Responses to City of York “Our Big Conversation” consultation on the draft 10 year Strategies

woman holding a poster that says "demand a carbon neutral York" in St Helen's Square

Climate Change Strategy

This strategy is a welcome step forwards in creating a framework for the whole city to sign up to as we work together towards the urgent task of tackling climate change. It offers a basic structure around which to build and implement the wide range of bold actions we need to tackle the Climate Emergency. It could also help the city to deliver the ‘co-benefits’ of climate action including reducing fuel poverty and energy bills, creating safer more vibrant local neighbourhoods and providing new good quality green jobs.

We are pleased that the document has been produced, and we support many of the proposed actions, but we do believe there are some significant ways in which it needs to be improved. These are set out below.

The ambition for emissions reduction

The climate emergency motion put forward by the Green Party and approved almost unanimously by Full Council in 2019 called for York to be carbon neutral by 2030 ( in line with strong scientific signals from the IPCC) and it is crucial that we all keep in mind that this is an Emergency! The motion explicitly mentions scope 1 (i.e. directly produced emissions such as from gas boilers or from petrol/diesel vehicles), scope 2 (i.e. indirect emissions for example using electricity that has been generated from fossil fuels) & scope 3 emissions (i.e. emissions that arise from producing the goods and services that we use – including manufacturing electric vehicles, building infrastructure, growing food or transporting it to our shops). If we want to protect York residents from worsening future flooding and heatwaves of the kind experienced in July 2022, we have to have bold targets and put reducing carbon emissions at the centre of everything that we do.

Following pressure from Green Councillors, some critical actions have been identified and built into this draft strategy document, and these are very welcome. We are also pleased to see a commitment for the council itself, as an organisation, to being net zero by 2030, but it would be valuable if the text could make explicit that net zero in this case includes consideration of scope 1, 2 and scope 3 emissions.

It also appears that some parts of the council and perhaps some councillors are not yet fully committed to achieving emissions reductions that are in line with the council’s declared policy and compatible with the science. This is apparent in the gaps between the goals stated in the Climate Emergency motion, that was adopted almost unanimously, for the city to reach net zero by 2030, the Paris Aligned Pathway for net zero by 2050, and the document’s Projected Emissions Reduction Pathway presented in figure 4. This Projected pathway, apparently “includes the interventions that are achievable under existing conditions”, but the document does not explain what criteria have been used to determine what is or is not achievable under existing conditions.

What can be achieved

Whilst we are concerned that the council’s strategy should set out ambitious targets, it is also imperative that the council and the city take action quickly to reduce emissions. Therefore, we would rather encourage the council to use every power and influence at its disposal, including its regulatory and convening powers as the only elected local organisation, to work with others to bring about the changes that are needed (see further comments below).

Emissions and the council’s control

The draft strategy identifies that CYC is directly responsible for only 4% of the direct emissions from the city as a whole and commits to reducing those to zero by 2030. It would be helpful to include a clear statement in relation to scope 3 emissions arising from CYC’s activities in the context of this commitment.

We welcome this commitment and the identification of the various further spheres of influence that the council can exert on the remaining city emissions on page 8 of the strategy. We believe that some ‘re-framing’ of the ‘stronger’, ‘medium’ and ‘weaker’ categories could improve and strengthen the strategy. Whilst it is certainly true that the council cannot do this alone, it does have significant powers and influence.

More detailed work is needed through the strategy and future action plans on how to exert influence through council procurement policies (and to actively encourage city partners to do the same) and more detail is needed on how the council’s regulatory powers, including planning powers, can help to achieve the city’s zero carbon ambitions. 

With respect to the ‘medium and ‘weaker’ categories we would like to see more focus articulated in the strategy on the council’s convening powers as the democratically elected lead organisation in the city. We welcome the work that the council has been doing to re-establish city-wide partnerships during and following Covid including the City Leaders Group and the work that group has been doing on the new Economic and Skills strategies, plus the over-arching city wide 10 Year Plan for York that is currently in production.

The strategy needs to better articulate how the council will work through all these partnership forums to actively encourage and facilitate the delivery of the Climate Change Strategy. This should include expanding the work of the York Climate Commission to become a more transparent and publicly accountable organisation, adding to its membership, establishing working groups, reaching out to the voluntary, community and social enterprise sectors as well businesses large and small and organising more public events including some Citizen’s Assemblies.

More also needs to be done to reach out to residents with sustained information-sharing that not only explains the urgency of acting on climate change but inspires individuals and communities with examples of how climate solutions can improve every day life for everyone – whether through cheaper fuel bills, cleaner air or more green spaces.

The strategy also needs to reference the council’s own Action Plan for reducing its own direct emissions to zero by 2030, with clear annual milestones.

Actions in specific sectors

Establishing the level of ambition and the pathways to 2030 is a very important part of this strategy that should enable us to plan for the longer term. However, the urgency of the situation and the scale of the challenge does mean that what matters most is the actions we take as a city over the next 5 years. On that basis we welcome the identification of the sectors where most action is needed – buildings (domestic and non-domestic) and transport.

We welcome the progress that is already being made in these areas but we believe it is crucial that the public can see a more detailed Action Plan setting out not just what is happening already but also how the city will progress the actions needed to deliver the pathway to zero carbon over the next five years and beyond. Throughout the document there is a need to demonstrate the relationships between the top level objectives and more specific, measurable targets for 2030, which can then be associated with specific actions (such as the action that 29,100 homes will benefit from a deep retrofit).

Engagement

The objectives described in the ‘Engagement’ section are difficult to disagree with, however, a strategic response should be identifying key partners from the private, public and third sector organisations as well as media partners who could become more active players in delivering the vision of zero carbon York.

Domestic and non-Domestic Buildings

We support the general objectives around buildings, focusing on improving the energy efficiency of existing buildings with an emphasis on ‘fabric first’, ensuring that new build adopts high standards and switching from gas to renewable energy heating systems. A whole house approach to energy efficiency should be included in the objectives. We are not sure why point 2.3 talks about ‘making gas boilers more efficient’? We need to move away from gas altogether. Whilst we recognise that some gas boilers may have to be fitted in the short term as retrofit programmes are still getting underway, the priority has to be stopping the use of gas as quickly as possible.

Whilst there is mention of reducing energy demand in the strategy this needs to be strengthened to make this a key objective alongside the others listed. It is crucial to ‘keeping the lights on’ that we reduce the overall amount of energy we need to use to keep our homes comfortable.

This section is supported by some specific figures about where we need to be in 2030 including a 56% reduction in emissions from domestic buildings and a 37% reduction in emissions from nondomestic buildings. There are also figures given for the number of homes to receive a medium retrofit and the number to receive a deep retrofit in order to achieve targets, but there is no information about how these figures have been arrived at. In particular, it is unusual to note such a small number of homes receiving ‘medium’ retrofit, whilst about one third of homes in York are expected to benefit from deep retrofit within the next eight years. This does raise questions about what will happen in the remaining two thirds of homes. These figures need to be better explained in the strategy and supporting documents.  Specific Action Plans for both domestic and non-domestic buildings are needed.  We welcome the fact that a draft retrofit action plan for domestic buildings is being progressed. The council also needs to produce an action plan for non-domestic buildings,  in collaboration with business and other city partners.

Transport

We welcome many of the objectives set out in the transport section, particularly the clarity on the need to reduce overall levels of car usage. However, the targets are too weak to deliver the needed step change towards public transport, active travel and 20 min neighbourhoods. We believe some objectives are missing, others need to be clarified and all objectives need to be set more clearly in a strategic context. This clearer strategic approach needs to be mirrored in anyforthcoming Transport Strategy or Local Transport Plan which must have carbon reduction and therefore a significant modal shift target (from car travel to sustainable modes) at its heart. Quantifiable carbon reductions will be a requirement of LTP4 to secure government infrastructure investment from 2024. All the indications from efforts to implement  the Active Travel programme demonstrate that higher funding is required than has previously been anticipated to secure the quality of infrastructure needed to achieve modal shift.

The way that figures presented on pages 20 and 21 have been derived, and  how much each action contributes towards achieving zero carbon by 2030 needs to be more clearly explained.

Objectives

Under ‘Objectives’ we have the following specific comments:

It is not clear what ‘Travel shorter distances’ means in the context of carbon reduction. As the table on page 20 indicates over half of commutes to work are 3 miles or less and two-thirds are less than 6 miles. These short journeys are significant and disproportionate contributors to carbon emissions and poor air quality. Simply reducing overall miles travelled might leave all these shorter journeys (often in more densely residential areas) still continuing by car. Therefore actions are needed not only to reduce overall annual distances travelled by car, but also to reduce the proportions of short journeys using private cars.

This links to the idea in many other cities’ carbon reduction strategies of promoting “20 minute neighbourhoods” where mixed communities and healthy streets enable many facilities to be reached either on foot or by bike within 20 minutes. Enabling modal shifts to happen, in conjunction with other measures to reduce demand for longer journeys and encourage more sustainable modes should be the overriding aim, in keeping with York’s already established transport hierarchy.

Taking the above into account the first 3 objectives should focus on:

Reducing the need to travel by supporting home working, mixed communities (where employment and other facilities are close to where people live) and ‘20 minute neighbourhoods’;

Reducing overall levels of car usage, through modal shifts to more sustainable modes including walking, cycling and escooter/ ebike, public transport and where appropriate increased car sharing;

Ensuring that all policy objectives take account of the transport hierarchy putting into practice the principle that pedestrians, disabled people and cyclists should be at the top of the hierarchy, followed by public transport. This needs to be more strongly reflected in residential areas through more direct, safe attractive walking and cycling provision, crossings, 20mph limit etc.

Commitment to these three objectives should precede the current objective 3.3 of encouraging the switch to electric vehicles. It is important that we do switch to electric vehicles to reduce scope 1 and 2 emissions, but it must be accompanied by traffic reduction, reductions in the embodied carbon (scope 3 emissions) and use of finite resources such as lithium involved in EV manufacture and use, whilst also reducing air pollution and making our streets and neighbourhoods safer and healthier for everyone.

Tackling freight emissions is obviously also very important and has significant implications for cities like York impacting not just on carbon emissions but also on air quality and the fabric of our city centres. However, the strategy should also make it clear what proportion of overall road traffic, pollution and carbon emissions are accounted for by freight emissions in York.

Where we need to be in 2030

The list of targets in the table under this heading needs to be substantially improved in keeping with the above. There should also be clarifications of the contributions that each change will make to the overall emissions reductions. Specifically, we note this issues below.

The reduction in miles travelled needs to be far more specific as to what it actually means, as above.

The target figure for a reduction in ‘road transport’ use needs to be explained and reassessed. 3% is a very low level of reduction and surely unlikely to meet carbon reduction targets. The definition of ‘road traffic’ is also not clear – are not buses ‘road traffic’?

The percentage increase in active travel of 33% seems far too small, given the need for a major modal shift, particularly for short journeys. Also, the document gives no indication of what that 33% figure actually refers to. Does it represent distances travelled (e.g. all York’s  current cyclists travelling a bit further every day), or numbers of journeys (e.g. an increase in 33% of people cycling into York City Centre each day?), or a 33% increase in the number of people reporting that they use bikes for journeys of under X miles. These targets must be properly defined and explained.

The figures regarding the switch to EVs need a great deal more explanation. The suggestion that York might have 89% of vehicles on the road being hybrid or EVs by 2030 seems a much higher proportion than current national projections. Is York expecting far quicker uptake of EVs than the national average? These figures need to be more clearly explained.

The strategy cannot put too much reliance on electric cars. Electric vehicles continue to cause congestion and contribute to particulate emissions and bad air quality. They represent large amounts of embodied carbon and therefore imply large scope 3 emissions. Similar detail is needed regarding the figures for freight and taxi services.

With regard to the taxi fleet in York, the strategy should set a clearer objective. Given the regular turnover of vehicles in the taxi fleet, we can see no reason why the council should be licensing any kind of fossil fueled taxis after 2030.

Waste

The targets under waste are acceptable initial targets though again it would be helpful to understand where these figures for York are derived from.

Whilst the strategy is correct that waste processing only accounts for a small proportion of our locally derived scope 1 and 2 emissions, there is a huge amount that can be done locally to address the scope 3 emissions related to the sheer volume of materials that we currently use as residents in York and which are not repaired, re-used or re-purposed (or recycled). The strategy needs to include much more on how to develop the circular economy in York in keeping with regional ambitions, for example by developing food waste collection, re-use centres, local commercial materials resource registers etc

Commercial & Industrial

The section on emissions arising from commercial and industrial activities in York is extremely weak, being mostly directed at general trends in these sectors in the UK, rather than any specific thinking about how commercial and industrial operations IN YORK might reduce their carbon emissions. A more useful approach to this section might be to consider CYC’s ‘convening power’ to bring together commercial and industrial operators within the York area to exchange best practices and encourage reduced emissions. This could be closely linked to the efforts to reduce emissions associated with non-domestic buildings and also closely linked to work supporting the Economic Strategy.

Natural Environment

The section on the natural environment refers specifically to trees and notes the low level of canopy in City of York. However, a very narrow focus on trees may obscure other important areas where biodiversity could be improved and protected with long term benefits for the climate and for citizens of York. A wider focus on green spaces, diverse habitats and clean air could provide important benefits. Such a focus might also recognise the deep inequalities in access to high quality green spaces and clean air that affect different groups of residents in the city.

Energy Supply

We support the broad objectives regarding energy supply. A further key objective needs to be stated that focuses on Reducing demand for energy, for example through fabric first approaches to energy efficiency buildings, traffic reduction measures and the promotion of a resilient circular local economy. The most effective, cheap and secure form of energy is the energy we no longer need.

Again, the specific actions / changes that are associated with this sector are not clear. The suggestion that 2.36GW of renewable energy generation will be installed in the CYC area by 2030 needs further elaboration. This either suggests that some large scale solar farms are planned (for example, Britain’s largest solar farm in Shotwick, Wales generates 72MW from an area of 250 acres), or that every household in York will have a highly efficient installation (vastly more efficient than any currently available technologies) generating approximately 25kW per household. These numbers need to be clarified.

Governance

The Governance section needs to be strengthened as we have indicated above, with more emphasis on the involvement of city partner organisations. We welcome the work that has been done so far on developing partnership organisations in the city including the City Leaders Group. The Climate Change Strategy and associated action plans need to be at the core of this work and will need to be progressed through all partnership bodies, not just the Climate Commission. At the same time the Climate Commission needs to be expanded and become more transparent, inclusive and outward facing.

Scope 3 emissions

Finally, the strategy document should include a section on Scope 3 emissions. Scope 3 emissions account for up to 50% of York’s total emissions. We accept that some scope 3 emissions are difficult for local councils and their partners to tackle at the city level without changes in Government policy. However, a great deal can be done in terms of supporting a resilient local economy in which as many goods as possible are sourced in the region, a circular economy which minimises waste and thus carbon emissions from the production of new materials, working regionally to promote local food strategies and reduced meat diets and encouraging behaviour change regarding the goods York residents consume. The Strategy should include a more in-depth section on how Scope 3 actions can be incorporated into ongoing work.

Health and Wellbeing Strategy

Our main comment on the current draft is that there is absolutely no mention of the effects of air pollution on health, which may be a significant contributor to differences in healthy life expectancy.

On 29th July 2022 the United Nations General Assembly recognised “a clean, healthy and sustainable environment” as a human right. Air pollution disproportionately affects those wards in York that have the lowest healthy life expectancy. The World Health Organisation highlights the links between air pollution and cardio-vascular disease, stroke, lung cancer and chronic obstructive pulmonary disease, whilst recent UK government meta analysis has shown a link between air pollution and dementia. Recent research has noted that PM2.5 and PM10 generated from tyres and braking by electric vehicles could be a similar or even a larger problem than particulates from internal combustion engines. These concerns highlight the importance of reducing the use of private cars in residential areas, providing high quality public transport networks, promoting clean air zones and low traffic neighbourhoods, and connecting up safe cycling, walking and active travel facilities.

Any health strategy that sets out to reduce health inequalities across the city, must be joined up to CYC’s 10 year economic strategy, and the climate change strategy. The health strategy needs to acknowledge these (and related) environmental factors, and the climate change strategy (particularly in relation to transport) needs to be revised to recognise that simply switching to electric cars will insufficient to address the challenges.

Economic Strategy

Given the climate emergency, we have focused most of our analysis and feedback on the climate change strategy. In relation to the draft economic strategy, however, it is disappointing that the draft text does not consider the importance of creating a circular economy that implements the priorities of Reduce, Re-use, and then Recycle.

As the city becomes better able to quantify and monitor scope 3 emissions (i.e. those emissions generated in creating the goods and services that we use), we will need an economic strategy that responds accordingly. There are many opportunities for the council to work with local businesses, social enterprises, voluntary and community organisations to promote repair, re-use and repurposing of goods. These kinds of initiatives can improve lives for citizens, encourage skills development, offer ways to build positive relationships in communities, provide employment opportunities, and reduce the burdens we place on our environment. In the current draft strategy, this a missed opportunity, that could contribute much to enabling all our citizens in York (not just those in the paid workforce) to thrive.

Leave a comment