Peatland & Energy Policy
Dave Windle
Since the last issue, we have responded to one consultation; the Peatland and 
  Energy Policy Statement. I have summarised the key points made below.
  - The document needs to address cost, effectiveness and efficiency. Since 
    the focus is on carbon retention, the main "output" (C or CO2) is 
    simple and relatively easy to value in monetary terms. Thus, core "value 
    for money" should be relatively easy to establish for any particular 
    proposal, or for types of action (e.g. high or low altitudes, wet or dry locations, 
    easy or difficult access). The document needs to provide guidance on this 
    aspect or at least refer to where this guidance can be found.
 
  - The frequently cited carbon store of "approximately 2,000 Mt carbon" 
    is only marginally relevant to the policy. What matters are flow rates (Kt/yr) 
    under future conditions. Evidence on this is much more difficult to determine, 
    being harder to measure (e.g. over time under different weather conditions), 
    and highly variable over space. However, the policy needs to be clear that 
    flow rates are what matter. Efficient policy should try to target activities 
    which maximise the absorption of carbon into peatland, or minimise its emission.
 
  - It is important that peatland restoration should not be used as an excuse 
    to build new hill tracks or to infringe agreed areas of wild land.
 
  - 
    
      
          | 
      
      
        Damaged peatland, by the Steplar Road  
          © C Lacy | 
      
    
    Payments to landowners to restore peatland which is eroding constitute a good 
    example of "paying polluters" rather than following the "polluter 
    pays" principle, which is a well-established tenet of Scottish environmental 
    law. The fact that the landowner may have inherited, or purchased, the land 
    in question does not alter the fact that the area is emitting a harmful substance 
    into the atmosphere and water systems. In such circumstances, the landowner 
    should take action to reduce, and if possible stop, these emissions. Public 
    payment should only be undertaken where there is a well-established case of 
    market failure (e.g. limited information, monopoly supply) or social unfairness), 
    which is not the case here.
   
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