Ealing Draft Climate Strategy

 

Comments by Ealing Friends of the Earth

 

1.  On its own, the Executive Summary does not have enough to give the reader a real feel for the issues or the strategy. For example, it would be useful for the ‘Executive Summary’ to include:

• A breakdown of emissions by sector (some figures are scattered through the strategy)
• Mention of the main target

The executive summary is an important section because it may be the only part read by busy people; the rest of the document is long and detailed so will not be read by LSP members, groups or individuals.

 

2.  There is a shortage of numbers in the strategy.  It would be useful to have all the data from ‘King et al 2007’ and any additional breakdowns that are available.  We need a breakdown of emissions by source, firstly by sectors such as transport, housing, industry, commerce and then by sub-sectors, eg cars, buses, lorries, trains and aircraft.  Without such data, it is not possible to target sectors and prioritise actions.

 

3.  It is not clear how progress and success in achieving targets will be monitored.

 

4. We are not convinced by the target to “reduce per capita carbon dioxide emissions in the borough by 10 per cent by 2010/11 from 2005 baseline.”  There is no obvious linkage, relationship or consistency between the national and LBE targets, eg a reduction in UK emissions by 60% by 2050.  (We understand it is an LAA target adopted by LBE/LSP, but this does not resolve the issue).  Also, a target for 2011 seems very short term.  Assuming the actions do not commence until Sep 08 (after summer holidays and Cabinet approval) there is only 2½ years left.  Climate is long-term issue that demands long-term strategies and actions – that is why targets are set for dates as far out as 2050.          

 

5.  Carbon dioxide (CO2) is not the only greenhouse gas.  We would expect some consideration of the full range of greenhouse gases (if only to demonstrate that they do not need or merit action).

 

6.  In addition to a breakdown by source, we also need some assessment of the extent to which emissions can be realistically reduced from that particular source.  For example, the extent to which council policies or LSP member can influence emissions.  We recognise that this can only be done fully once it has been decided to prioritise the relevant sector or activity.

 

7.  These issues of quantification are not a matter of being purist or pernickety.  They are at the very heart of a strategy that seeks to reduce emissions by a specified amount.  Without proper data and quantified plans, there is a very real danger that many or all the suggested actions could be carried out without yielding significant reductions in emissions. 

 

8.  Following from 7, we have concerns about the list of actions. It is quite long and some of actions are quite minor.  Issues such as planning policies (LDF etc) and transport policies, which potentially have very large impacts, are virtually absent.  The list should be regarded more as a list of possible actions, to be refined and pruned, rather than a part of the plan at this stage.

 

9.  There is no mention of economic or financial costs/benefits.  A telling figure for the economic cost of carbon can be readily computed -  £43m in 2005.  (1717 ktonnes CO2 from LBE, at DEFRA’s ‘shadow cost’ of £25.0 per tonne - http://www.defra.gov.uk/environment/climatechange/research/carboncost/step1.htm              

                                                                                                                 Nic Ferriday, Aug 08