Draft Carbon Neutral Roadmap Review (S.R.7/2022): response of the Minister for the Environment

Findings

Comments

1

Jersey has previously failed to meet its targets to achieve 80 per cent reduction in carbon emissions by 2050 under the Kyoto Agreement, and as set out in the Pathway  2050:  An  Energy  Plan  for Jersey.  The  GoJ  considers  that  the Carbon Neutral Roadmap is more likely to succeed where Pathway 2050 failed due to the level of funding (£23 million) provided  for  the  Roadmap's  first delivery  phase  of  policy  initiatives (2022-25).  Additionally,  with  there now being a clear trajectory of actions outlined  up  to  2050,  to  facilitate commitment to the pathway. However, meeting  the  trajectory  for  the  Paris Agreement  to  net  zero  by  2050  will remain a challenge which relies on the GoJ  to  continue  to  meet  sufficient funding  requirements  over  the  long term.

Agree.

SP1  covers  the  expected  emissions  reduction trajectory as well as a programme for monitoring and review of the long-term programme to reach net-zero  by  2050  with  a  milestone  of  carbon neutral by 2030.

SP  3  covers  the  challenge  of  the  long-term financing  which  will  be  addressed  by  future Assemblies.

Findings

Comments

2

Strategic  policy  two  of  the  Carbon Neutral  Roadmap  assumes  that electricity  imported  to  Jersey  will remain  carbon  free  or  low  carbon, affordable and reliable going forward. The Panel raised concern regarding the assumption  on  which  the  policy  was being  based  given  that  France  had recently shut down three of its nuclear power plants and the impact this might have  on  both  Jersey's  low-carbon emissions status and the reliability of supply to the Island. It is unknown how (or if) this affects Jersey's greenhouse gas  emissions  inventory  accounting, however,  the  GoJ  anticipates  no disruption  to  the  Island's  electricity supply.

Noted. SP2 covers a review of the energy market and includes provision to further address Jersey's long-term security of supply.

3

A  significant  consideration  for  the Carbon Neutral Roadmap is the longer- term security of supply and provenance of  the  Island's  power  and  strategic policy two of the Roadmap indicates the requirement  for  an  energy  market review  which  would  include consideration  for  Jersey's  electricity supply.  The  likelihood  of  Jersey continuing  to  have  some  degree  of connectivity  to  the  European  market was considered high, however, it was emphasised that recent global tensions, such as Brexit, and energy volatility, was  placing  urgency  on  Jersey  to consider its security of supply.

Agree. See SP2 energy market.

4

The Citizens' Assembly recommended the  exploration  of  Jersey-based renewable  energy  generation, infrastructure,  and  the  promotion  of self-sustainability forms of renewable energy  sources,  to  reduce  Jersey's dependency  on  the  French  grid.  The GoJ clarified that whilst there is long- term  thinking  for  these  types  of opportunities (such as an offshore wind farm)  even  if  there  was  immediate agreement  to  build  an  offshore  wind

Agree. SP2 post-consultation version addresses this issue.

Findings

Comments

farm, it would still take several years to accomplish.

5

With  a  proposed  target  of  2030  for Jersey to achieve carbon neutrality, the Island would need to consider shorter- term  initiatives  that  were  currently feasible to achieve. It was noted that the Roadmap's  first  delivery  phase concentrates  on  the  immediately available options and in order to ensure the  easiest  way  to  reduce  carbon emissions, electrification is being used as the first step. However, sustainable energy  generation  from  sources  like wind and tidal will be considered in the long-term.

Agree.  Please  see  SP2  as  above  –  the  energy review  and  strategy  will  consider  long  term security, sustainability and affordability

6

To  ensure  a  selection  of  the  policy initiatives which will provide the best value for money in respect of the carbon reductions they intend to provide for Jersey over the next four years, a multi- analysis  tool  was  used  to  score proposed policies and prioritise them according  to  their  carbon  abatement potential and other relevant factors in order to identify the best outcome for the available funding.

Agree.

7

Currently,  financing  of  the  Roadmap has  remained  within  the  Climate Emergency  Fund.  However,  as  a substantial amount of money will be required  to  fund  the  Roadmap  going forward,  consideration  for  other financing options will be researched by the GoJ as part of strategic policy three.

Agree.  This  is  covered  in  SP3  the  Financing Strategy

8

Additional significant funding will be required to achieve the Island's carbon neutral and net-zero targets and the cost of future delivery plans will need to be considered in future Government Plans. As  such,  a  financing  strategy  for Jersey's  complete  decarbonisation journey remains unclear. Considering that  proposals  for  new  economic instruments will need to be considered in the medium to long-term to continue

Agree.

Findings

Comments

to  fund  the  trajectory  of  Jersey's pathway to net-zero, it is noted that a longer-term  financing  strategy  is planned  to  conclude  in  2024;  with associated measures incorporated into the  Government  Plan  2025-28.  It  is further  noted  that  the  economic instruments  will  be  subject  to consultation and impact analysis.

9

There was confusion amongst the GoJ consultation  responses  regarding  the terminology  for  carbon  neutral'  and net-zero'  and  how  either,  or  both, positions could be achieved as part of Jersey's pathway. The link between the two  positions  did  not  appear  to  be clearly  understood  and  highlights  a need that further information is required to inform the public that through Jersey aligning with the Paris Agreement (net- zero  by  2050)  that  becoming  carbon neutral at a target date along the way would  also  remain  achievable.  In response to this, the GoJ has revised its SMART  objectives  across  policies, where  appropriate,  to  address  the concerns raised.

Agree.

10

Current proposals for governance and oversight  of  the  Carbon  Neutral Roadmap include: the establishment of a  Ministerial  portfolio  with responsibility for Energy and Climate Change; a new Standing Scrutiny Panel on Energy and Climate Change; a new Programme Office created within the Strategic  Policy,  Planning  and Performance  Department;  and  a Carbon Neutral Network' to facilitate stakeholder  engagement  and  policy development.

Agree.

11

There is no formal framework proposed within the Carbon Neutral Roadmap for independent,  scientific  oversight  and governance,  despite  this  being considered best practice across the UK and Europe. This raises concern with

Agree. The Panel proposed a related amendment to  the  Carbon  Neutral  Roadmap  which  the Minister accepted as amended, and the Assembly adopted.

Findings

Comments

the Panel given the long-term nature of the Roadmap and that technology will continue  to  advance.  Policies  and delivery  plans  will  need  to  be continually  updated  in  line  with scientific  and  technological advancements,  as  well  as  Jersey's societal and economic commitments.

12

Framework climate change legislation, along  with  a  group  of  autonomous experts, is considered by experts to be beneficial  in  guiding  mitigation  and adaptation  planning.  Jersey  does  not currently have any climate framework legislation and it was considered by the Carbon  Neutral  Steering  Group  that such  primary  legislation  was disproportionate  to  Jersey's  size. Instead, it was felt that requesting the Paris Agreement be extended to Jersey was  a  high  profile,  international commitment and that this, coupled with the  proposed  governance  processes, was  sufficient  to  deliver  on  carbon emissions  reduction  targets.  Despite this, the Minister for the Environment considers that there would be merit in pursuing  over-arching  legislation, provided that doing so would not hinder the  delivery  of  the  proposed  Carbon Neutral Roadmap policies.

Agree. The Panel proposed a related amendment to  the  Carbon  Neutral  Roadmap  which  the Minister accepted as amended, and the Assembly adopted.

13

Concerns were raised by Ministers that establishing  an  independent  scientific council would be too costly. However, the  Panel  has  identified  that  it  is plausible to establish and operate such councils on varied budgets, depending on their scope and size. For example, the size and available resources vary across different independent scientific councils  in  Europe,  with  members ranging  from  4  to  15,  and  annual budgets  varying  significantly  from 200,000  to  4  million.  A  similar approach has already proven possible in Jersey through the establishment of the Expert Advisory Panel for the Citizens'

Noted – costs as quoted are conservative as they only reflect costs of a short period of engagement for  specific  activity,  rather  than  reflecting  the establishment of an ongoing body that will attract additional administration and logistical costs.

The Carbon Neutral Roadmap as amended will required  the  presentation  of  a  fully  costed proposal by the end of 2022.

Findings

Comments

Assembly  on  Climate  Change  which had a 6-member membership and cost £22,000 (based on payments of £500 per  day  to  5  members  of  the  expert panel).

14

Owing to concerns over the lack of a formal framework for governance and independent,  scientific  oversight  and the known benefits this can bring, the Panel  lodged  an  amendment  to P.74/2022 which seeks to establish an independent, scientific climate council to  enhance  the  governance  and oversight of the long-term delivery of the Carbon Neutral Roadmap.

Agree. The Panel proposed a related amendment to  the  Carbon  Neutral  Roadmap  which  the Minister accepted as amended, and the Assembly adopted.

15

Ministers and members of the Carbon Neutral  Steering  Group  are  not completely  aligned  on  the  speed  at which  electrification  of  vehicles  is proposed. Whilst in agreement with the policy  direction,  the  Minister  for Infrastructure  believes  that  the transition away from fossil fuels to the electrification of vehicles is happening too fast and that Jersey is not prepared.

Noted.

16

There  are  significant  challenges relating  to  the  infrastructure  and technology  requirements  for  electric vehicles.  Particularly,  the  number  of charging  points  which  are  currently deemed far from sufficient to meet the required future capacity, as well as how and where to locate them; and necessary upgrades  to  cabling  to  accommodate increased  demand  on  the  electricity supply.

Noted. This is reflected in Strategic Policy 2 (the energy  market  review)  and  TR1  (Speeding  up adoption of electric vehicles).

17

Jersey  Electricity  would  like  to  see some  measures  to  the  proposed subsidies for EV chargers "fine-tuned" to avoid unintended consequences. For example, that financial support for EV chargers  is  reserved  for  smart' chargers  "to  ensure  charging  is restricted to off-peak, overnight periods when demand on the grid is low, power is  cheaper  for  the  consumer  and

Agree.

Findings

Comments

capacity is plentiful." The Panel notes that it is the GoJ's intention to work on the policy details in further consultation with key stakeholders in delivery phase 1.

18

Policy  TR2  Vehicle  Scrappage Incentive' has been removed from the Carbon  Neutral  Roadmap  owing  to concerns  raised  in  the  public consultation  that  the  value  of  the incentive  would  not  be  sufficient  to meet the policy's aims and for potential abuse of the system. The £410,000 in funding previously allocated to Policy TR2  has  been  redistributed  across policies  HT3  Energy  Performance Certificates';  TR1  Speeding  up adoption of electric vehicles; and TR3 Supporting transition fuels.'

Agree.

19

Concerns were raised during the GoJ public consultation, and to the Panel, regarding the absence of a policy within the draft Carbon Neutral Roadmap for the  adoption  of  standard  grade renewable  content  petrol  and  diesel. The Panel considered the possibility of an  amendment  to  address  this  gap. However, it was observed in the revised lodged version of the Carbon Neutral Roadmap1 that policy TR3b has been included. This proposed policy outlines the research and market analysis that will be undertaken in consultation with industry  stakeholders  to  determine  a policy  position  on  the  suitability  of renewable  content  fuels  for  Jersey regarding financial, infrastructure and spatial implications and options by the end of 2022.

Agree – policy TR3b was included in the final version of the Carbon Neutral Roadmap.

20

Policy TR5 End the importation and registration of petrol and diesel vehicles that are new to the Island from 2030' has been designed to ensure that Jersey does not become a dumping ground'

Agree.

Findings

Comments

for older, polluting vehicles. The policy will  be  developed  with  further stakeholder  engagement  and consultation,  and  it  is  the  further intention  of  the  GoJ  to  create  an exemption for historic, classic vehicles within the draft legislation.

21

The Sustainable Transport workstream has  been  impacted  by  the  Covid-19 pandemic and as result, progress has been slower than anticipated. It is the intention  for  the  GoJ  to  publish  a Sustainable Transport Roadmap by the end of 2022 and it is envisaged that these  policies  will  form  a  similar Roadmap-type framework to that of the Carbon  Neutral  Roadmap.  Public consultation responses highlighted the importance that the needs of disabled Islanders are taken into consideration when  developing  the  Sustainable Transport Roadmap, as well as ensuring a Just Transition'.

Agree.

22

Since  preparing  the  draft  Carbon Neutral Roadmap, Ports of Jersey has become  a  signatory  to  the  Toulouse Declaration (an agreement to help the aviation  industry  become  more  eco- conscious) and has committed to ensure a net-zero future.

Agree.

23

The GoJ acknowledges that a potential barrier to policy HT1 – Supporting low carbon  heating  systems  and  home insulation' is the lack of available on- Island skills and expertise to roll this policy  initiative  out  faster.  However, the funding for this in the first delivery phase is capped and will therefore limit the number of heating boilers which can realistically be changed, allowing more time for the GoJ to work on a skills strategy and to be able to train local people to deliver more heating system transitions in the future.

Agree.

24

A fundamental concern was raised in the GoJ public consultation regarding

Agree.

Findings

Comments

policy  HT1  Supporting  low  carbon heating systems and home insulation' and  ensuring  a  Just  Transition.'  To ensure that Islanders are not adversely impacted  by  increased  income inequality  as  a  direct  result  of  the proposed policies, the GoJ confirmed that a distributional impact assessment of the policies was carried out, which helped to identify where things may be made unequal for Islanders and how to mitigate this.

25

The  proposed  deadline  of  achieving Policy  HT2  Review  building  bye- laws' in the Carbon Neutral Roadmap is 2025 and not 2023 (as recommended by the Citizens' Assembly). The rationale provided for this by the Minister for the Environment is that 2023 is deemed too soon for the construction industry to be able  to  adjust  to  new  building regulations.  This  time  is  considered necessary for the industry to train and up-skill in new building methods, as well as new materials and equipment.

Agree.

26

Alternative  options  for  identifying rental properties are being considered by the GoJ to be able to pursue policy HT3 Energy Performance Certificates' given that a landlord licensing scheme is noted as a dependency for this policy but has not yet been adopted by the States Assembly.

Agree.

27

The  Minister  for  Children  and Education acknowledges that there may be challenges in relation to resourcing the ambitious deadlines set against the objectives of Policy EN4 Delivering the  COP26  Pledge'  due  to  multiple agendas  currently  being  addressed within  the  Department  for  Children, Young  People,  Education  and  Skills, however the Minister has stated that the Department  remains  committed  to achieving the objectives as laid out in the COP26 education pledge.

Agree.

Findings

Comments

28

Concern was raised in a submission to the  Panel  that  whilst  work  had previously  been  undertaken  by  GoJ with Cranfield University to identify and implement additional measures to increase  carbon  sequestration',  soil carbon  sequestration  policy  was notably absent in the Carbon Neutral Roadmap.  When  questioned  as  to whether this had been unduly omitted from  the  Roadmap,  the  Panel  was advised by GoJ that this was reflective of  Jersey's  intensive  agriculture industry  and  that  the  more  soil  is disturbed  due  to  intense  agricultural practice, the less carbon it sequesters. The Panel noted that there was funding set aside for a PhD student to carry out further work to discover where there are possibilities  for  increased  organic matter in soil, which can in turn lead to carbon sequestration.

Agree.

29

The  Panel  is  satisfied  with  how  the Citizens'  Assembly  recommendations have  been  fed  into  the  policy development process. Moreover, where recommendations have been rejected or will be considered for the medium to longer  term  development  of  the policies, the Panel is satisfied with how the GoJ has demonstrated any future alignment,  or  the  reasons  for  the rejection of the recommendations. The Panel notes that six recommendations were rejected, in the main, to assist with ensuring a Just Transition.'

Agree.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

In  the  Ministerial Response  to  this  report, the  Minister  for  the Environment  should expand  further  on whether the closure of the three  nuclear  power plants  in  France  affects the  provenance  of  the electricity  supply  to Jersey from that of zero emissions nuclear power to  a  carbonised  power source, and if so, how this is being accounted for in Jersey's  greenhouse  gas emissions inventory.

ME NV

Accept

–  see commen ts.

In  line  with  IPCC  reporting requirements,  emissions  are  accounted for in country of origin, so any emissions arising  from  French  electricity generation are accounted for within the French emissions inventory.

The  Carbon  Neutral  Strategy2 established  the  principle  that  Jersey would take responsibility for the scope 2 emissions  arising  from  electricity generation imported from France. In line with this commitment analysis has been carried out and the findings published in a  report3.  The  report  shows  that  our scope 2 emissions are very low, in 2020, 0.81%  of  Jersey's  scope  1  and  2 emissions were attributable to emissions from electricity generation in France.

JE plc have an agreed contract with EDF for the supply of certified low carbon electricity. This means that any changes to  the  internal  operating  market  or infrastructure do not directly impact the emissions  factor  of  the  electricity supplied to Jersey.

Q1  2027

–  end  of the current contract with EDF.

2

As part of its long-term financing strategy, which is  currently  under development until 2024, the Government of Jersey should  consider  how Covid-19  recovery packages  could  be utilised  moving  forward to  provide  support investment  into  Jersey's economy (post-pandemic recovery),  whilst advancing  Jersey's environmental goals and

ME NV/ Co M

Accept

It  is  recognised  that  this  objective overlaps  with  the  environment  pillar within  the  Future  Economy  Strategy. Opportunities to use funding such as the Covid-19  recovery  package  and  other incentive schemes such as the recently approved technology Accelerator Fund (P.75/2022) to invest in the economy and advance  Jersey's  environmental objectives whilst greening' businesses will continue to be explored.

Q4 2023.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

supporting businesses to go green.

3

The  Government  of Jersey  should,  on adoption  of  the  Carbon Neutral  Roadmap  and throughout  each  policy package  life  cycle,  roll out  suitable  public awareness  raising campaigns  in  order  to educate  and  familiarise the  public  with  climate change  terminology,  as well  as  communicating policy aims and outcomes as simply as possible and across  multiple communication channels.

ME NV

Accept  

The delivery of education and awareness is  considered  across  Carbon  Neutral Roadmap and within the policy package (SP4).  The  following  policies  have  a particular  focus  on  education  and awareness:

• OE1  -  Promoting  low-carbon lifestyles.

• EN2 - Create a Carbon Neutral Alliance.

• EN3 - Developing supply chains and  on-Island  skills  for  a sustainable economy.

• EN4  -  Delivering  the  COP26 education pledge.

Much of this work will be led by the Sustainability  and  Climate  Change Engagement  Manager  (previously  the eco active programme manager) and the role has been made full time to reflect the imporance of this work. An assistant role will also be advertised in due course.

4

The current Minister for the  Environment  should formally advocate to his successor,  through acceptance  of  this recommendation,  that  a Ministerial  Decision  be signed at the start of the new  Government  term which instructs officers to draft  climate  framework legislation  with  the intention  of  this  being lodged in the States for debate before the end of Q1 2023.

ME NV

Reject

Please see the Minister's response to the Panel's  letter  on  the  Draft  Carbon Neutral  Roadmap  Review  –  Written Questions, dated 28 March. In summary, the  Minister  is  supportive  of  the principle.

"As a retiring Minister, I am of the mind that in future there could be a case for introducing a law, especially if it can be progressed  in  conjunction  with  the establishment of a portfolio for Energy and  Climate  Change.  However,  this work  is  very  much  a  task  for  my successor  and  the  new  Council  of Ministers to consider and should not in any way hinder the crucial first step that is  the  CNR  when  it  comes  to  our addressing climate change."

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

Various policy options will be presented to  the  Minister's  successor  for consideration  which  will  include legislative mechanisms.

It should be noted that the timeline to deliver a new law by end of Q1 2023 is not  feasible.  A  new  law  will  require significant drafting time; comprehensive consultation  with  the  public,  key stakeholders,  the  new  Scrutiny  Panel, and  with  Council  of  Ministers;  and funding will need to be allocated in the next Government Plan which will not be debated until December 2022.

5

The  Minister  for  the Environment  should support  the  Panel's amendment  to  establish an independent, scientific climate  council  and subject to the successful adoption  of  the amendment by the States, should ensure that before he leaves office Officers are instructed to set this into  motion and  so  that the  necessary groundwork can progress prior  to  the  new Government term.

ME NV

Partiall y accept

The  Panel  proposed  a  related amendment  to  the  Carbon  Neutral Roadmap which the Minister accepted as amended, and the Assembly adopted.

Q2 2022

(complet ed).

6

The  Government  of Jersey  should  ensure that the  research  and market  analysis  in consultation  with industry stakeholders for policy  TR3b  must  also include consideration for how the Government will ensure  a  level  playing field  and  competitive market across the Island's

ME NV

Accept  

The policy position paper on TR3b will be  produced  in  line  with  all  relevant legislative  framework  and  regulatory requirements.

Q1 2023.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

fuel industry as to avoid any  competitive advantage  as  an unintended  consequence of policy TR3 and TR3b.

7

The  Government  of Jersey should ensure that as part of its preparation of  the  Sustainable Transport  Roadmap,  the needs  of  disabled Islanders  are  taken  into full consideration, as well as how to ensure a Just Transition' within all the proposed policies.

ME NV / MI NF

Accept

The  Second  Interim  Report  on  the Sustainable Transport Policy published in  December  2021  highlighted  ten decision  making  principles  which included:

2. to conform with the Jersey mobility hierarchy (which places children, elderly people  and  people  with  sensory  or mobility  impairments  as  the  highest priority).

3. to  improve  transport  options, including  parking,  for  people  with mobility impairments.

5. to Invest in a better bus system that more  people  want  to  use  and  that  is accessible to all.

A Just Transition' will be central in the development  of  the  Sustainable Transport Roadmap.

End  of Q4 2022.

8

As  part  of  regular, ongoing governance and oversight  of  the Roadmap,  the Government  of  Jersey must continue to review impact assessments of its policies  on  an  annual basis,  to  ensure  that  a Just  Transition'  is adhered to throughout the life of the Roadmap and with  a  particular watching brief on global energy prices.

ME NV

Accept  

Ongoing review impact assessments will be carried out as  part of the ongoing governance  and  reporting  schedule. Policies will be monitored and reported on in line with CPMO major projects reporting requirements. A data strategy is under development to benchmark and set  out  the  KPI's,  monitoring  and reporting  requirements  for  the  policy interventions. A full DIA will be carried out at the 4-year review period. As the relevant  data  sources  to  enable  the analysis are not updated annually, full assessments will only be carried out at each 4-year review period in order to inform  the  incoming  Government  in setting priorities and funding through the government  plan  process.  Work  is

End  of first delivery phase 2026.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

ongoing with Statistics Jersey to align data collection and analysis.

9

The  Government  of Jersey  should  seek  to complete and publish the findings  of  the  ongoing soil  research  which commenced in 2019 with Cranfield  University  by the end of Q2 2023. The aim of which would be to provide  a  clearer indication  in  relation  to Jersey's soil quality and potential  for  carbon sequestration and with a view to this providing a suitable evidence base to inform  whether  soil carbon  sequestration should be considered an advantageous  policy direction for inclusion in the next delivery phase of the  Carbon  Neutral Roadmap.

ME NV

Accept  

There is ongoing work with respect to soil  quality  including  the commencement of a PhD study in 2022. This PhD will conclude in time for its recommendations to be considered in the next term of delivery. Interim findings can be published in Q2 2023.

Q2 2023.