PCS Submission to the GLA Consultation
on the Draft London Environment Strategy – November 2017
General Introduction
PCS trade
union has around 180,000 members working in the UK civil service, public sector
and on privatised, commercial contracts. Of this over 44,000 are based in the
London and South East region. Our members work across a broad range of roles
including in London’s culture sector, direct delivery of public services, policy
development and drafting legislation.
PCS recognises
climate change and the environment as a trade union issue which is evidenced in
conference policy initiated from the grassroots of our membership. This includes support for renewable energy,
opposition to fracking and Heathrow third runway, lobbying for workplace
environmental reps, climate jobs, energy democracy and a Just Transition for
workers and communities.
Whilst global
challenges, climate change and the public health crisis of poor air quality are
critical to workers and must be addressed at all levels. For this reason the
London Environment Strategy must be seen to fit within a wider framework of
action all countries need to take on climate change in line with achieving the
Paris climate agreement target of reducing greenhouse gas emissions (GHG) to 2
degrees Celsius or better 1.5 degrees.
The strategy
notes that 42% of London’s GHG emissions are generated from workplaces (page 187).
PCS therefore argues for statutory rights for Workplace Environmental Reps (WERs)
to help support measures in the workplace to reduce GHG emissions, and adapt to
climate change.
In this
submission we particularly focus on two areas: Energy for Londoners programme
and air quality. In summary we believe
that whilst there are many welcome commitments within the strategy, it does not
go far enough if measured on the principles of seeking to improve lives and reduce
inequality, leading by example, avoiding negative impacts on other policy
areas, learning from international best practice and moving beyond business as
usual (page 19). We also believe the principles need to be strengthened to
include public and worker engagement and Just Transition. In regard to this we would
welcome the Mayor of London’s support for Workplace Environmental Reps (WERs).
We conclude by
noting that the decision of the Mayor of London not to go ahead with a fully
licenced publicly owned London energy company would in our view be a serious
mistake in addressing the urgency of climate change, high energy costs for
Londoners, air pollution and jobs such a company would create. We therefore
urge the Mayor to reconsider this. This is one of the strongest areas’ within the
Mayoral power where a real difference could be made, leaving a lasting positive
legacy to all those living and working in London.
Overarching Questions
1. Do you agree with the overall
vision and principles of this draft London Environment Strategy?
Whilst PCS welcomes
the opportunity to comment and contribute to this consultation on the draft
London Environment Strategy we believe there is an important democratic
principle of ongoing public and worker engagement missing within the proposals.
One way to do this from a worker side is for the Mayor of London to support
Workplace Environmental Reps (WERs).
WERs play an instrumental role in helping develop practices and support
in the workplace for environmental and carbon reduction measures. For example in waste, energy efficiency or
transport policies. As the 2014 TUC
report The Union Effect: greening the
workplace[1]
highlights WERs can have a “transformative effect on workplace efficiency
and sustainability” that can also extend back into communities. This would certainly go some way to help
overcome the barriers of reducing emissions in workplaces (page 211).
However we
also think it is important for communities to be actively engaged in decision
making. Therefore mechanisms need to be established to ensure democratic control over decision making
that impact people’s lives. For example, as the energy system changes bringing
with it more options for distributed and energy storage, communities need to
play a role in energy choices and how services are run. The strategy makes several references to heat
networks which have been a curse rather than a solution to high fuel costs for
the social housing residents of Myatts Field North[2], locked into an energy
deal with E.on as part of a 40 year private finance initiative contract with
Lambeth Council.
Aside
pressing the need for a fully licensed London energy company (see below) it
illustrates very starkly both how workers and residents need to have strong democratic
role over the solutions to climate change.
A second
major principle which is missing, and links strongly to the point above, is
Just Transition. No worker or community
should have to pay the price of an economic transition to a zero carbon
economy. Whilst London may not be at the
heart of fossil fuel extraction, many of its activities and pension funds of
workers profit from it. Therefore in supporting divestment from fossil
fuels reinvestment should be made in climate jobs, jobs that lower greenhouse
gas emissions and ensure protections for workers and their communities impacted
by the transition. This is one of three
high level demands of the international trade union movement, reiterated to the
COP23 in Bonn this November.[3] A phrasing also enshrined in the Paris 2015
Climate Agreement:
Taking into account the imperatives of
a just transition of the workforce and the creation of decent work and quality
jobs in accordance with nationally defined development priorities [4]
It is indicative
in the strategy that workers and trade unions are a missing part. Engagement
and consultation with workers is fundamental to Just Transition and we propose
they should be a fundamental principle of the strategy.
2. To achieve the policies and
proposals in this strategy, which organisations should the Mayor call upon to
do more (for example central and local government and businesses) and what
should the priorities be?
There is a
clear need to call on Government to do more to enable the policy framework to
achieve a zero carbon London by 2050.
Currently policy is disjointed across transport, energy and the
environment, and certainly impedes progress for example on establishing public
sector/municipal energy supply companies. For example the need for such
companies to compete nationwide rather than being allowed to operate within a defined
‘catchment’ area. The point is also well made on page 107 regarding the need
for government investment in grid infrastructure to support increasing
electrification of transport.
Business
should also be called upon to support initiatives given the contribution of workplaces
to GHG emissions. This can be both in
addressing their own carbon footprint, supporting establishment of workplace
environmental reps, joint employer/trade union sustainability forums and
workplace policies that enable workers to reduce their carbon footprint.
Influence
should also be brought to bear in ensuring good procurement practices and
building on initiatives such as the delivery pooling.[5] This includes greater engagement with trade
bodies/associations. There is some
reference to the taxi trade in relation to diesel vehicles (section 4; Proposal
4.2.1c) and water (section 8) but not more broadly.
Whilst the
GLA already has a best practice procurement policy[6] and is referenced in the
strategy, we believe that this and proposal 10.1.1d (page 372) should go further
to include procurement that clearly lowers
greenhouse gas emissions, including carbon budgeting to take account of
embodied emissions of imported or transported goods and services.
Additionally
strong links should be built into the City to City trade programme with
overseas cities to ensure they meet the aims of the strategy, as well as all agencies
of the GLA.
Finally there
is a need to ensure that the GLA does not support business that encourages
waste. For example we know that high street coffee chains such as Costa Coffee
have outlets in a number of PCS workplaces yet their ‘paper’ cups cannot be
recycled.
3. Do you agree that this draft London
Environment Strategy covers all the major environmental issues facing London?
Broadly the
strategy covers the main issues although it lacks a recognition of movement of
populations of in and out of the city and consequent environmental impacts e.g.
tourists, people attending major sporting or cultural events, flows of
temporary workers such as in construction that may come in for major projects.
There is also
a lack of coherence in joining together an economic, social and environmental
justice framework to arrive at the key end goals of becoming the “greenest city
in the world” as part of a Just Transition for workers and communities.
4. There are a number of targets and
milestones in this draft London Environment Strategy, what do you think are the
main key performance indicators that would demonstrate progress against this
integrated strategy?
There is an
issue of mixing ambition with real measureable progress. For example sweeping statements such as
achieving zero carbon by 2050 mean little without the clear routes to get there
and showing the necessary policy steps to achieve it. Indeed, there is a danger
that some policy decisions taken now with reduced ambition such as the Energy
for Londoners programme will lock in the GLA to contracts that will disable the
ability to meet the more challenging targets.
5. What are the most important changes
Londoners may need to make to achieve the outcomes and ambition of this
strategy? What are the best ways to support them to do this?
There is an
important need for highly accessible public information and awareness of the
London environment strategy, citizens and workers’ rights within it and why it
is important. People are clearly
concerned about climate change but can often feel paralysed that it is too
overwhelming. It has to be clear that whilst there needs to be individual
actions such as encouraging recycling, this is a collective action solution. As
also noted in the Paris Agreement, there needs to be a recognition that
solutions should engender processes that strive to eradicate inequality,
include gender responsive, participatory and transparent approaches that take
account of vulnerable groups, communities and ecosystems.
It is
recognised that the transition and transformations needed for a zero carbon
economy will change the way people live and work. Londoners should therefore be supported
through good policy to change practices such as providing an integrated public
transport systems, public ownership of energy, and greater democratic control
of the decisions that impact their lives.
Again, this
is something which Workplace Environmental Reps can also play an important role
in.
Chapter 4: Air Quality
1. Do you agree that the policies and
proposals outlined will meet the Mayor's ambitions for air quality in London
and zero emission transport by 2050? Is the proposed approach and pace
realistic and achievable, and what further powers might be required?
Air quality
is a serious public health issue as clearly noted in the strategy (page 52) and
we welcome recognition of the social inequality of health impacts (page 54).
Therefore this needs to be addressed as a matter of urgency, and if anything
the pace should be speeded up. However we also note this requires wider
government interventions.
The objective
4.1 to “help empower people to reduce their exposure to poor air quality” is
too limited in its reach. More needs to be said about working with employers
and businesses about their own actions and support for workers in this. Many working outdoors such as on construction
sites, working at London’s airports, undertaking public sector services such as
refuge/recycling collection, or even teachers supervising children on breaks
need to be protected to ensure both safe working practices and that their
employers are aware of their own legal obligations. Equally office based workers need to be aware
of potential risks from opening windows or indoor ambient pollution.
A missing
part in the strategy is consultation with trade unions and workers in assessing
the impacts on workers and steps needed to mitigate risk.
PCS supports
the proposal 4.2.2b and particularly opposition to “any airport expansion in
London” but fail to see how there would ever be “no unacceptable impacts on air
quality and that GHG emissions are minimised” (page 86). Airports have a significant impact on both
air quality and GHG emissions. This is from aircraft, traffic flow to/from
airports and within its parameters including staff, passengers and freight
traffic on the ground. The recently updated Airports Commission air quality
plan and associated pollution climate mapping sensitivity testing,
concluded
“There are
limited actions that the scheme promoters can take to reduce the impacts of the
schemes in central London, and the mitigation of risks relies on the effective
implementation of the Government’s 2017 Plan measures and RDE legislation to
reduce emissions from road transport.”[7]
Therefore it
is our view that London should not be supporting any further expansion of the
airport, not least as noise is a similar significant irritant and health
concern to the thousands of people who live under or near flight paths in and
out of airports
PCS believe
that the UK government should be supporting the development of an alternative
transport policy that would include: reducing demand for air travel; better use
of aviation capacity at other London and regional airports without building any
new runways; providing a well-resourced and affordable rail network; providing
infrastructure for electric vehicle charging points. The latter which we urge should
be supported by a publicly owned London energy company but we would support the
Mayors call on government to address the structural power grid barriers (page
97) and facilitate investment (page 106).
However this
should also be supported with a call for public ownership of the transmission
and distribution grids as natural monopolies and which would ensure a joined up
strategy for decarbonisation, transition to full renewable energy, and
transport electrification. Equally some of this demand should be managed by
encouraging alternatives to car use, even if low emissions vehicles such as
through proposal 4.2.1a “to prioritise more sustainable travel”.
Finally
whilst supporting proposal 4.2.3c to improve air quality through energy
efficiency programmes, we argue a fully licensed London energy company is
essential to meeting this criteria. As part of the Energy for Londoners
programme, this would ensure a coordinated approach to tackling fuel poverty,
encouraging a transition to renewable energy, and supporting electric vehicle charging.
Chapter 6. Climate Change Mitigation
and Energy
1. Do you agree that the policies and
proposals outlined will meet the Mayor's ambition to make London a zero carbon
city by 2050? Is the proposed approach and pace realistic and achievable?
PCS fully
supports the aim of zero carbon by 2050 but argues this needs to be achieved
sooner if we are to avoid the worst impacts of climate change. Therefore the
strategy requires more than ambition but boldness to take decisive and strong
decisions.
As the draft
strategy identifies, “London’s GHG emissions are dominated by buildings and
transport” including homes and workplaces (page 187). The Committee on Climate Change which
oversees the implementation of the Climate Change Act 2008, has highlighted that
the UK will struggle to meet the 4th and 5th carbon
budgets not least as we have now picked the ‘low hanging fruit’ of power
decarbonisation – namely phasing out coal fired power stations.
London, as
all regions, will have a lead role to play in tackling some of the policy gaps
identified around space heating, low carbon power generation and transport. PCS supports the proposal to introduce a system
of five year carbon budgets (page 199) as part of a London emissions pathway. However
we are extremely disappointed by the lack of vision for the Energy for
Londoners programme which could be a real lynch pin of meeting long-term zero
carbon targets. The decision not to go
ahead with a fully licensed publicly owned energy company (proposal 6.1.2b page
226/7) would be a serious mistake in our view and we would urge the London
Mayor to reconsider this.
It is also contradictory
to say that the focus should be on “the most cost effective interventions which
can be rolled out quickly without compromising future options” (page 199). The political expediency of trying to meet a
short-term objective of achieving lower energy bills within the life-time of a politician
is a systemic failure and will do exactly what the draft strategy purports to
prevent i.e. “avoidance of costly one-off reductions” (page 199).
The
“white-labelling” will tie in the GLA to an energy supply contract for some
time that will create cost implications if there is a change in policy in five
years’ time. Exactly the kind of disaster that was mentioned earlier with
respect to Myatts Field North. It is also short sighted in not understanding
the changing face of the energy system to a distributed, more localised
network. It goes against the grain of what is happening at other municipal levels
in Nottingham or Bristol for example, community energy generation, and Labour
Party policy to take back into public ownership of the transmission and
distribution of energy, alongside the creation of regional energy supply
companies.
The TUC
congress unanimously passed a climate change motion[8] in September 2017 which
fully supports these aims including a mass retrofit and insulation of homes and
buildings. Several UK trade unions,
including PCS, are also part of an international Trade Union for Energy
Democracy initiative which calls for the public ownership and democratic
control of our energy system. We
advocate that this is the only route to achieve 100% renewable energy, address
social aspects of energy such as fuel poverty through energy efficiency
programmes, ensure workers are central in the energy transition with programmes
for reskilling and training for new or repurposed well paid, unionised, jobs.
A fully
licensed publicly owned London energy company in our view will be the best
route to achieving the wider policy objectives listed under 6.2 to “develop
clean and smart, integrated energy systems utilising local and renewable energy
resources” (page 238). This will also
help to ensure an integrated approach across all of the London boroughs rather
than is happening now with a white-label company in Islington Angelic energy or
proposals for a generation supply company in Hackney for example.
2. To achieve the Mayor's zero carbon
ambition we estimate (between now and 2050), up to 100,000 homes will need to
be retrofitted every year with energy efficiency measures. Do you agree with
the Mayor’s policies and proposals to achieve his contribution to this? What
more can central government and others do to achieve this?
PCS agrees
with a retrofit programme but disagrees with the policy mechanisms. As advocated for in the one million climate
jobs campaign[9]
PCS supports the creation of a National Climate Service that would oversee a
mass programme of retrofit and insulation.
We therefore believe this should be brought within the public sector
with increased funding support from central government to undertake this work
in consultation with local authorities and communities to ensure the most
vulnerable or ‘leaky’ homes and buildings are addressed first.
PCS is
generally opposed to carbon offsetting measures (page 219, 231) as it’s merely
a way of redistributing the costs of carbon to other parts of the economy. Given the very real challenges now faced in
decarbonising across the whole economy as outlined by the Committee on Climate
Change, we need real, long-term, solutions, not ‘greenwash’.
3. Which policies or programmes would
most motivate businesses to reduce energy use and carbon emissions?
Policy 6.1.5
should provide a good incentive to show which businesses are taking their
climate obligations seriously. Whilst PCS does not advocate for league tables,
clearly there will be advantages for businesses with an increasingly climate conscious
London citizen that will favour those which take their energy use and carbon
emissions practices seriously.
Particularly where this is also enshrined within public sector
procurement guidelines.
4. Please provide any further comments
on the policies and programmes mentioned in this chapter, including those in
the draft solar action plan and draft fuel poverty action plan that accompany
this strategy.
In support of
Policy 6.1.4 and earlier ones on retrofitting, there needs to be work in
developing and supporting training into zero carbon construction across all the
construction trades. Bringing these services in-house as part of public sector
work including in a publicly owned London energy company would ensure well paid
and unionised work.
Chapter 10: Transition to a low carbon
circular economy
As reiterated
throughout this consultation response, there is no mention of the role of
workers in this transition. This is a critical oversight and there needs to be
a section here on a Just Transition approach for workers and communities.
We welcome
proposal 10.1.1f but needs to go further in fully divesting pension funds from
fossil fuels. There also needs to be a
serious reinvestment programme that includes seeing how funds can be used for a
mass building programme of carbon neutral social housing, retrofit and
insulation programmes, and supporting a publicly owned London energy company.
Contact:
Sam Mason
Policy Officer
Assistant General Secretary Office
Tel: 020 7801 2623
Greener Jobs Alliance
Comments on the Draft London
Environment Strategy
Introduction
The Greener Jobs Alliance (GJA) is a
partnership body inclusive of trade unions, student organisations, campaign
groups and a policy think tank. It is active on the issue of jobs and the skills
needed to transition to a low-carbon economy.
In London we work closely with local trades union
and community organisations on environmental standards. This submission is also
supported by Battersea and Wandsworth TUC and the Furzedown Low Carbon Zone.
http://www.greenerjobsalliance.co.uk/
The GJA welcomes the opportunity to comment on the London
Environment Strategy. We believe there are promising initiatives contained in
the draft. We also feel there are weaknesses that need to be addressed to
achieve the stated ambition of being ‘the greenest city in the world’.
This submission provides a general response to the 5
questions in Chapter 2 and a detailed evaluation of the Air Quality section (pages
36 – 121). For this we have used the 6
question format in the Air Quality Chapter and also include an appendix with
specific comments on the 33 proposals.
Chapter 2:
Transforming London’s Environment (Consultation Questions Page 27)
1. Do you agree with the overall vision and
principles of this draft London Environment Strategy?
We support the overall vision but feel that the
principles need strengthening. The strategy refers to the vision of a
‘transition to a circular low carbon economy’. The United Nation's Paris
Agreement http://unfccc.int/files/essential_background/convention/application/pdf/english_paris_agreement.pdf is referenced that commits the UK to such an approach.
However, the strategy should also make a reference to two further important
principles contained in the Paris Agreement:
a. That there must be a ‘just transition’: 'Taking
into account the imperatives of a just transition of the workforce and the
creation of decent work and quality jobs in accordance with nationally defined
development priorities.' This principle establishes the importance of
social justice, employment and the active engagement of working people through
their trade unions in plans to tackle climate change.
b. Article 12 of the Paris Agreement, which states
that government 'shall cooperate in taking measures, as appropriate, to enhance
climate change education, training, public awareness, public participation and
public access to information, recognizing the importance of these steps with
respect to enhancing actions under this Agreement.'
This omission in the strategy partly explains why there
is not a single reference in the 400 pages to any engagement with the workforce
and recognised trades unions.
References to ‘partners’ and ‘stakeholders’ are insufficient
since experience tells us that workers and their representatives are often
ignored. Worse they are sometimes victimised. For example, the ongoing case in
the Construction Industry of union reps who have raised concerns about exposure
to pollution and poor health and safety standards, and been blacklisted.
The Mayor should encourage the recognition of Workplace
Environment Reps to promote the engagement of workers. This will be
particularly important to realise the ambitions in Chapter 8 – Adapting to
Climate Change. The strategy correctly points to the importance of work as a
major contributor to both the problems of climate change and solutions.
Consulting worker reps will provide an opportunity to listen to both workforce
concerns and find potential solutions to climate change mitigation measures.
Using these channels will also provide the best way to raise awareness. GLA
Group Operations should initiate discussions on this with GLA recognised unions
in line with Chapter 11 of the strategy ‘GLA - Leading by Example.’
Proposal – Insert
a reference to a ‘Just Transition’ in the strategy and make a commitment to
engage with the workforce and their recognised trades unions on implementation.
2. To achieve the policies and proposals in
this strategy, which organisations should the Mayor call upon to do more (for
example central and local government and business) and what should the
priorities be?
Achieving the aims in the strategy requires a much greater
focus on businesses and the workplace. As the strategy indicates workplaces are
responsible for over half of greenhouse gas emissions. Despite this there is
very little focus in the document on business obligations. For example, in
Chapter 6 ‘Climate Change and Energy’ there should be much clearer
expectations. The proposal to replicate national Carbon Budgets in the GLA is a
good one. It should also be practiced by all large employers in London. The
Mayor should call upon Government to introduce an Environment Act that makes
this a legal duty. Prior to any legal changes the GLA should seek to establish
a voluntary code on this and link it where possible to procurement policy.
Proposal – Insert
a section into each relevant chapter that sets out the obligations of employers
and how they can contribute to GLA targets and objectives.
3. Do you agree that this draft London
Environment Strategy covers all the major environmental issues facing London?
No. There is insufficient recognition that dealing with the
environment crisis can help deal with the economic crisis. An opportunity has
been missed to look at the potential for job creation and apprenticeships. A
much stronger connection needs to be made in Chapter 10 ‘Transition to a low
carbon circular economy’ with skills and jobs. For example, the London Economic
Action Partnership, isn’t referenced. It
should be asked to map a skills policy against the environment strategy. Apprenticeships
should be assessed against how they can deliver on part of the strategy. For
example, Air Quality. The GLA should consider directly recruiting, or work with
a company like Siemens, to recruit Air Quality apprentices. They could then be
employed to engage with local businesses and communities to assist with
monitoring and introduction of control measures. This would have the combined
benefit of job creation and facilitating local action on the air quality
objectives.
Energy generation, distribution and supply are key elements
of the transition to a low carbon economy. The Mayor can play a vital role in
promoting democratic ownership and accountability of all 3 strands. In Chapter
6 ‘Climate Change Mitigation and Energy’ there is a reference to the ‘Energy
for Londoners’ programme. This fails to address the issue of democratic control
and accountability. An opportunity has been missed to tap into the public
demand for energy to be brought back into the public sector.
Proposal – Identify
the opportunities for much closer working between the Mayor’s teams. For
example, the Environment, Skills and Business teams need a co-ordinated plan to
show how job creation and skills can be enhanced through the strategy
objectives.
4. There are a number of targets and
milestones in this draft London Environment Strategy, what do you think are the
main key performance indicators that would demonstrate progress against this
integrated strategy?
Much greater clarity is need on KPIs. There are 6 strategic
aims listed on Page 23. Three of them only refer to a 2050 target. One
references a couple of shorter time frames. The remaining two have no target
date mentioned. The KPIs referenced in the Air Quality chapter are clearly set
out even though a case can be made for bringing forward the target dates. The
other 10 policy areas require a similar roadmap to the one found on Page 108
for Zero Emission Rad Transport.
Proposal – Shorter
term milestones needed and mapped across to each policy and set of proposals.
These KPIs should then be subject to annual review where appropriate. Without
this there is a risk that the policies will just become a set of good
intentions.
5. What are the most important changes
Londoners may need to make to achieve the outcomes and ambition for this
strategy? What are the best ways to support them to do this?
Londoners need a far greater understanding of climate change
and the impact on jobs and their communities. The inequalities referenced in
the strategy highlight the need to ensure that measures need to be targeted
primarily at those who are most at risk and are under greater pressure to focus
on other immediate issues of surviving in an unequal society. The requirements
in the Paris agreement to provide climate awareness and training to citizens is
not adequately reflected in the strategy. This needs to cover both formal and
informal education. The school and tertiary sector need to be referenced as
well as community organisations.
Proposal – Insert
a Chapter on Education for Sustainable Development. Provide resources and
guidance to organisations who can mainstream the policies contained in the
strategy into the curriculum. Include programmes that also support workplace
and community based training.
Chapter 4: Air
Quality (Consultation Questions Page 121)
1. Do you agree that the policies and
proposals outlined will meet the Mayor’s ambitions for air quality in London
and zero emission transport by 2050? Is the proposed approach and pace
realistic and achievable, and what further powers might be required?
There is little guarantee that these proposals will achieve
the 2050 targets. This is partly due to the many determining factors that are
outside the Mayor’s control. It is why the overall aim in the opening section
that states ‘London will have the best air quality of any major world city by
2050, going beyond the legal requirements to protect human health and minimise
inequalities’ (Page 38) is laudable but problematic. We support high ambition, but the purpose of a strategy is to
deliver what is in your control. The GLA don’t know what other cities will
deliver on air quality and many of the policies needed are dependent on central
government and others.
A glaring omission in the policies is any clear reference to
the role of employers. This is unfortunate given the data in the document about
sources of pollution. Half of pollution emissions are transport related and
most of these are linked to work. The other half are designated as ‘Other’ and
are broken down into 6 categories. 5 of these are primarily business related –
construction, industrial, commercial, aviation and river. Most air pollution is
therefore created by work, and people travelling to and from work. Workers are
exposed to and create pollution to fulfil contractual obligations to employers.
Since it follows that most air pollution is a product of the relationship
between employers and workers why is more not being said about getting
employers to address the causes of this environmental disaster?
There is not a single generic reference to the word
employers or businesses in any of the 33 proposals contained in the section!
There are references to ‘other partners’, ‘stakeholders’, ‘relevant groups’ but
no indication that the business sector has any responsibility or role to play.
Proposals 4.2.3.a and b do refer to the construction industry but surely
employer responsibilities extend beyond that. This compares with some local
authority action plans which at least give a nod in that direction. Their
proposals for employers are however largely limited to advising employees of
better travel options.
Guidance from NICE published in June, 2017 on ‘Air
Pollution: outdoor air quality and health’ also specifies employers as one of
the 6 target groups for the guidance.
Air pollution is an occupational health hazard and includes
both internal and external pollution. Apart from the workforce it can also
impact on the wider community as a public health hazard. The Mayor’s strategy
needs to reflect that. Health and safety legislation has a role to play but in
its current form does not provide a sufficiently clear duty on employers to address
the problem. The Mayor has limited powers here but should at the very least be
engaging with employers to contribute to solutions. Businesses who have
procurement contracts with the GLA should identify their emissions and show how
they intend to reduce them.
A voluntary scheme prior to a duty in a new Environment
Protection or Clean Air Act would serve to underpin the principle that the
polluter pays. Imposing a congestion / polluting charge on vehicles does not
achieve this at the scale required. It also often means that the individual
worker using their own vehicle ends up paying even though it serves the
employers interest to have them available for work. There are social justice
issues here of increased air pollution financial burdens falling on workers with
less ability to pay. It is similar to the regressive characteristics of the T
(Toxicity) Charge introduced on 23/10/17. It hits the low paid hardest who are
more likely to have older polluting vehicles.
Finally, the pace of change in the strategy fails to reflect
the urgency of this public health emergency. An end date of 2050 to make the
transport system zero emission is not ambitious enough. 32 years to achieve
this is too long and the timescale should be reduced by 10 years to complete in
2040.
Proposal – The
strategy needs a much clearer focus on the role of employers and businesses.
Their responsibilities should be more commensurate with their role in
generating air pollution.
2. Do you agree with the Mayor’s policies and
proposals to raise Londoners’ awareness of the impacts of poor air quality?
Yes, but they are too limited. Empowerment is not only about
providing information it is about supporting those who want to act on the information.
The Mayor needs to promote networks of community activists who can support
empowerment. This means supporting skills development and awareness to reduce
exposures. For example, workers are vulnerable to victimisation if they raise
concerns about poor air quality. In workplaces that have high emissions it
means working with trades unions and others to give employees a voice.
Monitoring undertaken by trade union and community activists
can be an important way to empower people and help demystify the science. The
Mayor needs to work with local authorities to facilitate opportunities for
‘citizen science’ projects in pollution hot spots. The Mayor should scale up
the work that takes place in schools to raise awareness. Equally more support
for awareness raising in colleges and universities could generate more
community engagement.
Proposal – The
strategy needs a funded workplace and community engagement programme to raise
awareness and that also contributes to air monitoring and control measures. This
proposal is an example of an education for sustainable development mentioned
above.
3. Do you agree with the Mayor’s policies and
proposals to safeguard the most vulnerable from poor air quality?
The Mayor aims to do more to protect London’s schoolchildren
by reducing their exposure to poor air quality at school and on their journey
to and from school. The proposal needs to include all education locations not
just schools. This point is referenced in the text but needs to be stated in
the proposal to ensure it receives proper attention. The fact is some of the
most polluted workplaces / locations are in the FHE sector in London. For
example, studies have shown that 42% of all London FE colleges are in areas
exceeding EU limits. The schools audit programme should be extended to tertiary
education.
Another potentially vulnerable group are workers who raise
air pollution concerns with their employer. The history of blacklisting in UK
industry illustrates the victimisation that can take place. The Mayor needs to lend
his voice to the call for legal rights for workers to be represented on
environmental issues.
4. Would you support emergency measures, such
as short-term road closures or vehicle restriction, during the periods of worst
air pollution (normally once or twice a year)?
Yes.
5. Do you agree with the proposed approach to
reducing emissions from non-transport sources (including new buildings,
construction equipment, rail and river vehicles and solid fuel burning)?
Yes. These proposals will require stringent monitoring and
enforcement. Currently the Environment Performance Plans of many construction
companies are not implemented effectively leading to higher pollution levels.
The Mayor needs to co-ordinate an effective strategy with London Boroughs to
target employers suspected of breaching their obligations.
It is already clear that employers are not doing enough to
support the UK climate targets. New research from the
Carbon Disclosure Project (CDP) found that only 14% of its sample of 1,073
large companies around the world had “science-based targets” – that is, goals
to reduce carbon emissions which are in line with the global agreement to hold
warming to no more than 2C.
The Mayor has correctly drawn the link between air quality
and climate change. New measures need to be introduced which promote
accountability. In the absence of a legal requirement, the Mayor should develop
a voluntary code which large employers would be encouraged to sign up to. This
would provide information on carbon emissions and a timetable for reductions
that is consistent with both the GLA Environment Strategy and UK Carbon budgets
up to 2050.
6. Please provide any
further comments on the policies and programmes mentioned in this chapter.
Freight - The
Mayor aims to reduce emissions from freight through encouraging a switch to
lower emission vehicles, adopting smarter practices and reducing freight
movements through better use of consolidated trips. It is clear employers in
the freight sector are not doing enough to minimise emissions. In the absence
of effective legislation, the Mayor should initiate a scheme whereby large
employers are encouraged to produce a publicly available document indicating
their current distribution patterns. Town centre plans should then be drawn up
aimed at reducing the number of trips and / or rescheduling to less congested
periods.
Taxis – Switching
to zero carbon taxis will be an important step forward. However, the proposal
is silent on the question of who pays for the new vehicles?
Conclusion
The Mayor needs to address the role of public and private
sector employers in this strategy. There also needs to be a much clearer role
for workers and trades unions – not mentioned once in the document. Nowhere is
this omission more obvious than the Chapter 10 – ‘Transition to a low carbon
economy’. The draft strategy references the Paris Agreement as a driver for
action. This contained an important statement about the need for ‘a just transition’. Unfortunately this
requirement doesn’t figure at all in Chapter 10 or anywhere else in the
document.
The reason why Governments signed off on this principle is
because there was a recognition that workers should not be disadvantaged during
the transition. The proposals in the strategy are far-reaching and they also
have implications for the employment of workers across a range of sectors.
Just Transition is a framework that has been developed by the trade
union movement to encompass a range of social interventions needed to secure
workers' jobs and livelihoods when economies are shifting to sustainable
production, including avoiding climate change. Trade unions are important
stakeholders in the transition to a low carbon economy and failing to reference
this in the strategy needs to be addressed.
Graham Petersen
Sent on behalf of:
Battersea and Wandsworth Trades Union Council, Furzedown Low
Carbon Zone and Greener Jobs Alliance.
15/11/17
AIR
QUALITY APPENDIX – Comments
(in italics) against specific proposals.
. OBJECTIVE 4.1 SUPPORT LONDON AND ITS
COMMUNITIES, PARTICULARLY THE MOST VULNERABLE AND THOSE IN PRIORITY LOCATIONS,
TO HELP EMPOWER PEOPLE TO REDUCE THEIR EXPOSURE TO POOR AIR QUALITY.
Policy 4.1.1 Make
sure that London and its communities, particularly the most vulnerable and
those in priority locations, are empowered to reduce their exposure to poor air
quality.
Comment
– Empowerment is not only about
providing information it is about supporting those who want to act on the
information. The Mayor needs to promote networks of community activists who can
support empowerment. This means supporting skills development and awareness to
reduce exposures. For example, workers are vulnerable to victimisation if they
raise concerns about poor air quality. In workplaces that have high emissions
it means working with trades unions and others to give employees a voice.
Proposal 4.1.1b The
Mayor will aim to do more to protect London’s schoolchildren by reducing their
exposure to poor air quality at school and on their journey to and from school.
Comment
– The proposal needs to include
all education locations not just schools. This point is referenced in the text
but needs to be stated in the proposal to ensure it receives proper attention.
The fact is some of the most polluted workplaces / locations are in the FHE
sector in London. For example, studies have shown that 42% of all London FE
colleges are in areas exceeding EU limits. The schools audit programme should
be extended to tertiary education.
Proposal 4.1.1c Through the London Plan the Mayor will
consider policies that mean new developments are suitable for use and for their
particular location, taking into account local air quality.
Comment – We welcome the cross-referencing
to the London Plan. However, it will be important to see what powers local
communities will have to prevent developments that are not consistent with air
quality or wider social justice issues.
Policy 4.1.2 Improve
the understanding of air quality health impacts to better target policies and
action.
Proposal 4.1.2a The Mayor will produce and maintain the
London Atmospheric Emissions Inventory (LAEI) to better understand pollution
sources in London.
Proposal 4.1.2b The Mayor will work with boroughs to
safeguard the existing air quality monitoring network and enhance it by
exploiting new technologies and approaches such as personal and localised
monitoring.
OBJECTIVE 4.2 ACHIEVE
LEGAL COMPLIANCE WITH UK AND EU LIMITS AS SOON AS POSSIBLE, INCLUDING BY
MOBILISING ACTION FROM LONDON BOROUGHS, GOVERNMENT AND OTHER PARTNERS.
Policy 4.2.1 Reduce
emissions from London’s road transport network by phasing out fossil fuelled
vehicles, prioritising action on diesel, and enabling Londoners to switch to
more sustainable forms of transport.
Proposal 4.2.1a The Mayor will promote and prioritise more
sustainable travel in London including walking, cycling and public transport,
as part of the Healthy Streets Approach.
Comment - Much more recognition
is needed in this proposal of the reason why people use cars. The current
alternatives are either not considered safe, are too expensive or not efficient
for the journeys needed. It also fails to recognise that the majority of
vehicle use is work-related. It follows that employers should have much clearer
responsibilities. The Mayor needs to encourage employers to support their
workforce to make the switch. This could be done by providing a lead where the
GLA is the employer.
Proposal 4.2.1b The Mayor, through TfL, will clean up the
bus fleet by phasing out fossil fuels, prioritising action on diesel, and
switching to zero emission technologies.
Comment – Figure 12 on
Page 75 is confusing. It states that TfL will ‘buy only electric or hydrogen
double decks’ in the’ Now’ column and then repeats the pledge in the ‘2025’
column.
Proposal 4.2.1c The Mayor, through TfL, will reduce
emissions in the taxi and private hire fleet by phasing out fossil fuels,
prioritising action on diesel, and switching to zero emission technologies.
Comment – This proposal
has major implications for the livelihoods of thousands of taxi drivers in
London. It provides an opportunity to ensure a just transition to a cleaner
sector. This will only be achieved if there is full consultation with drivers
and relevant trades unions over the introduction of incentives and other
measures for the industry.
Proposal 4.2.1d The Mayor aims to reduce emissions from
private and commercial vehicles by phasing out and restricting the use of fossil
fuels, prioritising action on diesel.
Proposal 4.2.1e The
Mayor aims to reduce emissions from freight through encouraging a switch to
lower emission vehicles, adopting smarter practices and reducing freight
movements through better use of consolidated trips.
Comment
– It is clear employers in the
freight sector are not doing enough to minimise emissions. In the absence of
effective legislation, the Mayor should initiate a scheme whereby large
employers have to produce a publicly available document indicating their
current distribution patterns. Town centre plans should then be drawn up aimed
at reducing the number of trips and / or rescheduling to less congested
periods.
Proposal 4.2.1f The Mayor will work with stakeholders to
understand the barriers to deploying ultra low emission auxiliary power units
on vehicles and encourage further take up in London.
Policy 4.2.2 Reduce
emissions from non-road transport sources, including by phasing out fossil
fuels.
Proposal 4.2.2a The Mayor will work with government and
relevant groups to reduce emissions from activity on London’s waterways.
Proposal 4.2.2b The Mayor will work with government and
other partners to seek reductions in emissions from aviation activity in London
and the south east particularly from Heathrow.
Proposal 4.2.2c The Mayor will work with government and
other partners to seek reductions in emissions from rail transport and at
stations.
Comment – These proposals
are welcome but must be achieved in a way that engages with the workforce in
all 3 sectors. It needs to be clear that ‘other partners’ includes the relevant
trades unions that that represent employees who will be impacted by proposed
changes.
Policy 4.2.3 Reduce
emissions from non-transport sources, including by phasing out fossil fuels
Proposal 4.2.3a The Mayor will work with government, TfL,
the London boroughs, the construction industry and other users of Non-Road
Mobile Machinery (NRMM), such as event organisers, to prevent or reduce NRMM
emissions.
Proposal 4.2.3b The Mayor will work with industry and other
partners to seek reductions in emissions from construction and demolition sites.
Proposal 4.2.3c The Mayor aims to improve London’s air
quality by reducing emissions from homes and workplaces, including through
energy efficiency programmes.
Comment – Energy
efficiency is a vital part of any emissions strategy but the reference is far too vague. Re:New and Re:Fit, the programmes
referenced, require a massive expansion if they are to address this. Re:New
which supports energy efficiency in homes has only directly supported less than
5% of households in London since it was set up. London has some of the least
energy efficient housing stock in Europe and yet programmes have been based on
short-term funding for projects that are not able to finance the kind of
insulation measures needed. A far more comprehensive programme is required and
one that also addresses the current dependence on European funding.
Proposal 4.2.3d The Mayor will work with government to seek
reductions in emissions from large scale generators producing power for
commercial buildings in London.
Proposal 4.2.3e Through the London Plan the Mayor will
consider policies to reduce the impact of new industrial and waste sites on
local air quality. The Mayor will also work with regulators and industry to
reduce emissions from existing sites and will address the antisocial burning of
waste and the inappropriate use of bonfires.
Policy 4.2.4 The
Mayor will work with the government, the London boroughs and other partners to
accelerate the achievement of legal limits in Greater London and improve air
quality.
Proposal 4.2.4a The Mayor will use the London Local Air
Quality Management (LLAQM) framework to assist and require boroughs to exercise
their statutory duties to improve air quality and will exercise statutory
powers as required.
Proposal 4.2.4b The Mayor will work with the government to
achieve full legal compliance with UK and EU limits as soon as possible.
Comment – The 18 actions
listed here are all needed. There are additional ones that are needed to ensure
that objectives are realised. These include targeted measures for employers:
i)
Introduction
of clear legal duties on employers. The current statutory framework fails to
address the direct and indirect external emissions of businesses. Outdoor and
internal pollution are occupational health risks that employees are exposed to.
They must be provided with information and support to reduce these exposures.
Recognised trades unions must be consulted on the adoption of appropriate
control measures.
ii)
Increase
funding to the HSE and the Environment Agency to ensure that standards are
effectively regulated.
Proposal 4.2.4c The Mayor will work with European
institutions, other European cities and city networks on efforts to minimise
transboundary pollutions.
Policy 4.2.5 The
Mayor will work with other cities (here and internationally), global city and
industry networks to share best practice, lead action and support
evidence-based steps to improve air quality.
{no proposal with
this policy}
OBJECTIVE 4.3
ESTABLISH AND ACHIEVE NEW, TIGHTER AIR QUALITY TARGETS FOR A CLEANER LONDON BY
TRANSITIONING TO A ZERO EMISSION LONDON BY 2050, MEETING WORLD HEALTH
ORGANISATION HEALTHBASED GUIDELINES FOR AIR QUALITY.
Policy 4.3.1 The
Mayor will establish new targets for PM2.5 and other pollutants where needed.
The Mayor will seek to meet these targets as soon as possible, working with
government and other partners.
Proposal 4.3.1a The Mayor will set new concentration targets
for PM2.5, with the aim of meeting World Health Organisation guidelines by 2030.
Policy 4.3.2 The
Mayor will encourage the take up of ultra low and zero emission technologies to
make sure London’s entire transport system is zero emission by 2050 to further
reduce levels of pollution and achieve WHO air quality guidelines.
Proposal 4.3.2a The Mayor, through TfL, will ensure all
taxis and private hire vehicles are zero emission capable by 2033 and the bus
fleet is entirely zero emission by 2037.
Proposal 4.3.2b The Mayor, working in partnership, will
reduce emissions from fleet vehicles in the GLA group, the London boroughs and
the wider public sector by switching to zero emission capable vehicles.
Proposal 4.3.2c The Mayor, working with government, TfL, the
London boroughs and industry will aim for London’s entire transport system to
be zero emission by 2050.
Proposal 4.3.2d The Mayor, through TfL and the boroughs, and
working with government, will implement local zero emission zones in town
centres and aim to deliver a central London zero emission zone from 2025, as
well as broader congestion reduction measures, to pave the way to larger zero
emission zones in inner London by 2040 and then London-wide by 2050 at the
latest.
Proposal 4.3.2e The Mayor will work with the industry and
other partners to seek solutions to reduce emissions from tyre and brake wear.
Comment – These proposals
are welcome but fail to sufficiently address the urgency of air pollution
measures.
Policy 4.3.3 Phase
out the use of fossil fuels to heat, cool and maintain London’s buildings,
homes and urban spaces and reduce the impact of building emissions on air
quality
Proposal 4.3.3a Through the new London Plan, the Mayor will
consider policies so that all new large-scale developments in London are ‘Air
Quality Positive’, and maintain Air Quality Neutral requirements for all other
developments.
Proposal 4.3.3b Through the new London Plan, the Mayor will
consider new policies on heat and power provision to make sure CO2 and
pollution targets are achieved in a coordinated way with no air quality
disbenefits.
Proposal 4.3.3c The Mayor, working with London’s boroughs
and other partners, will seek to reduce emissions from wood and other solid
fuel burning in London.
Policy 4.3.4 Work to
reduce exposure to indoor air pollutants in the home, schools, workplace and
other enclosed spaces
Proposal 4.3.4a The Mayor, through educational materials,
campaigns and the planning system will raise awareness about indoor air quality.
Proposal 4.3.4b The Mayor, through TfL, will conduct further
research into the health risks of particulate matter on the London Underground
network and take appropriate measures to mitigate the adverse effects of any
risks found where practicable.
Comment – There is a
failure here to recognise the specific duties on employers and businesses that
own and run workplaces where indoor air pollution is at dangerous levels. Many
employers fail to carry out their responsibilities in this area because they
are concerned it will have a negative impact on employees and in some cases
members of the public. For example, high street chains who fear that it will
influence foot fall in their shops. In the absence of any new legal
requirements on employers in new legislation (eg. Clean Air Act and / or
Environment Protection Act) the Mayor will need to have a robust voluntary
programme in place to ensure that employers implement appropriate control
measures.
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