valuable!for!food!production;!hydro!schemes!alter!the!flow!of!rivers!and!streams;!and! industrial!scale!projects!of!any!kind!can!have!a!significant!detrimental!impact!on!remote!and! wild!landscapes.!! ! I!do!not!think!we!have!evidence!that!we!can!successfully!transition!to!a!balanced!and! sustainable!lowRcarbon!economy!while!protecting!our!environment!without!accepting! nuclear!as!part!of!the!mix.!Nuclear!power!plants!make!very!efficient!use!of!land:!they! generate!of!the!order!of!100R1000!times!as!much!power!as!a!wind!farm!occupying!the!same! land!area.!(Admittedly!this!does!not!take!account!of!land!affected!by!mining!the!uranium! ore.)!! ! At!a!personal!level!I!am!frustrated!by!the!lack!of!costReffective!solutions!to!reducing!the! energy!consumption,!and!hence!carbon!emissions,!of!existing!houses.!!Current!ecoRhousing! products!seem!to!be!driven!more!by!subsidy!and!fashion!than!by!sustainability!and!intrinsic! costReffectiveness.!Insulation!of!existing!houses!is!a!highly!effective!way!to!make!them!more! comfortable!and!reduce!carbon!emissions!and!energy!demand.!But!beyond!the!early!!quick! winsR!of!loft!and!cavity!wall!insulation,!costs!are!high!and!planning!guidelines!will!often! restrict!options.!!!!

Energy!supply!figures!and!security!risks:!what!are!our!targets!anyway?! Most!renewable!power!sources!are!only!‘on’!for!about!30%!of!the!time.!Some!are! predictable,!some!are!not.!6GW!of!installed!wind,!wave!or!solar!generating!capacity!would! generate,!on!average,!2!GW!of!power!over!the!year,!and!little!or!no!base!load.!Are!we! aiming!to!get!50%!of!our!CAPACITY!from!renewable!energy!plant!or!50%!of!what!we!actually! generate?!There!is!lots!of!room!for!manipulating!the!figures!!We!need!to!understand!the! whole!system,!its!dynamics,!and!the!potential!for!secondary!effects,!perverse!incentives,!and! unintended!consequences.!! ! Scotland!uses!about!5.5!GW!of!electricity!at!peak!demand.!This!demand!will!be!reduced!by! more!energy!efficient!homes!and!factories,!offset!by!increased!demand!for!high!speed!rail.! Scotland’s!generating!capacity!is!over!11!GW:!nuclear,!hydro,!coal,!gas!and!renewable.!This! means!that!either!we!export!half!of!our!production,!or!we!run!our!plants!at!50%!capacity,!or! somewhere!in!between.! ! Nuclear!power!is!carbon!free!during!operation!and!a!very!good!source!of!base!load.!It!is!not! fully!!renewableR,!but!the!fuel!can!be!made!to!last!much!longer!by!fast!breeder! technologies.!! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010

! Carbon!Capture!and!Storage!(CCS),!is!currently!a!major!area!of!investment.!Worldwide,!CCS! is!the!only!way!to!reduce!carbon!emissions!quickly,!given!the!worldwide!dependence!on!coal! for!power!generation,!so!from!an!industrial!point!of!view,!being!a!leader!in!CCS!is!attractive.! However!it!is!not!in!the!least!‘renewable’!or!sustainable.!Indeed!it!uses!coal!or!gas!faster! than!power!stations!with!the!same!output!to!the!grid!that!do!not!use!CCS.!It!is!not!carbon! free!–!CCS!is!only!likely!to!remove!80R90%!of!the!carbon!at!best!–!and!is!not!risk!free!–! industrial!scale!plants!are!not!yet!in!routine!operation.!While!it!seems!very!likely!to!work,! the!residual!technical!risk!means!that!the!time!it!will!take!for!CCS!to!become!widely!used!is! uncertain.!! ! And!finally,!efficient!renewable!energy!generation!from!wind,!wave!and!tide!will!need!good! electric!generating!devices.!These!need!powerful!magnets.!These!need!exotic!materials,! including!the!family!of!metals!known!as!!rare!earth!metalsR.!It!is!reported!that!China!has! sequestered!approximately!60%!of!known!reserves!of!rare!earth!metals!and!over!90%!of! refining!capacity.!So!we!need!to!pay!attention!to!security!of!supply!of!critical!materials!to! underpin!a!renewable!energy!industry.!(There!are!suggestions!that!as!Greenland’s!glaciers! recede!due!to!global!warming!they!are!starting!to!expose!previously!undiscovered!deposits! of!rare!earth!metals.)!!

References:! Prof!David!Mackay,!!Sustainable!energy!without!the!hot!airR! John!Muir!Trust!Journal!Spring!2010!–!(source!of!quotes!and!IUCN!reference)! The!Times,!March!9,!2009,!!China!takes!charge!of!keys!to!technologies'!futureR:!Leo!Lewis,! Asia!Business!Correspondent!! Digest!of!UK!Energy!Statistics!(DUKES):! http://www.decc.gov.uk/en/content/cms/statistics/source/electricity/electricity.aspx!! A!personal!perspective! Relevant!experience!and!expertise:!I!am!a!physicist!and!systems!engineer!with!over!30! years!industrial!experience.!I!have!worked!on!optical,!laser!and!infraRred!systems!and!major! projects!delivering!complex!systems,!and!spent!30!months!seconded!into!a!government! department!as!a!Senior!Civil!Servant.!I!am!a!fellow!of!the!Institute!of!Physics,!a!chartered! engineer,!a!Fellow!of!the!International!Council!on!Systems!Engineering,!and!a!visiting! professor!at!the!University!of!Bristol.!I!am!responding!to!the!consultation!as!a! knowledgeable!private!citizen!who!lives!in!Scotland!and!has!recently!attempted!to!take! climate!change!issues!into!account!when!planning!a!house!extension.! ! Perceptions!and!beliefs:!to!me,!as!a!trained!scientist,!the!climate!change!science!is!obvious.! If!we!pump!more!CO 2!into!the!atmosphere!the!earth!will!get!hotter,!the!ice!will!melt!and!the! oceans!will!rise;!or!we!will!trigger!secondary!feedback!mechanisms!we!don’t!understand!and! might!not!like!when!they!happen.!In!any!event!we!risk!deRstabilising!a!complex!dynamic! natural!system!that!we!do!not!fully!understand.!Finding!out!what!will!actually!happen!is!not! a!sensible!experiment!for!the!human!race!to!conduct!on!its!own!planet!!! ! That!this!is!a!problem!we!need!to!tackle!now!is!widely!accepted!by!the!political!classes!and! the!quality!press.!But!to!many,!even!the!intelligent!lay!person,!it!is!not!at!all!obvious;!and! there!is!a!big!gap!between!the!opinions!of!the!policyRmaking!elite!and!the!perceptions!and! beliefs!of!many!of!the!voting!public.!This!gap!will!set!people!against!policies!intended!to! mitigate!climate!change,!unless!they!also!make!economic!sense!for!the!businesses!and! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010 individuals!involved.!Many!of!the!public!–!and!politicians!–!believe!the!current!style!of! !scientific!argumentR!shows!lack!of!consensus,!and!is!an!excuse!for!inaction.!! ! There!would!be!merit!in!the!scientific!community!placing!more!emphasis!on!the! uncontested!evidence!provided!by!!leading!indicatorsR!such!as!arctic!ice!melt!and!increasing! concentration!of!atmospheric!CO 2;!and!on!scientific!education!seeking!to!improve!general! public!understanding!of!feedback!loops,!timeRlags,!and!the!inherent!unpredictability!and! potential!for!unintended!consequences!in!complex!systems!–!and!of!the!nature!of!science!as! a!continuing!voyage!of!discovery,!not!invariant!and!proven!!factsR.! ! Transport:!I!travel!a!lot!for!work!–!commuting!to!Glasgow!several!times!a!week!and! travelling!to!England,!France,!and!sometimes!further!afield!most!weeks.!I!usually!use!the! train!to!go!to!Glasgow!and!usually!fly!when!travelling!outside!Scotland.!Remote!conferencing! has!significant!limitations!compared!with!faceRtoRface!contact;!so!while!I!am!trying!to!reduce! the!amount!I!travel!for!work,!I!do!not!believe!I!can!stop!altogether.!! ! We!seek!to!minimise!our!car!use,!walking!when!practical!and!using!public!transport!when!it! makes!sense.!We!would!buy!an!electric!car!once!they!are!the!same!price!as!equivalent! conventional!ones!and!able!to!do!the!round!trip!from!Edinburgh!to!Glasgow!and!back! dependably!in!rushRhour!traffic.!We!will!not!buy!one!as!an!!ecoRgimmickR.! ! High!speed!trains!will!use!less!hydrocarbon!fuel!but!more!electricity,!compared!with!air!or! (currently)!road!transport.!A!high!speed!electric!rail!system!seems!to!be!an!essential! component!of!future!transport!strategy.!A!high!speed!rail!link!could!reduce!the!journey!time! of!rail!travel!between!Central!Scotland!and!the!south!of!England!to!a!time!comparable!with! air!travel,!improve!links!to!the!European!rail!network,!reduce!the!total!energy!required!for! interRcity!travel!in!the!UK!and!northRwest!Europe,!and!make!it!genuinely!carbonRfree!if! powered!by!nuclear!or!renewable!electricity!generation.!This!seems!to!be!the!only!practical! way!to!achieve!a!dramatic!reduction!in!energy!use!and!carbon!emission!for!interRcity!travel.! The!physics!of!flight!(as!outlined!by![Mackay])!prevent!dramatic!reductions!in!fuel!burn.! Though!year!on!year!engineering!improvements!in!aircraft!and!air!traffic!control!will!make! worthwhile!reductions!in!specific!fuel!consumption!and!carbon!emissions,!there!seems!to!be! less!scope!for!radical!reduction!in!carbon!emissions!from!air!travel!than!elsewhere.!! ! Biofuels!are!a!good!solution!for!niche!users!and!may!be!part!of!the!wider!mix,!particularly!if! it!can!use!otherwise!unproductive!land.!But!for!all!sorts!of!reasons!biofuel!must!not!be! allowed!to!use!land!and!water!resources!that!would!be!better!used!to!grow!food.!! ! Energy!infrastructure:!While!some!electricity!demand!is!variable!and!discretionary,!so!can! be!adjusted!to!match!the!availability!and!price!of!power!–!we!can!choose!to!use!the!washing! machine!when!the!wind!blows!–!other!demand!is!not.!Discretionary!demand!can!be! matched!to!supply!by!smart!grid!systems,!variable!pricing,!and!intelligent!management!of! appliances.![Mackay]!has!suggested!that!we!could!use!electric!car!batteries!to!store!power:! power!companies!could!!borrowR!electricity!back!from!charged!car!batteries!when!the!wind! stops.!But!we!need!to!keep!the!lights!on,!our!factories!producing!and!the!trains!running! regardless!of!the!weather.!Rail!systems!place!a!continuous!heavy!demand!on!electricity! supply,!which!cannot!be!met!by!wind,!wave!or!tidal!power!which!are!inherently!variable,! and!(in!the!first!two!cases)!unpredictable. You!can!imagine!that!you!could!get!some!sort!of! reasonably!dependable!base!load!of!a!GW!or!two!by!judiciously!distributed!tidal!power! systems!–!as!long!as!the!turbines!keep!turning!and!don’t!grind!to!a!halt!due!to!corrosion!and! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010 sand!ingestion.!There!is!scope!for!some!nice!modelling!to!see!how!much!base!load!might!be! provided!by!balancing!the!different!tidal!flows!around!the!coast!with!pump!storage.! ! Carbon!Capture!and!Storage!is!attracting!a!lot!of!interest.!If!successful!it!would!allow!us!to! carry!on!burning!fossil!fuels!to!generate!electricity!without!pumping!as!much!CO 2!into!the! atmosphere.!The!technology!is!not!yet!proven,!and!new!technologies!usually!take!longer! than!expected!to!work!reliably!and!efficiently,!and!may!have!unintended!consequences.!It! looks!like!CCS!might!remove!85R90%!of!CO 2!from!flue!gas,!and!use!10R15%!of!the!generated! power!to!do!so.!We!would!need!to!burn!more!coal!or!gas!than!we!do!now!to!generate!a! given!amount!of!electricity.!So!while!CCS!could!possibly!reduce!overall!CO 2!emissions!from! fossil!fuel!power!stations!by!80%!for!a!given!amount!of!power!supplied!to!the!grid,!it!does! not!make!them!!renewableR!–!if!anything!the!reverse,!the!resource!will!be!used!10R15%! faster.!! ! Hydro!electric!power!makes!a!useful!contribution!to!power!generation!but!there!simply!isn’t! enough!capacity,!installed!or!potential,!even!in!Scotland!with!its!mountains!and!rains,!to! meet!current!demand.!Some!time!ago!the!Hydro!Board!web!site!said!that!potential!hydro! generation!in!Scotland!was!2GW!of!which!the!easy!1GW!was!already!being!exploited.!There! may!be!potential!for!making!more!use!of!existing!hydro!infrastructure!as!pump!storage,!to! store!excess!energy!from!renewable!sources.! ! Another!way!of!storing!renewable!energy!until!it!is!needed!is!to!electrolyse!water!to! produce!hydrogen,!then!burn!it!to!generate!electricity,!or!transport!it!for!use!as!a!fuel! elsewhere.!The!science!works,!but!hydrogen!is!dangerous!to!handle!and!efficiency!is! (apparently)!quite!low,!so!the!engineering!challenges!are!significant.! ! Given!the!uncertainties,!risks!and!inherent!variability!in!other!options,!it!is!difficult!to! imagine!that!a!dependable!and!economically!effective!carbonRfree!electricity!supply!system! can!be!provided!in!the!near!term!without!including!nuclear!in!the!mix.!I!believe!it!is!a!matter! of!major!concern!to!this!enquiry!that!the!Scottish!G overnm ent!has!failed!to!publish!a! credible!scientific!body!of!evidence!–!or!indeed!any!evidence!at!all,!as!far!as!I!can!establish!–! to!prove!that!Scotland’s!requirements!for!secure!base!load!electricity!supply!can!be!met! without!the!use!of!nuclear!power.!! ! Modern!nuclear!plants!can!be!radically!better!and!safer!than!the!old!plants!they!would! replace.!Given!that!the!distribution!infrastructure!already!exists!it!seems!inadvisable!to!rule! out!the!possibility!of!building!new!nuclear!power!stations!on!the!existing!sites.!The!overall! system!should!be!designed!!holisticallyR!R!in!a!!joined!upR!manner!–!to!minimise!risks!and! optimise!wholeRsystem!wholeRlife!performance!and!cost.!A!good!design!principle!would!be! to!minimise!the!movement!and!degree!of!enrichment!of!radioactive!material!through!the! whole!life!of!new!power!plants.!While!nuclear!waste!disposal!is,!rightly,!an!emotive!issue,! the!actual!quantities!involved!are!small!–!minuscule!compared!with!the!amount!of!material! involved!in!the!coal!industry!and!the!stillRtoRbeRproved!concept!of!carbon!capture!and! storage.!The!interesting!prospect!that!nuclear!power!generation!would!be!the!most! pragmatic!way!of!disposing!of!noRlongerRneeded!nuclear!weapons!material!has!not!to!my! knowledge!been!discussed.! ! There!may!be!valid!arguments!and!evidence!in!favour!of!the!Scottish!Government’s!current! policy.!But!I!have!been!unable!to!find!any!credible!published!evidence.!A!strong!argument!in! favour!is!the!desire!to!stimulate!the!renewable!industry!by!a!clear!symbolic!commitment!to! the!need!for!change.!There!may!be!a!view!that!if!Scotland’s!nuclear!power!stations!export! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010 much!of!their!output!they!are!not!relevant!to!Scotland’s!power!needs.!However!other!things! being!equal!nuclear!is!a!lower!carbon!source!of!base!load!than!coal!or!gas,!even!with! successful!CCS,!so!if!the!objective!is!to!reduce!our!carbon!emissions!!as!quickly!as!possible,!it! would!seem!more!logical!to!have!more!nuclear!and!less!fossil!fuel!generating!capacity.! ! Solar!power!is!not!as!effective!in!Scotland!as!it!is!nearer!the!equator!because!we!are!a!long! way!north,!see!the!sun!at!a!shallow!angle!for!most!of!the!year,!and!have!clouds!quite!a!lot!of! the!time.!Solar!power!has!its!uses!but!it!is!never!going!to!be!a!major!contributor!to! Scotland’s!energy!supply.!It!should!be!used!only!when!economically!justified.!O f!the!solar! power!possibilities,!there!seems!most!merit!in!using!solar!thermal!power!for!water!heating;! though!prices!are!still!unattractive!and!costReffectiveness!dubious!when!a!mains!gas!supply! is!available.!! ! We!need!to!make!sure!we!do!not!encourage!solar!power!installations!!for!the!sake!of!itR! with!subsidies!that!distort!the!market.!Consumer!subsidies!should!focus!investment!on! practical!systems!that!have!a!realistic!prospect!of!being!economically!viable!without!subsidy! once!the!economies!of!scale!kick!in!and!fossil!fuel!prices!rise.! ! Similar!considerations!should!apply!to!the!enabling!infrastructure!for!tidal,!wave!and!wind! power.!These!power!sources!are!distributed!and!far!from!centres!of!population.!The!whole! life!whole!system!financial!and!carbon!cost!must!be!considered!when!deciding!on!the! balance!of!investment!between!renewable!generation!and!complementary!approaches!such! as!nuclear!power!and!better!insulation!for!houses.!Subsidies!must!not!become!the!steady! state!condition!for!renewable!energy!or!they!will!lead!to!market!distortion.!It!is!expensive!to! put!in!the!distribution!network!for!distant!wind!farms.!Clearly!the!first!wind!farm!should!not! have!to!pay!the!whole!cost!of!infrastructure!–!this!is!why!we!need!the!initial!subsidies.!But! the!subsidies!should!scale!down!as!the!installations!scale!up.!We!also!need!to!make!sure! that!we!maintain!clarity!of!purpose.!It!is!generally!asserted!–!though!it!is!difficult!to!find! evidence!–!that!the!embodied!carbon!and!energy!cost!of!a!wind!turbine!is!!repaidR!after!6! months!operation.!But!when!wind!farms!are!put!on!peat!land,!methane!is!put!in!to!the! atmosphere!as!a!result!of!the!damage!to!the!peat.!There!are!reports!that!the!global!warming! effect!of!the!greenhouse!gas!so!released!is!equivalent!to!a!!carbon!debtR!that!the!wind!farm! needs!over!11!years!to!repay.!Better,!and!public,!data!is!required!to!allow!independent! interested!parties!to!do!their!own!sums!to!build!confidence!that!decisions!are!being!made! on!a!sound,!wholeRsystem,!wholeRlife!basis.! ! Housing:!The!UK!plans!to!get!new!build!houses!down!to!zero!carbon!by!2016,!but!by!2050! 80%!of!the!housing!stock!will!still!be!"old".!Since!buildings!account!for!quite!a!large! percentage!R!something!like!30%!R!of!the!UK's!energy!use,!and!we!are!trying!to!cut!our! emissions!by!80%!by!2050,!the!sums!don't!add!up!unless!the!energy!efficiency!of!the!existing! housing!stock!is!radically!improved.!! ! O ur!personal!experience!is!salutary.!We!are!doing!a!house!extension!project!at!the!moment! and!looked!at!what!could!be!done!to!make!the!house!!greenerR!and!reduce!energy! consumption.!It!seems!that!the!!greenR!housing!market!is!still!immature!in!this!country,!with! vendors!offering!whatever!product!they!happen!to!know!about!rather!than!offering!holistic! wholeRsystem!solutions!to!the!!wholeRhouseR!problem;!and!apparently!driven!by!subsidies! as!much!as!by!fundamental!value.!! ! We!already!have!a!condensing!boiler!and!use!gas!central!heating,!and!have!made!the!cheap! wins!of!increasing!the!thickness!of!loft!insulation!and!putting!in!some!underRfloor!insulation.! Mr Hillary Sillitto, CEng, FInstP, ESEP; April 2010

Cavity!wall!insulation!has!already!been!fitted!to!our!house!but!is!not!very!effective.!It!seems! that!external!insulation!would!be!the!best!approach!to!reduce!our!energy!costs!and!carbon! footprint,!could!bring!the!house!close!to!PassivRHaus!standards,!and!would!greatly!reduce! our!exposure!to!rising!energy!costs.!But!at!current!prices!this!still!looks!very!expensive!and! there!are!issues!to!do!with!maintaining!light!through!windows!and!the!external!appearance! of!the!house.!In!conservation!areas,!planning!controls!presumably!rule!out!external! insulation!altogether.! ! We!looked!at!solar!water!heating!systems;!but!these!are!expensive!and!don’t!produce! enough!power!to!make!a!useful!difference!to!our!annual!energy!use.!Solar!systems!make! more!sense!further!south,!but!are!of!limited!value!in!Scotland.!! ! Air!source!heat!pumps!are!very!expensive.!And!because!of!the!lower!coefficient!of! performance!in!cold!weather!(about!300%)!and!the!power!station!conversion!efficiency! (about!30!%),!it!seems!that!we!would!use!as!much!carbon!with!an!air!source!heat!pump! powered!by!a!gas!fired!power!station!as!we!do!at!the!moment!using!an!efficient!condensing! boiler!(which!is!over!90%!efficient).!Ground!source!heat!pumps!are!much!better!because!the! temperature!of!the!ground!is!more!stable.!They!are!good!for!new!build!and!large!gardens! but!difficult!to!retrofit!if!your!garden!is!small.! ! The!Renewable!Heat!Incentive!(RHI)!will!hopefully!jumpRstart!the!market!for!heat!pumps!and! solar!thermal;!the!consequent!increase!in!volumes!should!increase!competition!and! innovation!and!drive!down!prices.!As!the!proposals!stand!at!the!moment,!there!is!a!risk!that! demand!will!outstrip!supply!when!the!RHI!comes!into!effect,!leading!to!rising!prices!and!a! rush!of!imports,!and!that!the!requirement!to!have!systems!serviced!by!approved! maintainers!will!result!in!excessive!prices!for!the!maintenance!service,!reducing!the!benefit! of!the!RHI!to!consumers.!! ! The!other!key!component!of!low!carbon!housing!is!air!circulation!and!heat!recovery!systems.! These!are!designed!to!maintain!healthy!air!circulation!and!maintain!comfortable! temperatures!with!minimal!energy!loss.!These!are!bizarrely!expensive!considering!the! relative!simplicity!of!the!technology.!Comparison!of!similar!systems!in!the!automotive! industry!suggests!that!with!high!enough!production!volumes!we!have!a!right!to!expect!that! prices!will!come!way!down.! ! In!summary,!much!of!the!!green!housingR!market!seems!to!be!driven!by!subsidy!and!public! sector!procurement!rather!than!a!rational!marketRdriven!response!to!the!prospect!of!rising! fuel!prices!and!more!extreme!temperatures.!This!is!probably!a!good!way!for!government!to! kickRstart!the!industry,!but!subsidies!must!accurately!reflect!long!term!whole!system! benefits,!otherwise!they!risk!introducing!perverse!incentives!leading!to!market!distortions! and!other!unintended!consequences.!!!

Summary The!nub!of!the!generation!issue!seems!to!be!whether!the!lights!will!go!out,!or!whether!in! fact!Scotland!exports!so!much!power!that!we’ll!be!OK!even!if!we!mess!it!up!!It!is!a!concern! that!much!of!our!aspirations!depend!on!rapid!exploitation!of!immature!technology!of! uncertain!costReffectiveness,!and!that!the!costReffectiveness!of!existing!technologies!is!poor.! Carbon!Capture!and!Storage!is!not!!renewableR!or!!sustainableR.!Subsidies!must!not! become!the!steady!state!condition!for!renewable!energy,!or!provide!perverse!incentives! leading!to!unintended!consequences.!A!holistic!and!sustainable!!whole!systemR!approach!is! needed.!!! L ! "# ! ! $ $ % L & ! ' $ ( ! )) # # ) "# % L ' $ # *

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a I D { /9 CL t 9{9t W

Our Ref: DG/PS ORG13-A2537. :

Dr Marc Rands, The Royal Society of Edinburgh, 22-26 George Street, Edinburgh EH2 2PQ 3rd May 2010 by email: [email protected]

Dear Marc

ROYAL SOCIETY OF EDINBURGH INQUIRY - FACING UP TO CLIMATE CHANGE

Thank you for providing the Scottish Environment Protection Agency (SEPA) with the opportunity to comment on the Royal Society of Edinburgh Inquiry - Facing Up to Climate Change. Although Peter Singleton and I gave verbal evidence to the Enquiry we thought it was worth responding briefly to the issues you raise in your call for evidence.

SEPA’s State of the Environment Report1 showed that climate change will have a major impact on the environment and has the potential to undermine the environmental improvements that have been achieved across Scotland in recent years. Climate change affects the natural environment on which we depend and can have far-reaching consequences for our economy and society. It presents major threats and major opportunities.

In the Climate Change (Scotland) Act 2009, Scotland has made a major commitment to action on this issue. The challenge for all in Scotland, individuals, the private and public sector is to translate this commitment into action. SEPA believes that Scotland can and will give significant leadership in this area over the next 5 – 10 years. To achieve this we will need to break down existing barriers and work together in new and innovative partnerships. For instance SEPA is represented both on the 2020 Climate Delivery Group – made up of both public and private sector and on the Public Sector Climate Challenge Group.

As a public body committed to openness and transparency, SEPA feels it is appropriate that this response be placed on the public record. If you require further clarification on any aspect of this correspondence, please contact Peter Singleton, Environmental Futures and Trends Unit Manager, at the address shown below.

Yours sincerely

Dave Gorman Head of Environmental Strategy

1 http://www.sepa.org.uk/publications/state_of/2006/main/index.html

Corporate Office Erskine Court, Castle Business Park, Stirling FK9 4TR Chairman Chief Executive tel 01786 457700 fax 01786 446885 David Sigsworth Dr Campbell Gemmell www.sepa.org.uk

Organisations

Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

The changing climate clearly has an affect on the environment and thus needs SEPA to adjust its policies and practices to continue to protect the environment. Given the long term nature of many developments, SEPA also requires the capacity to predict future climate, to enable it to make valid environmental assessments. Operationally, changes to Scotland’s weather may also require SEPA to change working practices for staff safety etc.

- What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

This will be clearer when the Public Sector Duties under the Climate Change (Scotland ) Act, which are due to come into force on 1st January 2011, are implemented. SEPA regulates businesses and organisations responsible for a significant proportion of Scotland’s GHG emissions. However, in many cases we have limited or no ability to require a reduction in these emissions. It is a risk to SEPA that our decisions will be challenged either by environmental charities seeking a GHG reduction, or by a business who believe our regulation to be too onerous.

The changing climate will also impact SEPA’s scientific monitoring and analysis, requiring new monitoring to be undertaken, as well as impacting on fundamental scientific and modelling assumptions.

The need for leadership in this area will also drive further SEPA action on facilities management, travel and transport, energy consumption and so on.

- What do you plan to do in response to these factors over the next 5 – 10 years?

SEPA has already developed a Climate Change Action Plan, and Climate Change is now a Corporate Outcome embedded within strategic plans. This should ensure that the issue is continuously assessed to ensure that the organisation is making an appropriate response.

- How integrated is your response with other organisations in similar or related fields?

SEPA worked closely with the Scottish Government in developing our Climate Change Action Plan and generally in the development of the Climate Change (Scotland) Act. There is also an ad-hoc Climate Change group consisting of SEPA, Scottish Natural Heritage, Historic Scotland and the Forestry Commission (Scotland). SEPA is a funder and member of the development group of the Scottish Climate Change Impacts Partnership.

- What are the main barriers to change for you and/or your organisation?

The key barrier is the sheer size of the task and the cross-cutting nature of both climate change and society’s response to climate change. There are also the usual internal barriers to introducing new and challenging issues to an organisation. A specific concern is the ability of SEPA to regulate comprehensively for climate change, given the limitations imposed by existing regulations.

What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

The key issue for SEPA is for action to be taken to limit and adapt to climate change. This requires all possible measures - carrots and sticks. Regulation to set a minimum acceptable standard, trading to promote and innovate in the desired direction and incentive schemes to support early adopters.

Energy generation What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure? - It is not SEPA’s view that there is a major public perception issue with renewables. The key issues for SEPA are clarity of advice and guidance, and clear methodologies for identifying the “desirable” schemes from the “less desirable” ones.

How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020? - This is an enormous challenge and requires clarity of thinking and objectives. To achieve this we need to clearly identify how this can be started with today’s technology and how to continuously innovate as better technology becomes available. For instance, what are the relative merits of biomass based technology over heat pumps at present? Comprehensive action is needed on incentives, funding, planning, building regulations, skills development and advice.

What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020? - This is also an enormous task. It is likely Scotland is on track to achieve a high percentage of renewable electricity generation. However, it is in extending this to renewable energy that the real challenge appears, with the most likely route being an increased use of electricity for heating and transport. This requires a significant injection of effort (intellectual, financial, organisation and physical). This will require a large number of households and business to switch to renewable heat and a significant injection of renewable energy into the transport network, which may be best achieved via public transport.

Is there sufficient action to exploit the potential of microrenewables?

It is essential that this issue is correctly thought through so that effort is expended on micro-renewables that really make a difference, but not wasted on “token” micro-renewables that do not actually make a significant difference.

What are the obstacles to cutting energy use?

Price and rebound. It is important that the market promotes & rewards energy efficiency. However, we also need to be aware of the rebound effect when designing policies.

Land use How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats?

An enormous strategic challenge which is at the heart of the Land Use strategy that is being developed by the Scottish Government as a result of the Climate Change (Scotland) Act. Scotland needs to identify the land available, and prioritise it use according to sustainability, suitability and national needs.

What do you see as the major barriers to changing rural land-use activities in this way?

The fundamental change required in the way we use our land. Major elements of present policy are effectively designed to promote food and forestry, with an acknowledgement for the need for nature conservation. The challenge is to add carbon storage and renewables development. There are opportunities in the next “re-shaping” of the EU Common Agricultural Policy, but the historic inertia is a major factor.

Buildings What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events? - How should Government ensure that business/domestic energy efficiency measures are met?

Mandatory surveys and implementation of energy efficiency measures, funded via existing buildings related council tax e.g. installation of insulation/and or micro-renewables free of change, but funding reclaimed by increases in council tax.

What are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act?

Transport How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

Applying the principles of a Travel Management Hierarchy could go a considerable way to helping achieve a 30% cut in transport emissions. SEPA already uses this principle which broadly looks like this:

MOST PREFERRED

1. Question the need to travel in first place. Can email, telephone or video conferencing replace need to physically travel? 2. If necessary to travel, use public transport such as train and bus before travelling by plane or car. 3. If no alternative is available to a flight, is it possible to fly one way and return by train? 4. If you have to drive, can you car share? Can you use a modern, more efficient pool vehicle to travel part of the journey and public transport for the rest? 5. the lest preferred mode of travel is alone in a car or flying both ways

LEAST PREFERRED

SEPA could feasibly cut our business car mileage by 30% by removing the need to physically travel between our own buildings. Instead we would rely on a greater use of tele- and video-conferencing. Barriers include the belief that face-to-face meetings are superior to virtual meetings and that cutting direct, environmental regulatory and monitoring travel is more problematic as a significant proportion of regulation and monitoring is a statutory requirement.

Pool vehicle emissions may be cut by switching to smaller, more efficient vehicles e.g. replacing 4x4s with equivalent diesel engine to those of small vans with similar off road capability. However there is a probably a limit to how far this kind of efficiency measure can go.

Flights can be reduced further by improving video and teleconferencing – and by changing requirements of other agencies and UK govt departments to require a physical presence at regular meeting less often

ROYAL SOCIETY OF EDINBURGH – INQUIRY INTO FACING UP TO CLIMATE CHANGE:

RESPONSE BY SCOTTISH ESTATES BUSINESS GROUP

1. BACKGROUND

The Scottish Estates Business Group (SEBG) represents a group of progressive land-based estates with significant agricultural and rural business interests. It aims to promote a modern business approach in the management of Scotland's land resource in ways which deliver social, economic and environmental benefits. The group seeks to secure a sustainable and prosperous future for rural areas.

Estates are proven business models that assist the development of smaller rural businesses, and landowners and estates have a vital role to play in the ongoing and future development and prosperity of Scotland. SEBG is committed to rural economies and its members work hard across Scotland to stimulate enterprise and economic development.

2. OVERVIEW

SEBG welcomes the opportunity to offer comments on a range of issues. As a group representing a number of Member Estates, we need to reflect generic rather than specific issues and responses. Estates encompass a wide range of activities - environmental and social as well as economic. Whilst frequently diverse, together they serve to support and enhance an overall role for the estate at the heart of its local community. Estate land management and planning is essentially aimed at long-term objectives and viability, with a much longer view taken than that of most other commercial businesses.

Estates have the benefit of being multi-functional businesses, where one element or business operation might impact on the practice of another. Innovation in one area might be transferable to or have implications for another. However, notwithstanding the implications of the leasing of land on the extent to which its use can be controlled, Estates are better placed than most to apply a holistic approach to land management and to be able to resolve spatial issues, for example flood plain or whole water catchment management.

With their interests being spread across a number of land use sectors, land management issues which are central or relevant to tackling climate change also tend to play a centre stage role for Estates - for example moorland and forestry management and their roles in carbon storage and sequestration; availability of resources suitable for use in the production of renewable energy such as biomass, wind, and hydro; a range of businesses to which energy efficiencies or emissions reduction measures might be applied; and optimum land use as already mentioned.

At a strategic level, of particular relevance to topical consideration of measures aimed at addressing the impacts of climate change is the developing debate on the future direction of the Common Agricultural Policy (CAP) post 2013. Support systems have a key role to play if policy behaviours are to be changed, and over the years CAP has proved to be a primary driver of policy change at the micro as well as macro level. To date, this tool has been used to direct the growing of food and latterly energy crops. Now emerging thinking appears to suggest a shift in focus from production towards the delivery of public goods i.e. those desirable outputs for which there is no existing economic market, such as biodiversity. However, other objectives will need to be factored in too, such as the retention of rural communities in remote areas in order to deliver continued best practice in land management in 1

Chairman: Sir Alastair Gordon Cumming Deputy Chairmen: David Greer, Atholl Estates and Sandy Lewis, Seafield Estates Head Office: 27 Silvermills Court, Henderson Place Lane, Edinburgh EH3 5DG Tel: 01620 861898 Email: [email protected]

the context of mitigating climate change and maximising optimum land use, carbon storage management and sequestration – arguably also public goods. When competing pressure on land use in order to enhance food and energy security is factored in, the picture becomes even more complicated and difficult to manage. Yet at the heart of these issues lies land.

That role must necessarily be played in partnership with Government, public agencies ands other stakeholders not only to help to deliver public objectives, but also to show leadership in the promotion to peers of best practice in innovative land management.

3. RESPONSES TO SPECIFIC QUESTIONS

Q. Do you perceive the changing weather patterns in Scotland and globally as affecting you and / or your organisation?

A. It is predicted that the likely effect of climate change in the UK, and in particular in Scotland, is likely to be more volatility in the weather patterns. Predictions suggest that the west will get wetter and the east will become drier. Changes in rainfall could significantly affect the ability of Scotland’s fertile arable east to produce crops without some form of irrigation systems being put in place, whilst increased precipitation in the west may cause problems for the dairy sector in terms of waterlogged fields. It is also predicted that there will be an increase in the number of extreme weather events such as flash flooding, which will in turn impact significantly on land management.

Scientific predictions indicate greater impacts of climate change for lower latitudes, which if proved correct will inevitably have a knock-on effect on the planet’s capacity to grow enough food to feed its population. Consequently, greater pressure can be expected to be placed on the more northern and southern expanses of productive land to produce the food required to feed an ever-increasing global population.

Demographic changes can also be expected, which may also have a direct impact on competing demands for land use in Scotland. Migration of population from more badly affected climates will create increased demand for housing in more temperate climates. For Scotland, this is likely to add to pressure on land for housing, particularly in the drier East - where the more productive lands are to be found.

Q. What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

A. The legislation can be expected to lead to yet more regulation, but also possibly greater incentive to manage natural resources to better effect - to reduce greenhouse gas emissions; to protect natural resources, particularly peatlands and water catchments to minimise the impact of flooding, and improve the quality and availability of water; and of course to maintain and enhance those habitats that lock up carbon, including peat and forestry. A focus on the various activities involved in farming can also be expected, in particular how farming might respond to the challenges of reducing greenhouse gases.

There will clearly be a significant change in the way land assets can be used to produce different forms of renewable energy and heat, and the energy efficiency performance of the built portfolio will need to be looked at, to see how it might be improved further.

All of this suggests that landowners will need to re-evaluate and re-assess how assets might best be utilised in order to achieve the integrated set of outcomes required to meet the challenges of climate change. Changes to Government’s financial support systems will also be needed if its targets are to be delivered, and local authorities and other stakeholders will also need to adjust their polices to deliver the changes in practice that will be required.

Q. What do you plan to do in response to these factors over the next 5-10 years?

A. A number of Scotland’s Estates have begun or are looking to Strategic Land Use Reviews, in many cases working closely with their local authority to identify development options and opportunities. Linked to this will be a need to consult with local communities, including farm tenants, to identify the best ways to develop the business mechanisms needed to bring together the range of skills, interests and investment that will be required.

In Scotland’s upland areas, a shift away from food production towards the provision of public goods – environmental benefits such as biodiversity protection and enhancement, water course management, moorland management for carbon conservation for example - must surely be expected. However, the ability to adapt will very much depend upon the outcome of CAP reform discussions and the size of the budget to be directed towards facilitating change.

Q. How integrated is your response with other organisations in similar or related fields?

A. It will become increasingly important for land management organisations to work ever more closely with other organisations, other stakeholders and communities in order to deliver the range of activities and benefits that will be required in the future. Scotland’s land resource is finite and the availability of usable land is shrinking, so it is therefore vital that maximum benefits be achieved from Scotland’s land resource. This will require an approach that brings together all the different sectoral interests in order to identify optimum complementarity and minimise conflict between different land use activities.

Q. What are the main barriers to change for you and your organisation?

A. Certainly, the lack of appropriate business vehicles and mechanisms for delivery of land use and business objectives is one of the major barriers to change. The various forms of agricultural tenancy which have evolved over time make change, diversification and innovation difficult to deliver. What is needed is much more flexibility in tenancy arrangements. Allied are the costs of innovation and diversification, and the (lack of) availability of reasonably priced finance for investment.

A further significant barrier is the approach taken by local authority planning departments and the incredibly difficult process of securing the consents necessary to undertake land use development. The new planning legislation should encourage local authorities to focus more on rural land use and development. In the process of developing the next set of Local Plans there should be an opportunity for landowners and managers to work with and influence the direction of policy for the future.

Q. What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

A. The development of environmental markets – which introduce market forces into the delivery of a wide range of desirable environmental goods and services – could provide a useful route for 3

financial support to be made available to land managers to continue delivering those outcomes desired by the public but for which there is currently no price mechanism. For example, money could be paid to land managers by large carbon emitting organisations to look after their moorlands appropriately, or to plant trees. Similarly, the introduction of a suitable mechanism for carbon emissions trading could be of enormous benefit in the UK and in particular to land use based businesses. There is however a need for the science associated with the measurement of carbon sequestration and emissions to be developed and an appropriate carbon calculator for rural land uses to be introduced.

In terms of incentive schemes, there is little doubt that historically farmers and rural land use businesses respond better to the carrot of incentive schemes and less well to the stick of regulation. By way of example, regulations on energy performance standards are being imposed on landlords yet the benefits accrue not to the landowners required to invest to comply with them, but instead to occupiers who, more often than not, are not prepared to reflect the benefit they receive in increased rents for the properties concerned. It is therefore of little wonder that landowners are reluctant to do more than the minimum required to meet their regulatory obligations.

4. QUESTIONS BY ISSUE

Energy Generation

Q. What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure?

A. Certainly for wind energy generation there are significant concerns over landscape impact and therefore there really is a requirement for a clearer strategy from the Government and local authorities that will identify key areas where wind farms of appropriate scale should be encouraged and areas where it should be discouraged. Landowners and Estates should have a major part to play in developing such a strategy. In terms of land for food or land for energy, Scotland is in a global market, and what is done in Scotland is unlikely to have any significant effect on food security in Europe or more widely. Because of its climate, Scotland is well placed to grow crops that can be used for energy, so this opportunity – where appropriate – should not be missed.

Q. How do you see 1 in 10 buildings being heated by renewable heat technologies in 2020?

A. Currently, the technologies associated with renewable heat are young and little understood by the general public. Capital costs are currently high and for some renewables the payback period remains long. Nevertheless, there is certainly a real opportunity for micro generation in upland and highland areas of Scotland – through for example biomass boilers, ground source and air source heat pumps and solar - and the economics for these schemes does appear to be attractive, particularly if a heat ROC is to be introduced in 2011 to encourage the use of this technology.

There may be an opportunity in regard to the high capital cost technologies for greater cooperation between landowners and land managers to share the cost and reward involved. New builds should be obliged to include the installation of renewable technologies.

Q. What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

A. The facilitation of greater investment in renewable energies will very greatly be influenced by the approach of Government and local authority planning and the extent to which financial support may be available to potential investors. As previously stated, there is certainly a need for advice on different business vehicles and mechanisms that might be used to bring together the relevant interests and skills to achieve delivery. If this can be done effectively, the financial institutions might be more interested and supportive of investment in this sector.

Q. Is there sufficient action to exploit the potential of microrenewables?

A. Not in the rural sector - there is no obvious strategy nor any clearly directed advice.

Q. What are the obstacles to cutting energy use?

A. In the rural sector there needs to be greater use of precision farming to reduce the quantities of fertilisers and chemicals being used to produce food. This is a win-win situation where farmers can save money and also contribute to the reduction of carbon emissions. There may also be merit in looking at nutritional regimes for beef and dairy cattle to achieve reductions in methane output. In the property sector there is little incentive for landlords to invest in increasing energy efficiency unless there is support available from the Government to do so, due to the fact that the benefits of this investment accrue primarily to the occupier and are not reflected in the rents an occupier is prepared to pay currently.

Land Use

Q. How can we use our land most efficiently for energy, agriculture and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity and wildlife habitats?

A. Earlier answers have covered this point. A whole water catchment and whole landscape approach to management which disregards land ownership boundaries is highly desirable. Greater incentive, perhaps through SRDP, for adjacent landowners or managers to co-operate to achieve broader objectives must be given greater emphasis in future. Ways of valuing public goods will also enable encouragement and reward to be given to land managers where currently there is no reward for many of the public goods being provided. SEBG awaits with interest the Scottish Government’s draft Land Use Strategy, due to be issued for consultation later this year. It is to be hoped that the Strategy might offer pointers on how best to use Scotland’s finite land resource in order to achieve maximum benefits.

Q. What do you see as the major barriers to changing rural land-use activities in this way?

A. The main barriers to change revolve around the decision making process. Decisions will largely be based on economic sustainability and viability, underpinned by regulation where these relate to good practice and protection of the environment. The nature of land holdings being as they are, i.e. small geographic units, mitigates against a holistic approach to dealing with these issues and therefore greater effort needs to be made to find ways of encouraging landowners and managers to work more together to transcend ownership boundaries.

Changing mindsets is also very important, if farmers are to be encouraged to be innovative and to farm in a different way, to plant areas with trees, or to install renewable technologies.

Transport

Q. How could your organisation’s transport emission be cut by 30% by 2020, and what are the barriers to achieving this?

A. The agricultural industry is not a major emitter of greenhouse gases from transport activities. Other than, in due course, to convert machinery and farm vehicles to biodiesel usage or other renewable energy fuels, it is difficult to see how any significant reductions can be made in the sector.

SEBG 30th April 2010

SCV O response to the Royal Society of Edinburgh’s Inquiry: ‘Facing up to climate change’

The Scottish Council for Voluntary Organisations (SCVO) welcomes the opportunity to contribute to the Royal Society of Edinburgh’s inquiry, ‘Facing up to climate change’. SCVO recognises its responsibility to address the issue of climate change and to support others across the sector in doing the same.

Scotland’s voluntary sector includes 45,000 formally constituted voluntary organisations, generates £4.1 billion a year and provides paid employment for 130,000 people. SCVO seeks to advance the values and shared interests of the voluntary sector.

Two of the underlying themes to SCVO’s work are to promote equality, and to take, promote and embed a sustainable development approach. We recognise that unmitigated climate change challenges those values. If we do not carefully nurture our natural environment, the social and economic implications of climate change will be disastrous for communities around the world. It is the most vulnerable in society who are already being hit hardest by the impacts of such change and yet it is often those same groups, living low-carbon lifestyles, who are least responsible for the high emissions levels.

Fundamental to SCVO’s work is building resilience and strengthening communities and this will be an essential element of adapting to climate change. Given the diversity of the organisations which SCVO represents, our response raises issues faced generally by the voluntary sector. Individual organisations may be able to respond more specifically.

What are your views on the following issues based on your expertise/ experience: a) Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

Based on predictions for Scotland1, we anticipate that changing weather patterns will bring generally warmer and wetter winters and hotter, drier summers, with a concomitant increase in extreme weather events. We also anticipate rising sea levels.

In some respects, warmer climes have the potential to reduce energy demand in winter so easing levels of fuel poverty and thereby benefiting particularly tenants in rented accommodation, and organisations responsible for providing services to those living in poverty (especially women and children), older people, and other vulnerable groups. However, this is clearly dependent on a minimum quality of housing, as temperature is not the only factor and unless homes and buildings are well insulated, any increase in humidity could counter this benefit with associated detrimental health implications.

As has been demonstrated in recent years, incidences of flooding and storm surges in Scotland have resulted in serious disruptions and damage to transport, housing and access to services as well as lives and livelihoods. Such events can have a direct impact on voluntary organisations – as exemplified by the care home in Huntly which had to evacuate its 20 elderly residents in the middle of the night during the November 2009 floods – as well

1 Scottish Climate Change Impacts Partnership www.sccip.org.uk/Default.aspx?pid=1

1 as resulting in an increased demand for their services2. This is not just for assisting with the immediate emergency but, significantly, in the long term providing support to communities and individuals long after the weather event itself has subsided. This may involve organisations working with the homeless and unemployed, as well as providing psycho- social services for those suffering depression and mental health problems.

Many voluntary organisations whose core objectives are environmental and/or developmental have been working with international communities which are already suffering the effects of climate change overseas. Their services too will be in increasing demand as the effects become more sustained and frequent. But the impacts of these will also be felt locally as voluntary sector services within Scotland are called on to support a growing number of climate migrants in need of access to housing, jobs, health services etc.

From an operational perspective, we anticipate that organisations will need to adjust their working environments to ensure offices remain comfortable. There is likely to be increasing occurrence of disruption, especially to travel plans resulting from weather events, affecting attendance at meetings, visits etc. This could threaten the sector’s effectiveness, especially in relation to work with remote communities.

b) What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

Whilst the voluntary sector is not subject to specific requirements under the Act, there are implications for its vast range of activities:

Targets: To set an example, SCVO is assessing its own carbon footprint and plans to set and report on annual emissions reductions targets as part of a new environmental management regime. Voluntary organisations individually will be encouraged to take practical action and SCVO aims to support them in this, which requires additional resources.

Duties of public bodies: Voluntary sector interaction with public sector bodies may be affected by their own requirements to consider climate change in their actions. This could result in voluntary organisations having to adapt their service provision accordingly; and/or finding favour as a provider offering means for public sector bodies to fulfil this requirement.

Adaptation: The Third Sector has a recognised role in building resilience to climate change3. Voluntary organisations have the potential to serve as catalysts for action by working with community groups at local level, as well as ensuring that the most vulnerable in society are not excluded from the necessary adaptation measures. However, planning and implementation of such measures will require significant resources, coordination and collaboration to be effective.

Land use strategy: The proposed new strategy could provide increasing opportunities for community asset development which means voluntary organisations potentially taking on risk through investment and responsibility of ownership/leasing of land and property for community benefit.

Forestry: In the modifications to the functions of the Forestry Commissioners, SCVO is keen to ensure that any resulting corporate activities on the National Forest Estate or sale of land optimise opportunities for community involvement and benefit, e.g. in wind power

2 British Red Cross (2008). Consultation on Proposals for a Scottish Climate Change Bill: British Red Cross Response 3 Scottish Government (2009). Scotland’s Climate Change Adaptation Framework

2 developments; this would bring associated investment and risk implications for such communities.

Energy efficiency: Many voluntary organisations will need to take measures to improve energy efficiency at their premises. Anticipated tightening of building regulations, rising fuel prices, as well as emissions reduction targets, will be drivers across the sector but these bring considerable cost implications. The incentives resulting from the Act open up opportunities for the sector in support of efficiencies, notably in renewable energy generation, though these too require investment capacity.

Public engagement: The voluntary sector’s networks reach right across society and with so much activity at both national and local level, community organisations can promote engagement on climate change as part of what they do, making it relevant to local and national audiences. There is already expertise in the sector and with additional resources these could be effectively deployed.

c) What do you plan to do in response to these factors over the next 5-10 years?

SCVO operates several offices and has been taking measures to improve its environmental management of all of these. New recording procedures will need to be incorporated into financial and management systems to account for carbon, as well as continued engagement with staff to emphasise the significance of mainstreaming climate change in all areas of SCVO’s operations. We are exploring opportunities to install renewable energy technologies, as is currently under consideration at SCVO’s new Glasgow premises.

SCVO is working to increase capacity of voluntary organisations to address climate change in the sector at a practical level, through workshops, training events and provision of information on its ‘green web pages4. In addition, SCVO with Scottish Environment LINK has established a simple carbon accounting tool, CarbonLINK, to assist voluntary organisations to assess their own emissions. Addressing the required mitigation and adaptation measures requires investment of time and resource by voluntary organisations which are already extremely stretched. Subject to funding, we plan to establish an applied programme to support voluntary organisations to embark on emissions reductions initiatives.

We believe there is potential for strengthening communities through community asset development, particularly local renewable energy initiatives. As exemplified by the communities of Gigha and Fintry, such investments provide a long-term source of income, as well as energy, which further builds community resilience. In addition, ownership of such projects automatically engages community members in climate change issues. SCVO is exploring how best it can facilitate the sector in renewable energy development and is examining avenues to provide investment support.

SCVO has established a Green Reference Group, drawing on representatives of organisations across the sector, to steer the organisation’s green agenda and to inform its response to Government policy on climate change.

SCVO will continue to contribute to ongoing policy development on climate change, although we feel the lack of voluntary sector representation on the 20:20 Delivery Group is a missed opportunity. The sector can provide solutions, particularly in promoting engagement on climate change and in providing green jobs. The range of organisations already working, for example, in conservation, community learning, renewable energy, sustainable transport,

4 www.scvo.org.uk/green

3 waste management, greenspace, local food, etc, demonstrates this. The sector’s involvement with the Future Jobs Fund, facilitated by SCVO, can further support this.

d) How integrated is your response with other organisations in similar or related fields?

SCVO is actively encouraging voluntary organisations to address mitigation of their emissions. We are currently working in partnership with the National Union of Students on a pilot project in Aberdeen to carry out energy audits for local voluntary organisations. The intention is to roll out the programme more widely.

We have collaborated on joint events: with the Carnegie UK Trust on a seminar specifically targeting non-environmental third sector organisations to highlight the economic and social implications of climate change; and on the wider civil society agenda, with a range of organisations, including the Royal Society of Edinburgh, for which one of the key discussion themes was climate change5.

We confer with our sister organisations, the National Council for Voluntary Organisations (NCVO - England) and the Welsh Council for Voluntary Action (WCVA). Following publication of the report, ‘Shaping our future’6, SCVO has been invited by the Green Alliance to participate in a three nations round-table with NCVO and WCVA to explore potential synergies for taking forward opportunities on climate change by the Third Sector.

SCVO is a member of the Climate Challenge Fund Supporting Alliance, providing assistance to community projects, especially on governance issues; we are also a member of Stop Climate Chaos Scotland and have supported its campaigning work and played an active role in The Wave demonstration in December 2009.

SCVO also works closely with both Scottish Environment LINK, which brings international connections through its global networks, and Eco Congregation; we supported the latter’s amendment to the Climate Change Bill to incorporate the commitment to a Public Engagement Strategy.

Voluntary organisations are involved at varying levels with local government, including on community planning partnerships, through which they can contribute to the climate change agenda; they are also working amongst themselves on a range of collaborative programmes. In addition, a number of organisations, such as the British Red Cross, work closely with local authorities in relation to building resilience and emergency responses.

e) What are the main barriers to change for you and/or your organisation?

The identification of areas where there can be significant, year on year, carbon emissions cuts in the internal operations of an organisation which do not jeopardise the achievement of core activities, nor conflict with other regulations, is increasingly difficult. For example, poor building design in one of SCVO’s premises and official listing of another means there are limits to what can be achieved in terms of further energy efficiency without substantial cost implications. Whilst technologies such as video-conferencing are used, as a national and a representative organisation, there is a need for SCVO staff to travel, often to rural areas,

5 ‘Our time is now… Scotland’s Civil Society Summit’, Edinburgh 18.02.10. 6 HM Government (March 2010). Shaping our future: The joint ministerial and third sector Task Force on climate change, the environment and sustainable development

4 which limits emissions reductions possibilities. Other national and UK voluntary organisations face similar dilemmas balancing travel, time, and resource.

The recession has squeezed funding and donations to the sector from private sources and from reduced public spending, added to which many voluntary organisations have seen a marked increase in demand by service users. An organisation struggling to secure funding for the next 12 months in order to carry out its core objectives finds it hard to consider the seemingly ‘distant’ issue of climate change. Greater recognition by funding bodies of climate change and proportionate requirements in applications may assist in ‘mainstreaming’ the issue.

A further barrier on funding is that those voluntary organisations who do wish to improve their environmental stance and specify an ethical policy on investment and funding are automatically limiting their options and possibly restricting their activities.

Many voluntary organisations operate out of leased office space, sometimes at a favourable rate. It can therefore be difficult to exert influence over the introduction of energy efficiency measures in the building. Some landlords may be persuaded of the financial benefits of, e.g. better insulation, but there is currently limited incentive for them to act, resulting in tenants feeling helpless. An incentive scheme for non-domestic landlords to encourage improvements in properties would be helpful.

The complexity of climate change, the very varied media reporting of the issue, the uncertainty it provokes and the language used all serve to confuse all but the very engaged. Added to this, the infrastructure and options which facilitate ‘greener’ living, e.g. for recycling, composting, sourcing local goods etc, require additional effort and are often more expensive. Making sense of climate change requires different language and materials for different audiences. One of the themes emerging from a recent event on engagement7, is the need to interpret the issue through the experience of individuals, i.e. to make it relevant to their lifestyles, but who can resource such engagement at the individual level?

A further difficulty with respect to engagement is the dilemma of how to address the scale of the problem without appearing to deceive: given the prognosis on the climate and anticipated temperature rise, should we be focusing on small energy efficiencies, if what is needed to achieve the targets we have set ourselves is fundamental change in the way society operates. But if this is too scary a vision, does it simply result in total disengagement?

People are looking for stronger leadership which establishes policies to complement the ambitious emissions targets which Scotland has set and to demonstrate how change will be achieved; at present there is an apparent hesitancy from government to be bold and concern about the relative popularity of the necessary measures.

Overall, our resistance as a society to thinking long-term represents a fundamental barrier. Funding is typically short-term which inevitably restricts capacity for planning for adaptation. If there was a greater propensity from all funding bodies, including government, to allow the really sustainable development of a project and/or organisation and to consider life-time costs, then there may be more take-up in risk planning for apparent unknowns.

7 SCVO. Positive spin: making sense of climate change: summary of event 19.02.10 (www.scvo.org.uk/scvocms/images/Green/Positive%20Spin%20summary%20190210.doc)

5 f) What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

If the proposed carbon tax is on energy use, despite the overall benefit this could bring, there is an inherent disadvantage with managing older buildings, which would affect SCVO. It is important that the proceeds of any carbon tax are directed towards mitigation/adaptation, e.g. to assist fuel poverty, or to invest in public transport. Assurance would be needed that there are no unintended consequences, i.e. those who are vulnerable and require more heating, or those living in rural areas and are reliant on a car for transport, are not unduly penalised. A differential tax on energy – so that consumption beyond a standard limit incurs an increased unit price would introduce a greater incentive for efficiency and fairness.

SCVO is not aware of any members required to participate in emissions trading nor which currently fall under the Carbon Reduction Commitment (although SCVO is registered to follow the process and we recognise that the eligibility threshold for the CRC may be reduced in future years). A personal carbon quota could, in theory, establish a level of equality and reward those living less carbon-intensive lifestyles.

The sector could be adversely affected by more stringent energy performance regulations applied to buildings. Generally these are important, given the level of emissions lost through buildings, but there would need to be significant support available to bring existing buildings up to appropriate standards and assurance that those least able to make changes would not be disadvantaged due to such regulation.

Incentive schemes such as Feed-In Tariffs and ROCs, subsidies for insulation and energy efficiency measures, renewables installations, and landfill tax are generally beneficial to voluntary organisations and their service users. In addition to economic benefits, they make practical actions feasible at an individual level and encourage wider engagement and behaviour change. It is important though that incentive packages are consistent, joined-up and sustained.

If you have further comments on some of the following issues, then they would also be welcome:

ENERGY GENERATION

What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure?

The benefits are generally disproportionately skewed in favour of large power companies. Greater public/community ownership and involvement in renewables installations will allow local benefit and simultaneously encourage engagement and acceptance.

At micro-level, more support – as opposed just to advice – is required to help individuals and small organisations understand and work through the planning and technical requirements for renewables installations.

There is resistance to increasing infrastructure on the grounds of local ‘NIMBYISM’, or by taking a precautionary principle; yet this conflicts with the need to recognise and seek to address the global problem of climate change.

6 How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020?

There is a need for acknowledgement of life-time costs rather than capital costs in investment in these technologies. The establishment of and support for demonstration projects, for example, district heating/CHP systems, in both rural and urban areas would assist. It is noted, however, that the appropriateness of a particular scheme and the feedstock it utilises will be location-specific and there is a need to ensure that each operation does not have unintended consequences on other environmental policy.

Consistent and sustained grant funding to incentivise take-up of small-scale renewable heat technologies would reassure potential investors; it would also encourage economies of scale to develop which would bring down the costs of technologies, such as solar heating.

What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

NB We understand that the 2020 target is for 50% renewable ELECTRICITY, not energy.

There is insufficient disincentive from use of fossil fuels. Profits from the oil business continue to attract significant investment, including from what are now publicly owned banks, and despite this involving extremely damaging extraction processes with major effects, not just on the climate but also on local communities. Publicly owned banks should instead be required to invest in (UK-based) renewable technologies.

There are increasing indications that the UK Government is in favour of nuclear power development which is extremely capital-intensive and likely to compromise significantly investment in less capital-intensive renewable energy technologies, to their detriment.

The risk of the up-front investment required for feasibility studies, planning procedures and grid connection etc is a deterrent to all but the most committed small to medium-sized organisations in pursuing installation of renewables.

The lack of skills in the manufacture, installation and servicing of technologies could serve as a deterrent to achieving these targets if there is not sufficient commitment to training and jobs.

The additional cost of choosing to use 100% renewable electricity is prohibitive for some voluntary organisations which would like, but are unable, to make that choice.

Is there sufficient action to exploit the potential of micro-renewables?

Recent incentives are encouraging action but if pioneers of micro-renewables are penalised, as is the case with the recent introduction of FITS with its differential rates for energy generation depending on when the technology was installed, this will not encourage future innovative behaviour.

Conflicting information about some technologies, e.g. rooftop turbines, can be confusing. Building capacity with the Energy Savings Trust/Carbon Trust (or similar) and extending its remit to provide more practical support, in addition to advice, would assist.

7 Action to streamline planning in respect of technologies, allowing a build-up of momentum and resulting lowering in unit costs, would accelerate action8.

What are the obstacles to cutting energy use?

There is still insufficient emphasis on energy efficiency, doing more with less and doing things differently, for demand actually to decrease. There needs to be assurance that the focus on technological solutions does not result in an actual increase in electricity demand and consequently a larger 50% renewable electricity target by 2020 which is more difficult to achieve.

LAND USE

How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats?

Fundamentally, we need to take an holistic view of land use management recognising the need for integrated planning underpinned by the goal of sustainability. These issues are largely addressed by Scottish Environment LINK9.

Additionally, we need to:

• Base and promote land use planning on multiple-benefit objectives in order that the full range of potential uses are realised10

• Encourage better management of woodland to improve provision of raw material for small- scale, local woodfuel heat markets, but protect against industrial scale bioenergy crop cultivation

• Involve and benefit communities in local renewable power generating installations; and facilitate and simplify opportunities for community ownership/leasing of land for such ventures

• Encourage greater use and regeneration of - especially urban - land for food production and require that new housing developments include community gardens/ allotments/ orchards; use brownfield sites for community initiatives, including temporary ones.

What do you see as the major barriers to changing rural land-use activities in this way?

The leasing/ownership of land for innovative uses, such a community gardens, is discouraged by both planning rules and government guidelines on asset transfer.

The problem of government departments adopting a ‘silo’ approach to different land uses, rather than a multi-benefit approach which promotes consideration, for example, of using agricultural land for forestry, or forestry land for recreation.

8 EAS (Feb 2010). Energy Action Scotland reponse to Permitted development rights for domestic micro-wind turbines and air source heat pumps consultation 9 Scottish Environment LINK (Dec 2009). Living with the land - proposals for Scotland’s first sustainable land use strategy www.scotlink.org/files/publication/LINKReports/LINKReportLivingwithLand.pdf 10 As above.

8 BUILDINGS

What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

Tighten planning regulations against continued building on flood plains, and improve building regulations to incorporate consideration of life-cycle assessment with regard to materials and energy use.

How should Government ensure that business/domestic energy efficiency measures are met?

Tighten enforcement of Energy Performance Certificates

What are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act?

TRANSPORT

How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

Based on SCVO’s business travel (excluding commuting), such a target would likely require limits/bans on the use of taxis and domestic flights (the latter are already discouraged and used infrequently). These could be supported by further guidance to staff but both measures have time implications and may result in meetings/events not taking place. Introduction of a walking/ cycling ‘mileage’ rate might incentivise some staff; though this has cost implications and will have only limited impact. Video-conferencing can cut travel significantly and is used by SCVO regularly; with the development of Skype and similar technologies, this option should be available more widely to smaller voluntary organisations. SCVO has an important rural remit and our services could be limited by restrictions in car travel, where public transport is not available.

SCVO is part of an international network of voluntary organisations and we are increasingly working to minimise the number of international flights (which are not many) and to make more use of video-conferencing etc. A cessation of all international flights however would severely restrict our ability to contribute to this area of work, although a limit on air miles per year could be explored as a compromise.

Given the individual remits of organisations across the sector, it would be difficult to propose a generic travel policy, although SCVO does provide advice on reducing travel impact, how to assess it and its carbon impact through use of the CarbonLINK accounting tool.

April 2010

04 May 2010

SCOTTISH WATER

Dr Marc Rands Castle House The Royal Society of Edinburgh 6 Castle Drive 22-26 Georg Street Carnegie Campus Dunfermline Edinburgh KY11 8GG EH2 2PQ Customer Helpline T: 0845 601 8855 W: www.scottishwater.co.uk E: [email protected]

Dear Dr Rands

RSE Inquiry into Facing up to Climate Change

Thank you for the opportunity to respond to the call for evidence for the above enquiry.

The main details of our response are contained in Appendix 1 to this letter. I have also taken the opportunity to include at Appendix 2 a short paper that was submitted by Scottish Water as part of a presentation to a recent conference focussing on carbon and wastewater quality. This may offer some insight into current carbon thinking in the water industry.

Scottish Water has taken a proactive approach to the challenge of climate change. Our strategy is to deliver a low carbon water service that is resilient to the impacts of climate change. We will do this by adapting our services to make them more resilient and measuring and mitigating our carbon emissions.

Our Delivery Plan for the 2010-20151 regulatory period highlights the commitments we have made to address climate change. These include investing in 25GWh of renewable generation from hydropower, strategic studies to better understand how climate change may impact services, and projects to pilot more sustainable means of operating treatment works. More detail is included in Appendix 1.

Adaptation Strategy

The water industry can be considered to be at the forefront of climate change. A changing climate predominantly means a changing water environment in terms of quality and quantity. This has the potential to directly impact our services - in the maintenance of secure water supplies of sufficient quality to treat and serve our customers, and also in the assimilative capacity of the environment to consume the products of wastewater treatment.

1http://www.scottishwater.co.uk/portal/page/portal/SW_PAGE_GROUP_PS_ADMIN/SW_PUB_SCHEME_AD MIN_HOLDING/TAB65572/SWDeliveryPlan201015March2010.pdf - 2 -

Our adaptation strategy is to secure a service to customers that is resilient to climate change. We will do this by investing in strategic studies to understand the extent to which our services will be impacted, developing necessary tools to integrate climate models into investment planning, and using these outputs to deliver a resilient service either by investing to adapt the asset base or making operational changes to increase resilience.

Mitigation Strategy

Water services are energy intense and have been increasing in intensity over the past 2 decades. The industry is heavily regulated, with a large number of regulatory objectives for drinking water and environmental quality driven by the EU. It is clear that in many cases this has led to substantial environmental gains and Audit Scotland recently concluded that wastewater discharges are no longer the principal cause of bathing water failures2. However, this has come at a cost in terms of carbon emissions.

Operational Carbon Since 2002, Scottish Water has invested around £4bn to meet improved service and quality standards. During that time, electricity consumption has grown at a rate of around 2% per annum. Our annual operational carbon footprint currently stands at 475,000 tonnes carbon dioxide equivalents (CO2e). On a like-for-like basis, we reduced carbon emissions by around 9000 tonnes between 2007-8 and 2008-9 largely as a result of investment in leakage reduction3.

Embodied carbon In addition to operational carbon, Scottish Water manages one of the largest capital investment programmes in the UK water industry. The circa £500m per annum is intended to continue over the 2010-2015 regulatory period to continue to meet regulatory objectives. A top down assessment of the 2006-2010 investment plan suggested an overall embodied emission impact of around 1.4m tonnes CO2e.

Our carbon mitigation strategy is to measure and understand carbon across our business, to seek to reduce energy demand, to invest in energy efficiency, and to increase our renewable electricity portfolio. We will also seek to evolve a more sustainable asset base by integrating carbon into investment planning.

Key Issues and Actions

We believe there are a number of issues that need to be resolved if we are to move towards a more sustainable water industry. Some of these are discussed in more detail in Appendix 1, however I would like to highlight several points:

Legislation, Regulation and Policy A recent report by the Scotland and Northern Ireland Forum for Environmental Research into the regulatory drivers of carbon included a case study of Scottish Water. This indicated that in some cases, investment to meet local quality drivers led to a rise in carbon emissions of several thousand percent4.

2 http://www.audit-scotland.gov.uk/docs/central/2010/nr_100114_environment_overview.pdf 3http://www.scottishwater.co.uk/climatechange/Scottish%20Water%20Operational%20Carbon%20Footprint% 202008-09.pdf 4 Minimising Greenhouse Gas Emissions Across Environmentally Regulated Industry in Scotland and Northern Ireland. Scottish and Northern Ireland Forum for Environmental Research http://www.sniffer.org.uk/Webcontrol/Secure/ClientSpecific/ResourceManagement/UploadedFiles/UKPIR11.pd f - 3 -

Whilst legislation and regulation has clearly driven an improvement in our environment, it must be acknowledged that the regulatory drivers to which we operate were written in a pre-carbon era. They do not have the scope to include carbon when assessing the benefit of regulatory outcomes and they have largely been based on prescriptive standards that may not fully relate to the specific local circumstances.

We believe there is a need to fully review the EU and Scottish regulatory frameworks to ensure they are fit for purpose and drive the appropriate quality outcomes, including carbon. The review should consider EU directives, how they have been transposed, and how they are implemented. With respect to the latter, the public body duty contained in the Climate Change (Scotland) Act should help promote carbon thinking when applying policy.

Source Control for Water Quality We need to move away from continually increasing treatment intensity in response to quality drivers. One of the key projects in our Delivery Plan is to develop catchment management approaches to quality across 5 water supply catchments. This will seek to improve quality through better management of rural catchments; for example reducing pesticide release to surface waters and hence reducing the intensity of water treatment.

This approach is consistent with the aims of the Water Framework Directive and will require a partnership approach across agencies to both incentivise good practice and to regulate where necessary to protect drinking water sources and reduce the need for energy-intensive treatments.

Such an approach must also be an integral part of the application of new regulatory regimes for quality, particularly the Priority Substances Directive, which aims to end releases of certain chemicals to the environment. This has the potential to be very costly and energy-intensive if applied at ‘end of pipe’ rather than in controlling the original sources.

Impacts on Service and Expectations of Society As stated, our adaptation strategy is to ensure our service is resilient. However, we are still in the process of fully understanding what climate change will mean for our customers. Climate models highlight the potential for changes in rainfall patterns and storm intensity and these have the potential to impact services through:

1. Increasing frequency and intensity of extreme rainfall events –  There is a risk that there will be increased incidence of flooding in the future. This has the potential to drive significant cost in the future and it is important that society understands this as it may be a growing investment driver.  Protecting against this risk will require more innovative thinking and to move away from hard engineering (e.g. building more network capacity). Working in partnership with others and within the Flood Risk Management Act we need to seek to promote flood attenuation higher in catchments and to avoid surface water entering the foul sewer network.  Working with customers we need to understand what their adaptive capacity is, for example influencing behaviour against non-permeable paving in driveways, water butts to collect roof drainage (increases network storage), not connecting new conservatory roofs to foul drains, disconnecting existing roofs.

2. Increased risk of drought – - 4 -

At present, our Water Resource Plan5 indicates that existing security of supply issues will drive investment in the medium term. However, climate models suggest that whilst overall rainfall may remain the same over the year, there will be an increase in winter flows and a decrease in summer flows. As with flooding, this will require a better understanding of the risks to service, customer expectations and willingness to pay, and customer response to drought conditions.

Partnership Working

Climate change cannot be addressed by organisations working alone. We are committed to working with customers, Government, Regulators, Local Authorities and other key stakeholders to better understand the challenges and to devise and deliver appropriate solutions. For example, with respect to flooding there are multiple organisations and agencies that have responsibility, from roads drainage to overland flow to foul drainage.

We strongly advocate partnership approaches as the way forward, and would cite the evidence of the Metropolitan Glasgow Strategic Drainage Partnership as an example of good working6. Here, Scottish Water is working in partnership with SEPA and 7 local authorities to deliver a long term plan to develop a sustainable approach to the drainage infrastructure of Glasgow.

I look forward to meeting with the Committee on 20th May and hope that this submission is useful to your enquiry.

Yours sincerely

Richard Ackroyd Chief Executive

5 www.scottishwater.co.uk/publications 6 http://www.mgsdp.org/ - 5 -

Appendix 1 – Questions Directed to Scottish Water

Do you perceive the changing weather patterns in Scotland globally as affecting you/your organisation?

Scottish Water is expected to provide full water and wastewater services across Scotland at all times. This is necessary for protecting public health and the environment. Our assets and services are intended to cope with the excesses of the Scottish climate which, even in the absence of climate change, can be challenging.

They are challenging because weather patterns in Scotland are highly variable both temporally and spatially. We are just emerging from a winter characterised by a prolonged spell of unusually cold weather that has created significant operational difficulties for Scottish Water in respect of increased water main bursts and process difficulties at biological wastewater treatment facilities.

These sites may be equally challenged through the year in terms of higher temperatures leading to microalgal blooms, and low water flows leading to operational difficulties. In addition, prevailing conditions across Scotland are highly variable, such that at any one time we may be dealing with extremes of wet weather and dry weather. This places additional burdens on our assets as they will have to cope with increasingly diverse conditions.

Climate Change impact risks Changes in weather patterns associated with climate change might be expected to impact on our services in a number of ways. A major exercise was undertaken in 2007-8 with the UK water industry, through the representative body Water UK, to put together a comprehensive overview of the potential impact risks.

The range of potential impacts on activities in the industry was developed in partnership with Water UK in 2008 and this is appended as Appendix 2. It is important to stress that this is not a risk assessment of service in Scottish Water. Rather, it is an indication of the factors to be considered in risk assessments at the various asset categories we operate.

In essence, the main potential impacts we are concerned with are:

General Asset Base  Over 10,000 installations across Scotland from treatment works to pumping stations and waste management facilities – risk of physical flooding impacting operation of assets  We are also concerned about secondary resilience at these sites – risk to power supplies, particularly in remote areas (e.g. if substations flood).  50,000km each of water and wastewater network across Scotland potentially vulnerable to secondary climate impacts such as land slippage (a consequence of increasingly variable soil-moisture deficit)

Water supply  Potential for reduced flows and increased evotranspiration leading to water shortages  Increased temperature coupled with low flows raising risks of algal blooms  Increased water demand may be a secondary effect  Increases in probability and intensity of storm rainfall may impact raw water quality due to increased land runoff

5 - 6 -

Wastewater systems  Potential challenges to drainage capacity with increased storm intensity  Temperature increases coupled with lower rainfall during summer may present risk of septicity in sewers  Surface waters receiving treated effluent may have lower flows during summer necessitating increased treatment to protect quality (conversely there may be opportunities to scale back treatment during spate conditions)

What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

As a business owned by the Scottish Government, Scottish Water is committed to supporting the ambitions laid out in the Climate Change (Scotland) Act. However, we also support the goals of the Act because climate change presents a significant long term threat to our service. The water industry is at the forefront of climate change. We are dependent upon a good quality water environment from which to abstract water for drinking, and also to receive the treated wastewaters we manage on behalf of society.

Scottish Water is one of Scotland’s largest users of energy. Our annual carbon footprint is circa 475,000 tonnes CO2 equivalents, two thirds of which is attributed to grid electricity. We use circa 470GWh per annum of electricity in providing our services.

Our activities and services are heavily regulated. Over the past 10 years we have invested circa £4bn in capital improvements to meet regulatory standards for potable water and effluent treatment. This has driven an average rise in energy demand of around 2% per annum.

For these reasons, we welcome the Climate Change (Scotland) Act as a mechanism, to promote the right actions and to co-ordinate policy across government. It is clearly ambitious in terms of GHG reduction and seeks to promote activity to ensure Scotland is able to meet the adaptation challenges. These factors will have a major influence on the activities of Scottish Water.

Public Body Duty A key element of the Act that will drive change is the duty on public bodies:

Climate Change (Scotland) Act 2009 A public body must, in exercising its functions, act— (a) in the way best calculated to contribute to the delivery of the targets set in or under Part 1 of this Act; (b) in the way best calculated to help deliver any programme laid before the Scottish Parliament under section 53; (c) in a way that it considers is most sustainable

Scottish Water is of the view that this will drive a changed approach across the public sector. It is incumbent on bodies to not just seek to mitigate their emissions, but to consider how, in the exercise of their functions, they take carbon into account. We are therefore working with regulators to develop mechanisms for accounting for carbon in regulatory decisions (see below).

6 - 7 -

What do you plan to do in response to these factors over the next 5-10 years?

Our climate change strategy is to deal with climate change proactively on behalf of customers by taking steps to mitigate carbon and to understand the impacts of climate change and the actions necessary to secure service. The objectives we are striving for are a low carbon water service for Scotland that is resilient to climate change.

Scottish Water’s Delivery Plan sets out what we will deliver in the 2010-2015 regulatory period7. Pages 25-27 set out the deliverables for carbon and climate change. We will deliver these goals by taking action across the range of work areas. Specific initiatives to note are:

Carbon measurement, monitoring and reporting

Operational Carbon Scottish Water has been measuring its carbon footprint annually for the past 3 years using an industry standard approach that was developed with the Carbon Trust. This allows comparison of Scottish Water’s performance against the rest of the industry.

Our reports are published on our website and the latest report indicates a footprint of 8 around 475,000 tonnes CO2e per annum from operating our service . Although year to year comparisons are difficult owing to data and methodology changes, on a like for like basis there is a 9000 tonne reduction largely as a consequence of investment in leakage control. We are committed to publishing our carbon footprint annually.

Evolving a sustainable asset base We are developing whole life costing approaches that will enable us to include carbon in decision making. We will use this tool to appraise future investment plans to ensure our plans are as sustainable as possible.

Innovation We will work with our regulators to develop innovative approaches to managing quality and compliance at treatment works such that the environmental outcomes are protected whilst minimising energy demand. This will require piloting initiatives such as dynamic control and licensing to optimise performance in line with environmental conditions and seeking to promote sustainable technologies.

Renewable Energy Generation Within the regulated business Scottish Water currently generates around 16GWh from hydro schemes. We will increase this by at least 25GWh by 2015 through additional hydro, saving around 12,000 tonnes CO2 equivalents. In addition, we will undertake feasibility studies of CHP for our sludge assets.

Outside the regulatory contract, we are also seeking to deliver renewable generation projects with third parties in a joint venture model. We recognise that we have landholdings that may be appropriate for wind generation, and are currently seeking partners to exploit these opportunities. There is the potential that we could become self sufficient for energy via this route, however this is a very long term goal.

Understanding climate change

7 Scottish Water Delivery Plan 2010-2015, www.scottishwater.co.uk/publications 8 http://www.scottishwater.co.uk/climatechange

7 - 8 -

We will undertake strategic studies to establish the potential impact of climate change on our asset base, and develop best practice tools to respond to climate impacts on our services.

How integrated is your response with other organisations in similar or related fields?

There has been strong collaboration across the UK water industry over recent years to understand carbon and climate impacts and issues, develop tools for adaptation and carbon accounting, and research issues such as sustainable treatment technologies. Broadly, a common position has been reached that the industry will work towards a low carbon future, and will need to understand how climate change will impact in order

Industry positioning statements are available on the website of our trade body Water UK9. These reflect extensive cross working within the industry along with shared engagement of UK government and regulators.

At a practical level, much of the guidance to the industry has been developed through our collaborative research company, UK Water industry Research Ltd. This is a vehicle, funded by the industry, to procure research intended to develop best practice approaches across our activities. Climate change is a specific research subject area within UKWIR and projects are initiated by companies, approved by the industry and delivered as collaborative ventures for dissemination across the industry. Scottish Water currently fulfils the role of ‘Client Manager’ for all climate projects on behalf of the industry.

In recent years, UKWIR has published research on climate change impacts on stormwaters, use of oow quality water, water quality impacts, carbon management and mitigation, water availability, droughts and general climate impacts. Further details of over 20 reports can be found on the UKWIR website10, along with details of the current programme of work.

Key projects to note that have delivered that have driven an integrated approach include:

UKWIR Greenhouse Gas emissions workbook This was a piece of work to establish (with input from Carbon Trust) a GHG emissions workbook to enable the industry to consistently measure and report carbon emissions. All companies utilise this approach and report figures annually via the Water UK sustainability indicators11. The workbook is updated annually with the latest emissions factors and is now adapted to meet the needs of operational management and regulatory reporting.

Carbon Whole Life Costing Research has also been delivered to understand how to integrate carbon thinking into asset investment. This has set out guidance to the industry on assessment of the carbon impact over the life of an asset from construction (embodied, onsite

9 http://www.water.org.uk/home/policy/climate-change 10 http://www.ukwir.org/site/web/content/reports/reports?FolderId=90265 11http://www.water.org.uk/home/policy/reports/sustainability/2008-09-sustainability- indicators?s1=sustainability

8 - 9 - carbon), capital maintenance through its life (embodied, fuel etc) and operational (power, transport, waste etc). This approach has been adopted across the industry and Scottish Water is developing a costing tool for capital investment that will allow carbon to be included in optioneering.

Effect of climate change on river flows and groundwater recharge This is a series of projects that has set out scenarios for companies to use to enable climate change to be considered in water resource planning. This work was originally based on UKCP02 climate models and is now being updated with UKCP09 models. They also provide tools that will enable Scottish Water to consider the latest climate impacts in future water resource plans.

Further details of all these projects may be found on www.ukwir.org.

What are the main barriers to change for you/or your organisation?

Carbon Mitigation

A rising energy demand As stated previously, Scottish Water is one of Scotland’s largest consumers of energy. The rising trend of around 2% per annum since 2002 is a reflection of the £4bn we have invested in the asset base to improve service and deliver the quality objectives.

Aside from customer service improvements, our investment has focussed on meeting standards set by European directives, transposed into Scots Law. Typically, these include more stringent quality standards that require in many cases a step change in energy intensity at the treatment works. For example, requirements to disinfect effluent leading to energy-intensive ultra violet or membrane barrier technologies, and more stringent ammonia standards leading to energy intense aeration of effluents.

It is apparent that older EU directives and Scottish Legislation take no account of carbon when setting regulatory objectives. This is a clear disconnect with the carbon constrained era we are now in. EU quality directives relating to surface waters and wastewater treatment have broadly driven a focus on treatment standards, prescribing the quality of effluent to be achieved. A recent report has highlighted that at several Scottish Water treatment works, improvements to meet UWWT and shellfish standards have led to an increase in emissions of between 150% and 2441%.12

A key concern of the water industry is that with the advent of further regulatory regimes such as Priority Substances Directive, further attention on phosphorous and revisions to regimes such as the Bathing Waters Directive, this trend of increasing energy intensity will continue.

Overcoming the barriers We believe there are opportunities to take a more holistic approach to environmental quality. It is imperative that local environmental quality and wider carbon

12 Minimising Greenhouse Gas Emissions Across Environmentally Regulated Industry in Scotland and Northern Ireland. Scottish and Northern Ireland Forum for Environmental Research http://www.sniffer.org.uk/Webcontrol/Secure/ClientSpecific/ResourceManagement/UploadedF iles/UKPIR11.pdf

9 - 10 - benefit/disbenefit are adequately considered by Scottish Water and regulators. Accepting that traditional regulatory regimes have focussed primarily on the immediate quality outcomes, there is a need to move to a more holistic consideration of benefit.

There are 3 levels at which carbon could be considered:

(i) EU law  Recognising that carbon has hitherto been ignored in EU legislation, we have a framework that potentially drives poor carbon behaviour. New EU law should be fully carbon aware, seeking to integrate near term objectives with longer term carbon policy.  All new EU law should be consistent with EU carbon objectives and policy  For existing EU law a full review should be undertaken to ensure that, where possible, carbon thinking can be incorporated to ensure that the right carbon behaviour is promoted.

(ii) Transposition into Scots Law  When EU law is transposed, care should be taken to ensure that the legislative interpretation is fully integrated and is consistent with the policy objectives of Scotland’s Climate Change Act.  Existing legislation and regulations that were written in a pre-carbon era should be reviewed and amended to incorporate carbon assessment and promote the right outcomes.

(iii) Implementation – Regulatory Policy and Interpretation  There is a huge body of guidance and interpretation documents along with policy positions of regulators that seek to guide the implementation of regulations.  These should be reviewed for ‘carbon fit’ – i.e. is there an opportunity to implement the legislation in such a way as to achieve the quality outcome in a manner that does not drive an increase in carbon?  There are several issues that might be considered in seeking to ensure regulation is implemented in a way that does not unduly drive carbon increase: o Full cost-benefit assessment to review local benefit/disbenefits and cost of carbon to promote the right solutions for Scotland o Promote a risk based approach to regulatory implementation. We believe that a risk-averse approach to the quality objective has contributed to both Scottish Water and regulators defaulting to the more energy intense solution that guarantees local quality. For example, if a sustainable wastewater such as a wetland or reed bed system solution guarantees quality for 80% of the year and does not present long term risks to the quality of the environment, this should be considered ahead of an energy intense system that guarantees 100% compliance with a high carbon cost. o Consider the timeline for implementation. Where quality outcomes are driven by a near term regulatory timeframe it invariably leads to an energy intense system utilising available technology to guarantee a local quality outcome. Taking a longer term perspective may offer more opportunity to explore and deliver a range of alternative measures that will deliver longer term quality without driving an increase in carbon.

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o Consider scope for innovation. Linked with the risk aversion and timeline points above, the potential for providing innovative low carbon solutions over a longer timeframe must be included in the regulatory implementation. o Consider holistic solutions to local quality issues. The Water Framework Directive with associated River Basin Management Plans offers the scope for Programmes of Measures to be developed that drive solutions to problems over a longer timeframe. These programmes of measures should be subject to full carbon assessment to ensure they are sustainable.

Scottish Water anticipates that carbon will become a bigger consideration in new and existing legislation, and is happy to provide a comprehensive overview of the range of regulatory drivers we operate under. A paper that was presented at a recent conference that sets out some of the challenges to moving towards sustainable regulation of wastewater is provided at appendix 3.

Climate Adaptation The key barrier at this stage is good data and robust tools. We are integrating climate models into longer term water resource planning, but there remains further work to be done with the wider industry to ensure UKCP09 models are appropriately integrated into asset planning.

In addition, there is a need to ensure we have good real data on which to work. It is imperative that we understand the fate of water when it falls in a catchment and our Delivery Plan highlights work to be delivered to identify data gaps that need to be addressed in a multi-agency manner.

What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

The principal incentive mechanism used by Scottish Water is the Renewable Obligations Certificate scheme. This incentivises investment in renewables by enabling organisations to sell ROCs based on renewable generation. It is a necessary scheme to make investment in renewables cost-effective. Currently, Scottish Water sells ROCs based on its existing hydropower generation and revenue from ROCs was a factor in planning for an increase of 25GWh hydropower capacity in the 2010-2015 regulatory period.

Scottish Water is captured under the CRC Energy Efficiency Scheme, a trading scheme that will require participants to purchase carbon allowances equivalent to their projected energy consumption. The money is intended to be recycled back to the participants depending on how they perform within the scheme in terms of carbon reduction within the year. The best performers will realise more than they paid, whilst poorer performers will suffer a financial loss.

We have a number of concerns over this approach: 1. Scottish Water has limited ability to control demand on energy where driven by regulatory requirements. As evidenced earlier, regulatory quality drivers have led to a significant increase in energy demand over the past few years. 2. One of the measures of performance in the scheme is emissions relative to turnover. Companies such as large retailers have the opportunity to grow revenue relative to their energy demand. As a water and wastewater service

11 - 12 -

operating under a price control and with limited opportunity to grow demand this is something that we cannot take advantage of. 3. The CRC EES does not permit the counting of renewable generation where ROCs have been sold (a necessity to make renewables cost-viable). As renewables is perhaps our best opportunity to significantly reduce the carbon intensity of water services, we are concerned that we will still perform poorly in the scheme despite taking significant, costly and positive steps to reduce our carbon intensity.

For these reasons, we view the CRC as potentially being simply a tax on our customers that has limited potential to drive actual savings in the regulated business. The CRC scheme will only be effective where organisations have an opportunity to reduce carbon in line with the incentive or penalty mechanism. For this reason, we question the effectiveness of the scheme for a regulated utility such as Scottish Water.

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Appendix 2: Range of POTENTIAL impacts that climate change may present to water industry assets (excerpt from industry adaptation tool). This is taken from a water industry risk assessment tool and is not a statement of impact specific to Scottish Water WATER RESOURCES Water All Drought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts Resources - 105, 106, 108, 209, 213, 223, 303, 314, 404, 410, 412, 414 105, 106,108, 303, 314, 404, 410, 412, 414 104,205,206,207,314,303, 402,404, 410, 412,414, 104,205,206,207,231, 314,303,402,404, 410, All 412,414, All Water D1 3 Reduced available supply causes political pressure Higher average and peak temperatures affect Direct asset flooding causes service failure and 201, 215, Direct asset flooding, storm damage and coastal Resources for essential water users, e.g schools and structures, buildings, H & V, MEICA plant working asset loss 304, 406 erosion or 'planned retreat' cause service failure hospitals, and for other customers reduces life, causing accelerated asset deterioration and asset loss security of supply D2 3 Daily & peak demand for 'garden' watering Redistribution of / increase in tourism increases Increased storm frequency and power supply 201, 215, Saline intrusion degrades infrastructure, causing increases, causing a reduction in security of seasonal demand and causes a reduction in flooding increases frequency of power loss, causing 304, 406 accelerated asset deterioration supply security of supply service failure D3 3 Intake, borehole pump and reservoir draw-off levels Daily and peak domestic and commercial demand Flooding in certain areas causes redistribution of 117 Flooding in certain areas causes redistribution of do not match reduced levels causing service increases, causing a reduction in security of permanent population (eg away from flood plains) permanent population and tourism (eg away from failure supply and tourism, which affects demand and impacts on flood plains), which affects demand and impacts on security of supply security of supply D4 3 Lower river yields, borehole yields or reduced water Higher temperatures and longer growing season The threat of treatment works being flooded (with quality lead to abstraction licences being reduced causes redistribution of / increase in agricultural subsequent service loss) increases customer or removed, causing a reduction in security of demand and impacts on security of supply expectations for visible hard engineering supply adaptation solutions D5 3 Increased customer sensitivity to possibility of Redistribution of permanent population in response service failure impacts security of supply. to temperature rise affects demand and impacts on security of supply Increased customer sensitivity impacts security of supply Storage D6 3 Lower river flows reduce yields and hence Increased evaporation and evapotranspiration Increased soil erosion causes the siltation of dams, Reservoirs and increased demand on existing storage, and causes reduce yields, causing a reduction in security of causing accelerated asset deterioration and asset Aqueducts a reduction in security of supply supply loss Increased evaporation and evapotranspiration More intense rainfall events & changes to soil reduces yield of surface reservoirs and increases conditions lead to the slippage of soil dams, causing demand on groundwater recharge, causing a service failure, customer flooding and asset loss reduction in security of supply More intense rainfall events exceed capacity of spillways to deal with increased storm intensity, causing service failure, customer flooding and asset loss Boreholes / D7 3 Lower groundwater levels reduce borehole yields Increased evaporation and evapotranspiration More intense rainfall events compact upper soil 224, 405, Saline intrusion decreases yield, causing a service source pumping and causes a reduction in security of supply reduce infiltration, and so borehole yields, causing layers, increasing run-off, reducing recharge of 416, 417 loss and reduction in security of supply stations a reduction in security of supply aquifers and reducing security of supply

Raw water D8 3 Lower flow rates cause deposition leading to Flood water infiltration into pipelines increases pipelines reduced raw water quality drinking water quality risk Intake Pumping D9 3 River levels fall and they become less reliable Greater volumes of storm water cause increased Tidal limits move upstream and lead to greater stations sources, reducing security of supply pumping where pumps are part of the infrastructure, salinity at intakes, causing raw water resource leading to increased asset usage and accelerated loss and reduction in security of supply asset deterioration

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WATER TREAT M ENT Water All Dr ought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts Treatment - All 303, 314, 404, 410, 412, 414

All Water D10 4 Low flows lead to greater sedimentation, with Increased algal growth and risk of microscopic Direct asset flooding causes service failure and 201, 215, Direct asset flooding, storm damage and coastal Treatment blockages causing service failure organisms within the water supply system asset loss 304, 406 erosion or 'planned retreat' cause service failure increases drinking water quality risk and asset loss

G1 4 Relocation of permanent and tourist population Higher average and peak temperatures affect Increased storm frequency increases frequency of 201, 215, Saline intrusion in groundwater increases structural from drought, temperature rise, flooding or sea structures, buildings, H & V, MEICA plant working power loss, causing service failure 304, 406 attack on infrastructure, causing accelerated asset level rise (impacts D2, T2, T3, T5, F3, S2 ) life, causing accelerated asset deterioration deterioration. changes supply-demand balance. Response chosen (within WR) impacts WTW requirements and capacity needed. Sea level rise increases frequency of power loss, causing service failure Treatment works D11 3 Reduced raw water volumes reduce dilution and Higher temperatures reduce raw water quality and Discolouration and odour problems caused by the 312 Saline intrusion decreases yield, causing a service increase drinking water quality risk increase drinking water quality risk biological consequences of more intense rainfall loss and reduction in security of supply events increase drinking water quality risk

Higher temperatures impact treatment process Increased runoff leads to greater sediment levels, Tidal limits move upstream and lead to greater improving treated water quality which increases drinking water quality risk salinity at intakes, causing raw water resource loss and reduction in security of supply

Increased incidence of disease leads to introduction of additional potable standards, increasing drinking water quality risk Discolouration and odour problems caused by the biological consequences of higher temperatures increase drinking water quality risk

Service D12 3 Loss of / intermittent supply increases risk of Increased rate of micro-biological growth Direct flooding causes contaminants to enter 419 Reservoirs and contamination from accumulated silt and debris increases risk of residual chlorine depletion and underground storage tanks increasing drinking Water Towers being flushed out of service reservoirs and towers, contamination of supplies, increasing drinking water quality risk increasing drinking water quality risk water quality risk

Treated water D13 3 Loss of / intermittent supply increases risk of Increased rate of micro-biological growth Direct flooding causes contaminants to enter 418, 419 pipelines contamination from external contaminants entering increases risk of residual chlorine depletion and pipelines, increasing drinking water quality risk the pipelines, increasing drinking water quality contamination of supplies, increasing drinking risk water quality risk D14 3 Loss of supply and de-pressurisation of pipelines Greater extremities in wetting and drying cycles 418, 419 leads to greater incidence of pipe failure with lead to greater soil movement, causing pipe resulting contamination increasing drinking water systems to move increasing burst frequency quality risk D15 3 Inversions occur more frequently in incidences of low water levels; Cryptosporidium accumulation issues increase drinking water quality risk

Treated water D16 4 Loss of supply and depressurisation of the supply pumping stations system leads to greater incidence of air blockages, causing service failure

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WATER NETWORKS Water All Drought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts Network - All 303, 314, 404, 410, 412, 414 All Water D17 3 Daily & peak demand for 'garden' watering Higher average and peak temperatures affect Direct asset flooding causes service failure and 201, 215, Direct asset flooding, storm damage and coastal Networks increases, increasing asset use and causing structures, buildings, H & V, MEICA plant working asset loss 304, 406 erosion or 'planned retreat' cause service failure accelerated asset deterioration life, causing accelerated asset deterioration and asset loss

G2 4 Relocation of permanent and tourist population Increased storm frequency and power supply 201, 215, from drought, temperature rise, flooding or sea flooding increases frequency of power loss, causing 304, 406 level rise (impacts D2, T2, T3, T5, F3, S2 ) service failure changes supply-demand balance. Response chosen (within WR) impacts water networks requirements and capacity needed.

Distribution D18 4 Loss of supply or intermittent supplies increases Greater extremities in wetting and drying cycles Flood water infiltration into pipelines increases 304 networks risk of external contaminants entering the pipelines, lead to greater soil movement, causing pipe drinking water quality risk including increasing drinking water quality risk systems to move increasing burst frequency ancillaries D19 4 Loss of supply and de-pressurisation of pipelines Increased rate of micro-biological growth Direct flooding causes contaminants to enter 418, 419 leads to greater incidence of pipe failure, and increases risk of residual chlorine depletion and pipelines, increasing drinking water quality risk resulting contamination during re-pressurisation contamination of supplies, increasing drinking increases drinking water quality risk water quality risk

D20 4 Loss of supply or intermittent supplies leads to increased risk of mechanical asset failure in PRV's, PSV's, Actuated Valves causing service loss

Distribution D21 4 Loss of supply and de-pressurisation of the supply pumping stations system leads to greater incidence of air blockages, causing service failure Distribution D22 3 Lower flow rates cause deposition leading to Increased peaks of demand lead to greater storage Direct flooding causes contaminants to enter 418, 419 storage reduced raw water quality. requirements reducing security of supply underground storage tanks increasing drinking water quality risk D23 3 Loss of supply or intermittent supplies leads to Increased rate of micro-biological growth contamination from accumulated silt and debris increases risk of residual chlorine depletion and being flushed out of service reservoirs and towers, contamination of supplies, increasing drinking increasing drinking water quality risk water quality risk

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WASTE WATER NETWORKS Waste Water All Drought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts Network- All 303, 314, 404, 410, 412, 414 All wastewater G3 4 Relocation of permanent and tourist population Higher average and peak temperatures affect Direct asset flooding causes service failure and 201, 215, Direct asset flooding, storm damage and coastal networks from drought, temperature rise, flooding or sea structures, buildings, H & V, MEICA plant working asset loss 304, 406 erosion or planned retreat cause service failure and level rise (impacts D2, T2, T3, T5, F3, S2 ) life, causing accelerated asset deterioration asset loss changes supply-demand balance. Response chosen (within WR) impacts wastewater networks requirements and capacity needed.

Higher temperatures lead to greater microbial Increased storm frequency increases frequency of 201, 215, Saline intrusion degrades infrastructure, causing action, and increased gas production and risk of power loss, causing service failure 304, 406 accelerated asset deterioration ignition endangers H&S of site staff Sewer networks, D24 3 Lower precipitation, infiltration & inflow and water Greater extremities in wetting and drying cycles Higher rainfall intensities lead to runoff exceeding High rainfall and high tides coinciding causes incl./trunk sewers conservation lead to lower average and peak 'carry' lead to greater soil movement, causing pipe combined sewer capacity, causing surface flooding increased customer flooding and reduce flows, resulting in greater sewer deposits and more systems to move, leading to accelerated asset and reducing receiving water quality receiving water quality frequent blockages, causing customer flooding deterioration and customer flooding

Increased levels of septicity cause accelerated Increased volumes of storm water in combined 201, 215, Saline intrusion and subsequent H2S formation in asset deterioration and increased odour sewers exceeds sewer capacity and causes 306, 309, 406 sewer creates environmental health risk customer flooding Higher groundwater levels cause increased 201, 215, Saline intrusion increases corrosion, leading to infiltration into sewers, causing customer flooding 224, 306, accelerated asset deterioration 309, 406 Change in customer behaviour lead to increased instances of sewer misuse (dumping down sewer) leading to blockages which cause sewer flooding and reduce environmental water quality

Pumping stations D25 3 Lower average and peak 'carry' flows lead to Increased levels of septicity affect pumping Increased volumes of storm water exceed pump 201, 215, settlement in the system, affecting pumping regimes and causes accelerated asset capacity, causing service failure and impacting on 306, 309, 406 regimes and causing accelerated asset deterioration and increased odour receiving water quality at outfall deterioration Increased volumes of storm water require increased pumping in combined sewer systems, causing accelerated asset deterioration

Rising mains D26 3 Lower average and peak 'carry' flows lead to H2S Greater extremities in wetting and drying cycles Increased volumes of storm water exceed raising 201, 215, settlement in the system, causing accelerated lead to greater soil movement, causing pipe main capacity, causing burst and subsequent 306, 309, 406 asset deterioration systems to move, leading to accelerated asset service failure deterioration and customer flooding

Increased levels of septicity cause accelerated asset deterioration and increased odour

CSOs and D27 3 Lower average and peak 'carry' flows lead to Increased levels of septicity lead to increased Higher storm intensity means CSOs spill more Costal esturine CSO discharges become tide- overflows settlement in the system, with shock loads causing toxicity, reduced receiving water quality and frequently, impacting on receiving water quality locked, hindering free discharge and causing CSO H&S risk and reduced receiving water increased odour customer flooding and reducing received water quality quality Higher winter flows dilute and reduce the effect of High rainfall and high tides coincide and affect CSO spills, reducing impact of spills and improving discharges, reducing receiving water quality receiving water quality

Increased flood incidence increases risk of failure of 'spills per bathing season' type consents.

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Treatment works D31 3 Lower average and peak 'carry' flows lead to Increased levels of septicity in received sewage Extended duration of FFT at WwTW due to duration Saline intrusion increases sewage salinity which settlement in the system, with shock loads affecting causes increased odour and storage return affects process regime and impacts on H2S formation, reduces primary and process regimes and causing accelerated asset causes accelerated asset deterioration and asset FST sludge settleability, reduces dewaterability of deterioration and H&S risk failure SAS. Potential impact on ASP microbiology due to rate of salinity change, dissolved oxygen saturation causing accelerated asset deterioration and reduced process performance

D32 3 Lower average and peak 'carry' flows reduce Effluent standards raised to meet temperature- Increased intensity rainfall events and higher volumes received at WWTW and affects process affected Water Quality Objectives [O2 etc], average flows cause hydraulic overload of treatment regime increasing the risk of a consent failure/pollution process, causing service loss incident D33 3 Lower average and peak 'carry' flows reduce Higher rate of biological activity causes change to Dilution of, and rapid variations in, influent flows wetting rates onto process requiring minimum HLR process efficiency affects process performance efficiency (e.g. trickling filters), increasing need for recirculation pumping D34 3 Lower average and peak 'carry' flows increases Lower summer flows and reduced freezing Increased flushing effect (from sewer or PST retention times in settlement tanks leading to frequency lead to increased insect issues and washout) leads to higher loads to be treated, increased septicity / odour problems. create an environmental health risk affecting process performance efficiency and causing service failure D35 3 Lower river flows, increased seasonal variability Fewer months below critical process temperatures Longer retention of water in storm tanks leads to and reduced water quality lead to the tightening of causes increase process efficiency increased septicity and operational problems, discharge consents, increasing the risk of a affecting process performance efficiency and consent failure/pollution incident increased odour

Increased septicity levels and odour chemicals lead to increased health risk Increased septicity levels promote growth of undesirable species and inhibit growth of normal aerobic heterotrophs, affecting process performance efficiency Increased septicity in sewers / primary tanks leads to poor primary settlement and increased load onto secondary process affecting process performance efficiency

Increased temperatures lead to lower oxygen transfer efficiency in secondary process, affecting process performance efficiency

Outfalls D36 3 Lower river flows mean effluent is required to Increased levels of septicity lead to increased Higher peak levels at the discharge change outfall Higher peak levels at the discharge change outfall maintain river flows, reducing flexibility and toxicity, reducing receiving water quality and hydraulics and back up pumps, causing service hydraulics and back up pumps causing service increasing the risk of a consent failure/pollution increasing odour failure failure incident Reduced oxygen saturation as water temperature Higher sea levels affect dispersion characteristics, increases, increasing the risk of a consent leading to different classification, tightened failure/pollution incident consent, & H+S risk.

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SLUDGE Sludge - All Drought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts All 303, 31 4, 404, 410, 412, 414 All Sludge D37 3 Change in domestic waste disposal patterns leads Higher average and peak temperatures cause an Direct asset flooding causes service failure and 201, 215, Direct asset flooding, storm damage and coastal to change in dry weather flow pollutants affecting increase in incidence of sludge related disease asset loss 304, 406 erosion cause service failure and asset loss composition of sludge G5 4 Relocation of permanent and tourist population Higher average and peak temperatures affect Increased storm frequency increases frequency of 201, 215, Saline intrusion degrades infrastructure, causing from drought, temperature rise, flooding or sea structures, buildings, H & V, MEICA plant working power loss, causing service failure 304, 406 accelerated asset deterioration level rise (impacts D2, T2, T3, T5, F3, S2 ) life, causing accelerated asset deterioration changes supply-demand balance. Response chosen (within WR) impacts sludge treatment, storage and disposal requirements and capacity needed. Sludge treatment D38 3 Increase in the generation of dust causes Higher average temperatures reduce heating (including CHP accelerated asset deterioration and endangers requirement for sludge digestion and affects and incineration) H&S of site staff performance

Sludge disposal D39 3 Agricultural practice change affects sludge demand Agricultural practice change affects agricultural Flooding prevents access to fields causing service or re-cycling and affects agricultural demand for sludge demand for sludge failure

D40 3 Lower water flow increases concentration of toxic Higher temperatures lead to greater microbial Flooding cuts sludge transport routes causing compounds in sludge, affecting sludge reuse action, and increased gas production and risk of service failure and/or incineration and leading to waste disposal ignition in storage endangers H&S of site staff issues Higher temperatures lead to increased insect Increased run off rates from sludge treated issues and create an environmental health risk agricultural land reduce receiving water quality

SITE-WIDE SERVICES Side Wide All Drought Impacts All Temp Impacts All Flood Impacts All Sea Level Impacts Services - All 303, 31 4, 404, 410, 412, 414 All Site wide D41 1 Exfoliation cracks in storage basin affect Higher levels of UV increase the risk of sun-related Direct asset flooding causes service failure and 201, 215, Direct asset flooding causes service failure and Services coatings/seals, and cause clay liner failure. injury, endangering H&S of site staff asset loss 304, 406 asset loss Accelerated asset deterioration D42 4 Relocation of permanent and tourist population Higher average and peak temperatures cause an Direct asset flooding cuts access to assets, 201, 215, Direct asset flooding cuts access to assets, from drought, temperature rise, flooding or sea increase in incidence of water & wetland endangering H&S of site staff 304, 406 endangering H&S of site staff level rise (impacts D2, T2, T3, T5, F3, S2 ) associated disease changes supply-demand balance. Response chosen (within WR) site wide services requirements. Higher average and peak temperatures affect Increased storm frequency and power supply 201, 215, Direct storm damage &/or coastal erosion or structures, buildings, H & V, MEICA plant working flooding increases frequency of power loss, causing 304, 406 'planned retreat' causes service failure and asset life, causing accelerated asset deterioration service failure loss

Higher temperatures cause increased vegetation Direct flooding leads to submersion of electrical 418, 419 Saline intrusion degrades infrastructure, causing growth at sites assets, increasing risk to operatives of electrocution accelerated asset deterioration endangering H&S of site staff SCADA & Flooding causes loss of SCADA and /or telemetry Direct flooding leads to submersion of electrical Telemetry causing a service loss assets, increasing risk to operatives of electrocution endangering H&S of site staff Electrical Supply

Buildings Security Mobile Plant

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Appendix 3 – Paper Presented by Scottish Water to Aqua-Enviro Conference “Water Quality Standards or Carbon – is there a Balance?”

A sustainable approach to delivering good water quality outcomes?

Dr Mark Williams Environmental Regulation and Climate Change Manager Scottish Water

Introduction

For the past 30 years the water industry and regulators in the UK have been responding to the European agenda to drive improvements in the quality of the environment we all enjoy.

Landmark legislation such as the Bathing Waters and Urban Wastewater Treatment directives have significantly improved the quality of the water environment and driven a level of consistency across Europe that offers citizens a degree of confidence that environmental matters are being regulated.

However, these improvements have come at a cost both in financial terms and in the carbon associated with investment, and it is right to consider how to balance and manage local environmental quality with wider societal and environmental benefits. With the move into a carbon-aware era with statutory obligations for carbon, there is a need to consider the holistic, sustainable development challenges. In addition, with the advent of the Water Framework Directive there a change in focus from prescribing end of pipe standards towards overall environmental outcomes – i.e. good ecological and chemical status.

This requires a more sophisticated approach to decision making, taking more factors such as social and environmental externalities (e.g. carbon) into account when working towards an objective of good status.

Energy and the Water Sector Between 2002 and 2010 Scottish Water will have invested around £4bn in capital improvements to meet service and quality objectives. This is in keeping with the trends observed across the industry. Over that period, Scottish Water has been increasing its energy consumption by around 2.5% per annum. Only recently have we observed a potential reversal of that trend, with the latest figures showing a small decline that we believe is due to the benefits of our recent focus on leakage. What is clear, however, is that investment in quality using the traditional approaches to date would appear to come at a cost in terms of energy and carbon.

Scottish Water Carbon Footprint Scottish Water has reported its carbon footprint annually for the past three years. The latest footprint for the 2008-9 financial year indicates a level of annual emissions of around 475,000 tonnes CO2 equivalents. This footprint is calculated in line with the UK Water industry Research Greenhouse Gas Emissions Workbook, and covers all direct (process emissions, on site generators, transport) and indirect (grid electricity) operational emissions. The breakdown of emissions is shown below.

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GHG Emissions by Activity 2008-09

Transport 4%

Administrative Drinking w ater Activities treatment and pumping 2% 25%

Sludge treatment, recycling & disposal 35%

Wastew ater treatment and pumping 34%

Carbon Intensity of Water and Wastewater Services Table 1 demonstrates the relative intensity of water and wastewater services for Scottish Water in comparison with the UK industry average, as reported annually through the Water UK Sustainability Indicators. This demonstrates that, in comparison to the rest of the UK, Scottish Water has a lower carbon intensity for water treatment and supply, mainly because of the high quality raw water sources and the ability to exploit gravity from upland catchments.

Scottish SD Indicator UK Average Water Greenhouse gas emissions from supplying water 0.30 0.15 (tonnes CO2e per Ml of water supplied) Greenhouse gas emissions from wastewater treatment 0.75 0.95 (tonnes CO2e per Ml of wastewater treated)

By contrast, wastewater services in Scottish Water have a higher carbon intensity than elsewhere. In comparison with the rest of the UK, Scottish Water operates significantly more small treatment works and expansive sewerage networks to cover the distributed population of Scotland. This elevates the per capita carbon consumption. In addition, many of our treatment works in coastal areas have been upgraded in recent years to meet bacteriological conditions. A recent report has highlighted that at several Scottish Water treatment works, improvements to meet UWWT and shellfish standards have led to an increase in emissions of between 150% and 2441%.13

13 Minimising Greenhouse Gas Emissions Across Environmentally Regulated Industry in Scotland and Northern Ireland. Scottish and Northern Ireland Forum for Environmental Research

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Environmental Standards or Carbon? Given the information above, it is often portrayed that this is a simple choice between local quality or global impacts. However, it is imperative that we recognise the significant environmental gains made to date as a consequence of regulatory standards. In Scotland, these have clearly contributed to an improvement in the water environment. A recent (January 2010) Audit Scotland report has highlighted the improvements to date, declaring diffuse pollution and not sewage to now be the most significant cause of environmental quality downgrades14.

The question therefore arises of how to make better choices and deliver sustainable levels of wastewater treatment that secures a good environment locally, without driving up carbon emissions, and at a cost that is acceptable to customers. In considering this, it is important to recognise that there has been a shift in regulatory focus with the development of the Water Framework Directive.

Traditional regulatory regimes such as the Urban Wastewater Treatment Directive prescribe standards of treatment to be met irrespective of the environmental outcome in a specific water body. The water regulator is required to apply such standards, and the water company must seek to apply a level of treatment that will guarantee year round compliance. This invariably means that there is a default to more energy intense treatments that will secure the compliance with the licence conditions.

By contrast, the WFD advocates a focus on environmental outcomes – good ecological status – and seeks to develop sustainable programmes of measures to achieve this outcome. Explicit references to issues such as cost benefit and disproportionate cost assessment offer the opportunity to consider carbon in decision making.

How do we move towards sustainable treatment levels? Barriers In spite of the outcome focus of the WFD, there remain a number of barriers to progressing towards a more sustainable asset base. A key barrier is the prescriptive nature of consents. There has been some movement in recent years towards seasonal consenting, for example of microbiological standards for bathing waters, and nutrient removal outwith the growing season. This has allowed water companies to ensure compliance during periods where there is a genuine environmental need and to reduce treatment to appropriate levels outwith these times.

In seeking to expand this approach, one of the key barriers we have observed is risk aversion on the part of both regulator and operator. For example, Scottish Water has invested in mechanical secondary treatment at a site where it might have been possible to install wetland treatment. This was in response to regulatory concerns and the lack of a contractual guarantee for the performance of the wetland. In the

http://www.sniffer.org.uk/Webcontrol/Secure/ClientSpecific/ResourceManagement/UploadedF iles/UKPIR11.pdf 14 Protecting and Improving Scotland’s Environment, Audit Scotland. http://www.audit- scotland.gov.uk/docs/central/2010/nr_100114_environment_overview.pdf

21 - 22 - event a wetland was constructed under an EU habitat enhancement project and is performing exceptionally well, receiving the full treated effluent all year round.

Further, for the many assets across Scotland operating to existing standards there is a need to build an evidence base that might support more variation of the licence conditions – i.e. give the regulator the confidence that environmental objectives can be met in a more sustainable manner.

There is a need to assess how we might employ an improved risk based approach to both setting environmental objectives and also in selecting and operating assets that provide a sustainable means to achieve the environmental outcome.

Developing Evidence In developing the scope for carbon projects in the 2010-2015 regulatory period, Scottish Water and SEPA have proposed several projects to begin to overcome the barriers highlighted above and to provide an evidence base for making better decisions.

1. Sustainable treatment Taking the example of the secondary treatment instead of the wetland above, we propose to scale back treatment at the secondary works and to assess the performance of the wetland. This will inform the extent to which we might consider bypassing the secondary works at various points in the year.

2. Dynamic treatment at existing works In order to progress the issue of variable consenting, it is proposed to seek to operate an activated sludge plan in relation to the prevailing environmental conditions in the receiving water. For example, current consenting arrangements are based on a specific dilution factors which may be exceeded for much of the year. This project will seek to install real time environmental monitoring and control mechanisms to enable the plant operation to be varied according to the prevailing conditions. Key to this is the regulatory support to undertake the study and to understand the risks and benefits of such an approach.

Conclusions Wastewater treatment has in recent decades evolved to be an energy intense activity. In many cases this has led to environmental improvements in watercourses across the UK that have clearly benefited society. However, we are moving into an era with the WFD where there is an increased focus on environmental outcomes over prescriptive standards. In order to respond to this new approach we need to develop the evidence to demonstrate that initiatives such as sustainable treatment and variable consenting can provide a means to secure environmental quality without impacting carbon emissions.

Royal Society of Edinburgh Inquiry into “Facing up to Climate Change”

Scottish Enterprise Submission

Introduction

Scottish Enterprise is very pleased to submit its views to the RSE’s inquiry Facing up to Climate Change. We have focused on those questions that are within Scottish Enterprise’s remit and where we feel we have some insights and expertise. While we are responding from an organisational perspective we also provide views from a wider economic development perspective given this is our role.

Background

Scottish Enterprise (SE) is the main economic development agency for lowland Scotland. The Government’s Economic Strategy guides our work and we adopt an industry-led focus to stimulating sustainable economic growth. We work with the public and private sectors to support the development of:

o globally-competitive businesses: more firms growing faster and with higher productivity; o globally-competitive industries: increasing the scale and growth rate of Scotland’s key sectors and growth industries; and o a globally-competitive business environment: fostering an innovative, outward-focused environment that enables sustainable economic growth.

Our approach and activities are summarised in our Business Plan and include:

• providing support to a wide range of businesses, from pre-revenue to established global players, to help them unlock new opportunities and grow;

• helping companies to invest in innovation to ensure they have the right products and services to take advantage of opportunities at home and overseas;

• working with our Industry Advisory Groups to develop and deliver industry-led strategies, alongside other public sector partners, that identify and respond to global opportunities;

• supporting the commercialisation of Scotland’s intellectual assets by helping to create high growth spin out companies and stimulating the flow of university knowledge and expertise to drive improved company performance

1 • working with our partners to increase the availability of early stage risk capital that will allow our companies to develop the scale required to become globally competitive.

SE has a clear role in supporting the transition towards a low carbon economy and we are currently working with the Scottish Government to develop a low carbon strategy for Scotland which will integrate with the Government Economic Strategy. The transition towards a low carbon economy presents both challenges but also major opportunities for Scotland. Stimulating low carbon products and services offers the potential to stimulate the Scottish economy and exploit rapidly expanding global markets. We believe that Scotland is well placed to benefit and SE is already actively promoting low carbon activities through our support for the renewable energy industry (particularly offshore wind and marine/tidal), business resource efficiency and low carbon innovation in particular.

To achieve the Climate Change Act targets will require incentives, tighter regulations and attitudinal change from both business and individuals. The public sector has an important role in addressing market failures at this early stage. SE’s role is to help tackle the barriers delaying or preventing investment and innovation by, for example, providing better information on market opportunities and sharing risk by partnering with businesses to help demonstrate the viability of new products and technologies. An early and proactive approach to stimulating low carbon innovation and investment by business will not only enable Scotland to achieve its climate change targets more easily and quickly but will also benefit our economy as a whole.

Against this positive message, however, we are realistic and understand that there may be many adverse impacts from climate change and the transition to a low carbon economy will take many years to achieve. We must also overcome a popular view among some businesses and individuals that climate change brings increased regulations and curbs on their freedoms.

We believe strongly that it is important for policy makers to promote a positive vision of a low carbon economy that is prosperous, competitive, resilient, job-rich and equitable. For business the benefits include secure energy supplies and opportunities for growth for companies, willing and able to adapt and innovate. Since businesses will deliver the majority of carbon reductions it is therefore important that policy makers engage the business community directly when developing climate change policies.

2. What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

Scottish Enterprise

The Government’s Economic Strategy already has the twin aims of increasing GVA and reducing carbon emissions (by 2011). The Climate Change Act will extend and further promote the carbon reduction targets. SE is actively evolving its internal policies and operational delivery to respond to the challenges and opportunities presented by climate change.

The Climate Change Act’s public sector duty will affect SE when it comes into force on 1 January 2011. We will have to demonstrate that our activities contribute to the Government’s carbon reducing targets. Together with other public sector partners

2 under the umbrella of the SENCE group (SE, HIE, SNH, SEPA, Sustainable Development Commission for Scotland), SE has already met with the Government team responsible for developing guidance in relation to the public sector duty.

Scotland’s economy

SE has a broad remit to support growing companies and industries. We are supporting them to mitigate their carbon emissions and increasingly engaging at a strategic level to identify the adaptations necessary in relation to climate change. Many are proactively embracing this agenda. Energy efficiency is currently a key priority (also see Question 11).

Adaptations that result in reducing emissions will present both opportunities and challenges for individual businesses, key sectors (such as Tourism, Food and Drink, Energy and Chemical Sciences) and the wider business environment (including internationalisation and transport improvements). Growing companies and industries contribute a disproportionate amount to Scottish GVA and we need to support them to adapt effectively to a low carbon economy: for example, by promoting domestic tourism and supporting research into more efficient manufacturing methods for chemicals. There are also many “win-wins”, for example, investment in renewable energy, resource efficiency measures, and research and development into low carbon products.

3. What do you plan to do in response to these factors over the next 5–10 years?

SE already has a Sustainable Development Policy and guidance for project managers that includes consideration of “carbon productivity”. In addition, we are in the process of developing a carbon assessment tool to use in our business planning and project appraisal process. These developments will help strengthen our approach to assessing potential carbon impacts alongside economic impacts in our decision making processes.

In the future, we anticipate a more sophisticated carbon analysis of our projects that will help us meet targets for each sector. Although not every project that we support will directly help to reduce carbon emissions, our portfolio of activities will support the transition towards a low carbon economy.

In terms of our economic development role we will continue to adopt a proactive and forward-looking position to supporting the Scottish economy to reduce its carbon emissions, adapt to climate change and maximise the potential economic opportunities.

4. How integrated is your response with other organisations in similar or related fields?

We have many examples of partnership working which demonstrate strong alignment across Scotland. These include:

• working with the Scottish Government to help shape a ‘low carbon strategy’ for Scotland; • membership of the Public Sector Climate Action Group and Opportunities Sub-group of the 2020 Delivery Group;

3 • currently developing a Scottish strategy for Environmental and Clean Technologies partnership in partnership with HIE, SNH, SEPA, the Scottish Funding Council and the Scottish Government. This will be integrated within Scotland’s low carbon strategy; • SENCE - policy partnership with HIE, SDC, SNH and SEPA; • on a regional level, supporting SusTAY (led by Tayside Councils and Dundee universities) and the Sustainable Glasgow initiative; • SE’s new carbon assessment tool is being developed in liaison with the Scottish Government, HIE and several of the English RDAs; and • we have strong links to other partnerships, for example, the Sustainable Scotland Network of local authorities and various environmental technology partnerships.

5. What are the main barriers to change for you and/or your organisation?

Potential internal barriers include staff awareness, the traditional focus on economic (GVA) growth and the fact that carbon assessment can be seen to be an additional hurdle to overcome before a project can proceed. However, we are currently taking active steps to address these issues and our Board and Executive Board are enthusiastically champions of low carbon business opportunities.

6. What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

We feel it is appropriate for us to address this question from a wider business perspective rather than on behalf of SE’s individual position and have summarised the advantages and disadvantages in the table below.

Advantages Disadvantages Tax Simplicity, fairness, transparent, Fuel poverty, affect on small stable, focus on cost-effective savings businesses and resource intensive businesses Trading Delivers planned reductions, focus on Leakage, exemptions, complex, cost-effective savings administration burden Regulations Quickest way to drive up standards, Blunt instrument, unintended side- level playing field, useful where the effects, may stifle innovation, needs market does not work, may to be enforced encourage innovation Incentives Populist, less business backlash, Expensive; may not deliver enough positive message, may be required to or, if too generous may create a support innovation boom and bust

Although traditionally the business community has often resisted tighter regulations, some of the more progressive companies welcome tighter environmental standards if it leads to a level playing field.

4 7. What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure?

• It is sometimes difficult to clearly demonstrate the effects of climate change, especially in Northern European countries. Consequently, some will question the need for action; • Planning issues may further hamper the further development of onshore wind, which is currently the most economic new renewable technology; • Public acceptance is mixed in relation to the perceived need for an enhanced electricity grid to deliver power from locations other than established thermal generation sites (e.g. the Beauly – Denny line); • Similarly, there is currently mixed acceptance of greater numbers of on-shore and off-shore wind turbine structures in visible locations; • Given that the cost of electricity is significantly higher when generated from renewable sources, it is inevitable that the public must accept significant rises in electricity prices over and above inflation with the increasing roll-out of renewables. Some commentators have estimated that this may potentially involve a doubling or even tripling of current electricity price levels. These increases in electricity prices may only be partially offset by energy efficiency measures.

It should be noted that the National Renewables Infrastructure Plan, being implemented by SE, HIE and the Scottish Government in conjunction with port owners and operators, provides a strategic approach developing Scotland’s renewables infrastructure. The Plan will support the identification and development of sites and infrastructure to exploit Scotland’s offshore wind and marine renewables potential.

8. How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020?

This will potentially be a challenging target to achieve because of the availability of relatively low-priced gas. Progress will be easier in rural areas and in new developments. There is, however, huge potential for innovation to drive down costs, which will help the Government meet its renewable heat targets.

The relatively high cost of micro-renewables means that, without significant government subsidy or significant innovation to reduce these costs, it is unlikely that there will be widespread public up-take of these necessary to make significant distributed energy economically possible.

9. What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

• Cost, leading to possible public and business inertia and/or resistance; • Investments in the grid are necessary; • Transmission costs in rural areas are higher; • The increased cost of energy from renewables (see Question 7 above); • Owing to the lack of clear economic benefits in the short term there is a heavy reliance on public sector funding in an environment of severe downward pressure on public finances;

5 • Access to capital has been difficult outwith onshore wind farms. Massive amounts of capital investment are needed to fund off-shore wind farms and growth in this area has been hampered by the perceived commercial risk up until now. This issue may potentially be addressed in future by the creation of the Scottish Investment Bank and/or the proposed new UK Green Infrastructure Bank; • Capital costs of off-shore wind have not reduced as investors expected but have probably increased; and • Next-generation energy technologies also require significant investment and there are difficulties currently in raising the funds necessary to bridge the demonstration gap between research and commercialisation.

10. Is there sufficient action to exploit the potential of microrenewables?

Care is required to distinguish between different micro-renewable technologies. Solar pv continues to be relatively expensive and micro-wind is inefficient in many areas. This relatively high cost of micro-renewables may mean that without significant government subsidy, or significant innovation to reduce costs, it is unlikely that there will be the widespread public take-up of these necessary to make a distributed energy economy possible.

There is, however, huge potential for innovation to drive down costs, which will help the Government meet its renewable heat targets.

11. What are the obstacles to cutting energy use?

Some cost-effective energy efficiency measures are not implemented by business, particularly smaller businesses. This can be because:

• In most businesses energy costs are a small proportion of total costs; • Small businesses may lack management time and expertise; • Often there can be insufficient awareness and importance given to carbon issues; • Businesses are largely focused on short-term payback, and bias their investment expenditure in favour of growth rather than cost-saving measures; • Particularly in the current economic climate, many businesses have insufficient capital (cash flow) available to invest; • There is often a bewildering choice and insufficient product labelling and information at the point of purchase.

It can be seen that there are multiple barriers that will be complex to overcome.

In addition, the rebound effect makes it difficult to achieve targets for cutting energy use. Businesses that are more efficient can reduce prices and this will help to increase consumer demand. The Department of Economics at the University of Strathclyde is carrying out research on the rebound effect.

6 12. What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

Given our role in supporting firms in the construction, energy and environmental/clean technology industries we suggest that:

• more research, development and testing is required into how buildings (existing and new build) can be developed that are more reactive to climate change effects. SE is already supporting a programme of projects addressing market opportunities from low carbon buildings (both new build and retrofit), but more activity is needed; • planning permission for significant new build projects should not be granted in high flood risk areas; and • homes should utilise passive heating/cooling technologies as much as possible, e.g. passive ventilation systems and high thermal insulation, allowing lower capacity heating systems to be used.

13. How should Government ensure that business/domestic energy efficiency measures are met?

The CRC Energy Efficiency Scheme will act to drive energy efficiency measures in larger businesses. Further measures will be required for SMEs to either regulate or incentivise businesses to reduce their carbon emissions. Whilst business would prefer incentives, it is unlikely to deliver the extent of the cuts required. Regulations to enforce businesses to improve energy efficiency are likely to be unpopular with some businesses although grants or loans could potentially be offered as an incentive.

15. How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

Scottish Enterprise:

Under SE’s Green Transport Policy we have encouraged staff to use public transport and most travel between offices is now undertaken by public transport. In addition, we are increasingly using conference calls (particularly instead of one-to-one internal meetings) and we are extending the use of ‘WebEx’ technology to enable documents to be shared online. While we have already significantly reduced our emissions as a result of the introduction of our Policy, it is important to bear in mind that we are a customer-facing organisation directly supporting businesses, and also operate overseas offices which necessitates air travel.

In addition to the savings we have already made we consider that a further 30% cut by 2020 can be achieved through ‘business as usual’ measures. Due to improvements in teleconferencing facilities, we do not forecast an increase in staff travel. The emissions per km travelled are expected to decline significantly (for example average new car is 160g/CO2 per km today, with the EU aiming for 95g by 2020 – a 40% cut).

7 Wider business response:

SE is an active member of the Sustainable Transport Group. As a result, we are currently investigating possible projects with our industry partners regarding the use of Intelligent Transport Systems to enable more efficient and effective use of public transport and to reduce urban congestion.

The move to electric cars is likely to alter the balance between capital expenditure and running costs for private cars. Cars will become more expensive to buy, but cheaper to run. This could have adverse consequences, including congestion and public transport becoming less competitive, unless the Government considers how to introduce an alternative method to charge drivers for distance travelled.

Royal Society of Edinburgh Inquiry: Facing up to climate change

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 1 of 7 30/07/2010

Scottish Engineering promotes the Scottish manufacturing engineering industry and its interests, in Scotland, in the United Kingdom and Europe, whilst providing market leader high quality practical services in all aspects of employment. Scottish Engineering is the major support and lobbying organisation for the manufacturing engineering industry in Scotland. The present membership of Scottish Engineering encompasses around 400 companies from throughout Scotland. Member companies include some of the largest, together with many companies, which are smaller but also innovative and successful. They are involved in all sectors of engineering and manufacturing across every geographic area of Scotland.

Scottish Engineering welcomes the opportunity to respond to this consultation on behalf of our member companies.

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 2 of 7 30/07/2010

Responses to Questions

Organisations - Do you perceive the changing weather patterns in Scotland and globally as affecting your organisation? The bad weather at the beginning of 2010 did contribute to work days lost by staff not being able to get to work. There were also problems caused for companies trying to export their products from Scotland by air, rail and road. These problems were not major as it was a one off, however if this sort of winter weather were to become common then it would affect manufacturing/engineering businesses.

- What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? Manufacturing/Engineering businesses in Scotland are in general setting goals and engaging in activities that work towards a reduction in their energy consumption and an increase in their recycling activity not because of the Climate Change Act but because they are suffering pressure on their margins and need to reduce their costs. There is also commercial pressure in the engineering supply chains to operate in an environmentally friendly way.

- What do you plan to do in response to these factors over the next 5 – 10 years? The chief scientist at the Department of Energy and Climate Change Professor MacKay last year set out his vision for supplying our power needs for the next five, 10 or even 50 years while keeping emissions under control. At the heart of his proposal was nuclear power, which he claimed, would involve a fourfold increase over today’s levels. He has calculated that renewable energy sources including wind and tidal power will only be able to provide a fraction of our electricity needs. Scottish Engineering will continue to lobby Scottish and UK Government to ensure they come up with a balanced energy policy, which includes electricity generation from nuclear power.

Scottish Engineering companies will have to continue with the development of all available generation sources. With the amount of research and development that is going it is likely that there will be regular and significant breakthroughs which will allow renewables to supply increasing amounts of power to the grid.

However, where will we find the people to carry out this research and implementation? Given that the timescales stretch well into the future we must ensure that there is a constant source of well skilled and motivated engineers and scientists to carry the research baton. Take another step back and we see that students at school and university must be enthused and educated in the basic building blocks of maths, science and technology. Today’s children are our future and they must be nurtured through schools, colleges and further education establishments to provide the skills we need for the next 30 to 40 years. Scottish Engineering will continue with their programme of inspirational roadshows to enthuse young people about engineering and their support for individuals who are interested in engineering as a career. Already the skills required to sustain our nuclear industry are in danger of draining away as the existing power plants approach the end of their useful lives – and no others are being planned to take their place. Even more worrying is the policy of the Scottish Parliament which does not countenance nuclear power at any cost.

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 3 of 7 30/07/2010

- How integrated is your response with other organisations in similar or related fields? Via supply chain management in the engineering industry and especially through schemes run by The Carbon Trust there is effectively an integrated response..

- What are the main barriers to change for your organisation? Business will only consider change if it is cost effective. Reduction in costs is the best driver for engineering companies to work towards the aims of the Climate Change Act. Schemes that the Scottish Manufacturing Advisory Service, The Carbon Trust and The Energy Savings Trust operate in Scotland provide results. The carrot works better than the stick. So a plea to Government, limit the amount of climate legislation controls placed on companies.

- What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes? Scottish Government should support businesses of all sizes in improving energy efficiency through tax incentives, at least in so far as devolved powers allow. Other measures should include enhanced R&D support for technological solutions to reduce emissions and setting out a more effective approach on energy efficiency, especially in the household and transport sectors.

Energy generation - How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020? There is little evidence that this target is achievable across Scotland.

District heating systems using pumps to extract heat from water or air are increasingly popular on the Continent. The advantage is that the heat delivered far exceeds the energy consumed. The European Commission has designated such pumps a renewable technology. Star Refrigeration, the Glasgow based specialist supplier of cooling and heating systems, is in the process of completing a £2 million project to supply a cutting-edge heating system to a Norwegian town – which promises to save 15% of the hourly cost of energy bills. The City of Drammen system will extract 10MW of heat from the Fjord and deliver 15MW of 900 C hot water into the district heating system. This system is using Ammonia rather than R134a as the working fluid. If Star's solution saves 1000kg of R134a from leaking into the environment, this will save the equivalent of around 5 million car miles. R134a is over 1400 times as damaging as CO2 and one of the most potent greenhouse gases that exists. More information on this project is available at http://www.star-ref.co.uk/star/images/stories/news/Herald_article.pdf

Most of the current case studies in this area in Scotland are located in rural or island communities. To make a significant impact to the Scottish data they need to scale up to larger towns and cities as in mainland Europe.

- What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 4 of 7 30/07/2010

Scottish Engineering suggests that no time should be lost in putting a long-term energy strategy in place, it’s objective is clearly to source a competitive, reliable and secure supply of energy, as well as achieving significant reductions in emissions.

Our concern is that without such a long-term strategy and a sense of urgency to implement it, industry’s competitiveness will be threatened by more expensive and less reliable energy supplies and there will be far less chance of meeting the Scottish Government’s aspiration to reduce greenhouse gas emissions by 80 per cent by 2050. This view has come even more sharply into focus as a result of the recent escalation in energy costs.

If the objectives are to be met, we firmly believe that no options should be ruled out, including replacement nuclear build as part of a balanced, sustained, long-term energy strategy. Emerging technologies and energy efficiencies have their part to play, but in isolation are unlikely to provide a comprehensive answer.

Future policy on supply has to include a range of options, which feature fossil fuels, renewable sources and nuclear power. In a world of low gas and carbon prices, conventional gas is substantially more competitive than any other energy source. However, in a high price gas and carbon scenario, nuclear power is likely to be the most competitive form of energy, although that competitiveness is sensitive to the rate of return required by those potentially financing the construction of new plants, and Governments have a significant influence on this.

Consideration should be given to the use of long-term power contracts with consortia of major energy providers, or other forms of intervention that might assist the financing of large-scale, low-carbon power generation.

Carbon Capture and Storage All the elements of the technology have been tried at tested. Now we need to integrate the different elements and scale them up to work on conventional power stations. • By 2020, CCS could already be cutting carbon emissions. • By 2030, CCS could be the largest single emissions reduction technology around the world. CCS must be part – and a large part – of any carbon abatement strategy. In the UK it will be a vital component in our efforts to meet the statutory target of reducing greenhouse gas emissions by at least 80% by 2050. To develop CCS commercially in the UK, we need initial commitments from Government regarding the detailed policy framework within which a development and deployment programme can begin. We need to ensure an immediate commitment to a funding mechanism for commercial-scale plants is developed.

Buildings - What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

Financial incentives for energy efficient heating and insulation for companies’ premises would encourage business to upgrade older systems.

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 5 of 7 30/07/2010

A previous Scottish Enterprise scheme to fund 75% of costs associated with companies gaining the ISO 14001 Environmental Standard allowed companies to justify training staff and implementing procedural changes to improve their environmental operations and work on annual improvements.

Transport - How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

HGV’s In the logistics industry fragmentation and low margins, plus historic and enduring lack of collaboration, even between ‘own account’ operators. Lack of trust in Govt. long-term intentions (e.g. previous frequent changes to taxation policy; short-term incentives to purchase low carbon fuels.) Lastly, the vehicle acquisition cycles of most commercial operators result in slow take-up, even when all other factors are favourable. Consequently, the decision to adopt any particular technology must stack up economically both in terms of total cost of ownership and initial capital outlay. Therefore any targets relating to the uptake of low carbon vehicles (LCV’s) should be for a reduction in total emissions across the fleet (similar to the ‘cap and trade’ CRC for energy usage). Adopting total emissions reduction across the fleet gives the maximum flexibility in achieving the targets given the diversity of number and type of vehicles in most fleets. Operators may choose to have fewer of the current type of vehicles, or more low CO2 vehicles for the higher proportion of the fleet and retain current technologies where appropriate. It is the outcome that is important rather than the way it is achieved. If the targets relate to specific vehicle types or fuels (i.e. those originally defined as “LCV”), then there would be a disincentive to development of technologies not foreseen in legislation. Government organisations such as the Technology Strategy Board are key facilitators in the stimulation of new technology development and then in the transfer of information on viable technologies to targeted markets that would be required to support them in terms of supply chain and infrastructure. If the commercial case is made for the adoption of LCV technology, it will go a long way in reducing the perception of risk. Seeing lower risk that the technology is not a dead end will stimulate provision of the necessary support.

Electric vehicles (Cars, Vans, Taxis, LGV’s) Electric vehicles (EV’s) currently charge by connecting a charger to the Grid at either 230v (synchronous or single phase) or 415 v (asynchronous or three phase). 230v systems are typically available in homes and circuits providing up to 30 amps are available. 415v systems are typically found in industrial environments and will charge vehicles at up to 9kw/hr. This means that charging on three phase will be up to twice as quick as single phase. Developments in batteries will mean that EV’s will be able to charge quicker by accepting fast or rapid charges. These chargers may require a transformer but could result in charge times of less than five minutes. They have the advantage of being able to be dispersed and readily available. Hot swapping of batteries is not regarded as practical given the wide variation of electric vehicles and their battery sizes, construction and composition. Hot swapping stations would put a huge centralised drain on the grid rather than using the grid’s ability to disperse power. At present EV’s are significantly more expensive to purchase than Internal Combustion Engine (ICE) equivalents. eg a £20,000 van would cost in the region of £50,000. This cost

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 6 of 7 30/07/2010 is distorted by the Battery which costs c.£20,000. These costs are expected to fall as vehicle numbers increase but are a significant hurdle for the uptake of these vehicles. The running costs of EV’s are significantly lower than equivalent ICE vehicles with fuel (electricity/diesel some 9-11.5p/km cheaper), no road fund licence and no congestion charges. UK Government support for electric vehicles has been mainly in the form of the Low Carbon Vehicle Public Procurement Programme. This was announced in 2007. There is a danger that programmes of this type which are restricted to a small number of Government departments and local authorities could distort the market with non supported departments and authorities putting off the investment decision.

Allied Vehicles Ltd, Glasgow have committed to a programme of development of a range of light commercial vehicles from 1.8 tonne to 4.5 tonne. All of these vehicles have passenger car equivalents. These developments have been fully funded by Allied vehicles Ltd without specific support from Scottish or UK governments.

Scotland with companies like Allied and Axeon is well positioned to take advantage and to create commercial advantage from the move to EV’s. Initially as EV’s are more niche market there could be hundreds of jobs created but as EV’s become mainstream there is the opportunity for the economy that has invested in EV production to benefit significantly.

Scotland is well placed to be at the forefront of electric vehicles benefiting not only the environment but also the economy. The Scottish Government must put in place support structures for public and private operators who wish to move in this direction. Scottish Government and its agencies should prioritise support for development and job creation in these sectors. Support service tenders should include requirements to utilise electric vehicles.

Royal Society of Edinburgh Inquiry: Facing up to climate change Page 7 of 7 30/07/2010

Evidence from the SAGES Graduate School for the Climate Change Inquiry

This evidence was prepared by graduate students funded by the Scottish Alliance for Geosciences, Environment and Society and their participating universities. The evidence is based on the outcome of a short debate on the science and risks associated with using geo- engineering techniques to mitigate climate change. The debate was organised for the annual SAGES Graduate School Retreat on 11th November 2010 and was attended by SAGES graduate students, SAGES theme leaders and graduate school directors, and by Anne Glover, Chief Scientist at the Scottish Government. Following Anne Glover’s advice, we have synthesised some of the ideas raised during the debate for the climate change inquiry.

Geo-engineering techniques for climate change mitigation are a set of techniques designed to reduce carbon concentration in the atmosphere or to reduce absorption of solar radiation by the Earth. Much descriptive information on these techniques and their associated risks can be found in The Royal Society’s 2009 report (Royal Society; 2009), CO2 removal techniques include:

• Land use management: removing CO2 through carbon sequestration in terrestrial ecosystems (e.g. afforestation, agroforestry);

• Enhanced weathering: removing CO2 through the chemical reaction with silicate minerals (e.g. add silicate minerals like olivine to soils used by agriculture, processing of carbonate rocks in chemical engineering plants resulting in bicarbonate solutions released in the sea); • Biochar: harvesting and sequestering biomass to produce organic material (e.g. by burying crop wastes, or pyrolysing crop wastes);

• Oceanic uptake: encouraging CO2 uptake by oceanic biological systems (e.g. iron and macronutrient supply.

Solar radiation management include:

• Increasing surface reflectivity: increasing proportion of solar radiation reflected to space (e.g. white solar roofs, desert deflectors, changes in crop varieties and grasslands); • Enhanced marine cloud reflectivity: enhancing number of small could drops scattering solar short-wave radiation (e.g. atmospheric release of seasalt nuclei); • Enhanced scattering of sunlight through stratospheric aerosols: enhancing number of small particles in stratosphere scattering solar short-wave radiation (e.g. injection of sulphate aerosols); • Space based techniques: using sunlight reflectors to reflect solar short-wave radiation (e.g. shields in near-Earth orbits).

The debate’s main question was: should Britain invest in researching geo-engineering techniques? How should Britain account for risks and public views? The main aim was to raise awareness of science-policy-societal issues taking these techniques as an example. Geo- engineering was chosen for 1) its controversial nature amongst scientists and more generally society, and 2) the potential for every member of the participants to feed in its specialist knowledge. The SAGES Graduate School indeed encompasses a large range of expertise across the environmental sciences1. The participants were encouraged to think about the scientific controversies in using these techniques, but also the governance implications of funding further research and development. The debate also tried to embed discussions at multiple scales of governance in particular the national and international level.

Four groups were created with the objective of supporting conflicting viewpoints and policy prescriptions. The debate allowed for two group sessions to develop arguments, two plenary sessions to convince the audience and one plenary session as open debate. The debate lasted 2

1 For more information see: www.sages.ac.uk

hours and, given the unfamiliarity of the topic to most participants, the moderator gave a brief presentation of the techniques and each group were provided with 5 articles and reports (Fleming, 2009; IOP et al., 2009; Keith et al., 2009; Royal Society, 2009; Victor, 2008). We thus do not wish to comment on specific techniques, but on the general outcome of the discussion and the dimensions we felt important to take into account in future policies

Participants discussed the scientific risks associated with R&D in geo-engineering techniques. It was noted that, while underpinned by sound scientific principles, there were significant gaps of knowledge and embedded uncertainties. Many techniques relied on atmospheric, oceanic and terrestrial processes not yet fully understood by the scientific community. Manipulating natural processes may result in uncontrolled feedbacks or unknown systemic change. Monitoring would be challenging and potentially expensive if a precautionary approach is taken.

Participants discussed the societal risks associated with R&D in geo-engineering techniques. It was noted that they may be ineffective and may entail intense maintenance and monitoring costs. Research and development require time and resources, which could be used for other purposes such as low carbon technologies and renewable energies. Large upfront investments may also lock government into further investing in that approach rather than exploring other potential valuable routes. They may be used as alternatives to the preferable option of reducing carbon emissions. Risks and positive/negative impacts may be unequally distributed across the globe and strata of society. Vulnerable, less powerful groups could bear a disproportionate amount, while powerful groups would reap the benefits. These technologies may be dangerous or un-ethical, and may be misused or manipulated by governments.

Participants discussed the potential benefits associated with R&D in geo-engineering techniques. R&D lies at the heart of scientific and technological innovations that have improved many aspect of human life. Researching geo-engineering has thus the potential to enable valuable discoveries, improve lifestyles, and create new jobs and new ways of dealing with climate change. Society needs to be prepared for different future climate change scenarios, including the potential for rapid changes as a result of passing ‘tipping points’. Rapid, short-term geo-engineering solutions might contribute to limiting extreme climate change in situations of emergency. Furthermore, better knowledge of the impacts of geo- engineering could help prepare a better regulatory framework at national and international level, and ensure technologies are used in the way most beneficial for the whole society.

Participants discussed some of the dimensions for good governance. They noted that given the risks associated with geo-engineering techniques but the potential benefits arising from better knowledge, R&D may be encouraged with an adequate political framework. Key dimensions include: 1) emphasis on systematic consideration of environmental and societal impacts, 2) careful weighting of risks and opportunities with other potential valuable technologies, 3) risk and profit sharing across society, and 4) an international approach to ensure shared understanding, outcome and an enabling environment if technologies need to be tested/used in emergency.

The SAGES Graduate School, November 2010

References

Fleming J.R. (2007) The Climate Engineers: Playing God to Save the Planet. Wilson Quaterly, Spring 2007, 46-60.

IOP, RSC and RAE (2009) Geo-engineering: challenges and global impacts. Report on seminar held by Institute of Physics, Royal Society of Chemistry and the Royal Academy of Engineering on 15/08/2009.

Keith D.W. Parson E. and Morgan M.G. (2010) Research on global sun block needed now. Nature, Vol 463, 426-427.

Royal Society (2009) Geo-engineering the climate: Science, Governance and Uncertainty. London: The Royal Society, September 2009.

Victor D.G. (2008) On the regulation of geo-engineering. Oxford Review of Economic Policy, Vol 24 (2), 322-336.

Prof George Marshall SAC Central Office West Mains Road Edinburgh EH9 3JG Dr Marc Rands, The Royal Society of Edinburgh, 22-26 George Street, Edinburgh EH2 2PQ [email protected]

30 April 2010

Dear Dr Rands

SAC responses to Royal Society of Edinburgh Inquiry: Facing up to Climate Change

SAC welcomes this RSE inquiry and the opportunity for SAC to respond.

Our Business has been contributing to domestic and international climate change mitigation and adaptation agendas through targeted multi disciplinary research, teaching and farm advisory services. Particular strengths of our work are focussed on the potential for the agricultural sector to mitigate climate change and to understand adaptation pathways. An important pre cursor to the latter is an improved understanding of downscaled climate projections to national and local scales.

As agricultural stakeholders SAC can speak from two perspectives, our own business perspective, and from the more general perspective of how climate change is affecting the sector and related land based industries. We will address your specific questions (as relevant to us) after outlining each of these perspectives.

SAC business perspective (www.sac.co.uk) http://www.sac.ac.uk/climatechange/farmingforabetterclimate/

From our own business perspective, potential climate change (paradoxically) offers significant business opportunities in terms of our core divisions: • Research • Teaching/learning • Consulting & advisory

In terms of research, it is now clear that agriculture is vulnerable to climate change and, on a global scale; this vulnerability is closely linked to concerns about food security. Agriculture is also part if the problem (as a source of emissions), and part of the solution to climate change. There is an urgent need to understand how the sector can play its role in national and international mitigation obligations. There is a need for increased research focus on these issues, but this comes after a period of sustained reductions in agricultural research.

Direct Tel Line: +44 (0)131 535 4008 Direct Fax Line: +44 (0)131 535 4332 Email:[email protected] www.sac.ac.uk

Research funders are recognising the need to reverse this trend and are allocating significant funds (RERAD, BBSRC Food Security, FP7 etc). SAC is in an excellent position to offer interdisciplinary solutions spanning crop, soil and plants science with socioeconomics. This interdisciplinary advantage is recognised by our main funding bodies.

Education – SAC has responded to the need to incorporate a broad understanding of climate change within our portfolio of courses. The revisions of our courses have been made in consultation with land-based industries and employers in the sector. We have responded to an increased demand for training opportunities of new courses, modules and degrees Consultancy We have key links to the industry through an extensive farm advisory network. This puts us in a unique position on knowledge exchange with the land use industry. In summary, SAC is well positioned to respond and capitalise on providing solutions to the most pressing public policy challenges of our time

Responses to relevant specific questions:

General sector perspective

Agriculture is particularly vulnerable to climate change and is biologically heterogeneous in terms of the ways it mitigates emissions and adapts. This differentiates the sector from other industries characterised for example by homogenous and relatively well-understood mitigation technologies. There is therefore considerable uncertainty in the science underpinning the sector’s approach to the challenge (e.g. the role and stability of soil carbon). With the growing importance of global food security, ensuring continuity of production under changing conditions is critical. There is less uncertainty about what the socio-economic challenges are in terms of seeking effective, efficient and equitable solutions to mitigation and adaptation. SAC authors recently co-authored a paper for the OECD summarising the main issues facing agriculture under climate change.1

Changing weather patterns

As an adjunct to the natural environment, agriculture is highly exposed to changing climate and weather patterns. Ironically, these changes offer both opportunities and threats to our organisation. On balance, and in the short to medium term in Scotland, the former are likely to outweigh the latter, although the increasing incidence of extreme events is likely to complicate this.

Climate Change (Scotland) Act

The Act places climate change on the agenda for all sectors. While the Act affects our drive for energy efficiency within the organisation, our greater contribution to its objectives lies in how our researchers are identifying the agricultural sector’s contribution to its aims (both mitigation and adaptation), and how our consultants and advisors are delivering relevant message to the land based sector. To support the important links between research and

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Direct Tel Line: +44 (0)131 535 4008 Direct Fax Line: +44 (0)131 535 4332 Email:[email protected] www.sac.ac.uk farm advice, we are re-organising our research strengths around a specific centre of expertise on climate change and low carbon farming. We believe that this centre will house a unique mix of expertise in the UK.

Responses next 5 -10 years

Our existing business plans make provision for SAC to be recognised as a centre for multidisciplinary expertise in rural land use and climate change.

Integration of our response

We see integration as being crucial in the adaptation agenda, not only within our business, but across the land use sector. This is because both autonomous and planned adaptations could lead to adverse public good outcomes. Through the forthcoming Scottish Government’s Rural Environment Research and Analysis Directorate’s research strategy (2011-2016) there will be considerably more integration between SAC and other Scottish research institutions on climate change research. There is currently limited research or practical experience on institutional coordination – possibly with the exception of flood management. We also see the importance of integrating the two challenges of mitigation and adaptation, to ensure that responses to one do not undermine the other.

Energy generation

Exploiting the renewable energy potential of the land based sector throws up a number of challenges, including the location of wind farms, the development of increased central and on-farm anaerobic digestion facilities to handle waste, and the use of land for biomass and biofuel crops. All these issues are currently under investigation by SAC research. In each of these areas there are a number of planning (regulatory) and market barriers hindering further development. In the case of anaerobic digestion, there are current constraints on the transportation of wastes to central facilities and about the biosecurity element of using digestate on land. Current policy also does not support the development of small scale plants (i.e. connection costs and access to ROC subsidy). Trade-offs between food security and biomass production need to be carefully considered, as well as possible negative environmental externalities resulting from biomass production.

Major advantage (for your organization) of a carbon tax, emissions trading, energy regulations for performance standards or inventive schemes

The relative properties of alternative incentive measures are already well-documented in the environmental economics literature. We see different advantages (though no threats) from any of these approaches to our own business, but we recognise the importance of understanding the relative costs and benefits of these instruments as they are applicable in the farming sector more generally (Prof Hanley knows this literature).

Land use: How can we use our land use most efficiently?

Research is needed to understand the efficient (i.e. cost-effective) mitigation potential of agriculture (UK and internationally), a sector allegedly contributing 18% of global

Direct Tel Line: +44 (0)131 535 4008 Direct Fax Line: +44 (0)131 535 4332 Email:[email protected] www.sac.ac.uk anthropogenic emissions. For policy purposes in the UK, this job is being led by the Committee on Climate Change which is charged with developing mitigation budgets under the terms of Climate Change Act (2008). SAC undertook the initial research for the CCC to develop an initial ALULUCF budget using bottom-up marginal abatement cost curves2. This work is the beginning of an ongoing research agenda on understanding the mitigation potential of a range of crop, animal and land use measures. The MACC framework provides a snapshot of the most cost effective measures applicable in the sector. It is ideal for organising scientific and economic knowledge. It also reveals the relevant measures that need to be communicated to the sector in terms of mitigation actions.

In terms of adaptation, climate change may provide opportunities to the Scottish land use sector. Careful planning will be required to ensure that adaptations do not lead to increased emissions or threaten other priorities, including biodiversity and wildlife. SAC recently produced a report for Defra3 assessing the impacts and adaptation options for the livestock sector in the UK, addressing some of these issues.

Land use: Major barriers In terms of reducing emissions, major barriers include the need to accelerate the science of mitigation in both animals and plants. There is also a need to improve the way the national inventory accounts for all direct and indirect emissions and links between sectors. For some land based measures, the basic science is still uncertain (e.g. the effectiveness of nitrogen inhibitors). SAC is involved in a number of projects aimed at improving the uncertainty associated with agricultural emissions. In addition, policy in some cases creates barriers, for example, banned products such as some animal food additives (ionospheres) to address enteric fermentation. The whole potential for using GM technology for plant and animal efficiency is also off the agenda in Scotland for the time being.

With regard to land use decisions for adaptation, SAC research3 has identified that an important barrier appears to be a perceived lack of certainty about the direction of future climate impacts. In some ways the policy is running far ahead of the science. However, our perspective is that we cannot wait for complete scientific precision, and decisions need to be made now that are robust under uncertainty. Other barriers to adaptation include being locked-in to practices that may no longer be appropriate, either due to policy or market incentives, restrictions on land use, traditional practices, or physical characteristics of the land and land ownership.

For both mitigation and adaptation, the behavioural characteristics of producers and their attitudes to risk can form major barriers. Understanding what incentive structures can be offered through rural development policies and other carrot or stick mechanisms is vital.

Yours sincerely

2 Moran, D., MacLeod, M., Wall. E., Eory, V., Pajot, G., Matthews, R., McVittie, A.., Barnes, A., Rees, B., Moxey, A., Williams, A.. & Smith, P. (2008) UK Marginal Abatement Cost Curves for Agriculture and Land Use, Land-use Change and Forestry Sectors out to 2022, with Qualitative Analysis of Options to 2050, Final w ! / / / [ ! ++0 0 0 '+ !"+"!!1 " + . a 5 Ç!! Y í 9 í ! / !" * "' " w ! 5 !/.3

Direct Tel Line: +44 (0)131 535 4008 Direct Fax Line: +44 (0)131 535 4332 Email:[email protected] www.sac.ac.uk

Royal Town Planning Institute in Scotland 57 Melville Street Edinburgh EH3 7HL Tel: +44 (0)131 226 1959 Fax: +44 (0)131 226 1909 Email [email protected] Website www.scotland.rtpi.org.uk Dr Marc Rands The Royal Society of Edinburgh 22 – 26 George Street Edinburgh EH2 2PQ

28th April 2010

Dear Dr Rands

RSE Inquiry into Facing up to Climate Change

Thank you for your letter of 26th November inviting the Royal Town Planning Institute in Scotland (RTPI) to contribute views on how we can best respond to climate change in Scotland.

The RTPI is the UK body chartered to represent the planning profession and offers these comments from the point of view of a diverse and politically-neutral professional body committed to supporting devolved government in Scotland. The Institute has approximately 2100 members in Scotland, working across all sectors of central government, local government, government agencies, the voluntary sector, private consultancy, the development industry and academia.

Since devolution, the Institute has empowered its RTPI in Scotland Office, together with its Scottish Executive Committee, with the responsibility for working with government and public bodies generally for the improvement of the planning system in Scotland. This is in accordance with its charter obligation to work for the public interest.

Our responses to the questions set out in your letter are given in full in Annex 1 attached to this letter. These responses have been discussed with members of the RTPI in Scotland’s Policy Sub-committee and focus on addressing your key aims of:

• helping to develop and respond to proposed Government climate change policies; and • identifying barriers to change, measures to be adopted, and timescales for implementation.

Head Office: Royal Town Planning Institute 41 Botolph Lane London EC3R 8DL Charity Registration Number: 262865 Scottish Charity Registration Number: SC 037841

In summary, the RTPI considers that spatial planning has a key role to play:

• in creating, protecting and managing energy efficient communities; • in reducing emissions and the impacts of climate change; and • in supporting related actions at national, strategic, local and community levels.

Addressing issues of climate change requires co-ordinated actions from many different stakeholders and across all sectors. We consider that planning has both a direct and an indirect role to play and makes a significant contribution through its direct role in influencing the location, scale, mix and character of development, and through its coordinating role in setting out the overall framework for development. The Institute also has a role to play in supporting continuing professional development for its members and in facilitating discussion and the sharing of good planning practice aimed at better mitigation of and adaptation to the impacts of climate change.

The Institute trusts that these comments are of assistance and has no objection to them being made available to the public in the usual way. If you wish any clarification or further assistance, please do not hesitate to contact me at our Edinburgh office: 57 Melville Street Edinburgh, EH3 7HL phone: 0131 226 1959, or email: [email protected]

Yours sincerely

National Director, RTPI in Scotland

Annex 1

The response by the Royal Town Planning Institute in Scotland to the Royal Society of Edinburgh’s Inquiry into Facing Up to Climate Change.

Please note that in the main we have responded to these questions in terms of the responses required by planners operating the planning system. We have provided a note of actions by the Institute where appropriate.

General Questions

Do you perceive the changing weather patterns in the UK and globally as affecting you and/or your organisation?

1. Scotland’s Climate Change Adaptation Framework sets out the challenges for the Built Environment, and we agree with this analysis. Whatever the actual causes of climate change, the need for a different and more resource-conscious approach to land use, energy production and consumption and water management are fundamentals in spatial planning. These objectives should be addressed in line with the sustainable development duty established for the National Planning Framework and for strategic and local development planning in the Planning etc (Scotland) Act 2006 whereby Minister and planning authorities must exercise functions with the objective of contributing to sustainable development.

2. Changing weather patterns may have major implications for future patterns of development across Scotland and for the detailed design of such developments. Development planning will have an important role to play e.g. in avoiding areas of flood risk, landslip and coastal erosion, in the amelioration of heat islands through greater use of green infrastructure, and through closer integration of land use and transport strategies to encourage greater use of public transport, cycling and walking. In addition, energy and heat requirements of new developments will need to be considered and more effort will be required to address issues relating to existing building stock and the retro-fitting of energy saving technologies, and emissions reduction more generally.

What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

3. Planning authorities will need to respond to the general duties for public bodies as set out in the Act. Of particular interest to planners are the sections dealing with permitted development rights in domestic properties and microgeneration in non-domestic buildings; the requirement for any Local Development Plan to include policies requiring all developments to include greenhouse gas emission policies; and the requirement for Scottish Ministers to prepare a sustainable land use strategy by 2011, and every five years thereafter, setting out objectives in relation to sustainable land use and proposals and policies for meeting those objectives in a way which will contribute to climate change mitigation and adaptation, and to sustainable development. We consider that the land use strategy should provide an integrated approach to urban and rural issues.

4. The Act sets out clear targets and reporting obligations but the real challenge will be in making the changes that enable these targets to be achieved. Meeting these targets by 2020 will require huge levels of political and public support. Carbon reduction projects will require increased prioritisation within current and future capital programmes if the necessary changes are to be achieved, and will require effective co-ordination of legislative, environmental and financial drivers.

5. This new legislation reflects the need for innovative policy responses at different scales. As noted in the Stern Report and in Scotland’s Climate Change Adaptation Strategy the planning and management of the built environment has a key role to play in addressing climate change issues within a sustainable development context, and there is a clear expectation that spatial planning will play an important part in mitigation and adaptation efforts.

What do you plan to do in response to these factors over the next 5- 10 years?

6. The planning system has both a direct and an indirect role to play in response to these factors. It will influence actions by the public and the development industry through planning applications, development plans and planning guidance material. However, as noted below, land use allocations will not in themselves make a huge impact on emission levels and close co-ordination will be necessary with other stakeholders.

7. Planning policies relating to climate change are set out in Scottish Planning Policy (SPP). This notes the need for development plans to promote both a locational and site specific pattern of development which reduces the need to travel and encourages active travel and travel by public transport. Development plans should also require the siting, design and layout of all new development to limit likely greenhouse gas emissions. Retro-fitting energy-saving technologies and encouraging public take-up in existing housing stock will also be major concerns.

8. Energy efficient, microgenerating and decentralised renewable energy systems will all be components in the move towards reducing emissions, but the energy-efficient design of buildings will also make a significant contribution to reducing emissions. All have implications for the design of retro-fitted and new buildings and the planning regime.

9. Location, siting, orientation, design, materials and insulation are important factors in the energy efficiency of buildings. Under section 72 of the Climate Change (Scotland) Act 2009 Local Development Plans must require all new buildings to be designed to reduce (by a specified (and rising) proportion) projected greenhouse gas emissions, through the installation and operation of low- and zero-carbon generating technologies.

10. Actions should also include further consideration of combined heat and power schemes, heat recovery systems, the implications for waste disposal strategies, and the development of heat networks and a market for heat. Sufficient energy for electric transport systems and vehicles will require new macro-generating capacity of abundant clean energy. The National Planning Framework should address the location of plant and infrastructure.

11. The shift to a low-carbon economy is a major economic opportunity as well as a necessity and the planning system should play a part in supporting new initiatives to encourage job creation in this area whilst ensuring that the thrust for economic benefit is not counter- productive in terms of the central purpose of protecting the biosphere and the environment it supports.

12. Climate change adaptation tools for policy makers include Strategic Environmental Assessment (SEA). Most public sector plans, programmes and strategies which are likely to have significant environmental effects must be subject to an SEA. Recent guidance published by the Scottish Government Environmental Assessment Team (March 2010) sets out background information and provides guidance on the consideration of climate change factors at different stages within the SEA process. SEA, EIA and applications, as appropriate should include a ‘carbon audit’, set out in a standardised manner clearly understandable to the public.

Action by the RTPI

13. The RTPI launched its Seven Commitments on Planning to Live with Climate Change in June 2009. These commitments address:

• behavioural change; • actions to adapt existing places; • working towards responsive legislation and policies; • improving current practice; • celebrating best practice; • providing an information base on best practice; and • developing climate change education and skills. 14. An up-date of activities under these headings is available on the RTPI website at: http://www.rtpi.org.uk/item/2624/23/5/3

15. Other recent work by the Institute includes the RTPI in Scotland Annual Conference in 2008 which addressed Spatial Dimensions of Climate Change. A short report of this event, with some of the presentations, is available at http://www.rtpi.org.uk/item/2360&ap=1. In addition, a report of international views on climate change was published for World Town Planning Day 2009 and is available at http://www.rtpi.org.uk/item/3090&ap=1.

16. New skills and accessible information systems for members will be required. The Institute will work with others (including the Universities and the Improvement Service) to provide training opportunities, and will develop information systems such as the Energy Saving Trust’s Sustainable Energy in the Built Environment: Best Practice for Scottish Planners. The 2010 revision of this work has now been completed and is available via our website at: http://www.energysavingtrust.org.uk/scotland/Scotland-Welcome-page/Business-and- Public-Sector-in-Scotland/Local-Authorities/Planning-policy

17. The RTPI is addressing its own carbon impacts in heating and lighting, business travel, waste disposal and recycling.

How integrated is your response with other organisations in similar or related fields?

18. The National Planning Framework and Strategic and Local Development Plans provide frameworks for the integration and delivery of activities relating to climate change mitigation and adaptation across all sectors of the economy. Close links between the National Planning Framework, the Marine Spatial Plan, and the Sustainable Land Use Strategy should be developed to address fully issues including renewable energy generation, food supply, and water management.

19. At the level of the Strategic Development Plan, the InterMETREXPlus Greenhouse Gas Regional Inventory Project by the Glasgow and Clyde Valley Structure Plan Committee recognised that land use allocations alone will not make a huge impact on emission levels: however, it identified the Strategic Development Plan as having the potential to play a key ringmaster role in influencing other stakeholders, and in ensuring that the necessary policy levers are pulled harmoniously in order to produce effective actions.

20. At regional and local levels there is a need for close integration of land use and transport policies and actions. The Scottish Government’s SPP states that:

• authorities should ensure that the local transport strategy and development plan are complementary, and work with Regional Transport Partnerships to ensure consistency between the development plan and regional transport strategy; and • the planning system should support a pattern of development which reduces the need to travel, facilitates travel by public transport and freight movement by rail or water, and provides safe and convenient opportunities for walking and cycling.

21. It is also expected that reductions in emissions will also be achieved through changes in vehicle technology. The planning system must support the installation of infrastructure to support new technologies, including the provision charging points for electric vehicles and the provision of fast broadband.

22. Other areas of needed policy integration include links between water management, waste disposal and planning policies (to encourage the efficient use of water resources and the use of combined heat and power), links with design, building and technology (to use design which encourages energy efficiency), and links between environmental policies and planning (to ensure protection of peat carbon sinks; to support woodland creation; to support local food production; and to protect green networks for species migration; and the wider protection and support of biodiversity).

23. The RTPI and professional planners work closely with other professional groups linked to architecture, surveying, building control, engineering, landscape architecture and the built and natural environment. We work closely with Scottish Government, SNH, SEPA and SNIFFER, and with the voluntary sector through the Built Environment Forum Scotland (BEFS).

What are the main barriers to change for you and/or your organisation?

24. Key barriers relate to finance, increased understanding, education, advice and training, and the (lack of) co-ordination of activities. The levels of commitment to action by individuals, politicians, developers and communities will depend on an understanding of the imperatives and on ‘carrots’ as well as ‘sticks’. Many of the necessary societal and economic changes lie outside the parameters of the planning system.

25. Members of the planning profession will require additional training, for example in the appropriate installation and use of energy production and saving, water-saving and waste reduction technologies.

26. A recent report Adapting to Climate Change by the House of Commons’ Environmental Audit Committee following their own Inquiry http://www.publications.parliament.uk/pa/cm200910/cmselect/cmenvaud/113/113.pdf concluded that:

• local authorities need greater levels of support; • planning officers need more resources and skills; • new developments should only be permitted if they are suited to future climates; • there needs to be political commitment to be able to consider adaptation objectives in decision-making; and • the Government must exercise leadership in raising awareness of the issues.

27. Investors and developers need increased certainty in the planning process. Planners should espouse certainty and confidence in their commitment to and application of planning policy and in their support or otherwise for individual proposals and impact mitigations. Planning procedure and integration with other regulatory regimes should be clear and efficiently applied, through co-ordinated working and guidance to applicants, regulators and the public. Royal Society Inquiry into Climate Change in Scotland

Road Haulage Association response

Do you see the changing weather patterns in Scotland and globally affecting your organisation?

Yes - more extreme weather events will have an effect on the haulage industry’s ability to deliver the goods. Heavier rainfall will lead to greater flooding and landslips cutting arterial roads such as at the Rest and be Thankful. More gales will have a greater effect on lorries crossing bridges and maintaining supplies to the islands. Also, as we have seen this winter, more severe snowstorms will increasingly disrupt supplies. If sea levels rise, a number of coastal roads will be under threat.

What are the impacts of the Climate Change (Scotland) Act on the goals / activities of your organisation re investment and exposure to risk?

Unilaterally imposed pollution reduction measures, both nationally and by councils, could affect delivery operations by requiring more investment by the industry during these difficult economic times. Any measures need to be agreed on a mutual basis between all the parties concerned – the freight industry is willing to play its part. One impact is that fuel sources are likely to become more expensive - and there is uncertainty at the present time about being able to develop effective non-fossil fuel engines for medium to long distance HGV journeys. There are likely to be ever increasing bureaucratic controls in calculating the carbon footprint. This will provide difficulties for smaller RHA members to cope with in addition to running a viable business - complex carbon controls will favour a trend towards bigger operators who will be able to deal better with extra paperwork.

What do you plan to do over the next 5 – 10 years in response to these factors?

The RHA participates in numerous groups at national, regional and local level which are addressing climate change issues. Specifically we sit on the Scottish Government run Freight Advisory Group (ScotFLAG) which has a carbon issues sub group. At UK level we sit on the DfT‘s Low Carbon group and more locally on Regional Transport Partnerships, Freight Quality Partnerships and Council’s air quality groups. Hauliers will have to gear up to adopting carbon reducing measures as customers seek to implement green freight routes. As an aid to firms the RHA has produced a publication called the Carbon Footprint Explained. The freight industry will, in cooperation with partner organisations, examine positively the possible benefits of establishing consolidation centres at the edges of conurbations in order to reduce overall lorry journeys (financing such centres is a major problem). Promote and encourage the development of alternative fuels for HGV's which are cost effective and sustainable in a business sense. Work positively with other transport modes e.g. rail and shipping, to develop mutually beneficial routes.

How integrated is your response with other organisations in similar or related fields?

We sit on virtually all the same groups as the Freight Transport Association (FTA).We also keep in touch with the British Association of Removers (BAR) and international road haulage organisations. We are in regular touch with the EU and its Commission.

What are the main barriers to change for your organisation?

Many members are small firms (95% of all road freight operators have less than 10 vehicles) who will continue to be battling for economic survival and this is likely to remain their top priority for some time to come – particularly given soaring fuel costs. Climate change issues will only come to the top of the pile when the majority of customers demand carbon footprint adherence in awarding haulage contracts, and are prepared to pay extra for it! There remains widespread scepticism about the extent – and effects – of climate change. The industry also has an ageing workforce which could probably be more flexible in adopting different ways of working although hauliers overall are very efficient in their business methods and are highly regarded internationally for the standards set. A particular barrier in Scotland is the lack of Government funding to encourage SMEs to go down the clean carbon route; this includes lack of finance to aid training such as for Safe and Fuel Efficient Driving (SAFED) which has resulted in an average of a 10% reduction in fuel consumption for those who have completed the training.

What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

Carbon tax - not attractive at all to hauliers. The UK haulage industry is already the most taxed freight sector in Europe – particularly as regards fuel duty (fuel already accounts for 35 – 40% of a small haulier’s operational costs) Emissions trading - likely to need a bureaucratic system to be set up to make it work and in any case doesn’t seem to meet the central issue head-on. Energy regulations for performance standards - not entirely sure what is proposed here but in any case it doesn’t seem attractive since any implementation will probably need to be underpinned by an increase in form filling. Hauliers already have to deal with a wide range of compliance issues (operator licence conditions, tachographs etc). Adding to the paperwork would not be welcome. Incentive schemes - as previously indicated Government encouragement (in a financial sense) would be the best route to entice hauliers into fully engaging with the carbon reduction issue and any associated regulations.

How could your organisation’s transport emissions be cut by 2020; and what are the barriers to achieving this?

The haulage industry’s emissions would be reduced by the development – and proving on the market – of alternatively fuelled HGV’s. Emissions are currently controlled by EU Directives which have brought emissions down markedly in the last 20 years. These Euro standards (currently at Euro 5) are then adopted by truck manufacturers. Increased use of telematics can lead to more efficient logistic systems. Greater uptake of SAFED driving courses would also help, as would increased cooperation between businesses to consolidate loads (and increase back loads). A big plus would be to reduce congestion by taking more cars off the road which in turn would reduce emissions for vehicles such as HGV’s which need to be on the roads (unlike many car journeys). Modal shift to rail and shipping will have a part to play but road will always be the principal mode. Barriers - most of the barriers have already been listed but the biggest will be the development of effective, reasonably priced alternatively fuelled HGVs, the lack of Government assistance to aid fuel efficient training and the lack of political willpower at a national and local level to tackle urban car use.

Currently there is no alternative to road freight for the majority of freight movements and all truck manufacturers are still investing in R&D for diesel engines

Road Haulage Association Roadway House, The Rural Centre Ingliston EH28 8NZ 0131 472 4180

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The Zero-Carbon Switch: Joint Manifesto for Renewables

A sustainable policy agenda for 2020 and beyond

The UK is already committed to ambitious targets for generating 15 per cent Introduction of all our energy supplies from renewables by 2020, up from about 2 per cent today – that is a seven-and-a-half-fold increase in a decade.

Such a dramatic growth in our zero-carbon supply will require an enormous investment in new technology, the development of new network Renewable energy infrastructure, and a fiscal and regulatory regime that seeks to actively encourage renewables development. is a central political The UK has an urgent need to act. The emerging scientific consensus is that issue. The questions unless global temperature rises are stabilised below 2 per cent within the next decade the world will face catastrophic and irreversible climate change. of how best to tackle A third of our aging electricity generation plant is due to be retired over the next 10–15 years, and the vast majority of fuels for heating and transport are climate change, from fossil sources with volatile prices. With our abundant natural resources and history of manufacturing, Britain is placed to seize this opportunity to secure our nation’s recreate its industrial base and develop a thriving low-carbon economy. energy supplies Over the last decade renewable energy has moved from the margins of the UK’s energy supply to become a central part of Britain’s energy mix. Our and develop a low- industries generate around 2 per cent of the UK’s energy, and wind power and hydropower alone accounted for £2.2 billion in turnover and over 7,000 carbon economy have employees last year. Around the world renewables now represent the fast- growing forms of industrial investment, with 56 per cent of all new global thrust sustainable, power generation capacity investment in 2008. There was more renewable energy plant built in the EU in 2008 and 2009 than all new fossil generation distributed energy up combined. This trend is set to continue indefinitely. Over the next decade our industries together will invest over £100 billion in the UK, and create the political agenda. thousands of jobs.

This summer the Government will produce a National Action Plan for delivering the 2020 targets. Continuing the political consensus around key elements of the recent Renewable Energy Strategy is vital to secure our clean energy future, but still more will be needed if the UK is to fulfil its potential.

Making the Zero-Carbon Switch

If Britain does not take the opportunity of the next decade to switch to renewables and other forms of low-carbon, decentralised generation, then we will be locking ourselves into another 40 years of fossil-fuel generation.

Britain needs a new proactive energy policy that continues to promote investment in sustainable energy. At a time of economic austerity it would be all too easy for a new Government to decide that it is not the right time to make this switch, as the initial capital investment in renewable plant will be greater than traditional forms of power generation from fossil fuels. However, such a decision could be a devastating mistake for the UK, and for the country’s energy consumers.

This document sets out 12 proposals that will help to secure delivery of the 2020 targets and make the zero-carbon Switch. They represent the key policy priorities of the renewable and small-scale low-carbon trade associations, which together cover virtually all forms of renewable power, heat and fuel generation in the UK. The Electricity Today approximately 6 per cent of all the UK’s electricity comes from renewable sources; within a decade this needs to rise to 35 per cent or over Sectors 40GW of installed capacity. However, in order to achieve this, a range of policy issues needs to be tackled, including streamlining the planning service, a reconfiguring of the grid network and training a new generation of skilled engineers.

Meeting the UK’s Heat ambitious 15 per cent Heat from renewable sources, such as wood fuels, recovered resources and other biomass, geothermal, solar, and ambient energy available from the air, renewable energy water and ground contributes less than 1 per cent at present. Most of this is accounted for by industrial biomass use. Its contribution is anticipated to target by 2020 reach 12 per cent by 2010. will require action A radical new policy – the Renewable Heat Incentive – is due to be implemented in April 2011. This should provide, for the first time, a stable across all three framework within which these technologies can grow. energy sectors. Transport

The Renewable Energy Directive contains a sector-specific target of 10 per cent of road transport energy being from renewable sources by 2020. Although electric vehicles and new technologies will have a role to play in the longer term, the vast majority of this target will be met by existing biofuels. Biofuels will only be supported if they meet conditions on sustainability and offer a significant greenhouse gas saving compared to fossil fuels.

The Renewable Transport Fuel Obligation was introduced in April 2008 – the current target is for biofuels to make up 3.5 per cent of road transport fuel. The 10 per cent energy target translates to around 14 per cent by volume, so there needs to be a major ramp-up.

The organisations supporting this statement, which represent the The overwhelming majority of businesses involved in renewable energy in the UK, call on all political parties to commit themselves to the following 12 key Policy policies for the next Parliament. Provision of strong leadership and delivery, combined with a long-term stable investment framework Choice Strong leadership is essential in the current economic circumstances. There must be cross-party consensus, where possible, to ensure there is a long- term stable investment framework, including the Renewable Heat Incentive.

Reform of the regulatory regime to ensure delivery of low-carbon measures Over the next 10 years and to enable investment for a significant expansion of renewable energy by 2020 The current regulatory regime was not designed to facilitate the massive the private sector will investment that is required to make the Green Switch and modernise Britain’s energy infrastructure. The regulator should actively encourage invest over £100 billion the development and connection of renewable generation, including heat technologies. We believe that the next Government should commit to working pounds in developing with the renewables industry and the wider energy sector to develop a long- term and coherent market framework to deliver the diversity required for a the UK’s enormous secure and low-carbon future. green energy potential. Laying out of a clear pathway for the expansion of renewable energy generation up to 2050 The 2020 renewable energy targets have created great momentum and provided a clear signal to the market of the Government’s commitment. However, in order to However, it is less clear what the vision for the UK’s energy mix is after 2020, and the various actors will need guidance in developing their own investment unlock this, the next strategies. We believe that the next Government should set out realistic renewable energy targets to sit beside the CO2 reduction targets up to 2050. Government needs to Commitment to the roll-out of a smart grid network by 2030 lay out a clear policy The Government has already committed to a roll-out of smart meters by 2020 – however, in order to truly empower consumers, take advantage of this framework, with technology and properly integrate many of the larger renewables, this needs to be accompanied by a move to a smart grid network. We believe that the next robust and stable Government should commit to delivering a smart distribution network by 2030. financial support Ensuring that the Local Development Frameworks conform with national planning policy, including the 2020 targets mechanisms to provide The reforms of the Planning Act 2008 have been welcomed by the industry, however, the cumbersome nature of the planning regime remains a major investor confidence. obstacle to the expansion of renewable energy. Many good local schemes remain stuck in planning even though the need for them is clearly laid out in national policy. While local communities must retain the right to make local planning decisions they should have to conform to the democratically drafted national planning policies – including those that incorporate the 2020 renewable energy targets. The next Government should ensure that LDFs conform to National Policy Statements.

Development of a strategic plan for the delivery of key energy infrastructure The proposals laid out by the Government/Industry/Regulator taskforce, the Electricity Networks Strategy Group (ENSG), for a broad-brush plan for grid upgrades is very welcome – however, there is no single body tasked with ensuring its delivery. For heat there is still a lack of capability at a local level to drive the development of heat networks and no clear pathway to unlocking the finance needed for this vital sustainable energy infrastructure. We believe that the next Government must urgently develop a strategic plan for the provision and funding of the new energy infrastructure the UK requires, including the widespread development of local heat distribution networks, appropriate support for the gas grid and its infrastructure, and restructuring of the electrical grid to support widespread use of renewables.

Introduction of a streamlined and properly funded accreditation scheme for microgeneration and small systems technologies Many small and microgeneration manufacturers struggle to bring their new product models to market as a result of the complex and potentially expensive accreditation and testing regime. We believe that the next Government should properly fund the testing centres so that small-scale suppliers are not faced with prohibitive costs when trying to bring their goods to market. Likewise, Government should look to support new Installer Company entrants to the MCS scheme with appropriate training and support.

Establishment of a national business rate relief scheme for renewable energy schemes The proposed revaluation of business rates could have a very significant impact on the viability of certain forms of renewable energy, especially hydro and onshore wind, with increases of up to ten times in some cases. We believe that the next Government should follow the example of the Scottish Executive and introduce a national business rate relief scheme for renewables.

Improvement of access to funding for employers to provide vocational training places There is a desperate need for a new generation of skilled technicians and engineers for large renewables and for trained installers for small and micro products. Although there are significant amounts of funding available for training places, accessing these from the array of different training bodies can often be difficult, confusing and frustrating for employers. We believe that the next Government should rationalise the funding streams to create a coherent funding pathway for vocational training places.

Ensuring that any publicly backed Green Investment Bank effectively facilitates an improved flow of public and private capital The credit crunch has hit many renewable schemes hard – even those that remain a good investment with little risk of default have seen private capital run dry over the last year. We welcome the creation of a ‘Green Investment Bank’, however, care must be taken to ensure the new institution does not compete with private lenders but instead works in partnership. We believe that its roles should be to facilitate improved flow of private capital and provide vital advice to Government of the impact of policy changes on the availability of finance.

Introduction of Government-backed low interest loans for initial capital costs of heat and microgeneration technologies The new Feed-in Tariff and the planned Renewable Heat Incentive should make a real difference to the uptake of on-site renewables and microgeneration by households and businesses. However, these products still represent a significant financial outlay, especially at a time of economic difficulty. The successful Feed-in Tariff in Germany was accompanied by a system of low-cost loans to consumers for installation. We believe that the next Government should introduce low-cost loans to cover the capital costs of installing micro and small systems.

Creation of a coordinated mechanism to deliver energy efficiency Energy efficiency will play a key role in the energy future of the UK – it helps to tackle both carbon emissions and fuel poverty and, combined with smarter networks, will enable better use of our existing resources as well as the energy resources of the future. We believe that the next Government should put in place a framework that allows every householder to easily access high-quality advice and finance for investments to reduce their energy consumption.

RSE Climate Change inquiry response 21st April 2010

Dr Dave Reay, Senior lecturer in Carbon Management, School of Geosciences, University of Edinburgh

General response section:

1. Not directly. In Scotland the changes and resulting impacts thus far have been relatively minor, however the impacts of climate change globally have resulted in an increase in applications to the University of Edinburgh from students wanting to study the causes of climate change and the available solutions.

2. The Climate Change Act Scotland has given our institution a clear policy context in which to set its own emissions reduction targets and from which to direct various research strands.

3. A key area of investment for us is the new Edinburgh Centre on Climate Change to meet the needs of the private and public sector in light of the Climate Change Act Scotland, UK and international policy and market developments of relevance to climate change.

4. Over the next 5-10 years we expect the ECCC to develop into a trusted portal for climate change advice to and collaboration with business and government. In addition, the CC Act Scotland and its implementation is expected to provide us with opportunities to focus some of our research on emissions mitigation and adaptation in various sectors, especially those of energy and land use.

5. Well integrated, but with room for improvement. On research, pooling initiatives such as SAGES have allowed us to better integrate our climate change-related research. But on policy and industry advice and collaboration further integration is needed.

6. The main barriers are the size of our institution and the traditional ‘silo’ format of academic research disciplines. To address climate change effectively requires a multidisciplinary approach and the integration of the available expertise.

7. All have both merits and downsides for our institution. For our students, improving energy performance and cutting GHG emissions is am important demand of us. The CRC has the potential to cost Edinburgh more than 1% of its profits if we do not continue to improve our emissions performance.

Energy

1. As past wind project development has shown, community engagement is central to gaining public acceptance. This needs to go beyond a ‘why we need zero C energy’ education exercise, and instead show the local stakeholders how new developments will benefit them directly e.g. reduced energy bills, ROCs or FITs revenues.

2. In the domestic sector this will depend on the renewable heat FITs and their level when introduced in April 2011. With a high enough incentive uptake could easily reach 10% of domestic buildings by 2020 (mainly via solar heating, heat pumps and biomass). For commercial buildings, again if the incentives are high enough then the technologies are already available for this transition (e.g. CHP).

3. The main barrier is that of investment, which is itself acutely affected by long development times and planning barriers. For wind in particular, the long development times and numerous planning barriers could mean that the 50% target is missed if the status quo continues and investors are scared off by the high transaction and development costs involved.

4. Yes, the FITs for electric microgen are very generous and demand is soaring, aligned to the heat FITs coming in next April the microgen component of renewables in Scotland should expand rapidly. The £10k limit to loans currently available to home owners should, in my view, be increased and, in line with an easing of planning barriers, allow individuals and communities to more easily invest in larger microgen installations (e.g. >4kw wind turbines).

5. In Scotland, the poor energy efficiency of much of the housing is the main barrier – improved insulation of solid wall homes needs a coordinated approach that addresses the ‘hassle factor’ for home owners and landlords and ensures no net cost of improvement. For transport, EU and UK standards should help to reduce energy usage, but the current dearth of high class public transport would need very substantial investment if a significant switch from car to bus/train/tram is to be achieved. On the latter, greater incentives for and availability of low and zero C cars is more likely to reduce energy use.

Land use

For Scotland, a growing concern should be the vulnerability of its C-rich soils (esp. peatlands) to land use and climate change. Coordinated peatland restoration and protection should be at the heart of reducing land use emissions and enhancing sinks in Scotland. Forestry, esp. in NE Scotland, is projected to benefit from CC and this should be accounted for in reforestation policy (see: http://www.foresight.gov.uk/Land%20Use/jlup/19_Land_use_and_climate_change_in_th e_UK.pdf). On a related note, land use policy should take full account of the GHG emissions implications, with due regard taken of the role of forestry and agriculture in providing low and zero C energy via biomass and anaerobic digestion – for both of these renewable energy technologies, the financial and planning barriers to development should be better addressed to provide investors with more confidence.

The major barriers to changing land-use activities are lack of investment, stakeholder rejection and policy antagonisms (e.g. EU vs UK, vs Scotland). Given the importance of this sector to Scotland’s emissions budget and targets, an expert sub-group of the CCC would be useful in advising policy of specific relevance to Scotland.

Buildings

1. Such adaptation should be linked with energy performance improvements. The UKCP’09 projections allow dialogue with stakeholders to be based in the context of likely impacts at a community scale. Flood risk is the most pressing issue, but heat stress in public buildings |(e.g. schools), water supply, land use and agriculture stand out as sectors where special attention is required.

2. For business, the CRC combined with rolling out of public disclosure of emissions performance. For domestic sector, education, smart metering and FIT incentives.

3. As mentioned above, the numerous impact surveys and ‘permission’ hoops that any renewable energy development must jump through. While planning restrictions mean that a wind farm development may take >6 years in Scotland (as opposed to 6 months in the US) investment will always be harder to secure.

Facing up to Climate Change

I don’t see a huge impact for Scottish people from climate change in the short term at least, a far bigger impact will come from the changes required for low carbon living. I think that the lifestyle change will ultimately be beneficial to all, obviously due to limiting climate change to a manageable level, but we should also see a higher standard of living due to cheaper energy supply than the current fossil fuel source. At the moment we are relying on cheap fossil fuels to power our activities, but it is only cheap because we are not paying for the hidden costs. Sustainable energy production should in the long term be effectively free, allowing for a higher standard of living for all.

Issues regarding the transition to low carbon living in Scotland

For myself as a consumer I see 3 main areas that my family and I need to address

1) I need to cut emissions of carbon from the house I live in

2) I need to look carefully at the carbon emissions from the things which I consume

3) I need to cut the emissions from transportation I use

I plan to address all 3 of these as aggressively as I can afford to, bearing in mind that I am investing in the future for my children and theirs. This means that I am not expecting the changes to be cost effective on paper in the short term, but rather I am looking at the long term benefits. For example the cost of manufactured goods falls with production volume, so as an early adopter of new technologies I must expect to pay more now for a particular product than in the future. The log term benefits are difficult to quantify but are nevertheless going to be very significant. There is no doubt that the government emission targets can be achieved or exceeded, but there must be changes in policy to make it happen.

Housing (and other buildings)

I will firstly outline what I plan to do with my own house, then some general comments about the way forward.

I plan to cut the emissions from my household energy use by 50%-80% by increasing efficiency and using solar energy and a ground source heat pump. It will be more expensive for me to do than for many homes, as I have an old house, but looking at the long term picture my investment will still pay for itself.

1) Use LED lighting with automatic switch off when a room is not occupied 2) Make sure the insulation and draught proofing in the house is as good as it can be. 2) Purchase only the most efficient appliances and use them sensibly (noting left in standby mode when not in use) 3) Use of passive solar heating and heat storage as the base heating for the house 4) Use ground source heat for all further heating requirements 5) Use solar thermal and PV panels over the entire south facing roof of the house.

Facilitating the necessary changes

There are significant barriers to doing the above, and urgent action is needed to reduce or remove these. I am in the fortunate position that I have the money and expertise to achieve these goals, but most people don’t so the government really needs to step in and help home owners achieve their targets. The current grant schemes are far too cumbersome, there needs to be a more accessible form of subsidy. The feed in tariff for PV is a good move, as the guaranteed income will make it easier for owners to obtain loans to do the installations. Due to the large number of people who need to upgrade their homes, there will not be enough specialists to do the work, so DIY improvements must be made easier to do. For example I should be able to pop down to B+Q and buy a 3Kw PV system in a box, take it home, install all of the equipment myself, requiring only an electrician to do the final connection, saving thousands of pounds and a lot of time. We don’t have time for the current web of regulation if we are to achieve the targets we have set. We need to look back to the 2nd world war for inspiration on how to get things done; they achieved massive results in little time with scant resources through hard work and very clever organization.

To take it a step further the government or local authority needs to survey each house in the country, do an assessment of the best systems for that house, supply them to the owner for self installation where possible, along with a detailed plan, and have teams of installers who can work systematically through the entire existing housing stock assisting owners where applicable, or doing installations.

A special government department needs to be set up to design systems which are plug and play for easy and safe installation. They also need to train installers, and provide support for people who want to do some or all of their own installation. I believe this is the most important change which needs to be made.

Many people will surprise themselves with what they are capable of achieving with a bit of help and guidance.

Planning

There needs to be a complete re-think on the purpose of the planning department, with the top priority being the minimization of carbon dioxide emissions due to the building and use of our homes and other buildings. We can look to the Scandinavian countries for guidance, for example their widespread use of wood for construction and use of heat pumps.

All new builds should be carbon neutral, and serious thought should go into each existing property with regard to whether it will be better in the long run to demolish and re-build.

Transportation

Cars

I want to highlight the fact that a large proportion of the emissions from cars occur during their manufacture and subsequent recycling. It is therefore easy to reduce the emissions from cars by simply using them for longer. The current status quo of using a car for 10 years then dumping it is unsustainable. Retro fitting older cars with more fuel efficient engines and conversions to electric and hybrid propulsion should be the center part of car emissions reduction strategy over the next 10 years. The car manufacturers won’t like that because new car sales will fall. It is therefore up to government regulation to encourage the continued use of older cars, and discourage the manufacture of cars (and other goods for that matter) with build in obsolescence. There is no reason why the next generation of cars can’t be designed to last for 50 years or more. They can be designed to be easily refurbished in simply equipped workshops or at home by putting on new body panels and seat covers etc. All wearing components should be easily replaceable; this is made a lot easier on an electric car with far fewer moving parts. I believe this is the main reason for the lack of adoption of electric cars, i.e. they would last too long. Car manufacturers should be forced into building sustainable cars with an indefinite service life. Future style changes and safety / performance improvements could be retrofitted to existing models

Public Transport

The public transport system needs to be electrified. There is no new technology required for this, it’s well established around the world. Incremental efficiency improvements can be expected.

Energy production

Scotland can easily meet all of its energy needs from renewable sources (Hydro, wind, tide, wave), as long as this energy is used efficiently.

Dr Marc Rands The Royal Society for Edinburgh 22-26 George Street EDINBURGH EH2 2PQ

Direct line: 0844 493 2565 Email: [email protected] 1st May 2010

Dear Dr Rands,

Facing up to Climate Change – Royal Society of Edinburgh Inquiry

Please find attached a response from the National Trust for Scotland (the Trust) on the above. The Trust response has received input from its Conservation Committee as well as a wide range of staff. Consideration of this topic is a ‘work in progress’ but we hope the experience and ideas expressed will be of interest and use to the Society in drawing up its findings.

We would be grateful to be kept informed of progress in this matter and for a copy of an eventual report on the Society’s consideration and findings. I hope that this response will be helpful. Please contact me or the Policy Team at the above contact points if we might be able to provide any additional information or clarification. For the avoidance of doubt the Trust is happy that these views be made available to the public.

For and on behalf of the National Trust for Scotland

John Rosser p/p Terry Levinthal Director of Conservation Services & Projects

The National Trust for Scotland is Scotland’s leading conservation charity. The Trust protects Scotland’s most important historic buildings, collections, gardens and wild habitats. In carrying out its work the Trust is dependent upon the support of its members, volunteers and the general public. The National Trust for Scotland for Places of Historic Interest or Natural Beauty is a charity registered in Scotland, Charity Number SC 007410.

Patron - HRH The Prince Charles, Duke of Rothesay KG KT GCB OM, President – Duke of Buccleuch and Queensberry KBE FRSE DL, Interim Chairman – Richard Balharry MBE, Chief Executive – Kate Mavor MA (Oxon)

Registered Office - Wemyss House 28 Charlotte Square, Edinburgh EH2 4ET. Tel: 0844 493 2100 Fax (0131) 243 9301

‘Facing up to Climate Change’

A Response by the National Trust for Scotland to The Royal Society of Edinburgh Inquiry on Climate Change

The National Trust for Scotland The National Trust for Scotland (‘the Trust’) is a conservation charity which protects and promotes Scotland’s natural and cultural heritage for present and future generations to enjoy. We are Scotland's largest voluntary conservation charity; we believe that the natural and cultural heritage of Scotland is one of our nation’s greatest assets and that we have a duty to pass on this inheritance to benefit future generations. We aim to achieve this in three ways:

• by directly owning or managing some of Scotland’s most important heritage places • by engaging with all sections of society to make our heritage more socially inclusive • by campaigning on behalf of the whole of Scotland’s heritage

We are supported in this by our 310,000 members and a team of 3500 dedicated volunteers. Our 131 properties include 76,000 hectares of Scotland’s finest countryside and wild landscapes as well as castles, country houses and gardens. Each year we welcome around 3 million visitors to these very special places, and well over 100,000 young people benefit from specially arranged educational visits. Introduction We are grateful for the opportunity to make this response. It has been prepared by the Policy Team based in the Head Office of the Trust. The Trust is almost unique in the way it owns and manages both natural and cultural heritage assets and so can appreciate climate change across a very wide spectrum of environmental impacts. The Policy Team has drawn views from across a range of Trust experts in these fields, both staff and members, from the Trust’s Conservation Committee, from internal working groups looking into consideration of climate change issues and from the Trust’s Environment Officer. The Trust has been addressing the issues of climate change impacts mainly at a departmental level but has recently commissioned a consultancy aimed at bringing the strands together as a step towards to establishing a more corporate understanding of risks and programme for action. This work is still in progress.

As with other areas of the Trust’s educational, curatorial and technical work, whether it be on the natural or the man made, it has contributed its experience to others through a wide range of avenues either run directly or in conjunction with others. Recent examples include understanding thermal performance in historic building structures, developing an integrated curatorial pest management system and tackling the outbreak of phytophthera in some of our gardens. It is hoped that as work progresses to tackle climate change impacts through mitigation and adaptation the Trust can help both to alert others to the type of change that is occurring and how its experience can contribute to developing best practice in the broad heritage sector.

Some of the Royal Society’s Inquiry questions though concern quite specialist areas especially in relation to the organisational and financial settings for renewable energy generation. Here we should point out that the Trust does not have in-house specialist energy expertise but does try to identify what appear to us as salient issues, even if only at very initial stages in our work, which merit consideration.

Summary From the Trust’s survey work a range of climate change impacts on both natural and built heritage are identified. Tackling these impacts are placing calls for additional organisational responses to resource levels and use, new business systems and skills improvement and identification of ways that best develop long term solutions that ‘fit’ with the historical context and character of the heritage that the Trust owns and manages. This is a continuing and developing exercise building on the experience of the organisation’s members and staff, across a wide range of expertise, disciplines and locations and on its own conservation principles and policies1.

The Trust previously contributed to and recognises the importance of the Climate Change (Scotland) Act 2009 and agrees with the main thrust of the RSE Inquiry that in rising to the challenges emphasis must be given to implementation. Detailed comments are offered for the 5 main areas under investigation. Rather than barriers or obstacles set from ‘without’ the Trust considers there are also opportunities to improve the process from ‘within’ and identifies here some common themes emerging from our detailed responses in how this might be approached: • More emphasis on strategic and integrated planning (both in achieving multiple benefits through the Sustainable Land Use Strategy but also spatially in locating renewable energy generation / transmission to reduce unfavourable impacts). • Better integration of energy efficiency with renewable energy / micro-renewable generation initiatives. • More attention to infrastructure planning, not just energy generation but also power and heat transmission systems, vulnerability of utilities to climate change, more support for alternative modes of transport, and comprehensive coverage of wired / wire-less high speed / capacity communications links so that all communities share in the ‘information age’. • Simpler, longer lasting and better value incentive or grant assistance schemes in both built and natural environments • Encouragement to adopting longer term cost in use analysis. • Develop better auditing of both natural and built assets and carbon footprinting techniques to assess change and recognition to environmental limits. • More support for research, development of best practice and dissemination of change management in this field (and particularly to Historic Scotland and Scottish Natural Heritage for support to the heritage sector). • More encouragement and support for genuine changes in culture and behaviours in work / life balance, through new business models which see work as an activity rather than a place (remote and dispersed working) and low carbon working practices (home working, video conferencing) helping to revive local economies, making walking / cycling more feasible but also through energy use monitoring, local sourcing, materials reuse, biodiversity enhancement etc.

Evidence Questions Organisations - Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

1 See National Trust for Scotland Policy Context at http://www.nts.org.uk/Policy/

Briefly we understand the changes to be generally warmer temperatures, changes in seasonal precipitation patterns, more frequent storm events and disruption of the ocean currents affecting our coastal and offshore areas.

Natural Heritage Impacts: Nature Conservation specialists carry out regular surveys on land and marine environments. Global warming as monitored by UKCIP shows since 1980 seas warming by 1.5 C and land by 0.5 C. The distribution patterns of prominent members of the plankton have shifted northwards by some 1000km over the same period. It has been observed that in years when temperatures have been higher than average sandeels, one of the most important food stocks for several species of seabird, have been scarce. In the three years leading up to 2007 they were partially replaced by snake pipe fish which chicks cannot swallow or digest leading to dramatic fall off in breeding success for species such as Black-legged Kittiwakes, Atlantic Puffins and Common Guillemots. Pipe fish have become much scarcer again since 2008. The Trust has a number of islands in its care and is increasingly recognising that they represent special opportunities to identify subtle changes in climate, species breeding success, species range etc. without the ‘background noise’ prevalent on the mainland.

On land, higher temperatures have led to milder winters with reduced snow cover. This can be critical for Arctic-alpine plant species, such as the Woolly Willow, which are exposed to more intense grazing during the critical late winter months leading to their increasing scarcity. Other rare Arctic-alpines, such as the Snow Pearlwort, have shown a marked decline, but the exact cause is less clear. Bird and butterfly ranges are shifting generally northwards – whilst this may mean the introduction of new southern species it means indigenous species may be under threat. Warmer and wetter conditions may also facilitate the spread of disease and pests such as blue tongue virus and phytophthora.

Increased frequency and strength of storm events is leading to upland soil and coastal erosion and the need for increased moorland management to help alleviate down river flood events. Storms are leading to increased shelterbelt strengthening and new drainage in gardens and the increasing uncertainty of seasonal weather sequences is causing difficulties in plant success, replanting choices and timings2. The Trust is engaged in securing a sustainable future for parts of the Caledonian pine woods which are especially vulnerable due to their marginal environment and tree planting along banks to shade sections of the River Dee to help preserve salmon stocks which are thought to have dwindled due to increasing temperatures being recorded in the river. Changing climate raises questions about which replacement plant/tree species will suit the new climate expected in the future, which will have an impact on both our gardens and the wider natural environment. Coastal erosion is also exacerbated by sea level rise.

Cultural Heritage Impacts: Increased winter rainfall and more frequent storm events are having increasingly damaging impacts on many of our traditional buildings, often with no or little rain water systems included as part of the original design and character. Coastal erosion threatens some buildings located near to the shore. The increased wetting of traditional materials, especially when coupled with rapid changes between mild and freezing winter temperatures is causing increased water ingress, erosion, rot and reduced thermal performance leading to more damage not just of the external fabric but also of important and classical interior finishes, fabrics and artefacts. It too is creating ideal and longer lasting conditions for existing and new pest infestation and breeding. Stronger summer time light is meaning increased prevention to avoid fading materials, paintings, furniture etc.

2 ‘Gardening in the Global Greenhouse – the Impact of Climate Change on Gardens in the UK’ by UKCIP, RHS and National Trust for Defra & others, 2002 Summary Report at http://www.nationaltrust.org.uk/main/w-gardening_global_greenhouse_summary.pdf

- What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? The main goal of the Trust is its work as a charity committed to the conservation of nationally important natural and cultural heritage, including all aspects of the property in its care from wild land, natural settings and surroundings, its buildings and the wealth of their contents and their promotion through access, education and enjoyment through a wide range of services and opportunities.

Some of the changes being experienced are outlined above. Whilst conservation does not mean preservation (the prevention of change) the speed and magnitude of change could be thought unacceptable. These conflicts may be brought about by increasingly having to introduce a broad range of non-traditional adaptation measures, from adding new or enlarged rain water drainage systems to historic properties to cope with extreme rainfall to planting more drought resistant species in gardens which may be tolerant of warmer drier conditions but not previously thought of as native species.

In all circumstances the sort of issues highlighted previously will lead to increasing planned or preventative maintenance to the care of artefacts, buildings, gardens and countryside. These may impose risks of additional costs at a time of considerable resource constraint, the need for innovatory yet unproven approaches, scarce skills through a time of developing knowledge and experimental responses that may be of uncertain life spans. These ‘internal’ risks then need to be seen together with ‘external’ risks for their impacts on visitor experience, visitor ability to travel and so visitor income – similarly there may be increasing demands placed on those agencies of government that also support the work of the Trust. These may result in reducing income. On the other hand warmer summers may encourage ‘staycations’ and so improve visitor numbers.

In summary: • Climate change impacts require increased maintenance and adaptation measures and introduce further requirements in resourcing, monitoring and business planning • Historic Scotland should be supported to carry out more research on introducing acceptable adaptation measures for historic buildings, on appropriate management and maintenance techniques and craft skills

- What do you plan to do in response to these factors over the next 5 – 10 years? Considerable input does already go into regular and comparative surveying of Trust property whether it is artefacts, buildings, natural habitats and their flora and fauna to detect change more rapidly. The Trust has also started to prioritise land uses that result in increased carbon sequestration or storage. This has resulted in establishing priorities for protection of peat lands and woodlands as carbon stores. Decreased output of CO2 from our own activities is being addressed by introducing energy performance monitoring and energy efficiency over its buildings, public transport information for visitors and as yet limited approaches to providing renewable energy generation where appropriate.

These initiatives are being progressed in the teams responsible, sometimes through their own ‘environmental working groups’, through specialist staff under work programmes and in liaison with or directly by the Trust’s Environmental Officer.

The next interim stage currently in progress is to draw together and prepare an internal Trust current position statement from calls for action, from its own reports and documents and from work practices across the Trust in relation to Climate Change. This should help to establish how the Trust can take a coordinated approach in its activities in relation to Climate Change, including recommending priorities and objectives, concerning in particular the following: • Mitigation impacts at its own properties, including guidance for Property Managers

• Connect with and offer guidance for members and visitor services • Monitoring and reporting systems, including consideration to introducing a carbon footprinting system of actions and operations • Corporate best practice issues in relation to governance, external policy context, and property support services

- How integrated is your response with other organisations in similar or related fields? The Trust has had direct contact with other environmental NGO’s on this topic through the intermediary organisations like Scottish Environment LINK and Built Environment Forum Scotland (BEFS). It has also worked closely with other bodies. It is carrying out a study with Historic Scotland on the thermal performance of traditional constructions and has assisted at workshops on climate change impacts; it is working with Scottish Natural Heritage (SNH) and Forestry Commission Scotland (FCS) to develop good practice measures in its countryside management and with the help of the Carbon Trust and Energy Savings Trust it is developing renewable energy initiatives and internal organisational practices especially in regard to energy efficiency.

- What are the main barriers to change for you and/or your organisation? As an organisation with so much cultural and natural heritage to conserve there are many and considerable competing interests looking to secure funding from the limited resources available. This applies to how much resource it is able to direct to this issue. Whilst the use of the term barrier may be too strong there are then limits to how much investment can be made into research, development of understanding, assessment of likely changes, review of best practice, identification of appropriate responses, deployment of best skills and long lasting solutions.

- What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes? No formal and agreed assessment of these different schemes has been made by the Trust and so only an initial view is offered of the relative merits. The Trust is committed to reducing its direct contribution to the emission of green house gases and that the best practice should provide a focus on reductions at source.

Carbon taxes and emissions trading are ways of offering financial incentives to reduce emissions, the former through encouraging use of lower carbon content energy generation by price certainty on emissions and the latter more through energy efficiency by a need to address quantity certainty on emissions. It is our understanding that the main aim of an emissions trading scheme is to provide increasingly strong incentives to reduce emissions over time. The system as it operates at present does not achieve this because of the unrealistically low cost of carbon emissions.

Trust policy and practice is directed foremost at energy efficiency measures so that in the first place the amount of energy required is reduced but there are limits to which this can be achieved in the type of property it owns without undue change of their historic character. The same though could also be said about the extent to which new energy generation techniques, especially renewable, might also impact.

In balance the ‘policy choice’ might then be an assurance of an emissions scheme to achieve decreasing levels of emissions in order to create a sense of certainty of achieving nationally set targets – and this is not to underestimate the financial implications of paying for the alternative of a steady increase in carbon taxes. In practice a choice between these systems could also depend on how they come to be developed and what is considered eligible. If either of these systems could credit the Trust for the carbon sequestration of its peat lands (some 60% of its 76,000ha in ownership), woodlands and soils, especially if this could be by some measure of existing capacities rather than schemes to achieve greater capacity, then that system, with all the

land owned by the Trust, might be advantageous. The Trust has recently introduced some moorland management guidelines, applicable across all of its upland properties,that specifically address this issue.

Incentive schemes, whether as tax breaks, feed-in tariffs or capital grants, appear easier to operate but again precedence suggests that the levels at which they have been set have not always been generous in relation to the overall cost of installing new technologies, the budgets set aside have run out quickly and their availability has not always coincided with cycles for plant replacement. It may be that with reducing costs for renewable technologies and increasing costs of traditional fuels the level of incentives, should they remain as they are now, might seem more advantageous by comparison eventually. Below we consider whether there may also be merit in aligning some of the more direct incentive programmes with developments in the Energy Performance Certificate regime.

Whilst again understanding resource constraints for Government the question then that might still be asked is how seriously do we as a country think change is needed and to what extent are we prepared to support it. The complexity of existing systems and the balance of support do not give an impression of needing to make haste – see the response below concerning micro-renewables. This is rather contrary to the impression to be gained from the urgency set out in the timetable contained in the Sullivan report ‘A Low Carbon Buildings Strategy for Scotland’3 for changes to the Building Standards (Scotland) Regulations.

In summary: • The Trust continues to explore ways it can itself carry out and demonstrate best practice in energy efficiency and renewable energy generation and direct incentives appear to offer the simplest, quickest and best ways forward.

Energy generation - What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure? It still seems there is a considerable effort required to convince people that climate change is actually happening and that renewable energy is necessary or indeed works. The Trust, as an advocate for Scotland’s landscapes, continues to get considerable correspondence asking it to support objections to energy developments (particularly wind farms) and their associated transmission infrastructure on the basis of their visual impact on landscapes and damage to biodiversity, especially in areas of considerable character or areas prized for their remoteness and wild land qualities. Sometimes these objections are coupled with a lack of consideration by the sponsors to any community involvement in (other than statutory planning requirements) or gain from their proposals.

In summary: • The lack of a locational strategy for renewable energy is leading to opportunistic and ad-hoc developments that are in danger of eroding the nation’s considerable landscape assets.

- How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020? Currently the emphasis has been on biomass with heat from waste as an emerging priority4. With a target of 11% of heat consumed to be from renewable sources by 2020 this would appear to mean a contribution will have to be made by more urbanised settlements where air quality standards may become an issue for these technologies. Further investigation may need to be made on whether district heating schemes, like local area electricity generation, would be subject to competition rules. In Edinburgh it is understood some small scale

3 ‘A Low Carbon Buildings Strategy for Scotland’ The Sullivan Report, The Scottish Building Standards Agency 2007 page 8 http://www.sbsa.gov.uk/pdfs/Low_Carbon_Building_Standards_Strategy_For_Scotland.pdf

4 Renewable Heat Action Plan for Scotland http://www.scotland.gov.uk/Resource/Doc/290657/0089337.pdf

district schemes have been installed in housing association led new build housing developments mainly using conventional fuels and one through biomass.

It is estimated though that between 65 and 75% of the housing that will be in use in 2050 is already here so the challenge becomes more one of what measures could be applied in the circumstances of existing housing. The traditional tenemental housing form, typical of so many urban environments in Scotland and still accounting for almost 20% of all housing stock, together with other flats some 13% 5 , could be well suited to the introduction of communal heating schemes - it may be that other forms of renewable energy/heat generation could be initially coupled with a traditional fuel like gas with a view to future changes as plant requires replacement. There may be scope for investigating the retrofitting of renewable heat schemes in recent peripheral development, particularly where new business parks are located along side new housing developments so day and night time use loads might be balanced.

New forms of shared heat generation might be coupled with an ‘energy action area’ approach that first set out to ensure energy efficiency measures were in place to reduce the overall amount of generation required. Social acceptance of new and shared forms of heat/energy generation may particularly be encouraged as energy prices continue to escalate. One energy price comparison web site is cited by a community energy project as saying energy bills for the average household will be £5000 p.a. by 2020 6. Some progress has been made in Scotland, for example in Edinburgh through the study ‘Powering Edinburgh into the 21st Century’7 and more directly the Seaton CHP Plant in Aberdeen8 though this is thought again to be conventionally fuelled. There is still though a great deal to be learnt from our other North European neighbours, especially in bringing this form of technology into the mainstream.

In summary: • Further research is needed into combining renewable and conventional fuels in decentralised energy / heat generating schemes and how these can be mainstreamed in urban environments with increasing introduction of renewables as generating plant needs to be replaced.

- What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020? The field of energy generation and transmission is very fragmented in which it seems difficult to identify or adopt a strategic approach. Secondly there appears a reluctance to break down national targets into sectoral, spatial or scales/types of energy generation components which make it hard to judge the success or otherwise of policy and programmes set out to deliver renewable energy. Thirdly it would seem carbon footprinting assessment of options is still very much in its infancy. Rather it seems as though progress is to be determined through market mechanisms in which a multiplicity of producers and technologies compete according to where incentives / constraints exist at any given time.

As a result the development of renewable energy generation, particularly wind farms seems too often to be ad-hoc and opportunistic in which concerns for landscape quality, cultural heritage and even community benefit seem increasingly to suffer. There is a lack of public dimension in setting out a clear locational strategy and in balancing the needs for new forms of energy generation against the other public benefits that the environment brings, quite apart from opportunities for the health and welfare activities our countryside

5 ‘Scottish Housing Condition Survey – Revised Key Findings 2007’ Scottish Government 2007 http://www.scotland.gov.uk/Resource/Doc/1035/0093899.pdf

6 http://www.sustainableblacon.org.uk/

7 http://www.greenpeace.org.uk/files/pdfs/migrated/MultimediaFiles/Live/FullReport/8056.pdf

8 http://www.sustainablecities.org.uk/energy/portfolio/supply-networks/

might offer but particularly in a country where the tourist industry is also so important to local and rural economies.

Development of wind farms in this way also seems to lead to localised improvements to the transmission grid rather than an overall view of how the grid capacity should be improved (and indeed located) to respond to the wide range of generating sources seen as necessary from those on the continent, the increasing attention to marine based technologies and right down to individual building installations for micro-generation. Coupled with this come the connection and transmission charging regimes which perversely at a national level seem to operate against renewables in Scotland and bring considerable burden (both financially and organisationally), where connection is possible, even at a domestic level.

In summary: • There should be a clear national strategy showing how climate change targets are to be addressed through different market sectors, through a hierarchy of spatial locations and scales with prospects for energy efficiency / type of renewable energy generation technologies. • A review should be undertaken of grid connection and transmission charges and how the grid as a whole should be improved to meet the challenges posed by inter-connectivity with other countries, new technologies including compatibility with micro-renewables and need to reduce environmental impacts.

- Is there sufficient action to exploit the potential of micro-renewables? A greater contribution from micro-renewables would appear to offer the basis for a more sustainable future which could help to reduce landscape impacts, better balance rural and urban contributions, reduce transmission losses and bring greater awareness for individuals in terms of their own energy use and expenditure / income – especially when combined with energy efficiency measures. This route may not be attractive to the mainstream producers of power. The new proposals for Feed In Tariffs and Renewable Heat Initiative may eventually produce stronger incentives to install these technologies.

When compared with some other countries in Europe the UK is certainly not making similar progress (e.g. in 2007 less than 300 solar photo-voltaic panel installations in UK, 130,000 in Germany9). The grant programmes that are implemented are usually of short duration, quickly run out of funding and may be technology specific. At least this would appear to show there is interest if funding tends to run out fast but the variability and uncertainty about future programmes does not help a more sustained involvement and investment in micro-renewables which would help to bring prices down, encourage skills development, better manufacturer warranties and acceptance by insurance bodies all helping to increase familiarity and take-up by consumers.

In summary: • There should be better targeted, sustained and co-ordinated programmes to develop the potential of micro-renewables.

- What are the obstacles to cutting energy use? A particular challenge lies in the forecast for an increasing number of smaller households so that while population may increase slowly the demand for houses and power will continue to increase. Even in new house building the levels of emissions reductions required by the Sullivan Report place considerable emphasis on building far more thermally efficient houses and the skills required to achieve a far higher standard of air tightness than even those currently under construction. As remarked above there are limits, particularly in historic properties as owned by the Trust, to introduce energy saving measures. This though needs to be seen against a changing picture of power use, for example in the home from space and water

9 http://www.guardian.co.uk/money/2008/apr/19/householdbills.consumeraffairs2

heating to increasing demand by equipment and the need too for more efficient appliances and intelligent connection systems that can even out power use10. Challenges also lie in encouraging behavioural change and the programme, for example, for smart meter read out devices, a key factor it would seem in helping here, seems to have already taken a long time to be decided and will take an even longer time to get rolled out.

In summary: • The Trust supports the recommendations of the Sullivan Report for phased increases to the thermal performance of buildings through the Building Standards (Scotland) Regulations and associated research programmes investigating their implementation. • Consideration should be given to bringing forward the Sullivan Report recommendations for retrofitting improvements in existing properties with appropriate relaxations for safeguarding the character of historic properties. • Greater urgency should be made in programmes introducing home energy monitoring, installing smart metering and making available smart plugs.

Land use - How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats?

The Government’s “Farming for a Better Climate”11 recommends that farmers concentrate on the following key actions; using energy and fuels efficiently, developing renewable energy, locking carbon into the soil and vegetation, optimising the application of fertiliser and manures and optimising livestock management and storage of waste.

The Trust, as a member of Scottish Environment (SE) LINK, is represented on its Sustainable Land Use Strategy Taskforce helping to inform the Scottish Government duty to prepare this strategy by March 2011. This should be a key vehicle in the search for not just the most efficient but also the most sustainable way land use can address multiple objectives. The Trust has also contributed to SE LINK’s report ‘Living with the Land’12 intended to set out the principles and direction such a strategy should cover.

The Trust is supportive of further effort to support ‘public benefits’ and mixed set of land uses where appropriate and where landscape character, wealth of biodiversity, wetland and peatland restoration are all enhanced. It is important that this strategy becomes the ‘parent’ to a range of current strategies, that it helps integration with and between these and other relevant policy formulation, it covers both urban as well as rural land and is accompanied by a clear statement of procedures governing implementation and monitoring. Equally though it must be properly resourced and supported.

10 ‘Domestic Energy Primer – an Introduction to Energy Efficiency in Existing Homes’ (CE101.GPG171)Energy Savings Trust, 2006 http://www.energysavingtrust.org.uk/Publication-Download/?p=1&pid=249

11 ‘Farming for a Better Climate’ Scottish Agricultural College for the Scottish Government, 2009 at http://www.sac.ac.uk/climatechange/farmingforabetterclimate/fiveactions/

12 ‘Living with the Land’ by J. Mayhew for SE LINK 2009 at http://www.scotlink.org/files/publication/LINKReports/LINKReportLivingwithLand.pdf

At a more direct level in many of those parts of Scotland where carbon storage in peatlands and the maintenance of a particular landscape character is important crofting tenure offers protection through its smaller scale, low intensity, mixed activity and sustainable way of living and land use13.

- What do you see as the major barriers to changing rural land-use activities in this way? Rural land uses are often supported by a range of agencies and complex funding systems, many of which are currently subject to review and potential change. The degree to which a more ambitious and co-ordinated view of land use is enabled either through the development of Scotland’s Sustainable Land Use Strategy14 and through revised funding streams remains to be seen. The Trust is concerned though that at a time when consideration is being given to introducing new directions to improve sustainability in the use of land, and whilst these issues are acknowledged in current reviews on agricultural (‘Inquiry into future support for Agriculture in Scotland - Pack Interim Report15) and rural development(‘Scotland’s Rural development Programme – First Interim Review’ – the Cook Report16) the case for funding support for multiple public benefits and climate change requirements appears to remains a subsidiary rather than a central issue. Again these funding systems appear geared towards larger land owners and not smaller scale operations as practiced for example through crofting tenure.

This also needs to be facilitated by progressing the introduction of ecosystems analysis in to planning on which better informed and sustainable land use decisions can be made and through which we can move more towards ‘living within environmental limits’.

In summary: • The development of Scotland’s Sustainable Land Use Strategy is supported and greater emphasis should be given in rural /agricultural programme reviews to recognition of the Strategy and the resources needed to implement it.

Buildings - What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events? In going forward there must be more attention to the ‘precautionary principle’, for example by avoiding building in flood plains and more attention to sustainable urban drainage techniques, rain water harvesting, use of passive design approaches for solar shading, natural ventilation, green roofs (in Switzerland some cities require all flat roofs to be green roofs), green walls, extended eaves, and better standards of construction with the use of more robust materials to address both thermal performance and extreme events. Experience needs to be fed back into product design, building codes and skills and brought increasingly to bear, through adaptation and extension related work to the whole existing building envelope. One particular issue requiring more consideration following this year’s winter is how to address power failure. Areas may have different types of vulnerability requiring bespoke forms of protection but perhaps in some cases there may not be feasible ways to adapt.

It may be necessary to look at buildings in their context to see ways in which extreme wind patterns or temperatures might be eased by shelterbelts and green spaces, greater protection from heat gain by the introduction of solar shading and from storm / flooding events by permeable ground surface materials. These factors should also inform the design of the public realm through greater protection of green spaces, playing

13 ‘Committe of Inquiry on Crofting – Final Report’ 2008 at http://www.ecology.ethz.ch/education/BE_documents/Crofting_final_report.pdf

14 Land Use Strategy: http://www.scotland.gov.uk/Topics/Environment/Countryside/Landusestrategy 15 http://www.scotland.gov.uk/Topics/farmingrural/Agriculture/inquiry/interim/interim

16 http://www.scotland.gov.uk/Topics/farmingrural/SRDP/SRDPReviews/FirstStageReview/ReviewReport

fields, street trees, and introduction of places to rest and arcades for shelter and shade. Perhaps a degree of mitigation might be introduced by redesigning surroundings to encourage greater walking, cycle and public transport use.

From recent extreme weather events, and rising sea levels, it seems it is also some of our basic infrastructure of power and sewerage stations, transmission systems and transport routes that may need to be the subject of either enhanced protection measures or in the longer term even relocation.

Better building adaptation might be brought about through the Building Standards (Scotland) Regulations (see next) but it would also seem those schemes involving guarantees through insurance regimes might also drive suitable practice. There should also be more promotion of guidance and advice available to building owners on how to include such adaptation measures when considering other alteration, extension or upgrading work. This might include reference to Carbon Trust and Energy Savings Trust publications like their energy efficiency primers or to guidance leaflets as offered by the former Scottish Building Standards Agency like the Home Improvement Sustainability Guide.

In summary: • More attention is needed to good passive techniques like solar shading, reverting to sustainable urban drainage systems, green roofs and improving construction skills and practices • More consideration to using a buildings context for shelterbelts and shading • Checks should be made on the vulnerability of public infrastructure and utilities • Greater efforts at promoting good practice

- How should Government ensure that business/domestic energy efficiency measures are met? A fundamental consideration in the way we build is how to move away from short term capital cost to one of whole life costing. The present financial appraisal system means there is little benefit for developers in increasing initial investment in order to try reducing the consequent ‘building in use’ costs for the eventual occupier. One way to approach this may be through the introduction of a rating system like that for the Code for Sustainable Homes or the BREEAM ‘eco ratings’. These systems recognise benefits from consideration to more efficient long term energy use, less waste and reduced embodied energy of materials helping to involve the whole of the construction chain in greater energy efficiency and reduced emissions. The Code has become mandatory in England, Wales and Northern Ireland for new house building with levels or ratings increases being phased in.

In its response to the Scottish Government consultation on ‘The energy performance of non-domestic buildings’17 in 2009 the Trust noted that the preferred route for such requirements in Scotland is through the Building Standards Regulations. This has similar phasing in of increasing standards though the standards currently are not so wide ranging as the Code or BREEAM. The Scottish approach does aim energy efficiency standards at both domestic and non-domestic property and gives encouragement (at present) to their application to existing buildings undergoing conversion or extension.

‘Guide for Practitioners 6 – Conversion of Traditional Buildings, Application of the Scottish Building Standards’18 by Historic Scotland promotes ‘the need for the adoption of a systematic and holistic approach to the design of systems’ and building envelope improvements (Part 1, page 4). It goes on to state that especially in the case of conversions, but also in the case of alterations, for specific identified standards the

17 Trust response to Scottish Government Consultation ‘Energy Performance in non-domestic buildings’ http://www.nts.org.uk/conserve/downloads/energy_perf_in_non-dom_buildings_resp_1_181108.pdf

18 guide for Practitioners ‘Conversion of Traditional Buildings’ Historic Scotland, 2007 http://www.historic-scotland.gov.uk/conversionoftraditionalbuildings1and2.pdf

existing building is required to be improved ‘as close to the full requirements as is reasonably practical’. The Building Regulations define ‘reasonably practical’ as ‘having regard to all the circumstances including expense involved of carrying out the building work’.

We acknowledge the work done through the Sullivan Report and the Building Standards (Scotland) Regulations as a way of increasing standards at explicit intervals to improve efficiencies. It would appear that there is considerable research being undertaken through Building Standards Division on the effectiveness of implementation in both new build and conversion work with a view to better informing guidance for example on appropriate detailing and choice of low and zero carbon energy generating technologies. We would urge that more progress could be made with developing the agenda set out in the former SBSA publication ‘Sustainable Development Policy into Practice: New Buildings’ from April 2006.

There are also some positive indications from continuing on site research being done by the Trust in coordination with Historic Scotland into the assessment of the performance of traditional constructions. We are also aware of other work on energy efficiency and renewable in historic property being conducted by the Edinburgh World Heritage Trust, the Energy Savings Trust and Changeworks which might benefit from greater promotion.

The Trust is also involved in surveying all its property to establish Energy Performance Certificate (EPC) ratings. In its response to the consultation mentioned on energy performance of non-domestic buildings the Trust supported the Sullivan Committee view for further legislation to introduce statutory duties for more regular assessments of energy performance certification at set timescales and for a requirement that recommendations for improvements be implemented. The latter was supported on the basis that various conditions be introduced, particularly that requirements for implementation be accompanied by financial incentives but also to mitigation in the case of historic buildings to protect their character.

It is worth repeating here some of the Trust’s other comments in relation to the EPC regime. This includes the observation that the Scottish Government’s own consultation on Energy Performance Certificates in an impact analysis estimated a requirement for some 20,000 non-domestic EPCs each year over the early years19. The Guide for Practitioners referred to in the consultation estimated that there are 500,000 pre 1919 traditional buildings in Scotland (page 6). The number of EPCs and improvement projects being delivered by the current support programmes clearly falls far short of the scale required.

Further in a sample, for example, of government buildings a National Audit Office Report20 suggests that 80% of projects in the public estate would not meet the required environmental assessment standards. It reports that the energy performance of the majority of non-domestic buildings completed even in recent years attain only the very lowest G grade on EPC’s. However it goes on to point out that as very few post- occupancy surveys have been carried out ‘it is impossible to judge how we are doing if no one knows what our energy performance is’. This seems a key point if we are to be able to judge how much progress is being made.

The Trust therefore also recommended the introduction of a national electronic database for the recording of EPC’s and/or building performance as an essential tool to understand the size of the challenge that has to be faced. Such a tool would also enable assessments to be made about the relationship between performance and requirements in emissions reduction at a national level and to monitor assessment, upgrading and

19 Regulatory Impact Assessment of the EU Directive 2002/91/EC on the Energy Performance of Buildings – Annex A, Scottish Government 2008 page 11

20 ‘Building for a Better Future : Sustainable Building & Refurbishment’ National Audit Office 2007 page 12 http://www.nao.org.uk/publications/nao_reports/06-07/0607324.pdf

enforcement if improvement is to become a reality at the local level. It is our understanding that the Energy Savings Trust (EST) maintains a register for domestic buildings and so the Trust recommended that a similar register for non-domestic buildings could be maintained by the Carbon Trust.

In summary: • Broad efficiencies across the building industry by encouraging a whole life costing approach might be achieved by the introduction of’eco-ratings or codes for sustainability • The Energy Performance Certification process should be reinforced by the introduction of specific renewal periods and improvement targets • The introduction of registers for all building types is needed to measure progress / identify areas for further action

- What are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act? As recognised above the Trust acknowledges the way these issues were being addressed in the planning and building standard regimes before the Climate Change Act came into law. Rather than obstacles we do see areas that need resolution. One will be in the way the Sustainable Land Use Strategy, raised above, will relate to the National Planning Framework and the development planning system that lies under it. We have also raised the issue of measuring carbon foot prints of development proposals and their impacts on climate change targets.

At a more operational level we also raise the relationship of climate change impact / energy efficiency and renewable energy generation considerations to both the planning and building regulation regimes. Often renewable energy generation in particular may have considerable impact on the appearance and layouts of development and thus be a concern for planning assessment. However traditionally energy requirements have been more the concern of building warrant consideration which occurs at a later stage in the design process. The ability to prepare accurate energy calculations, to support for example the sizing and location of a renewable technology in a planning application, means greater detail design work and the appointment of specialist consultants has to take place at an earlier stage. This work can involve the use of energy modelling through SAP or SBEM calculation tools which can be expensive. Consideration might be given to staged warrants so that the exercise does not have to be gone through in its entirety at the later warrant stage.

In summary: • The establishment of an agreed method of carbon footprinting is needed • An investigation should be made into the possibility of introducing staged building warrants to address the need for early energy assessments.

Transport - How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this? Whilst formal calculations have not as yet been made the Trust is exploring various ways of reducing staff travel by reducing the amount of internal meetings, greater use of video & tele conferencing, trialling home working and remote file sharing.

The Trust also supplies public transport information for members and visitors in Guides to its properties.

Hi,

Here are my comments to the consultation.

Regards

Fergus Murray

- Do you perceive the changing weather patterns in the UK and globally as affecting you and/or your organisation? Yes, climate change is already having an impact on Argyll and Bute through rising sea levels, more intense storm events and associated precipitation giving rise to increasing incidents of landslips, increasing disruption to travel including ferries and flooding events. This is giving rise to increased infrastructure costs and higher maintenance liabilities through damage caused by weather related events such as recent damage to Oban seafront, undermining of roads or the erosion of sand dunes in Tiree. - What are the impacts of the Climate Change Act on the goals and activities of your organisation in terms of investment and exposure to risk? The Council has signed up to a commitment to reduce carbon and is looking to reduce its dependence on fossil fuels to heat its buildings and build modern buildings that can cope with the increasing demands of the climate and the need to conserve energy. This will require considerable capital investment which might not be available due to the current pressure on public expenditure in the public sector - What do you plan to do in response to these factors over the next 5 – 10 years? In terms of planning we have prepared sustainable design guides to encourage the use of renewable energy technologies and site buildings to take advantage of solar gain and shelter from the prevailing wind etc. Our existing local plan’s settlement strategy has focused the majority of new developments in our main and key settlements to help support crucial services and reduce the need to travel. The new LDP aims to go further with the need to reduce our carbon footprint fully integrated into planning policy. Our woodland and forestry strategy also aims to further develop the biomass industry and add value to the timber resource at a local level. - How integrated is your response with other organisations in similar or related fields? We always take a partnership approach through the development of our plans and the use of the community planning partnership. In particular we work closely with SNH, Forestry Commission, Scottish Water and SEPA to focus our resources where it is needed most. - What are the main barriers to change for you and/or your organisation? A genuine lack of money to do the necessary actions and a number of individuals who try and stop change because they do not believe climate change is happening or they feel they can do little to prevent in an affordable manner. The Government need to realise that when targets are established their true implications need to be evaluated and costed where necessary. Budgets also need to be set aside to take necessary actions. Councils cannot be expected to absorb costs or enforce standards that are unaffordable to many. This will simply stop development with the resultant impact on our economy and local communities. - What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes? Fine if the income raised can be directed to organisations working at a local level and not simply divided up nationally based on population. Energy generation - What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure? Impacts on the landscape, settlements and our outstanding tourism assets. This is already happening causing planning blight and deterring future investment. Also the cost of renewable energy and the necessary government subsidies to make it happen has not impacted on local people yet. When it happens there may be growing resistance to renewable energy infrastructure which has happened in countries such as Denmark. People might also become resentful when we cannot spend money on things like roads, schools, community centres, leisure facilities and affordable housing and yet the government can find funds to subsidise the renewable energy industry. - How do you see more buildings being heated by renewable heat technologies by 2020? The growth of CHP schemes has to happen more whether it is through burning waste or through biomass or gas plants - What are the institutional, organisational and financial barriers to meeting the renewable energy targets by 2020? I think it will be done to money at the end of the day - Is there sufficient action to exploit the potential of microrenewables? Yes, but will it really make a difference. It is very expensive at the moment with poor returns. Better to save energy through insulation and the better siting of new buildings - What are the obstacles to cutting energy use? It should be better built in to building standards and again its down to finances and political will at a local level to impose higher costs on local people when others are not going down the same path.

Buildings - What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events? It is going to be very difficult and expensive. I am concerned the building industry does not have the necessary skills to do the work in the first place. We need to think about water recycling, the introduction of grey water systems, alternatives to the flush toilet, better rainwater goods that can cope with extreme events. Flood proofing of buildings or even the removal of buildings from flood plains or some coastal areas. Better ways of providing outer and inner wall insulation would be good as would more planting and green space to cope with warmer summers. Single glazing may need to be banned, even in historic properties, so to uvpc windows made from oil based products. Driveways could be constructed with permeable materials to allow water to drain away. The list is pretty endless. - How should Government ensure that business/domestic energy efficiency measures are met? Through higher building standards and codes to tackle things like shops leaving their front doors open and temperatures maintained at over 80 degrees etc - What are the obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act? All of the above points

Transport - How could your organisation’s transport emissions be cut by 2020, and what are the barriers to achieving this? Money is the main barrier; It could be done by requiring all public sector organisations to undertake green transport plans and site new buildings where people can actually walk to rather than taking the car. Public transport needs to be catered for and car park spaces reduced. All of these are very difficult for rural authorities and costly.

The Viscount and Viscountess Monckton of Brenchley, The Carie Estate and Monckton Enterprises Limited

To The Royal Society of Edinburgh

The intractable non-problem of climate change

Gentlemen, œ In this joint submission, made in January 2010, two individuals and two organizations have the honour to answer the questions that you have posed about the State‘s grandiose policy of attempting to intervene in the evolution of the complex, non-linear object that is the terrestrial climate. Our advice to you is that the policies you advocate would be unbearably costly, damaging and futile. You will not succeed where Canute failed.

‹ Do changing weather patterns affect you or your organization?

No. After 300 years‘ largely natural warming, it is unsurprising that recent years have been warmer than average. In 50 years the weather is as likely to be cooler than the present as it is to be warmer, according to an eminent Professor of Meteorology whom we have consulted.

‹ How will the Climate Change Acts affect your investment and risk exposure, and how will you respond over the next 5-10 years?

The Scottish Act‘s target of reducing emissions in ten years by 42% compared with 1990 (i.e. ~60% compared with today) is naive as well as pointless. If the State makes any serious attempt to implement the target, we and thousands of similar businesses will leave Scotland.

‹ W hat are the main barriers to change for your organisation?

There is no need for any change. The science behind the notion of catastrophic —global warming“ is politicized, rent-seeking, wrong and, in some aspects, fraudulent. Even the UN‘s climate panel concedes that our effect on climate before 1950 was negligible. The only warming since 1950 occurred in the 1980s and ‘90s, with no warming since. Yet the rate of warming in those two decades was no greater than it was from 1860-1880 or 1910-1940. Therefore, there is no anthropogenic signal in the temperature record. In the two warming decades that we might in theory have influenced, the radiative forcing from reduced low- latitude, low-altitude, high-optical-density cloud cover was ~4.5 W mœ2, more than five and a half times the ~0.8 W mœ2 attributed by the IPCC to CO2 over the period. Therefore, the IPCC‘s central conclusion that, with 90% confidence, more than half the warming since 1950 was anthropogenic is untenable. Humankind‘s influence on the climate is minuscule.

However, ad argumentum and per impossibile, let us pretend that the IPCC‘s imagined high-end warming from a proportionate increase in CO2 concentration might in reality occur. And let us generously assume that all Western countries, on average, offer to reduce emissions by 30% compared with 1990 (50% compared with today) by 2020, cumulatively achieving 5%/year. Then the average Western reduction over the 10-year period would be 25% compared with today œ i.e. some 12.5% of global emissions. Let us also pretend that these cuts are actually achieved, as they were not after Kyoto (global emissions now are 40% above 1990 levels). The IPCC implausibly assumes that CO2 lingers in the atmosphere for hundreds of years before equilibrium is restored (the overwhelming consensus in the literature is an atmospheric residence-time of just ~7 years). However, we shall pretend that on this, too, the IPCC is right and the consensus wrong. On its analysis, the effect of a 100% emissions cut would be merely to stabilize CO2 concentration at today‘s 390 ppmv, rather than adding 2 ppmv/year (20 ppmv/decade) as now. So we should achieve a 12.5% reduction in the 20 ppmv CO2 concentration increase that would occur without any cuts. By 2020, instead of 410 ppmv, there would be 407.5 ppmv in the atmosphere. Thereby the West would forestall, at most, 5.7 ln(410/407.5) = 0.035 C° of global warming, and at a cost of trillions.

Accordingly, the main —barrier to change“ that our analysts see (and they are the best in the business) is the manifest cost-ineffectiveness of this or any attempted mitigation of carbon emissions. Adaptation to climate change as and if necessary would be orders of magnitude cheaper than attempted mitigation. Furthermore, the environmental penalty for doing absolutely nothing for the next ten years, at a tad over 1/29 of a Celsius degree, is vanishingly close to zero. It would œ on any view œ be better to wait and see whether global mean surface temperatures start to rise as the IPCC predicts. It has already had to reduce its —global warming“ estimates twice in a row. There are plenty of real environmental and social problems to spend the trillions on instead. For the past decade and a half there has been no statistically-significant —global warming“. For the past nine full years there has been rapid and statistically-significant global cooling. Thanks to three wet summers and three cold winters in a row, none of them predicted by the catastrophist Met Office, the prolonged absence of any —global warming“ can no longer be concealed from the people. Let us save our trillions for better purposes while we wait and see whether and at what rate, if at all, the —global warming“ that has been absent in the past decade and more resumes in the next.

‹ W hat are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

Scotland represents ~0.2% of global carbon emissions. Therefore, if Scotland were to do nothing for ten years except wait and see, the warming that we should otherwise have forestalled would be 0.2% of 0.035 C°, or 0.00007 C°. Call it zero. So there is no merit whatsoever in carbon taxes, emissions trading, energy regulations to curb emissions or incentive schemes (which have to be paid for by taxes anyway, plus the usual burdensome overhead for all those bureaucrats). The correct policy response to the non-problem of —global warming“ is to have the courage to do nothing. We challenge you to try that.

‹ W hat do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure?

Over the past half-century our estate and many others in Rannoch and Tummel have been damaged by the gross, insensitive, environmentally-illiterate, large-scale, late-1940s hydropower schemes on the Ericht-Ba-Laidoch-Eigeach-Gaur-Rannoch-Tummel-Garry-Tay river system. The fish-ladders are all in the wrong place. With the dour dam at Falls of Gaur, they have destroyed what was once the longest and most beautiful migratory system for salmon in Britain. Micro-hydro schemes would be less damaging but less profitable. Wind-farms are not welcome in the Highlands because of the very grave threat they pose to rare birds such as the ospreys that breed in these parts. Also, wind-farms typically deliver only one-sixth of rated capacity, are a monstrous blot on the fragile and beautiful landscape of Scotland, cannot survive without continuous subsidy, and do not work at all when the wind is not blowing or when it is blowing a gale. Solar power, at its present stage of development, is not viable in Scotland. For these reasons, there is and will always be very little acceptance of the waste of taxpayers‘ money that —investments“ in renewable energy would engender.

‹ How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020?

Childish and unrealistic target-setting of this kind has its origins in the Five-Year and Ten- Year Plans of the hated and now defunct Soviet Communist system. Resistance to soi-disant —renewable“ technologies will continue to stiffen in Scotland as their cost, unreliability and damaging environmental footprint come to be better understood.

‹ W hat are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020?

The insuperable institutional barrier to Soviet-era targets of this kind is that the institutions setting such targets are run by people most of whom lack any understanding of science or economics and are, therefore, credulous and easily manipulated by powerful vested interests. However, the people are rapidly learning that they cannot trust Scotland‘s financial, political, journalistic, scientific, academic or commercial institutions to tell them the truth about the climate. It is now known that too many in the classe politique are personally as well as corporately profiteering from the —global warming“ scam at the expense of taxpayers and working people generally. This profiteering is increasingly resented, and will not long be tolerated or permitted by the people.

‹ Is there sufficient action to exploit the potential of micro-renewables?

In general, micro-renewable energy œ while less environmentally devastating than giant windmills hundreds of feet high or vast, dreary dams hundreds of feet across that dislocate river systems for miles either side of them œ is even less economically viable than they are. Leading institutions such as the Royal Society of Edinburgh must learn that, in the coming years of extreme austerity after the recent Socialist binge at taxpayers‘ expense, funding of fashionable but absurdly uneconomic ventures and —picking of winners“ by the State will prove not only politically unacceptable but financially unaffordable. The money has gone.

‹ W hat are the obstacles to cutting energy use?

Increasing cold weather in recent winters has proven to be a major obstacle to cutting energy use. The chief obstacle, however, is the desire of humankind to become more prosperous by the establishment of industries and enterprises that, by their nature, consume energy both in manufacture and in vecture. Humankind, being communuataire, also enjoys travelling, which again consumes energy. Short of a widespread reintroduction of monasticism, the only workable way to remove obstacles to reducing energy use is via the price mechanism. However, as the current US administration is discovering, State-mandated increases in energy prices fall disproportionately upon the poorest, who spend a greater proportion of their incomes on energy than those who are wealthier. Attempts by the State to subsidize the poorest to mitigate the worst effects of artificially-increased energy prices are doomed to fail, because every penny spent on such subsidies reduces the disincentive influence of the energy-price increase, as well as introducing unacceptable economic distortions at every level. It would be better for the dribblers and dabblers not to meddle. Drop it, Fido.

‹ How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats?

On any view, there is no need whatsoever to reduce carbon emissions. True science has long moved on from that notion. Once again, the teetotal totalitarians who have been slavering at the prospect of micro-managing every aspect of people‘s lives and every square inch of Scotland‘s —wee bit hill and glen“ must learn to stand back and leave well alone. This particular scam for increasing the power and reach of the State has failed. Move along.

‹ W hat do you see as the major barriers to changing rural land-use activities in this way?

The major barrier to interference in our uses of rural land is the unacceptability and extravagant cost of State-imposed measures intended, however piously, to address the non- problem that is the climate. In the Highlands and Islands of Scotland, there is already a movement afoot to throw off the hated yoke of Edinburgh, with its constant meddling and its serial failure to prevent the continuing loss of essential services in rural and mountainous regions. The Kingdom of Alba is heading for outright independence from the Central Belt. Any further attempts by the State to inflict otiose circumscriptions on the people‘s freedom in the specious name of —Saving The Planet“ will be firmly resisted.

‹ W hat is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

There is not the slightest evidence that extreme-weather events will become more frequent if and when the 300 years‘ recovery of temperature from the Little Ice Age that reached its nadir at the Maunder Minimum resumes after 15 years without warming. It is settled science, conceded even by the IPCC (admittedly not the soundest of authorities), that temperature differentials will tend to diminish if the climate warms, leading œ outside the tropics, at any rate œ to a general reduction in the incidence of extreme-weather events. As recent winters have demonstrated, cold is a far bigger killer than heat. Therefore, the increased availability of fossil-fuelled energy œ the cheapest available for as long as the State resists the temptation to interfere œ will do more than anything else to provide affordable heating to prevent old and vulnerable people from being killed by the cold.

‹ How should Government ensure that business/domestic energy efficiency measures are met?

Energy prices are likely to rise in accordance with the law of supply and demand, irrespective of any Government interference. The market, therefore, will provide any necessary incentives to minimize energy consumption by efficiency measures, via the price mechanism. Etatiste dirigisme in this field cannot contribute anything useful. Don‘t do it.

‹ W hat are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act?

The measures envisaged in the Climate Change Act are mad. The more obstacles, the better.

‹ How could your organisation‘s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

We are currently working with a professor of fuel chemistry œ though not in Scotland, where innovation is taxed as no longer welcome œ on the development of two new fuels, either of which will allow savings of ~30% by 2020 if the current research pathway is followed. One of the two fuels will work in unmodified automobiles made since 2000, and will also greatly reduce particulate emissions œ the only form of fuel pollution that matters. Carbon dioxide emissions are of course harmless and beneficial: a doubling of atmospheric CO2 concentration, which would still leave it at half the level which has prevailed throughout nearly all of the past 600 million years, would help to end the CO2 starvation of the past few million years and increase yields of some staple crops by up to 40%, and of all trees and plants by similarly significant percentages. Now that it is known by measurement that anthropogenic increases in CO2 concentration are only a bit-part player in the climate, the costly, dim, futile demonization of CO2 by climate racketeers must end.

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My concern is the lack of a coherent strategy to achieve modal shift to more sustainable methods of transport and the conflicting messages given out by government. The first example, which I was allowed to give, is the removal of the bridge tolls over the Forth and the Tay, noting that while the cost of private motoring had been cut there was no corresponding reduction in the cost of public transport across the Firths, not even a token cut in the bus fares. As far as I recall there was no pressure, not even a polite request, from the Scottish Government or Transport Scotland for the bus and rail companies to do so. Therefore the balance between private and public transport was tipped in favour of the former, with no overarching strategy to even attempt to re-balance it. I suggest this is no way to encourage people to switch from cars to public transport.

My second example is the fact that it is more cost-effective for residents of Dundee and its surrounding travelling south by rail to drive the 7 or 8 miles to Leuchars Station to begin their journey than to use their nearest station at Dundee. This is because car-parking at Leuchars is free, while in central Dundee it is not, and there is a significant difference between the cost of the rail fares from Dundee and from Leuchars. Even before the removal of the Tay Road Bridge tolls, canny Dundonians were doing this. Where is the overall strategy to remove this anomaly so that driving to a more distant station is not more cost-effective than driving to the nearest?

The third point is the fact that there are places which are very popular destinations but are only accessible by road, St Andrews being the obvious example. Here you have a major tourist centre, Scotland's oldest university and the Home of Golf, as well as an employment destination, with more people commuting in than commuting out, and as a result of its being 6 miles from the nearest railway station, is swamped with cars. It is well-known that rail is the form of public transport most likely to get drivers out of cars, certainly much more so than buses. As the A91 between Cupar and St Andrews is the busiest road in north-east Fife, a railway would not only benefit St Andrews but also Cupar, on the route of all St Andrews-bound cars, and the smaller settlements of Dairsie and Guardbridge. Yet Fife Council's solution appears to be a bypass for Cupar, which is certain to generate more traffic along the A91, and vague comments about public transport enhancements between Leuchars and St Andrews. The Scottish Government, for its part, believed that a 'virtual branch line' was all that was required. This turned out to be putting the bus times into the rail timetable (though inexplicably not the only real connecting service which meets the last train from Edinburgh), selling railway tickets at the St Andrews bus station and some extra electronic signs showing the published bus times, but not real-time information. You can buy a joint bus and rail ticket to and from St Andrews to wherever, but it is no cheaper than buying them separately, and there is little if any time saved. Also the 'virtual branch line' was to be operated by existing bus services, i.e. no extra capacity. As far as I can see there has not been a significant switch from car to bus between St Andrews and Leuchars and, indeed, a senior Stagecoach officer has said that 'no sane person' wishing to travel from St Andrews to catch a train at Leuchars, would use a bus if they had the option of driving!

The lack of a coherent strategy to encourage the switch to public transport is demonstrated again by Fife Council's proposals to increase Leuchars car-park by 100 spaces. I understand that this was at the behest of Dundee City Council, who wished to alleviate traffic congestion in Dundee city centre (strange that it was stated at the meeting at Thursday that Dundee's city centre traffic had stabilised). It was stated that this was to make it easier for North East Fife commuters to Dundee, so that they could park at Leuchars and take the train to Dundee, and driving only 5 or 6 miles each way rather than 13 all the way to Dundee. Yet the cost of the rail ticket is at least as much if not more than the cost of parking in Dundee! In any case, hardly any St Andrews drivers (and the strategy must be aimed at St Andrews, as Tayport and Newport drivers, within sight of Dundee, are hardly likely to drive south to Leuchars) want to break their journey nearly halfway to Dundee and change to a train. What is far more likely to happen is that 100 more canny Dundonians as mentioned before will drive the extra 7 or 8 miles each way and fill the spaces. This is where there are conflicting messages; firstly, use the 'virtual branch line' (i.e. bus) to get to Leuchars, secondly, we are providing more car-parking so you can use your car! The result is likely to be more car miles, not fewer.

School of Psychology ______Dean Professor Trevor Harley

Dr Marc Rands, The Royal Society of Edinburgh, 22-26 George Street, Edinburgh EH2 2PQ 26 april,2010

Dear Marc

Appended please find my submission in response to the inquiry “facing up to climate change.” Could you please let me know if you need hard copy as well.

With all best wishes,

Alan Kennedy FRSE

Senior Research Fellow, University of Dundee; Research Associate, Laboratoire de Psychologie et Neurosciences Cognitives, Université Paris-Descartes.

Coll ege of Art and Social Sciences UNIVERSITY OF DUNDEE Dun dee DD1 4HN Scotland UK t +44(0)1382 384622/3 f +44 (0) 1382 229993 e [email protected] www.dundee.ac.uk/psychology The University of Dundee is a Scottish Registered Charity, No. SC015096

Facing up to Climate Change?

Shortly after the Society set up its Inquiry into the public response to global warming I wrote to the President expressing some disquiet: “…first, there are well-documented reasons for doubting some of the claims made in the Briefing Paper with regard to anthropogenic global warming. Second, the composition of the committee appears to contain only two Fellows of the Society and a membership drawn from the social, rather than the physical, sciences. Finally, I very much regret the tendentious style of the title “facing up to climate change.” This sounds more like a campaigning slogan than a scientific endeavour. The implication is that there is something to face up to; that we can do something about it; and that we are not addressing the issue: all three claims are questionable, or are, at least, worth questioning by members of a serious Scientific Academy.”

The President was kind enough to reply, inviting me to justify my comments. This submission is an attempt to do that.

The composition of the Committee

Notwithstanding the fact that the Chairman and his deputy are both Fellows, I am still perplexed that the whole composition of the committee was not drawn from the Fellowship and, in particular, from among those Fellows competent to assess the merits of a highly technical research field. Surely the whole purpose of the Royal Society is called into question if it is thought that the Fellowship cannot supply enough experts to deliberate on an issue of this importance. Obviously, informed and interested outsiders can be co-opted, but Fellows are elected with an obligation to involve themselves in the work of the Society. More to the point, the Fellowship has a formidable range of expertise. It was an unhappy decision.

The Briefing Paper

On Page 2 of the document we find the key claim:

“...a warming trend for the last 100 years and averaged over the last 30 years, has changed at a rate that is faster than at any time since the end of the last Ice Age, 10,000 years ago…”

I can find little or no evidence that the rate of change is changing (i.e. that the trend is accelerating). Such a claim rests in part on analyses involving undisputed statistical errors (first pointed out in the peer-reviewed literature by McIntyre & McKitrick in the late 90s). Otherwise it rests on the use of temperature proxies that have repeatedly been shown to be inappropriate or misleading (see The Wegman Report, 2006). Indeed, the term “hockey-stick” has become a metaphor in the public mind for manipulated science, even among people who have no idea of the basis of the manipulations involved. It is extremely unfortunate that this briefing paper has its own example.

Also on Page 2, there are a number of more specific claims. For example,

“The dramatic trend of reduction in the extent of arctic ocean sea ice, increased melting of the Greenland Ice Sheet, and strong warming in the near-Arctic zones are a reflection of this; the decade 2000 –2009 has been warmer on average than any in the preceding 150 years of instrumental observations…all major glacier systems worldwide are retreating and global sea levels are rising, both at an accelerating rate…this year’s unusually destructive typhoon season in South East Asia, whilst not easy to attribute directly to climate change, illustrates the vulnerabilities to such events…The transfer of water to the oceans from melting glaciers coupled with thermal expansion of the oceans could result, in worst case, of a global sea level rise of up to 2m by 2100…”

A member of the public would be justified in feeling alarmed by all this. But the scientific basis for these claims is far from settled. The current state of the sea ice in the arctic is not unprecedented: it had retreated further in the 1920s, before the recent up-surge in CO2 emissions. With regard to the “the warmest decade,” a single ten- year sample extracted from a system in a state of dynamic flux with underlying cyclical changes involving periods counted in hundreds, if not thousands, of years is unconvincing (see Taylor’s recent book, Chill: A reassessment of global warming theory for an expanded treatment of this point and a radically different conclusion from that presented in the briefing paper). As the whole world now knows, glaciers are not retreating at an accelerating rate. Neither is there any evidence of an accelerating rise in sea levels. Reference to typhoons is to confuse weather and climate and since whoever drafted the document clearly knew this, it would have been wise not to include the statement at all.

Polemical publications in matters of opinion are useful ways of keeping an issue alive. And were the topic of climate change a purely political question (i.e. a shorthand for “environmental concern”), this briefing paper could simply be left to fight its corner as one among many presenting a plausible case for social and economic change to protect the environment. What concerns me is that the paper, in tone and style, dresses its case up in the language of serious science. Worse, it then shelters the case that the science is settled under an umbrella provided by The Royal Society of Edinburgh. Surely the Society should not be seen as a campaigning political organization? Its only source of authority is serious scholarship. Serious scholarship is typically cautious and sensitive to all sides of an argument. Frankly, I am dubious whether this document meets that criterion.

The scientific case (around Page 8) discusses greenhouse gases. Fourier, Tyndall, Arrhenius and others are invariably cited by proponents of the theory of man-induced global warming. As here, the argument generally put is that it was these men who showed the role played by carbon dioxide in producing a greenhouse effect. Quite so; but the argument then becomes fallacious: the fallacy goes, hence the science of climate change is settled. But Gerlich and Tscheuschner (2009) are only the most recent to point out to proceed along these lines has had very unfortunate consequences. It has bequeathed to the public a potent, but entirely inappropriate metaphor, characterizing the atmosphere as a “heat trap” or “blanket”. It is noticeable that the briefing paper does little or nothing to dispel this potent myth, albeit it is possibly the most important “public understanding of science” message to convey (among climate scientists, Richard Lindzen has an exemplary record in this regard). It is hard to avoid the conclusion that this reluctance relates to the fact that the notion of a “heat-trap” fits readily with a narrative of “accelerating trends”, “tipping points” and run-away positive feedback. The truth draws less on the notion of imminent catastrophe and more on the obvious fact that an immeasurably ancient atmosphere acts as a self-calibrating system containing largely negative sources of feedback. The planet itself is, quite literally, an existence proof on this score.

Nonetheless, to clinch the Armageddon argument yet another hockey stick figure is presented (Figure 3). The briefing paper makes two claims about this: (1) “this is independent of the University of East Anglia reconstruction, about which there has

recently been much controversy”; and (2) it shows late 20th Century warming to have been rapid and large compared with earlier periods. I am puzzled by the first claim. If the many submissions to the “Climate Audit” website are correct, the paper in question is a reconstruction making use of exactly the same (questionable) tree-ring series used by Professor Mann, the author of the original hockey stick. I am not in a position to verify this, but it would be worrying if it were true because other claims about independent verification have proved similarly controversial. Setting this point aside, I believe Hegerl et al 2007 to be the paper discussed by A. W. Montford on page 323 of his recent book The Hockey Stick Illusion. If so, and if his comments are correct, publication and presentation of the paper involved considerable discussion and correspondence among members of the relatively small group of climate scientists surrounding Professor Mann. A group that certainly includes researchers at the University of East Anglia. A group, incidentally, described in the Wegman Report in the following terms:

“…this group has a self-reinforcing feedback mechanism and, moreover, the work has been sufficiently politicized that they can hardly reassess their public positions without losing credibility…”

A personal opinion, but this seems to me to stretch the concept of “independent.”

Much more important is (2). Do these data really show rapid late 20th Century warming compared with earlier periods? Anyone who takes the trouble to read the available literature must surely conclude that the case hangs on a thread. Not only is there considerable doubt on the accuracy (or even validity) of the temperature proxies employed, there is strong evidence that the planet was warmer, or as warm, in the 13th Century, obviously without triggering run-away catastrophe.

Computer Modelling

I have spent a good part of my professional life working with statistical and computational models. I have been on both sides of the argument “models vs laboratory experiments” and have published on the topic. Some of my experience is relevant to the present debate. First, the statistical means for comparing the fit of different models to a given data set are often much weaker than the statistical under-

pinning of the models themselves. To outsiders it may appear a scandal, but it is not at all unusual for instantiations of models with radically different architectures to fit the same data set equally well. It then becomes fruitless to arbitrate on the science by appeal to models alone; observation and experimentation become essential A very considerable degree of caution and humility is called for when drawing conclusions based on an examination of models alone. A second, and certainly related, point is that without a good understanding of the underlying mechanisms in the real world, constructing statistical models is at best perilous and at worst a complete waste of time. Unless you know what is going on, do not expect a statistical model to tell you. This problem appears to be particularly severe in the domain of climate science because aspects of the underlying physics present problems that appear insoluble, at least with present means.

“It cannot be overemphasized that even if these equations are simplified considerably, one cannot determine numerical solutions, even for small space regions and even for small time intervals. This situation will not change in the next 1000 years regardless of the progress made in computer hardware…As the extremely simplified one-fluid equations are unsolvable, the many-fluid equations would be more unsolvable, the equations that include the averaged equations describing the turbulence would be still more unsolvable, if “unsolvable" had a comparative.”

Gerlich & Tscheuschner (2009)

I have two somewhat less elevated comments to make. First, in statistical modelling it is a cardinal sin to look for effects, for you are pretty well bound to find them. This has been one rather neglected aspect of the Climategate affair: email exchanges showing a group of deeply committed scientists poring over data sets, actively searching for an elusive “anthropogenic signal”. Second, when the data are noisy and the modelling involves approximations, there is an almost irresistible tendency to select, and to present best cases. The scientific justification (I will ignore the so- called “post-normal science” account) is that the story becomes more coherent that way, when scientists are faced with political pressure to explain and disseminate their work to non-scientists. One cannot but sympathise with someone working in a field where the outcomes are of such critical social and political significance. But cherry- picking for the sake of a good story, however understandable, is always deeply reprehensible. It should be resisted. It is barely a step away from actually adjusting

the data to fit a particular view of the world. The remedy is obvious: there is an urgent need for others to have access to raw data underlying the surface temperature record. The more significant the social and economic implications of the work, the more imperative this becomes and the more inexcusable it would be if raw data were no longer available. Finally, I note the briefing paper refers to “experiments” involving models. I think the term is best reserved for empirical measurement and hypothesis testing. There are great risks in substituting parameter-setting in a modelling exercise for actual measurement in the real world.

The political context

The current hysteria about global warming is an uncanny echo of similar hysteria in the 1970s concerning global cooling. At that time, concerned scientists petitioned President Nixon to take action to stave off an imminent catastrophe involving “substantially lowered food production; changed rain distribution; increased frequency and amplitude of extreme weather anomalies such as those bringing floods, snowstorms, killing frosts…” Looking back, mania of this kind has its comic side. It can also undoubtedly have more sinister aspects (see Vaclav Klaus, Blue Planet in Green Shackles, 2008). Mass hysteria has been studied by psychologists for many years, starting with Festinger’s classic work When Prophesy Fails (1956). This dealt with a group of flying-saucer believers who had (rather unwisely) set a date for the end of the world. What Festinger showed was that when dearly-held beliefs are disconfirmed, far from the believers giving up and going home, they re-double their efforts to recruit converts and become even more vociferous in defence of a discredited creed. Adherents to the theory of man-made global warming, faced with reasonable, even plausible, challenges to their orthodoxy should not similarly close ranks. Sadly, there are already signs that this is happening, with grandiose appeals to authority and sometimes rather unpleasant abuse of nay-sayers. Any disinterested person reading the many books and papers that have appeared in the past two years on this topic would inevitably conclude that the science is far from settled. Assertions to the contrary simply generate suspicion in a domain that has already become excessively politicized.

Response by Grampian Regional Forestry Forum to the RSE Inquiry into Facing Up to Climate Change Note: This response will appear on the RSE website.

Priscilla Gordon-Duff, Chairman

13th April 2010

The RSE 22-26 George Street Edinburgh EH 2 2PQ [email protected]

Dear Dr. Rands

Response by Grampian Regional Forestry Forum to the RSE Inquiry into Facing up to Climate Change

The members of the Grampian Regional Forestry Forum welcome the opportunity to respond to the Inquiry. Please find our response below.

‘The scale and urgency of these challenges (posed by climate change) are such that they require to be driven at the institutional level, and cannot be left to the actions of individuals.

‘Considerable regional variations can be expected.’

(The Read Report 2009)

- Change:The Forum perceives the effect of changing weather patterns in Scotland and globally and believes it has an important role to play in responding to the changes in the Grampian region. The Read Report identifies summer drought as posing the most immediate threat to the UK’s trees – increased frequency and severity of summer droughts has been forecast specifically for Grampian. - Investment and Risk: The Forum aims to disseminate relevant and accurate information and forecasts from both FCS, from Forest Research and from other Land Use research bodies such as the Macaulay Institute. This will help individual organisations across Grampian to make informed management decisions. - Response: The Forum intends to work closely with stakeholders to develop effective partnerships and increase resilience in all sectors. - Integrated Response: The Forum works with the FCS team to monitor and develop the Grampian Regional Implementation Plans as part of the delivery of the Scottish Forestry Strategy targets. An annual regional stakeholder meeting contributes to the development of the Implementation Plan. The membership of the Forum represents the economic, environmental and social aspects of sustainable development within Grampian, contributing to effective links with different sectors, organisations and agencies. A sub group has been formed to develop the Forum’s communication on climate change and all members will have had the opportunity to comment on this response. - Barriers: The barriers to change will be the same as for any organisation faced with change: competition for resources at all levels, conflicting information, inertia, the long term nature of the effects of some changes, complex messages, perceived or actual lack of guidance and support. - Opportunities: The Forum aims to give clear information on incentives that are available and to find ways eg Case Studies, Demonstration Days of enabling individuals and organisations to access good information.

Actions within Grampian Conservancy to be supported by the Forum in 2010 to 2011 include:

∑ Quantifying forests’ role in flood alleviation and mitigation ∑ Quantifying forests’ role in carbon accounting for a farm business ∑ Illustrating woodlands’ positive impact on local environment in the urban sector. ( Dapple shade, shelter etc) ∑ Consideration of holding small scale harvesting demonstrations. Incorporating the role of sole traders/co-operative working ∑ Identify priority stakeholders eg the local authorities, land managers and owners and the forest industry and provide accurate information ∑ Promoting the use of home-grown timber in construction ∑ Promoting a sustainable wood fuel supply ∑ Actively participate in the Scottish Government Land Use Strategy Consultation process ∑ Work closely with the FCS Communications Officer to improve and develop our communication on Climate Change ∑ Hold the Annual Implementation Plan Stakeholder Meeting

The actions agreed at the Forum level will include: ∑ Exchange of information within the Forum including contacts, details of seminars, research by other organisations. Work towards meeting some of the 10:10 targets including: ∑ considering most suitable locations for meetings ∑ encouraging co-operation and sharing of transport to reduce the Forum’s carbon footprint. ∑ supporting local business in the choice of meeting venues and catering. ∑ Distributing copies of the Synthesis Report on ‘ Combating Climate Change – A role for UK forests’ to the Forum Members

The Forum wishes the RSE every success with this Inquiry Yours sincerely PGD – Chairman, GRFF

Royal Society of Edinburgh - Inquiry into Facing up to Climate Change

Glasgow City Council welcomes this inquiry and has responded to all the relevant questions that have been asked. We have also tried, as far as possible, for the brevity in response that has been requested. A consequence of this is more limited responses than we would like but if anything is unclear or you require further details then this is available.

Q1 – Do you perceive the change in weather patterns in Scotland and globally as affecting you and/ or your organisation? Changing weather patterns currently affect our organisation, the individuals it employs and the communities it serves. This has become more apparent in the last decade, e.g. more severe flooding from heavier and more frequent rainfall. Air Quality has also been affected. Glasgow’s recent Local Climates Impact Programme (LCLIP) assessment supports this view.

Q2 – What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? Glasgow, as Scotland’s largest local authority and city, will play its part in tackling climate change and contribute to achieving the ambitious targets set by the Climate Change (Scotland) Act. For this reason, many of the proposed actions in our forthcoming Climate Change Strategy are intended not only to change the way that the Council operates but also to assist residents, communities, businesses and others to make the changes that are required.

Section 65 of the Climate Change (Scotland) Act places a duty on local authorities to establish energy efficiency discount schemes. Glasgow is investigating best practice in this matter and seeking to design a scheme that will effectively encourage the uptake of energy efficiency measures and the best possible offer to the communities it serves.

Section 44 of the Climate Change (Scotland) Act places duties on public bodies relating to climate change. The duties, which come into force on 1 January 2011, require that a public body must, in exercising its functions, act:

• in the way best calculated to contribute to delivery of the Act's emissions reduction targets;

• in the way best calculated to deliver any statutory adaptation programme; and

• in a way that it considers most sustainable.

As the government develops further guidance on these new duties, the council will make the necessary arrangements to both ensure compliance with these and become more climate responsive.

A consultation on the draft statutory guidance will take place in March 2010, prior to the public bodies’ duty entering into force, and the council intends to play an active part in this.

Our investment, which considers the main areas of exposure to risk (heavy rain, flooding and high winds), has to date focussed on SUDS schemes and the Glasgow Strategic Drainage Plan, Local Housing Strategy, improved waste facilities and recycling, air quality action plans, preserving our biodiversity, implementing its carbon management programme, which includes promoting renewables and energy efficiency, non-car transport and preparing for the forthcoming Carbon Reduction Commitment challenges.

The City Plan 2 has also introduced new or amended policies in respect of sustainable design and construction, waste treatment and recycling, energy, flood prevention and land drainage.

Glasgow City Council continues to establish and implement policies which ensure our approach to the Single Outcome Agreement (SOA) with the Scottish Government helps deliver improved services which provide benefits and opportunities for the city and its citizens.

In terms of climate change, National Outcome 14 “We reduce the local and global environmental impact of our consumption and production” sets out Scotland’s response to facing environmental pressures by promoting measures which will result in a sustainable way of life”.

There is a strong history of partnership working in the City and the Glasgow Community Planning Partnership is committed to working together to meet the significant challenges and barriers ahead through its Community Plan. This joint approach is also evident in how the various parties agreed to work together as the Glasgow Climate Change Partnership with the aim of achieving significant carbon reductions across the city.

Q3 – What do you plan to do in response to these factors over the next 5 – 10 years? GCC is developing a Climate Change Strategy, which outlines how the Council has acted, how they are acting and how they will act in the future to respond to these factors and challenges resulting from climate change.

The Strategy will tackle the impacts of a changing climate on Glasgow and includes mitigation and adaptation. It sets out the strategic measures and actions planned by Glasgow City Council to address the serious challenges the organisation faces as a result of global warming both now, and in the future. Although the main initial focus of this document relates to the services and activities of the organisation, it is clear that the Council must also adopt a leadership role in helping the City to deal with what the Scottish Government considers is one of the most serious threats facing the world.

“Climate Change will have enormous and complex social, political, economic and ecological impacts”, (Stockholm Environmental Institute, 1992). To respond to that complexity, this strategy and action plan has considered nine key themes. These are Education & Awareness, Energy, Waste, Transport, Sustainable Procurement, Cultural & Natural Heritage, Water, Planning & Built Environment and Health & Well-being.

While minimising future negative impacts by reducing greenhouse gases (GHGs), we must also make preparations to deal with future changes to our climate that are now unavoidable due to past emissions. These changes are said to be already ‘locked in’ and will include more frequent flooding, storms, heatwaves and other extreme weather events.

In terms of adaptation, Glasgow is one of the local authorities taking part in the ongoing Local Climates Impact Programme, undertaking a research programme and producing a report which will inform an adaptation strategy for the Council.

City Plan 3 is already underway and will ensure that the risks posed by climate change are addressed in the most sustainable and effective manner, particularly by promoting sustainable construction and energy efficiency measures; therefore addressing both adaptation to unavoidable impacts of climate change and mitigation, reducing GHG emissions.

Together with the SOA and the Community Plan, the Council Plan forms the planning framework which is designed to help everyone understand the links between the activities we carry out and the effect these will have on delivering our priorities and objectives. Under the heading of sustainability, the framework provides the integrated approach to deliver on climate change issues such as energy efficiency, waste, air quality and transportation.

The recent launch of the Sustainable Glasgow initiative responds to many of the energy related issues such as district heating whilst other strategies and action plans take forward complementary themes.

Finally, the 2014 Commonwealth Games Athletes Village, some 1400 homes, will also be designed to achieve a low carbon lifestyle.

In summary, the council’s approach to climate change:

• Takes account of current EU, UK and Scottish legislation on climate change

• Builds on the Council’s existing plans and policies and will encourage a carbon neutral approach to its future services and activities

• Sets out options to reduce CO2 emissions and take additional measures to enable Glasgow’s business community and citizens to adapt to climate change

• Will continue to evolve as further guidance and policies are issued by the Scottish Government.

Q4 – How integrated is your response with other organisations in similar or related fields? Glasgow City Council is a member of different networks and has signed a series of agreements to ensure that it adopts a coordinated and joined up approach to the challenges presented by climate change. Examples include membership of the Sustainable Scotland Network and its different working groups, e.g. Sustainable Procurement; the Scottish Climate Change Declaration alongside all Scottish Local Authorities. At a more local level the Council have recently involved our Community Planning partners, by promoting and supporting the Glasgow Climate Change Partnership, whereby all partners committed their organisations to address climate change mitigation and adaptation.

We are also working with SEPA/Scottish Water on drainage issues, have joint agency working via the Glasgow and Clyde Valley Strategic Development Plan Team using the GRIP model (Greenhouse Gas Inventory Project) to assess land use change impacts on climate - Glasgow also works with them on their Area Waste Group. The City Council is substantially involved alongside various partners including Strathclyde University on the Sustainable Glasgow initiative.

Q5 – What are the main barriers to change for you and/ or your organisation? The main barriers are often communication difficulties, lack of awareness and lack of funding to enable investment to be made in reducing the City’s exposure to risk and in climate proofing the organisation and the wider community.

The financial barrier has led to a lack of investment in infrastructure – generally strategic infrastructure – such as retrofitting buildings which are one of the main sources of carbon emissions.

Other issues include the need for a strong global/national response, the time taken to bring renewables on-line, over reliance on car traffic linked to the often poor (or monopolised) public transport and services.

Finally, the imposition of additional and complex targets to the remit of local councils in parallel with a depletion in resources also raised barriers. This is brought into sharp focus due to the ongoing economic downturn and anticipated cutbacks in services and staff. The multi-faceted requirements of the Climate Change legislation will present a challenge in such a period of flux for the Public Sector generally. It is vital therefore that procedure and practice are closely linked at all levels of government and adequate funding and guidance provided.

Q6 – What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes?

Glasgow City Council (GCC) is in the process of developing systems and procedures in response to the Climate Change (Scotland) Act 2009, and in particular the Carbon Reduction Commitment.

Carbon tax The Carbon Reduction Commitment has resulted in a heightened profile of carbon emissions: it is now possible to ascertain a financial price of carbon. GCC can therefore now quantify a true cost for the use of fossil fuels, including the associated production of carbon as a bye product. Going forward, it is envisaged that this will enhance decision making within GCC: including carbon and the price of carbon in emissions will assist in the implementation of GCC’s carbon management plan, and consideration of the financial impact arising from anticipated changes in carbon emissions will better inform decisions that involve energy use. A key challenge will be cascading accountability for carbon throughout the Council and its subsidiaries, a large and disparate organisation.

Emissions trading Emissions trading will only impact if the purchase of allowances exceeds or falls below that required by the organisation. GCC is in the process of implementing a range of measures to minimise the Council’s exposure to open market trading. The price of emissions on the open marked will also depend greatly on whether the “caps” in the scheme are set realistically, allowing the price of carbon to impact on decision making. The current economic climate has led to other cap and trade schemes to be ineffectual as there is an abundance of allowances and this has made it cheaper to purchase allowances rather than to implement actions to reduce carbon emissions. As a public sector organisation selling/purchasing additional allowances will impact on the revenue accounts of the organisation and will be ultimately funded by the tax payer. However, the financial impact will be minimal during the initial stage of the Carbon Reduction Commitment scheme. As the scheme develops, public sector organisations will have to ensure that they have the expertise and sound management information to trade effectively in the open market, where required.

Energy Regulations for performance standards The merit of this is that performance standards are clearly identified and this informs decision making. However, the cost of such standards has to be weighted against the benefits. GCC has developed its own carbon management plan and within that, clear targets and milestones have been set to reduce the Council’s carbon emissions.

Incentive schemes The merits of incentive schemes are that they reward best practice. These schemes only benefit those organisations that achieve best practice. Incentive schemes must be transparent, auditable and realistic. For incentive schemes to be effectual they must support the sharing of best practice and support those organisations that are failing to achieve targets. There is perhaps scope for greater sharing of best practice across the public sector as each organisation reacts to the requirements of the Climate Change (Scotland) Act.

Energy Generation

Q7 – What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure? Some renewable technologies (and their associated infrastructure) require a subsidy to be financially competitive with conventional technologies. As many of these incentives are ultimately funded through schemes that add money onto everyone’s fuel bill (i.e. ROCs, CERT and CESP), some members of the public may object to this. However, as the price of conventional technologies rise as fossil fuel costs rise, this will become less of an issue. Indeed, having renewable technologies installed in the future may help to keep bills down.

Another issue is the objections from the general public or organisations to renewable technologies due to the perceived adverse impacts e.g. visual, noise or adversely on biodiversity.

Q8 – How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020? To install renewable heat devices in 10% of buildings will be a tall order, but it will be made easier if particular buildings with larger energy consumption are targeted. Indeed, it is larger heat loads that often make the incorporation of renewable heat cost effective. In an urban context, district heating using renewable fuels will also play a part in reaching the 10% target. By hooking many buildings onto the same heat network, a few large renewable systems are required rather than lots of small systems. This is good for efficiency and will help keep emissions down (in the case of biomass - larger systems can install better filters).

Q9 – What are the institutional, organisational and financial barriers to meeting the 50% target of renewable energy by 2020? Institutional barriers: statutory instruments such as the Climate Change Act and Carbon Reduction Commitment are forcing institutions to take note of the need for lower-carbon energy solutions (some of which will be renewable). In terms of electrical generation, there is a series of projects in the pipeline across Scotland, so the focus for organisations such as Glasgow City Council is on lower-carbon heat.

Financial barriers: the Carbon Reduction Commitment has put a price on carbon, so organisations can now begin to cost carbon into all future energy (and building) solutions. As the price of carbon rises, as is anticipated, the use of renewable technologies will become evermore attractive. Having said that, many technologies are still relatively expensive to fund initially, so funding assistance is essential. For micro-renewables, schemes such as the Renewable Heat Incentive (RHI) and Feed in Tariff (FiT) will play a huge role in the introduction of renewable technologies (both electrical and heat) across the country.

Organisational barriers: statutory instruments (see institutional above).

The key to meeting the 50% target in an urban context is to ensure that developments across the city work together. Sustainable Glasgow offers an excellent model for collaborative working and coherent energy planning – without this level of coordination in our towns and cities, it will be difficult for us to meet the 2020 target.

Q10 – Is there sufficient action to exploit the potential of microrenewables? Since the announcement of the RHI and FiT, it is likely the introduction of microrenewables will increase considerably.

Q11 – What are the obstacles to cutting energy use? It is very difficult to change people’s behaviour; therefore this should be considered the greatest obstacle. Active energy management can be introduced in larger buildings, but to reduce domestic consumption in the next ten years will require people’s habits to change and a commitment to carry out the appropriate thermal improvements e.g. insulation.

Land Use

Q12 – How can we use our land more efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats? Glasgow as a mainly authority may have more limited opportunities in this area but our options could involve using our land for:

• Energy use such as biomass production currently ongoing at Castlemilk • Agriculture use potentialities are limited as most of the existing land is already leased to tenants or contract farmers • Forestry use such as Glasgow’s current work with the Forestry Commission Scotland (FCS) to develop areas of forestry for biodiversity and to help the FCS meet its carbon sequestration targets • Conservation use is advance by protection (through SINC designation and LNR management) and creation of new wetlands which promotes biodiversity and stores carbon in peat forming wetlands.

Q13 – What do you see as the major barriers to changing rural land-use activities in this way? Not applicable

Buildings Q14 – What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

This response refers to existing building/housing stock, though undoubtedly much of what is currently being constructed may struggle to deal with the projected climatic conditions by 2080, assuming they are still standing by that time. We also assume that we will continue to improve the thermal efficiency of the stock in order to reduce carbon emissions in line with the Climate Change (Scotland) Act 2009.

The Department for Environment, Food and Rural Affairs (DEFRA) published the 2009 UK Climate Change Projections in June 2009. There are projections for different regions of the UK with a range of scenarios based on the relative probability of different levels of rise in greenhouse gases, based on current evidence. The results quoted here are central estimates for 2080 and assume a medium level of emissions.

The key findings for the West of Scotland are: • Increase in winter mean temperature 2.6ºC; very unlikely to be less than 1.4ºC or more than 4ºC. • Increase in summer mean temperature 3.5ºC; very unlikely to be less than 1.8ºC or more than 5.5ºC. • Change in winter mean precipitation +21%; very unlikely to be less than +6% or more than +41%. • Change in summer mean precipitation –15%; very unlikely to be less than –32% or more than +1%. • Rise in sea level around 35cm.

On this basis the greatest challenges will be to deal with higher rainfall in the winter months, cooling buildings efficiently during the summer months and dealing with flood prevention either through rising sea levels – the Clyde is tidal in to the centre of Glasgow – or flash flooding.

Flooding is generally very localised and there is good historical evidence on where this is most likely to occur. It should therefore be possible to carry out risk assessment on the most critical areas. Glasgow currently has plans in place to deal with some of the most critical issues, such as the River Clyde Flood Management Strategy, the Glasgow Strategic Drainage Plan and the White Cart Flood Prevention Scheme. All of these strategies will be kept under regular review. All local authorities need to assess the risk of flooding in their areas and take a strategic view on how they will deal with this. Parts of Glasgow’s Victorian sewerage system are already at capacity. There is, therefore, a need to consider an appropriate surface water management solution.

There will also be a variety of consequences for property/householders in protecting their properties e.g. are their drainage systems are capable of dealing with larger volumes of water, is an adequate maintenance regime in place to deal with blocked drains, gutters and rainwater conductors promptly. Housing stock that is in a poor state of repair will find their problem exacerbated by the forecast climate changes.

In terms of rising temperatures, in theory the issue that may need to be addressed is cooling. However, if changes to the weather pattern also produce greater variation in winter temperatures, such as we have experienced this winter, then heating could also become an issue. Currently heating design tends to work on the basis of around -2 degrees C, if there are regular winter drops below this level then the current heating designs will not be capable of dealing with this.

In the context of the Scottish Government’s Climate Change Strategy and reducing carbon emissions, they have discussed changes over time from a gas grid to a heat grid, utilising district heating and combined heat and power. The Sustainable Glasgow Initiative will help facilitate this change.

It is perfectly possible to retrofit cooling through the use of air-conditioning units, but these will tend to run from peak rate electricity, will increase carbon emissions, and do little for the fuel poor.

While new build can be designed to maximise passive heating and cooling retrofitting is a more difficult issue. There is therefore a challenge for the building industry to produce products that can deliver this.

Q15 – How should Government ensure that business/domestic energy efficiency measures are met? There are several ways that energy efficiency measures can be promoted, with an area based approach being potentially the most effective. However, promoting measures and delivering measures are not the same thing and in the end there is only one possible answer to this and that is by regulation. There are many examples of households being offered free insulation measures yet not taking advantage of them and others where common ownership issues in flatted properties have prevented work going ahead. Any regulation would have to be matched with an effective enforcement regime.

There are many ways that this could be developed and enforced: through housing benefit legislation or landlord licensing in the case of rented properties or through the land register or council tax in the case of owner occupied properties.

With regard to built heritage, legislation is responding to the need for better energy efficiency and the use of renewables in both theory and practice. Various documents have been produced which will lead the way in this field whilst ensuring protection of our heritage assets e.g. the Change Works Renewable Heritage Project, 2009:

Cost is a critical factor however, as retro-fitting renewable technologies to existing building stock is currently prohibitive. The focus should be on removing this barrier and augmenting the progress made in promoting basic energy efficiency measures such as insulation/draught proofing and boiler replacements.

Through evolving policy e.g. PAN 45, and sharing of good practice, the planning system is equipped to ensure the balance is struck between maximising energy production and minimising unwelcome visual impacts. At a local level, Glasgow City Council is committed to the aspirations of the Climate Change (Scotland) Act and has incorporated this agenda into the core aims of the Service and the Policies contained within City Plan 2. The Glasgow response to the recent Government consultation on the Energy Efficiency Action Plan for Scotland provides more background.

Potential mechanisms to ensure that business/domestic energy efficiency measures are met would include energy efficiency audits (as already piloted in Glasgow) and subsidised improvement schemes for all homeowners and businesses. Access to information, advice and affordable systems which are appropriate for their environment are the key issues to address. In the long term, there may be scope to adapt the taxation system according to energy efficiency ratings.

Q16 – What are the current obstacles in the current planning and building reulations to implementing the measures envisaged in the Climate Change act? Retrofitting energy solutions is an issue as whilst we have higher standards for new buildings, these only represent a very small proportion of overall stock even over a fairly lengthy period of time. At present too much focus is place on micro renewable solutions which can be expensive to maintain or which are not fully proven over the longer period. More focus could be given to simpler measures such as boiler replacement, insulation and draft proofing.

At present we have separate carbon emissions requirements through planning (SPP) and the building regulations. This is not working or causes confusion and it all should be integrated within actual building regulations

Transport

Q17 – How could your organisations transport emissions be cut by 30% by 2020, and what are the barrier’s to achieving this Cutting carbon emissions from transport by 30% by 2020 will require some quite significant changes in the way we currently operate. Perhaps the first and most obvious is the change to low carbon technology vehicles.

Glasgow City Council has already started to reduce its carbon impact from Transport by adopting a green procurement strategy for its fleet vehicles. As part of this strategy we have already purchased in excess of 200 cars with emission levels below 100 g / km, giving them a zero road tax, and are where available buying vehicles with a higher Euro emission standard than the current legislative requirements.

Moving Forward Glasgow will continue this strategy; however there will need to be significant developments in vehicle technology if this target is to be achieved.

Glasgow has become involved in 2 Department for Transport supported programmes to help develop electric vehicles. Around July 2010 Glasgow will take delivery of 40 cars and 10 vans gap funded through these programmes.

It is envisaged that these vehicles will be operated over a 3 year period and the information gathered from these programmes will be used to help “kick start” the introduction of electric vehicles on a much larger scale.

The reality is that with high oil prices and legislation driving down carbon emissions, here will be a natural move by main stream manufacturers towards lower carbon vehicles; however will this be enough to meet the 30% reduction by 2020?

Even if we do see the introduction of low carbon technologies such as full electric vehicles there will be a requirement for a robust infrastructure of charging points throughout the City and wider area. There will also be an issue with charging times – currently this can take many hours for a vehicle to achieve a full charge.

Moving on further with technology, one possible solution is the introduction of hydrogen powered vehicles. Again these are currently in the very early stages of development and of course there would be a requirement to develop an infrastructure of hydrogen refill points.

These are the issues that relate to technologies, which may be the largest barrier; however there are a number of other issues such as changing the way people think within our Transport group. Many people use a vehicle when they could easily walk or take public transport.

Other issues such as better routing of vehicles, the introduction of communications in all vehicles can have a significant benefit in reducing carbon emissions. This kind of technology is currently available, however it is costly.

In summary, the barriers to change in achieving this carbon reduction are: • Limited low carbon vehicle technologies • Lack of infrastructure for electricity • Cultural behaviour • Limited funding 1. Steps to Change Behaviour

I generally avoid using the car for unnecessary short trips, walking to the shops and taking a back pack. I try to use trains and buses as much as possible. I plan to install enhanced insulation in the loft.

2. Difficulties

After investigating the alternatives, I concluded that the best way to insulate my loft would be to install the insulation under the roof, so as to protects hot and cold water tanks, whereas the alternative of putting the insulation between and on top of the joists provides no protection to the tanks and pipe. However, government grants are only available for the inferior solution.

When I learned that , I contacted Claire Baker, the List MSP who looks after people in my part of Fife and, after talking to Lawrence Cowan, a member of her staff, I sent him an email, with a copy to Sarah Boyak, The Shadow minister for Environment and Climate Change in the Scottish parliament - and i am forwarding acopy of that email to you.

3. What is Stopping me

Question does not apply

4. Further Comments on the Issue

I am a semi-retired Operational Research Practitioner and I do sessional work for the School of mathematics at University of Edinburgh, findintg and supervising external projects for students doing the MSc in Operational Research - and some of the project offerings I am currently working on relate to the application of systems thinking to issues pertaining to the response to climate change. For instance, one project idea is to get a student to build a model to help explore the natural synergy between wind and hydro. As I am sure you know, the value in use of Denmark's relatively large windpower capacity is much greater than it would otherwise be becauseof the huge trade in electricity between Denmark and Norway. The opportunity to trade, and the benefit therefrom, arises because it is impossible to control the timing of the output from wind installations, whereas, the operators of the Norwegian hydro schemes have total control over when they run their water turbines. By buying surplus Danish power, the Norwegians save water which can then be used to supply Danish demand at other times.

Unlike England, Scotland has existing hydro schemes (and, I imagine, scope to build more), which provides an opportunity to either trade like the Danes and Norwegians, or for a single company, like Scottish and Southern, to optimise the joint operation of their wind and hydro capacity.

I already have a draft Project Outline, but have so far failed to find a suitable sponsor. You might be able to help? I sought a referral to Scottish and Southern, but was told that they already have an exclusive arrangement with another university.

5. Further Comments on the Event

Overall, I was impressed with both the organisation and the panelists. I thought Professor Sugden (?), the accounting professor and the architect were all excellent and the councillor was good in parts, but some of his answers showed a lack of understanding of systems. For instance, he suggested that replacing electric storage heaters with efficient gas boilers would cause a reduction in the use of renewable and nuclear generated electricity. This could only be true if the grid is very inadequate. Otherwise, the reduction in electricity usage would come from a reduction in power generated in thermal power stations. To explain, less nuclear and renewable power may be used in Dundee, but, with sufficient interconnect capacity, that power would be diverted to Fife, Edinburgh or Glasgow, where there would be an offsetting reduction in power generated in thermal power stations.

I hope you have found these comments useful and not excessively long-winded - and I hope you may be able to help me in getting a sponsor for my Wind and Hydro Synergy Project.

Best Regards

Dudley N. Foster

----- Forwarded Message ---- From: DUDLEY FOSTER To: Lawrence Cowan Cc: Sarah Boyak, Claire Baker, Scott Dryburgh Sent: Tuesday, 19 January, 2010 10:23:12 Subject: Government Grants for Loft Insulation

Dear Lawrence

Last week Thursday, 14th January, I made an appointment with an outsourced government insulation surveyor to visit my house and make an assessment with respect to improving the loft insullation.

Prior to the surveyor's visit, I consulted a friend, Mr Scott Dryburgh, who is a civil engineer, to discuss the relative merits of installing insulation under the roof-slope, vis a vis immediately above the ceiling. Scott confirmed my judgement that installing insulation under the roof- slope is the better solution, for the following reasons.

(1) Under-the-roof-slope insulation protects hot and cold water tanks, whereas the alternative not only provides no protection to the tanks and pipes, but increases the risk of bursts by making the loft colder.

(2) For anybody who may want to do a future loft conversion, or for any future purchaser of the house, under-the-roof-slope insulation is superior because, in Harold Wilson's famous phrase, it helps to keep ones options open.

(3) Mr Dryburgh also said that laying insulation material over the joists creates a serious health and safety risk for people like himself, who have to go into people's lofts in the course of their work. The lack of any visible evidence of where the joists are means there is a risk to the loft inspector of putting a foot through the ceiling and injuring himself - and damaging the ceiling - and upsetting the home owner.

In the light of the above, I find it amazing that government policy is so narrowly specified that grants are only available to people who choose the inferior, risky, inflexible option.

I am not suggesting that the amount of money available for people who choose under-the- roof-slope insulation should be any greater than if they chose the government preferred alternative, but I find it odd that grants are not available at all to people who are prepared to spend more of their own money on a better, more far-sighted solution.

Next, I realise that all of this is entirely the result of badly drafted legislation by the drafting clerks servicing the House of Commons, and probably does not even reflect a conscious intent by the UK Government, and is certainly not in any way the fault of the Scottish Government or of the Labour MSPs, or of the Liberal Democrat or Conservative or MSPs, either. However, the funding is routed through the Scottish Parliament and I contacted you because I know Claire Baker, who is the List MSP who looks after constituents in my part of Fife.

Finally, you told me that there is a possibility that there may be other government schemes which do provide grant money to home owners who want to insulate their lofts in the manner I have described. Accordingly, I shall hold of acting on my plans until the end of February in the hope that you might have some good news for me by then. But even if you can't help me soon enough, I would like you to continue to pursue the matter for the benefit of others in the future.

Kind regards

Dudley N. Foster

Forth Ports PLC

Re: RSE Inquiry Facing up to Climate Change

Introduction Forth Ports run a group of regionally based ports in the central belt of Scotland and Tayside. Grangemouth is Scotland's largest container port, serving both the Glasgow and Edinburgh Metropolitan Regions. The Port of Tilbury is London's major distribution hub for South East England. We also have a port terminal operation at Chatham in Kent operated under the Nordic banner. We provide marine services, controlling navigation in the Firths of Forth and Tay through the Forth and Tay Navigation Service as well as operating our own towage fleet. We have a Property Division that manages and develops our property assets, a recycling division (Nordic Recycling) and a joint venture renewable energy division (Forth Energy) with Scottish and Southern Energy.

RSE Questions Forth Ports welcome the opportunity to contribute to the inquiry and as such we wish to contribute the following:

• Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation? Clearly adverse weather events have the potential to impact on our operations. Severe weather can delay vessels on the routes between ports or can prevent them being worked. Delays create frustrations for vessel scheduling, for crews and for the owners of the cargo on the vessels. Our staff work in all weathers. We have not identified any change of trend in weather, and therefore do not foresee any issues at this time in relation to weather patterns. Precipitation does not directly impact on our operations; wind can have impacts as can extreme tides, whether high or low, if there is a substantial increase in relative sea level in the future (see below) this could also have implications.

• What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk? Forth Ports PLC established an environment integration committee at around the time that the draft Climate Change (Scotland) Act was consulted upon. The goal of this committee is to pull together the learning points from all divisions of the business. Energy efficiency is one of the primary goals of this group in the interim. This committee has presided over an unprecedented improvement in energy efficiency in our ports business, where we measure electricity per tonne of non-piped cargo handled. Every year the group completes a risk register, environment is one of the headings in the risk register, each heading has a list of scored top risks to the business. We are acutely aware of the potential for climatic changes to impact on our business. As part of examining these risks, the board agreed to fund a Ph.D. student to examine the top perceived climate risk: relative sea level change in the Forth and Tay Estuaries. Our student at Dundee University is working on the data available and at the end of the process we expect to be in a strong position to be able to use this information to inform our ongoing infrastructure investment decisions. This was particularly important because the majority of figures available for relative sea level change for the Forth and Tay tend to be extrapolated from more distant areas and we were keen to develop a strong understanding of the local trends.

Forth Ports PLC – RSE Inquiry Facing up to Climate Change 1/3 • What do you plan to do in response to these factors over the next 5-10 years? We plan to continue to improve our energy efficiency. As part of owning a recycling business, we continue to examine opportunities to improve the proportion of our waste that we recycle or reuse. We also intend to continue to work to increase the amount of coastal shipping from our ports. We see this as a particularly important and valuable service that we can offer to reduce Scottish and UK carbon emissions through modal shift from land based transport means to sea based transport means. Movement of goods on water is considerably more energy and carbon efficient than the movement of goods over land. Our renewable energy business will also focus on delivering renewable energy projects (these can be found at www.forthenergy.co.uk). Finally, investment decisions will benefit from the information that we gain from funding our Ph.D. student at the University of Dundee.

• How integrated is your response with other organisations in similar or related fields? As well as being the Environment Manager for Forth Ports, I also Chair the joint UK Major Ports Group and British Ports Association Environment Policy Group. One of the activities of this group is to share information on environmental issues and approaches used to deal with these issues. Separately, the Chief Executives of all of the member companies of the UK Major Ports Group (of which Forth ports PLC is one) have agreed to share information on energy efficiency in particular.

• What are the main barriers to change for you and/or your organisation? The main barrier to change is inertia. This is mostly found outwith the Forth Ports Group of companies, suppliers and manufacturers of plant and equipment can be resistant to changes that they consider could cause them risk (see below). Whilst this is understandable in today’s litigious society, this needs to change.

• What are the relative merits for your organisation of a carbon tax; emissions trading; energy regulations for performance standards; or incentive schemes? We believed that it was inevitable that there would be some form of carbon or related taxation beyond the Climate Change Levy. However, such taxes must be relevant, enforceable, practically applied and above all, fair. We have been vociferous in our position criticising the government’s position requiring the ports to be responsible for the emissions of tenants in relation to the Carbon Reduction Commitment (CRC). In the case of Forth Ports this is expected to result in our CRC liability for electricity being considerably larger than if we were only responsible for our own use. To put this into context, of those tenants we supply electricity to, they use four to five times more electricity than we do. Then own the plant and equipment, often also owning their own buildings on our land, in these cases, the tenant has all the control over the energy efficiency of their processes and buildings, we as landlord have none. The government’s usual argument here that the landlord can upgrade lighting, heating, windows and insulation to make a building more energy efficient does not hold true. Furthermore, these aspects are insignificant in the context of energy use from a cement batching plant, pipe coating works or other industrial processes. We were initially under the impression that we would be notifying the government of our tenant on-sales, each tenant would therefore be a participant. However, it would appear we were given this advice in error following the mix up over wording. We now find ourselves in a challenging position, our tenants will be part of the CRC through us, but we will have the liability; financial and reputation. In such a complex scheme, there is no easy

Forth Ports PLC – RSE Inquiry Facing up to Climate Change 2/3 and fair way to pass this burden on to our tenants. We have always said that we are comfortable being part of the scheme for our own use, but believe that the inclusion of our tenants, particularly the industrial tenants is grossly unfair, disadvantaging our selves and our tenants.

Transport – how could your organisation’s transport emissions be cut by 2020, and what are the barriers to achieving this? We have been working to identify organisations that could provide assistance on the energy efficiency of our marine plant (tugs and pilot boats) and our shore based plant (straddle carriers, top lifters, forklift trucks etc.). Until recently this proved rather challenging. The key barrier is the manufacturers warranty. In many cases the manufacturers of engines warn that the fitting of devices to improve fuel efficiency will void engine warranties. Similar discussions have been had regarding fuel types and whether there are different grades of fuel (in particular for our marine plant) that would lower emissions. Issues of warranty may well be a genuine concern to the manufacturer; it certainly makes us think twice before examining options further, as the risks then lie with us if an engine fails when an unapproved device has been fitted (regardless of what has caused the failure).

In Forth Ports we are actively working to reduce our carbon footprint through resource efficiency measures. We have been developing these projects for some years, substantially reducing our energy usage with considerable attention at board level. Forth Ports support activities to reduce carbon, indeed the shipping routes calling at our ports substantially reduce the carbon budget of the UK and we strongly believe that more use of the shipping routes calling at our ports could make a significant impact on the UK’s ability to meet its carbon targets. A recent study by the Edinburgh Centre for Carbon Management (part funded by the Carbon Trust) showed that just three of the many routes from our ports saved more than three times the Forth Ports Group carbon footprint (using the Greenhouse Gas Protocol approach, Scopes 1, 2 & 3) when compared to road transport alternatives. Following further work we have identified that Forth Ports PLC has a carbon leverage in excess of 10:1; we save more than ten times the carbon we emit in conducting our business, just from the limited number of routes and projects we have examined. Furthermore, we are working on a number of potential coastal shipping and barge transport options that will further demonstrate the carbon benefits that can be derived from growing port volumes by diversion from road. We therefore believe that by working in partnership with government and attracting more trade to travel by sea rather than by land we can reduce the UK’s carbon footprint and substantially contribute to the 2050 80% target.

Conclusion Improving energy efficiency is a core aim of the Forth Ports Group of companies. We have made substantial savings in electricity in particular over the past few years, relative to tonnage of material handled. We are finding barriers, warranties being one, where there is potential to retro-fit devices to existing plant and machinery. Fuel efficiency is only part of the story, we firmly believe that by moving more trade from road and rail to short sea shipping Forth Ports can continue to grow and assist the government in meeting its highly ambitious carbon targets.

D. McGlashan Environment Manager – Scottish Operations

Forth Ports PLC – RSE Inquiry Facing up to Climate Change 3/3

Facing Up to Climate Change - Written evidence

Liz Marquis, Director, Energy Agency

Individuals

-Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

Organisational impacts are set out in more detail below. For individuals more severe weather events will have a range of effects from more widespread travel disruption to more frequent insurance claims for damage to property and personal injury. This will ultimately impact on the value of land and property in certain areas particularly vulnerable to damage

-What are the impacts of the Climate Change (Scotland) Act on you and/or your organisation?

These remain to be clarified, but will potentially be significant.

Organisations

-Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

There are few services provided by the public sector and local government that are likely to avoid tangible impact of changing weather patterns and climate. In broad terms, an increased intensity of rainfall, storm events and extended and more frequent periods of drought and high temperatures will impact adversely on the built infrastructure. This will range from increased frequency and severity of flooding events with short term travel disruption and social displacement with associated economic impact and in worst cases structural damage with consequent resource impacts. We anticipate more severe coastal flooding and coastal erosion of significant economic assets such as golf courses and bathing beaches. Heavier sediment loads in rivers will intensify erosion and potentially affect bathing water quality. Lesser immediate impacts will involve extended growing seasons with possible impacts on grass maintenance and weed growth, and health related impacts around pest control, food safety and heat stress for vulnerable citizens and certain elements of the workforce.

-What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

Impact of climate has been identified as a strategic risk for the organisation, principally in relation to asset management and elements of emergency planning

-What do you plan to do in response to these factors over the next 5 – 10 years?

There is an objective in our community plan to address preparedness for the impacts of climate change

-How integrated is your response with other organisations in similar or related fields?

Limited. Main focus is through responsive emergency planning, and specific areas such as river basin management and catchment plans related to flooding.

-What are the main barriers to change for you and/or your organisation?

The principal barrier is the conflicting demand on resources and the significant investment required to maintain and improve structural resilience. Availability of viable alternative commuting and working arrangements.

Energy generation

-What do you see as the issues with public acceptance of increasing investments in renewable energy and its associated infrastructure?

The main issue will be the undoubted premium required to finance these essential investments, whether through taxation or utility costs. Must be equitable and capable of clearly demonstrating the social and economic advantages as well as the environmental ones.

Acceptance of this cost will be linked to the success with which the Authorities and the energy industry can communicate to the community the ‘tangible’ environmental and wider economic benefits and the long term cost savings associated. There is a public education role which should itself have resources allocated to it.

-How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020?

By providing a suitable range of cost-effective technologies to suit a variety of applications, and capable of low disruption installation on a reasonable payback period supported by a readily understood set of financial incentives.

Due to lack of capacity in the renewable energy installation industry, we cannot see this target, requiring an average of over 20,000 installations per annum, being achieved. If the figure is roughly equivalent to a third of all Scottish dwellings off the mains gas network, this take up would require virtually all non-mains-gas boiler replacements to be renewable energy systems although a great many homes would require major energy-efficiency improvements including solid wall insulation for them to be practical.

The most likely scenario for this being achieved would result from the very fast acceptance by the heating industry and the on-gas population, incentivised by the Renewable Heat Incentive (RHI) supported by a state-supported technology-specific loan package, together providing a ‘pay-as-you-save’ facility. (Local mass production of air-source heat pumps, as is already planned, would help with this.)

This would result in a large increase in domestic electricity demand, due to the switch from gas and oil to electricity with ramifications for the Distribution Network Operators and generators, balanced to a small degree by those switching from direct electric heating. For these, the ‘pay-as-you-save’ facility would have to also cover the cost of installing wet radiator systems. The increased demand in domestic electricity will also have an effect on the requirements for 50% of electricity generated from renewable resources by 2020, meaning more renewable generation necessary to meet the target.

This will also require a relaxed approach to the criteria for permitted development status for ASHPs, currently under consideration, with regard to noise abatement and proximity to neighbouring properties.

Whilst solar water heating is relatively easily adopted, it will not account for more than approximately 15-20% of the heating requirement of a typical home with a suitable unshaded roof. This may not meet the definition of ‘heated by renewable heat technologies’.

District heating schemes will play a part but the isolated incidence of sites practical for retrofitting (in terms of ownership and heat demand density) means it will be very limited unless there is a significant uplift in the RHI for district heating systems to cover the high establishment costs.

Likewise wood pellet heating will expand greatly from a small start but the practicalities of delivery in urban areas and the relatively large size of boilers and fuel stores limit the potential for widespread retrofitting of anything other than simple room heaters which the RHI proposals appear to exclude.

-Is there sufficient action to exploit the potential of microrenewables?

No. The main problem will be lack of capacity in the installation industry.

1. Overcoming this will require well-funded initiatives to devise appropriate training courses and incentivise plumbing and heating engineering businesses to ‘up- skill’ staff and encourage broad adoption of renewable technologies through funded training and recognised, widely accepted qualifications.

The Renewable Heat Incentive is insufficient on its own to make renewable energy systems more attractive than conventional alternatives in almost every situation where their use is practical. To ‘release the brakes’, the route to accreditation for installers must become simpler and cheaper. The current Microgeneration Certification Scheme (MCS) is very comprehensive in its requirements, but it will act as a major barrier to the rate of uptake required by the national target. The existing MCS is a particular barrier in areas of low population density where installer companies do limited amounts of installs which do not justify the cost and complexity of the accreditation system.

2. Scotland needs a ‘smarter’ alternative which focuses on the particular circumstances of the Scottish heating industry and is much cheaper, without a drop in standards in the all-important technical areas, thereby allowing the large numbers of small firms to participate. (Such a scheme is believed to be under consideration by the SG.)

3. The currently tight restrictions on the permitted development rights for ASHPs and solar panels, in particular the distance-from-neighbours limit for ASHPs, the wind turbine tower height in rural areas and the 9m2 size limit on ground-mounted PV arrays, are a significant restraint on adoption and need to be relaxed. (These are under consultation, now closed, by the SG.)

-What are the obstacles to cutting energy use?

1. Lack of financial incentive 2. Lack of knowledge and understanding combined with the increasing availability of energy-intensive products 3. Lack of political will, at EU and national levels, to attempt to control demand for energy

The main controller of energy consumption is human choice. According to the RSA “Almost half of the UK’s emissions of greenhouse gases can be attributed to our individual actions.” Primarily, the obstacle to cutting energy use is the lack of financial incentive. Lack of knowledge and understanding comes second to this. A system to effectively ration the use of energy is the solution, challenging to implement though it is.

The energy price inflation which will result from the FiT and RHI schemes is a ‘blunt instrument’ which will have the overall desired effect but at the expense of increasing numbers in fuel poverty, contrary to Government pledges.

Energy rationing at the individual or household level, along the lines of the scheme outlined by the RSA – see http://www.thersa.org/projects/past-projects/carbon-limited - is the long term solution. Operating progressively, the great majority of those in fuel poverty are unlikely to use up their ration so would not be affected. Those with a tendency to use much more than the average would experience the greatest pressure to cut back.

Rising demand for energy intensive products

Land use

-How can we use our land most efficiently for energy, agriculture, and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity, and wildlife habitats?

This is of course a near-impossible balancing act worthy of a very extensive national study (possibly already carried out or under way).

There is a good opportunity for the objectives of energy supply, carbon emission reduction, public amenity and wildlife habitat by applying a nationwide, strategic scheme to significantly increase the ratio of woodland/forestry. This is underway in Scotland but currently, it appears, without the necessary level of funding behind it for its objectives to be attained.

Providing food security is a quite separate matter but not necessarily in conflict with the former in terms of land use, but possibly conflicting with the objective of carbon saving.

-What do you see as the major barriers to changing rural land-use activities in this way?

Consistent policy and funding

Land owners and managers are highly sensitive to financial drivers of land use variation, but they are also very sensitive to uncertainty about future policy changes. The Scottish Rural Development Programme (SRDP) can be an effective tool in encouraging the above objectives by targeting grant at desired outcomes, but the policies and the funding streams behind them must inspire confidence that the ‘goal posts’ will not be moved before the project can be developed and delivered without an unseemly rush. A ten year horizon should be the aim, rather than 3 or 5 years.

Buildings

-What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

Insulation and draught-proofing, including the major step of tackling the need for solid wall and coombed ceiling insulation, delivered most cost-effectively ‘street-by-street’ and available to all, without cost to the householder for materials and labour.

‘Pay-as-you-save’ facilities provided by local authorities or appointed agencies for energy-efficiency improvements.

Interest-free loans for energy-efficiency improvements continuing to be promoted to businesses as they are currently.

Greater focus on quality energy efficient new build with in particular increasing incentives for social housing providers

-How should Government ensure that business/domestic energy efficiency measures are met?

These can only be ensured by means of surveys to assess rates of take up and the effectiveness of the above methods, leading to reviews of and tweaks to these methods if required.

-What are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act?

Lack of training/knowledge of these measures within the authorities responsible for policing the planning and building regulations. Perhaps these departments should all have an appointed Climate Change Act Officer who should be consulted on the relevant aspects of applications and should ‘sign off’ all applications with energy use implications.

Transport

-How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

Continuation and extension of existing fiscal and other financial incentives to procure and operate more energy-efficient vehicles; Incentives to displace car miles with public transport miles by means such as corporate travel cards.

Barriers

Cultural inertia

Barriers are cultural unwillingness of business managers to influence individuals’ choice of transport, and tendency to attach unrealistically high value to minutes saved by faster travel methods.

Lack of understanding/knowledge – need for information/advice

This is exacerbated by lack of understanding about the quantitative differences between the alternative modes of transport. More public information on this area would be beneficial.

Lack of infrastructure

Electric vehicles will not become a viable choice until public charging stations are reasonably common, or standard exchangeable batteries become available at public filling stations.

FACING UP TO CLIMATE CHANGE Dundee, 14 January 2010

The following points and questionnaire feedback was received from a public debate and discussion at the Steps Theatre, Dundee in connection with the RSE Inquiry into Facing up to Climate Change: the future for Dundee and the East of Scotland. The viewpoints expressed are those of the public that attended and are not those of the Royal Society of Edinburgh.

Points raised by the Audience

• Policy Planning Statement 25 only requires architects to build for appearance rather than sustainability, functionality or climate change. • The relative costs of private and public transport are unbalanced. When the bridge tolls were removed it was an opportunity to reduce bus fares to Fife, but this did not happen. More needs to be done to make pubic transport attractive. • The climate has always changed, and in addition to carbon dioxide levels, there have been changes to cosmic radiation, volcanic eruptions and cloud cover. The focus on carbon dioxide is misplaced. • Affordability of energy is an issue. Government should encourage communities to generate their own power, by investing in district heating schemes, and “island” electricity grids that allow electricity to be generated and circulated within a community. • Science has shown Carbon dioxide to be the driver of climate change. CO2 levels between periods of glaciations rose to 280 ppm, but levels had now reached 380 ppm. In the first half of the 20th Century temperature followed solar cycles but since 1980’s this link was broken. • In the Ordovician ice age, CO2 levels were in the 1,000’s ppm. Warming results in more CO2 emissions. The IPCC were instructed to ignore solar emissions and cloud cover in their model predictions. • It would be expensive to move to a low carbon economy due to the subsidies for renewable energy. • Heating bills were rising. Old houses without cavity walls or attic space were given no options for insulation through energy company energy efficiency schemes. • Sceptics didn’t believe in climate change but if the Government focused on reducing heating bills, then everyone would be interested. Marketing should focus less on ethical world issues and more on reducing costs. • Care homes have to keep 15 lights on 24 hours a day due to health and safety. This was surely working against these goals. • Dundee City Council were rightly encouraging cycling and walking but many cycle lanes only lasted 50m. More needed to be done to encourage people out of their cars to cycle and walk. • An earlier RSE Inquiry into energy highlighted the need for combined heat and power. However planners were reluctant to install biomass boilers because they couldn’t guarantee supplies, and foresters were unwilling to invest until there was a market for biomass. • Planning processes should treat community owned renewables projects differently to commercial projects, with a quicker planning process.

The Royal Society of Edinburgh, Scotland's National Academy, is Scottish Charity No. SC000470

• During the still weather this winter the amount of electricity generated by wind turbines was likely to be low. The percentage of Scotland’s electricity needs during this period being met by renewables should be made public. Base load electricity provision needed to be in place.

Summary of feedback from audience questionnaires

1. Are you, as an individual, taking steps to change your behaviour to respond to climate change? If so, in what ways? • Widespread decrease in use of car and flights, increased use of public transport, cycling and walking. • Widespread consideration of energy efficiency at home: switching off appliances and lights, less use of gas and electricity, lowering thermostat, energy saving light bulbs. • Several examples of insulating lofts and cavity walls, one or two of installing small wind turbine, solar panels, wood-burning stoves, air-to-air heat pump. • Reusing and recycling. • Sourcing food locally and in season. • Local group volunteers promoting waste reduction, resource conservation etc

2. If you answered yes to Q1, what difficulties, if any, have you encountered and what has been the biggest obstacle? • Lack of good public transport and cycle paths and the cost of public transport are key obstacles for many. • Lack of clear information on the options for increasing the energy efficiency of a home, particularly with regards to the costs, benefits and reliability of a wide range of options (not just insulation as this is not always possible). • Costs of making changes and installing equipment, particularly on a small scale. Wide variety of funding and funding bodies are available but these are always changing so it is difficult to keep track. • Reluctance to change and a lack of government leadership and support at a number of levels, compounded by a feeling of helplessness in the face of the problem. • Difficult to engage children and demonstrate that their actions now will make a difference.

3. If you are not taking steps to respond to climate change, what is stopping you? • Those renting their homes are unable to make changes such as insulating walls and lofts. • Lack of incentives and government grants. • Lack of research funding for individuals and small groups with innovative ideas.

4. Do you have any comments you would like to add to the debate? • More information and support (including practical advice and funding for upgrading housing stock etc) for individuals. Easier access to information and support. • Need for ‘envisioning’ of decarbonised society, what will it look like in 2020 or 2050 if the targets are met? What transitional steps are needed? Lack of clear guidance – what future is Scotland planning for? • Legislation for new builds needs to change significantly if to meet 2020 targets. • The need to control population levels. • Need more focus on small scale community projects for renewable energy. • Need to protect Scotland’s landscape and biodiversity while developing renewable energy, nuclear should not be ruled out as an option. • Govt should lead research to come up with credible figures that show the financial cost of lifestyle choices and place a monetary value on our carbon consumption. E.g. leaving a TV on stand-by = 10p per night and an extra £36.50 on energy bills for the year. Similarly £1.00 to watch TV all day but £5 with a plasma screen TV etc.

The Royal Society of Edinburgh, Scotland's National Academy, is Scottish Charity No. SC000470

FACING UP TO CLIMATE CHANGE: COMMENTS FROM AN HISTORIAN

Here are some reflections prompted by my attendance at the meeting ‘Facing up to Climate Change’ on 3 March 2010 in Aberdeen. The paper that follows contains a rationale and an amplification from the point of view of an historian. Needless to say, other historians would not necessarily share it.

1) INTRODUCTION ‘We are poised to bend the arc of history toward a world free of nuclear weapons’, the Board of the Bulletin of Atomic Scientists announced at the beginning of 2010, observing that they had detected in Copenhagen and other meetings ‘signs of a growing political will to tackle the two gravest threats to civilization – the terror of nuclear weapons and runaway climate change’, sufficient to move the Doomsday Clock back from five to six minutes before the fatal hour. For the first time ever, they asserted, ‘industrialized and developing countries alike are pledging to limit climate-changing gas emissions that could render our planet nearly uninhabitable.’ They claimed that for the first time since atomic bombs were dropped in 1945, they claimed, ‘leaders of nuclear weapons states are cooperating to reduce vastly their arsenals and secure all nuclear bomb-making material.’ The Board encourages scientists ‘to continue their engagement with these issues and make their analysis widely known.’ No doubt, many Fellows will want to answer this call individually, or in research groups, concentrating on aspects of these pressing problems of today. However, there is also a case for a broader response, which the Royal Society of Edinburgh is particularly well placed to make because of its longevity and the nature of its foundation. To elaborate this assertion, let us take as an example the Copenhagen climate conference at the end of 2009, and its context, concentrating on the paramount importance of the fourth dimension and the necessity of a response from a wide range of specialisations. There is no doubt that its deliberations were informed by the long- range weather patterns established by meteorologists, making use of the work of other natural sciences and going back to the beginnings of the Anthropocene Era in the late eighteenth century, and beyond. Certainly, the social sciences are needed to explain the process of industrialisation in general as well as the part played by the BRICS (Brazil, Russia, India and China), the USA, the EU and a wide range of states at varying stages of development in particular. The convergence of geological and human time from the end of the eighteenth century assigns a significant task to historians, while specialists in other humanities no doubt have their part to play, too. I shall elaborate this point by looking at aspects of the RSE’s past.

2) THE RSE In his recommendation of the establishment of Academies or Societies, Francis Bacon suggested ‘that the learned world should be united, as it were, in one immense republic, which, though consisting of many detached states, should hold a strict union and preserve a mutual intelligence with each other, in everything that regarded the common interest.’ Bacon lamented ‘the want of this union and intelligence as one of the chief obstacles to the advancement of science.’1

1 Bacon, De Augmentis Scientiarum, I, 2 as paraphrased in ‘The History of the Society’ , Index to the Transactions of the Royal Society of Edinburgh, 1783-1888, Edinburgh, 1890, p. 1.

1 Arguably, at its Foundation in 1783, the Royal Society of Edinburgh fell short of Bacon’s suggestion and ignored his lament by dividing its members into Physical and Literary Classes. Specifically, the Society was to be concerned not only with Mathematics, Physics, Chemistry, Medicine and Natural History on the one hand but also with Archaeology, Philology and Literature on the other. This separation may have been a reflection of what Campbell and Smellie call ‘a liberal but ill-defined aim’. Certainly, let us recall, the main instigator was Principal William Robertson of Edinburgh University, a divine but also an historian. Moreover, the Literary Class was the larger, with 93 members, as opposed to the Physical, with 72.

From their beginning, however, the Transactions contained more papers from the Physical Class than the Literary, and with volume V, 1799-1803, the separation ceased. Thenceforth, Literary papers were still published, but in a small minority. By 1832, the Society’s separation into two classes was brought to an end, Principal Forbes commenting that this step was taken ‘not from any disinclination on the part of the Society to afford honourable room to literary papers, but simply from the cessation of such communications.’ We should not be surprised to see a trickle of papers drying up, with Lord Moncreiff writing later that ‘… The papers dwindled to somewhat pedantic dissertations on grammar, on modes of verbs, on pronouns, on the Greek letter signs, and were not animated in themselves nor likely to excite enthusiasms nor likely to excite enthusiasm on a general audience.’ 2

This was not the whole story, however, for, as the Physical Class was establishing a monopoly on public utility, the demarcation between disciplines was also becoming clearer. As part of this process, the English words ‘scientist’ and ‘physicist’ were coined in 1840 by William Whewell, the author of The Philosophy of the Inductive Sciences, who also wrote, however, that ‘The Consilience of Inductions takes place when an Induction, obtained from one class of facts, coincides with an Induction, obtained from another different class. This Consilience is a test of the truth of the Theory in which it occurs.’ In 1998, the entomologist Edward O. Wilson went so far as to assert: ‘the possibility of consilience beyond science and across the great branches of learning… is a metaphysical world view.’3 Arguably, we are on surer ground if we posit multidisciplinarity rather than consilience, especially if we bear in mind the observations of Francis Bacon, and the present organisation of the RSE.

3) CLIMATE CHANGE AND HISTORY The common interest of our multidisciplinary fellowship today is to be found in ‘Facing up to Climate Change’, the RSE’s Inquiry chaired by David Sugden. This presents an opportunity for the RSE to take advantage of developments taking place since 1976, when the Council took the decision ‘to take active steps to widen the Fellowship so as to include larger numbers of Fellows from Arts and Letters and from Technology and Industry.’4

Here, I shall not presume to trespass far into the territory of other ‘detached states’, to use again the terminology of Francis Bacon, but confine myself mostly to

2 ‘The History’, pp. 4, 12-3; Principal Forbes, ‘Opening Address’, 1862, Index, 1890, p.21; Neil Campbell and R. Martin S. Smellie, The Royal Society of Edinburgh (1783-1983): The First Two Hundred Years, Edinburgh, 1983, pp. 5- 9. 3 Edward O. Wilson, Consilience: The Unity of Knowledge, London, 1998, p.7 4 As recorded by Campbell and Smellie, The Royal Society of Edinburgh, p. 138.

2 the discipline of history, whose basic message is that there is a time and a place for everything. I shall illustrate this assertion with aspects of the lives and works of two founder members of the RSE, one from each class, Adam Smith and James Watt. To begin with, let us recall that the late eighteenth century was contemporaneous with the beginning of the Anthropocene Era, the confluence of geological with historical time, as indicated, for example, by Paul J. Crutzen and Eugene F. Stoermer in their detection of greenhouse gases from the late eighteenth century.5 Of course, neither Watt nor Smith would be aware of this, but each of them made a contribution to the Era, Watt by helping to begin it, and Smith by suggesting a way of understanding it, at a time when disciplinary boundaries could be easily crossed. For example, James Hutton lectured on ‘Written Language’ as well as ‘The Theory of the Earth’.6

It is too well known to need elaboration that Watt’s steam engine was intimately associated with the early stages of industrial revolution. It is not so well known that Adam Smith makes no mention of Watt’s invention in The Wealth of Nations. To be sure, he does make reference to the steam engine, but only in the shape of the earliest version known as the ‘fire-engine’, improved by a boy employed to open and shut alternately the communication between the boiler and the cylinder. Smith observes: ‘It was a real philosopher only who could invent the fire-engine, and first form the idea of producing so great an effect by a power of nature which had never before been thought of.’ Smith continues: ‘Many inferior artists, employed in the fabric of this wonderful machine, may afterwards discover more happy methods of applying that power than those first made use of by its illustrious inventer.’ But he makes no mention at all of James Watt and his improvements.

Let us recall Smith’s famous example of the advantages of the assembly line, pin-making, included a mechanical operation without benefit of steam engine. This classic description of the division of labour, enabling the production by ten men of more than 48,000 pins a day as opposed to a single man not necessarily producing one of them, mentions nothing more than the simplest of machinery. In general, we need to recognise, Smith gave primacy among economic pursuits to agriculture, asserting: ‘The ordinary revolutions of war and government easily dry up the sources of that wealth which arises from commerce only. That which arises from the more solid improvements of agriculture is much more durable…. The cultivation and improvement of the country…must, necessarily be prior to the increase of the town, which furnishes only the means of conveniency and luxury.’ Moreover, he noted: ‘It has been the principal cause of the rapid progress of our American colonies towards wealth and greatness, that almost their whole capitals have hitherto been employed in agriculture.’ Smith, then, was an advocate as well as an analyst of the pre-industrial mode of life.7

In the year 2010, it is one function of historians to indicate anachronisms, to insist that Adam Smith could not make any observations whatsoever about the impact of the steam engine and the replacement of agriculture by industry as the main focus of economic activity in the nineteenth century, still less about post-industrial concerns

5 Paul J. Crutzen and Eugene F. Stoermer in IGBP Newsletter 41, May 2000.

6 Campbell and Smellie, The Royal Society of Edinburgh, pp. 9, 22. 7 Andrew Skinner, intro. and ed., The Wealth of Nations, Harmondsworth, 1983, pp. 14-5, 465-6, 480, 520.

3 in the twenty-first century. Historians also chart the changes in the economy, society, political life and culture through the successive stages of the Anthropocene Era. Here, to be sure, they sometimes trespass on the preserves of Andrew Skinner and other colleagues in the social sciences.

4) CONCLUSION However, today, Bacon’s seventeenth-century recommendation, that ‘the learned world should be united, as it were, in one immense republic, which, though consisting of many detached states, should hold a strict union and preserve a mutual intelligence with each other, in everything that regarded the common interest’, does not seem anachronistic. Indeed, the multidisciplinary structure of the RSE is eminently appropriate for ‘Facing up to Climate Change.’

[email protected] Paul Dukes, Professor Emeritus, FRSE, History Department, Aberdeen University, Aberdeen, AB34 3FX

Note: This is a conflation of two earlier papers, ‘Proposal for Royal Society of Edinburgh’ and ‘The RSE, Climate Change and Multidisciplinarity.’

4 ‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre

Individuals

Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

Through the nature of the work we undertake, our team are constantly engaged with individuals from across Dumfries and Galloway on the topic of climate change. We have found a wide range in individual perceptions of the impacts of climate change/changing weather patterns - from those who consider there to be no problem, to those who are deeply concerned and perceive significant effects. However, there does not appear to be a simple set of factors that defines/determines the perceptions held.

Anecdotally, there appears to be a perception that Scotland will not be severely impacted by climate change. This response focuses on the direct impacts of climate change in Scotland, rather than the direct and indirect impacts on Scotland in a global context. We have found the 4C map produced by the Met Office to be a very useful basis for discussion around this point. Organisations

Do you perceive the changing weather patterns in Scotland and globally as affecting you and/or your organisation?

The predicted changes in weather patterns for Scotland - increasingly wetter winters, summer droughts and higher frequency of extreme weather events – will likely impact on CCC’s ability to perform everyday practices, project work and research ( e.g. due to flooding). Climate change will also affect CCC’s employees and clients, which in turn could affect the ability to fulfil CCC’s strategic goals.

From a business perspective – CCC aims to help organisations reduce their greenhouse gas (GHG) emissions. As the need to take action against climate change increases, it is likely that we will experience more demand for our services - carbon footprinting and management, sustainable building advice etc.

What are the impacts of the Climate Change (Scotland) Act on the goals and activities of your organisation in terms of investment and exposure to risk?

The Climate Change (Scotland) Act will likely have a positive impact on CCC, with businesses, organisations and public bodies required by law to meet the 80% emission reduction target by 2050.

Presently, CCC is working with Small and Medium–sized Enterprises (SMEs), Communities, Schools and Colleges to assist them in measuring and reducing their GHG emissions. We anticipate that this work will increase and expand as a result of this legislation.

While the larger organisations/public bodies that we work with now have obligations under the CRC Energy Efficiency Scheme, many of our clients are in the non-regulated sector. Much

‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre of this work is funded through philanthropy and grants. This represents a financial risk to CCC, particularly in these difficult times, where the recession and spending cuts have tightened the purse strings of both the private and public sector.

We envisage that the requirement to introduce mandatory greenhouse gas emissions reporting in the Companies Act will significantly increase demand for our services, particularly with regard to training services.

As an organisation, CCC will face the same pressures as others to help Scotland reach its 80% reduction target.

What do you plan to do in response to these factors over the next 5-10 years?

CCC have a Carbon Management Policy, which highlights how we are, and will continue to, reduce emissions as an organisation. We are also formulating a new strategy to focus and use our strengths to guide how we can help Scotland reach its climate change targets and goal of becoming a low carbon economy. Our remit includes applied research that focuses on this theme ( how to engage and effect real change within our various client groups).

How integrated is your response with other organisations in similar or related fields?

CCC actively liaises with other advice and climate change organisations to provide the best solutions for different circumstances.

What are the main barriers to change for you and/or your organisation?

There are several barriers to change for CCC. The main barrier is financial, with limited resources available to run more carbon reduction projects. Barriers to reducing CCC’s carbon footprint includes funding for new premises that are more energy efficient and the rural location of the Centre – employees are limited to how much they can reduce their transport emissions. The work that CCC carries out requires face to face contact with clients to ensure that they are confident in the project that they are undertaking.

In our experience, businesses and organisations (particularly SMEs) are likely to encounter certain barriers when lowering their GHG emissions. The main issue is cost – financial and time - even in the case of those emission reduction measures that would be considered as low cost e.g. installing low energy light bulbs. In addition, despite going through the carbon management process with CCC, the environment is not always seen as a top priority when compared with legislation affecting the business or its day-to-day running. However, this may change with the new Climate Change legislation. Another barrier is colleague/staff resistance to change. This is could be due to lack of education/awareness of the issues, which can impact on the extent to which they change their behaviour to reduce emissions by no cost measures e.g. switching off lights when not in use.

‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre

Energy generation

How do you see 1 in 10 buildings being heated by renewable heat technologies by 2020?

Achieving 1 in 10 buildings heated by renewable heat technologies will require clear, centralised advice (an obvious ‘go-to’ source of information), a range of technologies suitable for different circumstances, easy to access financial incentives, and accredited installers/service engineers.

A key problem, particularly for the average homeowner, is being able to distinguish the most applicable system from an industry which markets many variations of the same product.

The Renewable Heat Incentive (RHI), as currently planned, will significantly reduce the pay- pack period for installation of renewable heat technologies. However, the up-front purchase and installation costs will remain a significant barrier. Some form of state supported renewable technologies loan system, such that energy payments under the RHI are utilised to repay loans would assist in overcoming this barrier.

1 in 10 homes is a challenging target, and some level of national assessment as to the most appropriate targets would assist in formulating a national strategy to achieve it.

What are the obstacles to cutting energy use?

There are many obstacles to cutting energy use, one of which is human behaviour. The need to conserve *energy+ is a concept which directly conflicts with society’s desire to consume and acquire more than they need. Land use

How can we use our land more efficiently for energy, agriculture and forestry to reduce carbon emissions and increase carbon storage, while providing food security, public amenity and wildlife habitats?

There are a number of practices that could be implemented in the land use sector for the purposes of carbon sequestration and emission reduction. In relation to agriculture, there is the opportunity for farmers to become more involved in GHG reduction. One potential action could be an increase in the utilisation of no tillage on cropland which would decrease the level of carbon lost from soils. Another option is the application of biochar produced from waste to agricultural land. Biochar is charcoal used for the purposes of storing carbon and early research has indicated secondary benefits – nutrient retention resulting in reduced fertiliser use and non-CO2 emissions (methane and nitrous oxide) and increased crop yields. The locating of renewable energy technologies on agricultural land of low value, would assist Scotland to reach its renewable energy targets (50% total electricity generated by 2020) and decarbonise electricity generation.

There will be a limit on the quantity of biomass/biofuels that can be produced on Scotland’s land, due to limited land resources – we live on a relatively small island, with an increasing population. As a result, these options cannot be used as large-scale measures to produce

‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre energy for the country - e.g. due to long lock-in times to grow trees to maturity – however, there is the option to use fast growing species to sequester carbon and fell to produce energy. Though a good option for carbon storage in wood, it does not take into account the carbon stored below ground or biodiversity and social issues. The ideal situation would be to find a balance using ecosystem management – grow areas of native forest species and leaving them undisturbed with occasional thinning. These native species may not be the most efficient for carbon sequestration; however their use would be positive from a biodiversity angle.

What do you see as the major barriers to changing rural land-use activities in this way?

The major barrier to the implementation of the measures mentioned above is financial. It is likely that farmers/land owners will have to be compensated or subsidised initially to replace any income lost through up take. There may also be resistance to these changes and land availability to implement these land use measures, as previously stated.

Buildings

What is your view on how we can adapt our building/housing stock to cope with a greater incidence of extreme weather events?

‘Climate proofing’ is becoming an ever important requirement for new buildings. However, anticipating the nature and degree of future extreme weather events, so that they can be addressed and accounted for during the design stages, is a difficult thing to do. Therefore the task of adapting existing buildings to cope with climate change is even more challenging. Buildings themselves are contributors to climate change; and so before ‘climate proofing’ of existing buildings is fully addressed, we need to first focus on changing the culture of ‘short- term’, ‘quick-fix’ refurbishments within the country. We need to get people understanding the benefits that better designed, better specified, better used and longer-term refurbishments bring. Addressing this issue alone will go a long way to ensuring ‘climate proofing’ of buildings.

When we see a change in the overall approach to quality and longevity of refurbishment, we can then think about the level of flexibility we give to existing buildings through refurbishment. Accepting that there are many restrictions to using existing buildings in manner that is different from their original purpose, it is important that the spaces within existing buildings are flexible enough to accommodate change of use as a result of seasonal variations (i.e. temperature, daylighting). They must also be able to accommodate a change in tenancy or ownership.

How should Government ensure that business/domestic energy efficiency measure are met?

‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre

The Scottish Government should give their support to initiatives such as the ‘Carbon Smart Organisations’ programme undertaken by CCC, which works with organisations to help them reduce their carbon impact; which often results in greater energy efficiency.

What are the current obstacles in the current planning and building regulations to implementing the measures envisaged in the Climate Change Act?

The problem with planning policy and guidance is that it focuses far too much on the process rather than the quality of the outcome. While it is prudent to address all issues and impacts of building and infrastructure development; a balance also has to be struck between what is practical and what can be removed from this process. It is widely accepted that unnecessary procedures within in the development process puts pressure on and absorbs capital, which often results in the dilution of quality, energy efficiency and usability of buildings.

Building regulations and technical handbooks have been revised every year from 2006 until know. The constant revision of the very details, which all new and existing buildings have to confirm to, means that those refurbished or built only 4 years ago are still not to a standard that maximises their performance. The simple solution would be to produce a set of regulations and technical guidance that takes on board the proposed standards for CO2 reduction and energy performance as outlined in the Sullivan Report, which the proposed 2010 technical revisions (October) do not meet. Transport

How could your organisation’s transport emissions be cut by 30% by 2020, and what are the barriers to achieving this?

CCC’s transport emissions could be reduced by 30% by implementing new policies and practices. For example, giving employees greater opportunity to work from home would reduce emissions related to commuting and providing lectures via the internet would reduce the need for students to travel to one location for classes. However, it should be noted that this could also have drawbacks, with the workplace/classroom being an asset, providing opportunities for interaction and knowledge transfer.

The transition from the use of private transport to public transport would also assist CCC’s progress in meeting this target. However, there is limited scope for employees to increase public transport use, particularly in the case of commuting. Dumfries and Galloway is a rural region, which is dependent on private cars. This is driven by the poor availability of public transport – few local connections are offered, timetables are limited, vehicles (particularly trains) are in a poor condition and services are expensive. Car sharing is regularly practiced by CCC employees when attending events/meetings and commuting and is a practice that will be continued.

Other actions that are being explored include the use of low carbon vehicles, cycling and walking. Barriers to widely implement such actions include the need for employees to voluntarily rearrange their daily routines. In addition, some of these practices may be expensive (e.g. cost of a hybrid car) and time consuming, with weather conditions,

‘Facing Up to Climate Change’ Response of the Crichton Carbon Centre particularly during the winter and the lack of facilities (showering, secure bike parking) making cycling impractical.