The Net Zero Strategy: An Ambitious and Flexible Path to 2050
The UK Government in October published its long-awaited Net Zero Strategy, building on its Ten Point Plan published last year. The Strategy serves the purpose of outlining how, on an economy-wide scale, the Government intends to meet the domestic net zero (“NZ”) target set out in section 1 of the Climate Change Act 2008 (“the CCA”), the 78% reduction (compared to 1990 levels) by 2035 target contained in the Sixth Carbon Budget, and the UK’s international obligations under the Paris Agreement, including its first Nationally Determined Contribution of a reduction of at least 68% by 2030 submitted by the Government in December 2020.
The Net Zero Strategy has long been anticipated as an important step towards meeting these emissions targets. In its Emissions Report to Parliament published in June this year, the Climate Change Committee (“the CCC”) had highlighted the need for a comprehensive strategy to fill existing ambition gaps and to provide a coherent pathway showing how sectoral efforts would fit together to achieve the NZ target.
This post will briefly outline the contents of the Strategy, and will then comment on some of its key features and potential risks.
Contents of the Strategy
The Prime Minister’s foreword to the Strategy sets the tone for the ambitious nature of the document as a whole, stating that:
“…this strategy shows how we can build back greener, without so much as a hair shirt in sight. In 2050, we will still be driving cars, flying planes and heating our homes, but our cars will be electric gliding silently around our cities, our planes will be zero emission allowing us to fly guilt-free, and our homes will be heated by cheap reliable power drawn from the winds of the North Sea. And everywhere you look, in every part of our United Kingdom, there will be jobs. Good jobs, green jobs, levelling up our country while squashing down our carbon emissions.”
The Strategy certainly does contain a wide range of ambitious targets, policies and proposals to deliver on the NZ target, focusing heavily on the development of new and existing technologies to reduce emissions across the following sectors:
(b) Fuel supply and hydrogen;
(d) Heat and buildings;
(f) Natural resources, waste and fluorinated gases; and
(g) Greenhouse gas removals.
Targets and policies outlined in the Strategy include:
- A commitment to taking action so that, by 2035, all electricity will come from low carbon sources (subject to security of supply).
- A focus on hydrogen, committing to funding for the Industrial Carbonisation and Hydrogen Revenue Support Scheme and the Net Zero Hydrogen Fund.
- Targets set out for the delivery of carbon capture, utilisation and storage (“CCUS”), supported by a £1bn CCUS Infrastructure Fund.
- An aim to phase out the installation of new and replacement natural gas boilers by 2035, supported by a £450 million Boiler Upgrade Scheme.
- Ending the sale of new petrol and diesel cars and vans from 2030 and introducing a zero emission vehicle mandate.
- Kick-starting the commercialisation of UK sustainable aviation fuels.
- Introducing farming schemes to support the transition to low carbon farming practices.
- Increasing tree planting and restoring at least 35,000 hectares of peatlands by 2025, and 280,000 by 2050.
- Setting an ambition to deploy engineered greenhouse gas removal methods.
As this list highlights, the policies and ambitions set out in the Strategy are extensive and varied. A number of different scenarios are identified in the Strategy for how the NZ target could be achieved.
The Strategy also sets out how the transition it envisages will be supported by the Government across the economy, for example by facilitating innovation, green investment, and green jobs and skills.
The Strategy clearly has its strengths. As the CCC noted in its independent assessment of the Strategy, it marks a significant step forward for UK climate policy. The CCC goes so far as to describe the Strategy as being “arguably the world's most comprehensive plan to reach Net Zero”, and as “setting a globally leading benchmark to take to COP26”.
One notable feature of the strategy is that very little is ruled out. In terms of the means that will be used to reach NZ by 2050, most strategies and technologies remain on the table. This undoubtedly reflects the scale of the task ahead, and the uncertainty inherent in the Strategy’s reliance on many forms of technology that are currently only in their early or pilot stages (for example, greenhouse gas removal technologies and the widespread use of hydrogen). It remains to be seen which technologies will take the lead, and the Government’s approach in the Strategy is suitably flexible to accommodate for this. This could, however, be a double-edged sword. In giving policy support for everything, the choice of which path we go down is effectively left to the market and to individual decision-makers. The Strategy places heavy reliance, for example, on mitigating emissions by way of CCUS. By its nature, CCUS will be attached to types of development that emit CO2. If planning permissions are granted on the basis that emissions generated by development will be mitigated using CCUS, simply because those applications come forward before lower-emitting alternatives, but the use of CCUS then ends up being unworkable or unviable, carbon-intensive development will be locked-in.
Second, and related to this, the Strategy does not include reference to a NZ test for use across Government decisions. The CCC had recommended in the Emissions Report that a ‘Net Zero Test’ be embedded in all Government planning and policy decisions, so as to ensure a rigorous assessment of and compliance with legislated emissions targets. The Committee had noted that decisions on road building, planning, fossil fuel production and expansion of waste incineration are potentially incompatible with the need to reduce emissions, and send mixed messages that could undermine public buy-in to the NZ transition. It was suggested by the CCC that a more coherent approach was needed. The Strategy does not adopt this recommendation. This could have been an opportunity for the Government to provide a useful tool to set out how NZ should be taken into account by decision-makers when they are faced, for example, with a policy decision or planning application which appears to have only a small or negligible impact in terms of UK-wide emissions, but does have an emissions impact nonetheless. In such circumstances, it is understandable that the NZ target would not necessarily be given great weight in the decision-making process. However, the cumulative impact of a multitude of decisions of this nature could be such that they would prevent effective emissions reductions from being made. A coherent approach in these circumstances, mandated by central Government, would clearly have been helpful.
A final notable feature of the Strategy is that there is only slight provision for emissions reductions on the demand side. Minimal behavioural change is envisioned, and throughout the strategy there is reliance emerging technologies such as CCUS and the increased use of hydrogen in, for example, steelmaking. The Strategy minimises the efforts that will need to be made by individuals for the NZ target to be met. As noted by the CCC in its independent assessment, the Strategy does not address issues such as the role of diets, or of limiting the growth of aviation demand until sustainable fuels become more prevalent. While this may be a politically more palatable and reassuring approach for the electorate, it does leave the Government with less wiggle room if the ambitious technological advantages envisaged by the Strategy do not pan out as planned.
The Net Zero Strategy is clearly an ambitious and comprehensive document. It sets out for the first time an economy-wide sectoral plan for how the target in s.1 CCA 2008 will be met, and for that reason it has been welcomed by bodies such as the CCC.
The Strategy is, however, exactly that: a strategy. It is one of a long line of strategy and policy documents setting out how the Government can, should or will seek to meet its Net Zero target. Focus clearly now needs to shift to delivery. The exact means by which that delivery will occur is left somewhat up in the air. Hopefully, given the recent warnings of the IPCC and the UN Secretary General, where we land by 2050 will not be too far off the Prime Minister’s utopian vision.
Flora Curtis is a barrister at Francis Taylor Building specialising in environmental, public and planning law.