GMCA’s draft Environment Plan for 2019-2024.
A guest commentary by Peter Somerville
The Greater Manchester Combined Authority has published a Draft 5-year Environment Plan for 2019 to 2014. This is the first Environment Plan that the Authority has produced, and follows the first Green Summit on 21 March 2018, extensive consultations, and the Springboard to a Green City Region report in August 2018. This draft plan will be presented to the second Green Summit on 25 March 2019 (next week) for approval.
The plan sounds ambitious, with GM envisaged to be carbon-neutral by 2038, achieved by 15% year-on-year GHG emission reductions. Looked at more closely, however, it has some serious weaknesses and omissions, and in some respects is not nearly ambitious enough. The introduction to the plan states that it is expected to be finalised by 29 March, which suggests that there is little time to make any substantial changes, though these are sorely needed.
On clean air, for example, the plan refers to 152 stretches of road where concentrations of nitrogen dioxide exceed the legal limit. One might imagine that the GMCA would give the highest priority to obeying the law, particularly as this issue has been raised for some years now as one requiring urgent and immediate action, but actually the plan is for GMCA to be compliant only by 2030 (p14), which makes it look as though a further decade of law-breaking is acceptable to the authority. If these stretches of road have actually been identified, surely action to secure compliance should already be underway?
A general problem with the plan is that it is not based on any clear evidence about the sources of GHG emissions in GM. All we get is Figure 4 on p13, which tells us that the main sources of emissions are (in descending order) buildings, industry and cars, but these are not broken down in any way (e.g. by type or by area). We are told later on that commercial and public buildings account for 70% of the total emissions from buildings, which is helpful, but more detail would not go amiss. As with other statistics produced by Anthesis, however, one suspects that they are merely artefacts of disaggregation and not measures of the actual GHG emissions in GM (the stated large reduction in emissions from 2015 to 2020, for example, seems scarcely credible).
The plan identifies three priorities for energy supply: 1) increase local renewable energy generation; 2) decarbonise the heating of buildings; 3) increase the diversity and flexibility of electricity supply. It is not clear where these priorities come from or what evidence or argument they are based on. The summary of actions on p19 contains a number of worthwhile proposals, and there are elements of a plan to meet priority 1, but there are no clear plans for priorities 2 or 3. It would also be nice to have some idea of what effects the proposed actions would be likely to have on reducing GHG emissions. One problem here is that the decarbonisation of heat and of electricity are largely outside of local control and are dependent on decisions made at national level, e.g. on decarbonisation of the national grid and the availability of renewable alternatives to gas-fired heating. Given these constraints, I would have expected the plan to prioritise the sourcing of renewable energy from outside GM as well as inside: consider what the effects might be if all GM residents and businesses switched to renewable energy suppliers – wouldn’t this solve a lot of the other problems?
On travel and transport, the plan is flawed in two respects. First, instead of reducing the amount we travel as the SCATTER analysis suggests we should (p28), the plan envisages a 15% increase in journeys by 2040, with only a slight decline in those made by car (from 3.4 to 3.2 million) (p25, Figure 6). Second, the plan does not recognise that switching to electric vehicles makes little difference to carbon emissions unless electricity is decarbonised, but the need for electricity decarbonisation is not even mentioned in the list of ‘What we need from government policy’ on p32.
On buildings, the goal is for all new development to be net zero carbon by 2028 (p33) but arguably this is a policy that should be introduced immediately, if only to save on the cost of retrofit in the future. The priorities stated are all about reducing heat demand, so it seems logical that the actions listed on p35 are all about increasing energy efficiency. It seems to be assumed, again, that electricity is decarbonised, there are no actions on using renewable energy, and there is no clear plan for up-scaling retrofit.
On sustainable production and consumption, I was unable to find any clear proposals for action, but only well-worn thrift mantras and exhortations to cut waste and live more sustainably.
On the natural environment, no one could disagree with the ‘plan’ to plant a million trees by 2024 but I’ve been hearing this for over two years now but I don’t know if any trees have actually been planted. This section of the plan does not really address issues of rurality or biodiversity or the ownership and exploitation of land and material resources, and I am not convinced of the desirability of a natural capital approach to nature conservation.
I agree that ‘Sustainable funding and financing is key to delivery’ (p71) but there is no clear plan here to address this issue.
As with the Manchester Climate Change Framework 2020-2038 this plan has nothing to say about aviation emissions, nothing to say about divestment from fossil fuels, nothing to say about working with organisations and networks that are trying to challenge fossil fuel incumbency, nothing about what GMCA could contribute to achieving a just transition to a low carbon society (e.g. nothing about redeployment or retraining for fossil fuel workers), and nothing to show that GMCA recognises that a whole world exists outside its little bubble.
Looking back at my earlier comments on the GM Springboard Report in August 2018, I find that most of the criticisms made there apply equally to this plan, namely:
1) There is insufficient information about the main sources of GHG emissions in GM;
2) There is no substantive information about what has been achieved in GM so far in reducing GHG emissions (reference to earlier strategies or plans is lacking);
3) Key responsibilities for taking the various actions proposed are not assigned;
4) The plan does not recognise the crucial role of putting an end to the extraction and combustion of fossil fuels, irrespective of whether this occurs in GM or not;
5) Priorities for action seem to be identified on an ad hoc basis rather than on a strategic basis such as in terms of how much a proposed action is likely to contribute to reducing GHG emissions.
Peter Somerville, 12.3.19