BCCF’s letter in response to the ‘Clean Growth Strategy’ – sent to the PM, Michael Gove, Claire Perry and Greg Clark last week.

Dear Prime Minister

Bedfordshire Climate Change Forum (BCCF) is formed by a group of people who share a deep concern about the threat and effects of climate change on us locally and on the peoples and biodiversity of the planet.   BCCF is non-party political, an independent voluntary organisation, which seeks to work closely with all the Bedfordshire local authorities, relevant local organisations and the wider public.

BCCF warmly welcomes the overall commitment to environmental sustainability expressed in the Clean Growth Strategy and recent speeches by yourself and Michael Gove. BCCF also welcomes the many good proposals in the Strategy on a wide front ranging from agriculture and land use to energy generation and transport. We agree that progress made to date, with carbon emissions down by over 40% since 1990, as confirmed in the audit by PwC, gives grounds for hope that much is possible, although of course the achievements of the past cannot guarantee success in the future.

We can only reiterate the extreme seriousness and urgency of the environmental crisis in its various aspects. Christiana Figueres, the executive secretary of the UN Framework Convention on Climate Change, under whom the Paris agreement was signed, has argued that the next three years will be crucial to stopping the worst effects of global warming, saying: “We stand at the doorway of being able to bend the emissions curve downwards by 2020, as science demands…”

Emily Farnworth, Head of Climate Change, World Economic Forum, explained, ahead of the annual meeting in Davos, why 2018 must be a pivotal year for climate change: “Action is needed to prevent the situation becoming much worse. During 2018, there are several opportunities to raise awareness about the solutions, demonstrate progress and ramp up ambition to do more – starting now.”

Johan Rockström of the Stockholm Resilience Centre has said: “We have been blessed by a remarkably resilient planet over the past 100 years, able to absorb most of our climate abuse. Now we have reached the end of this era, and need to bend the global curve of emissions immediately, to avoid unmanageable outcomes for our modern world.”

We understand that the Clean Growth Strategy is a higher-level document. Nevertheless, we must respect – and need to echo – the analysis of the Committee for Climate Change that the Strategy does not go nearly far enough. Notably:

  • Policies and proposals need to be firmed up
  • Gaps to meeting the fourth and fifth carbon budgets must be closed
  • Risks of under-delivery must be addressed, and carbon budgets met on time.

Thus, specific commitments must be made, legislation enacted, and practical action taken unless the Strategy is to become a “blueprint for underachievement”, in the words of Caroline Lucas. As the Climate Change Committee under its Chair Lord Deben notes, there must be no reliance on “accounting ‘flexibilities’ in the Climate Change Act… Their use would undermine the UK’s position of leadership and be counter to the commitments made under the Paris Agreement.”

We particularly endorse the support in the Strategy for CCUS, but note that the £100m allocated is far below the £1bn CCS scheme promised by the previous Conservative government’s manifesto in 2015 (as Carbonbrief points out).

Clearly it is vital that the energy efficiency of our housing stock is greatly improved, as the Strategy indicates, but fine words need to be matched by deeds. Just recently the requirement for landlords to raise the energy efficiency of F- and G-rated homes from next April under new regulations designed to protect vulnerable tenants and cut carbon emissions has been weakened. The government has now stated that costs of the upgrade will be capped at £2,500, half of what buy-to-let landlords had been given to expect, with huge reductions of the benefits. As regards new housing, there is no clear intention to re-instate the zero-carbon homes standard scrapped in 2015 (again as Carbonbrief points out).

You have stated a laudable ambition of “making the UK a world leader in resource efficiency”, with an aim of zero waste by 2050, and we applaud Michael Gove’s intention “to set the global gold standard when it comes to the environment, and for animal welfare.” However, we suggest a need to learn from the example of other countries, and to emulate their actions. Currently, England languishes at position 18th in a world table when it comes to recycling household waste, with a rate of 43%, whereas Wales has achieved, remarkably, second place with a rate of 64%. With the recent news that the Environment Agency has granted an operating permit to the Covanta incinerator at Stewartby, Bedfordshire, we have grave concerns about the lack of drive to a circular economy model as well as to the wider unsustainability and inefficiency of incineration of large plants like this, set up to run for up to forty years. In local terms we are similarly concerned about the planned expansion of Luton Airport (to double passenger numbers by 2050,) both in terms of local air pollution and of the need to curb aviation climate emissions. Much has been made of the planting of 50 million trees over 25 years to create the Northern Forest, excellent news, but New Zealand has recently announced an aim of planting 100 million trees a year. Denmark remains a stunning world leader in renewable energy.


We urge you to re-consider some matters, and ask that the Government:

  • Strongly renews support for on-shore wind as by far the cheapest low carbon technology (as well as off-shore)
  • Provides clearer support for tidal as in the Swansea Lagoon project
  • Challenges the desirability of airport expansion, with all of its environmental dangers and costs
  • Promotes public transport far more actively (together with cycling and walking) to reduce our dependence on cars.

We also wish to argue the value of community energy projects, and a universal carbon tax that provides a dividend to all citizens. These are just two ways of involving us all in becoming a low-carbon sustainable society. The remarkable industrial and economic growth in the field of renewables and sustainability in the UK, leading to an estimated job total of 430.000 cited in the Strategy, can provide further transformation. The Climate Change Committee has suggested that this might rise to two million jobs.

However, the very title of the Strategy may be misleading if, as seems the case, it promises that we can have endless economic growth in terms of conventional GDP, within the bounds of a finite planet. We all have to learn to live and think differently, with reduced consumerism together with quite different indicators as the prime measure of wellbeing.

Returning to the matter of the commitments made under the Paris Agreement, the Strategy is commendably frank in confessing that it is conceived within the framework of limiting global temperature rises to two degrees centigrade. However, it is of the utmost importance that the UK works towards the 1.5C goal of the Paris Agreement, as well as legal requirements of the 2008 Climate Act.

BCCF therefore commends the intention expressed thus in the Strategy: “… the Government believes the UK will need to legislate for a net zero emissions target at an appropriate point in the future”, though that point must come very soon. We agree that there is a need to consider and research negative emissions technologies provided that these do not contravene international law and agreements, and cause unintended but potentially highly dangerous environmental consequences.






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