Karen Barrass
Karen BarrassUK100
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At UK100, we are working closely as possible with Chris Skidmore MP on the Net Zero Review. Here is our submission to the call for evidence.

UK100 is the only network for UK locally elected leaders who have pledged to play their part in the global effort to avoid the worst impacts of climate change by committing to becoming Net Zero before the end of the decade. It brings together local authorities, from cities to the countryside, across all political parties, to share knowledge, collaborate, and collectively advocate for more acknowledgement of and support for their seminal role in delivering Net Zero. 

UK100’s submission to this call is based on our growing evidence base for local Net Zero delivery. As with the Climate Change Committee (CCC) and the National Audit Office (NAO) recommendations - our work highlights the vital role that local authorities must play if the UK is to reach its Net Zero targets. This response draws on UK100’s evidence base of research including: 

Local authorities are well placed to deliver actions in their local areas: local actions can be better tailored to suit the area than national actions and can secure social and economic benefits. Regional, city and local authorities must be the partners of choice for the government in developing and delivering Net Zero commitments. 

As convenors of place, communities, and economies, they bring together public, private and third sectors, education and research, and local residents, to better understand Net Zero challenges and opportunities and ensure its practical implementation at a local level. Local government has direct access to citizens and businesses.

Our three key recommendations for the Net Zero Review are as follows:

  • Local authority delivery of Net Zero should be retained and enhanced by boosting capacity and capability 

The Net Zero Strategy acknowledged through the introduction of the Local Net Zero Forum that it is important for the roles and responsibilities between national and local government on Net Zero Delivery to be clarified. We welcome this and the other strategic areas (private finance and government funding, capacity and capability of local government, data and reporting) that the Forum has been tasked to address. But this alone is insufficient and we urge the Government to develop a Net Zero Delivery Framework which can guide these relationships and activities over the longer term.

  • Place a floor, not a ceiling, on local ambition and commitment to deliver Net Zero - enabling local authorities to go further and faster than the government to deliver Net Zero as soon as possible. 

The CCC’s progress report to the Government highlighted that: “There is considerable momentum at local government level”, but it goes on to state that this strong local commitment to Net Zero ‘is currently at risk of being squandered.’ Whilst the Net Zero Strategy acknowledges that “taking a place-based approach to net zero is also vital,” ensuring local authority agency in this approach is fundamental. If local authorities want to go further and faster, then they should be given the opportunity and resources to do so. Many ambitious local authorities have set Net Zero targets that are ahead of the UK Government’s 2050 deadline. Giving more local authorities the power and support to set similar trajectories and build momentum for change will be key to delivering a Net Zero future.

However, the Levelling Up and Regeneration Bill introduces the concept of ‘National Development Management Policies’ and within this context, climate change has the potential to be framed as a national policy area, also potentially reducing the agency that local authorities have to integrate Net Zero delivery into their local plans. The Net Zero Review needs to offer assurances that local authority ambition on Net Zero will not be impeded by these developments and that there will be cohesion between the Strategy and the future planning system.

  • End the Wait. Insulate. The Net Zero Strategy, Heat and Buildings Strategy and the Government’s subsequent legislative agenda on energy have failed to address the importance of energy efficiency as a means of tackling both energy insecurity and Net Zero delivery. CCC highlights that progress on energy efficiency retrofits are significantly off-track. 

It is in this context that UK100 has undertaken research that seeks to highlight the key role local leaders can play in boosting UK energy independence, reducing household bills, driving skills and market transformation, and accelerating progress towards Net Zero. This research will be launched in November 2022. 

In this Net Zero Review, the Government needs to prioritise a significant response to improve the energy efficiency of our draughty homes. The Heat and Building Strategy recognised that “to meet Net Zero virtually all heat in buildings will need to be decarbonised,” requiring “a co-ordinated system-wide approach to decarbonise cost-effectively”, a ‘fabric first’ approach to energy efficiency, a commitment to develop the market and strong language on the need for local input and decision-making. This needs to be followed up with a detailed plan for retrofitting the building stock. UK100’s Local Net Zero Delivery Progress Report on Heat and Buildings recommended: 

  • Dedicated, large-scale, long-term, non-competitive funding for place-based solutions to the decarbonisation of existing buildings
  • A clear framework for delivering the partnership with LAs outlined in the Heat and Building Strategy.

UK100 responses 

Overarching questions

1. How does net zero enable us to meet our economic growth target of 2.5% a year?

There are clear examples of other environmental legislation that has fostered growth and prosperity. Here we outline a few examples which demonstrate that clear regulatory and strategic frameworks, such as the Net Zero Strategy, can offer market certainty and help foster economic growth. 

UNEP reports clear economic benefits from the Montreal Protocol being implemented to address the ozone emissions associated with CFCs. From stimulation of more efficient production processes, product innovation spurred by ozone-depleting substance (ODS) phase out and redesign of products and equipment - through to promoting competition between non-ODS refrigerants, industrial rationalisation and economies of scale, trade and overall contribution to GDP. UNEP highlight that:

“ The economic benefits of ODS phase-out through industrial development, technological innovation, and rationalisation [...] have all contributed to national macroeconomic growth in developed and developing countries as measured by GDP. [...] The opportunities provided by the [Montreal] Protocol to increase competitiveness through improved production efficiencies, introduction of new technology and industrial rationalisation set the stage for expansion of production and exports in manufacturing sectors such as refrigeration and air conditioning.”

The global catalytic converter market is estimated to be worth $14,233.0 million in 2021, and it is expected to reach $28,342.9 million revenue by 2030, advancing at a compound annual growth rate of 8.0% during 2021–2030. This market development has been primarily driven through stringent mandated tailpipe emissions standards.  

Increasing the charge for plastic bags to 10p in the Government’s own scheme is also expected to benefit the UK economy by over £297 million over the next 10 years.

Better utilising the Waste Electrical and Electronic Equipment (WEEE) regulations could deliver significant financial gains. In written evidence on e-waste to the Environmental Audit Committee, Green Alliance suggested that the UK could support eight to twelve recycling facilities and 50–200 more specialised waste reprocessors, creating over £500 million extra value and allowing for the extraction of critical raw materials such as lithium from batteries.

According to the EEA, the 7th Environmental Action Plan of the EU aimed to boost the competitiveness of eco-industries and strengthen the market share of green technologies by 2020. Since 2000 eco-industries have outperformed the total economy of the EU-28 in terms of creating economic prosperity and employment. Between 2000 and 2015, employment in eco-industries grew by about 47 % compared with 6 % for the overall economy. Moreover, the environmental goods and services sector (EGSS) economic significance grew in the same time frame, with an increased share of both GVA (from 1.6% to 2.3%) and employment (from 1.3% to 1.8%). Labour productivity in the EGSS is higher than in the overall economy, and the EGSS is on average 25% more productive than the overall economy. 

Harnessing the key opportunities that exist for delivering clear market signals with a commitment to Net Zero delivery has the potential to deliver economic growth, jobs and prosperity across all of the sectors of the UK economy that need decarbonising. But the government needs a long term, stable focus and clear policy and strategic direction to enable these markets to flourish. And it is key that local authorities are instruments of delivery. To meet the mandatory climate targets that the government has set, it needs to be mindful that fossil fuels will inhibit a growth economy as we will continue to be dependent on rising oil prices.  

Further, late movers who keep investing in fossil fuel infrastructure instead of decarbonisation technologies, will be left with stranded assets. Recent research shows that countries that decarbonise fastest will profit most from the Net Zero transition and predict that around half of the world’s fossil fuel assets will have become worthless as soon as 2036. Benefits vary by country with modelling finding that the UK could add $700bn to the value of its GDP under a Net Zero scenario by 2036.

2. What challenges and obstacles have you identified to decarbonisation?

See below - question 24.

5. Where and in what areas of policy focus could net zero be achieved in a more economically efficient manner?

There is a lot of attention currently focused on the potential to deploy hydrogen in homes, but there is a growing body of evidence to suggest that at the current time, heat pumps are much more economically efficient than hydrogen. This data should be considered in outlining policy focus. 

A comprehensive study was undertaken for the Greater London Authority to better understand the potential for deployment of heat pumps at scale in London. In considering the role of hydrogen the report clearly articulates some of the current challenges for the deployment of domestic hydrogen. Conventional boilers could only burn a blend of around 20% hydrogen and 80% methane - burning 100% hydrogen would require new boilers to be installed simultaneously across all parts of the network that were switching to supply pure hydrogen. The carbon neutrality of hydrogen currently relies on carbon capture and storage, which is yet to be demonstrated at scale in the UK. Production of low emission hydrogen is possible via electrolysis powered by renewable electricity, however the overall efficiency of heating would be less than 70% before accounting for distribution losses, compared to 260-300% for a typical heat pump.”

West Midlands Combined Authority have also undertaken scenario assessment in which heat pumps were more economically competitive than hydrogen for heat.

Hydrogen has a role to play in the transition to Net Zero, particularly for some ‘hard to decarbonise’ sectors. But it is only one part of the solution, and it is important to prioritise alternatives which are less reliant on fossil fuels and carbon capture technology. We should continue to look into how hydrogen can be scaled up as a more sustainable solution. 

With many Local Authorities committed to decarbonising faster than the Government has committed to, speeding up our transition to Net Zero, we need to prioritise technology available today, rather than relying on technological developments which aren’t yet widely available.

We need a focused approach to Hydrogen which solves problems which can’t be solved other ways. This includes using Hydrogen power in locations and for applications which are most suited to it, e.g electrolysis for freight/storage of renewables. Hydrogen should be part of place-based solutions where it makes sense - and local authorities need to be involved in conversations about infrastructure.

Questions for local government, communities and other organisations delivering net zero locally

24. What are the biggest barriers you face in decarbonising /enabling your communities and areas to decarbonise?

Through the course of conducting UK100 research in collaboration with our 103 members, three key challenges have been identified as inhibiting local decarbonisation.

Our members tell us that the things that currently have the most impact on their ability to deliver our funding and strategy. But they also identify funding and capacity as the two biggest barriers to success. 

Combining long-term, non-competitive funding, capacity development and support with a clear strategy for Local Net Zero Delivery could enable local authorities to accelerate progress.

Local authorities have responded positively to government programmes and initiatives - such as the Public Sector Decarbonisation Scheme. But much of this support, in the form of competitive funding rounds is not systemic, consistent or long term. Furthermore existing funding doesn’t test out new finance models or approaches, meaning innovation is dependent on government funding and is not replicated or transferred elsewhere. Some insight direct from our membership:

“Lack of a co-ordinated, long term approach to funding the required initiatives across government departments. Constant last minute competitions for short term projects results in huge inefficiencies for local government, lots of wasted effort discussing and co-ordinating bids, multiple monitoring methods/criteria for effectively the same outcomes. We require a much longer term approach to distribution of funds, more autonomy and trust from central government to target the funds at local needs/priorities. This would not only make delivery more efficient but also allow the numerous co-benefits of investment in skills/training of local suppliers/partners to be much more fully developed.” UK100 member, County Council 

“A more structured approach to regulation and strategy setting from central Government would be very helpful; it is hard for us to plan our work programmes when strategies and policies that may enable specific programmes are announced with too short a lead-in period, or withdrawn/delayed without notice. It makes our limited resource much more stretched as we have to be response-led rather than plan-led which would be more efficient.”  UK100 member, City-region

The current approach to local Net Zero delivery is not enabling. Despite the government saying that they don’t want to be prescriptive, the criteria for funding can be very tightly drawn, limiting the ability of the LAs to transform places, establish long-term programmes, and build up a skilled local workforce – which are all essential for a successful transition.

25. What has worked well? Please share examples of any successful place-based net zero projects.

UK100’s knowledge hub is building an evidence base that demonstrates that not only is local Net Zero delivery possible, but that it can bring significant co-benefits as well as decarbonisation. Below are select examples, but more information can be found on the UK100 website.

Bristol City Leap

Bristol’s City Leap low carbon energy investment project has had the biggest impact in securing financing for Net Zero delivery. The City Leap partnership aims to deliver low carbon energy infrastructure, such as solar PV, heat networks, heat pumps and energy efficiency measures at scale, all of which will help Bristol meet its carbon reduction targets of becoming carbon neutral by 2030. The project took a cross-organisational team of people from Bristol City Council over two years and £7.5 million to secure £1bn towards the decarbonisation of the city with a private sector partner, in this case Ameresco Ltd, a leading clean tech integrator and renewable energy asset developer, owner and operator. Private sector partners are contributing capital funding, including £424 million the first five years of the 20-year collaboration. In those first five years, the project will remove around 140,000 tonnes of carbon across the city.

Heart of the City: supporting SMEs to reach Net Zero in the City of London 

This project provides support for SMEs in the Square Mile. The ‘Climate for SMEs: 4 Steps to Action’ course offers accessible, practical resources and access to sustainability experts from across industries to help SMEs prepare to reach Net Zero by 2040. SMEs who have Net Zero action plans as a result of the course will benefit commercially; being a sustainable supplier will help them to keep current contracts and win new ones.

If UK businesses reduce carbon emissions to Net Zero by 2030 instead of 2050, then society (including the private sector) would escape costs equivalent to £1.1 trillion.

Somers Town Energy

A district energy network between Euston and King’s Cross train stations in order to provide heating and hot water to 550 homes, a new primary school and community facility. The project involved the retrofitting of a new low carbon energy centre within an existing council-owned car park, alongside new cycle parking facilities. The project has seen a reduction in energy costs for residents living in the social housing connected to the network, contributing to the alleviation of fuel poverty among Council tenants while enabling the Council to achieve its target of a 40% reduction in CO2 by 2020.

Swansea Retrofit

Retrofitting social housing. The impact for residents of these retrofitted homes has been huge. Residents paid just £3 in energy bills in April after the work had been completed and expect substantial future savings for occupants.

Energise Barnsley 

Community-owned energy company - six key methods: solar photovoltaic (PV), battery storage, demand-side response, peer-to-peer trading, asset management and community funding. It has delivered a significant financial and social impact. In the trial, participants saw energy bills fall around 30% as a result of solar panels being installed, and a further 20% as a result of the battery units. Over £40,000 of savings were made on electricity bills in the project’s first year alone (2014-15). The bond has provided 5% returns for investors, with over £400,000 being paid from all surplus income generated into the fund by 2020. By the end of 2020  Energise Barnsley had saved residents over £200,000 in reduced electricity bills and over 3,000 tonnes of carbon emissions.

Cornwall biomethane pilot

Farmers receive income from biogas sales, as well as saving on energy and fertiliser bills, having access to better slurry storage and being responsible for reduced environmental impacts from methane, NOx and ammonia. It also creates a large number of green jobs essential to the delivery of a green recovery and supporting the ambition for more sustainable farming, as well as reducing emissions from the sector alongside those of transport and heating.

District Heat Network Leeds 

The scheme will provide low carbon heat and hot water to 1,983 council homes which will save tenants money on their energy bills whilst reducing the city’s carbon footprint. This project also has wider connotations for the community, providing local employment and training opportunities. So far, the project has helped to employ more than 430 people in the local low carbon sector - including 36 apprentices. It is also being used to educate local schools on climate change - with the Leeds PIPES network being named by a local academy.

Gloucestershire County Council's new G2C cycle route 

Transformative project linking Gloucestershire’s two central conurbations, Cheltenham and Gloucester City, has exceptional strategic significance, supporting Gloucestershire’s long-term ambition for a countywide strategic cycleway network. Current low levels of cycling across Gloucestershire- 4-6% of commutes forecast to grow to 15% to 29%. Positive impacts of the G2C project are transferable and can be adapted. 

  • There are substantial economic and health benefits by reducing transport emissions through active travel and public transport schemes.
  • Commuters who opt to cycle using dedicated cycle lanes (where they exist) instead of cycling on the road in often congested urban centres take half as many days off as others, resulting in a £13.7 billion boost to the UK economy, equivalent to about £36 million per UK local authority.
  • Congestion in towns and cities across the UK costs the economy around £11 billion every year. For every kilometre of greenways and cycle paths constructed 1.6 FTE jobs can be created directly, indirectly and induced.

Ultra-Low Emission Vehicle (ULEV) Strategy for the West Midlands

The West Midlands is well placed to benefit economically from the increased supply and uptake of ULEVs. The ULEV Strategy complements current regional activity by providing specific recommendations for Transport for West Midlands and other stakeholders to effectively exploit these opportunities. This strategic transport plan has the potential to create a triple benefit: 

Additionally, the work of other organisations in the local Net Zero delivery space also warrants mention here. 

3Ci - the partnership between Core Cities, London Councils and the Connected Places Catapult - has been set up to build the investment case for local Net Zero programmes and interventions. Using collective networks and capabilities, 3Ci is seeking to use the combined scale of cities to mobilise finance and drive investment into low and Net Zero projects across all of the UK’s largest cities, rather than individual ones. The initial report concluded that the scale of the challenge requires new implementation and blended finance model.

A report from UK Research and Innovation (UKRI) and PwC, Accelerating Net Zero Delivery: Unlocking the benefits of climate action in UK city-regions compares the benefits of place-specific and place-agnostic approaches for the first time. It shows significantly better outcomes when places tailor their Net Zero delivery to the needs and opportunities of the area with the potential to contribute to levelling-up.

26. How does the planning system affect your efforts to decarbonise?

The biggest issue is that there is no statutory duty to pursue Net Zero through planning. In order to resolve this, there needs to be a wholesale review of the Town and Country Planning Act to bind planning with the Climate Change Act. 

The provisions of the Planning Acts and the Climate Change Act need to be better connected so that planning can deliver emissions reductions. This means strengthening the policy guidance and the introduction of a legal provision for planning on climate change. This would function as the Net Zero test on planning. Provisions that define and require adaptation resilience standards to be met in planning decisions must also be put on a legal footing.

The National Planning Policy Framework (NPPF) does not give climate change the priority which the science demands. Climate change is included in paragraph 8 at the end of a long list of other environmental considerations. The most significant part of national policy on climate change is included as a footnote which is not a commensurate way to deal with a global crisis. The publication in July 2021 of the revised NPPF was an opportunity to show how planning can play a crucial role in climate mitigation, for example by strengthening the policy presumption against fossil fuel extraction, but the revised document ignores the implications of the 6th Carbon Budget Order. National policy sets out detailed methodologies for forecasting many issues like housing, waste and aggregates.

There is no such guidance for carbon reduction. The NPPF also fails to prioritise key climate impacts such as surface water flooding and overheating.

Due to the changes brought in by permitted development, where full planning permission is no longer required, planning authorities have no way of ensuring that the climate emergency is reflected in decisions. The current prior approval process does not allow local authorities to consider the impact of development on carbon emissions or overheating. 

Taken together these problems help account for why only a minority of local plans have an effective approach to carbon reduction; why carbon intensive development, such as coal extraction, is still being proposed; and why so many decisions on the location and design of new homes will require expensive retrofitting. If we are to ‘build back better’ we need to urgently transform the built environment to both reduce emissions and be resilient to climate impacts.

To address these considerations, we need Building Regulations and the NPPF to mandate zero carbon new buildings with immediate effect and enable ground mounted renewable energy.  Priority also needs to be given to cycling and walking in all transport schemes.

27. How can the design of net zero policies, programmes, and funding schemes be improved to make it easier to deliver in your area?

Essentially the following criteria need to be applied to all policies, programmes and funding schemes to enable more impactful and successful delivery of Net Zero:

  • Longer term (at least 5 years) and non-competitive programme funding for the delivery of Net Zero
  • Multi-sector (covering more than just one sector, enabling true place-making to be planned for)
  • Place-based (and therefore not technologically neutral to account for the differences in geography and energy sources )
  • Mindful of the distinct challenges faced by rural and urban areas alike and tailored appropriately
  • More engagement with strategic stakeholders (DNOs for example) from the outset
  • Expectations for roles/responsibilities in delivery across local and national government.

UK100 continues to recommend the introduction of a National-Local Net Zero Framework for national, regional and local government. This framework would show clear outcomes and direction, provide additional powers where needed, and allow faster delivery in ambitious areas. The Local Net Zero Forum is welcome, but it needs to have teeth, with a dedicated Net Zero Delivery Unit at its disposal. It should have ministerial oversight and build on the recommendations that will be delivered by the Forum’s task and finish group working to establish a clear delineation of roles and responsibilities.

28. Are there any other implications of net zero or specific decarbonisation projects for your area that the Review should consider?

The following have been identified as further implications to consider in the Net Zero Review:

  • Retrofit: As outlined by UK100 research, and that of the CCC, there is a need for a much more detailed retrofit section with measurable interim targets, to be included in the Net Zero Strategy. The Review offers an opportunity to redress this current omission.
  • Additional legislative changes: There are some areas where it is clear that minor legislative amendments or updates would make a material difference to the ability to deliver local Net Zero. One example would be Energy Performance Certificate (EPC) reform. As outlined in UK100’s Power Shift report, EPCs do not currently provide a good representation of the carbon performance of a building in operation. The production of an EPC is a tick-box exercise based on the presence or absence of building and energy supply elements, rather than how well they perform. Some elements (e.g. underfloor insulation, some roof insulation) cannot be inspected and are typically ignored in the assessment. For traditional and rural properties, the recommendations frequently include external wall insulation which is technically unsuitable for these building types. This also speaks to a broader point related to the need to better understand and differentiate between rural and urban contexts in local Net Zero delivery.
  • To address these issues, amongst others, the EPC system should be revised to be more accurate and better reflect in-use energy performance, including a reflection of the technical limitations of energy measures in traditional and historic buildings. Additionally, a long term and flexible funding scheme should be introduced for landlords and private householders to enable them to meet the EPC requirements.
  • Onshore wind: The recent Growth Plan stated that consenting for onshore wind was going to be brought in line with other infrastructure. No further details were given and what this means in practice for local authorities and the deployment of local onshore wind projects is ambiguous. The Net Zero Review should clarify the government’s position on new onshore wind as an urgent priority.
  • Net Zero and local development: The Levelling Up White Paper and subsequent Levelling Up and Regeneration Bill have not adequately integrated local Net Zero delivery. The future of the Levelling Up and Regeneration Bill is currently uncertain, given the introduction of the Infrastructure and Planning Bill and the relationship between the two pieces of legislation are unclear. Similarly the Growth Plan’s commitment to Investment Zones did not reference or link provision in any way to Net Zero. Net Zero delivery should be central to all of these developments, and the Net Zero Review is an important opportunity to provide clarity and emphasise the need for cohesive local development and Net Zero strategies.
  • Future of Energy Bill: The Net Zero Review should give assurances that the Energy Bill will continue its legislative journey to provide stability for a sector which requires significant attention in terms of Net Zero delivery. In particular, the Review should confirm that the Future Systems Operator/Independent System Operator will be retained. More consideration of the strategic relationships that will be required to deliver Net Zero effectively (for example - between Distribution Network Operators and local authorities - particularly in the areas of electric vehicle charging infrastructure and renewable energy deployment) should be acknowledged.
  • Costs of adaptation: The economic costs of climate adaptation need to be better integrated into the Net Zero Review
  • Market confidence: There needs to be confidence in the market. That there is a Net Zero Review at all, sends a bad signal to the market. As an outcome of the Review, the government needs to make a clear statement that it remains committed to its mandatory targets for Net Zero delivery.

Please don’t hesitate to contact us for any further information you might need.