Select Committee on Environmental Audit Written Evidence


Memorandum submitted by the Regional Development Agencies (RDAs)

  1.  This response to the Environmental Audit Committee's Inquiry into climate change and local, regional and devolved government is submitted on behalf of England's nine Regional Development Agencies (RDAs). A number of RDAs will also submit individual evidence to the Inquiry to elaborate on the issues addressed in this response.

  2.  The RDAs' mission is to transform England's regions through sustainable economic development. In the period since our establishment in 1999, the RDAs' strategic role has deepened and broadened across the regional economic landscape. RDAs' core intervention areas have grown to encompass enterprise, innovation, business support, regeneration, economic inclusion and skills development. The changes announced in the recent Sub-National Review of Economic Development & Regeneration will further RDAs' remit (except in London 8) where the GLA Act 2007 has already assigned further powers to the Mayor of London, including a statutory duty to tackle climate change mitigation and adaptation).

1.  How can central government best support and encourage local authorities, regional government and devolved administrations to take action on mitigation and adaptation, and other climate change related areas like waste and transport? What funding, powers, and structures are required to improve joined up delivery of climate change policy at all levels of government?

  3.  Strong action is already being taken at regional and local level. RDAs' established regional leadership role in shaping strategies and mobilising partners; our delivery role in supporting businesses, commercialising new technologies and innovations; and our investment role in physical regeneration and development, means RDAs are already helping regions address the challenges and opportunities of climate change. Our track record in developing creative and innovative approaches to the economic dimensions of climate change; our ability to bring regional and sub-regional partners (public, private and third sector) to the table; and our strengths as a network in disseminating good practice are delivering a step-change in the response to the climate change agenda. Regional Development Agencies recently published a pamphlet setting out the action we are taking to tackle climate change and making a series of commitments to future action.

  4.  We believe that to be a leading competitive global economy we need to be an exemplar at home and a leader internationally and RDAs are committed to leading that agenda at regional and sub-regional level. Such actions should be seen in the context of the clear understanding at regional level, as set out in Regional Economic Strategies (RES), that quality of life and living within environmental limits represents a competitive advantage for England's regions. When powers are devolved to the regional level, RDAs and other regional and local bodies are proving their ability to deliver carbon emission reductions through innovative action. All regions are already making emission reduction savings, often led by RDAs, and will continue to do so as the urgency of climate change increases.

SETTING AND ACHIEVING TARGETS

  5.  Central government has a vital role to play in setting national targets and encouraging the adoption of regional and local targets to stimulate action. Please refer to our answer to Question 4 for detailed views on setting and achieving targets.

POLICY FRAMEWORK AND STRATEGIC INFLUENCING

  6.  Through the policy it drafts and implements, central government can drive forward action on mitigation and adaptation and other climate change related areas. There needs to be a mainstream and consistent climate change and carbon reduction policy and strategy framework nationally and regionally with policies and priorities based on common and robust evidence and intelligence. Whilst progress has been made, there remains a lack of consistency across government in the desire and implementation of policy on climate change. The Climate Change Bill should help to address this, but behavioural change across government departments and national public sector bodies is also required to achieve the necessary step change. By embedding climate change considerations into policy development, government can set a strategic direction which will drive change. For example, through planning legislation, it can set a strategic direction to encourage a significant shift in energy and waste infrastructure. It must also seek to minimise inconsistencies between its policies. Enabling powers in the draft Climate Change Bill, have insufficient emphasis on facilitating new instruments across all areas of policy to actually deliver emissions reductions and these therefore need to be strengthened.

  7.  Embedding consistent carbon reduction criteria into all government funding streams is critical to accelerating progress, driving innovation and helping to achieve behaviour change which is needed. Rather than creating new, separate funding streams specifically designed to address climate change, it might be appropriate for the Government to use existing architecture and try to mainstream the issue of climate change by driving action forward through existing and proposed new mechanisms. For example, hypothecated landfill tax receipts in the form of the BREW programme can make a significant contribution to tackling climate change; however, there needs to be a strong regional and sub-regional component to BREW funding if regional and local energy and dynamism in this arena is to be incentivised. A truly ambitious Defra in this regard might, for instance, increase the relative sub-national BREW funding streams vis-a-vis current, often nationally segmented approaches to funding. This would reinforce the emerging Single Regional Strategies (together with any climate change indicators that are agreed as part of those strategies) and LAA/MAA approaches to sub-national development. However, in fact, indications suggest Defra intend to do precisely the opposite of this—reinforcing nationally-segmented streams and reducing or eliminating sub-national commissioning through the RDAs. This is likely to be a significant disruption to sub-national delivery in the short-run, and is arguably counter to the intentions of SNR in the medium-term. At the very least, decisions on the amount of funding RDAs can expect (if any), to create the capacity to deliver their component of the Business Resource, Efficiency and Waste (BREW) Programme in 08/09, has not yet been announced which makes it very difficult to maintain momentum of existing initiatives, and forward plan with partners.

  8.  The Government needs to recognise the importance of regions and cities in tackling climate change. There is no mention of regions in the Climate Change Bill. There also needs to be a stronger endorsement of the need to deliver low carbon cities.

ADDITIONAL INVESTMENT

  9.  The Government needs to provide additional investment, via existing regional and local infrastructure, in skills development and training packages, in research and development, in promoting innovation and in attracting inward investment. The RDAs currently fund over 12% of the publicly supported R&D investment in energy (including renewables), enabling us to spearhead work in the development of low carbon technologies. This work could benefit, however, from additional public funding for science, innovation and R&D which prioritises interventions that accelerate a genuine shift to a low carbon economy. RDAs play an important role in promoting and supporting innovation; the recent report of the Commission on Environmental Markets (CEMEP) highlighted the importance of innovation support and creating forward markets (eg through public sector procurement) in creating a low-carbon economy and to position UK business to capture global market share in low-carbon technology and services. The RDAs will need to work closely with government on delivering these aspirations. RDAs play a significant role in the skills development agenda. We are working to identify the new skills needed to face the challenges and opportunities for the future and are working with partners to enhance entrepreneurial and leadership skills. We are working with the Sector Skills Councils to ensure that need is recognised and accommodated and with schools, FE and HE institutions to consider the need for adaptation of the curriculum to develop the knowledge, understanding and skills required on this agenda. Some RDAs have even been helping with the delivery of targeted training programmes, for example, South West RDA is funding a programme to help build capacity within local authority councillors on renewable energy issues whilst emda is delivering a green infrastructure awareness and capacity training programme for local planners. All of these areas of work, however, require additional investment from government if they are to drive forward the pace at which changes are taking place.

TRANSPORT

  10.  National and regional transport priorities need to promote integrated and sustainable transport choices with key investments and improvements delivered swiftly and effectively. The Department for Transport has recently published a discussion document "Towards a Sustainable Transport System—Supporting Economic Growth in a Low Carbon World". This sets out the Department's response to the Eddington study and Stern review. This includes five strategic goals for transport including one (goal 2) that seeks to address climate change by cutting emissions of carbon dioxide and other greenhouse gases. The paper recognises that various actions should be taken forward to address these including behavioural change measures, making better use of our existing transport system, technological innovations, pricing signals, regulation and enforcement, and enhanced public transport services, as well as investment in infrastructure. It is vitally important that Government guidance on transport appraisal techniques, and scheme development mechanisms, are refreshed to ensure that the greenhouse gas consequences of these actions are fully considered. The guidance should also incorporate advice on handling the adaptability of transport proposals to climate change.

  11.  This will ensure that as interventions come forward for funding from scheme promoters (including local authorities), the climate change consequences are fully considered, and that resilient transport networks are developed. In addition, it will be important that these impacts are also reflected in other decision-making processes such as transport prioritisation exercises for the Regional Funding Allocations. The proposed review of the Department's "New Approach to Transport Appraisal" will be a key mechanism through which these can be incorporated, but it will be important that as other DfT guidance is published it also reflects these issues.

  12.  The current technology development platforms are a vital lever for funding and stimulating regional activity. In addition, there should be greater rollout of the "Sustainable Travel Towns" concept currently being piloted in Darlington with funding from the Department of Transport. In a relatively short timescale a 12% shift from car use to public transport has been achieved.

2.  Is there clarity about the role played by local authorities, regional governments and devolved administrations in tackling climate change? How can their actions be coordinated and monitored? How can the accountability and transparency of the response at a local level be improved? How effective has the Nottingham Declaration process been?

  13.  The RDAs view their role as providing regional leadership on the economic dimensions of climate change, both adaptation and mitigation. This includes developing markets for low-carbon technology and services, along with support for R&D and innovation in key sectors (eg environmental technology).

  14.  RDAs are currently responsible for leading the development of Regional Economic Strategies (RES) which shape the growth and development of the regions. AWM and EEDA are both in the process of producing low carbon RES, building on the low carbon focus which SEEDA introduced into their RES last year and all RDAs are committed to including carbon reduction targets within their Corporate Plans. The Sub-National Review of Economic Development and Regeneration (SNR) has tasked RDAs (with the exception of London) with leading the development of Single Integrated Regional Strategies which will bring together the Regional Economic Strategy and the Regional Spatial Strategy and cover economic growth, planning and housing, as well as setting out social and environmental objectives for each region. These will replace the existing Regional Economic Strategies. RDAs will be ensuring that climate change adaptation and mitigation and low carbon aspirations are embedded in these Single Regional Strategies which will direct the investments of many public and private sector partners at regional, sub-regional and local level. It should be noted that many aspects of the Sub-National Review will not apply to London, however the Mayor now has additional duties relating to climate change. The London Development Agency is playing a key role in helping to deliver the Mayor of London's Climate Change Action Plan, with the Mayor having made tackling climate change central to many policy areas over which he has powers. The ambitious Climate Change Action Plan aims to stabilise London's CO2 emissions in 2025 at 60% below 1990 levels and LDA's recently launched Green Homes and Green Organisations programmes will make a significant contribution to delivering this target. RDAs have also committed to influencing key public and private sector partners to support regional carbon targets and adopt further voluntary targets.

  15.  All of the RDAs are supporting Regional Climate Change Partnerships and a number of RDAs have lead on the process of developing Regional Climate Change Action Plans, whilst others have just started down this route. The Regional Climate Change Action Plans, combined with the new Single Regional Strategies (where applicable), should provide the clarity as to which organisations are contributing to which aspects of climate change. It will be important that both of these documents provide the same strategic direction and clarity to ensure they become the valuable tools they have the potential to be; identifying the roles local authorities, sub-regional bodies and regional bodies can play to contribute cohesively to addressing climate change.

  16.  RDAs believe that they should act as exemplar organisations for carbon reduction, demonstrating to private and public sector organisations the potential to change and as such have launched a number of commitments. We have committed to having environmental/carbon management systems in place by 2010 with the view to becoming carbon neutral. We are committed to setting carbon reduction targets in our Corporate Plans and publishing the carbon we expect to save as a result of implementing our policies and programmes in 2010 and 2020. We are also committed to ensuring that all capital build projects that RDAs invest in strive towards achieving the BREEAM "Excellent" standard (or equivalent) including a percentage of recyclate material and a percentage of energy supplied by renewable energy.

  17.  Through RDA stewardship of sub-national business support, we are supporting businesses to improve the environmental footprint and efficiency of their operations. We are currently piloting the delivery of resource efficiency advice to SMEs through the Business Link network, an outcome resulting from the jointly chaired Healey/Ellis[2] Taskforce on Business Resource Efficiency. RDAs are at the heart of the Business Support Simplification agenda and, as such, are encouraging the mainstreaming of business support programmes and the progression of businesses towards a low carbon economy. We are also hosting a number of staff from other organisations working with businesses (eg Envirowise, Carbon Trust, WRAP). In addition, RDAs are delivering business growth in environmental and energy sectors through our enterprise and innovation interventions and accelerating the commercialisation and diffusion of new technologies. A number of RDAs have invested, for example, in Enterprise Hubs or Centres of Excellence (eg the Joules Centre in the North West), set up Renewable Energy Agencies (eg Renewables East), established Regional Knowledge Transfer Networks (eg EnerrgiSE) or delivery vehicles (eg the London Climate Change Agency).

  18.  Regional Development Agencies are also investing in improving the evidence base associated with climate change. RDAs collectively fund SCPnet, a partnership between the RDAs, Regional Assemblies, Environment Agency and WWF-UK which collects data and evidence on sustainable consumption and reduction. RDAs are using SCPnet directly to identify trends in resource efficiency across 49 sectors and to work out regional eco-footprints. The RDAs have also developed and piloted a number of approaches to provide more consistent monitoring information. Emda has developed R-ISEW, the first regional composite indicator integrating economic, social and environmental costs/benefits, Yorkshire Forward has piloted a methodology for quantifying greenhouse gas emissions associated with RDA projects and NWDA has developed the Enworks Toolkit, a monitoring tool that can be used by business as an improvement tool and a way of justifying cost actions.

  19.  In terms of monitoring and accountability, there needs to be recognition of existing monitoring and reporting requirements which local and regional bodies are subject to and an understanding that these existing requirements are likely to deliver evidence of the action being taken to deliver against the climate change agenda.

3.  What, if anything, needs to be changed in the framework governing the actions of devolved administrations, regional government and local authorities? For example, does there need to be a more explicit reference to climate change in the local government performance framework and will the new performance indicators on climate change be enough to stimulate action?

  20.  The RDAs welcome the inclusion of climate change mitigation and adaptation indicators in the new Performance Framework for Local Authorities and Local Authority Partnerships. Performance indicators have the potential to provide a real impetus for action at a local level. It is important that they are backed up with clear advice from government for regional and local bodies on how emission savings should be calculated and reported.

4.  To what extent should there be disaggregated targets for different levels of government? How should independent targets, for example Scotland set its own emissions target for 2050 (80% reduction rather than UK target of 60%) and the Greater London Authority has committed itself to making a 60% cut by 2030, fit together with national carbon targets and budgets? How can Government monitoring and forecasting of emissions be improved so as to disaggregate emissions, and the impact of carbon reduction policies, in different regions and nations?

  21.  Ownership of emissions targets at the correct level is crucial if the Government is to establish effective governance and deliver real change. There needs to be a robust and consistent process for cascading targets from the national level through the regions to local authorities. There needs to be a clear line of sight between targets in the Regional Economic Strategies and the Local Area Agreements (LAAs) currently being taken forward by government with local government. Targets need to exist at regional and local level and, in some circumstances, at sub-regional or city-region level. As time moves on, regions have started to identify their own targets in the absence of disaggregated national targets for the regions. It is important that the Government's Climate Change programme targets and these regional targets knit together and, further, that innovative action by regional bodies be accounted for by the Government's Climate Change Programme. Regional activity is generating additional carbon savings and without this recognition, there will not be clarity on how the UK's overall carbon reduction targets are being met. Locally, there appears to be the start of local target setting through Defra's NI 186. This approach, which sees regions and local authorities setting their own targets, has the potential to cause significant confusion. The targets should be complementary and consistent. Local targets should cover those areas which local authorities and LSPs can control and should connect to sub-regional and regional targets. The new Integrated Regional Strategies should recognise these targets.

  22.  Central government needs to provide robust and back-calculated datasets, disaggregated to the regional/local level, to support this process. Whilst some regions have developed their own greenhouse gas inventories, government needs to provide data and funding by way of assistance in establishing inventories and baselines.

5.  How advanced and co-ordinated are local, regional and national programmes of adaptation to climate change? What support is there for adaptation? How vulnerable to climate change are local authorities, regional government and devolved administrations?

  23.  Whilst the role of national government in providing climate change adaptation needs to be strengthened, adaptation is best undertaken at local level by, for example, local authorities in partnership with other agencies including the Environment Agency and RDAs. The RDAs want to ensure that they and the regions can deliver more economic growth while reducing carbon emissions and enhancing the resilience of our regions' communities, infrastructure, utilities and private sector to the effects of climate change.

  24.  The Government role should be to facilitate action by promoting good practice and providing recommendations on approaches, the extent of adaptation that may be required across the UK, the costs of the adaptive measures and the future financial implications of not adapting. The Government also needs to provide more funding and fiscal incentives for investment in adaptation activity, especially climate-resilient infrastructure, and remove policy barriers that prevent adaptation uptake.

  25.  Regional activity on adaptation is underway but the RDAs recognise that there is still more to do to achieve effective co-ordination and delivery. The North East, for example, is currently undertaking a Climate Change Adaptation Strategy with buy-in from a range of regional partners, EEDA is supporting the development of a Climate Change Action Plan with a focus on adaptation and NWDA is funding an adaptation group. The Mayor of London is preparing a world first comprehensive climate change adaptation strategy for a city covering risks such as heatwave, drought and flooding, which the LDA will help to deliver. The London, East of England and South East Climate Change Partnerships have published a guide for developers on climate change adaptation, together with a set of case studies. They have also commissioned a study, due to report shortly, on retrofitting existing buildings for adaptation to climate change.

  26.  The proposed Local Area Agreement adaptation indicator will help to embed and drive adaptation activity by local authorities if selected.

6.  How should the Committee on Climate Change reflect the interests and needs of the different levels of government across the UK?

  27.  The RDAs stated in their response to the draft Climate Change Bill that the Committee should include regional representation to ensure that it provides advice to the Government which recognises the diversity of regions and the contribution that they can make to tackling climate change through fit-for-purpose policy. The Government's response was that the Committee should consist of experts, not representatives of stakeholder groups, that it is up to the Committee to decide how to do this and that it has the power to establish sub-committees. The RDAs believe that regional and local government are key to delivering emissions reductions and that the Committee needs to be aware of and support action at regional and local level. The Committee must therefore have a mechanism for engaging with regional and local stakeholders, including RDAs, to ensure that regional programmes are recognised and that there is co-ordination between the national level and the regions on carbon budgets, targets and accounting. The Climate Change Bill is silent on this matter.

7.  What are the barriers to greater local or regional action? Do the different levels of government have sufficient powers to take action? What changes in policy are needed to support action at a local level? What policies are working well?

  28.  The RDAs believe that their commitments to tackling climate change are significant, but that their impact can be immeasurably multiplied by a similar level of commitment from national, regional and sub-regional partners and by the Government taking action to remove barriers.

  29.  The Government needs to provide a clear and consistent policy and strategy framework for climate change with carbon reduction being mainstreamed nationally and regionally and appropriate enabling policies put in place. Such a framework needs to provide a stable long-term direction of travel in order to give confidence to business, but also include challenging short-term targets to stimulate the market-place and supply chains (eg on low energy appliances). The Government's climate change priorities need to be applied consistently across the breadth of mainstream policy development and Public Service Agreements and through the way national targets are manifested in regional and local policy frameworks (eg Local Area Agreements).

  30.  Policies and priorities should be based on common and robust evidence and intelligence. As previously stated, Government has a vital contribution to make to this evidence at regional and local level as the evidence base needs to be used to establish baselines and monitor progress towards targets.

  31.  All regions will only be able to realise their full potential to reduce carbon emissions if Government removes key barriers such as subsidies for unsustainable products/services and makes changes to our current energy infrastructure to support a low carbon economy. We are pleased to see that the new Planning Policy Statement on Climate Change is encouraging decentralised distributed renewable energy supplies as delivery of robust renewable energy projects needs to be accelerated through the planning system. There are particular concerns about the competitiveness and practicality of renewable and low carbon energy generation at community level. Current barriers include regulatory licence exemptions that limit the maximum size of electricity generation plant exempt from the burdens of a Supply Licence (projects therefore tend to minimise their size in order to remain exempt) and the cost of connection to the grid. The regulatory and market structure for electricity also needs to be adapted to reflect the different scale and economics of decentralised energy, in contrast to centrally generated and supplied electricity. In particular, planning and regulatory changes are needed to provide more incentive for renewables and Combined Heat and Power (CHP).

  32.  It is vital that the Government take rapid action to introduce a comprehensive system of carbon pricing. This is a major barrier to action at all levels. It would better enable low and zero carbon technologies to compete against traditional energy supply technologies and therefore encourage the commercial implementation of low and zero carbon energy projects.

8.  What impact will the new Planning Policy Statement on climate change have on emissions reductions and work on adaptation? How are the so called "Merton rules" affected? How might other planning guidance be changed to reduce emissions?

  33.  Planning is crucial to effectively tackle the issues being raised by climate change. The recent Local Government Association (LGA) report on councils and climate change highlights planning as one of the four areas in which local authorities can make a difference. The requirements in the supplement to PPS1 will be crucial for the medium term in delivering real change in the planning system and in shaping the ability of local and regional government to this challenge. RDAs are yet to fully digest this Statement but from initial assessment it appears that the Statement is broadly welcome with new recommendations for planning authorities.

  34.  We are hopeful that the Statement will streamline the planning process to reduce delays in decision-making, thereby making it easier to develop decentralised energy and more widespread microgeneration. The Merton Rule plays an important role in encouraging development of renewables and we would like to see it applied more consistently to delivering decentralised energy networks. Some regions and local authorities are already setting high standards, for example, the Mayor of London is proposing that developments achieve a reduction in carbon dioxide emissions of 20% from onsite renewable energy regeneration because developers are already routinely meeting the current 10% standard in London.

9.  Are local authorities meeting their duty to enforce building regulations in relation to environmental measures? Does the enforcement regime discourage non-compliance?

  35.  There is anecdotal evidence that there is a lack of compliance with building regulations on new-build domestic properties, despite local authorities efforts to discharge their enforcement duties. We believe that local authorities need to be given the resources to enable them to ensure that developers are complying with additional requirements such as for carbon reduction through the use of renewables, an issue which will accelerate in demand as efforts are made to meet the Government's ambition for zero carbon homes by 2016.

  36.  The twin-track approach to improving energy efficiency, using both the planning system and building regulations, can be confusing. RDAs would like to see the building regulations strengthened as quickly as possible with adequate training of enforcement officials so that building regulations become the main means of delivering uniformly high energy efficiency.

10.  What good practice is there to be shared? How is best practice shared and does central government support for sharing best practice work? What role should UK Climate Impacts Programme, IDeA, Salix Finance, the Carbon Trust and Energy Savings Trust play in providing support?

  37.  The RDAs have national mechanisms in place, facilitated by EEDA as the climate change lead, for sharing good practice amongst themselves through both national meetings where all RDAs come together to discuss issues relating to climate change and through an online RDA-only resource. In addition, the RDAs periodically publish national documents setting out current RDA activity. For example, we published a national pamphlet on tackling climate change earlier in the year, whilst in the past, we have published sets of case studies on regional sustainable development activity (Smart Productivity and Smart Growth) which we have shared widely with partners and interested parties. RDAs are also involved in sharing good practice at a local and sub-regional level with partners; activity which is better explained in the individual submissions you will receive from some RDAs.

  38.  Sharing of good practice with other agencies does need further support in the short-term to help ensure that successful initiatives are effectively rolled out, as the skills and knowledge are not yet widespread. There is a critical role of national organisations in disseminating this best practice and ensuring that there is a central pool of expertise for the regions and local authorities to draw upon. Groups such as the Regional Energy Group, whose members include RDAs, are useful for sharing best practice and information on regional initiatives. It is important that sufficient Government funding be provided to Government-funded delivery agents and programmes such as the Energy Saving Trust, Carbon Saving Trust and Business Resource Efficiency and Waste programme to enable regional and local bodies to continue to benefit from their expertise, such as through the Carbon Trust's Local Authority Energy Financing Scheme.

  39.  The Energy Savings Trust plays an important role in disseminating good practice and its website with a list of publications is viewed as a valuable resource. Primarily, the Energy Savings Trust has provided support in the domestic energy sector. This is critical given that 28% of CO2 emissions come from this sector. The Energy Savings Trust is working with RDAs in some regions to deliver specific activity. The North East hosted a trial Sustainable Energy Network which was well received and the rollout of Sustainable Energy Networks across the country will ensure holistic advice is provided to householders. The announcement by Gordon Brown that a Green Homes Service will be rolled out supports the notion that taking a holistic approach to energy reduction is the most effective way forward.

  40.  The Carbon Trust is working closely with RDAs in some regions to help businesses improve their energy efficiency. The Carbon Trust has excellent examples of how reducing energy demand is extremely cost effective and some RDAs have found that useful.

  41.  The UK Climate Impacts Programme provides an invaluable source of expertise and support, assisting both with the development of policy for climate change adaptation and advice on implementation. It is important that the UK Climate Impacts Programme continues to provide robust scenarios, including at regional and local level, and to assist public bodies' adaptation improvement now required in the Climate Change Bill. As the planning and decision-making processes of both the public and private sector rely on climate change projections, it is essential that UKCIP is funded to continue to provide up-to-date scientific expertise in this rapidly developing area.

3 January 2008






2   Richard Ellis is Chair of EEDA, the Regional Development Agency in the East of England. Back


 
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