-Friends of the Earth (FOE) on Climate Change Strategy

Mayor’s Climate Change Mitigation and Energy Strategy (CCM&ES) draft for consultation with the GLA and London Assembly – response from Friends of the Earth.  April 2010

Thank you for the opportunity to respond to this first draft. At this point our comments are mainly of a strategic nature. We also refer you to our response to the London Plan public consultation draft.

For your information, all page numbers referred to are based on the pdf file on the GLA website i.e. ‘x/180’

Chapter 1 – Introduction

There is much to welcome in this chapter which sets out the need to tackle climate change and the benefits of doing so including security of energy supply and helping with the scourge of fuel poverty.

However page 24 and 25 state that the public consultation draft will be published with additional material including the Strategy’s contribution to sustainable development. It is crucial that the national policy context of the need to pursue sustainable development is taken as the starting point as this underpins how London must develop in ways that ensure both that climate change is adequately tackled and that climate change and other environmental aims are addressed in an integrated manner with social and economic aims.

The Government’s Sustainable Development Strategy emphasises that the guiding principle of “Achieving a sustainable economy” must be met together with other guiding principles including “ensuring a strong, healthy and just society” and “living within environmental limits” in an integrated way (chapter 1).

References in Chapters 2 and 3 (page 30 and 38 respectively) imply ongoing economic growth, but London must not pursue growth at any cost. Instead the aim must be on developing a sustainable economy, that is one in which economic activity builds a just society, reduces inequality and operates within our environmental limits including climate, air quality and resource use.

It is right that the national and international context for climate change and energy policy is set out in this chapter, but Government’s intended target of a 42% cut in CO2 from 1990 levels in the event of an international agreement should also be set out.

Chapter 2

The UK is behind where it should be in terms of cuts. The Committee on Climate Change (CCC) stated in October 2009 that cuts of only 0.5% per annum had been achieved between 2003 and 2007. See: http://www.theccc.org.uk/news/press-releases/477-uk-needs-to-achieve-a-step-change-in-its-pace-of-emissions-reduction-to-meet-carbon-budgets-12-october-2009

In London, the Integrated Impact Assessment (IIA) of the London Plan indicates that emissions were 44 million tonnes (mt) in 2003, but more recently are 47.5mt (the latter figure is taken to be the 2006 LEGGI figure). Care must be taken in London that the effects of the recession, which are likely to have had an impact on CO2 levels, are separated from cuts due to policy measures when assessing recent progress.

Clearly action needs to be taken, and Friends of the Earth welcomed the Mayor’s adoption of his predecessor’s target of a 60% cut in CO2 by 2025 from 1990 levels in his manifesto, and its inclusion in London Plan policy in policy 5.1. But whereas the London Plan “seeks to achieve” the target, policies must clearly be adequate to ensure the target is achieved.

It would be appropriate for the Strategy to adopt, as a longer term target, the current national target to reduce CO2 by 80% by 2050, as set out in the Climate Change Act 2008 (referred to on page 24).

Targets to be kept under review and be science-based

The overall target and those supporting it must be kept under review to ensure that they continue to be science based. To this end the current targets should be referred to in the CCM&ES as ‘current targets’, and clear commitment made to keep them under review to keep them and their supporting policies in line with the current scientific consensus and advice from the Government and the Committee on Climate Change.

Currently Chapter 10 says the Strategy will be reviewed 5-yearly ‘and more frequently if deemed necessary’. This does not reflect the necessary urgency now required to convert the strategy development process into concerted action and implementation with review of targets and regular adjustments being part of routine operations.

Responding to submissions on the Planning for a better London consultation the Mayor said “We will continue to ensure that our policies on climate change are innovative and evidence-based…”. Leading to a greener London (LTAGL), the precursor of the CCM&ES states “…for London to play its full role, based on the latest science on climate change…” (page 11). This reference to reviewing and science-based targets needs to be brought clearly into the CCM&ES (and the London Plan) which refer to a situation at a given time, but need to be kept up to date.

Interim targets

Having adopted the 60% target from his predecessor’s Climate Change Action Plan (CCAP), following through and adopting the accompanying 4% annual target would have been the logical basis for implementation for the Mayor. Friends of the Earth has recommended annual interim targets to help keep the Mayor’s 60% target on track, to help keep frequent track of progress and to provide a mechanism to adjust policies if needed. The CCM&ES should introduce annual targets as this will be a more reliable and realistic implementation tool than reliance on just two interim targets.

The London Plan states that “The GLA will monitor progress towards its achievement annually” (policy 5.1), and that “Progress will be kept under review to ensure that policies and programmes are on track” (paragraph 5.15). Chapter 10 of the CCM&ES says that the LEGGI data will be available on the website in future and that “this will enable people to track London’s performance on an annual basis against the projected targets set in this Strategy”. This reinforces that value and purpose of adopting annual targets. With only 5-yearly targets rather than annual ones, it is questionable that Londoners will be able to see whether cuts were on track or not and to play their role.

We recommend annual targets (the 4% target, or an updated annual target, as necessary) to be central to the CCM&ES being turned into strategy with a realistic chance of being delivered as part of London’s economic recovery. We note that the London Borough of Harrow’s Climate Change Strategy is already based on the 4% annual target from the 2007 CCAP.

We welcome the Mayor’s use of at least two interim targets in this first draft, for 2015 (22%) and 2020 (38%). We consider it is crucial that the 2020 interim target is for a cut of at least 40%, rather than the 38% proposed, on 1990 levels. There are several reasons for this:

1. The science demands it – to stop runaway climate change a cut of at least 42% by 2020 on 1990 levels is advocated nationally. See: http://www.foe.co.uk/campaigns/climate/news/tyndall_report_19448.html

2. The Committee on Climate Change and Government accepts 42% by 2020 on 1990 levels as an apppriate, and the intended, target nationally – just politically advocating a 34% cut until an international climate deal is reached. See http://www.theccc.org.uk/pdfs/LaunchPressRelease01.12.08.pdf

3. Leaving cutting CO2 in London from 38% to 60% between 2020 and 2025 is leaving too much to be done later; as the Stern Report sets out it is easier and cheaper to make cuts sooner and this is recognised on pages 17 and 20 of the CCM&ES..

4. A 4% annual target (as we recommend above), equates to a cut of around 40% by 2020 on 1990 levels anyway. The London Borough of Harrow’s Climate Change Strategy is based on the 4% annual target from the 2007 CCAP, as stated above.

5. Some London boroughs (Haringey, Islington and Harrow) have already signed up to a target to cut CO2 in their area by at least 40% by 2020 – using 2005 baselines related to NI 186).

6. The strategy proposes an unnecessarily small cut from the transport sector which is small compared with other sectors. Raising this would assist with raising the 2020 target from 38% to 40+%, avoiding having to rely on additional Government policies and could also help raise the 2025 target beyond 60% on 1990 levels as and when required by the latest science and government advice.

Delivering the cuts needed

For a world-leading city which should be taking the lead, the strategy’s proposed targets are inadequate, its implementation and tracking is less than rigorous and there is an over-reliance on Government measures, which are not at all proven in their ability to support the achievements of the required cuts.

The reliance on cuts from committed Government policies still leaves a gap in the figures as the contribution from Mayoral policies is low. The strategy is also relying on uncommitted further cuts from the actions of Government and other players to make up the difference, rather than propose that Mayoral policies deliver more significant cuts. (See the Mayor’s CCM&ES chapter 2, from page 25, particularly from page 30, and appendix C, and CCAP Executive Summary figure iii, page 9.)

The 1990 baseline from which cuts must be made is 45.1 million tonnes (mt) of CO2 per year, which needs to be reduced to 18 mt by 2025. The starting levels are different now for the Mayor’s CCM&ES than when his predecessor produced London’s first CCAP in 2007 – the ‘business as usual’ (BaU) reference case now expects emissions to be lower in 2025 than in 1990 (41.7 mt a year by 2025), whereas in 2007 BaU emissions were expected to be higher in 2025 than in 1990 (51mt a year by 2025), meaning more cuts were needed then.

However the draft CCM&ES is only in line to deliver cuts of 9.2 mt a year by 2025 from Mayoral policies, from the BaU level, needing the Government and others to contribute cuts of 14.5 mt (though only 9.5 mt are committed), to reach the total cuts needed of 23.7 mt. The first CCAP was set to deliver cuts of 19.6 mt a year by 2025, from the BaU level expected at the time, needing the Government and others to contribute cuts of only 13.4 mt, to reach the total cuts needed then of 33 mt.

The Mayor must now put in place the Mayoral policies that will result in deeper cuts, making a bigger contribution towards the 23.7 mt of cuts needed than the 9.2 mt proposed, and this should be perfectly possible. These must also be integrated into the revisions of the London Plan currently taking place.

The role of different sectors

The strategy does not require all sectors to play their part, overall or in meeting the Mayor’s contribution, and not all sectors are cutting by 60% which means that some sectors have to cut deeper.

The Transport sector is only set to contribute about 10% of total cuts needed (2.57 mt of the total of 23.7 mt cuts needed from BaU levels), and the transport is only set to contribute about 5% of Mayoral cuts (0.5 mt of the 9.2 mt total) .

The transport sector overall is currently expected to achieve only about a 32% cut from BaU levels (2.57 mt of cuts from expected BaU emissions of 7.95 mt in 2025). From 1990 levels this is still only a cut of approximately 43%. Mayoral transport policies are expected to achieve only about a 6% cut from BaU levels (0.5 mt of cuts – of which only 0.38 mt is from transport itself with the rest from energy supply for transport). From 1990 levels this only a cut of only approximately 5%.

As a result transport, which was responsible for 21% of London’s emissions in 2006, would end up being responsible for about 30% of emissions under plans in the draft Strategy transport. This is only just less than homes which would be responsible for about 32% of emissions (down from 36% in 2006), while workplaces would be responsible for about 38% of emissions (down from 43% in 2006).

We recommend that the strategy sets proper targets for each sector, particularly that the transport sector is set a tougher target. As part of working with all sectors towards London’s sustainable economic recovery, the implementation plan should create a clear role and expectation on all sectors to play their full cooperative role.

Chapter 3

The imperative to pursue sustainable development in London is referred to above under Chapter 1 with the need to reference the Government’s SDS of 2005 in the Strategy whereby economic, social and environmental objectives are met together. The benefits of acting quickly have also been referred to, and should facilitate taking plans beyond current proposals sooner. London must develop overall as a low-carbon economy, rather than these businesses, or initiatives to help them, forming just a part of plans for London.

The proposed Green Enterprise District is a welcome initiative and east London must be developed in a low-carbon way, including in relation to transport – see below. But this should be replicated around London, forming part of a diversification of London’s economy sectorally and geographically and helping reduce the need to travel. Minimum standards of inward investment could enhance the area, coupled with the roll out of smarter travel initiatives across London and strict parking standards.

The Mayor must make sure that the Economic Development Strategy fully integrates policies to deliver on climate change.

In terms of initiatives supporting low-carbon development, and examples from elsewhere, there have been some recent developments:

– The recent DECC announcement on Clean Energy Cash-back scheme – or feed-in tariff


The Conservatives are also supportive of such a scheme.

– The Green Investment Bank announced in the 2010 Budget


The Conservatives also have plans for such a scheme.

– Birmingham has set up a green new deal linked to housing:


Chapters 4, 5 and 6

Sectors other than transport

The draft Strategy headlines some key proposals which have already been announced, such as plans for ‘a free carbon makeover’ for 200,000 homes by 2012, and the 10 low carbon neighbourhoods or zones (for a 20.12% cut in CO2 by 2012). While these were welcome, for measures such as retrofitting homes and buildings to be effective there must be rapid and comprehensive roll out with pilot schemes mainstreamed across the whole capital. The assumptions on cuts in CO2 resulting from such measures must be based on realistic take up assessment. The draft Strategy is currently vague about how the variety of initiatives should be coordinated to create real momentum and to engage with people and businesses.

Regarding new build, the draft revised London Plan proposes removing from policy the requirement for a 20% cut in CO2 through on-site renewable energy – but this must be retained in policy as a key way to help deliver cuts. We understand that many in the development sector seek removal of this policy. It is doubtful that without such a policy the development sector would have moved as quickly as has been the case to pay attention to the use of energy in their designs. The policy be added to, not be removed.

On Energy supply, while it is welcome that the Mayor has adopted the target to produce 25% of London’s energy from decentralised sources, plans and investment for decentralised energy seem uncertain. More attention should be given to increasing the supply of renewable energy including for decentralised energy. There is potential to do more to develop renewables in London, and to support development of this sector.

In terms of energy, one key aspect is in relation to waste. Energy from waste must be only exactly that i.e. from materials that cannot be recycled. Thermal treatments such as gasification and pyrolysis bring a danger that materials which could be recycled would be used as feedstock. Anaerobic Digestion (AD) is a preferable technology and produces a 100% renewable gas, which can also be used in the transport sector. There is reference to the use of “sustainable biofuels” in the transport chapter and the true sustainability of biofuels requires great scrutiny and certainty that the fuels originate from truly sustainable sources .

Chapter 7 – the transport sector

We refer to the very limited contribution the sector is set to make towards the cuts needed, as set out above under Chapter 2 and “The role of different sectors”.

Transport could play a bigger role in making cuts, as stated above, to help avoid the need to rely on uncommitted measures, and to achieve at least a 40% cut by 2020 as well as more than a 60% cut by 2020 if needed. Transport is an area where the Mayor has probably the most control over emissions through considerable budgets to support policies to reduce emissions. Furthermore action to reduce CO2 emissions from transport would also have particular benefits in meeting EU legal air quality limits, help reduce inequalities, and enhance health through reducing air pollution and from more people walking and cycling instead of driving. Reduced traffic and congestion would also benefit business, whereas the MTS shows a 14% increase in congestion expected on 2006 levels despite planned public transport improvements and increased cycling.

In relation to urgent need to reduce air pollution, Professor Kelly of King’s College London stated to the Environmental Audit Committee that “we need to reduce the number of vehicles on the roads by a least 20 to 30 per cent”. This would clearly also benefit carbon emissions.

However the Mayor is proposing several policies in the London Plan and Mayor’s Transport Strategy (MTS) which would unnecessarily increase traffic which is likely to take emissions in the wrong direction, and so curtail the transport sector’s contributions to cutting CO2.

Key policy proposals with negative impacts are:

– the proposed removal of the Western Extension of the Congestion Charge zone (WEZ), which has had a proven beneficial impact of reducing traffic entering the area and emissions of CO2; this WEZ needs to be retained for these reasons and for its role in tackling air pollution.

– removing policy on road traffic reduction targets, when traffic levels urgently need to be curtailed as part of health and sustainable economic progress; such targets need to be retained in policy and strengthened.

– relaxing some parking standards in outer London, when these need to be at least retained, and more car-free or car-restricted development pursued if the form of new economic activity in outer London is not to replicate the kind of development which has led to much of London suffering the costly effects of traffic bound developments.

– to make it easier to build new roads which would then facilitate road building such as road river crossings proposed (3rd road crossing at Blackwall, vehicle ferry/road crossing at Gallions Reach). The Public Inquiry into the proposed Thames Gateway road bridge showed that such road building would generate substantial amounts of new traffic, would be likely to add to congestion in the area rather than help it (with any relief of existing congestion likely to be short-lived), and would worsen air quality as well as add to CO2 emissions. Criteria for allowing any road building must be strengthened if anything as solutions must deliver on social and environmental aims particularly in an area already disproportionately affected by a poor environment – benefitting those most in need and reducing inequalities rather entrenching them as would be expected to occur with road building. A better investment would be in further public transport capacity, helping free up existing road capacity for essential vehicle journeys, helping to develop east London in a low-carbon way as part of the Government’s Thames Gateway eco-region.

The impacts the above proposals would have on CO2 levels must be clearly set out in the relevant Mayoral Strategies.

The Mayor should also introduce policies that would increase transport’s contribution to CO2 cuts such as:

– rolling out smarter travel initiatives across London, deploying lessons from pilot schemes, and re-allocating road space to provide more attractive and safer walking and cycling conditions, and to assist public transport.

– rolling out road user charging more widely, rather than have it as a reserve policy

– reconsider the use of the CO2-related congestion charge

– opposing any increased airport capacity in London, particularly to oppose the 50% increase in flights sought for London City airport on social and environmental grounds as this would exacerbate problems local people are already suffering, as well as increase carbon emissions.

For further information and to discuss this submission please contact:

Jenny Bates

Friends of the Earth London Campaigns Co-ordinator

26-28 Underwood Street

London N1 7JQ



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