The government’s own assessments of its plans for net zero show it has concerns about risks including a lack of funding and project delays.
These assessments, known as “risk tables”, have been published by Good Law Project ahead of a legal challenge brought by the organisation alongside Friends of the Earth and ClientEarth against the government’s latest net zero strategy.
Among the risks include concerns around the government’s plan to deliver up to 10GW of low carbon hydrogen production capacity by 2030, the planned rollout of small modular reactors (SMRs), and potential delays to planned interconnectors.
Good Law Project claims the risk tables show that the government’s Carbon Budget Delivery Plan to reach net zero by 2050 is “being put in jeopardy by delays, an overreliance on unproven technology, insecure funding and a lack of joined-up policy thinking”.
On the government’s ambition to deliver up to 10GW of low carbon hydrogen production capacity by 2030, the government assessment adds: “Funding is subject to a future spending decisions (sic) so therefore cannot be confirmed now, creating inevitable uncertainty; aspects of the policy have yet to be consulted on.”
It further states that industry reaction to policies concerning hydrogen production, along with the known pipeline of UK hydrogen production projects, “provides confidence that HMG is moving in the right direction to meet our 10GW ambition”.
However, it adds, the UK is still at a near zero base of low carbon hydrogen production.
The document continues: “We are developing policies to support multiple off-takers of hydrogen, including the potential for blending as a demand sink, but there remains significant uncertainty from investors and industry to these policy signals.
“There are various significant dependencies (including funding and legislation) and external factors (including current levels of inflation) overlaying our ambitious policy programme which create further delivery risks. This means that hydrogen production is at risk of delay, which could reduce emissions savings from hydrogen use in end use sectors.
“Rapid developments and substantial public funding on offer/being developed in the US and EU mean the UK is now directly competing with other countries for the investment needed to support its hydrogen deployment ambitions. There is risk that mobile private investment will be drawn away from the UK while projects wait for certainty over the funding and timing for contract award, with associated implications for jobs and supply chain development. Anecdotal evidence from industry suggests increased risk in the next 12-18 months.”
Concerns are raised elsewhere about interconnectors. The government warns that there have been some delays in the applications process and there is risk of further delay.
It added: “While it is likely we will meet the ambition of at least 18GW interconnection capacity by 2030, there is not yet full confidence in the pipeline of projects as Ofgem is still considering applications to its third window and several projects are still seeking regulatory approval in neighbouring countries.
“This risk requires attention however appears resolvable based on the actions already underway.”
Despite the numerous risks listed within the document, one area in which the government did not foresee any issues was in the fifth allocation round of the Contracts for Difference (CfD) scheme.
The results of AR5, published last year, infamously did not include any offshore wind projects which prompted a furious reaction from many within the sector.
Good Law Project, Friends of the Earth and ClientEarth are in the High Court from Tuesday (20 February) to challenge the government on its revised net zero strategy, the Carbon Budget Delivery Plan, which they claim is inadequate and in breach of the Climate Change Act 2008.
This follows on from a successful legal challenge by the three organisations in 2022, where the High Court ruled that the government’s original climate action plan had breached the Climate Change Act and ordered the minister to come up with a revised plan to reach upcoming carbon reduction targets.
Good Law Project’s legal director Emma Dearnaley said: “This is a big win for climate transparency. We now urgently need a credible climate plan to make sure we will meet legally-binding net zero targets, grow the economy and create the next generation of jobs.
“If it wasn’t for our legal action, ministers would have continued to hide these alarming assessments. But now they must face the music and come up with solutions – and there is no time to lose”.
Friends of the Earth lawyer Katie de Kauwe said: “It is striking that there is no reference whatsoever to these risk tables in the government’s climate plan. We only learnt of their existence through our case and it’s clear as more pieces of the puzzle emerge that much of the government’s ‘strategy’ to meet legally-binding climate targets amounts to wishful thinking.
“Friends of the Earth is making the case in court that the failure to publish the risk tables is one of several examples of a concerning and unlawful lack of transparency and accountability by the government, which left parliament and the public in the dark about this climate plan’s dangerously high-risk nature.”
ClientEarth lawyer Sam Hunter Jones said: “These risk tables only further prove that the government is choosing to look the other way when it comes to the clear possibility of its climate plans failing.
“They show that the government is knowingly banking on uncertain, high-risk measures and an overall approach that simply does not add up. This is unacceptable, and we say that it breaches core parts of the Climate Change Act.”
A Department for Energy Security and Net Zero spokesperson said: “The UK is the first major economy to halve its greenhouse gas emissions since 1990, while growing the economy by nearly 80%.
“The government has overdelivered on every Carbon Budget to date and we’re on track to meet our future targets, which are among the most ambitious in the world.
“While we cannot comment further on matters that are subject to live litigation, the Carbon Budget Delivery Plan was the most detailed climate strategy published to date – outlining our long-term plans to deliver net zero in a pragmatic way will continue to lower energy bills, create jobs across the UK and reduce emissions.”