Annex A
Issues for consultation and response form: carbon reduction target and strategy (HEFCE 2009/27)
- Respondents should complete this form to respond to the HEFCE consultation. Text boxes may be expanded to the required length.
- Completed forms should be e-mailed to by Friday 16 October 2009.
- We will publish an analysis of responses to the consultation. Additionally, all responses may be disclosed on request, under the terms of the Freedom of Information Act. The Act gives a public right of access to any information held by a public authority, in this case HEFCE. This includes information provided in response to a consultation. We have a responsibility to decide whether any responses, including information about your identity, should be made public or treated as confidential. We can refuse to disclose information only in exceptional circumstances. This means responses to this consultation are unlikely to be treated as confidential except in very particular circumstances. Further information about the Act is available at www.informationcommissioner.gov.uk.
Respondent’s details
Are you responding:(Delete one) / On behalf of an organisation
Name of responding organisation/individual / National Union of Students
Contact name / Susan Nash
Position within organisation (if applicable) / Vice President Society & Citizenship
Contact telephone number / 07919323930
Contact e-mail address /
Consultation questions
Consultation question 1: What should the sector target be for 2020 and 2050 and should there be milestones? If yes, what should these milestones be?
The Higher Education sector has a real opportunity to be a leading force in carbon reduction. Whilst it is not alone in this challenge, and many public institutions will be expected to do the same, the sector has made significant progress in areas, and so there is fertile ground for the sector to be the leading force in carbon reduction. With cutting edge research on new technologies, to education on everything from adaptation to behavioural change, right through to influencing the actions of the students, staff and wider community, Higher Education could influence the path way to a new, greener future.
NUS supports the SQW report recommendations that the sector should aspire to carbon neutrality in 2050, with a target of 50% reduction in 2020 against 1990 baselines. In aspiring to carbon neutrality NUS would be keen to see carbon trading and offsetting limited, and the majority of savings generated within the UK. If carbon neutrality cannot be agreed NUS believes the sector needs to, at a minimum, commit to reducing the carbon emissions within Higher Education by 80% by 2050, and by at least 50% by 2020. In a survey conducted with 96 students exclusively for the HEFCE consultation the majority of our survey respondents felt the 2020 target should be between 40-50%, with 30.8% calling for a 50% reduction, and 24% stating a 40% reduction. In addition 14% felt there should be a half way target of a 70% reduction in carbon emissions.
94% of our survey respondents felt there should be a half way target in place, agreeing that milestones would be useful for the sector to monitor progress. We support a single mid-term milestone in 2015 of 25% reduction against 1990 baselines.
We believe these targets would underpin Higher Educations leadership role in society and allow Higher Education to offer assistance to other sectors who may be struggling to reach their long term goal. Furthermore, we believe ambitious targets which are geared towards the front end of the spectrum, i.e. requiring institutions to achieve a lot early on, are essential if we are to meet the considerable challenge of preventing climate change catastrophe.
Consultation question 2: What should be the key elements of a strategy to support the HE targets and what should the role of HEFCE, UUK and GuildHE be?
We welcome the SQW report which acknowledges the need for a strategy to underpin the sector targets. We also welcome the exploration into different ways of reducing carbon, and how best the sector may work together; through different means to reach the targets set. When we asked our students what the main elements of any strategy should be, they felt the biggest emphasis should be placed on reducing direct emissions through better space and energy management, with 66.3% of students prioritising this option. Secondly 59% of students felt it was imperative for institutions to change the behaviours of its staff and students. 41.3% wanted increased research and development into new technologies, and 28% wanted additional opportunities to learn skills and information, through teaching about issues connected to sustainability.
Given the sheer range of options available to institutions, and the inevitable varying ways these different options can be applied NUS believes a repository which seeks to share best practice would be a useful aid for carbon reduction. However we would want this tool to cover all aspects of sustainable development, not just carbon management.
Given the current carbon outputs of 38% for electricity, and 16% for gas in the 2006 figures, considerable attention has been, and will need to continue, to be focused on the physical infrastructure. We agree with the SQW report that there are a number of possible quick wins for institutions in this area, and that advances in technology will aid this process.
How institutions source energy to fuel activities, and how they save energy through better insulation and energy management within buildings, will be a important component of the sectors carbon reduction strategy. The SQW report estimates building energy and space management savings could generate a net benefit of £150million by 2020.
Whilst those methods which give the greatest financial return should be prioritised, NUS does see a role for HEFCE, UUK and GuildHE in researching, sourcing and providing further guidance to institutions to encourage greater investment in renewable technologies. The report highlighted that many of these technologies offer a low abatement or financial benefit for the institution. The report recognises that this is partly due to their infancy, and that the cost is likely to reduce further over time. The report also states that funding is available from government for investment in such technology. 68% of our student respondents felt renewable energy on campus was an important step in carbon reduction. NUS would like to see HEFCE, UUK and GuildHE explore and promote the opportunities currently available for investing in and sourcing renewable energy, as well as tasking these bodies with lobbying for greater access and fewer planning restrictions to introducing renewable sources on campus.
NUS welcomes the inclusion of behavioural change methods within the SQW report. We would like to see a greater emphasis on behavioural change initiatives within the sector and individual institutional carbon management plans. Virtually all measures in this category are cost-effective, and the cost is minimal, in fact the report acknowledges that they could save between £50 million and £70 million by 2020. In addition NUS would like to see more institutions working directly with their students’ unions, and nationally with NUS, to effectively deliver behavioural change initiatives as a major part of broader university-owned carbon management plan.
Students’ unions, NUS and NUS Services have well-established initiatives within this field, and it is becoming an increasingly important part of our campaign portfolio. This year alone NUS is delivering behaviour change projects at a total of 35 English HEIs through our members, funded both by the Department for Business, Innovation and Skills and Defra. Our work is not confined to the campus base, and not just to students – our projects reach out to staff, campus visitors and people living in the communities in which our members live and work.
For example, this year we were granted funding to expand our successful Carbon Ambassadors program to community organisations and local businesses, offering off campus assistance through carbon audits, carried out by local University students and Union staff. The expansion of this scheme not only contributes to positive local community relations; it could be an important mechanism in helping to reduce Scope 3, indirect emissions from local suppliers and firms who provide products and services to the institutions.
We believe UUK, HEFCE and GuildHE need to take much bolder steps in leading the sector in order for institutions across the board to meet the reductions required. We do commend the work that has already taken place, and concur with the reports recognition of the successes to date, but we are concerned that those who may currently be underperforming in this area will need greater direct assistance.
Whilst we recognise the diversity of institutions we are concerned that a light touch approach will simply encourage those who currently do well to continue to do so, with little encouragement for others to improve performance. We respect the autonomy and independence of HEIs but would like to see Government and sector bodies monitoring and measuring performance. We believe this is important for getting an accurate picture of performance within the sector.
Data gained in surveys conducted by NUS and NUS Services show students are increasingly concerned about the environmental impact of their University. 63% of students said they would do more to reduce their own emissions if it was clear the institution was taken action to reduce its carbon emissions[1]. Currently information on carbon reduction performance is not readily available from within the sector. Students rely on data compiled by the People & Planet Green League. The information that is provided by the sector is inaccessible to those who may not be familiar with traditional sustainability language or the standard formulas. Students, staff and the public at large do have an interest in these matters, and so effective national communication is important. We believe UUK, HEFCE and GuildHE do have a role in communicating the progress that has been made, and more importantly communicating the steps that will be taken within the sector year on year to meet the challenges ahead.
At a local level, students regularly tell us that they see their institutions wasting energy across campus. Our Greener Living Fund scoping survey asked students to tell us how their institutions could save energy and we have thousands of ideas, from switching off the hockey pitch lights in the daylight to not over heating specific lecture theatres. Our work rolling out our staff behaviour project, Green Impact, reinforces this – only a few departments have a culture of saving energy with the vast majority being hereditarily inefficient. This culture has to change is we are to meet the targets recommended in the SQW report, and our projects are attempting to do exactly this.
Returning to the bigger picture, NUS was a founding member of the 10:10 campaign, and have worked with a number of institutions over the summer who have signed up and committed to trying to achieve a 10% reduction in their carbon emissions by the end of 2010. Whilst we understand that some institutions have reservations about publicly committing to year on year targets, we do believe this campaign is very accessible to an institutions staff, students and stakeholders. It has the benefit of wider publicity within society, and a clear recognisable brand.
We feel that any additional communication by the sector would have to be mindful of this and other pre-existing information, which is highly visible and possibly embedded in the minds of those the sector, is trying to engage.
Consultation question 3: Do you think that the monitoring and reporting arrangements in relation to the sector-level target are appropriate? How can the measurement of the sector’s total carbon emissions be improved?
We believe annual reporting should be conducted by HEFCE on a standard formula, with the same data being requested from different institutions. When surveyed on the matter, 91% of the students responded stated that they would like to see HEIs forced to report and publish their carbon emissions. Therefore we welcome the announcement that carbon emissions will be reported through the Estates Management Statistics, which will be migrating to HESA in 2010.
NUS believes providing data through HESA will make it more transparent and more widely accessible to a broader range of people. We accept that institutions should be able to include commentary which gives contextual data, but ultimately the focus should be on providing the public with clear indications of progress.
We support the SQW report which calls for absolute targets which are based on 1990 baselines, not targets which account for sector growth. Any growth within the sector or within an individual institution should be neutralised by reductions elsewhere.
Consultation question 4: Do you have any comments on the guidance on developing carbon management plans? Is there a need for further support and guidance? If so, what is this?
Whilst we understand the need to focus on Scope 1 & 2 emissions, as the sector has clear data on those aspects of carbon emissions, we believe the sector does need to urgently begin work to explore carbon reductions in Scope 3, and begin to capture more accurate data for the indirect carbon emissions, particularly around procurement.
We asked students what they would expect to see monitored in a carbon management plan. They stated they would like the following information recorded and publicised;
- 77% would like staff travel to and from work to be monitored
- 75% respondents would like carbon emissions from research activities to be monitored
- 68% wish for Vice Chancellor travel to be monitored
- 50% want international student travel to be monitored
- In addition some respondents mentioned looking into procurement, the supply chains and food/drink in order to further monitor carbon emissions
Some activities which are categorised as scope 3, such as staff and student travel, should be considered by an institution and recorded accordingly. Whilst it may be indirect, the institution does have some capacity and influence over these emissions. NUS believe it is crucial that these are part of an institutions wider understanding of the environmental impact of their activities. Even if data is currently sparse we would encourage institutions to include this within their carbon management plans, with a commitment to source fuller information as part of the carbon reduction action plan.
Furthermore NUS would like to see carbon management plans acknowledge more readily the role of teaching in carbon reduction. Institutions have a valuable role to play in utilising teaching and research to promote sustainability. 80% of our survey respondents wanted to learn more about sustainable development, with 62.9% stating that they would like the opportunity to take an open module in this area within their course. We believe future generations of students will need a greater range of skills and knowledge in the area of sustainability. NUS welcomes the Governments recent announcement of an additional 10,000 “green placements” for graduates but we are concerned that many students will be ill equipped or unprepared to take up those opportunities, within the “green industries” which will become more common place. Of our survey respondents only 9% felt they were well prepared by their institution for a job in a future green economy, 56.5% felt they were not prepared enough or not prepared at all. NUS believes there are greater opportunities to increase student understanding of the environment, and we believe Universities have a duty to ensure their courses are preparing students for the challenges ahead. Therefore NUS would like to see a more active introduction of education for sustainable development within the curriculum across the University sector.
We believe HEFCE and the Higher Education Academy need to place a greater emphasis on the ESD agenda. Our members who are currently engaged in environmental campaigns or initiatives come from a range of subject bases, but recognise the importance of gaining knowledge, skills and experience in carbon reduction or broader sustainability. Where courses have become available and open to all students there has been a great demand, with the open module on Sustainable development being oversubscribed at the University of Bristol in its first year. LSE for example has introduced an innovative new course aimed at introducing first year undergraduates to the fundamental elements of sustainable development through thinking as a social scientist and exploring issues of current public concern regarding issues such as climate change and world poverty.
NUS welcomes the recent announcement by the University of Exeter to create a new post of sustainable curriculum coordinator, whose job it will be to integrate sustainable development in all courses regardless of subject base. NUS would like to see a similar role created and maintained at every HEI.
Consultation question 5: HEFCE is required to link capital funding to performance against carbon management plans. Do you have any comments on how we will use CIF2 to assess this and how it should affect capital allocations?
NUS supports the link between capital funding and reduction. 62% of our survey respondents shared NUS’ perspective stating that they too felt future funding should be linked to carbon reduction performance, this figure was actually higher still amongst our Postgraduate responses, with 76% of that cohort agreeing to a link between progress and capital funding.