Response NYC draft climate action plan

NY Climate Coalition response to

NYC draft Climate Change Delivery Pathway (CCDP)

(April 2024)

For a summarised version of NY Climate Coalition’s response to the draft CCDP, see (in progress)

You can also download a copy of this response here.

North Yorkshire Climate Coalition is grateful for the opportunity to provide feedback on the draft CCDP. We wish to act as a ‘critical friend’ and therefore offer the following response in a constructive spirit.

We appreciate that there is a considerable amount of work involved in compiling relevant data from each of the predecessor councils in order to formulate a climate action plan spanning NYC’s full range of activities.

The draft CCDP contains many positives: emphasis on governance mechanisms; community engagement; climate communications plan; monitoring; breadth/scope (e.g. mitigation from ‘built environment’ to ‘carbon storage in environment’ and nature from ‘nature-based solutions’ to ‘marine environment’); willingness (in writing, at least) to aim beyond NYC’s operational emissions to exert an influence on the wider region; some ambitious language (e.g. ‘Embed climate change into every service and into policy and decision-making process so that taking climate responsible actions becomes business as usual’). While acknowledging these positives, this consultation response is intended to flag up what we perceive as gaps or weaknesses in the draft CCDP and where appropriate to suggest alternative or additional measures.

We note that initial draft directorate-level action plans will be in place by 31 March 2024. We hope to have an opportunity to review these documents at a suitable point in the pre-adoption process so that we can assess whether (in our view) they are sufficiently ambitious.

NYC is pursuing a twin approach that aims to reduce its own operational emissions to net zero by 2030 and to influence the wider regional push towards decarbonisation in line with and as a contribution to the Routemap to Carbon Negative targets.

NYC’s climate team have asked us to

Become familiar with the actions already proposed

To comment on those actions

To propose new or alternative actions and targets
To consider how the actions may be prioritised
To outline how our organisation(s) could help NYC to achieve the actions.

We have familiarised ourselves (Harrogate workshop, online session) with the proposed actions as set out in the separate tables (Governance, Mitigation, Adaptation, Nature). This response will therefore focus on b, c and d. Once the CCDP is finalised, we will consider how we can support the implementation process through our networks.

CCDP goals and ambition level

Our understanding is that the CCDP needs to achieve two main goals:

NYC operational emissions to net zero by 2030 based on clear actions, baselines, milestones and comprehensive methodology/monitoring;
NYC to use its influence to help drive NY as a whole towards the Routemap targets (NZ by 2034, carbon negative by 2040) by pulling every possible lever in key areas such as procurement, planning, transport, skills, nature restoration.

These are very challenging goals, but the science is clear that we need to achieve them. That requires a high degree of ambition and urgency. Our response looks at whether the CCDP as it stands meets these requirements and, if not, how it can be expanded or improved to enable us to meet the above goals.

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Decision-making and remit of CCDP drafting team

According to the draft, the CCDP ‘reflects the most effective task and actions’. This could suggest that the drafting team has been instructed to limit any proposals to what is considered ‘affordable’ or ‘viable’ given funding or other constraints. We would like to be assured that the remit (including ambition level) of the CCDP drafting team has not been explicitly or implicitly constrained by senior management or elected members (e.g. over funding concerns). Local Councils have wide-ranging powers to determine their own level of investment.

In our view, the explicit remit of the climate team should be to develop and propose actions that will enable NYC to reach its 2030 operational net zero target and make a significant contribution to the wider YNY Routemap goals. Decisions on whether the Council should adopt specific proposals made by the drafting team should be taken by senior management and elected members, who can then be asked by civil society groups to justify their decisions (e.g. on the grounds of cost-benefit; risk – including the risk of inaction; perceived affordability; resource allocation).

Senior management and the Council Executive should ensure that the drafting team are given the scope to ‘think outside of the box’ and to include radical and more expensive proposals for consideration if the team believes such proposals to be particularly useful or essential.

See also below under ‘Concerns over cost’ (page 5).

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Key recommendations

The draft CCDP combines actions to achieve the operational NZ target and support the wider regional goals. For greater clarity and to avoid confusion or conflation between these goals, we consider it essential that NYC develop two separate (but overlapping) pathways.

One clear weakness of current CCDP is the absence of metrics (baselines, milestones, both as % and ktCO2e). These are urgently needed to make the CCDP credible. NYC should allocate the necessary resources. Two separate sets of metrics are needed (for NYC operational NZ and contribution to the Routemap goals), each with its own milestones/interim targets and methodology/monitoring system).

Metrics showing the progress made towards both the operational NZ target and regional targets should be prepared for the Executive Committee on the same quarterly basis as for other areas of the Council’s operations.

Explicit clarification from senior NYC management (RF) and Council Executive (CL, GW) that the remit of the climate team should be to develop and present proposals that will meet the stated goals, leaving decisions on adoption to senior management and the Executive/Full Council. CCDP team to classify proposals to Council as ‘medium ambition’ or ‘high ambition’.

The CCDP does not appear to fully harness NYC’s procurement and planning powers as potentially the main levers for driving the transition to a low-carbon economy. Greater urgency and more radical actions may be required – if necessary, diverting resources from LP development on the balance of priorities.

As a guiding principle, resources (funding, staff time) should be allocated to actions with the greatest decarbonisation potential. NYC should avoid channelling the bulk of its time and resources into internal measures if those same resources could be used to achieve a much greater impact on the wider economy.

Switch bank given Barclays’ record of financing high-carbon projects (see below) as the current choice of bank is incompatible with NYC’s climate emergency declaration and adoption of the YHCC leadership pledge.

Phase out NYC’s remaining pension investments in fossil fuels – admittedly not a huge volume but as a clear signal. The current position is incompatible with NYC’s climate emergency declaration and adoption of the YHCC leadership pledge.

Ensure that the cost of delay/inaction is considered and given appropriate weighting when making decisions on CCDP proposals (see OBS report below).

Have confidence that there is clear public support for ambitious climate action. Be aware of perception gaps.

Establish and provide ongoing support for a NY Citizens’ Assembly to involve the wider public in this complex area of public policy, gauge public support for specific policies and generate a common sense of purpose.

Identify and consider successful actions and good practice at other local authorities to avoid ‘reinventing the wheel’.

Develop a much bolder, broader and more detailed communication plan.

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Response to proposed actions for NYC to achieve operational net zero

NYC operational emissions – rough estimate of baseline figures and required reductions

The predecessor County Council had Scope 1 emissions of 4.1kTCO2e in 2021/22, Scope 2 of 3.3kT and Scope 3 of 1.7kT, making a total of 9.1 ktCO2e (source: NYC website). The Scope 3 figure seems questionable as Scope 3 emissions are usually higher than Scope 1 and 2 (e.g. considering the large amounts of bituminous highway materials brought in by contractors). For the sake of argument, we suggest doubling these figures to include the operational emissions of the seven former district councils, making a rough baseline estimate of 18.2 ktCO2e.[1]

Assuming that the reductions achieved since 21/22 follow the historical trend of incremental steps (1-2%), NYC now has 6 years to achieve much greater annual reductions leading to net zero, say a 20% decline in each year, equivalent to a straight-line reduction of 3.5ktCO2e each year and therefore at least a ten-fold increase compared with the average historical rate.

We understand that metrics will be in place for the CCDP by the end of June 2024. In its present draft form, individual target reductions appear to be insubstantial (e.g. 7.3 tCO2e from the use of alternative fuels). The policies needed for NYC to reach operational NZ by 2030 will clearly need to be highly ambitious, including a complete decarbonisation plan for the Council's own buildings and a full fleet replacement programme. Are the measures under consideration aligned with this high ambition level? How far advanced are procurement decisions in these areas?

For wider context, public sector emissions make up just 2% of NY’s total emissions according to the BEIS local authority GHG statistics for 2021. Our understanding is that NYC wishes to focus resources on reaching its operational net zero target. While this is important as it lends credibility to NYC’s efforts to influence other key stakeholders (e.g. agricultural sector, transport system operators, private sector, suppliers), we wish to stress NYC’s crucial and even more important role in leading, enabling and incentivising the wider regional transition to a low/zero carbon economy and society, i.e. rapidly addressing and cutting the remaining 98% of NY’s emissions.

It is clear from the action tables that NYC accepts this wider responsibility. However, we are concerned that Council resources and energy may be so focused on the operational side that actions to exert a wider influence on the remaining 98% may be held up, deprioritised or even put to one side.

It is our view that NYC needs to pursue both its operational net zero target and the wider Routemap decarbonisation goal (as endorsed by the council) .

In our view, as a guiding principle, For example, if a given amount of funding/resources could deliver either an in-house reduction of 100 ktCO2e or a region-wide reduction of 1,000 ktCO2e, priority should (probably) be given to the latter. Wherever possible, this cost-benefit analysis should be applied to all proposed actions in the CCDP, and the actions should be prioritised accordingly.

Accordingly, we are keen for NYC to start exerting its wider influence immediately (see below) rather than channelling the bulk of its time and resources into internal measures that may cut the public-sector’s contribution from the current 2% but have little wider impact.

With regard to NYC’s operational emissions, we are concerned that baseline figures will not be available until the end of June, a full year on from the adoption of the climate strategy and two years on from the declaration of a climate emergency. Whether this is due to technical problems in data collection or a lack of resources (staff time), it does not in our view convey the required sense of urgency.

We note that each directorate will have its own pathway and designated climate lead. These are positive governance steps that will help to mainstream a low/zero-carbon mindset across the council. However, the development of individual directorate pathways will also create a requirement for additional monitoring and progress-checking. How will directorates assess whether progress is on track and identify the corrective action needed when they are off-track?

Once the baseline figures for NYC’s operational emissions have been produced, we hope to see a clear set of metrics covering the period up to 2030. These should be made available as soon as possible and should include clear, ambitious and credible milestones (reductions expressed as % and in ktCO2e). For reasons of transparency, we would also like to see a clear and transparent set of monitoring and review mechanisms.

On the question of , we are pleased to note that NYC has signed the Yorkshire and Humber Climate Commission’s climate pledge, which is essentially a commitment to play a leadership role (‘Action on climate and nature will be a top priority within our business / organisation, with leadership on climate and nature’).

We also understand that NYC has updated its corporate risk register to include climate change as a top-level risk factor.

At this point, we wish to propose two specific actions (in addition to those set out in the CCDP) that would help NYC to :

Switch bank. NYC currently banks with Barclays, which was Europe’s biggest funder of the fossil fuel sector between 2016 and 2021. This choice of bank is incompatible with NYC’s declaration of a climate emergency and its adoption of the YHCC climate pledge. Although Barclays recently announced plans to end direct funding for any oil and gas projects in the Amazon or in the Arctic Circle (or projects aimed at extracting, processing or transporting oil from oil sands), direct funding for specific projects makes up only a small fraction of Barclays' overall lending to the sector. Our view is that major oil and gas financiers will continue to largely ignore calls for them to phase out their oil and gas lending activities unless major clients, including local authorities such as NYC, make a conscious choice to bank elsewhere. Our member group Fossil Free North Yorkshire can provide all the information you may need to back up and action this proposal.

Pension scheme. North Yorkshire Pension Fund (NYPF) currently invests 1.3% of its total assets in fossil fuel companies, which equates to £55 to £60 million worth of holdings. NYPF has made progress in divesting from fossil fuel companies. However, were this £55 to £60 million to be divested and reinvested in local sustainable North Yorkshire schemes, the benefit to the local economy could be significant. There is no evidence that such an approach would materially impact pensions. We would encourage NYC to work with other local government pension funds that have holdings in the Border to Coast Pension Partnership (a pension pool which manages the funds of eleven local government pension schemes) to bring about a rapid reduction in the volume of BCPP’s fossil fuel holdings. While the figure for NYPF is not high, the crucial factor here is the message that divestment by a large public authority would send. See UK Divest website for more information. Other local authorities have already taken a lead on this issue. See, for example, How Waltham Forest is divesting pensions out of fossil fuels | Climate Action (takeclimateaction.uk).

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Response to proposed CCDP actions for NYC to influence the wider push towards regional decarbonisation

We are pleased to note that the CCDP includes a wide range of areas in which NYC can exert a significant influence over the rate of decarbonisation in the wider region and thus contribute to the Routemap targets.

Background, BEIS local authority area GHG statistics for 2021, projections and general observations

The most recent (2021) BEIS (now DESNZ) emissions statistics for NY as a whole show:

grand total all NY: 6,392 ktCO2e (10.3 tCO2e per capita)
of which public sector emissions just 2%
average annual reduction 2005-21: 1.6% (i.e. small, incremental steps)
9.1% UP on 2020 (post-Covid rebound v UK rebound 5.9%)
agriculture 32%; transport 30%; domestic 18%; industry 17%
Our understanding is that GHG emissions from Allerton waste recovery site are not included in the BEIS figures classed as ‘within the influence of the local authority’ as they fall under a different category (ETS) but are included in the overall NY figure of 120 ktCO2e. Is this correct? Are GHG emissions figures for Allerton available?

For the NY local authority area as a whole, as shown in Figure 1 below, net zero by 2034 (in line with the Routemap target ‘endorsed’ by NYC) would require at least an immediate 5-fold increase in the rate of decarbonisation assuming a straight-line reduction (i.e. the historical average rate of 1.6% x 5 = 8%). As the BEIS figures are now two years’ old, the actual reduction required with a start date of 2024 would be even higher.

Anything less than this reduction rate now will make the target even more difficult to achieve later. It follows that radical policies will be needed to deliver reductions on this scale. Delaying the introduction of such policies now in the hope that future technology roll-outs or central government action will come to the rescue is highly risky.

Concerns over cost

Cost implications are often cited at NYC (and other local authorities) as the main obstacle to more ambitious climate policies. We are of course aware of the increasing pressure on council budgets, especially in areas such as adult care and special needs provision.

Nevertheless, we wish to highlight the clear message of the Office for Budget Responsibility (OBR) that delaying action would increase costs, while losing control of climate change would increase them many times over.

The OBR guidance is summarised in the excellent report Paying for Net Zero produced by the Institute for Government.

We suggest the CCDP drafting team classify proposals as ‘medium ambition’ and ‘high ambition’.

In this context, we understand that the actions proposed by NYC’s climate team focus where possible on invest to save options.

In addition, there are many ways in which NYC can contribute significantly to the wider regional decarbonisation targets without placing additional pressure on budgets, above all by making full use of its influence as a major purchaser of services and its powers as a planning authority (e.g. promoting the use of suitable land for renewable energy generation)[2] and by adopting some of the low/zero-cost measures already implemented successfully by other authorities (see appendix).

Concerns over public support – public mandate and perception gap

Recent polling shows very strong support for climate action by policymakers, see e.g. Environment-and-Climate-Polling-Report-September-2023.pdf (greenpeace.org.uk).

The results of the Let’s Talk Climate consultation demonstrate clear public support across the county for NYC to adopt a ‘high ambition’ approach.

Despite this evidence, a recent study reported in Carbon Brief February 2024 demonstrates that there is a significant perception gap between where people stand on the need for strong climate action and where they think others stand. The underlying survey (135,000 people in 125 countries) shows that while there is clear evidence of very strong public support for climate action, we nevertheless systematically underestimate the willingness of our fellow citizens to act. This short video clip from climate barometer explains the concept well.

This perception gap can be an obstacle to meaningful action at NYC if policymakers (officers and elected members) do not believe there is a public mandate for ambitious decarbonisation policies in spite of the evidence showing that that there is.

Accordingly, we believe the CCDP drafting team should present decision-makers with genuinely ambitious and even radical policy options and, importantly, should avoid moderating proposals in anticipation of their rejection. If decision-makers then choose not to consider or adopt such proposals, we can then challenge them in our civil society role to explain their reasons. It may be appropriate for the drafting team to frame/classify proposals as ‘medium ambition’ and ‘high ambition’.

One way of gauging public support for strong climate actions would be to establish a NY citizens’ assembly (see below under Communication).

When developing and presenting proposals, the CCDP drafting team should also be aware of, anticipate and challenge other obstacles to ambition that can be present in all organisations, such as institutional inertia and silo thinking.

Borrowing ideas from other local authorities

We are pleased to note that NYC is already seeking out examples of best practice at other local authorities in order to identify potentially useful templates for actions rather than necessarily starting with a blank sheet. We would encourage the CCDP drafting team to maintain and ideally expand this approach.

This may save considerable time and money (synergies). For example, is there a local authority with a highly regarded sustainable procurement strategy? How have other planning authorities used their powers under the planning system to reduce the GHG emissions of existing and new housing stock? Is there a similarly large rural authority that has found an innovative solution to rural transport provision or ways of incentivising the transition to more sustainable forms of agriculture and food production? Which authorities have already developed a climate change communication strategy?

NY Climate Coalition is very willing to use its own resources, knowledge and networks to help NYC identify examples of successful policies and actions that could be replicated in or adapted to NY.

Two useful online sources of ideas and good practice are the Ashden Trust website (https://ashden.org/sustainable-towns-cities/) and the LGA Knowledge Hub.

A large number of case studies (coordinated with Ashden) can be found on the FoE website at https://groups.friendsoftheearth.uk/resources/councils-tackling-climate-chaos.

Sustainability and net zero standards and LGA/UK100 guidance. The only mention of ‘standards’ in the CCDP relates to the Future Homes Standard. Could NYC adopt existing standards to underpin its CCDP actions, e.g. UK Green Building Council’s New Homes Policy Playbook. Does the CCDP make full use of the actions suggested in the LGA’s Delivering local net zero | Local Government Association and in the UK100_Powers in Place_FINAL_26_April.pdf?

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Specific feedback on the CCDP categories

Draft pathway tables

The pathway is arranged under four headings, each with sub-headings.

Governance (performance; governance & communication;

Mitigation (Built environment; Travel & transport; Waste & circular economy; Renewable energy transition; Agricultural emissions; Capturing and storing carbon)

Adaptation (to be developed)[3]

Supporting nature (Work in partnerships; Prioritise nature-based solutions; Implement statutory requirements; Support nature through economic growth; Sustainable land use and green spaces; Tree planting at scale; New opportunities in the marine environment)

GOVERNANCE

The most obvious gap under the heading ‘Governance’ is the absence of metrics (baseline, targets, interim milestones). See comments above (page 2). The pathway as a whole will be much more credible once these figures are in place (draft CCDP target date: end June 2024). We would encourage NYC to allocate the resources needed to define these metrics as quickly as possible.[4] The Executive Committee currently receive performance monitoring data across the Council on a quarterly basis. Given the significance of carbon reduction within the policy framework, metrics should be reported in a similar way for progress on climate action.

In addition to metrics showing progress towards NYC’s operational net zero target, we would like to see a set of metrics developed that address the impact of actions taken by NYC to help decarbonise the county as a whole.

Procurement (scope 3)

Although this is probably the area in which NYC as a major public sector procurement body can have the greatest influence over the trajectory of GHG emissions in NY (scope 3), the short-term pathway actions appear to be limited to ‘revisit(ing) the procurement strategy to support low-carbon procurement’, developing a methodology for measuring procurement emissions and compiling performance data by the end of June 2024. While these are of course good things to do, we are concerned that NYC has not already reviewed its procurement strategy, identified the main areas in which it could exert an influence and developed corresponding procurement criteria (e.g. social value, GHG emissions, suppliers with SBTi certification) for inclusion in the specifications (terms of reference) issued to potential and existing suppliers.

Given the GHG mitigation potential of this core NYC activity, we strongly encourage NYC to allocate the resources needed so that faster progress can be made in this area.

We are also concerned at the language used in relation to suppliers. We appreciate that NYC will need to manage this change process carefully and will need to support those suppliers (especially SMEs) that have fewer resources and further to go, but the wording ‘encourage our suppliers to take climate-responsible actions’ appears weak given the urgency and scale of the challenge.

Highlighting the importance of procurement as a decarbonisation lever, one of the key actions proposed by carboncopy, a UK charity focused on low-carbon solutions, is for local authorities to link their low-carbon strategy and team with their procurement strategy and team. See https://carboncopy.eco/initiatives/local-authority-low-carbon-procurement.

For reference, the Welsh Government has produced a sustainable procurement toolkit at https://www.wlga.wales/local-authority-sustainable-procurement-toolkit.

The LGA has a Sustainable Procurement Toolkit at Sustainable procurement – delivering local economic, social and environmental priorities | Local Government Association.

Planning

We are surprised at the lack of emphasis on planning in the CCDP as it is one the key levers that NYC can pull to help drive the wider decarbonisation of the region.

Our impression from discussions with planning officers at the workshop was that all the Council’s planning resources are currently focused on preparing the new local plan and that the planning team is unwilling to consider more immediate actions that would divert resources away from this goal.

For example, we have proposed introducing a master net zero supplementary planning document setting out stringent low-carbon specifications that could be applied to all new planning proposals for the interim period until the new local plan is in place. We believe such a ‘net zero SPD’ could be in place relatively quickly and could be hooked on to current district-level local plans through existing sustainable development policies which predominantly all refer to the NPPF, for example the Craven Local Plan (adopted 2019). The NPPF definition of sustainable development (para 8) includes the need to mitigate and adapt to climate change, including moving to a low carbon economy. Indeed paragraph 11 sets out that plans and decisions should apply a presumption in favour of sustainable development. Some more recently adopted district plans (for example, Harrogate Local Plan policy CC4, adopted 2020) contain specific policies in relation to sustainable design, acknowledging the role the planning system plays in securing radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to climate change. As such, hooks to a specific SPD could be found within such policies.

Warwick DC are currently going through examination of their net zero SPD, but the signs look good. Also Royal Borough of Kensington and Islington Council.

Although the Future Homes Standard should be an improvement, there will be no ‘expectation’ for local planning authorities to deliver above standard. It follows that NYC should not simply wait for the FHS to raise standards.

While we understand the planning team’s wish to make rapid progress on the new county-wide LP, in the context of a declared climate emergency we simply cannot afford three more years of delay (anticipated completion 2027) before using NYC’s planning powers to support the regional Routemap targets. The planning authority has the power to specify and impose much more stringent net zero requirements now. We urge NYC to find ways of doing so and in particular to reconsider its rejection of our Net Zero SPD proposal.

Communication/messaging

Councils can only do so much themselves due to limited resources but their ability to influence through messaging is much greater.

The Combined Mayoral Authority’s Routemap to Carbon Negative explains the crucial role of communication as follows: ‘Getting people and organisations actively engaged and being part of the journey to carbon negative is absolutely critical. We now know what we need to do to get to net zero and beyond to carbon negative, but communicating these solutions and obtaining buy-in remains a huge challenge. An important part of reaching and engaging people is communicating the most appealing co-benefits (e.g. saving money, cleaner air, improved health) to different types of stakeholders. This enabler is critical to supporting behaviour change – making individuals and organisations aware of the changes that they can make, as well as empowering them to take action.’

While effective and inspiring communication is a crucial element of any climate action plan, there has been little evidence of high-level public messaging on this subject by senior Council officers or Executive members over the last two years despite the declaration of a climate emergency.

Equally, there appeared to be little evidence of a comprehensive NYC climate action communication strategy at the Harrogate workshop. While we appreciate the opportunity to provide input, we were surprised that the comms team did not appear to have already developed a clear picture of the main communication goals, target audiences and the key channels for engaging with that audience.

The CCDP includes a relatively modest set of proposals given the urgent nature of the challenge. These include a short-term action to develop a communications and engagement plan by 2025. The objective is expressed as ‘improving engagement with residents / businesses and communities and regional partners’. The planned output by 30 June 2024 is to develop 6 engagement activities p.a. and 12 newsletters and a partnership engagement plan. The current climate newsletter is excellent but may be of limited interest outside dedicated campaign groups.

Our view is that a much bolder, broader and more detailed communication plan is needed.

While it is difficult to quantify the impact of such a strategy in terms of reduced emissions, it is widely accepted that effective communications are crucial when it comes to making the case for ambitious climate action.

The aims of a climate communication/messaging strategy should be (in no particular order) to:

keep the economic and social benefits and co-benefits at the forefront in public perceptions
raise the profile of the Council’s zero-carbon journey
communicate a sense of urgency, challenge, common purpose and can-do spirit
raise public awareness of the underlying climate science (educate, encourage, challenge, reward) – online, in the media and in person (climate roadshow?)
obtain public buy-in for potentially difficult or radical policies (‘critical mass’ of public support)
present a strong and consistent message in the media (press, radio, TV), with regular articles/appearances by senior officers and elected members (nb this has not been the case to date)
promote behavioural change.

The communication strategy itself should employ proven and effective methods. The CCDP drafting team may wish to study the Climate Change Communications Plan developed by Manchester City Council.

Climate Outreach also have great resources. See https://climateoutreach.org/local-authorities-climate-comms-2/ and https://www.involve.org.uk/resource/public-engagement-climate-practical-guide.

We would encourage NYC to establish a NY citizens’ assembly as a key element of its wider communication plan. This approach emphasises the need for action ‘across the board’ – individuals, households, communities and voluntary organisations, companies and statutory bodies. There needs to be a keen sense that we are all pulling together, and that responsible action is being taken at all levels. With good facilitation, we believe that an Assembly could provide a very necessary focal point for coordinated action. Guidance on how to set up and then support a Citizens’ Assembly can be found at https://www.involve.org.uk/our-work/our-projects/how-can-councils-engage-residents-tackle-local-issues.

The Institute for Government website also has a useful explainer on citizens' assemblies and how they work at Citizens' assemblies | Institute for Government. A citizens’ assembly would provide North Yorkshire Council with views from a wide range of residents who are representative of the demographics of the county, i.e. not just the views of activists, politicians and vested interests. It would encourage a collaborative rather than combative approach and would help NYC to understand the concerns of the wider population. In our view, this approach to participatory local democracy is ideally suited to complex policy areas such as climate change.

With further regard to building local awareness of climate issues across the county as part of an ambitious communication strategy, NYC’s climate policy team will find a series of useful tools and resources produced by DEAL (Doughnut Economics Action Lab), which was founded by the highly respected economist Kate Raworth. The DE approach is to bring people together in a specified community or group of communities to identify and find solutions to environmental issues that they can potentially solve themselves or encourage others to do so. Examples on the website show how this approach has been put into practice elsewhere. The tools can be used to support the CCDP’s objectives in the Governance areas of ‘Communications/engagement’ and ‘Embed(ing) climate change into every service and into policy and decision-making process so that taking climate responsible actions becomes business as usual’.

Climate literacy training (for officers, elected members and the public) should also form an integral part of NYC’s communications plan. We highlighted the importance and benefits of this approach last year in our NYC Climate Coalition response to the consultation on the climate change strategy. At least one full day (or equivalent) of climate literacy training should be mandatory for those in decision-making roles at NYC. The cost would be relatively modest. This would reflect very positively on the Council and provide assurance to the public and to all our climate groups across the county that our representatives will then be in a position to make decisions with a clear understanding of the climate implications and a sense of the required urgency.

Alternatively, NYC may wish to consider engaging the services of an external communications expert/team with relevant local authority experience to produce (or lead the development of) such a strategy. One agency with a strong online profile in this sector is Forster Communications, which classes itself as a B Corporation.

We encourage NYC to allocate the resources needed to develop (or commission) a comprehensive communications plan as quickly as possible. Without such a plan, there is a significant risk of actions being unfocused and therefore less effective.

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

MITIGATION

On a positive note, this section of the CCDP addresses a wide range of areas with mitigation potential: the built environment, travel and transport, waste and circular economy, renewable energy transition, agricultural emissions, capturing and storing carbon. These have actions in place with funding either identified or being bid for, although metrics are still lacking.

In the time available, we have not been able to draft further specific comments on the Agriculture or Transport sections of the Mitigation pathway document.

We have already set out proposals in these areas in our previous response to the draft climate strategy and on 20 October we discussed transport options at a meeting with AD Micheal Leah and Transport Team Leader Louise Neale.

Domestic

After agriculture and transport, households are the biggest contributor to emissions across our area. Within budgetary constraints, there is still a great deal the Council can do to actively help residents decarbonise their homes.

The following proposals are not budget-intensive and much more about NYC using its purchasing power, knowledge and influence to:

establish a 'Solar Together' project as has been done both in Kendal https://zerocarbonkendal.org.uk/solar-made-easy-kendal/ and Kent CC https://www.kent.gov.uk/leisure-and-community/cost-of-living-support/household-energy/solar-together-kent to reduce the costs to home-owners
guide residents towards approved retro-fitters e.g. https://www.chichester.gov.uk/wholehouseretrofit to make the process as stress and hassle free as possible
provide a leadership example to residents and retrofit Council owned buildings e.g. https://groups.friendsoftheearth.uk/climate-action/how-north-east-derbyshire-upgraded-council-homes-and-tackled-fuel-poverty

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

NATURE

NYC is the lead authority for the LNRS, and we encourage it to fully support the efforts of the LNRS drafting team, ensuring that it has a remit to be highly ambitious.

As with the overall pathway, no mention is made of the role of the planning department in protecting biodiversity other than to say that BNG is in the Local Plan (target date 2027) policy workstream. As BNG is a requirement of the Environment Act, presumably it will be applied with immediate effect. Please confirm.

The pathway seems heavily reliant on supporting community and charitable endeavours in enhancing biodiversity. This may present a risk as volunteers are becoming harder to source. In addition there does not seem to be any focus on protecting biodiversity within built-up areas or any acknowledgement that access to nature is important to the wellbeing of the council's residents. This is clearly important in those areas where access to nature is limited because of the absence of a local public transport network.

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

Appendix

Appendix of suggested low/zero-cost climate and nature actions aligned with the goals of NYC’s climate strategy

Communication/messaging

NYC to organise or facilitate a climate roadshow and/or public information campaign (REG) to get the message out around the county, e.g. explaining the climate science, highlighting potential energy savings and the benefits of moving rapidly towards net zero.

Cost: low.

Declare support for the Blueprint for accelerating climate action and a green recovery at the local level.

Council case study Why Kingston is backing the climate action Blueprint | Climate Action (takeclimateaction.uk)

Cost: zero.

Free parking for EVs (and possibly ULEVs) (as in Sheffield) for a limited period to encourage take-up. Consider making up any shortfall by increasing the parking charge for large vehicles (SUVs) - excluding vans which may be used by small businesses.

Cost: low - manageable loss of parking revenue as currently (March 2024) relatively few EVs (1 in 32 of all cars on the road). Primarily intended as a market signal.

Set up a limited scrappage scheme for the oldest and therefore most polluting vehicles. This has been introduced e.g. in Birmingham. The cost can be managed by limiting the overall budget, specifying the age of eligible vehicles, required proof of length of ownership, etc. The Council could use its influence to invite contributions to this budget from EV distributors or use any funds generated by a Community Municipal Investment (CMI) of Community Infrastructure Levy (CIL), see below).

Cost: low to moderate depending on scheme

Organise a series of EV days in collaboration with EV distributors and EV owners’ groups. Possibly start with a pilot, e.g. the Farmer’s Market site in Thirsk have expressed an interest.

Cost: low

Voluntary speed limit. invite NY residents to adopt voluntary lower speed limits on NY roads, e.g. 70>60 and 60>50. Most efficient speed is around 55 mph.

Cost: zero.

Set a phase-out date for petrol/diesel buses and taxis and council vehicles to incentivise switch to EV. This was done in Southampton.

Cost: low/zero

Financial

Raising money for green infrastructure through a Community Municipal Investment (CMI), as in West Berkshire) for low-carbon infrastructure, particularly measures that speed up carbon emissions reductions, such as energy efficiency and converting roads or car parks to public green space. This has been done in Warrington.

Cost: zero or negative.

Raise money for green infrastructure through a Community Infrastructure Levy (CIL) as used by South Gloucestershire Council. South Gloucestershire Council established a Climate Emergency infrastructure budget with funding from a CIL. Expected to raise £1.5 million a year until at least 2024. Cost: neutral.

Energy-efficiency, renewables and retrofitting

Campaign to encourage schools and public buildings to install rooftop solar, possibly with battery storage. This should be a no-brainer given the falling costs of solar installations and the rising cost of energy. Solar for Schools - Education funded by the sun. Cost: depends on number of schools and scale of installation. Perhaps pilot in 2-3 areas. Set overall budget/cap.

Cost: neutral (see S4S website).

Parallel scheme for residential properties using the Council’s group-buying power. This approach is now established e.g. in East Hertfordshire. See Solar Together East Herts | East Herts District Council. Possible use of CMI/CIL funds.

Cost – request info from East Herts CC.

NYCC voluntary guidance to shops/office on min/max temperatures and night-time lighting (REG)

Agriculture, Nature and land-use

Tree-planting. Possible aid to identifying appropriate sites. See How to use the Woodland Opportunity Map | Resources (friendsoftheearth.uk).

With specific regard to strategic land-use planning, we are interested to know whether NYC’s planning team has identified areas for renewable energy development including onshore wind and solar. See footnote 2 (above) on Friends of the Earth’s new research (available Tuesday 9 April) into potential generation capacity in North Yorkshire from ground-mounted solar and onshore wind. See also CPRENEY research into the potential generation capacity of rooftop solar.

Waste

Simple council decision to ban single-use plastic in council offices and premises. This has been done by Durham Council.

Cost: zero

NY Climate Coalition

5 April 2024