Council must take ambitious, science-based climate action

9 July 2020

Scale of climate challenge is far greater than indicated

Green & Liberal Democrat councillors have written to the Norwich City Council Labour cabinet members expressing deep concerns about the council’s Environmental Strategy and proposing a number of urgent actions. The text of the letter, sent on 8 July 2020, is below.


From: Cllr Denise Carlo, Cllr Judith Lubbock, Cllr Jamie Osborn

To: Cllr Kevin Maguire, Richard Willson

cc: Norwich City Council Cabinet, Stephen Evans (Norwich City Council Chief Executive), Cllr Sandra Bogelein, Cllr James Wright

8 July 2020


Dear Kevin and Richard,

Environmental Strategy Final Revision

As mentioned we are writing to explain why we were unable to endorse the Environmental Strategy at CEEEP on 1 July.  We appreciate the large amount of work which has gone into its preparation and we do not doubt the City Council's commitment.  We have welcomed the City Council's delivery of walking and cycling  schemes, 20mph zones, a Norwich standard for council homes, new Council housing to Passivhaus standard, auctions for solar panels and other measures.  

A large number of responses were submitted to the consultation on the Environmental Strategy, including lengthy ones by Green Party councillors, yet the Action Plan is substantially no different in light of those comments, with the exception of three minor additions (1.42 – 1.44) and a fourth, more substantial amendment to the target for the Council’s carbon management programme.  We acknowledge the major effort which will be required for achieving a 100% reduction in operational carbon emissions, nonetheless, the statement, 'Norwich City Council plans to be net zero by 2030' only relates to the Council's own operations which contribute to less than 2% of Norwich's carbon emissions.  

Our overall conclusion and concern is that the Action Plan does not address the scale of the climate change challenge shown in the accompanying scientific graphics.  The Tyndall Centre graph (Fig. 5) shows an almost vertical drop in emissions necessary for Norwich between now and 2030 in order to achieve compliance with the Paris Agreement, amounting to a 12.7% cut year on year.  The graph sits alongside the  Action Plan and yet little relationship is shown between the two.  The Action Plan doesn't make any reference to the 12.7% figure or acknowledge that the proposed measures as they stand will not meet the Tyndall challenge.   

We had been hoping to see an action plan linked to quantified carbon reduction targets.  We accept that it is difficult to specify how different actions would achieve quantifiable emissions reductions.  However, there are methods available, including through the SCATTER pathways tool, which allows local authorities to identify the impact of particular actions and to aggregate those actions to identify their total projected level of emissions cuts. Even if the SCATTER pathways tool is not used, the SCATTER Inventory (Fig 6) indicates where the largest sources of emissions come from across the local authority population. For example, residential buildings and road transport combined form nearly 60% of CO2 emissions in Norwich, and one would therefore expect any action plan to show how those emissions would be addressed. It is however unclear how the council has applied either the SCATTER pathways or the SCATTER inventory tools to devise the Action Plan.    

We are pleased to note an Action Plan commitment (at 1.25) to explore the SCATTER tool for use in Norwich. We hope that this means there will be a fuller application of SCATTER to establish a clear link between reduction targets and the scale of actions required to meet those targets. We hope that the application of SCATTER will result in additional actions, suggestions for which we would be happy to discuss (and some are indicated below).

The need for additional action is because the scale of challenge is even greater than indicated.  The Strategy states that Norwich is on track to achieve 2 tonnes of C02 per person by 2023/24 and based on trajectory data the city will achieve carbon neutrality before 2050 (section 14).  This figure does not factor in emissions from production, consumption, aviation and shipping.  The latest climate change science points to the urgent need for radical cuts in carbon within the next decade by 2030.  We dispute the claim that the Government’s target of net zero carbon by 2050 represents “highest possible ambition”: as has been evidenced by work such as the Zero Carbon Britain report and the efforts of many councils that have set carbon neutral targets for sooner than 2050, it is possible to aim for 2030.

Clearly, meeting even the 2050 target, let alone a more ambitious one, will be possible only if national and local governments grasp some difficult nettles which the Committee on Climate Change has repeatedly highlighted, notably the domestic and transport sectors.  A pre-condition for helping citizens to change their behaviour is to 'tell the truth' and not under-state the local emissions burden and scale of challenge.                                               

The Action Plan contains a lot of good action points but the means of accountability are not clear. Regrettably, it also includes several references to other strategies which will increase Norwich's carbon footprint, including:

  • Greater Norwich Joint Core Strategy: this strategy was predicated on the NDR. In his decision letter approving the NDR Development Consent Order, the Secretary of State accepted that the NDR would increase Norfolk's transport carbon emissions by 6.17% between 2018 and 2032. This increase took into account future sustainable transport schemes such as development of Bus Rapid Transit by 2026 in the transport model for the Norwich Area Transportation Strategy and so a significant number of Transforming Cities schemes have already been accounted for. Further measures and a more radical programme will be required to achieve a shift away from the private car to green travel modes.  As renewable energy has grown in importance since adoption of the JCS, the weak on-site renewable energy policy in the JCS has enabled several large housing developments to get away with sub-optimal renewable energy standards.
  • Greater Norwich Local Plan: this includes a policy for a Western Link.  This scheme is not simply intended to displace vehicular traffic from the existing road network to a new link road but to grow traffic by opening up land for development and improving access to development sites. The draft amended policy for on-site renewable energy remains disappointingly weak, despite massive technological advances making on-site renewable energy much cheaper.  
  • River Wensum Strategy: the main thrust of this strategy is to improve economic return from the river and there is no specific carbon reduction component, although increasing biodiversity along the river will help to mitigate carbon to some degree.

We acknowledge that the Action Plan is intended to match the City Council's resources and capacity.  In order to address the limited capacity of the Council's small environment team, the Green group proposed a dedicated climate change officer at Budget Council to supplement Richard's team, but this wasn't accepted. We hope that this idea can be reconsidered especially given the importance of supporting the green economy. 

In relation to limited Council funds, we acknowledge this is a major constraint.  At the same time, there is much that the City Council can do at the political level which would not cost anything financially. For example:

  • As a key partner in the Greater Norwich Development Partnership, the City Council could state its unambiguous opposition to a Western Link, as the County Labour group has done.
  • With a place on the board of New Anglia LEP, the City Council is in a strong position to challenge some of its recommendations.  Past decisions which the Council Leader has endorsed have included agreement of £1million for a Food Hub at Easton which is dependent on car and lorry access and a Green Growth Strategy which includes a transport strategy based on road building.       
  • As a consultee, the City Council can state its opposition to local national road improvement schemes. Highways England admits that the A47 dualling and A47/A11 Thickthorn schemes will probably increase carbon emissions.
  • Norwich City Council can oppose the expansion of Norwich Airport and work to identify and support alternative sectors for jobs outside of the aviation industry.

On a more positive, proactive note, some suggestions for what the council can do using its existing budgets and powers include:

  • The City Council could use the new Good Economy Commission to drive a green recovery from Covid, through making this explicitly part of the terms of reference and including an environmental expert on the board.
  • The City Council can join the Place-based Climate Action Network (PCAN) and from this implement key actions for the transition to a lower carbon economy, including mobilising finance for, amongst other sectors, housing and low- or zero-carbon SMEs.
  • The City Council can use its position as convenor of the City 2040 Vision group to work towards a shared commitment to a target for carbon neutrality that is sooner than the current target of 2050, and can convene a set of shared actions to follow this.
  • Planning and licensing powers could be used to incentivise or make mandatory greener building and greener business.
  • The City Council can also choose to use its commercial investment ability to invest in large scale green initiatives for a financial return such as solar power, and battery storage – a budget proposal from the Lib Dems in 2019 - rather than in types of commercial premises which contribute to climate change.
  • Carparks owned by the City Council could be reviewed with a view to providing sites for less carbon-intensive sources of income, as per a recommendation from the Scrutiny committee. Similarly, the council could review its off-street car parking policy to find ways of disincentivising cars entering in the city centre.
  • A retrofit auction has been suggested, on the model of Solar Together, to help provide affordable retrofit options at scale.
  • A proportion of HRA money could be set aside specifically for climate emergency mitigation and adaptation measures, as was suggested at the Budget Scrutiny meeting in February this year.
  • Further implementing actions to support a circular economy, a theme which is mentioned twice in the Strategy and is also mentioned in the covid recovery blueprint document, but which is not linked to any specific actions. For example, the city council can work to support repair facilities and to support businesses that are innovating in reducing waste.


The Green and Liberal Democrat Groups would be pleased to contribute to the Council's shift to net zero carbon in as short a timescale as possible by feeding in ideas, helping to deliver schemes and acting where necessary as a critical friend.

We look forward to continuing to work with you.


Kind regards,   

Cllrs Denise Carlo, Judith Lubbock, Jamie Osborn.

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