NY Climate Coalition full response to NYC draft Climate Strategy
(April 2023)
For a summarised version of NY Climate Coalition’s joint response, see Summary response to NYC draft st... | NY Climate Coalition.
General comments
North Yorkshire Climate Coalition welcomes the opportunity to comment on NYC’s draft climate strategy. We appreciate the considerable effort that has gone into pulling the draft strategy together in collaboration with the former districts and other contributors.
The wider context here is that of a planetary climate ‘emergency’ (or ‘crisis’). The recent IPCC synthesis report produced by the world’s top climate scientists and endorsed by 195 governments (including the UK) presents a very stark picture of what climate change will mean:
‘B.2.1 In the near term, every region in the world is projected to face further increases in climate hazards (medium to high confidence, depending on region and hazard), increasing multiple risks to ecosystems and humans (very high confidence). Hazards and associated risks expected in the near-term include an increase in heat-related human mortality and morbidity (high confidence), food-borne, water-borne, and vector-borne diseases (high confidence), and mental health challenges36 (very high confidence), flooding in coastal and other low-lying cities and regions (high confidence), biodiversity loss in land, freshwater and ocean ecosystems (medium to very high confidence, depending on ecosystem), and a decrease in food production in some regions (high confidence).’
The report notes that we cannot now avoid some of these impacts, but we can still do a lot to make them less severe:
‘Some future changes are unavoidable and/or irreversible but can be limited by deep, rapid and
sustained global greenhouse gas emissions reduction.’
‘Deep, rapid, and sustained mitigation and accelerated implementation of adaptation actions in this decade would reduce future losses and damages related to climate change for humans and ecosystems.’
‘We still have time to act, and we have everything we need to act. We know which mitigation and adaptation measures work. But the sense of urgency in implementing them is currently lacking.’ (Lead report author Dr Friederike Otto).
‘This report is a clarion call to massively fast-track climate efforts by every country and every sector and on every timeframe. Our world needs climate action on all fronts: everything, everywhere, all at once.’ (UN secretary general, António Guterres).
We strongly recommend that all elected members and all senior council officers read this IPPC report so that they have a sense of the gravity of the situation and of our shared responsibility to take rapid action on the required scale.
Against this background, we believe NYC’s draft climate strategy as a whole needs to be more ambitious in order to reflect the seriousness, scale and urgency of the report’s findings.
While we support the overarching goals of the draft strategy and welcome the many positive elements it contains – e.g. references to other important sources of ideas and recommendations (such as the Rural Commission report) and the efforts made to consult and inform residents through Let’s Talk and the webinars – we believe that overall it is unduly constrained by pragmatic considerations (e.g. current government policy and concerns that NY residents may not support more radical options). As a consequence, we feel it misses opportunities to go beyond a relatively incremental, business-as-usual approach and create instead a vision that can unite the people of NY in a common purpose at a crucial moment in our human history.
The draft strategy sets out good overall objectives (mitigation, adaptation, Nature, NZ NYC by 2030, NZ NY 2034, CN NY 2040), and we welcome the fact that target review periods are set. However, it has relatively few specific targets and, importantly, no milestones. We believe milestones are essential to measure progress.
We note that some of the proposed targets in the draft climate strategy are relatively unambitious, e.g. page 12 ‘increase share of public transport – by bus 8% and train by 17% of all journeys by 2030; plant 37,000 hectares (= 91,429 acres) of woodland by 2038; install an additional 2,500 MW of electricity via renewables (the 'Harrogate and the Dales' LAEP on its own gives 2,000 MW, so why only a further 500KW from other parts of the region?)
We acknowledge that some of these gaps in ambition can still be filled by other strategies under development/to be developed, e.g. YNY Retrofit Strategy, the Local Transport plan for NY and the North Yorkshire and York Local Nature Recovery Strategy. However, these will take time to produce, and the IPCC report stresses that the time available for developing strategies, consulting on them and then taking action is now very limited: ‘There is a rapidly closing window of opportunity to secure a liveable and sustainable future for all (very high confidence).’
Coalition members liked the idea of ‘climate-responsible choices’; the draft strategy’s explanations of scientific context, challenges and future scenarios (e.g. ‘cascading impacts on health, etc); and the Council’s commitment to ‘get its own house in order’.
We are particularly concerned that some of the more ambitious targets (e.g. retrofitting 250,000 buildings, installing 270,000 heat pumps, improving/expanding pathways for cyclists and pedestrians) all involve very significant funding that is not allocated in the Council’s (draft) budget. The only specific funding streams mentioned are government grants and ‘devolution deal finance’. These may or may not materialise. As such, the proposed actions may prove unviable due to lack of funding. See also below under the heading ‘Resourcing – Financial’.
We note that the draft strategy is divided into NYC’s ambition to be carbon neutral by 2030 in its own operations and its wider contribution to the regional ambition (as set out in the YNYLEP Routemap) of being carbon neutral by 2034 and carbon negative by 2040.
The first of these (NYC’s own operations) is important as a sign of Council leadership in this area. However, we note that the public sector as a whole contributes only 2% to NY’s production-based GHG emissions total (2020: 5.8 MtCO2e according to BEIS statistics). From an overall mitigation perspective, therefore, the strategy is much more important in terms of what is says about the Council’s contribution to the wider regional targets for NY (and YNY), i.e. how far it can influence the remaining 98% of regional emissions, primarily from agriculture (33%), transport (28%), homes (19%) and industry (12%).
In this context, according to the Local Government Association (LGA), local authorities can act as place shapers, master planners, purchasers, problem solvers, asset owners and convenors.
According to the LGA’s Councillor workbook – The local path to net zero, ‘Whilst local authorities are directly responsible for only 2-5 per cent of local emissions, through their policies and partnerships they have strong influence over more than a third of emissions in their area.’
The draft strategy acknowledges this crucial role and sets out three overarching strategic objectives – reducing greenhouse gas emissions, preparing for the changing climate and supporting nature to thrive. We welcome the inclusion of Nature as a third key objective.
We like the draft strategy’s description of risks and opportunities and its summary of the main challenges (grid capacity, transport in a sparsely populated region and a relatively energy-inefficient housing stock). However, see below under Agriculture.
Beyond the public consultation on this draft strategy, we would encourage opportunities for all NYC staff to have a say on what they are already doing or would like to do to support aspects of the strategy, and how NYC could support actions in their respective department. NYC may already have provided these opportunities for staff input.
We like the emphasis in the strategy on working with other organisations: ‘We will work with partners to develop climate change awareness and actions approach to enable individuals, organisations and businesses to make climate responsible choices.’ (nb typo in the draft strategy text here). In this context, alongside climate/environmental organisations (e.g. NY Climate Coalition, Yorkshire Wildlife Trust, Yorkshire and Dales Rivers Trust), we would highlight the role of town and parish councils, business/industry groups (e.g. NFU), community organisations such as Community First Yorkshire and other initiatives such as Race to Zero and Race to Resilience (see below).
Given the scale and urgency of this challenge (see IPCC report above), we would encourage NYC to consider and adopt other more radical approaches to complement those set out in its draft strategy. These should include setting up a North Yorkshire Citizens’ Assembly (see e.g. https://www.glasgow.gov.uk/cop26citizensassembly). If properly briefed, this would help to create a stronger vision of what is needed in our region and give NYC a stronger mandate to adopt more innovative approaches and act with greater urgency. NYC should also consider innovative methods of generating new funding for decarbonisation measures (see e.g. https://issuers.abundanceinvestment.com/council-climate-bonds), creating an Executive post with sole responsibility for climate policy/action, appointing an in-house climate champion, NY young climate ambassadors, introducing voluntary speed limits in our region and a commitment by elected members and senior officers to undertake at least one full day of climate training (leading by example). Many of these and other ideas have already been tried successfully by other local authorities. Some (e.g. climate literacy) are discussed in more detail below. If communicated with real conviction, measures such as these would help to fill the ambition gap and create a strong sense of common purpose across NY.
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Specific areas
Agriculture (and land-use)
The section on challenges (from bottom of page 8) omits agricultural decarbonisation as a major challenge. Given that agriculture is responsible for 33% of the region’s GHG emissions, this is surely a major challenge. What form does that challenge take? The sheer scale of farming activities in our region? Vested interests? Resistance to change? The political risk of any policy that suggests reducing meat consumption? The Lobbying power of the agriculture sector? Lack of awareness of solutions among farmers? The need to create new incentives (and disincentives) for farmers to reduce their emissions?
We understand the sensitivity and risks of climate policymaking in this area, especially in our region. However, it cannot be avoided. While NYC may argue that it has little direct influence in this area, it must explore every opportunity to work with partners (especially regulators such as the Environment Agency and sector representatives, esp. the NFU – see below) to drive down agricultural emissions. How has this challenge been tackled in other agricultural regions? Herefordshire is a similarly rural county. Herefordshire County Council’s Farming and Land-Use Action Plan may provide some ideas for a NY approach.
The issue of mitigating agricultural emissions is addressed in section 7a (p. 31) of NYC’s draft climate strategy:
‘As a Council we have less interaction with this sector than other economic sectors but we can work in partnership to support decarbonisation activity.’
Strategic objectives are shown as:
‘i. Support agricultural businesses to calculate and reduce their emissions through partnerships such as protected landscapes and Grow Yorkshire
ii. Increase efficiency of food production through low carbon technologies
iii. Support local food supply chain initiatives such as reducing ‘food miles’, and improved quality to encourage ‘sustainable’ diets.’
Under the heading ‘Capturing and storing carbon’, we welcome the fact that the draft strategy proposes to ‘Encourage the use of farming techniques to store carbon in the landscape such as regenerative agriculture, tree, hedgerow and soil management.’
These sectoral objectives, initiatives and proposals are appropriate. Overall, however, the draft strategy appears ‘light’ in its approach to tackling agricultural emissions.
Given that agricultural emissions make up a third of the county’s emissions, much more is needed on what we can do (e.g. see below NFU strategy, opportunities created by ELMs for more sustainable agriculture). Also, the strategy does not differentiate between the different farming systems in the county, ranging from large arable to smaller upland sheep farms (and all things in between).
Some specific recommendations
NYC could work with regulators (e.g. the Environment Agency) to set emissions limits for diffuse pollution, to avoid wasted fertiliser application and reduce the need for carbon-intensive 'end of pipe' treatment of nitrates and phosphates.
NYC could promote nature-based solutions to improve catchment water resources and sustainability and to lock up carbon in peatlands (especially given the nationally / internationally important scale of peatlands in North Yorkshire. This requires bolder thinking, such as landscape-scale recovery plans linking to the Environmental Land Management schemes (ELMs).
NYC could work with landowners to proactively implement ELMs and measures to reduce emissions and promote sustainability.
We would also point to the following reports and proposals as examples of how the draft strategy could be firmed up in this area.
The National Farmers’ Union plan to achieve net zero by 2040: Achieving net zero – meeting the climate change challenge – NFUonline. This is referenced briefly on page 51 of the draft strategy but could be fleshed out to give agriculture a much more substantial profile. Farmers may be more likely to embrace the case for net zero in NY if they are aware that the sector’s main union is actively promoting early adoption of net zero by 2040. The report sets out ‘how the farming industry is in a position to be part of the solution to climate change; what the NFU is calling for to help farmers work towards implementing solutions; changes you can make on farm as part of your day-to-day business decisions.’ On the website, the NFU invites its members to join its net zero pledge. The map below shows the number of farms that have already signed up to this pledge in our region. The number is quite small, but the NFU’s pledge initiative could act as a useful platform for NYC to encourage other farms to adopt low/zero-carbon methods.
NFU pledge map from Net zero – Make your pledge – NFUonline.
The NFU has also published a booklet entitled Doing Our Bit For Net Zero' booklet, with ‘26 case studies, from farms across England and Wales, showing how farmers are working towards net zero, illustrating how changes can be made to farming businesses to help achieve the NFU’s 2040 net zero ambition. The examples represent every farming sector and cover each of the three pillars outlined in the NFU’s net zero plan: productivity, carbon storage, and renewables and bioenergy.’
Has NYC held discussions with NFU North-East on a regional target?
The Council should also be aware that the NFU’S Net Zero by 2040 strategy has been criticised as ‘way too slow’, overly reliant on unproven technology and overly reliant on government action. Even so, any attempt to tackle agricultural emissions would need to involve the NFU as a key stakeholder.
The NYC draft climate strategy appears to lack background information on the way in which agricultural activities contribute to climate change and, in many cases, degrade our natural capital (e.g. nutrient run-off into watercourses). Most readers are likely to be familiar with the mechanism by which burning fossil fuels produces CO2. However, they may be less familiar with the sources of GHG emissions from farming (e.g. methane from belching livestock and nitrous oxide as an indirect product of organic and mineral nitrogen fertilisers). We suggest including some factual information in the strategy by way of context, perhaps also setting out the main challenges to GHG mitigation in the sector.
Linking agriculture and nature-based solutions. We welcome the fact the draft strategy includes a strong focus on Nature. However, there is an impression given by the document that 'Nature' is seen as separate from 'agriculture'. There is a need to link the two so that agriculture and land management more widely deliver nature recovery networks at the required scale. It is not adequate to rely solely on protecting nature in designated protected sites – wider biodiversity matters throughout the landscape.
While initially poorly designed, DEFRA’s now revised ELMS initiative could act as the springboard needed to encourage the uptake of sustainable, low-GHG farming practices in our region. How can NYC support this and provide additional incentives?
NYC should explore the potential for links with the Nature Friendly Faming Network: Nature Friendly Farming Network - Sustainable Farming (nffn.org.uk)
Background on ELMS: Environmental land management schemes: overview - GOV.UK (www.gov.uk)
Other important initiatives covering the sector include DEFRA’s Sustainable Farming Incentive (SFI), Countryside Stewardship and Countryside Stewardship Plus.
Soil association: https://www.soilassociation.org/causes-campaigns/climate-change/
NYC is unlikely to have the in-house expertise to maintain an overview of all these schemes. We therefore recommend that NYC obtain external advice/guidance (e.g. government agencies, NFU, agricultural consultants) where required to ensure that its strategy reflects and harnesses the full potential of all these (and any other) schemes.
As a general point on agriculture and land-use, we would emphasise the need for landscape-scale change. Peatland is a good example. Soil loss is already up to 300mm in well-maintained moorland bogs with only a 1.2°C rise in average global temperature. However, the draft NYC Climate Strategy correctly anticipates possible temperature rises between 2° and 4°C. A study by the Climate Change Committee notes: ‘Whilst it is hoped that restored peatlands will be able to withstand climate change pressures, it is possible that they will not and that their condition and associated provision of ecosystem services will decline over time. However, in either case, degraded peatlands will be less resilient and will experience more rapid deterioration in ecosystem service delivery than functioning peatlands.’ If peatland burns or dries and is blown away, the stored carbon is added to atmospheric concentrations. It follows that any further loss or degradation of North Yorkshire’s peatland must be avoided.
We fully support the draft strategy’s target for 100% restoration of upland and lowland peatlands. This target is for 100% of peatland to be ‘under restoration’ by 2038. Is this as ambitious as it could be? Could this date be brought forward? Given the huge capacity of healthy peatland to store carbon and the fact that our region is home to 24% of England’s total – storing over 40 million tCO2e, we urge NYC to provide as much financial and political support to the Yorkshire Peat Partnership as possible.
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Climate literacy training for councillors and senior officers
A commitment to undertake climate literacy training should be in the strategy as a clear indicator of seriousness and intent. How can councillors and senior officers (except those with relevant expertise) be expected to manage/guide NY’s transition to a low-carbon economy on the basis of a 90 minute training video? We acknowledge that this is better than no training, but given the huge scale and complexity of the task ahead, it is wholly inadequate.
All councillors and all senior officers in decision-making roles should undertake a full day of Carbon Literacy Project training. This would ensure that they are aware of the mechanisms that are driving climate change, have a greater sense of the urgency of tackling it and understand the policy implications (e.g. risks and opportunities of action and inaction).
We believe such training should be at the heart of the strategy. Indeed, it should be an explicit commitment in the strategy.
This would have the added advantage that all participants have to set a personal carbon reduction goal, and a team goal, which would encourage change in behaviours across the organisation and sharing of good practice.
Apart from these gains in terms of institutional knowledge-building, it would also put NY on the map at relatively little cost and generate positive coverage for the new Council.
Suggested wording:
‘NYC wishes to demonstrate its commitment to delivering this strategy by providing a full day of climate literacy training for all elected members and senior council officers (e.g. xxx level and above) with the UK’s best-known provider, Carbon Literacy Project. We have made a start on this training path. Councillor Greg White has completed the UK 100 Climate Leadership Academy and incoming AD Environment Michael Leah has completed the CLP training with the Association for Public Service Excellence (APSE). + Insert training arrangements for elected members and other senior staff. We encourage our partners in the public and private sector to consider arranging this training for those of their employees in decision-making roles.’
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Urgency
We understand that the draft Climate Strategy is not an action plan and as such focuses on broader objectives. Equally, we acknowledge that NYC intends to produce a detailed action plan (to be in place by September 2023).
In one sense, this is a logical sequence and should ensure that the strategy and action plan undergo appropriate (public) consultation and review and therefore have greater public buy-in.
Given the context of a climate emergency, however, we have reservations about the length of time involved. The UN Environment Programme states: ‘The science is clear. The world is in a state of climate emergency, and we need to shift into emergency gear.’ According to UN experts, action to bring about radical cuts in emissions is required within the next 5-10 years to avoid likely tipping points in the world’s climate systems. Assuming the NYC action plan is in place as anticipated towards the end of 2023 (‘every Directorate and Service has a Climate Change Action Plan to support prioritisation, by December 2023’), it seems likely that the first actions based on the strategy will not be implemented until 2024.
We are aware that some district-level and NYC actions are already being implemented. Apart from a few sporadic references, however, it is not clear from the draft climate strategy what specific actions are currently in place and already reducing the county’s emissions. This may create an impression that there will be a period of inaction on climate change while the strategy is finalised and while the ensuing action plan is prepared, put out to consultation, finalised and then adopted.
To avoid this impression, we have two suggestions.
First, the strategy should explicitly reference existing actions. What measures are already being taken across the county to mitigate our emissions, adapt to the changing climate and support Nature? Are these actions at a meaningful scale? What level of county-wide GHG reduction might they realistically achieve? Is that enough?
Secondly, we suggest that – in addition to any existing measures inherited from the previous eight councils – NYC identify a series of agreed ‘low risk’, ‘low regret’ (but ideally big impact) actions that it could begin to implement more or less immediately rather than waiting for a finalised and formally adopted action plan. We are currently working on recommendations for such actions.
In this context, as noted in the IPCC synthesis report, we would highlight that some actions will produce a much greater mitigation effect than others. See below under the heading Best mitigation options.
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Best mitigation options
Some GHG mitigation actions have more potential and are more cost-effective than others. These are set out in a chart on page 28 of the IPCC synthesis report.
The chart (see below) shows that solar and wind power are by far the best mitigation options, with the potential to cut a huge 8 billion tonnes each year from global CO2 emissions by 2030 (equivalent to the combined emissions of the US and European Union today). The next most effective mitigation actions are energy-efficiency, stopping deforestation and reducing methane emissions. According to the report, the combined potential mitigation impact of nuclear power and carbon capture and storage (CCS) is much lower at around 1.5 billion tonnes, and at far higher cost.
Obviously, some of the options shown in the chart will not apply to North Yorkshire, but many do. In terms of potential, the most effective solutions – wind, solar, trees, energy-saving, reduced conversion of natural ecosystems, carbon sequestration in agriculture, ecosystem restoration and shifting to healthy diets, require no new technology. In terms of cost (blue-red scale), the chart shows that solar, wind, fuel-efficient vehicles and public transport/cycling are the cheapest options that can be influenced by NYC.
We suggest that NYC consider these findings in its assessment of the most promising and cost-effective options in our region.
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Not waiting for central government action
The draft Climate Strategy states (page 18): We know these are extremely challenging and ambitious targets. We must accept that, at present, it may not be technically or financially possible to achieve them and they will require significant Central Government policy interventions to drive the economic and infrastructure systems to change which we will continue to work with partners to lobby for.’
NY Climate Coalition acknowledges that national policies are likely to have the greatest impact and that action by local government is subject to nationally imposed budget constraints. However, we believe there is a risk in waiting for central government action. Writing in the Local Government Chronicle in January 2023, Mark Kemp, president of the Association of Directors of Environment, Economy, Planning & Transport, observed that local authorities cannot afford to wait for government intervention, planning system reform and additional resources:
‘Government action on climate change has been high on word count and low on action. Disjointed policy making, dispersed funding pots and a prolonged silence on biodiversity net gain, embedding environment and nature into planning, and enabling local authorities to deliver through increased powers and resources, have been dispiriting. Those of us in local government cannot just shake our heads and wait for that to change. If COP27 achieved anything, it reminded us that the climate emergency is accelerating. The recent UN Emissions Gap Report confirmed that the 1.5°C target has been missed, so it is left to us to roll up our sleeves. If I could send one clear message to my many careworn colleagues it is that everything you do is making a difference. We cannot wait for the government to respond faster, although it should. We already have powers we can use to grow resilient and sustainable communities. We have control over our own procurement policies and we are creating processes to address scope one, two and three emissions, working with partners and supply chains to achieve net zero.’
While central government is of course best placed to drive the broader changes needed in order to decarbonise our economy, we support Mark Kemp’s view and urge NYC to lobby but not wait for those changes and in the meantime to harness every lever at its disposal (procurement, transport, planning, etc) to drive the transition at full speed.
In doing so, it will need to show leadership, a clear vision and deploy all its powers of persuasion. This will require a strong communication strategy, especially to keep the economic and social benefits and co-benefits at the forefront in public perceptions.
See also below under individual page comments (page 18).
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Resourcing – financial
The success of any strategy depends in large part on adequate funding. NYC’s draft climate strategy appears to rely heavily on external sources of funding: ‘We will ensure we are ready and prepared to seize all appropriate opportunities for additional funding to help achieve the ambitions for the Council set out in the Strategy and for the region in the Routemap.’
In addition to external funding, as we understand it, climate actions may also be funded out of capital budgets for individual directorates. While these sources of capital may (or may not) prove adequate to fund parts of the strategy and the associated actions, we are concerned that no specific amounts have been allocated in the Council’s budget in the form of revenue spending (e.g. to cover recurring costs related to climate action) and capital allocations.
The draft strategy acknowledges that climate action taken today will save costs in the future: ‘Taking action now will reduce costs and impacts in future years’ (page 9). We urge the Council to ensure that action is not unduly reliant on the success of competitive funding bids and that crucial measures such as retrofitting and upskilling are not held back by a lack of dedicated funding.
Finally, in this context, we recommend that NYC action should be driven by a comprehensive appraisal framework that prioritises those projects with the greatest carbon reduction impact per £ spent, with sufficient funds available to pilot innovative projects.
To this end, NYC should apply a shadow value on carbon. Central Government uses a current social value of around £40 per tonne of CO2e rising to about £80 per tonne in 2030. In the interests of early progress, these or similar values should be adopted in appraising early work and commissioning projects.
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Resourcing – human
We suggest that overall responsibility for driving climate change policy and action, galvanising partners and the wider public, and communicating NYC’s climate vision in the media should lie with a single elected member and a single council officer to avoid any dilution of responsibilities and messaging. According to Committee membership | North Yorkshire County Council, Cllr Greg White is currently responsible for ‘working in localities, including stronger communities, Area Constituency Committees, broadband and mobile telephony and to act as the Council’s digital champion, working with Parish and Town Councils, libraries, and other face-to-face contact points (Registrars, Coroners and Records), and the Council’s response to Climate Change. We would argue that the portfolio of the Executive member responsible for the Council’s response to climate change should allow him to maintain a consistent focus on driving climate action without additional responsibilities. This is a huge remit on its own. Importantly, this would also demonstrate the importance attached by the Council to this issue and help to raise public awareness. For the same reasons, we would suggest designating a single council officer in a senior decision-making role as NYC’s ‘climate champion’ with an exclusive focus on climate policy, action and public engagement.
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Carbon budgets
The draft strategy notes that future actions may include setting a carbon budget target to ensure that we are making sufficient progress. Year-by-year carbon budgets should be developed for each part of the Council’s activities, starting with departmental totals. The annual (financial) budgeting process should be mirrored by a carbon budget allocation. The two processes should be fully integrated.
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Nature
We welcome the inclusion of Nature as one of the strategy’s three key elements. The strategy acknowledges the important role of Nature in combatting climate change (e.g. nature-based solutions, cooling cities as temperatures rise, flood mitigation, placing nature at the heart of adaptation). Section 7c states: ‘Nature underpins our economy, enriches our lives and helps protect us from environmental threats. We rely on healthy, well-functioning ecosystems to provide us with food, clean water, natural fibres and timber and our way of living and economy is based on natural world ecosystems. The food that we eat, the water we use, the clothes we wear and the businesses that drive our economy are reliant on the health of the natural world ecosystem and this is under threat.’
This message is strong, though we would like to see more appreciation of Nature for its own beauty and richness as well as its economic usefulness. Very often ‘supporting nature’ comes at a financial cost, but in due course generates major economic benefits, though traditional cost-benefit approaches are not good at capturing those benefits. Without active protection and support of nature we risk wrecking our economic position so thoroughly that it becomes impossible to avoid economic decline, yet our decision-making systems generally push us down a ‘growth agenda’ without sufficient attention being given to environmental consequences. See also below on the Doughnut Economics methodology.
We would suggest a reference to the 30 by 30 Plan adopted by the Convention on Biological Diversity (the commitment to protect at least 30% of land and sea for nature by 2030). Does NY have an allocated target within the UK commitment? As a rural region, can we set a higher target?
We would suggest a commitment in the strategy to engage with Yorkshire Water, the Environment Agency, Yorkshire Dales Rivers Trust (YDRT), the NFU, our region’s MPs and other relevant stakeholders to address the issue of storm sewage discharges. According to the latest Environment Agency data for 2022, Yorkshire Water was responsible for 54,273 sewage spills lasting a total of 232,054 hours, equivalent to 9,669 days of continuous sewage discharges into our rivers and coastal waters. While this may not have a direct link to climate mitigation or adaptation , it certainly falls under the strategy’s third main focus, i.e. ‘Supporting Nature to Thrive’.
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Planning
The draft strategy includes a commitment to use the future development plan (anticipated 2028) to ‘ensure properties do not require retrofitting in future’. Given the urgency of this task, this timescale needs to be drastically shortened.
One of the main challenges to decarbonising the region is the current lack of a single unified local development plan. We hope to address this with NYC at a future meeting (with Michael Leah and if possible NYC’s new chief planning officer on 18 May).
Some of the current district-level local plans that will remain in force for several years contain useful supplementary planning documents (SPDs) covering all aspects of planning, including design codes. Indeed, there is now a requirement for local authorities to produce a design code, and a model can be found at National Model Design Code - GOV.UK (www.gov.uk). Design Codes are incredibly useful as they can prescribe how development should be presented in specific areas whether at the strategic or local levels. The codes can set out matters of aesthetic appearance and what important elements of architectural note or heritage within a specified location should be preserved and considered in new design; but also can incorporate climate-friendly requirements, including building materials, cycle parking, planned greenspace, walking and cycling routes, flood resilience measures and biodiversity net gain. This helps both local planning authorities and developers know what is expected to be delivered when undertaking any master-planning exercises.
One approach being explored is to produce a specific overarching ‘net-zero’ supplementary planning document which can be adopted for all former district areas for use across the new Authority area until such time as a single Local Plan document can be developed. The principles of such a net zero SPD can then be lifted (and updated) into the emerging document. The net-zero SPD would be linked to relevant policies in each existing local plan and would enable essential low-carbon and net-zero principles to be embedded within all decisions affecting all types of development including buildings, infrastructure and the need for green space. It is envisaged that this would include low/zero-carbon construction techniques, low/zero-carbon embedded materials and technologies in all new-builds including the expectation that all proposals should incorporate appropriate best practice standards and include mandatory rooftop PV or similar to be embedded through design. Furthermore, the SPD would be able to consider the potential for retrofitting, community renewable energy schemes and the need for appropriate responses for climate mitigation such as raised levels, SUDs, planned (multi-beneficial) greenspace areas, tree-lined streets, etc.
The government now plans to publish its Future Homes and Building Standard (FHS) in 2024. The legislation will be introduced before its implementation in 2025. The strategy may (or may not) be ambitious, funded and viable, but in any case we cannot afford to wait until 2025 to ramp up action in this area.
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Procurement
As recognised by the Local Government Association, one of the most effective ways of leveraging the influence of local authorities to accelerate decarbonisation and promote social value criteria is through procurement.
The Council’s strategic objectives (as set out in the draft strategy) should be incorporated into all parts of the wider procurement process, including the contract specifications, exclusion criteria, bid assessments (e.g. awarding additional points to low/zero-carbon suppliers) and decisions on the award of contracts.
While this needs to be done, wherever possible, in ways that do not, for example, disadvantage local SMEs that may not yet have the capacity to offer lower-carbon products or services, the approach should be at the heart of NYC’s decarbonisation strategy for its own operations and the wider region.
We understand that the former Craven District Council has already made significant steps in this direction.
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Transport
The draft strategy highlights that the transport sector is responsible for 28% of carbon emissions in North Yorkshire. The draft strategy notes that the next version of the Local Transport Plan, due by 2024, will set out how we will make ‘quantifiable carbon reductions’.
The LTP will need to explore new and innovative ways to reduce car use while maintaining access for rural communities.
With regard to transport, we would like to see greater ambition and budget investment to develop sustainable ( i.e. EV regular & frequent bus services) in partnership with providers such as Moorsbus.
Individual groups in NY Climate Coalition may have submitted more detailed responses in this area.
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Active travel
Our main concern here is that the targets in the draft strategy appear to be weaker and less specific than those in the YNYLEP’s Routemap to Carbon Negative.
The Routemap, section 4.3 (5 pages), sets out four strategic priorities for transport: ‘Increase active travel’ and ‘Decarbonise & increase use of public transport’ are the first two of these. It goes on to consider how these will be achieved, assigns responsibilities to the actions, and then covers challenges and risks. The NY strategy (section 7) covers transport in less than 2 pages (although a few other mentions are scattered around the document); not surprisingly, therefore, it lacks much of the detail of the Routemap. The prominence of active travel and public transport is lost.
The Routemap contains measurable goals on transport, including:
- increase walking by 40% by 2030
- increase cycling by 900% by 2030
- decrease vehicle miles travelled by 48% by 2030
The NYC draft strategy does not include these measurable goals, leaving mostly generalised statements.
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Energy
We welcome the draft strategy’s emphasis on domestic energy-efficiency/retrofitting. As shown in the IPCC mitigation potential chart (see above), domestic energy-efficiency/retrofitting is one of the most effective and cost-effective options. The government has published plans for energy-efficiency and retrofitting and for the development of a skills base in its revised net zero strategy entitled Powering Up Britain (see page 94 ff ‘Boosting the skills pipeline for the green economy’). Hopefully the government will make appropriate levels of funding available to local authorities for this purpose, but see above under ‘Not waiting for central government action’.
The government plans also include a huge investment (£20 billion) in CCS, and this focus on CCS also finds its way into the NYC draft climate strategy. While we accept the need for some use of CCS to mitigate emissions in some areas, we are concerned that this approach features in an unduly prominent role in the draft climate strategy. To be fair, the draft strategy does say this: ‘where we cannot decrease emissions, we need to capture and store them to reach net zero.’ However, we wish to emphasise that CCS should only be regarded as a solution for mitigating those emissions that we cannot avoid, eliminate or rapidly phase out. It must not be seen as a way of delaying emissions cuts, i.e. continuing to burn fossil fuels on the (unproven) assumption that we can capture the resulting emissions on the necessary scale.
There is considerable scepticism among our members about the role of Drax and biomass burning (even if equipped with CCS) in regional decarbonisation. We note that at national level Chris Skidmore (net zero ‘tsar’) has also questioned the sustainability of biomass. As a minimum, we need to distinguish between what forms of biomass are (or are not) sustainable. He notes: ‘Wood that can be used for products shouldn’t be burnt. There is a reason why the net zero review constantly talked about sustainable biomass – we should have the equivalent of green/grey hydrogen for biomass that would make anything but residual waste unacceptable.’
These questions over CCS, BECCS (mainly Drax in our case) and the use of biomass are fundamental as the YNYLEP decarbonisation targets (especially carbon negative by 2040) appear to depend on their large-scale use.
We are pleased to see a commitment to support community energy projects.
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Influencing behaviour (‘climate-responsible actions’), public climate education (e.g. climate roadshow) and creating a sense of common purpose
As well as formulating and implementing specific policies and actions, NYC will need to encourage leadership among private-sector actors and galvanise action by residents and community groups.
Possible wording: ‘We will endeavour to provide leadership in our role as your elected regional council. However, we cannot do this alone. We need each of you to lead in your own area.’
How can NYC generate a critical mass of action? Mechanisms, incentives? Public recognition? Other suggestions could include an online leadership board (NYC website) and weekly company profiles to highlight the climate action being taken in the private sector. Create a race to the top!
We understand that NYC will want to avoid a ‘preaching’ tone, but as part of its responsibility to inform and engage with the public, it should consider ways in which it can raise awareness more generally and encourage positive action, e.g. a climate roadshow, involve regional celebrities, through an app, by designating NY youth climate ambassadors. Would NYC consider subsidising climate literacy training for local community leaders or residents (e.g. through Carbon Literacy Project)?
Other local authorities have launched campaigns to galvanise wider action (individuals, communities and businesses) and create a sense of common purpose. One such campaign in a similarly rural area is Herefordshire County Council’s Greener Footprints Pledge. We suggest NYC explore this as a possible model for a NY campaign.
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Data, technical matters and ‘net zero v zero’
The GHG emissions in the report are based on 2020 figures. BEIS data for 2021 regional GHG emissions should be out on the last Thursday of June. If the strategy is still being finalised at that point, we recommend updating the figures.
The draft strategy includes plenty of scientific context, references and data (and references to other sources). However, a brief section explaining the difference in the severity of impacts between 1.5 and 2 degrees of warming and why every tenth of a degree matters would be a useful addition.
To achieve the Council’s strategy, robust data management is essential as decisions can only be based on reliable and up-to-date data. Does the Council have the most suitable and robust data management systems it can afford to buy?
The draft strategy states that ‘Our work will take place within a set of principles that ensure our climate change activity is fair, evidence-based, and represents good value’. We note that the term ‘good value’ is subject to interpretation. How will these decisions be made objectively, ensuring that potential future costs due to inaction are also factored in to decision-making. Some decisions may involve weighing up ‘urgent needs now’ versus ‘long-term survival’. What methodology will the Council apply? Will this methodology automatically consider all the UN’s 17 SDGs?
Reliable data collection and analysis are fundamental to demonstrate progress towards the many ambitions and targets set out in the strategy.
Nothing will be achieved if the underlying composition of what is classed as ‘good value’ is not constantly scrutinised, updated and analysed through carbon and financial budgets (including analysis of differences between budgeted and actual outturns). These should cover from one to over ten years on a rolling basis and be regularly reviewed at all levels throughout the organisation.
We recommend the Doughnut Economics methodology, an approach to collecting and interpreting all sustainability data and identifying the full range of costs of any given activity. For more information on this methodology, see https://doughnuteconomics.org/tools/122 and Cornwall Council: Doughnut economics in council decision making – revisiting | Local Government Association. Will the Council use this, or some other similar methodology?
Some statement about this or a similar methodology should feature within the strategy as it gives confidence of HOW the Strategy will be delivered. Otherwise it risks simply becoming, or being regarded as, an unfulfillable wish list.
We welcome the fact that the strategy explicitly states that ‘offsetting should only be used in small amounts for residual emissions that can’t be reduced in other ways.’
What matters is the absolute amount and therefore concentration of GHG in the atmosphere. We cannot use offsetting as an excuse to carry on emitting. Scientists agree that offsetting (e.g. through CCS) will be necessary for hard-to-mitigate sectors such as aviation but absolutely must not be used as a way of avoiding crucial reductions in emissions.
The climate will respond to GHG released into the atmosphere now. Long-term offsetting arrangements that promise to compensate for today’s emissions over, say, 30 years (e.g. by planting trees) will be of little use in reaching our legally binding nationally determined contribution (NDC) of a 68% reduction by 2030 and 78% (sixth carbon budget) by 2035.
Finally, with regard to offsets, we note that recent investigations suggest that many if not most offsets are in any case worthless. See e.g. Revealed: more than 90% of rainforest carbon offsets by biggest certifier are worthless, analysis shows | Carbon offsetting | The Guardian.
The IPCC published its sixth synthesis report on 20 March 2023, emphasising the urgency of reducing our absolute emissions. We would suggest some reference to the report’s findings in the final strategy. NY Climate Coalition has published an open letter to NY elected representatives highlighting the key findings of the IPCC report and in particular the need for even greater urgency in policymaking.
Some of the key findings of the IPCC synthesis report are set out in the general comments at the beginning of this document.’