The UK Government has published its Carbon Budget and Growth Delivery Plan. Unfortunately, the plan has serious gaps and there are other areas of government policy that appear to contradict these carbon reduction targets.
Introduction
Every five years the Government must produce a Carbon Budget, as required under the Climate Change Act 2008. Such Budgets are revised every five years, but they cover up to 12 years in advance. Many goals in the Delivery Plan are not set to be achieved until 2050, or 25 years from now. Worse, the plan reduces expectations for achieving goals quickly in areas such as green hydrogen, tree planting, peatland restoration, and the allegedly crucial area of carbon capture and storage. The Climate Change Act of 2008 sets the target of reducing all UK greenhouse gas emissions to Net Zero by 2050, not just carbon dioxide emissions. The new plan addresses many subjects; this article deals with a small proportion of them.
The unpromising context for cuts in carbon emissions
The first gap is the most concerning. It is fair to say assumptions underlying the Plan offer only a skeletal version of the context in which we live, and how it may develop. The implicit assumption that future economic growth will be secure, fossil fuel prices predictable, or UK Government policy consistent over time involves “great expectations” indeed.
This context also includes the possible decline or collapse of the Atlantic Meridional Overturning Circulation (AMOC), which would fundamentally alter the UK’s climate to one comparable to that of Canada at a similar latitude. Canada does not benefit from the warming effects of what is generally referred to as the “Gulf Stream”, and as a result experiences much colder winters.
This raises many unanswered questions
Some of the most basic unanswered questions in the Plan include:
- policy alternatives to driving and flying that could reduce carbon emissions;
- commitment to building new homes that meet at least the “Passiv Haus” standard;
- a planning system that continues to support higher emissions, for example through new housing developments with two or more car parking spaces per home;
- support for car-free housing;
- commitments to sustainable retrofitting that addresses high up-front costs, such as those associated with solar PV and heat pumps;
- and transformation of council areas to resemble Denmark or Sweden in terms of sustainable transport and low-carbon heating.
Market failure not recognised
Repeated overt and implicit statements in the Plan suggest that the market system, as we have known it, will remain sustainable and resilient in a constantly changing global environment. Yet, the market system, certainly in the UK, depends heavily on household incomes and the capacity of households to spend.
If, for example, long-term food price inflation occurs as a result of increased droughts and flooding, both in the UK and in countries from which we import food, households will be forced to cut back on other forms of spending in order to afford food. With both substantial increases in water charges (35% in the case of Thames Water in April 2026) and growing uncertainty about the willingness of Government to protect energy users from fluctuating gas prices and the high costs of electricity from future nuclear power stations, there is a lack of consistency in climate policy and a failure of Government to provide adequate public protection.
Returning to food policy, if as many as eight major reorientations are needed, then relying on successive Governments to follow through on such changes requires a considerable amount of optimism. Meanwhile, the prolonged war in Ukraine has undermined that country’s role as a major contributor to global wheat production, further destabilising food markets.
Sustainable aviation fuel?
The Government expresses enormous confidence in the use of ‘sustainable aviation fuels.’ At an international level, however, these fuels are “self-certified” by states, raising questions about the reliability of sources. There are also significant land-use implications, and many well-established criticisms of this idea.
Given the scale and projected growth of the aviation sector, meeting aviation climate goals by 2050 seems highly challenging. If this task is proving difficult even for the United States, it is unclear why it should be any easier for the UK. Moreover, the continued use private jets and airport expansion are treated as compatible with effective climate policies, despite their higher emission impact. The Plan itself does not actually contain any specific measures to curb rising demand for air travel.
“Meeting carbon budgets” or subsidising fossil fuels?
The removal of fossil fuel subsidies should have begun in the early 1990s. At an estimated £17.5 billion per year in the UK, these subsidies represent a substantial available resource that could be redirected towards meeting climate goals. But instead, they are combined with limited action in high-emitting sectors such as surface transport, aviation, shipping (see p.87 of the Plan), and defence.
The Plan (p.11) refers to “enabling policies and proposals” that could potentially reinforce emissions reductions. However, potential is not implementation. Notably, this section of the Plan makes no reference to the UK’s major source of emissions: transport of all its forms. The limited attention given to public transport, and especially incentives for its use, is a serious omission.
Policies such as free bus travel and a 50% reduction in the UK’s exceptionally high rail fares would deliver clear climate and air-quality benefits. Additional policies could include removing the most polluting vehicles from the roads and improved access to e-bike use and ownership.
Climate and health?
The Plan makes reference to Active Travel (p.31). Yet, reducing emissions from vehicles whilst increasing public health depends on expanded investment in this sector. Recent cuts to Government spending on Active Travel directly undermine climate policy, air-quality objectives, and health promotion simultaneously. This contradiction highlights a broader failure to integrate climate policy with wider goals.
Public sector decarbonisation?
The Plan refers to the less than princely sum of £2.5 billion (p.55) for three phases of public sector decarbonisation. Given the scale and needs of the task, such as the investment required for the renewal of hospitals, schools, local government, and council housing, this is inadequate. Whilst additional railway electrification is mentioned (p.56), there is still no commitment to full electrification, which is a basic prerequisite for decarbonisation in the rail sector.
Enforcing energy performance standards?
The Plan refers to Building Regulations and higher energy performance standards (p.32). However, long-term austerity in local government has significantly weakened the capacity to monitor compliance. There is a shortage both of Building Control Officers and Planning Enforcement Officers.
It should be noted that the suggested ‘Future Building Standard’ for reducing fossil fuel use in buildings is not scheduled for implementation until 2028-2050 (p.78). This timescale is absurdly slow given the urgency of emissions reductions. Similarly, Warmer Homes local grants are spread over 2025-2050 (p.83), meaning that many households will continue to wait decades for action, particularly those unable to afford improvements themselves, or those living in rented accommodation.
Land-use in a sustainable future?
Reducing food imports and shifting pastureland towards growing more food crops for people would require a systematic reduction in domesticated livestock, including beef cattle, sheep, goats, and pigs. This is a necessary part of reducing UK methane emissions. Yet, none of these obvious measures are suggested in the Plan. Instead, the focus is limited to the use of “lower-emitting species” (p.77), avoiding the scale of change required.
Hydrogen as a myth
Hydrogen produced using fossil fuels – so called “blue hydrogen” – is the predominant form of hydrogen minimally available in the UK. ‘Green hydrogen’, produced using renewables, remains scarce. It is therefore unclear why either blue or green hydrogen is being promoted for domestic heating systems, particularly when heat pumps do not require the infrastructure that would be needed to create hydrogen in the first place. There are grounds for suspecting that this emphasis reflects a desire to satisfy the interests of the oil industry, rather than an evidence-based approach.
Misleading statements
The Plan claims that the UK is the ‘sustainable finance capital of the world’ (p.7). However, British banks are major investors in fossil fuels. Barclays is the leading European bank for fossil fuel investment; HSBC is among the leading fossil fuel financiers in the developing world. Lloyds and NatWest are also significantly involved. Therefore, the credibility of the Plan’s claim of leadership in sustainable finance is undermined.
Unsustainable policies generate more emissions
Separating electricity generated from renewable sources from polluting sources – including nuclear – in energy bills would allow consumers to see how much cheaper renewable electricity actually is. It would also allow households to avoid fluctuations in gas prices. The current structure of energy pricing hides these differences and, therefore, sustains higher emissions and costs.
Housing and infrastructure
The Government is not reaching its target of building 300,000 new homes per year. However, in terms of emissions, resource use, and any Government commitment to a circular economy, it is unclear why new-build housing remains the primary emphasis. Empty homes and wasted parts of the existing built environment are abundant and could be prioritised for sustainable retrofitting as genuinely low-cost housing.
Urban regeneration strategies could also include building apartments above surface-level of car parks, making good use of land that is already developed and located near existing facilities. Regenerating urban areas in this way is better than creating new communities, using resources efficiently and avoiding additional emissions from new infrastructure.
Conclusions
Before 2035, the introduction of a Green New Deal in each council area, incorporating climate goals, could deliver substantial emissions reductions whilst also supporting job creation. In general, like much of Government policy, the Plan places insufficient emphasis on expanding the various roles of local councils and on delivering a range of effective and integrated policies at a local level.
The Government’s Carbon Delivery Plan therefore has a profound localities gap, forcing us to question its ability to achieve sustained and socially just emissions reductions.
Thanks to Hazel Dawe and Professor John Whitelegg for their comments.
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