Memorandum submitted by the Local Government
Association
1. While climate change affects the whole
world it is only by taking local action that we can best help
defeat it. Local government has a pivotal role in leading this
action in both reducing carbon emissions and preparing the local
area for the potentially devastating effects of a changing climate.
2. Many councils are leading the way in responding
to climate change. For example, Merton Council on the provision
of renewable energy, Kirklees on domestic energy efficiency, Hampshire
County Council on adaptation and Nottingham City Council on sustainable
transport.
3. The independent Climate Change Commission
delivered its report last month, with recommendations on how councils
can best tackle climate change. The LGA will be making climate
change a major priority in 2008 and we will continue to help councils
lead the way in helping the UK meet its carbon reduction targets.
4. In the last year there have been significant
changes to the way local authorities are encouraged to tackle
climate change and how their performance will be judged. It is
too early to say what impact these have had on work on the ground.
5. Councils will need the support of national
government if they are going to effectively tackle climate change.
The government needs to recognise the role councils play in engaging
their communities to help stop climate change and remove key barriers
to local action. Developing the skills and capacity of local government
to improve their response to climate change is key.
BACKGROUND
Local government is uniquely placed to tackle
climate change—both mitigation (cutting emissions) and adaptation
(preparing for the worst). Councils help reduce carbon emissions
and manage the risks of climate change in five ways:
— By leading action in their communities
through example. Councils can take action in their buildings,
transport fleets and as a housing provider to reduce energy usage,
use energy more efficiently and use renewable energy sources.
Kirklees council are investing in the energy efficiency of the
area's entire housing stock (see Annex A).
— Through service delivery. Councils
in England have a procurement budget of around £50 billion
per annum. There are some obvious opportunities in the procurement
of buildings, transport, goods and services to reduce carbon emissions.
For example, to buy or lease energy efficient vehicles and other
energy efficient products. Westminster City Council has installed
over 50 electric vehicle charging points into council car parks.
West Sussex County Council have written carbon management into
contract specifications (see Annex A).
— By regulating for a low carbon economy—councils
can use their building control and planning powers to reduce carbon
emissions. Merton Council led the way a few years ago requiring
all non-residential developments to secure 10% of their energy
from renewable sources and now 166 other councils are looking
at implementing the "Merton rule". Uttlesford Council
requires homeowners to take cost effective energy efficiency measures
as a condition of planning consent for home extensions (see Annex
A).
— By making Local Area Agreements with
other local bodies to work together to tackle climate change.
— By helping communities assess and
guard against the major risks of a changing climate and maintaining
services during emergencies. Hampshire County Council has held
a commission of inquiry into the impact of climate change for
the county (see Annex A).
There are a number of councils that have led
the way in acting on climate change and have developed innovative
approaches that have been adopted by other councils. Over 280
councils have now signed the Nottingham Declaration on climate
change with the council leader and chief executive giving top
level commitment to put in place strategies to tackle both mitigation
and adaptation. There is a growing recognition within local government
that climate change needs a systematic, consistent and urgent
response from all councils.
LGA RESPONSE TO
THE COMMITTEE'S
QUESTIONS
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?
1. There are a number of ways in which the
LGA's Climate Change Commission has suggested that central government
could support local action more effectively. These include:
— First, by ensuring that all levels
of government, all departments and the public sector consider
climate change in all policy development and action, for example,
through carbon impact tests.
— Second, by ensuring that opportunities
afforded by the legislative programme are taken to strengthen
the statutory underpinning for local government action.
— Third, by reviewing the quality and
level of support available to local councils to tackle climate
change and supporting local government to develop a suite of interventions,
such as peer reviews and leadership training, to help drive improvement
in local government and the wider public sector.
— Fourth, working with the regional
development agencies, and skills bodies, to identify the skills
gaps that are constraining local action and to take action to
close them. There is, for example, a shortage of skilled energy
managers in the public sector.
— Fifth, working with the LGA, CIPFA,
Audit Commission and National Audit Office to introduce a whole-life
cycle costing approach into procurement practices that takes account
of the costs of carbon and overcomes the tension with short-term
financial efficiency.
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?
1. It is not yet clear how the targets in
the Climate Change Bill will be delivered and what contribution
could be made by different sectors. There needs to be flexibility
in what can be delivered at the local level.
2. All councils will be required to report
on the reduction of carbon emissions relating to both their estate
and the local area as part of the CAA. The same level of accountability
and transparency should apply across the public sector.
3. In many areas councils are co-ordinating
their response to climate change. The Association of North East
Councils has set up a council member led group on climate change
to work collectively and collaboratively to tackle climate change.
4. Over 280 councils have signed the Nottingham
Declaration which has been highly effective at mobilising council's
commitment to tackling climate change. The LGA is calling on all
councils to sign the declaration or make an equivalent commitment.
The LGA, as part of the Nottingham Declaration Partnership, is
also proposing an accreditation scheme where councils would provide
evidence to demonstrate their action on climate change. The partnership
is talking to the Audit Commission about how such a scheme could
complement the Comprehensive Area Assessment.
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?
1. In the last year there have been significant
changes to the way local authorities are encouraged to tackle
climate change and how their performance is to be judged. These
include new indicators for the Comprehensive Area Assessment (CAA)
on climate change; the Carbon Reduction Commitment, a mandatory
cap and trade emissions trading scheme that will apply to larger
authorities; and the Energy Measures Report which councils must
"have regard to" in exercising their functions.
2. The Audit Commission has said that it
will place much more emphasis on sustainability as long-term value
for money requires the sustainable use of resources. They are
also consulting on how a council deals with climate change will
be considered in its "Use of Resources Assessment".
3. It is too early to judge the impact of
the new performance indicators and the approach to the CAA taken
by the Audit Commission. This change will require it to develop
its capacity to make judgements on issues of sustainability. Other
agencies, such as government offices and the Environment Agency
will also need to improve their capacity to engage with local
strategic partnerships on climate change.
To what extent should there be disaggregated targets
for different levels of government? How should independent targets,
for example Scotland will 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?
1. Sir Simon Milton, chair of the Local
Government Association, has called on every council to have climate
change targets at the core of their local area agreements. He
emphasised their choice about how they tackle climate change,
but they should make it central to what they do.
2. Targets should be set at the local level
by bringing together the public, private and voluntary sectors
in Local Strategic Partnerships. They need to be evidence based
and tailored to local conditions—we could not support a
crude disaggregation of national targets. The LGA does however
support the national targets which serve as a guiding ambition
for each local area and have already informed local target setting
in many areas.
3. We support the need to develop more sophisticated
national data collection where it does not impose new burdens
on local government. There are however a number of technical issues
with the current area based emissions data, in particular, the
way in which the data takes account of transport related emissions.
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?
1. It is clear that policy and action on
adaptation is relatively immature compared to mitigation. There
are no national measures or benchmarks of a well adapted organisation
or area. Neither is there a national policy framework on adaptation.
2. It is important therefore that central
government place a much greater emphasis on adaptation, and provide
much more support to councils in identifying risk and mapping
vulnerabilities. The support available to councils to develop
approaches to adaptation is small in contrast to the support available
for mitigation.
How should the Committee on Climate Change reflect
the interests and needs of the different levels of government
across the UK?
1. Given the importance of local action
to tackling both mitigation and adaptation, it is essential that
the Committee on Climate Change has a deep understanding and knowledge
of the local government role. It is essential that it is able
to access local government expertise.
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?
1. The most significant barrier to local
action is skills and capacity. This varies in nature—from
a small district council lacking the officer capacity to develop
action on climate change to the need to significantly scale up
the sustainable building and energy efficiency skills in the design,
planning and construction industries—both for new build
and to address the energy efficiency of the existing housing stock.
It is an issue that applies to other sectors—the economy
needs to skill up for a low carbon future.
2. The LGA would therefore like to see a
national strategy to identify the skills gaps and specific sectors
and geographical areas. Some work has been done by the DTI (now
BERR) with the regional agencies. But it needs to be expanded
and pick up key issues such as developing local energy supply.
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?
1. We are pleased that the new Planning
and Policy statement embeds at the heart of the planning system
a focus on the need to minimise greenhouse gas emissions in new
developments and to ensure that development decisions reflect
risk assessments of the impact of climate change. Critically both
are to be assessed together rather than seen as separate issues
for planning consideration.
2. Importantly the PPS recognises the role
of planning in minimising emissions through encouraging low carbon
and renewable energy supplies. Locally produced energy and decentralised
energy systems are given a specific focus through various provisions
in the PPS. The PPS reiterates the central role that councils
have in determining the sustainability of their areas and provides
for the flexibility for locally determined approaches where appropriate
and justified.
3. However there needs to be clear guidance
from the government that the provision for "testing local
requirements" in paragraph 33 of the PPS does not allow developers
to unnecessarily challenge the decisions of councils.
4. The impact will also be dependent on
the capacity within councils to undertake complex assessments
across a range of technical areas. We will work with CLG and stakeholders
on improving councils capacity to respond to the PPS. It is imperative
that all players, including developers and the construction industry,
are pro-active in responding positively to the PPS.
Are local authorities meeting their duty to enforce
building regulations in relation to environmental measures? Does
the enforcement regime discourage non-compliance?
1. The move to place energy efficiency at
the heart of the building regulations was widely welcomed. However,
whilst the new requirements are relatively immature, there have
been problems with the practical implementation.
2. There is concern that enforcement of
the building control regime, in particular the energy efficiency
requirements in Part L of the Building Regulations, is not functioning
effectively. This is acknowledged by DCLG who are looking at the
future of building control. The LGA is particularly concerned
that the current regulatory regime—with a dual and competitive
public and private sector market for building control—is
undermining compliance with building standards.
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?
1. There are many examples of local best
practice, some are included in annex A. Within local government,
the IDEA plays the leading role in both capturing and spreading
best practice. The LGA has worked with the Nottingham Declaration
Partnership, the Energy Saving Trust, IDEA and Carbon Trust to
provide practical support and advice to councils.
2. Many local authorities are working very
successfully with the agencies the committee lists. But the support
could be more effectively targeted on councils that would like
to raise their performance on climate change, and that for "entry"
level councils there was a need for a simple one-stop shop offer.
There is also a concern that as councils place more emphasis on
climate change that the available support would be over stretched.
8 January 2008
Annex A
BEST PRACTICE EXAMPLES
KIRKLEES COUNCIL
Kirklees Council's new Warm Zone Plus was set
up in 2007. It offers all homes the opportunity to have loft and
cavity wall insulation installed free on a systematic, house by
house basis. Contact is by a personal visit offering energy efficiency
advice, low cost insulation and grant aided measures.
Over the three years of the programme, the council
expects more than 40,000 homes to install energy efficiency measures
under the first scheme in the country to offer all households
in one area free insultation. Warm Zone Plus which will cost £21
million over three years is being funded through capital borrowing
(using prudential borrowing powers) with the interest paid from
revenue. This is being supplemented by funds from Warm Front and
CERT.
Warm Front Plus builds on many years of targeted
energy efficiency work. Kirklees has around 26% of its population
affected by fuel poverty (ie people who have to spend more than
10% of their gross income on fuel to keep their home adequately
warm). The council has therefore run a variety of schemes over
a number of years including Keep Warm and Warm Homes Kirklees
to help raise home energy efficiency levels.
In April 2008 Kirklees Council will be launching
a £3 million scheme to promote householder renewables. The
principal barriers to the uptake of renewables by homeowners is
cost, confidence in the technology, its capabilities and how it
is installed. The scheme aims to address these barriers.
Private householders will be able to install
up to £10,000 of renewable technology on their homes and
pay for it when their home is sold via a second charge on the
property. The scheme is funded through capital borrowing. Kirklees
Council will administer the scheme providing tendered prices from
approved installers. Once the property is sold and the original
loan recovered it will be recycled into a revolving loan fund.
It is expected that this relatively simple scheme will attract
additional finance from energy suppliers through the Carbon Emissions
Reduction Target scheme.
The RE-Charge scheme is one of the schemes which
will demonstrate action to reduce household carbon emissions as
part of the Council's action plan to address carbon emissions
targets in the new Local Government Performance Framework along
with the Warm Zone Plus scheme.
UTTLESFORD DISTRICT
COUNCIL
Uttlesford District Council's Supplementary
Planning Document on home extensions is an example of how the
planning system can be used to reduce carbon emissions from existing
homes.
The SPD requires cost effective energy efficiency
measures to be carried out throughout the existing building as
a condition of planning consent for a home extension.
The installation of energy efficiency measures
is designed to: mitigate the additional energy requirements that
result from the house being extended; help reduce the household's
energy consumption; and reduce energy bills and improve comfort
levels. The scheme was designed by the councils' building control
and planning functions.
WEST SUSSEX
COUNTY COUNCIL
Tendering for new service partners is an ideal
opportunity to engage your supply chain in achieving your carbon
and wider sustainability goals. A recent tender for the provision
of managed desktop services by West Sussex County Council required
all tendering parties to, "demonstrate their carbon management
plans in respect of services being provided to the Council".
The Council shared their goals and the Council's Sustainability
Action Plan, inviting potential partners both to innovate and
to demonstrate their commitment to the low carbon agenda.
HAMPSHIRE COUNTY
COUNCIL
Hampshire County Council signed the Nottingham
Declaration in 2001 and was a pilot in Councils for Climate Protection
and the Carbon Management Programme. It was a founder member of
the South East Climate Change Partnership, leads the ESPACE European
project, part of the Advisory Group to the EU on adaptation to
climate change, and a founder signatory to the Aalborg Commitments
in 2004. In 2006 the Council adopted the vision "within a
decade Hampshire will prosper without risking our environment".
Recognising that climate change is probably
the biggest threat to achieving that vision, a Climate Change
Commission of Inquiry (COI) was established with commissioners
drawn from business, academia, media and councillors from all
the political parties on the County Council.
Four themed hearings were held between May and
September 2007, where evidence was presented by external experts,
and key findings were agreed by commissioners. A meeting of the
Council considered a report and recommendations at the end of
November.
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