31st January 2022

J Young Esq.
Minister for the Environment
Government of Jersey
Broad Street
St Helier
Jersey C.I.

Dear John

The Carbon Neutral Roadmap  Consultation

 The National Trust for Jersey very much welcomes the draft roadmap and the drive towards carbon neutrality. Having reviewed the document the Trust  would like to make the following observations for your further consideration:

Strategic Policy 1

It would be helpful if it could be clearly stated within the policy how much we have already reduced our emissions in 2022 as compared to the 1990 baseline as opposed to simply stating that we need to reduce them by 68% from 1990. Otherwise, the target is unclear and does not provide a guideline in terms of future achievement.

Equally if Jersey can reduce its emissions by a further 10% between 2030 and 2035 then this would suggest that it would be possible to achieve 12% within 10 years namely 2045 especially given the technological advances that will have occurred during that time. Jersey should not feel it is wed to international or UK targets but indeed should aim to exceed those targets where practical and feasible to do so.Strategic Policy 2

It is disappointing to see that there is no recognition of the benefits to be secured by working with our immediate neighbours to deliver a sustainable, secure and affordable energy market. By sharing and developing resources both in terms of renewables, technology and infrastructure there is a real opportunity to deliver an energy framework for the Channel Islands as a whole, which would potentially enhance purchasing power, mutual co-operation and energy sovereignty in the longer term.

The Trust considers that it is important to acknowledge that whilst benefitting from low-carbon energy from France this also comes at an environmental price given the nuclear waste legacy.

Strategic Policy 3

4.21 The Trust would question the suggestion that such investment by this generation should be viewed as solely benefiting future generations. Some measures will have immediate benefits as clearly illustrated throughout the strategy document including addressing fuel poverty and improving our environment on many levels

It would be helpful to have an indication as to the potential income to be generated from the proposed new economic instruments. Otherwise the public is none the wiser as to the value to be accrued and therefore it will be difficult to win support for such initiatives.

The Trust also believes that aviation and marine fuel should be taxed in collaboration with Guernsey and this should be done in an incremental manner to facilitate an appropriate transition period.

Strategic Policy 5

The Trust fully endorses this policy and very much welcomes the commitment to local reduction and sequestration projects before the purchase of off-Island offsets.

The Roadmap

Page 42 – The Trust believes that it is crucial for the roadmap delivery plan to be updated and reviewed on an annual basis given the urgent need for substantive progress and the regular need to review technological advances. This would also reflect that Jersey GHG emissions are calculated on an annual basis. This strategy must not be subject to the political cycle and the Trust is of the view that progress should be reviewed by an independent advisory body similar to the Fiscal Policy Panel which would provide the Environment Minister and States Members with advice and recommendations regarding Jersey’s progress towards carbon neutrality. Such a body could also be charged with reviewing the Island’s environmental achievements in four other core areas as advocated by Earthshot namely:

Protect and Restore Nature
Clean our air
Revive our oceans
Build a waste free world

The Panel could comprise 5 experts to reflect the five core areas. The Panel would be paid in a similar fashion to the Fiscal Policy or the Architecture Commission and could be funded by the Climate Emergency Fund or a private benefactor thereby not requiring additional budget spend.

7.6 Reduce the need to travel

Regrettably the Trust considers that little consideration has been given to recreational/leisure journeys and how this might be actively addressed. A comprehensive householder survey would help identify why people make such journeys and would be able to help inform future travel policies. For example, do we have a sufficient public transport network to our beaches/coastline/out of town retail facilities? Should provision be made within buses for carrying larger items? It is hoped that these key issues will be actively addressed in the forthcoming sustainable transport policy

Also the Trust considers that intelligent delivery services should be afforded greater attention and potential investment. During Covid delivery services became second nature for certain food retailers and there is a real opportunity to build upon and develop this fledgling initiative in partnership with the likes of Digital Jersey, Jersey Post and Jersey’s Chamber of Commerce.

7.10 Shifting journeys to less carbon intensive forms of travel

The Trust welcomes the ambition, but it should be acknowledged that cycle travel will only be more widely adopted if safe cycle routes are provided. This requires significant investment as well as over-riding commitment to deliver projects for the benefit of the majority even if this requires statutory intervention. The cycle path at St Peter’s Valley is a good example of what can be achieved and looking further afield the cycle networks that have been established in small islands such as Ile de Re are a valuable exemplar.

7.24 Reducing demand for energy in buildings

There is no acknowledgement that increasing energy efficiency in historic buildings may prove challenging and that some dispensation maybe required to ensure that the historic significance of buildings is not unduly compromised such as alterations to historic windows.

The Trust would question the need to undertake an energy efficiency assessment every time a new lease is issued for a rental property. If the building has not changed since its last assesment it is difficult to see what benefits would be accrued other than additional bureaucracy and unnecessary expense. Would it not be preferable to request a new assessment to be undertaken if any physical alterations have been undertaken since the last lease similar to the current Parish rates assessment form. This would still enable EPCs to change and reflect those buildings that are on a continuous path of improvement.

7.26 Switch to low carbon energy sources

The Trust does not understand why the installation of new fossil fuel boilers could not be cease much sooner than 2030 and would suggest a target date of the end of 2025. This would reflect  the proposed building law amendments highlighted under HT2.

Figure 19 Other Emissions

Blue Carbon – The Trust does not consider it is satisfactory to continue to explore the potential for blue carbon for the next 8 years and only start to protect, enhance and expand marine sequestration and biodiversity from 2030 onwards. Such a journey fails to acknowledge the current biodiversity crisis that we are facing as well as the significant threats our marine environment faces from inappropriate activities.

Given that the marine spatial plan will be completed by no later than the end of 2023 the Government should then be able to introduce scientifically based management measures to protect and enhance our marine resources including sequestration opportunities.  The Trust is of the view that this could be delivered either through the designation of a Marine Park or a network of Marine Protected Areas equivalent to 30% of Jersey’s territorial waters. 

The Trust therefore considers that Figure 19 needs to be duly amended with work on protection, enhancement and restoration reflecting the work on the spatial plan as well as Bridging Island Plan policies..

Agriculture – The Trust believes that the agricultural sector will need to implement new agricultural practices well before 2030. It is foreseeable that some food products will start to have carbon labelling within the next 3 to 5 years (see text for scope 3 emissions) and therefore it is crucial for the industry in partnership with Government to seek to reduce their carbon footprint at the earliest opportunity. This is particularly pertinent for high quality niche products which wish to maintain the integrity, value and desirability of their brand.

Practical Considerations P60

The Trust would question the statement “that electric cars will be limited or non-existent until the necessary charging infrastructure is in place”. Whilst charging infrastructure will be necessary the Trust does feel that this is often over-emphasised as a particularly large hurdle for a transition to electric vehicles. Most cars will be charged on a weekly basis at home and the necessary infrastructure can be installed relatively easily. It may be more challenging to install charging points for shared parking spaces and apartments, but it is not insurmountable especially as charging speeds will increase rapidly over the next few years.

Transport Policies TR2

The Trust believes that aviation and marine fuel, particularly in relation to private leisure activities, should be taxed in collaboration with Guernsey and this should be done in an incremental manner to facilitate an appropriate transition period.

The Trust also feels that greater consideration needs to be given to the importation of goods and in particular whether there should be an increased emphasis on procurement of goods from the continent as opposed to the UK mainland.

Heating HT1

The Trust believes this subsidy should have an extended period of implementation as it is unlikely that the manpower resources and expertise are available to implement this at such short notice. As a result, the proposed subsidy could be heavily eroded by inflationary pressures.

Energy Performance Certificates HT3

Please see comments under 7.24

Decarbonising Government and Create a Carbon Neutral Alliance EN1 & EN2

It is disappointing to see the disparity between the funding allocated to Government and the Climate Action Fund. It would be helpful to see how the figure of £500,000 was calculated given that this will be applied to projects across the whole of the Island including the charitable sector.

EN4 Delivering the COP26 education pledge:

The Trust welcomes a review of the quality and effectiveness of climate change education by July 2022 and enhanced training for schools. It is felt that the inclusion of an independent party in the review process is important, and that any improvements to climate change education should be embedded into both the Primary and Secondary School science curriculums. We recognize the support of ECO schools, however without being a curriculum requirement, climate change education may end up being marginalised in favour of other mandatory subjects.

It is important that the findings from the study referenced in ‘The Carbon Neutral Roadmap and the Children and Young People’s Plan 2019-2023: The Children and Young People’s Plan’, of the areas young people would like to see further education in (‘the potential impacts of climate change in Jersey, why it is important to take action, and most importantly what changes and actions can be taken by individuals to reduce their carbon footprint’) are kept at the forefront of the review, so that the Island’s young people’s specific climate change education needs are a part of the curriculum, in turn ensuring all schools focus on this.

As one of the 4 Outcomes in the Plan is ‘Be Valued and Involved’, it is important that the roadmap and resulting policies that directly or indirectly affect them are disseminated via teachers. Therefore, this should be included in teacher training, and possibly added to all KSs within the Jersey PSHE curriculum.

Blue carbon biodiversity and sequestration EN5

The Trust very much welcomes this policy but would also like to see a commitment to protecting our existing blue infrastructure as a whole and not just focusing on sea grass beds. Other seaweeds including kelp also have the ability to absorb significant carbon and should be duly recognized.

The Trust would also like to see a recognition of the value of restoration for addressing the biodiversity crisis as opposed to simply focusing on protection. The National Parks in the UK are a good example whereby landscape protection has been delivered over the years but little biodiversity enhancement. Restoration projects could be applied to both terrestrial and marine landscapes.

TR2 – Vehicle scrappage incentive

The Trust believes consideration should initially be given to limiting this incentive to one vehicle per household to ensure greater equity and avoid scrap vehicles being traded to secure green credits

TR7 – Green Number Plates

The Trust would question the value of this initiative in terms of seeking to positively engage and encourage all sectors of society to be part of the Island’s journey towards carbon neutrality.

HT2 – Update building bye-laws

The Trust believes that the policy should acknowledge the challenges presented by historic buildings and that it is paramount to protect and conserve historic significance.

HT3 – Energy Performance Certificates

Please see comments under 7.24

In conclusion the Trust truly hopes that its comments are seen as being constructive and useful in helping the Minister to finalise this incredibly important strategy. Whilst much emphasis has been placed on reaching targets for carbon neutrality, it is also absolutely crucial that Jersey’s Government is able to convey a positive vision for this strategy which illustrates the myriad of additional environmental benefits to be secured including cleaner water and air, better health, eradication of fuel poverty, restoration of biodiversity, increased leisure opportunities, reputational enhancement and reduction in road noise to name just a few. Hopefully this will help to illustrate that the required investment is not solely about reaching carbon neutrality, which some will consider to be an intangible and meaningless target, but rather investing and improving our Island’s environmental infrastructure for both this generation and those who follow on.

Yours sincerely

Charles Alluto
CEO of The National Trust for Jersey




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