NY Climate Coalition summary response to NYC draft Climate Strategy
(April 2023)
Please note that this is a summarised version of NY Climate Coalition’s full joint response. See also our full response at Full response to NYC draft strategy | 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.
The report states:
‘Some future changes are unavoidable and/or irreversible but can be limited by deep, rapid and sustained global greenhouse gas emissions reduction.’
‘There is a rapidly closing window of opportunity to secure a liveable and sustainable future for all (very high confidence).’
According to UN secretary general, António Guterres, ‘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.’
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.
We feel it misses opportunities to 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 but has relatively few specific targets and no milestones.
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.
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 (see full response). 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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Agriculture (and land-use)
The draft climate strategy does not adequately address the challenge of (or set out solutions for) reducing the county’s agricultural emissions, which make up 33% of the region’s total GHG emissions.
We propose a number of approaches in our full response. Overall, bolder thinking is required, e.g. landscape-scale recovery plans linked to the Environmental Land Management schemes (ELMs) and working with regulators, landowners and sector associations (see NFU’s 2040 net zero plan).
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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. Current training provision is wholly inadequate. We recommend a full day of Carbon Literacy Project training for all councillors and all senior officers in decision-making roles to 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.
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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).
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.
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?
In addition to any existing measures inherited from the previous eight councils, NYC should 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.
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. The next most effective mitigation actions are energy-efficiency, stopping deforestation and reducing methane emissions. By contrast, the combined potential mitigation impact of nuclear power and carbon capture and storage (CCS) is much lower and involves at far higher cost.
In NY, 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.
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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.’
While central government is of course best placed to drive the broader changes needed in order to decarbonise our economy, we 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.
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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 or funding 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 ‘Taking action now will reduce costs and impacts in future years’. 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.
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 and to apply a shadow value on carbon.
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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.
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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. This message is well conveyed in the draft strategy, although we would like to see more appreciation of Nature for its own beauty and richness as well as its economic usefulness. Traditional cost-benefit approaches are not good at capturing those benefits.
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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. 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. 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.
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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 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.
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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.
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Active travel
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. It contains measurable goals (e.g. increase walking by 40% by 2030, increase cycling by 900% by 2030, decrease vehicle miles travelled by 48% by 2030), considers how these will be achieved, assigns responsibilities to the actions, and then covers challenges and risks. By contrast, the NYC strategy (section 7) covers transport in less than 2 pages and lacks much of the detail of the Routemap, leaving mostly generalised statements.
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Energy
We welcome the draft strategy’s emphasis on domestic energy-efficiency/retrofitting, which is one of the most effective and cost-effective options for decarbonisation. However, we have strong concerns about the absence of dedicated funding beyond hoped-for government grants. See above under ‘Not waiting for central government action’ and ‘Planning’.
The government 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 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. 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.
How can NYC generate a critical mass of action? Mechanisms, incentives? Public recognition? It should consider ways in which it can raise awareness more generally and encourage positive action.
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’
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? We recommend the Doughnut Economics methodology.
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.