Is the Chapter “Climate change mitigation and adaption” appropriately titled?

1.1 “Mitigation” is a word which unfortunately has become a standard, or jargon, for reducing (or limiting increases) of emissions and thereby reducing or limiting climate change. That is, aiming to avoid the problem in the first place. It is unfortunate because common use of the word “mitigation” can imply one is overcoming a problem that is already present, not preventing the problem in the first place. In climate parlance, overcoming the existing problem is called “adaption”.

1.2 If the title is intended to be understood by people who are not familiar with climate change language, we suggest it is changed to “limiting climate change and adapting to it”.

2. Policy 5.1, Question a

“Is the 60% target for CO₂ reduction realistic, robust and sufficiently refined for monitoring purposes? Is there a sufficient evidence base to indicate that the figure will be attainable in a London context?”

2.1 Climate change is, quite simply, the most important issue on earth. If the issue of climate change is not addressed, all of the social, economic and many of the environmental objectives of the LP will ultimately fail. London, if it seeks to be a truly world class city, should be in the vanguard of action on climate change.

2.2 We support the ambitious but achievable target in Policy 5.1 “The Mayor seeks to achieve an overall reduction in London’s carbon dioxide emissions of 60 per cent (below 1990 levels) by 2025. It is expected that regional agencies, London boroughs and other organisations will contribute to meeting this strategic reduction target, and the GLA will monitor progress towards its achievement annually.”

2.3 The Mayor’s draft Climate Change Mitigation and Energy Strategy (CCM&ES) proposes the following targets:

To reduce London’s CO2 emissions by:

• 22 per cent of 1990 levels by 2015

• 38 per cent of 1990 levels by 2020

• 60 per cent of 1990 levels by 2025

2.4 The 2025 targets in CCM&ES and LP are consistent. We assume that the interim targets in CCM&ES for 2105 and 2020 apply to the LP also; in which case they should be written into the LP.

2.5 It is very important that LP policies are consistent with national policies. In the Climate Act the UK government has set a target of reducing CO2 emissions by 2050 by 80% from 1990 levels. The Committee on Climate Change has recommended an interim target of 34% for the 5-year period 2018 to 2022. If one takes the mid-point of this period as the average, it means a 34% reduction in 2020. There is no target for 2025.

2.6 Applying a ‘top down’ approach, a 34% UK reduction implies a 34% average reduction for regions, including London. More detailed planning may indicate that different targets for the regions are appropriate, but no work has been done on this. Until such a plan is devised, it seems reasonable to take 34% for each region as a first approximation.

2.7 The 38% CCM&ES and thus LP target for 2020 is slightly more ambitious than the 34% national target would imply. However, we consider it appropriate that London should set itself a more stringent target.

2.8 A more stringent target for London is appropriate because it is because it is easier for London to achieve reductions. London is a more dynamic area than most of the country – there is a faster turnover of people and buildings. This means that behavioural change and planning decisions can impact on emissions more rapidly than elsewhere. London also has more public transport, cycling and walking options which can impact on emissions.

2.9 There is another reason why a more stringent target is appropriate. The national targets are for all UK emissions, which include the UK’s apportionment of international aviation. Present government policy means that aviation emissions are forecast to greatly increase. This means that the other sectors of the economy are required to achieve larger cuts than 80% in 2050 or 34% in 2020 to achieve the overall 80% cut. Because regional emissions inventories exclude aviation, they need to achieve larger cuts than the overall national cut. (The London inventory does include emissions from airports, as opposed to aircraft and, we understand, emissions from aircraft below 1000 feet. But these emissions are relatively small compared with the aircraft emissions over 1000 feet.)

2.10 The final, and perhaps most important, reason why the target needs to be more stringent is that moving from 34% in 2020 to 60% in 2025 will be virtually impossible. A stringent target is being set for a good few years ahead, 4 mayoral terms ahead, but a relatively easy target is set for the shorter term. It means much more drastic action will be needed by later mayors and by Londoners. We are concerned there is an element of ‘kicking the policy into the long grass’ here.

2.11 Taking account of these points, we consider the 2020 target should be a reduction of 40%. This is in line with national Friends of the Earth policy.

2.12 Based on the above we consider the target is “realistic” and “robust” in the sense that it appears to be broadly consistent with the UK’s climate act. That in turn is broadly consistent with the generally accepted global targets for reducing emissions.

2.13 It is clearly possible, in physical terms, to achieve such reductions. But whether the targets are “realistic” and “robust” in the sense of being deliverable depends to a large extent on the political will, determination and quality of leadership in London, especially from the Mayor. But it also depends on those parties who are influential in determining mayoral policies choosing to exert their influence to ensure the targets are met. The Panel is one such party.

2.14 While we support the 2025 target, we do not see evidence of a plan or of a will or determination to achieve the target.

2.15 While we do not disagree with the policies 5.15 to 5.46, there in no indication to what extent these policies will help achieve the 2025 or earlier targets.

2.16 Ground-based transport accounts for 22% of London’s carbon emissions and should be explicitly included in the 60% reduction target. While emissions are addressed in detail in the Transport Strategy, transport ought to, at the very least, be mentioned in the Plan as part of the climate change chapter.

2.17 For more detail on the failure of the Mayor’s draft Transport Strategy to play its part and how it could be improved, see the ‘climate change’ section of West London Friends of Earth’s response to the strategy draft, lodged as an EiP document.

2.18 The question asks “is there a sufficient evidence base to indicate that the figure will be attainable in a London context?” From the above, it is clear that transport is not expected to make anything like its ‘fair’ contribution to reducing emissions by 60%.

2.19 Evidence from the other sectors appears to be absent. We see no estimates of to what extent the various sector and the various policies in the plan will contribute towards the target.

2.20 The failures described in 2.13 to 2.17 above add up to a fundamental flaw in the plan. The target is manifestly not “sufficiently refined for monitoring purposes”. A plan whose overall targets are not broken down into components and which bear no obvious relationship to the policies has limited value and can only engender cynicism among stakeholders about the entire process.

2.21 Without proper analysis and tracking, the 60% target is likely to fail. In order to reconcile the targets with the policies, we recommend that a small unit is set up comprising GLA officers but also with outside independent members. This would also monitor annually the progress (part of Policy 5.1).

2.22 The unit would be somewhat analogous to the Climate Change Committee, which was set up to analyse in detail how the top-down targets might be achieved in relation to government policies. The London Sustainable Development Commission could supply independent members and be otherwise involved. Indeed the whole task could be outsourced to it, but it is essential it is given the resources to do the job properly.

2.23 Policy 5.1 also says "Within LDFs boroughs should develop detailed policies and proposals that are consistent with the achievement of the Mayor’s strategic carbon dioxide emissions reduction target for London."

2.24 We endorse this wholeheartedly. But vigilance and processes are needed to make it happen. In the borough of Ealing, to take one example, there are no targets that are consistent with the LP targets. Indeed there is very little emphasis on climate change at all.

2.25 In the same way that, as a first approximation, each region should aim to meet the national targets, it is reasonable for each borough to have the same targets as the LP. This should be written into every LDF.

3. Policy 5.1, Question b

“Has the climate change agenda sufficiently informed other policies in the Plan? For example does the Plan provide adequate support for “Green Jobs”, consideration of the impact on disadvantaged communities or indicate how climate change should be addressed in outer London?”

3.1 As explained in our response to question a, there is no clear linkage between the policies in the plan and the impact on emissions. To this extent, the climate change agenda has not “sufficiently informed other policies in the Plan.”

3.2 We are not convinced that explicit “support for ‘green jobs’ ” is needed. If green policies are adopted, green jobs will inevitably follow.

3.3 Climate change affects everybody, disadvantaged and otherwise. “Disadvantaged communities” are likely to be affected more because they are less able to ameliorate the impacts and they cannot buy their way out of trouble.

3.4 We see no fundamental difference between inner and “outer London” in respect of climate change. The same determinants – town planning, building standards, transport policies, waste, etc - apply across all of London.

4. Policy 5.1 Question c

“Does the strategy provide a suitable response to the potential effects of development on climate?”

4.1 There is an issue about “development”. What development normally means in London is knocking down existing buildings and putting up new ones in their place. The existing buildings are often not that old and are often perfectly serviceable. Demolishing and rebuilding consumes large amounts of resources and creates significant amounts of greenhouse gases. But offsetting this, new buildings tend to be more energy efficient. The Plan should address these issue and its policies should be informed by climate change considerations.

5. Policy 5.2, Question d.

“Would London’s competitiveness with other UK Cities be diminished by adopting standards higher than those applying nationally?”

5.1 We see no evidence why London’s “competiveness” should be diminished. This question appears to reflect a belief, unsupported by evidence, that there is an inevitable conflict between environmental protection and economic growth. Or that those places which protect the environment perform worse economically. On the latter point, there is evidence that the reverse is true.

5.2 Judging by the population forecasts, there is a huge demand to live in London. London is clearly struggling to meet those demands. Meanwhile, other parts of the country are not under such pressures. This being so, it would be no bad thing if some people were deterred from living and working in London. We consider that London should compete with other UK cities on quality of life, environment and per-capita income, not on population and Gross Domestic Product.

6. Policy 5.2, Question g.

“Should the policy be clearer on what needs to be done, by whom and when?”

6.1 Emphatically yes! The policy should be much clearer on “what needs to be done, by whom and when”. The Plan is far too full of generalities, aspirations and vague statements of intent. It needs to be more focussed on specific policies and show how these relate to the over-arching objectives. Taking out generalized statements and listing only the real policies would allow the Plan to be much reduced in size – a great advantage if accessibility and public engagement are to be encouraged.

7. Policy 5.2, Questions e, f, h, i

7.1 We do not have comments at this stage.

8. Policies 5.3, 5.4

8.1 We do not have comments at this stage.