Changing places: advancing local government action on climate change

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changing places

advancing local government action on climate change


changing places advancing local government action on climate change by Tracy Carty and Hannah Hislop Published by Green Alliance, August 2007 Designed by Upstream and printed by Calverts © Green Alliance 2007 £5 ISBN 978-1-905869-05-3 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, without the prior permission in writing of Green Alliance. Within the UK, exceptions are allowed in respect of any fair dealing for the purposes of private research or study, or criticism or review, as permitted under the Copyright, Design and Patents Act, 1988, or in the case of reprographic reproduction in accordance with the terms of the licenses issued by the Copyright Licensing Agency. This report is sold subject to condition that it shall not, by way of trade or otherwise, be lent, resold, hired out or otherwise circulated without the publisher’s prior consent in any form of binding or cover other than in which it was published and without a similar condition including the condition being imposed on a subsequent purchaser.

Green Alliance Green Alliance is an independent charity. Our mission is to promote sustainable development by ensuring that environmental solutions are a priority in British politics. We work with representatives from the three main political parties, government, business and the NGO sector to encourage new ideas, facilitate dialogue and develop constructive solutions to environmental challenges.

Acknowledgements Many thanks to the following people who have helped considerably with this report: Ian Christie, Stephen Hale, Richard Howell, Denny Gray, Dan James, Russell Marsh, Chloe Meacher, Sarah Parkin, Steve Waller, Julie Foley, Hannah Dick and all who contributed their time to be interviewed as part of the research. We are also very grateful to Communities and Local Government, Groundwork and the Environment Agency for their support of this work. The recommendations presented in this report are put forward by Green Alliance and do not necessarily represent the position of steering group members, funding partners or interviewees.


changing places advancing local government action on climate change

contents executive summary

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1.

the case for action

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the potential for action action to date

_05 _07

2.

new local government performance framework

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changes to the new performance framework climate change indicators overarching principles reporting requirements: availability and attributability of data

_10 _12 _13 _15

3.

developing effective delivery mechanisms

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local strategic partnerships sustainable community strategies local area agreements the limits to ‘grassroots’ demand

_18 _21 _21 _23

4.

strengthening the overall policy framework

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what does success look like? finance: making action possible and making performance matter skills and capacity overcoming the barriers of complexity culture change

_25 _26 _26 _27 _28

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conclusion

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glossary

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interviewees and steering group members

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notes and references

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executive summary The 2006 climate change programme was unequivocal about the need for greater action by local government in tackling climate change: “The government wants to see a significant increase in the level of engagement by local government in climate change issues”.1 This marked the start of a shift in recognising both the pivotal role of local government in tackling climate change, and the need to strengthen the policy framework to drive it. More recently, the local government white paper, Strong and prosperous communities, stated that “All local authorities can and should be taking action to combat climate change”.2 To enable local government to step up to that challenge, the white paper urges local authorities to make their place-shaping role a reality. It gives local government new opportunities to drive local action on climate change through strong community leadership and strategic clout, and to coordinate local partners and partnerships to affect change. Some local authorities are already at the forefront of climate action, but it is clear from current examples of good practice that action has tended to be reliant on ‘wilful individuals’. It is also clear that there is a long tail of authorities with a low level of ambition and interest in climate action. The current policy framework has failed to mobilise those authorities that do not see climate action as a priority. Making local climate action matter to local authorities is essential if we are to see a step change in local government performance. There is a significant need to provide incentives for councils to take action. These need to allow for greater local autonomy but, nonetheless, must ensure that the group of uninterested or minimally active authorities sits up and takes notice of climate change. The commitment in the 2006 climate change programme “to ensure that the local government performance framework will include an appropriate focus on action on climate change, sufficient to incentivise more authorities to reach the levels of the best”3 has the potential to be a huge driver for change. Action on climate change has not previously been an explicit part of the local government performance framework (LGPF), and its inclusion, in the context of a stronger role for local area agreements (LAAs), makes it a central pillar in the government’s approach to enable and encourage greater action. Indeed, the recent report by the joint committee on the draft climate change bill described it as “the single most important action the Government could take to encourage local authority action on climate change”.4 This report looks at what will be needed to bring about a major increase in the extent and quality of local authority action, focusing in particular on the role of the new LGPF and LAAs. It also examines whether the emerging policy framework is capable of delivering what is needed, and assesses some of the overall constraints and barriers to getting the policy framework right. The report draws on the results of interviews with over 20 stakeholders from central government, relevant government agencies, local government, NGOs, and elsewhere, a literature review, and previous work by Green Alliance on local government and climate change.

The case for action With responsibilities including housing, planning and transport, and the ability to encourage action by citizens, local businesses and other stakeholders, local government has the potential to make a huge contribution towards tackling climate change on the ground in the UK.


New local government performance framework The report strongly supports the Department for Environment, Food and Rural Affair’s proposed climate change indicators, which would measure progress and encourage local authority action: in the management of their own estate and operations; through their role as a place-shapers and community leaders; in tackling fuel poverty; and to build climate resilient local areas. In particular, a community emissions indicator is vital in order to challenge local authorities to raise their sights beyond their own estate, and to orchestrate and oversee action by other actors who have an impact on an area’s carbon footprint. To be effective, the new LGPF and the inclusion of climate change as a key theme must focus on progress towards delivering long-term outcomes as well as short-term impacts; reflect a national level aspiration for local climate action; and ensure that top performers are rewarded.

Developing effective delivery mechanisms Sustainable community strategies (SCSs), strengthened local strategic partnerships (LSPs) and the new LAAs have considerable potential to advance local climate action. But there are challenges that must be addressed if these delivery mechanisms are to achieve significant change. LSPs are the right vehicle for co-ordinating activity between relevant partners, and they have been highly successful in some areas. But the quality of LSPs varies and measures will be needed to boost their capacity to deliver. The new SCSs will provide greater scope to embed climate change targets and objectives into an area’s overarching strategy. But to affect change, the SCS must have the vision and political clout to influence other objectives and processes. The new LAAs will help focus local authority action on a clear set of priorities. This is a potential opportunity, but also a risk if climate change is not prioritised to the extent that is needed. LAA improvement targets must reflect the high priority given to climate change at a national level and local government’s vital role in tackling it.

Strengthening the overall policy framework Without a benchmark for success, it will not be possible to assess whether the emerging policy framework is capable of delivering. Central government must define more clearly what contribution local government should make to tackling climate change and be clear about how this fits into action on a national level to curb emissions. Financial incentives and support will be needed to ensure that local authorities are motivated

and equipped to act. And to generate funds for carbon management and climate change adaptation, the government must commit to significant new funding, or should grant councils additional revenue raising powers. Finally, government must seek to reduce the complexity local authorities face; both through the requirement to work in partnership with a range of organisations and in accessing appropriate guidance and support.

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If this is to be achieved, its role as a place-shaper and community leader will be crucial. An average council produces at least 30,000 tonnes of carbon per annum, but its local community can generate ten million tonnes.5 As such, the largest gains in reducing emissions will be made through councils enabling and encouraging citizens, local businesses and other organisations to reduce their impacts. At a local level, local authorities are uniquely placed to articulate a low carbon and climate resilient vision for an area and build coalitions to achieve this.


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1.

the case for action

Climate change is a hugely significant political challenge that will have far-reaching effects on our economy, society and the environment. The Stern review, published last year, offered the starkest warning yet: failure to act would result in devastating social impacts and trigger catastrophic global recession. The past two years have seen a steady and growing rise in the public profile of the issue in the UK and elsewhere. Much attention is placed on action at the national and international level, which is essential. But local government also has a vital role to play as many of the activities causing carbon emissions are influenced by local authority strategies, services and actions. Earlier this year, the government published a draft climate change bill, which would set legally binding carbon reduction targets and a carbon budget every five years, in a bid to cut carbon emissions by 60 per cent of 1990 levels by 2050, and 26-32 per cent by 2020.6 Progress to date towards meeting our climate change targets suggests we will need to go much further and faster if we are to realise these goals. UK emissions continue to rise and we stand little chance of achieving the carbon emission reductions needed unless every department and every level of government plays their full part.

The political response to the challenge of climate change at a local level has been mixed, some councils have developed ambitious plans for local action but the majority have taken limited steps or have regarded climate change as just too difficult or remote a problem to give it priority. There are some examples of energetic, imaginative and innovative work by local government, but there is also a long tail of under-achievers and head-in-the-sand “until recently, central government’s authorities. Where councils have developed a response, action has mainly been driven by committed individuals, but there are limits to how far this grassroots revolution approach has been can go without stronger drivers for change.

characterised by mixed messages, lack Until recently, central government’s approach to action by local government on climate change has been characterised by mixed messages, lack of leadership and of leadership and weak intervention. Gradually this is changing. The government’s climate change weak intervention”

programme in 2006 was unequivocal about the need for greater action: “The government wants to see a significant increase in the level of engagement by local government in climate change issues”.7 In a recent speech to Green Alliance, Ruth Kelly, then secretary of state for communities and local government, said that climate action presented the “opportunity for local government to step up to the challenge and build on its historic placeshaping role in a modern context”. She also described climate change as the first “test” of the new relationship between local and central government and said that central government would intervene when there were “serious failings”.8 But there has been a huge disconnect between this high level exhortation and the actual policy framework, which has not given local climate action prominence and has been a weak driver for action on the ground. However, we are now moving into a period when the pressures on councils to act are increasing. Recent and forthcoming policy developments include, the carbon reduction commitment, the draft planning policy statement on climate change, requirements under the Climate Change and Sustainable Energy Act 2006 and provisions in the local government white paper. This emerging policy framework has significant potential to improve local authority action. Importantly, the government’s commitment to include climate change in the new local government performance framework (LGPF) will be key, and will provide crucial impetus to these other developments. But there are challenges and risks associated with its inclusion


The potential for action Much of the action needed to drive sustainable development and mitigate and adapt to climate change must be taken at a local level. This puts local authorities very much in the driving seat. With responsibilities including housing, planning and transport, and the ability to encourage action by citizens, local businesses and other stakeholders in their areas, local authorities are in a unique position to tackle climate change on the ground in the UK (see Box 2). Councils are best placed to know what will work in their area, to identify opportunities to reduce greenhouse gas emissions, to plan for the effects of climate change and to embed culture change. Of course, local authorities cannot work alone - central government in particular, as well as business, NGOs and others, all have a significant role to play - but local authorities are an essential part of the equation.

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and with ensuring delivery mechanisms - sustainable community strategies (SCSs), local strategic partnerships (LSPs) and local area agreements (LAAs) - give sufficient priority to action on climate change at a local level. These challenges and risks are explored in detail in the proceeding chapters.

Climate change is one of the biggest challenges facing local government. It requires local government to think differently, largely because it is not just about classic spending decisions or service provision. It is about behavioural and cultural change and it calls for a range of linked interventions, many of them challenging and sometimes requiring short-term costs to achieve longer-term benefits.

Box 1: Local government’s footprint9 l An average council produces at least 30,000 tonnes of carbon per annum, and its local community can generate ten million tonnes l Local government’s procurement spend in 2005-06 was £50 billion l Bristol City Council alone spends £6 million on energy l Local government’s capital spend in 2005-06 was £17 billion of which £4.5 billion was on housing and £3.5 billion was on transport

Shaping low carbon places Local government’s place-shaping and community leadership role is a consistent vision that provides the basis for current and proposed local government reform. Both the Lyons review and the local government white paper articulate a role for local authorities as community leaders and shapers of place. Sir Michael Lyons describes place-shaping as the “creative use of powers and influence to promote the general well-being of a community and its citizens”.10 The role envisaged is one that requires local government to go beyond its “if local government traditional function as direct service provider towards the orchestration of services is to achieve its full and strategies for a whole area and its communities.

potential in tackling If local government is to achieve its full potential in tackling climate change, its role climate change, its as a place-shaper and community leader will be crucial. An average council produces role as a place-shaper at least 30,000 tonnes of carbon per annum, but its local community can generate and community ten million tonnes.11 As such, the largest gains in reducing emissions will be made leader will be crucial”

through councils enabling and encouraging citizens, local businesses and other organisations to reduce their impacts.


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Indeed, climate change is a complex collective action problem that requires long-term vision from policy-makers across sectors: it can only be addressed if government, business, NGOs and others play their full part. At a local level, local authorities are uniquely placed to articulate and deliver that vision, building coalitions based on a common mission with local partners, businesses and residents. To enable local government to carry out this role, the white paper urges local authorities to make their place-shaping role a priority. It gives local government new opportunities to drive local action on climate change through strong community leadership and strategic clout, and to co-ordinate local partners and partnerships to affect change. The new performance framework has a potentially strong role in driving change and providing incentives for local government and its partners to act. The strengthened role of LAAs also provides a mechanism for joining-up and co-ordinating delivery on shared local objectives. The potential role of the new performance framework and LAAs in catalysing action on climate change, as well as the issues and challenges behind this, are explored in detail in the following chapters.

“the effects of climate change will not just be felt in far-flung corners of the world: they will be local and directly affect the communities that local authorities serve�

Adapting to change It is important to underline the pivotal role of local authorities in climate change adaptation. National leadership and action on this issue is absolutely critical, but local authorities also have a significant role to play in building climate resilient areas. The causes of climate change are global but its impacts are local and actions to adapt to climate change are very location-specific. The effects of climate change will not just be felt in far-flung corners of the world: they will be local and directly affect the communities that local authorities serve.

Already impacts have been seen which are fully consistent with forecasts of climate change: extreme rainfall and flooding leading to severe disruption in many communities in the UK; the staggering number of elderly people who died across Europe in the summer heatwave of 2003; and the major problems of water supply now being experienced in southern Europe. Although we cannot directly attribute a particular episode of severe weather to climate change, we do know that the greenhouse gas concentrations that are already in the atmosphere, and the cumulative effect of current and expected emissions, mean that some climate change is inevitable, despite action to reduce emissions significantly over the next few decades. In light of this, it is clear that adaptation is essential if we are to protect local communities from potentially devastating impacts in the longer-term. The process of adapting to climate change will affect many aspects of local authority activity. For example, in planning and development decisions local authorities will need to have regard to how the climate is expected to change during the lifetime of new infrastructure and buildings, and development plans will need to consider the need for more open and green spaces to offset the increase in temperatures that is expected.

Challenge and opportunity Climate change is a challenge, but local climate action also provides an opportunity to address other issues such as: the generation of new employment opportunities in an area; lowering fuel bills and helping to tackle fuel poverty and its health effects; more efficient use of resources in public services; improving the transport system and access for people living and working in an area.


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The scope for local authority action to mitigate and adapt to climate change falls into three main categories: Managing their own estate: Local authorities can lead by example through their own practices and the services they deliver, including contracted out services such as leisure and waste. Actions include more efficient energy use, supporting the development of renewable and low carbon local energy systems, and improving vehicle efficiency.

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Box 2: The scope for local authority action

Service provision: Local government delivers services that can make a significant difference to the carbon footprint of an area, through local transport, provision of housing, measures to address fuel poverty, planning, enforcement of building regulations and waste services. Moreover, local authorities have considerable purchasing power and expenditure programmes that can be used to deliver carbon reductions and stimulate markets for low carbon technologies and services. Community leadership and place-shaping: Local authorities can provide strong and visible leadership for climate action at the local level, both by creating and responding to public demand for action. They are uniquely placed to provide leadership in the community through their contact with every household through the democratic process and the provision of services. Local authorities can work with faith groups, schools and community groups to raise awareness of climate change and of ways to reduce individual and corporate impacts on the environment.

Action to date Many local authorities are already at the forefront of combating climate change. Change has been driven by local action with local government very much ahead of national government, leading the agenda, not following it. The Nottingham Declaration, a voluntary initiative sparked by the Local Government Association and the Improvement and Development Agency, has been influential in generating local authority interest. The declaration is a statement of a council’s intention to take action on climate change within two years. Among other things it commits the signatory authority to developing plans to address climate change with partners and local communities. More than 230 councils have already signed it, and the government welcomes the declaration. However, up to ten per cent of councils have chosen not to sign because they were either already early movers or did not see climate change as a council issue, and many have “if all local authorities yet to sign. followed the lead

of the best UK

In the mixed bag of local authority performance on climate action, there are some tremendous success stories (see Box 3 for examples of action to tackle energy use). If all emissions could be local authorities followed the lead of the best (the actions of Merton, Woking, Kirklees, cut significantly� and Bristol councils to name a few of the pioneers) then UK emissions could be cut significantly. But there is a huge gulf between this best practice and the rest. The local government white paper states that all local authorities can and should be taking action to tackle climate change.12 This is the right ambition, but there is a long way to go towards making it a reality.


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Research shows that action has tended to be led by wilful individuals with vision and determination,13 which suggests that the current mix of carrots and sticks has not been enough to mobilise an organisational focus on climate change. In many cases where local authorities have taken action, the driving force has been potential financial savings for the council or their residents in social housing. Of those who are active, there is little evidence of authorities taking a comprehensive approach to tackling climate change.14 The Tyndall Centre looked at the websites of 188 signatories of the Nottingham Declaration, and found that just 50 councils had climate change strategies. Where they did exist, few were comprehensive across the relevant areas of local council control.15 So while the declaration is an indicator of willingness to take climate action seriously it is not yet a measure of the quality of “although there has strategic commitment.

been innovative and significant action in some areas, climate change is not yet a mainstream agenda in local government�

There has been little analysis to date of the quality of practice in most - that is, nonexemplar - authorities and regions.16 There are around 140-150 local authorities that have no known commitment to action on climate change.17 It is usually the smaller district councils that are the least active performers, and who will struggle with delivery and will need far more support in the future. However, some major authorities have also yet to show much initiative or strategic commitment to action.

In conclusion, although there has been innovative and significant action in some areas, climate change is not yet a mainstream agenda in local government. The main barrier to local authority action has not been lack of power to act but a clear remit to do so. Therefore, the commitment to include climate change in the new LGPF, in the context of a strengthened role for LAAs, has the potential to be a significant driver for change. The following section examines what will be needed to incorporate climate change effectively and ensure it incentivises action at a local level on the scale needed.


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Council tax rebates for energy efficiency In 2004, British Gas trialled a scheme with Braintree District Council to encourage residents to become more energy efficient. In return for the installation of cavity wall insulation in their homes (subsidised by British Gas) householders receive a one off rebate of up to £100 on their council tax bill. Fifty-seven local authorities are now signed up to the scheme and 10,000 installations have now been completed. In March this year, British Gas announced it was to extend the scheme to include microgeneration, meaning homeowners will be eligible for a rebate on their council tax bill of up to £500 if they install solar panels on their property. This is being piloted by six local authorities.

Birmingham city energy service company In December 2006, Birmingham became the first core city to launch its own energy service company (ESCo): the Birmingham District Energy Company, in partnership with Utilicom. It will deliver combined heat and power (CHP) district energy schemes that will assist public and private sector organisations in the area to meet their energy needs. The first CHP plant, currently being installed in the centre of Birmingham, will be fully operational by November 2007.

Kirklees warm zone Warm Zones were set up in 2000 with government support to develop new approaches to fuel poverty, largely by improving energy efficiency. Kirklees Metropolitan Council funds the UK’s largest Warm Zone scheme. This will cover 140 thousand homes regardless of homeowner income over three years, and is anticipated to reduce borough domestic sector emissions by two to five and a half per cent. Rollout of Kirklees Warm Zone via a door-to-door campaign commenced earlier this year. Every household is offered free energy checks, low energy light bulbs, cavity wall and roof insulation in addition to other measures where applicable. The scheme provides the borough’s entire population a single route to efficiency measures, avoiding the confusion of a half dozen national schemes and funding frameworks.

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Box 3: Examples of local authority action to tackle energy use


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2. new local government performance framework Proposals in the local government white paper are intended to provide local authorities and their partners with the tools they need to develop greater strategic leadership and to tackle big cross-cutting challenges such as climate change. The power of well-being, enshrined in the Local Government Act 2000, gives local authorities considerable scope for action on sustainable development, including climate change policies. To date, the main feature that has been lacking in the policy framework is the statutory requirement to mitigate and adapt to climate change. Some councils have called for such a duty, but the government has been reluctant to impose further statutory duties at a time when the political pressure is for a revival of localism and a reduction in centrally imposed demands on local authorities. So there is a need for other incentives for councils to take action. These will have to allow for greater local autonomy but be nonetheless imperative, so that the group of uninterested or minimally active authorities sits up and takes notice of climate change. The obvious contender here is the use of performance assessment systems to provide a range of sticks and carrots and also set a benchmark of acceptable ambition and achievement.

“to date, action on climate change has not been an explicit part of the local government performance framework”

The white paper confirms the government’s plan, as initially set out in the 2006 climate change programme, to ensure: “the local government performance framework will include an appropriate focus on action on climate change, sufficient to incentivise more authorities to reach the levels of the best”.18

To date, action on climate change has not been an explicit part of the local government performance framework (LGPF). Its inclusion, in the context of a stronger role for local area agreements (LAAs), has the potential to be a significant driver for delivering a step change in climate action. It will send a powerful signal to local authorities about their crucial role in tackling climate change and where improvement targets on climate change are included within an LAA it will ensure that climate change is a high level political priority for a local authority and its partners. This is reinforced by the strengthened emphasis on sustainable development by the Audit Commission, which recently published a statement setting out its new approach to embed sustainable development policies within its own organisation and in the bodies it audits and inspects. The statement is a very welcome and clear indication of its expectation on those bodies to “reduce their corporate impact on the environment, that of the services they purchase and provide, and to actively work together in partnership to shape sustainable places”.19

Changes to the new performance framework National indicator set The national indicator set will be a core component of the new LGPF. From April 2008, all local areas will be expected to report against the national indicators, to provide a picture of an area’s circumstances. The indicators will be announced as part of the comprehensive spending review. At the moment there are between 600 and 1,200 indicators against which areas must report to central government. The government’s aim is to radically reduce the number of national indicators to around 200 to clarify key priorities and reduce the number of expectations placed on local authorities by central government.


Comprehensive area assessment (CAA) is scheduled for introduction in the next two years, to replace the comprehensive performance assessment (CPA). CAA will be the assessment component of the new LGPF, which among things, will utilise reporting information against the national indicator set to assess an areas prospects and capacity to improve. The scope of the CAA will consist of: l Measurement of performance against the new set of 200 outcome-focused indicators. l A risk assessment undertaken by all local service inspectorates. l A scored ‘use of resources’ judgement for each local authority, and other local service providers. l A scored ‘direction of travel’ judgement for each authority. Based on our interviews with key stakeholders and examination of relevant documents,20 the following principles underpin the emerging methodology for CAA: l Area-based focus: CAA will focus on outcomes secured by local authorities working alone or in partnership. This marks a shift in focus from local authority delivery to area-wide assessment. l From post-hoc measure of performance to pre-judgement of risk: Assessment will no longer just be about looking backwards at how a council has performed, but about looking ahead at the risks associated with whether an area will deliver against particular outcomes. The CAA will identify areas where local authorities and their partners need to improve, and where government and its agencies need to offer more targeted support, advice or intervention. Based on a judgement of circumstances and performance, inspection will assess and measure against the risk that outcomes will not be achieved. l Outcome focused: Indicators contained within the national indicator set will, where possible, be focused on outcomes rather than inputs. The intention is that local authorities and their partners will have the flexibility to decide how they deliver against each indicator, with some level of comparability across authorities. l Relevant to local people: In keeping with the move to more local targets, CAA will focus more on local needs and priorities.

Local area agreements Strengthened LAAs will be a crucial mechanism for improving an area’s performance in relation to national and local priority outcomes. They will continue to be a negotiated deal between central and local government, but their scope will be widened and their position in relation to the new LGPF strengthened. They will become the only place where central government, local authorities and local strategic partnerships (LSPs) will agree improvement targets for an area.21 Drawn from the national indicator set and taking into account the CAA, the LAA will contain a more focused set of up to 35 improvement targets for each area, reflecting particular priorities within a locality.22 The national indicator set will include a mixture of non-negotiable targets, floor targets (where an authority is not meeting minimum standards), negotiable targets (negotiations will include whether or not to have a target and if so at what level it should be set).

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Comprehensive area assessment


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Climate change indicators The starting point for considering which climate change indicators should be included in the new LGPF is to ask: what kind of performance should we be aiming for? The answer to this question is, to a large extent, set out in the previous chapter, which considers the role of local government in tackling climate change: to act to mitigate and adapt to climate change through the management of its own estate and service provision, and through its role as place-shaper and community leader. Appropriate indicators need to be included in the national set that reflect local government’s role in each of these areas. We strongly endorse the Department for Food and Rural Affair’s (Defra) proposed indicators on climate change, which have recently been published for consultation.23 In particular, we support those on mitigation relating to community carbon emissions, the management of a local authority’s own estate and operations, and tackling fuel poverty. We also support the indicator on progress towards a climate resilient local area.

Community emissions We strongly recommend the inclusion of an indicator based on a percentage carbon emission reduction per capita in the community. This could be a composite measure, which would include emissions from housing, local business, public sector and community organisations and local transport. We recommend it is a negotiated improvement target (optional). But it is vital that LAA negotiations on improvement targets are underpinned by an understanding of the national level aspiration for action by local authorities and their partners to “the new performance reduce community emissions, and that in aggregate the agreed LAAs reflect that aspiration. framework needs

to challenge local government to raise its sights beyond its own estate and to orchestrate and oversee action by other actors”

Rationale If local government is to deliver its full potential in tackling climate change, its role as a place-shaper and community leader will be crucial. Incentives will be needed to ensure that local authorities develop a more outward facing leadership role and consider the wider issues in their area. In keeping with the spirit of the white paper, the new LGPF needs to challenge local government to raise its sights beyond its own estate and to orchestrate and oversee action by other actors who have an impact on the carbon footprint of the area, such as partners, businesses and local residents.

Community emissions are affected by many factors, such as the demographic structure of an area, its local economy and average distance to work. The existence of an indicator would help local authorities to understand these various factors and their performance in relation to them, so that they are able to set local priorities accordingly.

Own estate and operations In line with Defra’s proposal we recommend the inclusion of an indicator based on a percentage carbon emission reduction of an authority’s own operations. This could be a negotiable target at first, but once baseline data of individual local authority performance has been established (following the first or second year’s reporting), it should become a floor target. This would make it non-negotiable for authorities that do not meet a minimum level of performance.

Rationale All authorities should be taking steps to reduce the carbon footprint of their own corporate estate and services (including contracted out services such as waste), an area they have direct control over. Emissions from an authority’s own estate are a small slice of the overall carbon emissions in a locality, but getting their own house in order is plainly important for their


Adaptation We support Defra’s proposals for an indicator to measure progress towards building a climate resilient local area. This would measure progress towards the development of an action plan and its implementation. We recommend that this is a negotiated improvement target so that it can be prioritised in areas where the circumstances require greater action.

Rationale It is essential that the new LGPF sends a clear message about the important role of local government in adapting to the impacts of climate change. The main challenge to incorporating adaptation into the national indicator set lies in finding an appropriate cross-cutting adaptation measure, as adapting to climate change will be geographically specific. For this reason, we recommend the indicator focuses on requiring local authorities to develop and implement an action plan, which will vary depending on the impacts in an area. This action plan might cover elements such as increases in urban tree planting; proportion of green roofs in new residential and commercial developments; proportion of local urban area covered by sustainable urban drainage systems; proportion of development at flood risk; and change in annual proportion of new development in areas of severe flood risk. Adaptation is not just about physical risks to an area, such as flooding, but also about other issues such as migration patterns and economic impacts. The UK Climate Impacts Programme has good scenarios on how climate change could hit different parts of the UK, which local authorities should be incentivised to use to climate-proof their social and economic strategies.

Fuel poverty We support the inclusion of an indicator on fuel poverty as proposed by Defra: to measure progress in tackling fuel poverty through improved energy efficiency. We recommend this is a negotiable improvement target.

Rationale Household energy use accounts for more than a quarter of all energy used in the UK, but the typical household wastes around a third of that energy each year.24 Local authorities can play an important role in promoting household energy efficiency, which will help poorer households save money. A fuel poverty indicator would encourage local authorities to introduce energy efficiency measures and work jointly with energy suppliers and others in initiatives such as the council tax rebate scheme outlined in the previous chapter.

Overarching principles Having set out which areas should be covered in the national indicator set, and whether these should be negotiable, non-negotiable or floor targets for LAAs, it is also important to outline the principles that should underpin the new performance framework and the incorporation of climate change as a key theme and an area for monitoring and benchmarking.

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community leadership role and gives them legitimacy to work in the wider area. An indicator on a local authority’s own estate would require relevant data collection. This, in turn, would incentivise councils to reduce their emissions, and would help them to better understand their own energy use and carbon footprint. This could also reduce councils’ costs by, for example, encouraging more efficient use of energy.


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climate change, social exclusion and anti-social behaviour can only be tackled if action in the short-term is in line with a longterm vision and strategy”

Long-term outcomes as well as short-term impacts The focus of the CAA on risk could help foster a more forward-looking approach on the part of local authorities to the long-term challenges climate change presents. Rather than simply judging past performance, which was the main focus of the CPA, the CAA will provide a stronger mechanism for assessing the risk to an area’s capacity to improve its performance, thereby driving improvement and supporting innovation.

The white paper underlines the need for the performance framework to measure long-term outcomes as well as short-term impact. The Lyons review also emphasised the importance of local authorities developing a long-term vision for an area, a vision owned by those communities and by local businesses.25 Both documents state that councils should focus their planning and performance management around long-term outcomes and the ultimate public value of their activities, rather than solely concentrating on narrow, short-term output measures. Nevertheless, one of the concerns expressed by a number of stakeholders we interviewed was that the LAA system could result in short-termism, with local authorities focusing on one set of issues for the course of the LAA (three years), then moving on to another set for the next round, without a long-term assessment of overall priorities as their guide. Challenges like climate change, social exclusion and anti-social behaviour can only be tackled if action in the short-term is in line with a long-term vision and strategy. To ensure coherence and effective delivery of long-term outcomes, LAAs must be the delivery plan for the sustainable community strategy, which sets out the long-term vision for an area. Moreover, an important priority for CAA, as acknowledged by the Audit Commission, must be to consider the overall risk of a local authority’s performance deteriorating. This will ensure that performance on areas not included in LAA targets do not slip down the agenda. The new LGPF also needs to guard against a short-term approach, where quality standards and progress towards long-term challenges such as climate change, are abandoned during times of financial pressure.

National level aspiration for climate action LAAs must strike a balance between the priorities of national government and local government and its partners. Climate change has become a top priority for central government over recent years and should continue to be for some time, given the scale and severity of the challenge it presents. Therefore in aggregate, the priorities agreed as part of the LAAs “the priorities must reflect national level aspiration for action on climate change at a local level.

agreed as part of the LAAs must reflect a national level aspiration for action on climate change at a local level”

Indicators relating to community emissions should be negotiable improvement targets. The negotiation of up to 35 improvement targets, which will become part of the LAA is crucial, and there is concern that the right issues will not be addressed in the negotiations. This is in part because climate change is an area where local drivers for action may not be sufficient; the benefits of action, and of mitigation in particular, are not always tangible or immediate to local communities. To help guard against community emissions not being prioritised, negotiations must be underpinned by an understanding at a national level of the aspiration for local authorities and their partners to reduce community emissions. In aggregate the agreed LAAs must reflect that aspiration. The central government demand for local authority action on climate change in general needs to be more clearly defined, as it is unclear at the moment what the expected level of ambition is. This is explored further in chapter four, which looks at the wider policy framework needed


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Resource use Sustainable procurement needs to be made part of the CAA’s ‘use of resources’ assessment. A sixth category should be introduced in the assessment to examine specifically local authorities’ efforts to procure sustainably and whether resources are used in a sustainable manner. This would encourage authorities to use their buying power to reduce their impacts - for example, by procuring green energy - and affect wider change among suppliers.

Basket of sustainable development indicators

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to support the new LGPF and LAAs, and the main barriers to action.

“climate change is an area where local drivers for action may not be sufficient”

Climate change should be part of a basket of sustainable development indicators within the national indicator set. Central and local government share the ambition to create sustainable communities that embody the principles of sustainable development at the local level. It is therefore crucial that the national indicator set includes a set of indicators on sustainable development that make it possible to assess how areas are performing in relation to this aim.

Reward performance If the new LGPF is to operate as an effective motor for change, innovation and performance improvement, there need to be rewards for the type of behaviour it is seeking to motivate. In general it is important the new LGPF rewards top performers by offering financial benefits, for example, extra money or the freedom to raise local taxes. One way of doing this and embedding sustainable development is by making a reward grant element to the LAA available to LSPs that set and achieve stretch targets for delivering sustainable development outcomes, with an emphasis on tackling climate change in their communities. This is discussed in further detail in chapter four.

Recognise indirect benefits The vision set out in the white paper is one of local authorities working with their partners to reshape public services and improve the economic, social and environmental conditions in an area. To raise the sights of local authorities and to give incentives for effective ‘place-shaping’, they must receive recognition for helping others in their area deliver outcomes. Equally, local authorities and other actors should not be penalised when the benefits of action do not accrue directly to them. Without this, there is a clear danger of entrenching short-term and compartmentalised thinking. The new LGPF must therefore reinforce the importance of local authorities seeing their assets and services in a more holistic way. For example, from a climate-aware sustainable development perspective, a parks budget is not only for a set of green spaces but also for urban cooling and shading, for public health and for biodiversity. Moreover, the budget for school meals would not simply be seen as spending on food-as-fuel but as a budget for public health, local produce and food enterprises, reduction in emissions associated with food miles and better outcomes for school pupils.

Reporting requirements: availability and attributability of data Local authorities will be expected to report against all 200 indicators in the national indicator set, and they will be assessed against them as part of the CAA. For each indicator, data will have to be collectable, affordable, understandable, reliable and comparable. To be credible, the indicators must be robust but also fair in their reporting requirements. For the potential climate change indicators outlined above this presents a number of potential challenges around the availability of relevant data and how attributable that data is to local authority performance.


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Own estate To begin the assessment process in 2009, at least one year’s baseline data will be required, which means the data should start to be collected in 2008. Many authorities already collect information about their own energy use and carbon footprint. To get all local authorities geared up to gather this data by 2008 is an achievable and very important objective, not least because understanding their own energy use and carbon footprint is the first crucial step towards identifying the action needed to reduce their emissions.

Community emissions Assessment against a community emissions indicator would need to take account of other factors that may also have an impact on greenhouse gas emissions of an area, which a local authority and its partners may have little or no control over. To build an accurate picture of performance and the risk that outcomes will not be achieved, both hard and soft intelligence will be needed. A number of stakeholders we interviewed, including the Audit Commission, underlined the intention to use this approach in the new CAA. They will use a variety of sources, for example, robust data and conversations with the bodies themselves, and the purpose of the assessment is to pull hard and soft intelligence together to make a sensible judgement. Moreover, as one stakeholder put it, the CAA “should not be about beating a community over the head or marching into a local authority and telling them how bad they are”. It is about looking at the things they do and do not have control over and assessing their performance, agreeing what may need prioritising and where advice and support may be needed. Based on our interviews with stakeholders, we are concerned that issues over attributability and availability of data could reduce the ambition of the climate change indicators to a narrow focus on that which a local authority has direct control over: their own estate. The issues around data are challenging but not insurmountable. Establishing accurate baselines and setting achievable targets are both essential, but auditing requirements should not be so onerous and rigid that they undermine the introduction of an indicator based on community emissions. Importantly, the inclusion of an indicator that only relates to the carbon footprint of the local authority itself rather than that of an area is not in line with the logic of the white paper and local government’s crucial place-shaping role. The performance framework must reflect the expectation that local authorities should lead by using their wider networks and influence to promote action on climate change within their area. Local authorities will need to be held accountable to some extent for the actions of actors in their area if they are to live up to their role as community leaders and strategic partners when it comes to climate action.


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Climate change indicators: l An indicator based on a percentage carbon emission reduction per capita in the community, which would include emissions from housing, local business, public sector and community organisations and local transport. We recommend this is a negotiated improvement target (optional) but it is vital that, in aggregate, the agreed LAAs reflect a national level aspiration for local authority action at a community level. l An indicator based on a percentage carbon emission reduction of an authority’s own estate and operations. We recommend this is a negotiable improvement target (optional) at first, but once baseline data of individual local authority performance has been established it should become a floor target (non-negotiable for those not meeting a minimum level of performance). l An indicator to measure progress towards building a climate resilient local area. We recommend that this is a negotiated improvement target (optional). l An indicator to measure progress in tackling fuel poverty through improved energy efficiency. We recommend that this is a negotiated improvement target (optional).

Principles for the new performance framework: l The new LGPF should focus on long-term outcomes as well as short-term impacts. l In aggregate, the agreed LAAs should reflect a national level aspiration for local action to reduce community emissions. l Sustainable procurement needs to be made part of the CAA’s ‘use of resources’ assessment. l Climate change should be part of a basket of sustainable development indicators within the national indicator set. l Top performers in the new LGPF must be rewarded with financial benefits. l The new LGPF must give recognition for action towards meeting climate change outcomes where the benefits do not accrue directly to the local authority.

Reporting requirements: l Establishing accurate baselines and setting achievable targets are both essential, but auditing requirements should not be so onerous and rigid that they undermine the introduction of an indicator based on community emissions.

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Summary of recommendations


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3. developing effective delivery mechanisms Previous chapters have focused on the role of local government in tackling climate change and the importance of the new performance framework, and the new emphasis on local authorities as place-shapers. The local government white paper states that central government wants to enhance the capacity of local authorities to work effectively with partners to tackle major cross-cutting problems such as climate change. It also sets out how strengthened local area agreements (LAAs) will be a key delivery mechanism for improving an areas performance in relation to national and local priority outcomes. This chapter will examine how this will be achieved, with particular emphasis on the role of the new sustainable community strategy (SCS), and the strengthened local strategic partnership (LSP) and LAA. The white paper heralds a number of key changes to the delivery mechanisms above. To the outsider, these changes are fairly impenetrable - the change from LAA funding blocks to themes is one such example - but many of them are significant. At the heart of the proposed changes is a single vision for an area, the sustainable community strategy. Previously called the community strategy, the SCS has been borne out of the recognition, articulated by Sir John Egan in his review of skills for sustainable communities, that local leaders need to take a more integrated approach to social, economic and environmental issues. The responsibility for achieving the vision set out in an SCS will lie with a strengthened system of local partnerships, known as the local strategic partnership. Led, in the most part, by local authorities but with a new duty on local partners to co-operate, the LSP will prepare the LAA. The new LAA has been defined by Communities and Local Government (CLG) as the only place where central government will agree targets with local authorities and their partners on outcomes negotiated by the LSP and central government.26 Its new structure, notably its nonring fenced grant, will mean that the LAA gains new importance as the main delivery vehicle for a community’s aspirations. The LAA will, in effect, be the implementation plan for the SCS and the expression of the LSP in action, with the local council as first among equals.

Local strategic partnerships All of the above strategies, agreements and partnerships are important, not least because of their interdependency. But as the body responsible for establishing and delivering an area’s vision for its future, the importance of the LSP - the ‘partnership of partnerships’27 - cannot be overemphasised. This is particularly the case when faced with a complex, cross-cutting issue like climate change. There are now over 360 LSPs in England,28 at unitary, county and district levels. The 2006 white paper strengthened the LSP, naming it the ‘overarching strategic partnership’ of an area and placing a duty on the local authority and a number of named partners to co-operate with each other to prepare and agree targets in the LAA. The majority of stakeholders interviewed believe that dynamic and effective LSPs have huge potential for tackling climate change. This view is derived partly from the knowledge that in areas where successful LSPs have been established, such as Birmingham and Cornwall (see Box 4 below), a major area for action has been climate change and sustainable energy. Sustainable procurement is also an area where the combined purchasing power of LSPs could have real influence and gain benefits for individual organisations and the area as a whole, as it is an area where even the most disparate of LSP members have interests in common. Ambitious LSPs can even press their advantage further and use their combined clout to secure preferential financial arrangements for larger infrastructure projects or to set up energy service companies (ESCos).


Key challenges for LSPs Local authorities, LSPs and the duty to co-operate The white paper sets out the duty on the local authority to prepare the SCS in consultation with others and on the upper-tier local authority (in two-tier areas) or unitary authority to prepare the LAA, also in consultation with others. It places a duty on both the local authority and named partners to co-operate with each other to agree the targets in the LAA and for partners to have ‘regard’ for relevant targets in the LAA. These duties are positive insofar as they elevate the status of the LSP and promote effective partnership working, but there is a lack of clarity about the ends to which co-operation is required. The duty to co-operate should focus on delivering sustainable development, with named partners co-operating to deliver specific targets, according to their role and remit. This should be made clear in guidance on “the duty to coSCSs expected from CLG in the autumn.

operate should focus on delivering Involvement and commitment of partners sustainable CLG have said that all LSP partners need to see collaboration as the only way to 29 achieve efficient and cohesive services, not as an addition to their day job. This is the development” right ambition but there is a question mark over how this will be achieved in practice. The quality and success of LSPs will depend on their partners being genuinely on board and feeling like they have a real stake in the LAA and SCS, rather than seeing them something for others to worry about.

Challenges for LSP action on sustainable development and climate change Incentivising an approach based on sustainable development Achieving sustainable development will require all partner organisations in an LSP to take action; in the case of climate change, by reducing their own emissions and promoting sustainable energy amongst their employees and stakeholders. To ensure that this happens, an individual partner organisation needs to know that it will be recognised and rewarded when it takes decisions or steps that ultimately lead to carbon reductions, even if the benefits of this action may accrue to another organisation or, more likely, the area as a whole. “there is a real

risk that climate change will be The new duty on partners to co-operate includes organisations such as the under-represented Environment Agency and Natural England.30 It is clearly important that these organisations are well represented on an LSP, yet the Environment Agency is currently on crucial local only able to sit on 30 per cent of all LSPs, and as a result has to make decisions about partnerships across where limited resources are best directed. Whilst not under the statutory duty to the UK” Capacity of LSP to deal with cross-cutting issues such as climate change

co-operate, the voluntary and community sector faces similar challenges in finding the resources needed to engage effectively with LSPs. There is a real risk that, despite the importance and urgency of the problem being acknowledged at the highest political level, climate change will be under-represented on these crucial local partnerships across the UK. To ensure local areas fulfil their potential to contribute to the UK’s climate change targets, steps should be taken to ensure that each major LSP has at least one senior-level person to champion sustainable development (see Birmingham Strategic Partnership case study in Box 4 below). This point is reinforced by a recent evaluation by the University of Warwick Business School,

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However, despite the excellent work of some LSPs, our research also suggested that in a large number of areas they can be a weak link in the chain. Often under-resourced and varying in quality, their activities can sometimes be an add-on to the primary roles of their partner organisations. Based on these findings, the points below set out the key challenges for LSPs at both a general level and in relation to action on climate change.


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which found that having a dedicated person for the strategic partnership helped mainstream a sustainable development approach.31

Box 4: Examples of partnership working on climate change Birmingham Strategic Partnership “Using the challenge of climate change to change the way we make decisions” Birmingham Strategic Partnership (BSP) was established in 2001 and brings together key public agencies and representatives of business, voluntary, faith and community organisations. In recent months the BSP has finished consulting on a climate change strategy and action plan for Birmingham and a revised strategy will be launched later in the year. Cutting household carbon dioxide emissions has already been included in Birmingham’s LAA and the city is on track to make a 70,000 tonne cut this year. The climate change action plan, that will deliver the strategy, is supported by BSP members and identifies lead agencies, delivery mechanisms, targets and actions for seven themes, including energy, transport, buildings and procurement. The partnership is also seeking to establish a dedicated co-ordination and support agency to enable Birmingham and all its residents, organisations and businesses to reduce their emissions and be prepared for a changing climate. BSP is unique in that it has the UK’s first ever sustainability champion dedicated to ensuring that sustainability is part of BSP’s core principles. The post is funded by the Birmingham Environment Partnership, which is one of the main thematic partnerships supporting BSP, through neighbourhood renewal funding (NRF). It is not clear how this role will continue to be funded when NRF ends.

Cornwall Sustainable Energy Partnership “A sustainable energy future for Cornwall” Cornwall Sustainable Energy Partnership (CSEP) was formed in 2001 by over 40 organisations, including Cornwall County Council and the six district authorities. In 2004 CSEP launched the sustainable energy strategy for Cornwall, which was signed by all the LSPs in Cornwall. Community Energy Plus, a registered charity and profit recycling company manages the partnership, which now involves over 80 organisations in sustainable energy initiatives such as the award-winning Home Health scheme. Separate from Cornwall Strategic Partnership and district LSPs, it has close connections to all Cornwall’s LSPs, and action on climate change has since become a key criterion of success for Cornwall Strategic Partnership. All eight local authorities within CSEP achieved Beacon Council status for sustainable energy in 2005-06.


Partnership working has long been central to the government’s strategy for delivery at a local level. The white paper places further emphasis on devolving real powers and decision-making to local authorities and its partners to enable local government to strengthen its place-shaping role. As a result, the quality, influence and reach of the new SCSs are of real importance. It is crucial that CLG’s guidance on SCSs sets out a clear and ambitious direction for them and explains how they differ from the community strategies that preceded them.32 The Egan review of skills for sustainable communities recommended “a more sharply focused SCS, through which a vision is developed, set and operationalised”.33 Current CLG documents add that the SCS needs to: be based on firm evidence, add value to other plans, be spatially relevant and robust enough to set the agenda for priorities in the LAAs.34 The results of our interviews with stakeholders underlined the importance of these conditions. A number of points in particular stand out that should be reflected in CLG’s guidance: l The aspirations of the SCS must reflect and take account of national commitment to action on climate change: The SCS should consider a community’s broader environmental impact, including its contribution to climate change, not just local environmental quality. l The SCS must secure high-level political commitment: Community strategies were rarely seen as an area’s overarching strategy, making it difficult to shape other strategies and plans enough to achieve its objectives. This was a significant weakness and SCSs must avoid it. l The SCS must secure the buy-in of the wider community: As well as requiring political commitment from the top, SCSs must secure the buy-in of the wider community: from the rest of the public sector, the voluntary and community sector and local businesses. This sense of ownership cannot be created overnight, so the process of creating the SCS is as important as the final document itself. l The SCS must contain an ambitious vision and a delivery plan: For the new SCS to be more successful, it must achieve the tricky balancing act of being both a long-term vision for an area and a shorter-term plan of action for achieving this vision, with concrete plans and milestones. If it is just a vision, the SCS risks remaining no more than a glossy mission statement. If it is only a series of short and medium term objectives, it risks being superseded by the next plan or strategy. A strong SCS that achieves both will ensure that future LAA negotiations are not just a rotating round of short-term priorities and targets but will deliver on critical long-term and multifaceted issues such as climate change. l The SCS must be translated effectively into an area’s LAA: There is concern over the extent to which the vision for an area articulated by an SCS will be translated into an area’s LAA. Much of this relates to the point above about political commitment and is especially important with regards to the LAA, which is now the only mechanism for negotiating an area’s priorities between local and central government. It is not yet clear how the negotiations will ensure that the long-term ambitions reflected in the SCS will get translated into the LAA. The Audit Commission and the new comprehensive area assessment will have an important role in ensuring that this occurs. A major concern is that local authorities will use all the money provided through the LAA to ensure that the 35 improvement targets are delivered, to the neglect of the other targets and issues identified in the SCS and LSP.

Local area agreements The white paper sees LAAs as the delivery plan for the SCS, and a leading mechanism for improving an area’s performance in relation to a small number of priority outcomes. An important change to LAAs is the removal of block funding: previous funding blocks have now been dissolved into four themes. This is a positive development, as it should make it easier for

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Sustainable community strategies


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LSPs to negotiate targets on cross-cutting issues. The white paper gives LAAs more weight by placing a duty on named partners to have regard to relevant targets set out in the LAA.

The role of the government offices in the regions The role of negotiating the new LAAs with local authorities and their partners lies with the government offices in the regions. Their influence is significant: in 2004-05, the government offices (GOs) were responsible for over £9 billion of government expenditure.35 However, interviewees raised questions about the capacity and skills of the GOs to encourage a change of pace in action on climate change by local government. This is a concern given the GOs’ crucial role in ensuring that national priorities are reflected in the English regions. A number of stakeholders suggested that GOs could better tailor their interpretation of national policy more towards the region they work in, so it is more specific to local circumstances, issues and opportunities. The appointment of regional ministers in July 2007 and recent proposals for a single regional strategy setting out the economic, social and environmental objectives for a region are both opportunities for the regions to take a greater role in tackling climate change. This shift in emphasis should be reflected in the remit and role of the government offices.

Negotiating the LAA The interviews suggest a lack of clarity amongst stakeholders about what mechanisms will ensure that climate change will be a central part of LAAs. The national position is that climate change is a priority issue for the UK. Locally, CLG’s definition of a sustainable community includes “actively seek[ing] to minimise climate change, including through energy efficiency and use of renewables”.36 Between these two statements however, a large degree of uncertainty surrounds whether and how the commitment to local climate action will be prioritised in LAAs. The CAA will be used to inform LAA improvement target setting. Therefore, an appropriate focus on climate change in the CAA (as set out in the previous chapter), should help identify where there are risks to outcomes being met and where action should be prioritised. However, in many cases the CAA will identify a significant number of areas for improvement and, as such, negotiations over LAA targets will play a crucial role in deciding between competing priorities.

“there is a danger that the challenges may end up being determined by which civil servants can get to which meetings ”

We are concerned that the proposed system lacks a mechanism for ensuring that the importance of tackling climate change filters down effectively to LAAs. As one stakeholder put it, “there is a danger that challenges may end up being determined by which civil servants can get to which meetings”. Moreover, local pressure from LSP partners, the community and the local authority itself may also not be strong enough drivers to ensure local climate action is prioritised to the extent that is needed. We believe that, to minimise this risk, the regional government offices need to come to the negotiating table with an understanding of what the national level ambition for local authority action is and ensure that, as a result of the negotiation process, the aggregate of individual agreements reflects this.

Incentivising action on climate change and sustainable development The rewriting of the fourth LAA theme as ‘economic development and the environment’ is a first step to encouraging LSPs to consider acting on climate change as a major component of their LAA. However, the scale of the challenge merits an approach to tackling climate change based on incentives that have real political and financial purchase. The 2007 comprehensive spending review will consider whether the new LAAs will have a reward grant element, that is, whether local authorities and their partners will be able to agree stretch targets that, if met, will release more funding for the authority or confer other benefits. We believe that there should be a reward grant element to the LAA available to LSPs that set stretch targets for


The limits to ‘grassroots’ demand Last year’s white paper confirmed that the direction of local government reform is towards devolving more power, and therefore more accountability, to local government. The new performance framework and the new LAA structure both aim to deliver this aspiration by achieving a better balance of local and national priorities. For many local authorities, tackling climate change and adapting to effects already in train will be a new area of action, challenging them to think, plan and spend differently. For authorities already grasping the challenge of climate change, this new way of working is an opportunity for environmental, social and economic gains. For others, tackling climate change may be considered a new burden, another thing that they are expected to do without a corresponding increase in the amount of money to help them do it. Given the thrust of reform is to put more weight on meeting local needs and concerns rather than imposing central government diktats, it is unsurprising that the white paper’s emphasis is on enhancing the capabilities of local government to tackle climate change, rather than saying that it must: “[the white paper] will give local authorities new opportunities to put climate change at the heart of their local priorities, and to lead action to make a difference to the local area, the country and the planet”.37 The extension of the community call for action to all local government services is highlighted as one of these opportunities. In a speech to Green Alliance in April 2007, the then secretary of state for communities and local government, Ruth Kelly, said: “In the future, citizens will have new ways to raise these issues with the local authority. For example, if people were unhappy with their local recycling service, they could use the call for action to press for change. As we loosen the control from the centre, we are providing ways for bottom “local authorities should see their role up pressures to be expressed, and local government must be ready”.38

as one of galvanising the community into both demanding and supporting action”

This is unquestionably a positive step forward both for local democracy and local authority action on climate change. However, we are concerned that too much emphasis might be placed on bottom up pressure from the community to tackle climate change. As discussed earlier, the benefits from tackling climate change will not always accrue in a direct or obvious way to a community. Furthermore, action on climate change is not yet something that people readily associate with local authorities, connecting it more with action by business and central government. A situation in which local authorities wait for community pressure before acting is not desirable. Local authorities should see their role as one of galvanising the community into both demanding and supporting action.

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delivering sustainable development in their communities. This will minimise the risk of LAAs focusing only on the short-term and the easily measurable, rather than delivering the vision for an area set out in the SCS. It will also support those already using the LAA process to achieve outcomes with benefits for climate change. More broadly, it is important that LSPs setting out to tackle cross-cutting issues such as climate change receive the support and recognition they will need to fulfil their potential on this vital issue.


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Summary of recommendations Local strategic partnerships: l For LSPs to live up to their place-shaping potential and deliver sustainable development, some significant challenges need to be addressed, such as securing sufficient resources and effective involvement of key partners. l The duty to co-operate on local government and relevant local strategic partners should focus on co-operating to deliver sustainable development. l To ensure local areas fulfil their potential to contribute to the UK’s climate change objectives, steps should be taken to ensure that each major LSP has at least one seniorlevel person to champion sustainable development.

Sustainable community strategies: l It is crucial that place-shaping guidance sets out a clear and ambitious direction for SCSs, in particular setting out what will distinguish the new SCS from its predecessor, the community strategy. l The guidance must also include provisions to ensure that the SCS: • Reflects and takes account of national commitment to action on climate change. • Secures high-level political commitment. • Achieves the buy-in of the wider community. • Contains an ambitious vision and a delivery plan with short to medium-term priorities and targets that deliver on long-term climate change objectives. • Is effectively translated into an area’s LAA.

Local area agreements and their negotiation: l To enable the government offices in the regions to meet the challenges climate change presents, a stronger remit to deliver sustainable development and extra skills and capacity are needed. l The results of LAA negotiations between local authorities and their partners and regional government offices need to reflect a national level aspiration for local climate action. l There should be a reward grant element to the LAA available to LSPs that set and achieve stretch targets for delivering sustainable development in their communities.


4. strengthening the overall policy framework Improving local government performance on climate change at the scale and speed necessary is a significant challenge. A strong policy framework will be essential to bring about a step change in local climate action that matches the breadth and the urgency of the challenge. At a national level, the main external drivers for change in local authorities tend to be duties, Audit Commission inspection and financial penalties, rewards or benefits. The government has made it clear that it does not favour introducing a duty on climate change, which is at odds with the main thrust of local government reform for less rather than more centrally-driven priorities. Without this, the commitment to include an appropriate focus on climate change in the new local government performance framework (LGPF) and other policy developments will be crucial.

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This chapter looks at whether the emerging policy framework for local government action on climate change is capable of delivering, and considers what other measures will be needed to support and complement the inclusion of climate change in the new LGPF, as well as some of the main issues that should be addressed. At the moment there are a number of constraints and barriers to action that need to be tackled if the policy framework for local climate action is to operate effectively. These include reliance on wilful individuals for climate action, lack of funding for local climate action, and a skills and capacity gap in many areas.

What does success look like? It is not possible to assess whether the emerging policy framework for local government action on climate change is capable of delivering without a benchmark of what successful delivery would look like. Local and regional bodies are recognised as having a leading role in climate change adaptation and mitigation.39 However, that role has not been clearly defined.40 At the moment there is a huge disconnect between high level aspirations for local authority action on climate change, as set out in ministerial speeches and policy documents, and the expectations on local authorities to deliver. The current policy framework does not clearly define local government’s responsibilities in this area, nor is there a national view of what contribution local government could make and how this fits into action on a national level to curb emissions and adapt to climate change. Clarifying local government’s role would help ensure the right policy framework and would also give local authorities a clearer signal and broad idea of what they should be aiming for. The inclusion of climate change in the new LGPF has the potential to partially address this but more will still be needed to clarify local government’s role. Given that we know the functions of local government at different levels and how they relate to climate change adaptation and mitigation, the government needs to define the areas and types of activities councils should be looking at to address the issue. This does not have to be either given or taken as a diktat from the centre but as an extra level of detail of the kind of action that is expected.

“local and regional bodies are recognised as having a leading role in climate change, but that role has not been clearly defined”

The forthcoming Adaptation Policy Framework, to be published by the end of 2007, will set out a strategic vision for adaptation in the UK and provide tools and mechanisms to support the development of adaptation strategies across government, at a regional and local level.41 The framework must clarify the role and responsibilities of local government in adapting to climate change.


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Finance: making action possible and making performance matter For the new LGPF and strengthened LAAs to operate as an effective driver for change, they have to make performance matter. To drive improvements in local authority delivery, positive incentives will be needed to reward good performance. Current proposals appear to lack this essential element.

Financial incentives are an effective means of recognising and rewarding improvements in a council’s performance and making action in a particular area count. To promote local climate action on the scale required, it is imperative that there are appropriate financial incentives and penalties within funding arrangements for top performing local authorities. There are a number of options that could be considered to give local authorities additional revenues or allow them to raise their own for local climate action. These include giving top performing authorities revenue-raising powers or allowing them to repatriate the business rate.42 Of the various options available, we strongly recommend making a reward grant element to “the delivery of local the local area agreement (LAA) available to local strategic partnerships (LSPs) that set and achieve stretch targets for delivering sustainable development outcomes, with an climate action will emphasis on tackling climate change, in their communities.

require significant extra resources to fund additional capacity, training and to cover upfront capital costs”

The delivery of local climate action will also require significant extra resources to fund additional capacity, training and to cover upfront capital costs. At present there are multiple national funding streams and programmes designed to support local and regional action on climate change mitigation and adaptation.43 But these are limited and often focus on pilots and innovation rather than ongoing costs. To enable local authorities to deliver on this agenda, serious additional resources must be committed.

Analysis by the Centre for Sustainable Energy estimates the cost of what is required at £36 million per year across all local authorities to provide training, support, improved coordination and guidance, and some basic resources for local and regional bodies.44 It is crucial the government commits in the comprehensive spending review (CSR) to significant new funding programmes; or it should grant councils additional revenue-raising powers to generate the funds needed for carbon management and climate change adaptation.

Skills and capacity It is clear, both from existing literature on the subject and the research conducted for this report, that there is a continuing need for more, and more effective, support and help for local authorities to develop the skills and capacity needed to make an effective contribution to tackling climate change.

“a number of forthcoming policy developments mean that local authorities will need to acquire new skills in the very near future”

The Local Government Association’s Climate Change Commission has identified “new planning and building regulations, carbon trading, the impact of climate change on services, the legal and financial skills necessary for energy service companies and measuring carbon emissions”45 as vital areas requiring new skills and competencies. Our research supports this finding. A number of forthcoming policy developments mean that local authorities will need to acquire these skills in the very near future: for example, the draft climate change planning policy statement sends a very strong and clear signal about the central importance of climate change to planning; and the carbon reduction commitment, the new energy cap-and-trade scheme, will catch those authorities with electricity bills of around £500,000 per annum.


Agencies such as the Energy Saving Trust and the Improvement and Development Agency will also be important contributors to the up-skilling of local authority staff, and will need resources proportional to the challenge they face. However, as Dr Gill Taylor, chief executive of the Academy for Sustainable Communities has said, local authorities themselves also have an important role to play: “the real prize, and therefore the real challenge, is for individual chief executives to lead a radical overhaul of skills and knowledge within their individual authorities”.46

Overcoming the barriers of complexity Towards effective partnership working Central to the government’s vision and strategy for improving governance and delivery at a local level is effective partnership working between authorities and other relevant bodies at a regional, sub-regional or local level. Local authorities are expected to work in partnership with multiple organisations and to play a central role in joining up service delivery. However, given the range of organisations with different remits and goals, the complexity of properly establishing such partnerships and delivering outcomes together can be a very real barrier to effective action, particularly on cross-cutting issues such as climate change. Some of the specific challenges in relation to LSPs and LAAs are discussed in the previous chapter. Partnership working at a regional level is particularly challenging, where the number of organisations involved is greater still. However, a number of the stakeholders interviewed for this report commented on the important role that regional bodies could play in addressing climate change through co-ordinating knowledge, experience and action on the issue. Regional climate change partnerships, such as the South East Climate Change Partnership, are ideally placed to carry out this role, particularly as there is currently no national climate change agency fulfilling this role.

“the complexity of properly establishing partnerships and delivering outcomes together can be a very real barrier to effective action”

Furthermore, regional action on climate change could be significantly strengthened through the development of multi area agreements (MAAs) on climate change. MAAs would allow local authorities and their partners to jointly tackle important regional issues such as housing and regional transport infrastructure, both with potential for considerable emission reduction. Regional climate change partnerships could be well placed to facilitate a more integrated approach to these MAAs across local authorities. However, at the moment such partnerships do not exist in all regions and the remits of existing partnerships are more focused on adaptation, to counteract the overwhelming focus of attention on mitigation. There is a need to have a partnership in each region with a stronger and more prominent role for climate change mitigation. But it is vital that this does not detract from the current regional focus of these partnerships on adaptation.

Towards providing effective advice and support Local authorities willing to take action on climate change also face a bewildering array of government agencies, partnerships, programmes, toolkits and guidance offering various forms of advice and support. Negotiating a path through this maze can be time-consuming

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The white paper sets out plans for a national improvement strategy for local government that will identify investment priorities and ensure that current support targeted at local authorities is efficient and effective. Identifying the skills local authorities will need to meet the new challenges for working outlined above must be a core component of this strategy. We recommend that the government work with organisations, such as the Local Government Association, the Academy for Sustainable Communities and the Sustainable Development Commission to deliver this.


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and difficult, particularly for the uninitiated, which makes it harder for even the most wilful individuals to act. The plethora of different forms of support needs to be streamlined, and more clarity provided about their purpose and strengths. Again, at a regional level, climate change partnerships would be well placed to facilitate partnership working and gather and disseminate regionally specific knowledge and expertise to help local authorities and others to take effective action. Such streamlining would significantly reduce the transaction costs that local authorities have to bear to act.

Culture change “local authorities willing to take action on climate change face a bewildering array of government agencies, partnerships, programmes, toolkits and guidance offering various forms of advice and support”

“For these improvements to continue, we must have the courage at the centre to let go. The challenges we face are too complex, the needs often too local, for all solutions to be imposed from the centre” Rt Hon Ruth Kelly MP, then secretary of state for communities and local government, Strong and prosperous communities: the local government white paper 2006, p4

It is easy to underestimate the scale of the change outlined in the local government white paper. For local authorities and their partners, the white paper sets out a positive and hopeful vision for local government, but the real proof will be in its delivery. Expectations of both central and local government will matter immensely. If local government expects more of the same, dressed up in the language of new localism, then they are likely to respond to the new comprehensive area assessment as they have done to comprehensive performance assessment, in part because that is what they are used to. A deep and consistent change in the culture of central government’s relationship with local government will be crucial if the vision set out in the white paper of confident, autonomous authorities, willing and able to tackle our greatest challenges, is to be realised.


National level ambition for local climate action: l Central government needs to define more clearly what contribution local government can make to tackle climate change and how this fits into action on a national level to curb emissions: a broad idea of the appropriate level of ambition, and importantly an understanding of what success looks like. l The government needs to clarify local government’s responsibilities in relation to climate change, and broadly define the areas and types of activities councils should be looking at to address it.

Finance: l It is imperative that there are appropriate financial incentives and penalties within funding arrangements for top performing local authorities. We strongly recommend making a reward grant element to the LAA available to LSPs that are set and achieve stretch targets for delivering sustainable development outcomes in their communities, with an emphasis on tackling climate change. l It is crucial the government commits to significant new funding programmes or grants councils additional revenue raising powers to generate the funds that will be needed for activities associated with carbon management and climate change adaptation.

Skills and capacity: l Identifying and developing the skills that will be needed by local authorities to tackle climate change must be a core component of the national improvement strategy proposed in the local government white paper.

Complexity: l There is a need for a stronger and more prominent role for climate change mitigation in regional climate change partnerships to promote more effective partnership working. l Streamlining the plethora of different forms of support and advice, and providing more clarity around their purpose and strengths, would significantly reduce the transaction costs that local authorities have to bear to act on climate change.

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Summary of recommendations


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5. conclusion As place-shapers and community leaders, local authorities have a vital role to play in taking action against climate change. There has been innovative and inspirational action in some areas: renewables in social housing in Cornwall and Kirklees; behaviour change work in Surrey and Hampshire; energy service companies in Birmingham and Southampton; and community leadership in Shropshire and Cheshire. But climate change is still not on the mainstream agenda of most local councils, and the majority have taken limited steps to tackle it. The main barrier has not been a lack of power to act, but the absence of clear responsibilities and incentives. The policy framework has so far failed to give climate action prominence and it has been a weak driver for action on the ground. Thankfully, there are some encouraging developments ahead: the government’s commitment to include climate change in the new local government performance framework is welcome. But there is still much to do to ensure initiatives like this meet their full potential. We have examined what will be needed to incorporate climate change effectively into the new performance framework and local area agreements (LAAs). Importantly, central government must take local government’s place-shaping role seriously in the context of climate change adaptation and mitigation. Some of the largest gains in reducing emissions will be made through councils enabling and encouraging their citizens, local businesses and other organisations to reduce their carbon footprints. But this is a huge challenge. Culture change, more resources and, crucially, stronger incentives are needed to ensure local authorities are motivated and equipped to act. The national indicator set, which all authorities must report against from 2008, must include an indicator on reducing community emissions. And provisions are needed to ensure a substantial number of authorities include a target on community emissions in their LAAs. This is essential to develop and strengthen the local authority role as leaders of local climate action. Central government must clearly define local government’s contribution to tackling climate change - in terms of areas to address and level of ambition - and clarify how this fits into the national strategy. To ensure that local authorities are motivated and able to act, this must be complemented by greater financial incentives and support. The severe flooding experienced this year has brought home to many of us what climate change means for local communities across the UK. Central and local government must seize the opportunity now to harness the potential and step up the drive for local climate action. The costs of inaction in the long-term will dramatically outweigh the costs of action now. 2007 must be the year for change.


Carbon Reduction Commitment (CRC) A mandatory emissions trading scheme, announced in the energy white paper 2007, which will apply to the largest local authorities. Community Strategy Under the Local Government Act 2000, local authorities in England and Wales had to produce a community strategy to promote the social, economic and environmental well-being of their areas. The community strategy has been superseded by the sustainable community strategy. Comprehensive Area Assessment (CAA) CAA is the assessment component of the new local government performance framework. It will replace comprehensive performance assessment within the next two years and is expected to place a greater focus on delivery of outcomes in an area by the local authority and its partners, rather that just the local authority. Comprehensive Performance Assessment (CPA) CPA is undertaken by the Audit Commission. It measures and ranks the performance of local authorities, based on their capacity to carry out functions and deliver services to their local communities. CPA will be replaced by comprehensive area assessment (CAA) within the next two years. Comprehensive Spending Review (CSR) The CSR was launched by the Treasury in 2005 and will report in autumn 2007. It will make spending decisions for the next three years, and by reference to the main challenges facing Britain, set the direction of a Labour government for the next ten years. Draft Planning Policy Statement (PPS) on Climate Change Published in December 2006, the PPS would put climate change considerations at the heart of the planning system by setting out how spatial planning should help shape low carbon places that are resilient to climate change. Duty to Co-operate The local government bill contained a duty that will apply to local councils and other local service providers, which requires them to agree local strategies and targets and deliver them together. Improvement target A time bound milestone in achieving an outcome in relation to a specific indicator agreed in a LAA. Indicator A quantifiable measure of progress towards delivery of an outcome, which will be included in the national indicator set. Local Area Agreement (LAA) An LAA is a three year agreement between central government (represented by the regional government office) and a local area (represented by local authorities, the local strategic partnerships and other key partners at local level). Their aim is to achieve local solutions that meet local needs while also contributing to national government priorities. Local Strategic Partnership (LSP) The 2006 local government white paper sought to make the LSP the overarching strategic partnership for an area. There are currently 360 LSPs in the UK. LSPs were originally required by the Local Government Act 2000 in all areas in receipt of neighbourhood renewal funding, although some partnerships predate this Act. Multi Area Agreement (MAA) Where a number of outcomes in an area may be best delivered through collaboration at a broader geographic scale than a single local authority, MAAs can be developed. These can provide greater flexibility in shaping interventions within the sub-region and strengthening cross-boundary working between local authorities and their partners.

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glossary


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National Indicator Set The government has proposed that there will be around 200 indicators on national priority outcomes that all unitary and county authorities will be required to report against. Sustainable Community Strategy (SCS) Previously community strategies, SCSs are the plans which local authorities are now required to prepare for improving the economic, environmental and social well-being of local areas and by which the councils are expected to co-ordinate the actions of the public, private, voluntary and community organisations that operate locally. Power of Well-being As enshrined in the Local Government Act 2000, every local authority has the power to undertake activities to improve the economic, social or environmental well-being of their area. The power is a significant resource and freedom, which encourages councils to look beyond their immediate service delivery responsibilities.

interviewees and steering group members The recommendations in this report are put forward by Green Alliance and do not necessarily represent the position of steering group members or interviewees.

Interviewees Alex Steward and David Thomas, HM Treasury Alice Owen and Denny Gray, Sustainable Development Commission Andy Walford, Audit Commission Caroline Green and Sarah Coe, Local Government Association Chloe Meacher and Jo Key, Communities and Local Government Ian Christie, Green Alliance associate James MacGregor, New Local Government Network Keith Budden, Birmingham Strategic Partnership Laurie Newton, UK Climate Impacts Programme Nick Gibbins, Communities and Local Government Oliver Myers, Camden Borough Council Paul Whittlesea, Communities and Local Government Philip Mind, LGA Climate Change Commission Secretariat Richard Howell and Roger Hoare, Environment Agency Richard Tarboton, Energy Saving Trust Robert Light, Kirklees Council Steve Waller, IDeA Tim German, Cornwall Sustainable Energy Partnership Tyrone Homes, Defra

Steering group members Chloe Meacher, Communities and Local Government Dan James, Communities and Local Government Julie Foley, Environment Agency Sarah Parkin, Groundwork


notes and references

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Defra (2006) Climate change: the UK programme 2006, p106 CLG (October 2006) Strong and prosperous communities: the local government white paper, Volume 2, Annex F: Climate change, p48 Defra (2006) Climate change: the UK programme 2006, p104 Joint Committee on Draft Climate Change Bill (July 2007) Joint committee on the draft climate change bill: first report, section 221 LGA Climate Change Commission (July 2007) Strengthening local action on climate change, p4 Defra (2007) Draft climate change bill Defra (2006) Climate change: the UK programme 2006, p106 Full speech on Green Alliance website: www.greenalliance.org.uk/grea1.aspx?id=1704 The first figure is mentioned in Strengthening local action on climate change published by the LGA, July 2007. All other figures taken from a presentation by Prof John Chesshire, Chair of the LGA’s Climate Change Commission, at the LGA Conference 3 July 2007 Michael Lyons (March 2007) Place-shaping: a shared ambition for the future of local government, p174 LGA Climate Change Commission (July 2007) Strengthening local action on climate change, p4 CLG (October 2006) Strong and prosperous communities: the local government white paper, Volume 2, Annex F: Climate change, p 48 Centre for Sustainable Energy (2005) Local and regional action to cut carbon Tracy Carty and Hannah Hislop (2006) Local government and climate change, Interim report: research assessing the evidence base, Green Alliance report submitted to CLG (unpublished) Research referred to on the LGA’s website: www. campaigns.lga.gov.uk/media/17/files/meeting2_ corpstrategy.pdf Centre for Sustainable Energy (2005) Local and regional action to cut carbon At the time of writing 239 of English authorities had signed the Nottingham Declaration. The other remaining councils have not taken the opportunity to make public their commitment. Defra (2006) Climate change: the UK programme 2006, p106 Audit Commission (2007) Sustainable development: the Audit Commission’s approach In particular Audit Commission (April 2007) The transition from CPA to CAA and (April 2007) Developing and implementing the new comprehensive area assessment and associated inspection arrangements www.communities.gov.uk/ index.asp?id=1509351 In the case of two tier authorities the county council leads the negotiation in the LAA. District councils are involved through the LSP. Plus the statutory early years and performance targets from the Department for Education and Skills. CLG (February 2007) Developing the future arrangements for local area agreements

23 The proposed indicators are on the Defra website: www.defra.gov.uk/environment/localgovindicators/ indicators.htm 24 Parliamentary Office of Science and Technology (Oct 2005) Household energy efficiency 25 Michael Lyons (March 2007) Place-shaping: a shared ambition for the future of local government, p 174 26 CLG (February 2007) Developing the future arrangements for local area agreements 27 Audit Commission (April 2007) The transition from CPA to CAA 28 ODPM (December 2005) Local strategic partnerships: shaping their future 29 Ibid. 30 CLG (October 2006) Strong and prosperous communities: the local government white paper 31 Warwick Business School (March 2007) An evaluation of sustainability within Birmingham Strategic Partnership 32 It should be noted that some LSPs are already negotiating their new LAAs in the absence of this guidance. 33 ODPM (2004) The Egan review: skills for sustainable communities, p 12 34 ODPM (December 2005) Local strategic partnerships: shaping their future 35 www.gos.gov.uk/aboutusnat/ 36 ODPM (December 2005) Local strategic partnerships: shaping their future 37 CLG (October 2006) Strong and prosperous communities: the local government white paper, Volume 2, Annex F: Climate change, p54 38 Full speech on Green Alliance website: www.greenalliance.org.uk/grea1.aspx?id=1704 39 Defra (2006) Climate change: the UK programme 2006, p105-109 40 Centre for Sustainable Energy (2005) Local and regional action to cut carbon, p4 41 Departments and the devolved administrations are working together to develop a cross-government adaptation plan which will identify priority areas for action. The framework will be published at the end of 2007. www.defra.gov.uk/news/2007/070406a.htm 42 As set out in the Review of sub-national economic development and regeneration (July 2007), the government is considering options for a supplementary business rate, which would allow local authorities to have a potential revenue stream to support economic development. 43 Centre for Sustainable Energy (2005) Local and regional action to cut carbon, p72 44 Ibid. p84 45 LGA Climate Change Commission (July 2007) Strengthening local action on climate change 46. www.ascskills.org.uk/pages/policy/article?news. policy.id=70856A0C-A927-41F9-9A79995C95F2A9A3

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