News + Opinion: ‘Fundamental Errors’ in Wales’ National Development Framework

Proposals ‘unlawful’ because they fail to treat climate change seriously enough

Wales’ proposals for a ‘National Development Framework’ (NDF)[i] have made several environmentalists shake their heads in disbelief. The reason? They do not think the framework takes climate change seriously.

The Free Range Action Network, a group supported by The Greenhouse Environmental Fundraising Group in Carmarthenshire, commissioned Mobbs’ Environmental Investigations and Research to critique the proposed National Development Framework.[ii] Author Paul Mobbs concluded: “The National Development Framework 2020-2040 report contains fundamental errors which render, in our view, the strategy chosen unlawful – because it violates the duty on the Welsh Government to implement ‘sustainable development’, and because the strategy cannot deliver the legally-binding requirements of the Climate Change Act 2008.” (p.15)

Aircraft trails across the sky, damaging Earth’s atmosphere

As Greta Thunberg stated during last week’s foot-dragging United Nations climate change conference in Madrid, “The real danger is when politicians and CEOs are making it look like real action is happening when in fact almost nothing is being done apart from clever accounting and creative PR.”[iii]

In Wales we have the Well-being of Future Generations Act 2015 and the Environment Act 2016, as well as the UK’s Climate Change Act 2008, which set a 2050 target for greenhouse gas emissions to be 80 per cent below 1990 levels. The Environment (Wales) Act set out a similar ambition, while the Well-being of Future Generations (Wales) Act tries to balance resource conservation and emission reductions with economic growth and greater wealth, without showing how this unlikely outcome could ever be achieved.

The NDF does not convey any sense of climate emergency, although it does mention decarbonisation, as in this extract from p.60 of the consultation document: “It is vital the region [Mid and West Wales] plays its role in decarbonising society and supports the realisation of renewable energy. There is strong potential for wind, tidal and solar energy generation and development plans should provide a framework for generation and associated infrastructure.”

‘Renewable energy’ here is synonymous with ELECTRICITY, but there are unaddressed problems arising from a switch to electricity, particularly for transport. Paul Mobbs quotes a panel assembled by the Natural History Museum[iv] as writing: “To replace all UK-based vehicles today with electric vehicles (not including the LGV and HGV fleets) would take 207,900 tonnes cobalt, 264,600 tonnes of lithium carbonate (LCE), at least 7,200 tonnes of neodymium and dysprosium, in addition to 2,362,500 tonnes copper. This represents, just under two times the total annual world cobalt production, nearly the entire world production of neodymium, three quarters the world’s lithium production and at least half of the world’s copper production during 2018.” Not exactly an equitable distribution of resources, and it is not at all clear how the UK could commandeer such colossal proportions of world output!

The final proposed outcome of the NDF, outcome no.11, states reasonably enough that “The challenges of climate change demand urgent action on carbon emissions and the planning system must help Wales lead the way in promoting and delivering a competitive, sustainable decarbonised society. Decarbonisation and renewable energy commitments and targets will be treated as opportunities to build a more resilient and equitable low-carbon economy, develop clean and efficient transport infrastructure, improve public health and generate skilled jobs in new sectors.” (p.21).

The Mobbs report counters: “Does the NDF contain a framework to reduce carbon emissions, without, for example, excavating large areas of open moorland to deliver biomass or wind energy projects? No – the NDF contains no set of policies commensurate with dealing with the declared ‘climate emergency’. There is no mechanism because those chosen – from a large roll-out of wind power to electric cars – are not viable within the terms of the strategy itself. The resources do not exist to efficiently build those projects.” (p.12)

Essentially, the NDF proposes a shift from fossil-fuel power to power from renewable energy technologies, overlooking the very large but unquantified consumption of resources needed for the switch to happen. New infrastructure requires cement, steel, aggregates, rare minerals and much more, transported over long distances and transformed by energy-intensive industrial processes.

The Mobbs’ analysis (p.13) is this: “The reality is that, in a cost-constrained world, what matters is achieving those things which reduce carbon by the greatest amount for the least cost. That is not necessarily the production of more ‘green energy’. ….If we look at the development options which reduce carbon in terms of their relative costs or savings, there are many options which produce a better effect than green energy – most specifically, reducing demand. The NDF is silent on many aspects of those alternatives.”

Reducing demand, or making do with less, is rarely heard in the political lexicon, but it has to be an integral part of a plan for the next 20 years. The Intergovernmental Panel on Climate Change (IPCC) issued its stark ’12 years’ warning over a year ago, at the start of October 2018,[v] so now we have less than 11 years to act, unless we are willing to face more extreme, dangerous weather and faster rising sea levels, flooding coastal populations. The IPCC said that to limit warming to 2 degrees C, the CO2 emissions would have to drop 20 per cent below 2010 levels by 2030 and hit zero by 2075. Capping warming at 1.5 degrees C means net anthropogenic CO2 emissions must decline by 45 per cent in the next 12 years (now less than 11) and fall to zero by 2050, requiring deep emissions cuts in every sector on an unprecedented scale.

Urgency is absent from the NDF proposals, which do not even whisper that we have to consume considerably LESS.

Britain agreed to a target of achieving ‘net zero’ by 2050. At the half-way point between 1990 and 2050, there has been a nominal reduction of 40 per cent[vi], achieved by switching away from the most polluting fuels in power stations and by continuing the process of offshoring manufacturing, so that the emissions are other countries’ problems (but still add to the global totals).

Emissions from aviation and shipping are excluded from Wales’, and the UK’s, reduction obligations. So why not expand Cardiff Airport? Import more by sea? Leaving out these important transport categories supports the illusion that we are making much more progress towards climate targets than we are in reality.

The NDF is predicated on hope that human ingenuity will come to our rescue in time, and so until then life can continue as normal and, give or take a bit of wealth redistribution, we can become more and more prosperous.

As Greta Thunberg said to the assembled dignitaries in Madrid, that’s just creative public relations.

[i] National Development Framework 2020-2040 Consultation Draft: 7 August – 1 November 2019, Welsh Government

[ii] A Response to the Welsh Government’s ‘National Development Framework 2020-2040’, by Paul Mobbs, Mobbs’ Environmental Investigations and Research, November 2019.

[iii] Greta Thunberg’s speech to COP 25, Madrid, December 11 2019, on YouTube.

[iv] ‘Leading scientists set out resource challenge of meeting net zero emissions in the UK by 2050’, Natural History Museum, 5th June 2019. https://www.nhm.ac.uk/press-office/pressreleases/leading-scientists-set-out-resource-challenge-of-meeting-netzer.html

[v] Summary in IPCC Global Warming Special Report 2018 | What does it actually mean?https://www.coolearth.org/2018/10/ipcc-report-2/

[vi] Updated energy and emissions projections 2018, Department for Business, Energy & Industrial Strategy, April 2019. https://www.gov.uk/government/publications/updated-energyand-emissions-projections-2018

PDR