Response to consultation on climate change strategy 31 January 2008 Response to climate change consultation 1 How easy did you find the Climate Change Strategy to understand? Neither easy nor difficult Has the strategy addressed the issues that you think are important? No. Action on a scale proportionate to a problem (ie, global, not some local council) and value for money for the poor people who have to fund it all. How did you feel about the actions contained in the strategy? Very unhappy Utterly shameful and cynical waste of public money. The London Borough of Merton is in no way the proper agency to deal with issues of a truly global scale. This document serves only to flatter the sense of self-importance of officers and councillors who imagine themselves as grander than solving mere local issues and pander to reactionary minorities who insist on 'action' where none would be better. Why has no Cost-Benefit Analysis been included as part of the assessment? I am pretty certain why - any rigourous analysis would illustrate this stategy can certainly impose a lot of costs on local businesses, residents and tax-payers but can do precious little to alter the planet's climate or the effects of any change upon Merton's residents. Then the officers and councillors would have to concentrate on the mundanity of local issues where they can make a difference. Such contempt for the tax-payer really is disgraceful. If you're going to propose these regulations and expenditures (and therefore taxes), at least have the courtesy to demonstrate why they will make people in Merton better off! Ans to Q4: Scrap it. A couple of items may be worth pursuing in their own right, but certainly not because our little borough has any power at all to alter climate change! Unfortunately, most will cause more harm than good, or are already the remit of other agencies which Merton should not be attempting to duplicate! Aim EE1: All nine of these propaganda policies require someone to be paid in order to 'co-ordinate' them, not to mention the media (posters, hoardings, leaflets, websites, books, newsletters etc etc) that will need to be produced. There is nothing at all about climate change that is specific to merton. The climate does not respect borough boundaries of policy. This stuff should be left to the Energy Saving Trust and similar bodies. There should be no advertising whatsoever in council propaganda, re policy EE9. If the propaganda cannot be justified on its own account - under no circumstances should the Response to consultation on climate change strategy 31 January 2008 council open itself to possible pressures of advertisers in order to establish itself in the publishing sector. The council should be unimpeachable - and that means no favours to suppliers, and no financial interests or dependencies. Aim EE2: This is a waste of money and is not the proper remit of a council. The Energy Saving Trust and others already perform this function. Aim EE3: Merton cannot influence the climate, so should not waste taxpayer's money attempting to 'educate' its employees as to how to do so. Turn off lights to save money by all means, but the focus should be on minimising council expenditure (and therefore tax) while performing necessary functions (ie, ones that cannot be done by others). Aim E1, E2 and E3: same principles as above. These are either duplicated, ineffective or, in terms of halting climate change, futile. The emphasis should be on reducing expenditure and taking less tax. Aim P1,2,3 and 4: The reason why developers do not already implement these policies without the the council forcing them to through planning policies is simple: they are a waste of money. If electricity were more expensive, then developers would respond to pressure from buyers to make developments 'effectively insulated', for example. Therefore these specific policies can only fall into one of two categories: 1) waste of time writing it, because developers would do it anyway. 2) waste of resources having to comply, because people have to be forced by the council into doing something that is not viable. T4 "Promote car free, work place and residential travel plans in all new developments." It is unclear whether 'promote' means, in this case, "tax people to pay for someone to extoll the benefits of", or "Force property owners to comply with this policy through the planning system." Neither of which is great, but the latter would be significantly more harmful. "Procurement and Fairtrade" "Supermarkets transport millions of tonnes of produce around the country, unnecessarily creating CO2 emissions from the cold stores and lorries." I am ashamed that my council has a policy document with such utter tripe as this written down and made publicly available. My council really believes that supermarkets 'unnecessarily' transport their produce from farms and factories to their shops? What utter nonsense! How else does the council suppose produce gets from where they are made to us? "As well as helping to sustain local industry, sourcing more food and goods locally will help to reduce the “food miles”, unnecessary cold storage and resultant C02 emissions" Studies have shown lamb from New Zealand, including airfreight, produces less CO2 than British lamb, likewise with Kenyan tulips compared to Dutch and countless other products. Merton council should not be promoting this discredited soundbite, and the vacuous thinking which lies behind it. "If farmers are impoverished then there is a great danger that to feed their Response to consultation on climate change strategy 31 January 2008 families they resort to aggressive and environmentally damaging agricultural techniques such as felling forests to grow crops." This is patently wrong. Low prices are the market's signal for producers to exit a market, they are a symptom of oversupply. Higher prices will provide a greater incentive to produce (through forest felling or otherwise) than low prices. Low prices encourage people to do something else - high prices encourage more production. Even council officers should know this! Aim PF1: This is a waste of money, and a harmful waste of money at that. Poor people in the third world do not need rich world local governments keeping uneconomic production afloat out of charity, thereby ensuring prices remain low and they remain poor. Nor does deforrestation caused by the artificial incentives of high prices help the environment. Especially not when this is all costing more in order to do this damage. Time to get back to community policing, rubbish collection, grafitti removal, education etc etc. 2 Feedback on the Draft Merton Climate Change Strategy 1. Aims EE1 to EE9 – there are opportunities to link in with the Mayor‟s DIY Planet Repairs campaign. The aim of the campaign aims to provide the public with practical advice and useful information that will enable them to make simple and effective changes to reduce their carbon footprint. The campaign is also providing a number of incentives, such as money back on the installation of loft insulation and other energy efficiency measures. More information is available at www.london.gov.uk/diy/. 2. Aims EE1 – EE9 – there are also opportunities to link in with the Mayor‟s Green Homes Service and the Mayor‟s Green Concierge Service. The Mayor‟s Green Homes Service aims to provide advice to homeowners, tenants and landlords, providing information, help and advice on simple green practices that will help reduce the city‟s CO2 emissions and achieve the targets from the Mayor‟s Climate Change Action Plan. More information is available at http://www.londonclimatechange.co.uk/. The Mayor‟s Green Concierge Service is for homeowners who are able and willing to pay for expert advice from Ten UK who specialize in reducing the „carbon footprint‟ of homes. The Green Homes Concierge service staff visit homes, calculate energy wastage and recommend tailor-made measures to reduce energy consumption. The payment covers the service for one year during which the service will research and advise homeowners on contractors, provide discounts on energy saving equipment and manage any necessary home improvement work. More information is available at: http://www.londonclimatechange.co.uk/greenhomes/green-concierge-service/. 3. Aims EE10 – EE12 – there are opportunities to link in with the Mayor‟s Green Organisations programme and the Mayor‟s Green 500 initiative. The Mayor‟s Green Organisations offers services, information, advice, tools and case studies and sets out how organisations can really make a difference. More information is available at http://www.londonclimatechange.co.uk/. The Mayor‟s Green 500 Response to consultation on climate change strategy 31 January 2008 initiative aims to help London based businesses or businesses in trade in London address climate change by acknowledging and encouraging organisations that commit to better green practices. The Green 500 provides businesses with a tailored carbon management service that provides specialist advice on reducing carbon emissions. More information is available at http://www.green500.co.uk/cms/. 4. Section 3 on Energy (p6) – there is the opportunity to use the information in the CCAP which states that 54% of the contribution to CO2 from the domestic sector is from space heating and cooling. This will provide further evidence why this is an area that is being targeting to reduce greenhouse gas emissions. 5. Aim E4: “Develop the business case to create advisory services on a commercial basis for residents who can afford to, and want to, go green” – this would provide another opportunity to work with the Mayor‟s Green Concierge Service (see comment 2) 6. Aim E5 - “Determine current CO2 emissions and monitor progress on reductions” – Merton can use the London‟s Energy and CO2 Emissions Inventory (LECI) to assist the calculation of Merton‟s geographical CO2 emissions. There will also information available shortly on greenhouse gas emissions based for 2004 – 2006 through the London Energy and Greenhouse Gas Emissions Inventory (LEGGI). There is the opportunity to link this aim with the forthcoming Local Performance Indicators on CO2 emissions and to link climate change into the borough‟s Local Area Agreements. 7. P7 – “What you can do – Produce clean energy/heat – consider installing wood burning stoves or biomass heaters in residential properties” - the Mayor‟s policies promote communal heating systems and not the installation of individual stoves of heaters in individual properties. 8. Aim P1 “Apply a policy requiring 20% renewable energy for all appropriate developments until the LDF is adopted” – very supportive of this aim as long as it‟s related to energy efficient design and supply policies in the draft Further Alterations to the London Plan, in particular policy 4A.15 as amended by the Panel report following the Examination in Public (see recommendation number 1.4 in the attached report). There is the opportunity to link this with the Draft Further Alternations to the London Plan (FALP), which now also requires a 20% reduction in CO2 emissions to be generated from onsite renewables. 9. Aim P3 “Require large housing and commercial developments to use CHP/DHP units” – very supportive of this aim. There is the opportunity to again link with the Draft FALP which requires new developments to demonstrate that their heating, cooling and power systems have been selected to minimise CO2 emissions and that their heating and cooling infrastructure should be designed to allow the use of decentralised energy. There is also the opportunity to work with the London Energy Partnership on the mapping of heat networks in London (contact firstname.lastname@example.org) 10. Aim P4 “require all developments to be effectively insulated” – recommend firming this aim up, first of all to confirm that this is for new developments and Response to consultation on climate change strategy 31 January 2008 secondly to give an indication on what you determine to be “effectively insulated”. For instance, requiring a U-value higher that what is required in building regulations. 11. Aim P8 “promote the use of sustainable materials in all new developments” – recommend consideration on how “sustainable” will be assessed, e.g. locality, recycled content, embodied carbon, etc. 12. Aim P13 “Explore the feasibility of erecting wind turbines on open spaces in partnership with residents and local organisations” – there is the opportunity to utilise the London Energy Partnership‟s (LEP) London Wind and biomass energy study and the LEP Wind feasibility studies - http://www.lep.org.uk/projects/energy-demand-and-supply.htm Feedback on the Draft Climate Change Strategy: Evidence Base 1. Section 2.10, p5 – Might assist the reader if it is made clear that the expected impacts are for the UK, and hence British crops, habitats and landscapes. 2. Section 2.18 – London (Greater London Authority) – London‟s 60% target for 2025 excludes aviation. There is an opportunity to reference the London Plan and the Draft Further Alterations to the London Plan that is providing some of the mechanisms to reduce CO2 in London. There is also a new duty on the Mayor as a result of the adoption of the GLA Act to have regard for climate change and the consequences of climate change in exercising his powers and to produce a „climate change mitigation and energy strategy‟ and a „climate change adaptation strategy‟. The climate change mitigation and energy strategy must minimise emissions of CO2 and other greenhouse gas substances. 3. Section 4.2 Figure 3 – the energy hierarchy presented here is not the same as the energy hierarchy presented in the Draft Further Alterations to the London Plan and supported by the Panel Report following the Examination in Public. The hierarchy has changed from the original 2003 Energy Strategy version, and now “cleaner energy” supersedes “greener energy”. Appreciate that you are using information from the LGA, but would strongly recommend using the energy hierarchy that is available for London. 4. Section 4.15 “Work has already taken place to examine the possibilities of implementing district heat and power in Merton. However, a further operational study must take place…” – recommend contacting the LEP on their heat network project – contact Ross Hudson as above. In support of the need to progress a further study, please note draft Further Alterations Panel Report recommendation 1.12 (p31) for a new Development Plan policy on implementing district heating. This will become a requirement for the Council in their LDF process. 5. P22, 7.2, Transport – There a figures available for London from figure (i) in the London Climate Change Action Plan for the proportion of London‟s contribution from ground-based transport, which at 22% is different to national figures of 40% because of the effect of London‟s highly used public transport infrastructure. You might want to reflect this in the strategy. Response to consultation on climate change strategy 31 January 2008 Biodiversity Comments: 1. This section is titled “Problem” but actually looks at both problems and opportunities. The reference to CO2 uptake by trees and forests is not relevant in London, firstly because of the tiny scale of any possible tree planting here and secondly because there is considerable doubt that forests in temperate latitudes actually function as net absorbers of carbon (unlike tropical forests, where they clearly do play an important role in CO2 uptake). Trees do have a role to play in mitigation in terms of shading buildings to which reduces cooling needs – but have a bigger role in adaptation to climate change, particularly in alleviating the urban heat island effect. 2. All the examples of benefits seem to refer to trees - the wider benefits of the natural environment for adaptation, including reducing runoff and the use of wetlands in sustainable urban drainage systems, could be mentioned. There are benefits of green roofs, both for mitigation (insulation) and adaptation (reducing run off), which could be mentioned. An additional aim could be to encourage new developments to incorporate green roofs, rather than including this only as a “what you can do” bullet point. 3. The problem is expressed as trees dying, but there will be far wider changes in the natural environment that will be threatened by drier summers 4. Aim B4 could add “and do this in ways which also benefit biodiversity” 5. Aim B5 should drop the reference to carbon uptake for the reasons discussed above. 6. Aim B5 and/or B7 could make a link with the Right Trees in a Changing Climate database produced by the Mayor and Forestry Commission http://www.right- trees.org.uk General comments 1. Figures are available for London in the London Climate Change Action Plan, which may be preferable to UK-wide figures. This includes the statistic that 38% of London‟s emissions (excluding aviation) is domestic, and of this 54% is from space heating and cooling. 2. This strategy does not appear to cover Climate change adaptation in depth. Will Climate change adaptation be covered in an additional strategy, so as to meet the forthcoming Local Performance Indicator on Climate Change Adaptation? It is recommended that either climate change adaptation be addressed in this strategy or in a subsequent strategy. For more information or to set up a meeting, please contact Alex Nickson – email@example.com. 3. Additional sources of information which may assist in the development of the strategy include Futerra‟s work on communication and climate change (http://www.futerra.co.uk/ or http://www.climatechallenge.gov.uk/) and the New Local Government Network‟s report “Carbon Footprints, Local Steps” which looks Response to consultation on climate change strategy 31 January 2008 at how local government can rise to the climate change challenge (http://www.nlgn.org.uk/public/press-releases/massive-carbon-reductions-could- be-made-decades-ahead-of-2050-target-according-to-nlgn-report/) Links Draft Further Alterations to the London Plan Examination in Public Panel Report September 2007: http://www.london.gov.uk/mayor/strategies/sds/eip-report07/index.jsp 3 I am disappointed that the document presented for public consultation is only a preliminary consideration of the issues. It lacks well defined targets specific to Merton and really has the broad aspirations and „helpful‟ suggestions one might expect in a magazine article. This is an important issue on which Merton has, in the past, developed some good initiatives. I hope that a coherent and closely defined strategy will be produced for consultation in the near future and that the present document will be viewed as the preliminary draft that it clearly is. 4 1. How easy did you find the Climate Change Strategy to understand? Quite easy to understand - However, there should be tangible targets in the strategy. - The Aims tables could be confusing, as the headings and the actions have the same labelling system. 2. Has the strategy addressed the issues that you think are important? Yes - However, the importance of Peak Oil should also be stated. 3. How did you feel about the actions contained in the strategy? Quite happy *Environmental Education: - I believe any business tendering for a Council contract should be required to present a sustainability policy and, where necessary, be encouraged to improve upon it. - Many high street businesses have 24-hour lighting. If they were encouraged to turn off their lights, etc when they were closed, this would not only reduce production of CO2 but Response to consultation on climate change strategy 31 January 2008 also send a message to those who visit the town centres after dark. The larger businesses might even be encouraged to take it nationwide. - Reference should be made to the Sustainable Communities Bill, and how people will be made aware of it's implications. *Transport: - "Maintain journeys made by sustainable transport at 40%" - if we already have a rate of 40%, this is very unambitious. If 40% is actually a future target, this needs to be made clearer. - There is currently a debate (and studies have been made) about the impact traffic lights have upon people's driving. One of the issues is increased production of CO2 from the constant acceleration/deceleration of vehicles, not to mention the energy/financial costs of maintaining them. I think there are 11 sets of traffic lights between Wimbledon Hill and the end of The Broadway, at least one of which serves no purpose (the pedestrian crossing between Morrisons and Woolworth). The Council should take a serious look at which traffic lights are really necessary - I believe Westminster Council is already addressing this issue. *Water: - At present, the drains on red routes are badly maintained and I believe this was instrumental in some of the flooding the borough experienced last summer. I've been led to believe this is due to restrictions imposed by TfL. If this is the case it should be addressed as a matter of urgency. *Procurement: - The Council should have a stated policy on the air-freighting of goods and support demands for products in general, and food specifically, to be labeled more clearly. 4. Are there any comments you would like to make about the climate change strategy? - To have any relevance, the climate change strategy must be at the heart of all Council business and every Council report should include an impact assessment. 5 My greatest criticism is the use the word 'small' in para 1.1 of the introduction. The emission of CO2 of course is caused by the accellerating use of fossil fuels, but these are rapidly depleting in the view of many experts. Colin Campbell of ASPO-ireland.org estimates a peak for all liquid fuels in 2010, and the latest issue of ASPO-usa.com warns that Russia may not be able to meet the gas demands of all its customers demands also by around 2010. I think it is imperative that the Council should not be so complacent about this aspect of the problem. I should like to see great urgency given to Aim P13 on page 9 to help focus the attention of the borough on these issues 6 Hello, Response to consultation on climate change strategy 31 January 2008 I have the following comments on the Draft Strategy: In general I am impressed that the Council has produced this document and appears to be taking climate change seriously. However I don't see a lot of evidence of any real commitment to spending at the level likely to be required to make any of these suggestions effective. That is my first major comment. On more specific points: p7 - Use energy more efficiently - This should be a major priority as improvements to current housing stock represent the greatest potential for reducing CO2 emissions. p9 - re Planning permission The granting of planning permission for alterations to current housing stock should incorporate requirements that: a. Suitable measures to increase energy efficiency have already been undertaken (eg installing solar panels, insulation etc) on the exisiting structure as well as incorporated into the new building, or b. the applicant will agree to implement measure to improve energy efficiency throughout the whole building as well as the new addition. The Council will then have to decide what are "suitable measures" p11 W6 - Community composting sites with waste going to parks/allotments? - this should be easy to set up if it is not already happening. W8 - this should be a high priority - could possibly be done with other boroughs to help with high set-up costs." p13 - GeeWhiz cars need special charging points. How many are there in Merton and could more be installed to encourage use of these vehicles? My additional comment is that Merton should join the movement and work towards becoming a Transition Town. 7 How easy did you find the Climate Change Strategy to understand? Very easy Has the strategy addressed the issues that you think are important? No. The strategy fails to address the issues of food production, distribution, consumption and waste. Climate change adaptation, retrofitting of domestic properties and in other areas, suggestions about which are made later in this response. Response to consultation on climate change strategy 31 January 2008 A section on food should be included along the lines of the following suggestion: Food The Problem Our consumption of food contributes more to our greenhouse gas emissions than any other human related activity. From the manufacture of fertilizers and pesticides through the machanisation of agriculture, the greenhouse gas emissions of the animals we eat, distribution, packaging, supermarkets and other shops, car journeys to and from shops and the waste resulting from the food we throw away. Helping local residents and organisations source locally produced organic food will contribute significantly to reducing the borough's carbon emissions. What we do now 1. Merton has 18 allotment sites which provide a unique outdoor leisure activity for residents living in the urban environment. (i'd be interested to know what these 18 sites equate to in terms of square meterage and what the current percentage uptake is - i've emailed danny lovelock) 2. A farmers market has been running in Wimbledon Park since May 2000. Located in a school playground, this market is very popular with the local community and is centrally situated in Wimbledon, serving people who live in both Wimbledon village and Wimbledon town. An additional market in Raynes Park has been planned for some time. 3. Residents are able to access commercial organic box schemes run by national companies who supply organic vegetables from UK farmers directly to the consumers' doors. Case Study Western Road Allotment Site - Local residents are working in partnership with the council to make unused allotment sites available to individuals, schools and community groups. Community food growing initiatives introduce residents of all ages to food growning as a fun and healthy partime which has many positive benefits including reducing greenhouse gas emissions associated with food. What we will do 1. Work with community groups and residents to acheive 100% use of all of the borough's allotment sites 2. Encourage residents to grow organic food in gardens, roofs and balconies and permit residents to grow food in unused green areas (such as verges) 3. Assist residents and community groups to set up and run community supported agriculture projects. 4. Plants fruiting trees in all green spaces in the borough and develop a system of harvesting by and for the local community 5. Promotion of health benefits of low meat/dairy diet as part of a healthy diet to reduce obeisity, diet related illnesses and greenhouse gas emissions. 6. Encourage residents to compost at home and collect biodegradable waste from those unable to compost for use in community composting schemes Response to consultation on climate change strategy 31 January 2008 What you can do 1. Eat less meat/dairy as part of a healthy balanced organic diet 2. Grow your own fruit and vegetables or buy organic vegetables from a local farmers market or box delivery scheme 3. Start composting at home How did you feel about the actions contained in the strategy? Quite unhappy The strategy needs specific, measurable, acheivable and targets set to a realistic timescale which reflects the urgency with which the challenges of climate change present us. The aims should be re-written as specific measurable targets aimed at meeting the overall aim to reduce the borough's carbon footprint by 3% per year and ultimately reduce carbon emissions in the borough by 80%. Climate change is a serious issue which requires significant action to be taken immediately. Anyone reading this strategy would not get this impression as the actions are not significant, immediate or concrete. Some other suggestions regarding the aims are detailed here: Chapter 3 Energy Establishing district CHP schemes in the borough is absolutely essential to reduce the borough's carbon footprint and provide energy security. There has already been a feasibility study into A chp plant as part of the mitcham regeneration scheme and another as part of the colliers wood area intensification plan so there are no excuses or not implementing these schemes Large scale wind turbines should be erected in in Morden park, Mitcham Common and Wimbledon Common and the council should immediately begin working with the stakeholders of these open spaces to ensure successful passage through the planning process. I welcome the move to encourage wood burning stoves using fuel from sustainably managed sources and the borough should implement a massive tree planting program in the borough of working trees which will provide food, materials and fuel for the borough. Chapter 4, Planning and Development Add the following action points: Ensure secure high-standard covered cycle parking is available at every workplace, station, public transport interchange, all entertainment and leisure facilities and shopping areas, as well as in all new homes. Response to consultation on climate change strategy 31 January 2008 Make planning permission necessary to pave over front gardens for car parking or any other reason. Define the size of large scale developments described in P3 Chapter 5, Waste The domestic recycling service should be enhanced and extended to included businesses. The borough should aim for zero waste and set a target date to acheive this. The borough should work with local communities to close the recycling loop. For example, food waste can be collected from flats, composted using an in-vessel system and then used in food growing programmes which can then supply fresh vegetables to the same households. Chapter 6, Transport Change aim T1 to Increase journeys made by sustainable transport to 60% Add the following action points: Make 20mph the standard speed limit on Merton's streets to reduce road danger and encourage cycling and walking. Deliver free on-road cycle training for Merton's children, subsidised training for adults and compulsory training for highway engineers and transport planners. Return one-way systems and streets to two-way operation and create advantages for cycling and walking, thus maximising route choice and minimising diversion. Pedestrians should be favoured over vehicular traffic and the centres of Wimbledon, Morden and Micham should be pedestrianised. Ensure the completion of the London Cycle Network Plus (LCN+) to a high standard with effective removal of all barriers as soon as possible Adopt ambitious targets to encourage walking and cycling to all major events in the borough, eg tennis, culminating in the first 'active spectator' Olympics in 2012. Work with TfL to create a Paris-style mass cycle hire scheme in the borough in time for Wimbledon Olympic tennis venue 2012. Work with police on a major campaign of action against cycle theft including a minimum 5% theft reduction target Work with police to enforce the law regarding vehicle engines left idling for long periods, eg at level crossings 'Countdown' timing indicators at all bus stops to make public transport more attractive. Action T9: bio-diesel will bring its own problems, and the commitment to continue to explore possibilities is too woolly and non-committal. We therefore suggest broader but firmer commitment: increase the proportion of council vehicles running on alternatives to fossil fuels to x% where "x" should represent both a significant step forwards from the present proportion AND significant proportion (at least half) of the total council vehicle Response to consultation on climate change strategy 31 January 2008 fleet. Electrification of public vehicles should be favoured ahead of biodiesel which is not a sustainable solution to public transport and council fleet requirements. Within the next 20 years, our entire transport system must be replaced by one that is powered completely by renewabe energy. The Centre for Alternative Technology envisages that battery electric vehicles will be the technology that enables this. Electric motors are 4-5 times more efficient than internal combustion engines, giving an immediate energy saving. They also have lighter motors and other components, producing lighter vehicles and supporting a virtuous cycle of efficiency improvements. A vehicle to grid system would allow users to sell the use of the onboard battery storage back to utility companies while they are not being used - helping to overcome some of the variability issues of renewable energy technologies. Under what you can do, add: Turn off your car engine when you are likely to be stationary for more than 30 seconds Chapter 7 - Water The council needs to ensure that the borough's victorian drainage is replaced to cope with the kind of deluges which we experienced last july and which flooded a number of properties in the borough, including mine. Rainwater harvesting, greywater recycling and flood prevention need to be seriously addressed as a matter of urgency. The economic and social cost to the borough of an interuption in water supply or of flooding is significant. Are there any other comments you would like to make about the climate change strategy? The climate change strategy should lead to the development of an energy decent plan for the borough detailing speciic actions to reduce the borough's energy dependence by 80%. an example of an energy decent plan is attached. The council should work with the local community to develop the plan and implement the actions. There should be a reference to the recently passed Sustainable Communities Act and how the borough plans to engage the community to use this legislation to help make our borough more sustainable. The citizens panel which has to be established by law could also be used to monitor progress on the climate change strategy. There should be a list of mechanisms by which the strategy can be implemented, for example the council's tendering process and procurement (EMAS), and examples of good practice from elsewhere. There should be a proper investigation of how many local businesses, particularly eco- businesses, would be ready and willing to provide support for initiatives and may already have conducted extensive research for themselves that could be adopted or may be already involved in projects that could be developed. Response to consultation on climate change strategy 31 January 2008 There should be reference to initiatives such as the eco-forums in schools involving the community AND service-providers AND contractors at once to promote ideas that can take hold quickly (and can be built into the curriculum meeting several of their own targets into the bargain). Projects already underway like Merton Parents already exist with ready-made networks – the Council simply has to pin-point a few localised projects and set target dates to achieve them. The document should explain what these organisations do and provide links to relevant websites to make this document a useful, living, ongoing tool to inspire people – people follow web-links. This could replace the case study idea which looks like tiny examples that cynics could see as a drop in the ocean (which they are not when taken together – this needs to reflect the huge movement that is happening on all this in the borough). And it should explain properly what things are e.g. eco-school – what does it mean in real terms that people can relate to? There should also be a requirement that all reports submitted to cabinets or committee meetings should contain a mandatory sustainability impact assessment and provide brief but clear training about what needs to be taken into account in writing these. So for example a report on criteria for allocating school places might have an adverse impact on pollution by increasing the number of cars delivering children to schools the other side of the borough – this should be included as an impact notwithstanding any recommendations of the report so that it is properly taken into consideration. 8 How easy did you find the Climate Change Strategy to understand? Quite easy to understand The numbering of the 'aims' and 'actions' is a little odd and possibly a bit confusing - there are both 'actions' and 'aims' with the same numbers - eg Aim EE1 to raise residents' awareness of climate change across the borough and action EE1 to support the Eco-schools programme and work with schools to develop other climate change practices and integrate climate into learning. Completing this form electronically, it's impossible to complete an answer to question 4. Has the strategy addressed the issues that you think are important? No This document is a fair attempt, but it feels a little lacklustre. - There seems to have been little effort made to get the views of residents, or to bring this strategy to their attention (odd given 'aim' EE1. Has the Council embarked on a leafleting, or email campaign or some public adverts to let people know? - The consultation is well under the 12 weeks consultation period that is stipulated by the Cabinet Office as being the optimum time, and over the Christmas holiday period too. - Furthermore, the document is missing that 'exciting idea' that would capture the public's imagination - for example, Islington's Climate Change Fund or becoming a plastic bag- Response to consultation on climate change strategy 31 January 2008 free zone. This would help generate interest and enthusiasm for the plan. For a strategy that "reaffirms our ambition" it's pretty dull! How did you feel about the actions contained in the strategy? Quite unhappy There are several issues where we feel there could be improvement in the strategy. - 2. Environmental awareness. See above comments in relation to efforts with regards to consultation and adopting something exciting and ambitious to capture people's attention and help bring the messages on climate change home. - 4. Planning. Aim P1. What are "appropriate developments"? Does this just mean new build? What about brownfield developments or large house conversions for example? Aim P9. How will Merton ensure that biodiversity is considered - does the Council have a biodiversity officer? - 5 Waste. Aims W1 & W2 (increase recycling/divert from landfill). There's nothing here about increasing kerbside recycling. Merton is still not meeting the 27% recycle or compost rates - there's nothing we can see to try to meet that target. What can be learned from boroughs with recycling rates in the 30s (%)? What about encouragng transport companies to install or allow recycling facilities Aim W3 to reduce amount of waste generated - at para 5.3 of the summary text, a trading standards department campaign to reduce excess packaging is mentioned, but where are the actions to ensure that it's effective or even to measure it? The commitment to "lobby government to set guidelines on excess packaging" seems just lip service. How and what's the plan?! What about lobbying local businesses, what about a plastic carrier bag free zone? - 6. Transport. Aim T1 (actions T1-T4) - Could cycle parks be considered at main stations in borough? Aim T2 (actions T5-T8) - Could (and does) the Council consider flexible working/working from home to reduce need of employees to travel? Aim T3 - public procurement is really important. What will Merton do about sustainable procurement? There seems to be some confusion about the Low Emission Zone - it's to do with air quality NOT climate change/carbon dioxide. For example, if one follows the suggested hyperlink, it states: “the Low Emission Zone (LEZ) is to improve air quality in London. London has the worst air pollution in the United Kingdom and amongst the worst in Europe, adversely affecting the health and quality of life of many Londoners. The Mayor of London has a legal obligation to take steps towards meeting national and European Union air quality objectives which are designed to protect human health.” It‟s therefore a bit worrying that the strategy says this is a “key element in the fight against climate change”. Response to consultation on climate change strategy 31 January 2008 - There's also no reference to the DfT's "Act on CO2" campaign - this is a great website, with info about better driving, best in class cars etc - 8. Biodiversity. Considering actions B1-B9, has Merton Council considered appointing a trained Biodiversity Officer. Such an officer could also help with action P9. Generally -The document seemingly lacks an Impact assessment: no financial information is available as to how much the Council's new initiatives are going to cost, or if they are going to save money: why? We should know where our council tax is going. The strategy seems a little short-sighted on national government plans, referring only briefly to the new planning bill and the energy bill etc, but what about the climate change bill and the effect that this may have on local issues? The new local transport bill? The TIF bids that Merton could investigate for local road-pricing schemes etc and also, has the PPS1 (climate change planning policy statement) been introduced yet? If not, that could have implications in terms of sustainable planning. (We would put this as an answer to question 4, but this document, as it is downloaded from Merton's website, is set up in such a way as to stop you from doiing so!) 9 You require replies to your consultation on Merton's Draft Climate Change Strategy by 30th January. There has not been sufficient time allowed for consultation with our local Residents Association or the John Innes Society, so I put forward the following comments as an individual. Q1. Quite difficult to understand - reason - so light weight and sketchy. Q2. No - other LA's CCS' are far more comprehensive. Q3. Quite unhappy - not enough aspects of the subject are covered; there is a lack of corporate co-ordination and a failure to take into account work already carried out by LBM. Q4. It is a great pity the draft plan has been put forward for public consultation at such an early stage in its formulation. It is clear from other LA's CCS's that a CCS should be a far reaching, major, Borough specific strategic planning document, covering all aspects of climate change from reduction in emissions through to dealing with extreme weather and changing economic conditions. Short of re-writing it, which it is not fair to ask the public to do, one cannot give meaningful comment on such a preliminary draft. One looks forward to further consultation when the draft has been progressed to a more comprehensive document. 10 All drains in the road-gutters should be cleaned and cleared. This used to be done on a regular basis years ago but I never see it done nowadays. This would help prevent flooding in the sudden heavy downpours, which we are to expect in the near future, due to climate change Response to consultation on climate change strategy 31 January 2008 Mothers of new babies should be encouraged to use the old-fashioned terry-towelling nappies with nappy-liners rather than creating mountains of 'disposable' nappies. We should go back to the old-fashioned method of householders having strong metal dustbins into which they put all their non-recyclable waste. The refuse collectors could empty the contents into their lorry and return the dustbin to the correct house. This would obviate the need for mountains of black refuse bags! Supermarkets should stop issuing free plastic carrier bags. Shoppers should be encouraged to take their own re-usable bags or baskets. Supermarkets should stop selling fancy products that require masses of plastic and cardboard packaging. People should be encouraged to eat fresh unpackaged vegetables [and to compost the peelings if they have a garden]. 11 How easy did you find the Climate Change Strategy to understand? Neither easy nor difficult. It was easy to understand only because it dealt in broad generalities and avoided any specific or practical issues. Has the strategy addressed the issues that you think are important? No. It does not seem to me to seriously address any of the issues it supposedly covers. There is little or no commitment to do anything specific - only advise, explore, encourage, examine the possibilities. It is not a strategy - it is only a promise to maybe start thinking about planning something. If I have to mention one neglected area, it is any mention of food. But the point is that all sorts of council policies - CPZs, education etc. all have an impact on the problem. If the council means to take the subject seriously it can't be relegated to some sort of vague adjunct to education/publicity. How did you feel about the actions contained in the strategy? Very unhappy. As explained above, very few actions were mentioned and these were very feeble. It seems that the council will only be taking action where forced by such external things as the landfill tax. And even then, the attitude seems to be to try to tick the boxes rather than follow the spirit of the law. To take one area - the council has the power to take some radical steps regarding sustainable transport - speed limits, road space allocation and so on, but will commit itself to nothing. Response to consultation on climate change strategy 31 January 2008 For another, there is nothing to stop the Council setting up a local CHP plant. The planning and finance are in place - such things have been common in other countries for years. But all Merton will promise to do is: 'explore the feasibility...if practical'. Are there any other comments you would like to make about the climate change strategy? The LGA Climate Commission report urged councils adopt 'demanding targets' , 'bold leadership', 'turn commitment into effective action', 'lock onto a more demanding trajectory'. They are right. What I think is evident from the scientific introduction is that Merton has grasped the simpler argument about climate change - that we are making things gradually warmer - but that's all. They think it is something we should probably do something about, but a slow serious of incremental changes will eventually turn things around. They seem to miss the point that nobody is bothered about the current gradual increase as such. They are bothered because after a certain point this slight rise will set off vast 'natural' events like the melting of the permafrost - once that happens, it really won't matter what Merton Council does as the matter will be out of our hands. If we want to prevent this, then we simply have to do some quite drastic things immediately. To put it another way, we are paddling our canoe towards the waterfall. We simply need to get out of the river! Just paddling a bit slower is not going to do it, let alone Merton's 'strategy' of thinking about maybe paddling slower in a few years time. 12 How easy did you find the climate change strategy to understand? Very easy to understand Has the strategy addressed the issues that you think are important? Yes How did you feel about the actions contained in the strategy? Neither happy nor unhappy. There are lots of good actions, but identifying more specific actions would support change more effectively: Environmental education and awareness raising - Retro-fit one existing (typical) home in each ward with insulation (including solid wall and floor insulation, as well as more widely used loft and cavity wall insulation etc.) and demonstrate the impact this has on the energy bills for that home. One demonstration in Germany saw annual energy bills cut from €700 to €100 for a 70 year old apartment. Energy - Encourage businesses to turn off lights and computers at night. Planning and Development - ensure that floor insulation is installed in every new property, along with cavity wall and loft insulation, low energy boiler etc. Floor insulation Response to consultation on climate change strategy 31 January 2008 doesn‟t cost much but can make a big impact as 15% of domestic space heat is lost through floors, according to the DCLG's Review of Sustainability of Existing Buildings. Transport - The need to encourage walking is recognised here and in other council documents. However, in practice, walking will only become the preferred choice if specific actions are taken to make pedestrians feel more important. These include widening pavements where there is heavy use, providing good quality walking surfaces and stopping vehicles from using pavements either by mounting them whilst travelling or by parking on them. How can parents encourage children to walk to school when even the pavements are not safe from cars? Besides causing an obstruction particularly for people with limited sight, wheelchairs and push chairs, parking on pavements givens the clear message that pedestrians are unimportant and walking is of low value. Currently, neither traffic wardens nor the police see parking on pavements as a problem and those I have spoken to are prepared to do very little about it. Failure in this area undermines efforts to encourage walking. The Council should liaise with traffic wardens and police to encourage them to stop vehicles parking on pavements. Install measures to slow down through traffic Use of bio-diesel is good, but only if it comes from a sustainable source. Biodiversity & the Natural Environment - Consider planting large trees in public open spaces. Small ornamentals may be easy to look after, but large trees support more bio- diversity, have a larger impact on micro-climate and provide more focus and character to an area. Procurement and Fair-trade - When looking at what shops and services are needed in a shopping centre, specify that food shops providing local/healthy/organic food are essential to improve health and/or reduce environmental impacts i.e. differentiate between different types of food shops. When making procurement decisions, the environmental impact of transport associated with each procurement choice should be part of the consideration. City Knowledge - Use thermal imaging to identify buildings leaking most energy. 13 I‟m not familiar with the planning law but I find there is a big omission in your climate change policy changes to existing buildings. A specific one is the issue of crossovers and the disappearance of front gardens. You are probably aware of the water management issues but a topic that is in general not mentioned in the issues related to crossovers is the disappearance of a lot of hedges and trees that results in a important reduction in bird populations. http://www.rhs.org.uk/gardeningmatters/frontgardens.asp I have nothing against crossovers: I got one myself recently, but I made sure no trees were removed and I left the bushes in place (but I had to remove one hedge). But most people have the front garden paved over completely. Part of your policy should be, as was done in a way with the Merton 10% rule, negotiate with the department of communities the ability to impose certain restrictions on Response to consultation on climate change strategy 31 January 2008 crossovers (http://www.merton.gov.uk/democratic_services/ds-agendas/ds- archived_reports/_000-5363/4887.pdf) in specific point 3.7. Climate change and biodiversity are allegedly high on the agenda of both Labour and the Conservatives. One can impose for instance that at least one tree needs to planted (AND maintained) and/or hedges or bushes, numbers related to the surface amount. Planning approval would only be granted for a loft conversion or an extension if a tree is planted (AND maintained) in the front garden etc. This would enable existing completely paved over front gardens to be „ripped open‟. There are enough guidelines freely available on water management issues related to crossovers. There are also guidelines on trees and foundations and I‟m sure there are people at the council who can advise on these issues. http://www.pavingexpert.com/geosheet.htm 14 General The draft strategy does not contain enough SMART targets - Specific, Measurable, Achievable, Realistic, Timed. Our response therefore makes a number of suggestions to introduce such an approach. Our response draws on our current mayoral manifesto, agreed at LCC level, and published here. Chapter 4, Planning and Development Add the following action points: Ensure secure high-standard cycle parking is available at every workplace, school, station, all entertainment and leisure facilities and shopping areas, as well as in all new homes. Make planning permission necessary to pave over front gardens for car parking Chapter 6, Transport Change aim T1 to Increase journeys made by sustainable transport to 60% Add the following action points: Make 20mph the standard speed limit on Merton's streets to reduce road danger and encourage cycling and walking. Deliver free on-road cycle training for Merton's children, subsidised training for adults and compulsory training for highway engineers and transport planners. Return one-way systems and streets to two-way operation and create advantages for cycling and walking, thus maximising route choice and minimising diversion. Ensure the completion of the London Cycle Network Plus (LCN+) to a high standard with effective removal of all barriers Adopt ambitious targets to encourage walking and cycling to all major events in the borough, eg tennis, culminating in the first 'active spectator' Olympics in 2012. Response to consultation on climate change strategy 31 January 2008 Work with TfL to create a Paris-style mass cycle hire scheme in the borough in time for Wimbledon Olympic tennis venue 2012. Work with police on a major campaign of action against cycle theft including a minimum 5% theft reduction target Work with police to enforce the law regarding vehicle engines left idling for long periods, eg at level crossings Action T9: Bio-diesel will bring its own problems, and the commitment to continue to explore possibilities is too woolly and non-committal. We therefore suggest broader but firmer commitment: increase the proportion of council vehicles running on alternatives to fossil fuels to x% where "x" should represent both a significant step forwards from the present proportion AND significant proportion (at least half) of the total council vehicle fleet. Under What you can do, add: Turn off your car engine when you are likely to be stationary for more than 30 seconds 15 How easy did you find the Climate Change Strategy to understand? Very easy. Thought it was informative and had relevant case studies. Has the strategy addressed the issues that you think are important? Yes and No. Thought it could be stronger on the targets it has for everyone to achieve. How did you feel about the actions contained in the strategy? Thought the actions were measureable on the whole but some quite cague and could be stronger. For example, if driving more slowly to reduce CO2 emissions from cars – why not bring in more 20 MPH limits in the borough? Do parking permits incentives low emission cars etc? Are there any other comments you would like to make about the climate change strategy? To help encourage businesses to be greener the system on the Isle of Wight worked very well – the green island awards. They audited your business and you got a Bronze, Silver or Gold award depending on your green practices – it has encouraged companies to be greener and shared best practice. 16 How easy did you find the Climate Change Strategy to understand? Very easy Has the strategy addressed the issues that you think are important? Yes Response to consultation on climate change strategy 31 January 2008 How did you feel about the actions contained in the strategy? Very Happy Are there any other comments you would like to make about the climate change strategy? 1. W4 quote „Explore possibilities of working with third sector organisations to increase reuse and recycling rates across the borough‟. This is help up because Merton will not empty our recycled bin without charge. They say only ONE free empty (and that‟s our normal refuse). Charities and not-for-profit organisations need a second free empty. 2. I strongly agree that extending Tramlink will build on the improvements to reduce traffic in Merton. 3. Very few mentions of third sector in the 23-page document. Merton must plan to let third sector help them more… at present we are treated like businesses and we cannot afford to pay like businesses can. A different arrangement for charities and not-for-profit organisations is need so we can get co-operation to do what we can do – recycle.