The consultation draft of the region’s action plan
on climate change has been developed with excellent input from a number of
regional partner organisations and experts, but it will only be truly effective
if it is owned across the region by the broad range of stakeholders that will
be pivotal in delivering real action on climate change.
Please take the time to read the action plan and
then give us your feedback and further suggestions using this form. If we work
together, the Northwest can lead the way in tackling climate change.
Consultation opens: 5
June 2006
Consultation closes:
5 September 2006
Final action plan
published: 9 November 2006
For a hard copy of the full Action Plan or for
further information on the consultation process, please email climate.change@nwda.co.uk.
For any further information visit www.nwda.co.uk/climatechange or
contact Mark Atherton on (01925 400283).
YOUR DETAILS
Please do not
feel that you have to answer all questions. Limiting your answers to the KEY
issues for you or your organisation/group will assist in the analysis of
responses. If you require more space for your comments please use the
Additional Comments section at the end of this document.
1. VISION - ‘A low carbon
and well adapted Northwest by 2020’
1a) Do you agree with the Vision above? Yes
No
If
Yes, please go to Q2
1b)
If no, do you think the Vision is Too ambitious Not ambitious enough
1c)
Do you have any additional comments on the Vision?
There
is no recognition that achieving the vision would make sacrificial demands on
people and organisations.
The
Draft is far too aspirational and lacking in specific proposals.
There
is evidence of woolly thinking and ignorance of scientific terminology - e.g.
the meaning of 'sequestration' - see our comments on sections 59 and 60, below.
We
feel that the value systems underlying many of the actions and purposes are
wrong - the environment is the primary concern and questions of funding and
attracting business secondary.
One
of our main criticisms with the document and hence with the vision is that it
is written from an urban perspective and largely ignores specifically rural
problems and community concerns of the countryside.
2. MEASURES, INDICATORS AND
TARGETS
2a) Do you mostly agree with the proposed measures,
indicators and targets on Page 3 of the consultation document? Yes No
If
Yes, please go to Q2c
2b)
Do you have any comments on the measures, indicators and targets?
We
were generally concerned that these were often couched in business and/or
financial terms and not necessarily what was best for the environment.
We often had great
difficulty in interpreting the 'action' descriptions of the sections, and the
actions and purposes were sometimes not consistent.
We have identified several
actions where we believe it would be impossible or meaningless to measure their
effectiveness.
M1: What is the base line for the 20% increase in energy savings
- not clear what it applies to. Need to
distinguish between economic activity and energy use. How is the proposed
expansion of regional airports such as Manchester, Liverpool and Carlisle
consistent with reduced energy use, particularly when so many of the planned
flights are 'short-haul', where the energy use per passenger mile is greatest?
M2: When you say 'low carbon
sources' this ought to include nuclear power, although we doubt whether you
were thinking of this. On page 2 you say that Heysham (nuclear) power station
produces 19 TWh per annum. Without replacement or licence extension Heysham
will have closed by or around 2020, and the M2 2020 target includes only 7.93
TWh from renewable sources - this just emphasises the significant contribution
nuclear power plays in electricity production with zero carbon emissions.
M5: Our main query here was
how these actions are to be assessed.
The measure should distinguish between rural and urban situations. People are
far more dependent on the car in the former, hence different measures are
needed. Manchester has recently agreed an extension to its tram system, for
example; this type of solution is clearly not applicable to rural areas. The
document makes no mention of freight transport, and what measures you will take
to transfer more goods from the roads to rail or canal - is The Manchester Ship
Canal actually used, by the way? We have commented on air transport in MI
above.
The underlying moral stance
should be that public transport is a service not a business
2c) Are there any other measures, indicators and
targets that should be included?
3. ACTION AREA A:
Building awareness, evidence and co-ordinated delivery
a) Please check the boxes in the table below to tell
us if you agree with the primary actions identified on pages 5- 7 of the
consultation document. Please use the Comments column to inform us of your
views.
3b) Do you have any comments on
any of the secondary actions under Action Area A?
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ACTION REF |
Comment |
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3 |
Specifically relevant to transport issues - rail. The NWDA needs to work with the Train Operating Companies (TOCs) and Network Rail |
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4 |
With regard to the purpose of 4, reduction in energy use may not reduce costs. The action and purpose are not compatible. There is some evidence that energy savings or cost reductions in some areas only lead to an increase in others. |
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5 |
Is 'best value for money' the real criterion here? An example might be the delivery of rural services, such as buses and trains. The final word should not be with the accountants! |
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8 |
This presupposes looking at regional policy in isolation. Security of supply is a national issue, eg the national grid, and choosing those means of energy or electricity supply that are least subject to interruption from political, geographic or environmental factors - nuclear power is the obvious example. |
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12, 15-19 |
12: Poor wording, also there is a mismatch between
action and purpose - what if the targets are not viable? Will
you reduce the targets to make sure you do achieve them? 15-19 as a whole: we are concerned about the bureaurocracy involved
- little practical outcome could
follow and the processes could
involve great waste of energy and resources. 16: Action is difficult to follow as described, clarify meaning of
'regional energy mapping'; mismatch between action and purpose. 17: Ignores those aspects of economic growth that are unsustainable
irrespective of carbon emissions. The purpose is inconsistent with
airport development aspirations see
above. 19: Rural areas, especially Cumbria, are greatly dependent on
agriculture and tourism. What measures are being proposed to raise awareness
of climate change on these businesses? For example the effect of rainfall and
climate change on hill farming; tourism may be affected by changes in weather
patterns too. This is another example where the document is apparently
urban-cented and the thinking too limited, although we are pleased that tourism and griculture are mentioned
in the preamble on page 12. |
3c) Would you / your organisation
agree to be involved in delivering any of the primary or secondary actions? If
so, please indicate whether this would be in the form of a lead or support role
and comment on the role you could play.
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ACTION REF |
Lead (L) or Support (S) Role |
Please comment on the role you could play |
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Area A |
S |
See Faith Community Comments at the end |
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3d) Are
there any other priority actions that should be included under Action Area A?
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Purpose |
Lead Organisation |
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4. ACTION AREA B:
Increasing the region’s energy efficiency
4a) Please check the boxes in the table below to
tell us if you agree with the primary actions identified on pages 8-10 of the
consultation document. Please use the Comments column to inform us of your
views.
Ref.
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Primary Action
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Agree Y/N |
Comments |
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20 |
Improve
awareness of energy efficiency amongst householders, landlords and tenants
and encourage them to take energy saving actions. |
Yes No |
The purpose should not be to maximise uptake
of funding, but to reduce energy use and achieve the Government's CO2
targets. Another example of mismatch between purpose and action. The purpose
is symptomatic of false value systems. |
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26 |
Set
minimum standards that go beyond building regulations for energy use in all
public sector funded new and refurbished buildings. |
Yes No |
Especially in new buildings. Please explain
what 'go beyond building regulations'
means. If valid such standards should apply to all new and refurbished
development, not just the public sector. |
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30 |
Deliver
a ‘step change’ in the effectiveness of regional business support
organisations to prioritise and better co-ordinate energy efficiency advice. |
Yes No |
Many businesses will have already built in
these energy efficiency measures from previous experience or advice. |
4b) Do you have any comments on
the secondary actions under Action Area B?
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ACTION REF. |
Comment |
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21-25 |
These do not sufficiently distinguish between new and older
properties, owner-occupied, rented properties and second homes, i.e. between richer and poorer people. |
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21 |
This action needs to be stronger, so that planning consent for new
housing should be refused unless it incorporates agreed energy efficiency
etc. What about the affordability of energy efficiency/saving measures for
poorer people? There is a link here with Item 23. |
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23 |
Energy
saving is far easier for better-off people since thay can afford to install
solar panels, insulation etc, and are more likely than pooer people to be
able to deal with applications for grants, etc. Will Council Taxes be raised on more expensive properties so
that help can be made available for those in poorer circumstances? Does
'landlords' include housing association? |
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27-29, 31-37 |
27: what
'strategic plans' are meant here; what criteria will be used to determine
priority if cost savings conflict with emissions reduction as they are bound
to. Timescale? 29: what is meant by 'support'
- financial or 'mere encouragement'? High efficiency housing tends to be the
province of the rich as already mentioned in 23 above. This and eco-centres
should target social and rented housing, not just the rich. 34: What does 'capacity' mean
in this context? 33: Delete 'possibly' in the purposes. 'Businesses' should pay for
it. 36, 37: Existing business support associations
should be better resourced/fiananced. There is also a case for supporting and
extending the work of energy advice centres open to the public. |
4c) Would you / your organisation
agree to be involved in delivering any of the primary or secondary actions? If
so, please indicate whether this would be in the form of a lead or support role
and comment on the role you could play.
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ACTION REF |
Lead (L) or Support (S) Role |
Please comment on the role you could play |
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Area B |
S |
See Faith Community Comments at the end |
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4d) Are
there any other priority actions that should be included under Action Area D?
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Suggested Action |
Purpose |
Lead Organisation |
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5. ACTION AREA C:
Adapting to the impacts of climate change
5a) Please check the boxes in the table below to
tell us if you agree with the primary actions identified on pages 11-12 of the
consultation document. Please use the Comments column to inform us of your
views.
Ref.
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Primary Action
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Agree Y/N |
Comments |
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38 |
Introduce
climate proofing criteria attached to all public sector capital spend through
grant conditions. |
Yes No |
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47 |
Undertake
a climate impact assessment of key regional business sectors to identify
areas for growth resulting from the impacts and mitigation of climate change. |
Yes No |
We are pleased that tourism and agriculture
are mentioned here. Other areas should be identified, though. |
5b) Do you have any comments on
the secondary actions under Action Area C?
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ACTION REF |
Comment |
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50 |
Higher added
value products is not the real purpose, it is how to deal with and adapt to
climate change. For example, 'biomass' is not a higher value product, but it
may be desirable to grow it as an energy source. It will not encourage
tourism, though and will not be suitable for hill farm areas. Will wetter winters and drier summers make hill and upland farms even more marginal? There is a need to relate 50 to conserving the best agricultural land with possible flood defence and managed retreat implications. |
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51 |
Some derelict land has social and environmental value in its current condition, e.g. for wild-life and activities such as trail biking, 4WD off-roading, etc. |
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52 |
Does 'capacity' here mean the capacity of the environment as well as the capacity in MW of electricity generation? |
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53 |
It is good to emphasise the advantages, but a 'low carbon lifestyle' may not be all positive in its impact. The necessary life-style changes may well create stress and inconvenience to those least able to tolerate them. Low carbon may also mean less energy available and/or more expensive energy and a disproportionate impact on the poor. Again this section brings out the middle-class perspective and bias of the whole approach in the document. |
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5c) Would you / your organisation agree to be involved in delivering any of the primary or secondary actions? If so, please indicate whether this would be in the form of a lead or support role and comment on the role you could play.
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ACTION REF |
Lead (L) or Support (S) Role |
Please comment on the role you could play |
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Area C |
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See Faith Community Comments at the end |
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5d) Are
there any other priority actions that should be included under Action Area C?
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Suggested
Action |
Purpose |
Lead
Organisation |
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6. ACTION AREA D:
Securing major carbon emissions at source
6a) Please check the boxes in the table below to
tell us if you agree with the primary actions identified on pages 13-15 of the
consultation document. Please use the Comments column to inform us of your
views.
Ref.
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Primary Action
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Agree Y/N |
Comments |
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54 |
Adopt
a more co-ordinated approach to the promotion of travel plans through a roll
out of best practice and encouraging organisations to make transport
decisions on available sustainable options. |
Yes No |
In
the preamble to this section emissions may be unavoidable from air
travel, but as we have emphsisied elsewhere in our response, air travel
itself, especially short-haul, should
be discouraged as a means of economic growth. The term 'travel plan' is obviously jagon for something, but we
weren't clear for what. In summary 54 is pure aspiration and no substance. |
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59 |
Investigate
the potential for and, if appropriate, facilitate carbon capture and storage
mechanisms. |
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61 |
Stimulate
an expansion of existing low carbon Research and Development schemes and
other business funding streams. |
Yes No |
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6b) Do you have any comments on
the secondary actions under Action Area D?
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ACTION REF |
Comment |
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59, 60 |
59: (couldn't write in the box). You don't understand the terminology associated with this concept. Storage, sequestration and sinks all have separate meanings. Sequestration is conversion of CO2 into a stable, non-volatile form, storage is what it says. In 60, sequestration should be 'sink'. Soil is not a sink for CO2. |
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61-67 |
These are concerned with bringing more money and business into the region. Although we would not consider finance to be the highest priority, we would welcome industrial/manufacturing development that benefitted the depressed economy of Cumbria, a county which we fear could be neglected as part of the NorthWest Region. |
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62 |
How does this relate to technology transfer to poorer countries so that they can develop their own capacity at lower cost? |
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65, 67 |
Agree with
purpose 65 as long as this refers to a comprehensive range of costs and
benefits, not just a balancing of
economic growth and cost reduction. 67: We are not convinced that energy and resources devoted to competitions achieves the best all-round environmental value |
6c) Would you / your organisation
agree to be involved in delivering any of the primary or secondary actions? If
so, please indicate whether this would be in the form of a lead or support role
and comment on the role you could play.
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ACTION REF |
Lead (L) or Support (S) Role |
Please comment on the role you could play |
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Area D |
S |
See Faith Community Comments at the end |
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6d) Are
there any other priority actions that you feel should be included under Action
Area D?
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Suggested Action |
Purpose |
Lead Organisation |
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7. ACTION AREA E:
Increasing low
carbon energy supplies
7a) Please check the boxes in the table below to
tell us if you agree with the primary actions identified on pages 15-17 of the
consultation document. Please use the Comments column to inform us of your
views.
Ref.
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Primary Action
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Agree Y/N |
Comments / Additional
activities |
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68 |
Encourage
public sector organisations to require a minimum of 10% renewable energy in
new developments or refurbishments rising to 15% from 2010. |
Yes No |
Why such limited targets? Is this 10% from
the grid or 10% from installations at point- of-use, or both? Why not encourage
non-public sector organisations as well? |
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73 |
Develop
large-scale low carbon supply schemes, conduct feasibility and impact
assessments for all potential future projects and work to increase good
practice in community engagement. |
Yes No |
Need to distinguish between low carbon and
renewable supplies, the former should include nuclear. |
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78 |
Increase
the regional availability of funding for R&D and demonstration projects
on low carbon energy supply sources and implement if feasible. |
Yes No |
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7b) Do you have any comments on
the secondary actions under Action Area E?
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ACTION REF |
Comment |
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69 |
One reason for caution under item 69 may be the cost of adapting the regional and local distribution network to cope with multiple, variable sources of embedded generation. It could also effect the ‘balancing’ of the national grid, and hence the economics of major generating stations which might have to run at less than optimum capacity more often, if microgeneration becomes very widespread. |
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70 |
See earlier reservations about biomass. Clarify what counts as 'a large scheme for microgeneration' Can sufficient biomass for micro-generation be sourced locally? [say within 20 mile radius?] How much land would be needed to produce the biomass crop for this size of plant? |
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73-77 |
Again, why
in the preamble on page 16 is there no mention of nuclear power as a low
carbon macrogeneration technology? We would have thought, whether you agree
with nuclear or not, an industry that currently employs 15,000 people in the
region directly, and has benefits for thousands of others, at least deserves
a mention in the document at this
stage. We note that in purpose 77 you
advocate increasing the demand for low carbon sourced electricity. The impression given by this section
is that it is grossly anti-social, if
not actually sinful, to oppose applications for wind and tidal generation!
Who decides if 'local resistance is unfounded'? We ought to emphasise that we are not against renewable low carbon macro-generation, but we think that it should form a realistic fraction of the energy 'mix'. |
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7c) Would you / your organisation
agree to be involved in delivering any of the primary or secondary actions? If
so, please indicate whether this would be in the form of a lead or support role
and comment on the role you could play.
|
ACTION REF |
Lead (L) or Support (S) Role |
Please comment on the role you could play |
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Area E |
S |
See Faith Community Comments at the end |
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7d) Are
there any other priority actions that you feel should be included under Action
Area E?
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Suggested Action |
Purpose |
Lead Organisation |
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8. additional comments
8a) Please
rank the Top 10 Actions in order of priority (1=Highest, 10 = Lowest)
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Priority |
Action Ref |
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1 |
See notes in the Covering email |
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2 |
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3 |
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4 |
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5 |
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6 |
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7 |
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8 |
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9 |
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10 |
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Please use the space below to make any other
comments that you wish. Continue on a separate sheet if necessary.
ACTION AREA 'B': We don't
understand the derivation of 'up to 13 units saved' in para 1 of this section;
is it a misprint? Energy losses in generation resulting from thermal efficiency
of boilers, say 40% and from grid transmission losses ( a few %) can amount to
no more than 50%. A factor of 13 is much too high.
GENERAL
We were pleased that the NWDA has
had the idea of involving people in climate change matters, and we hope that
the consultation exercise arises from a genuine concern for the environment and
is not just political correctness.
Overall we noted a lack of hard
fact in the actions, that on occasion there were mismatches between action and
purpose, and that it would be very difficult to find indicators to assess some
of the actions.
We noted that there was no box
for Faith Communities on page 1 of the reply form and we are glad to hear that
this will be rectified in future publications.
We believe that the faith
communities do have an important role to play in matters relating to energy use
and the environment. Although we have not made specific suggestions in the
spaces provided above for ways in which our organisation (CTiC)could be
involved, we offer the following observations and comments which we hope will
be helpful:
a) Faith Communities are
committed to protect the most
vulnerable in society and to show concern for ones neighbour, whether next door
or in another country. Engaging with energy and environmental topics is an
important part of this commitment.
b)CTiC has member churches in
every community, both rural and urban, and these are being encouraged to take
environmental issues seriously, both at church community and individual lifestyle
level;
c) Some churches are involved
with the Eco-Congregation Movement, through which environment and energy matters are given prominence in all areas
of their life and work: worship, finance, children's work, community involvement and management of buildings, grounds and
gardens.
d) The Eco-Congregation model has
been used as the basis for 'The Cumbria Sustainable Communities Project' which
is now operating successfully in six pilot locations throughout the County.
CTiC initiated this Project by working with Voluntary Action Cumbria, LA21
Groups, Parish Councils and Energy Advisory Groups.
e) The CTiC Energy SubGroup would
like to be kept informed of the progress of this initiative and would be glad
to work with the NWDA to promote awareness of local environmental/energy
matters where appropriate.
Thank
you for completing this form. All forms should be returned either
electronically to climate.change@nwda.co.uk
or by post by no later than 5 September
2006 to:
Mark Atherton
Head of Environment
and Sustainable Development
Northwest Regional Development
Agency
Renaissance House
P.O. Box 37
Centre Park
Warrington WA1 1XB
