Rt Hon John Major MP The Prime Minister 10 Downing Street London SW1A 2AA 16 August 1996
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Unsustainable Developments on Britain's Atlantic Frontier
I am writing to you to ask for your action to alter the pattern of development currently being encouraged by your Government in the area known as "West of Shetland" or the "Atlantic Frontier" and, more generally in the United Kingdom.
These are issues of UK policy with global significance. As you yourself said in respect of Rio commitments and global warming: “The environmental buck stops in our backyard - nowhere else”.
As I know you understand, it is difficult to define “sustainable development”. It is however easier to identify some specific elements of development that are clearly unacceptable on environmental grounds, and others which are part of the solution if we are to achieve a future in which nature is protected together with livelihoods.
Solar electricity for example, is a technology with an enormous and (in the UK) unrealised potential, without the environmental disbenefits inherent in generation from nuclear or fossil fuels.
Certain ecological communities are by their nature, more fragile and prone to catastrophic damage as a result of development pressure, than others. One such is the very deep sea environment where species diversity may be high but energy cycles are low, and biogeochemical and life cycles are long, making fish and other wildlife very vulnerable to exploitation.
If the Rio ‘Earth Summit’ commitments or the concept of ‘sustainable development’ are to mean anything, society must set itself on new trajectories of development. On the one hand these must neither harm particularly vulnerable ecosystems, nor continue the use of technologies with unacceptable global environmental impacts. On the other, they must vigorously embrace new technologies and practices which are part of the solution. This is recognized in Principles 8 and 9 of the Rio Declaration which state that “States should reduce and eliminate unsustainable patterns of production and consumption” and, enhance the development of “new and innovative technologies”.
All our experience in campaigning for ‘solutions’ and that of those in industry attempting to implement them, shows that this requires a Governmental policy commitment and framework, as well as action by others.
You pledged yourself to promote sustainable development at the Rio Summit in 1992, and you yourself commented that the Climate and Biodiversity Conventions launched there “demand effective follow up“.
Your Secretary of State for the Environment Mr John Gummer has this year written that “Achieving sustainable development presents a considerable challenge” and that “the United Kingdom [is] determined to make sustainable development the touchstone of its policies and ... to revise and refine those policies year by year ... ”.
Greenpeace welcomed the lead which Mr Gummer gave to other industrial nations at the recent Second Conference of the Parties of the Framework Convention on Climate Change held in Geneva earlier this summer.
Mr Gummer called for the removal of subsidies on fossil fuels, saying “there is no point in seeking to mitigate the effects of CO2 whilst providing an inducement for people to use more”. We quite agree.
Mr Gummer highlighted the role of the fossil fuel industry in opposing progress on climate protection, for example through lobbying against controls. He said “It's simply not good enough for major producers of fossil fuels, both oil and coal, to claim that their financial interests should stand in the way of progress in making significant reductions in greenhouse gas emissions”. Once again we agree with him.
Speaking on national BBC Radio Mr Gummer said that the only people who doubted that global warming would take place were “people who want to promote the interests of the coal and oil industries against the interests of the whole of the rest of the community”. Again, Mr Gummer is right and has identified the crux of the problem.
Mr Gummer added that “if we don't do something very dramatic” then climate change would be severe enough to stop the monsoon happening every year and cause desertification in Europe. The Department of the Environment has recently publicised its view that climate change is real and will affect Britain as well as the rest of the world. Greenpeace has made these points to the Government for some years.
In Genev, Mr Gummer warned that if there was not “common action” on climate, the Convention Governments would fail as the League of Nations had in the face of “purveyors of falsehood who put their selfish concerns before the interests of the world community”. He said “the credibility of the governments of the world is on the line”.
Nowhere is this truer than in the UK, where, unlike the current ‘stabilisation’ commitment, reduction targets larger than 10% will require real improvements in the efficiency of energy use.
You have stated that “I want Britain to be in the lead” in acting on the Rio commitments and “the UK must demonstrate that it will do more than offer assistance to others. We must show that we will act at home. The environmental buck stops in our backyard. Nowhere else. That means the Government must act, even when that means taking difficult and unpopular measures”.
All these sentiments from yourself and your Secretary of State for the Environment are admirable. We agree there is a need for “dramatic action” on global warming, we agree that the “people who want to promote the interests of the coal and oil industries against the interests of the whole of the rest of the community” must not be allowed to “put their selfish concerns before the interests of the world community”. We agree that the credibility of your Government in this matter is “on the line” and that “the environmental buck stops in our backyard” and “nowhere else”.
Yet we are most concerned that four years after Rio, there is a very serious contradiction at the heart of your Government; namely between your policies on environment and those on energy from fossil fuels. This chasm has now widened to a gulf in the wake of Mr Gummer's trenchant calls for action at the Geneva climate conference.
At international meetings to protect the climate you lead calls for action and rightly want to sweep aside the delaying tactics of the self-interested fossil fuel lobby and tell other countries in blunt terms where they are falling short.
At home, in Britain's ‘backyard’ you encourage the further exploitation of fossil fuel reserves. While your Environment Minister has been in Geneva attacking the influence of the fossil fuels lobby, your Department of Trade and Industry Ministers have been ‘fast-tracking’ a huge new oil development known in the industry as the ‘Atlantic Frontier’.
This contradiction is merely fudged in your “Indicators Of Sustainable Development”. The section on energy says “key sustainable development objectives” are to “ensure supplies of energy at competitive prices” and “reduce adverse impacts of energy to acceptable levels”. It notes that Britain has “abundant” fossil fuel reserves and that “additional reserves of oil and gas continue to be identified or confirmed in the UK continental shelf”.
Yet there is no word about restricting the use of these fossil fuels, and no recognition of the need to do so. Indeed, by an unconvincing act of sophistry, the energy section of your document attempts to define “sustainability” in economic rather than environmental terms.
The plain truth is that your present policy is for unlimited extraction and use of fossil fuels such as oil and an effective inhibition of new solar technologies which do not pollute with greenhouse gases. This is in direct contradiction to protecting the climate.
Relatively simple calculation shows that the world’s atmosphere cannot sustain the use of more than a few per cent of known fossil fuel reserves. I attach a paper by Dr Jeremy Leggett which illustrates this.
Climate protection therefore demands an end to fossil fuel use. The question is not if but when. Your Government does not have an answer to this question.
I wrote to you in the wake of the Braer disaster in January 1993 asking you to set an end date to the use of oil in the UK and to halt all further oil and gas exploration in UK waters. You replied saying that it was an “over-reaction” and that there was “no evidence to justify a complete end to the use of oil”.
This year we wrote to you following the Sea Empress disaster, once again asking for a phaseout date for the use of oil. This time your Government’s reply was merely that the Non-Fossil Fuel Obligation “may contribute to the reduction of the use of fossil fuels”.
Although Mr Gummer has now recognized the environmental threat posed by the fossil fuel industry, your Government has not even recognized the need to end fossil fuel use at some point, let alone acted upon your commitments to give leadership by setting an objective applicable in the UK’s backyard.
Your present policy does not begin to address this question, indeed it heads in the opposite direction by encouraging more oil development. Your 1996 “sustainable development” policy swallows this contradiction and says: “it is likely that the reserves still to be discovered or confirmed will enable the UK to sustain its current levels of production for much longer than a decade”.
Ending or reducing oil production and use will not be achieved or indeed encouraged by “ensuring supplies” of fossil fuels at “competitive prices” as your “sustainable development” policy presently has it. Indeed, this will encourage the exact opposite, and the tax incentives you give to oil exploration and production, and your policy of opening up new sea areas for oil licensing (eg this years’ “17th Round”), and your policy of “fast track” development, are all in direct contradiction to Mr Gummer’s statement that “there is no point in seeking to mitigate the effects of CO2 whilst providing an inducement for people to use more”. The greatest inducement is unlimited supply of cheap fossil fuels.
If your “sustainable development” policy is to have any credibility, this contradiction must be addressed and resolved. We therefore urge you to review it, and change it. A decision to stop further oil development will no doubt be “a difficult and unpopular measure” with oil companies and the fossil fuel lobby but it is required in order to give Britain an environmentally sound energy policy, and to realise your commitment to show international leadership as well as responsibility in your “backyard”. The measure of current policy is the use and promotion of solar power by your own Government. The scope for UK use of solar power is vastly greater than your "sustainable development" policy documents suggest. Indeed, renewable sources are more "abundant" than fossil ones. For example, the UK receives some 30 times the energy contained in proven UK oil reserves from the sun in one year, and in a typical year the sun delivers 140 times the amount of energy delivered from all oil platforms in the UK.
The Energy Technology Support Unit's report "The Potential Generating Capacity of PV Clad Buildings in the UK" suggests that solar electric building panels could deliver two-thirds of the electricity demand. Altogether UK buildings receive as sunlight, five times the energy used as electricity in the UK each year.
It is therefore remarkable that as of March this year, not one British Government Department building carried a single solar electric panel. At this time six Departments were refurbishing and upgrading their headquarters but none was using solar electricity. Similarly, in the last year for which figures are available, DoE spent 2.4 billion on capital works, which is around one-third of the commercial buildings market, yet none was on solar. Neither the new DoE nor DTI buildings will have solar installed.
Moreover, the DTI spends roughly twice on "publicity and promotion" for the oil industry as it does on investment in solar technology. By comparison, the United States government spends 76 times as much on investing in solar technology and the Japanese government 133 times as much.
This is all in spite of the fact that in 1992 the DTI's own research had concluded that solar cladding could "make a very substantial contribution to the electricity supply of this country". As the DTI itself later observed (1994) "there are no market incentives to stimulate deployment of this technology" in Britain.
If there is one place which is a “touchstone” for Britain’s commitment to environmental protection and “sustainable development” it is West of Shetland. Here oil development is entering new territory - for example in the Rockall Trough, the Schiehallion, Foinaven and Clair fields. There is no need to try and exploit this oil, and no common benefit in so doing.
There are new and considerable risks to people and the environment which arise through the largely untested and “frontier” technology which the industry intends to employ. The development relies on huge floating production, storage and offloading vessels to operate in extremely deep water on and off the Continental Shelf.
There has been very little public debate and almost no Parliamentary scrutiny concerning these developments, not least because they are being “fast-tracked” with minimal public information (even seabird data collected by your Joint Nature Conservation Committee for the oil companies are classed as “commercial in confidence”) but also because your Government’s policy is to rapidly encourage such development irrespective of factors such as global warming.
Greenpeace calls on you to halt the development of the oil fields West of Shetland and in so doing, to give the world leadership by showing that you intend to put Britain and its energy policy on a true path to a more sustainable future.
We and other environment groups have many specific concerns about the developments West of Shetland which would arise, notwithstanding the global issues, and we will be writing to your Government about these in due course.
Instead of looking upon areas such as West of Shetland as an open book for unlimited exploitation of natural resources, we believe you should take the opportunity to make it a model of environmental protection and a responsible attitude to nature.
Such a decision would mark a turning point for Britain as it nears the end of the twentieth century, as it should for example, be accompanied by a far greater commitment to the development of renewable energy.
The same area of the Atlantic is also threatened by the development of ultra-deep sea or “alternative” fisheries. Here too, your Government’s policy seems entirely at variance with your avowed commitments to conservation and your international obligations.
Your “Indicators of Sustainable Development” states that “the key issue for sustainability is ... to prevent over-exploitation of fish stocks and to balance fishing effort against the natural ability of fish stocks to regenerate”.
In the case of very deep sea species and communities, the “natural ability of fish stocks to regenerate” is extremely limited. The ecology of the deep sea ecosystem for example below 1500m is very poorly known. What is known is that the entire system is fragile and not inherently productive. Temperatures are low, there is no light and the system can be extremely diverse but incapable of withstanding the sorts of disruptive pressures that come with modern fishing. Moreover, previous attempts to exploit orange roughy and other very deep sea species, for example off New Zealand, have proved disastrous with fisheries collapses after a few years.
It is European Community and UK Government policy to increase exploitation of this ecosystem and establish major fisheries where none previously existed, just off the Continental Shelf. Currently there are no quotas but boats from Spain, France, Norway, Germany and the UK are using very powerful trawl gear and very long nets to seek out the deep sea species such as orange roughy and others. Those threatened may include roundnose grenadier, black scabbard, orange roughy, rabbit fish, greater forkbeard, mora, Portuguese shark, skates, rays and red crab.
Council Regulation (EEC) No. 4028/86 established funding for “the search for new outlets for products derived from surplus or underfished species” with the objective of facilitating change in the fisheries sector.
As Mike Holden, a former Head of Conservation in the EC Fisheries Commission wrote: “There is increasing interest in stocks of fish in the waters to the west of the British Isles deeper than 1500m. These have been fished by French vessels for a decade. However, these stocks cannot absorb much fishing. The present attractiveness of the fishery is based upon high catch rates resulting from exploiting virgin stocks. Once the accumulated surpluses have been caught, catch rates will fall. It is known that the species concerned are slow growing and, in consequence, the stocks will be replaced only very slowly and catch rates will remain low indefinitely. The ’search for new outlets for surplus for products derived from surplus or underfished species’ is likely to make little contribution to the problem of over capacity”.
After taking evidence about the vulnerability of the deep sea ecosystem, The House of Lords Select Sub-Committee on Science and Technology commented in its recent report "Fish Stock Conservation and Management" [3.40 p 54] that: “ideally we would recommend an interim suspension of all deep-sea fishing, but we recognise that it could not at present be enforced”.
Despite the fact that it is widely feared that the development of fisheries for these very deep sea fish is very likely to result in a biological disaster, and that they will in no way compensate for the obvious failure to properly manage the more robust shallower-water stocks for example in the North Sea, it is widely understood in the fishing community that your Government is encouraging British exploitation of these “virgin” stocks.
It is also widely understood that the reason for this is so that when quotas are fixed, the UK will get “its share” under the principle of “relative stability” when new fisheries are regulated based on an established practice.
These vulnerable communities are not covered by your sustainable development indicators for either “wildlife and habitats” or “marine” environment. Your 1994 post-Rio Biodiversity Action Plan merely states that it is one of fifty “aims” to “continue to have regard to the need to conserve marine flora and fauna in carrying out the Government’s duty to regulate fisheries” and to “seek to control the levels of fishing effort in the UK fleet by a package of measures to reduce capacity (eg decommissioning) and fishing activity (eg restrictions on days spent at sea)” which does not address protection of these very deep sea species.
There is also an established basis for not exploiting these stocks, within fisheries policy. The revision of the Common Fisheries Policy must now be based upon the precautionary principle, enshrined within Articles 130r of the European Treaty. This means action should be taken before stocks collapse, not afterwards. More widely, Principle 15 of the Earth Summit Rio Declaration states: “In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation”.
We believe however that this is a case where wildlife populations are so vulnerable that you should take action both within and outside fisheries policy to put these stocks off limits to exploitation, acting on the precautionary principle, both in the light of experience elsewhere in the world and in the light of what is known about their ecology. There is no need to exploit these fish. Instead, your Government should lead others in focusing effort on the better management of traditional stocks.
There is more at stake here than simply the exploitation of stocks whether for provision of gourmet novelties, fish and chips, meal, oil, or even petfood. Your Minister of State for Agriculture, Fisheries and Food, Mr Tony Baldry said in his opening speech to this year’s International Whaling Commission meeting: “the United Kingdom does not accept that because something can be exploited on a sustainable basis, it must be exploited. Other considerations can legitimately be taken into account”.
The very deep ocean is such a case. It constitutes one of the last wilderness environments on earth. Its fragility and diversity has often been likened to the tropical rainforests. There can be no justification for the UK Government to allow its exploitation, and every reason to protect it. We believe you should give a global lead in this respect.
Your Biodiversity Action Plan states that you will: “play an active part in developing effectively international conventions for nature conservation, particularly CITES, the Bern, Ramsar and Bonn Conventions and the specific agreements under the last of these”.
We now urge you to examine the application of existing environmental legislation such as the Habitats Directive and the scope for utilising such international instruments for the protection of these communities and species both in the UK and more widely.
We draw to your attention the provisions of the Bonn and Berne Conventions which establish clear obligations upon member states to protect migratory species, wildlife and natural habitats.
The Berne Convention is now adopted by the European Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora. The Bonn and Berne Convention establish clear obligations upon member states to protect migratory species, wildlife and natural habitats.
The Directive specifically allows for designation of a special area of conservation to take place within a Member State's "European territory " (Art. 2) and for new habitats and species to be added to the Annexes. It is likely that some at least of the species in these communities may be "endemic and requiring particular attention by reason of the potential impact of their exploitation on their conservation status".
Moreover, within the West of Shetland area some 21 species of cetaceans have been recorded. They are: northern right whale, humpback, fin, blue, sei, minke, sperm, narwhal, northern bottlenose whale, cuvier’s beaked whale, harbour porpoise, common dolphin, bottle-nosed dolphin, Atlantic white-sided dolphin, white-beaked dolphin, striped dolphin, killer whale, false killer whale, long-finned pilot whale, and Risso’s dolphin.
While your Government gives very welcome support to protection of whales from commercial exploitation, your energy and fisheries policies are allowing the development of a huge expanse of their natural habitat in, to use your term, Britain’s “backyard”. Moreover, last year your Government was even prepared to allow the deliberate dumping of industrial waste in this same area, in the shape of a redundant oil installation.
Not only is oil pollution from oil production water steadily rising but whales and dolphins are subject to a host of chemical pollutants which have subtle but sometimes serious effects. Dumping and oil development would simply add to these pressures with unknown cumulative impacts on any component of the environment. These factors must be considered holistically.
As the Natural Environmental Research Council Scientific Group on Decommissioning said in its recent report in the wake of its “Brent Spar” inquiry, “The public is concerned that any decision about the Brent Spar might serve as a precedent for future deep-sea disposal operations, and not necessarily only of off-shore oil installations. Existing procedures require the case-by-case evaluation of disposal options, which is necessary, but not sufficient, because continued disposals with small individual impact might give rise, by small increments, to an unacceptably large overall impact. The capacity of the oceans to deal with wastes is finite, and has to cope with all disposals, both deliberate and accidental. We recommend that assessments of both cumulative and case-by-case impacts be made ...”
Drawing these factors together, we believe that your Government’s treatment of these waters should and will be seen as a test case for your commitment to environmental protection and what your own support for the concept of “sustainable development” really means in Britain.
This area contains wilderness but it is being treated as a development frontier, both for the oil industry and the fishing industry. Britain should treat its few remaining areas of true nature with much greater respect.
Britain’s Government should also recognize that there are limits to exploitation, imposed both by practicality and responsibility, and that these developments, if allowed to proceed, exceed those limits.
The signals that you send if you permit such raw exploitation are not those of environmental leadership in entering the twenty-first century but of unsustainable development more worthy of the early industrial revolution.
It is Government’s job to impose limits to enforce responsible behaviour because without it, there will be no environmentally responsible development. So long as nature is available to be treated as a free good which can always be opened up, good stewardship elsewhere will be undermined.
This is why these developments are a test case.
Allowing the exploitation of the vulnerable ocean depths for unjustifiable fisheries risks squandering biodiversity for the sake of a short term financial gain by a handful of fishers. We know little about the ecology of the ocean depths but as you said in Rio “even though we cannot be certain, the evidence requires us to be cautious”.
Instead of allowing the fishing industry to expand into these vulnerable communities you should contain the problem to the existing fisheries and resolve problems of their management.
Similarly, to allow the ocean depths to be used as a dump ground will undermine the development of an effective industry for the re-use and recycling of wastes, and policies of waste avoidance. It is simple psychology: if a free dump exists, some in industry will want to exploit it. You should contain the waste within the industry and make it deal with the waste it produces, not dump it.
In the same way, permitting the oil industry to continue to expand into new areas ensures that those responsible for energy policy do not have to face up to the awkward question of ending the use of fossil fuels. Not until the end-game for fossil fuels is begun, will Mr Gummer’s attempts to secure climate protection have any real chance of succeeding. It is not a question of “when the oil runs out” because the climate cannot sustain that: Government must intervene with limits and turn off the tap of exploration, development and production.
Until that happens all the efforts of technologists and consumers to promote the use of solar power, renewable technologies and energy efficiency will be overwhelmed by the continued availability of cheap fossil fuels.
1997 will be the 5th anniversary of the Rio Earth Summit and on that occasion the collective and individual performance of states viz their Rio commitments will be under real scrutiny for the first time with the review of implementation of Agenda 21 at the Commission on Sustainable Development (CSD) in April, and a special session of the UN General Assembly (UNGA) in June. It would be most unfortunate if on this occasion the UK Government was to be seen as having not put its words into action. On the other hand, if the UK Government came to the CSD review meeting and the UNGA Special Session with an announcement to declare Britain’s Atlantic Frontier off limits for industry, it would be in a position to really take leadership and show that it has put its own words into action, and that the rest of the world must equally do so.
At Rio you said people were on the earth as “leaseholders with a huge responsibility” and spoke of the need to “reconcile the needs of the living with our obligations to future generations”. There could not be clearer needs than to signal an end to exploitation of fossil fuels and to protect the biodiversity in the ocean wildernesses off Britain’s shores.
I trust that you will give these matters careful consideration and look forward to hearing from you.
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Executive Director
Greenpeace UK
Major sets out plans to reduce pollution, THE TIMES 25 March 1993
Speech By The Prime Minister at UNCED Rio De Janeiro 12 June
1992
Indicators of Sustainable Development For The United Kingdom, DoE 1996 ISBN 0 11 753174 X
Statement Made By the Rt Hon John Gummer PC MP, Secretary of State For The Environment, to the Second Session of the Conference of the Parties to the UN Framework Convention on Climate Change, Wednesday 17 July 1996, Geneva
Statement Made By the Rt Hon John Gummer PC MP, Secretary of State For The Environment, to the Second Session of the Conference of the Parties to the UN Framework Convention on Climate Change, Wednesday 17 July 1996, Geneva
The Today Programme, BBC Radio 4, 17 July 1996
“Climate Change Will Have An Impact In The UK” - Department of the Environment News Release, 2 July 1995
Statement Made By the Rt Hon John Gummer PC MP, Secretary of State For The Environment, to the Second Session of the Conference of the Parties to the UN Framework Convention on Climate Change, Wednesday 17 July 1996, Geneva
Prime Minister's Speech To The Global Technology Partnership Conference, Birmingham, March 24 1993
p 42 - 3 Indicators of Sustainable Development For The United Kingdom, DoE 1996 ISBN 0 11 753174 X
Letter from The Prime Minister to Lord Melchett, Executive Director of Greenpeace, 3 February 1993
p 42 - 3 Indicators of Sustainable Development For The United Kingdom, DoE 1996 ISBN 0 11 753174 X
The amount of energy contained in all proven oil reserves of the UK continental shelf is equivalent to 7446 TWh - from The Energy Report Vol 2, DTI 1995 (575 m tonnes1 x 42.62GJ/3.6m GJ1)
The amount of sun that falls on the UK in any one year is on average 222,180 TWh (av 2.5 GWatts2/m sq/day X 365 days x 244,180 kmsq2)
(127m tonnes3 x 42.62/3.6 m GJ = 1504 TWh)
The Potential Generating Capacity of PV Clad Buildings in the UK, ETSU S1365, 1992
All these solar references are detailed and sourced in ’A Very British Failure - Government policy on solar power’, published by Greenpeace UK, March 1996
p 74 - 75 Indicators of Sustainable Development For The United Kingdom, DoE 1996 ISBN 0 11 753174 X
p 32 Holden, Mike, The Common Fisheries Policy: Origin, Evaluation and Future, Fishing News Books, 1994
p 167 Biodiversity: the UK Action Plan, Cm 2428 HMSO 1994
C7, First Report Of The NERC Scientific Group On Decommissioning Of Offshore Structures
Speech By The Prime Minister at UNCED Rio De Janeiro 12 June 1992