Memorandum submitted by the Office of
the Mayor of London
SUMMARY
This submission provides a summary of the issues
as perceived by the GLA. The GLA would be pleased to expand on
any of the points made by providing oral evidence to the Committee.
This summary highlights the following issues:
1. Government could and should take a more consistent
approach to adaptation, both within its policies and in leading
by example.
2. Government could and should do more to ensure
that public expenditure further enables adaptation.
3. Government could and should expand its focus
on adaptation to enable and deliver adaptation in existing buildings.
4. The regulation of the water industry needs
to evolve to deliver more sustainable approaches to long-term
issues, such as climate change.
5. The need for greater capacity and skills,
particularly at the local level effectively to deliver adaptation.
CONTEXT
— The Mayor of London welcomes the opportunity
to feed into the Environment Audit Committee's inquiry into climate
change adaptation. Tackling climate change (adaptation and mitigation)
is one of the Mayor's top priorities.
— The Mayor is developing a Climate Change
Adaptation Strategy for London. The aim of the Strategy is to
help prepare London and Londoners for the impact of climate change
and extreme weather. The Strategy identifies the risks and opportunities
presented by extreme weather today, and then uses the UKCP09 climate
projections to project how these risks and opportunities will
change in the future, or bring new risks and opportunities to
London. The strategy also identifies the key actions necessary
to manage these risks, or to realise the opportunities, and provides
a framework for the Mayor to work with partners to achieve.
— The draft London Climate Change Adaptation
Strategy identifies that London is already at risk of floods,
droughts and heat waves, and that climate change will increase
the frequency and intensity of these impacts, so increasing the
risk to London, Londoners and the national economy. The next draft
of the London Climate Change Adaptation Strategy will be published
for public consultation by the end of the year.
— The Greater London Authority Act 2007
commits the Mayor and London Assembly to a "climate change
duty", where the Mayor and London Assembly must mainstream
climate change adaptation across their plans and strategies, and
the Mayor must publish and regularly review a climate change adaptation
strategy for London.
— In addition, the Greater London Authority
is proposed for reporting under the Climate Change Act 2008 as
one of the "priority reporting authorities". The Mayor
will consult the London Development Agency and Transport for London
in developing the report to Government.
1.ENSURING A
CONSISTENT APPROACH
ACROSS GOVERNMENT
1.1 The Mayor welcomes the work being done
by the DEFRA Adaptation to Climate Change Programme in undertaking
the national Climate Change Risk Assessment and in supporting
Government Departments identifying the climate risks and opportunities
facing their assets and operations. However, it is also essential
that all Government Departments and non-departmental public bodies
drive a coherent and seamless adaptation message through their
policies, projects and guidance. The Mayor is concerned that Government
could and should do more to ensure this consistent approach to
adaptation. The following highlights gaps and inconsistencies:
1.2 Example: Communities and Local
Government launched the "Green Changing Rooms" initiative
to reduce carbon emissions from existing housing stock in Feb
2009. So far, there has been no inclusion of water efficiency,
or any other basic sustainability improvement, which would add
value to the programme and deliver adaptation measures in parallel
with mitigation measures.
1.3 Example: the Energy Performance
Certificate for buildings does not take account of water use,
and therefore misses the opportunity to reinforce the link between
water and energy efficiency. A good example to follow would be
the National Australian Built Environment Rating System (NABERS),
which measures and displays energy use, water use and waste generation.
www.nabers.com.au/
1.4 Example: Currently Building Regulations
and even the Code for Sustainable Homes (the Code) do not require
developers to consider overheating risk, and even best practice
recommendations suggest that buildings are designed for the summer
of 1983—only a modestly warm summer by this decade's example
and comparatively cool by future projections. (The GLA and CIBSE
are jointly producing a series of future hourly summer temperature
projections that can be used by architects and engineers in building
simulation software to manage the risk of overheating risk in
the future.)
1.5 Example: The Code sets water
use targets for new residential development. The water use is
calculated using a "Water Calculation Tool" (the Tool)
which makes assumptions about how many times and how long inhabitants
use various water-consuming devices. Developers have to use the
Tool in order to demonstrate compliance with the Code. The application
of the Tool, however, can lead to developers installing inappropriate
technologies or devices that do not deliver real water efficiency,
hence using the Code in urban development may be having the reverse
effect. The GLA recommends that the a simple fittings-based approach
that promotes water efficiency based on approved flow rates and
volumes, eg AECB Water Standards (see link) should be considered
in place of the Water Calculation Tool. This simple method could
also be transferable to future Codes on Sustainable Refurbishment
or Sustainable Buildings. www.aecb.net/PDFs/waterstandards/1503_AECB_Water_Vol_1_V3.pdf)
1.6 Example: Overheating risk in
social housing is driving social housing landlords to fit or provide
air-conditioners rather than invest in "passive" measures
(shutters, awnings, blinds, etc) to reduce the risk of overheating.
2. ENSURE THAT
PUBLIC EXPENDITURE
FURTHER ENABLES
ADAPTATION
2.1 The Mayor believes that Government should
ensure that public expenditure should encourage and enable adaptation
: too much public funding is still spent on programmes and projects
that do not consider the future climate. Adaptation in public
buildings should by now be common practice rather than best practice.
2.2 Example: The DoH guidance on
the design of new hospitals does not require hospitals to be designed
to stay cool in hot weather, yet we have experienced three heat
waves this decade.
2.3 Example: OfWat instructed water
companies that any investment in adaptation measures proposed
in the current round of business plans, based on UKCIP02 climate
projections would not be supported. This means that very little
adaptation of the water utility infrastructure will occur in this
round of business planning, and expensive retro-fits may be required
at a later date. Given that the UKCP09 projections are not significantly
different to the UKCIP02 projections, this would seem to be counter-productive,
especially as the water industry is one of the sectors leading
on adaptation.
3. ENABLE AND
DELIVER ADAPTATION
IN EXISTING
BUILDINGS
3.1 The Mayor believes that Government needs
to take more serious consideration on how to adapt the existing
building stock. Existing development represents 99% of all development
and retro-fitting existing buildings needs to be a Government
priority. An integrated retro-fit approach that considers for
energy and water efficiency, plus improving resilience, is urgently
required.
3.2 Government should remove the economic
barriers currently restricting sustainable and innovative technologies
that improve efficiency and resilience. This includes encouraging
retro-fitting of residential developments with the preferred water
and energy efficient devices, through reducing the VAT on measures
that increase resilience and water efficiency.
3.3 Government could help lever in greater
public and private sector funding into adaptation and sustainability
delivery by creating a fund to enable regions to undertake large-scale
retro-fitting work. This could be integrated into CERT and Government
refurbishment targets, such as the Green Changing Rooms programme.
3.4 The Government should lead by example
and accelerate the retro-fitting of all government and public
buildings, and ensure that adaptation measures are included.
3.5 Example: the Government's "Decent
Homes Standard" for social housing renewal, needs to be updated
to include water efficiency, overheating resilience and, where
required, flood risk management options. The GLA has published
research, "Towards a successor standard to Decent Homes"
that looks at how environmental standards of existing social housing
can be improved when being refurbished.
www.london.gov.uk/mayor/publications/2009/docs/decent-homes-successor-standard.pdf
4. REGULATION
OF THE
WATER INDUSTRY
4.1 The regulatory framework for the water
industry needs to evolve to give greater consideration of the
longer term, and drive the delivery of more sustainable solutions.
In particular, water companies need to be required to, and benefit
from, reducing demand for water.
4.2 Water companies are required to justify
the interventions proposed in their business plans by demonstrating
cost effectiveness to OfWat. The calculation of this cost- effectiveness
seems to encourage shorter-term solutions and the development
of large fixed assets (such as reservoirs) rather than more "diffuse"
solutions, such as metering and enabling greater domestic water
efficiency.
4.3 Example: Water companies are
only permitted to reduce leakage from their mains pipes to a point
defined as the "economical level of leakage". This is
the point where it is considered "more economical" to
find, or create new water resources rather than invest in further
leakage reduction. The cost effectiveness calculation does not
adequately take account of the message this sends to the public
regarding water efficiency—in effect it is asking the public
to be water efficient where the water companies are not, or the
damage that the abstraction of this water from the environment
causes in the first place.
4.4 Example: Water companies have
set themselves a voluntary water efficiency target of saving 1
litre per household per day, rather than face a mandatory imposed
target. In a region that is "seriously water stressed"
(meaning that the amount of water we withdraw from the environment
causes actual damage to the environment), this voluntary target
is too low to enable the step change required. We need to work
towards a goal where demand for water reduces at a rate greater
than climate change reduces supply.
5. INCREASING
CAPACITY TO
ADAPT
5.1 Despite the intense resource pressures
on all of the public sector at the moment, there is immense value
in even a small amount of capacity within public institutions
to raise the profile of adaptation and to make it relevant to
each institution. Without having an internal capacity to challenge
an organisation, and to present adaptation to its own decision
makers in meaningful terms, it is likely that adaptation will
be brushed off as being unimportant or trivial or, even worse,
as having been "done".
5.2 The majority of adaptation actions are
best delivered at the local level. However, many Local Authorities
do not have the capacity to assess climate risks and undertake
adaptation work. One option would be to create and enable networks
between Local Authorities where expertise can be called on across
Borough boundaries.
5.3 Example: There is a need to raise
the public's awareness of the climate risks they face and to encourage
the public to "own" these risks and understand that
in case of an emergency situation, the state response will be
to target the most critical assets and the most vulnerable in
the community. In London, fewer than 1 in 5 households at flood
risk has signed up to the Environment Agency's free Floodline
Warnings Direct service, which can provide essential time for
people to take action to reduce the impact of a flood on their
homes. Government at all levels should do more to encourage the
public at risk to register for this service—perhaps this
should be included as a requirement for achieving higher levels
on the local government performance indicator on adaptation (NI188).
5.4 Example: The National Heat wave
Plan relies on GPs identifying "vulnerable" people within
their practices and ensuring that these people are informed of
what they can do during a heat wave to reduce the risk of overheating.
However, many GPs have not compiled a list of vulnerable people
and vulnerability to climate impacts is not constant (for example
it may depend upon how that person is feeling on that day, or
whether their carer is present on that day). Furthermore, many
vulnerable people do not perceive themselves as "vulnerable",
and hence are unlikely to pay any attention to the information,
should they receive it. The solution to this issue (which also
helps to manage flood risk) is to enable a community spirit and
build community capacity, so that trusted residents look out for
vulnerable people and assist them when necessary.
28 October 2009
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