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The public consultation on the draft Birmingham Climate Change Strategy and Action Plan closed on 31st March 2007.  My response is reproduced below.   The draft Strategy document can be downloaded in PDF format from the Birmingham Strategic Partnership website,

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Response from Lynne Jones MP


A.  Preamble

B.   Overview

C.   Comments on Themes

C.1.   Sustainable Procurement

C.2.   Transport

C.3.   Buildings and Energy Use

C.4.   Planning and Land Use

C.5.   Waste

C.6.   Water

D.   Conclusion

Interleaved between these section are 43 questions.  Consideration of these questions should inform the final strategy.

A. Preamble

A. 1.Under the Home Energy Conservation Act (HECA) 1995, all local housing authorities have a duty to seek a 30% improvement in energy efficiency over a 10-15 year timescale.  Twelve months ago (12 April 2006), I wrote to Birmingham’s Director of Housing asking for a progress report on Birmingham’s performance in implementing HECA.  I also asked what contribution the housing sector had made towards the Council’s target that 15% of energy consumed would be renewable by 2010; the commitment to develop an integrated approach to explore the options and applications for combined heat and power energy; details of green building design principles; and energy demonstration features incorporated into house-building projects and refurbishments.  Finally I asked for details of how the Council intends to apply the Code for Sustainable Homes.

A.2. Over two months later, I eventually received a reply which did not answer any of my questions but referred me to the Climate Change Strategy that was expected to be published for consultation in the autumn.  In fact, the (draft) Strategy was held back until the end of 2006.  I say held back because it is clear from statements in this document, such as “the strategy runs from 2006 to 2010” and the reference to the establishment of a domestic renewable energy scheme with a focus on the fuel poor by 2006 that it is already out of date.  I can find no details on the Council’s website of anything worthy enough to be described in such terms - just a couple of commendable initiatives by small organisations - the installation of 5 solar water heating systems by the Balsall Heath Housing Co-operative and a refurbishment of a Victorian property as an “eco house” demonstration project by Family Housing Association.  Whilst the Council has allocated money from the Government’s Neighbourhood Renewal Fund to assist the Association’s improvement of further individual properties and a training scheme for solar water heating installation, it continues to install windows produced from UPVC in its own properties, hardly demonstrating a commitment to sustainability.

A.3. Further evidence that the Council is doing no more than engaging in tokenism when it comes to climate change comes from the 21 February edition of the Council’s own freesheet “Forward”.   On one page under the heading “Green Light for City Eco Village” the Family HA project mentioned above, involving up to 30 properties is described as “providing a real opportunity to address the issues of global warming” but on another page there an article about “one of the biggest redevelopments in the City” involving the City partnering with a private developer to construct 500 new homes in Northfield.  Such a development surely would be a real opportunity to address the issues of “global warming” but there is no mention whatsoever of any measures to curtail carbon emissions beyond regular building regulations.

A.4. The impression that Birmingham’s commitment to combating climate change is only superficial is confirmed by the absence of any mention of this in the Council Plan 2007-2010 approved by the Council in February.  Nor is the need for investments to maximise reduction in CO2 emissions mentioned in the Capital Strategy.  Given the rhetoric in the Climate Change Strategy (eg that it will enable the Council to demonstrate leadership on climate change regionally, nationally and internationally), surely the subject would at least warrant a mention?

A.5. Birmingham MPs were only officially notified of the consultation in an email on 15 February but such was my disappointment at first reading of the document that I sent an initial response on 8 March pointing out that, whilst the “Strategy” sets targets, exactly mirroring the Government’s, to reduce CO2 emissions from a 1990 baseline by 20% by 2010 and 60% by 2050 (these targets are already inadequate, if we are to ensure global warming does not increase by more than 2 degrees C, a target the Council acknowledges), there is no sense that Birmingham’s leadership has anything more than vague notions of how to achieve these aims.  Having also completed the on-line response process, I expressed the view that it was not designed in such a way as to be able to achieve any meaningful results and promising my considered response, which I now give.  I begin with a general overview then comment on each of the first 7 themes in the document.   I will comment on themes 8 and 9 (Communication and Leadership and Performance Management in the Overview and I will indicate in bold the questions that the Council/Strategic Partnership (BSP) needs to address.   I hope this response will be helpful in improving on the draft document.

B. Overview

B.1 I get no sense in this document that either the Council or the BSP are prepared to use the range of existing powers and resources available to them to drive forward the agenda on climate change.  Nor are there any demands for greater powers to be devolved from central Government.  It is stated that Birmingham wants to “take its place alongside London, Johannesburg, Chicago, New York and Copenhagen as a leader on tackling climate change” but there is no indication given as to what in particular about these cities’ performances should be emulated.  I am surprised there is no reference to knowledge gained from information from twin cities such as Frankfurt. 

B.2. In my response I will indicate some lessons to be learned from towns and cities I have visited as a member of the Environment, Food and Rural Affairs (EFRA) Select Committee or about which I have other sources of knowledge.

B.3. Despite being only a tenth the size of Birmingham, Woking Borough Council have set the pace for local authorities who want to demonstrate that they take the challenge of climate change seriously. They were awarded the Queen’s Award for Enterprise in 2001 for their Energy Services and Beacon Council status for Sustainable Energy in 2005/06.  Perhaps if more notice had been taken of their achievements, the Birmingham Strategy would have been much improved.  In their Climate Change Strategy, first produced in 2002 and updated in 2005, Woking give a list of specific actions with timescales and indication of progress.  They have already assessed their 1990 base as 1,060,000 tonnes of CO2 equivalent and adopted a climate neutral practice note, which is distributed to developers and they have made recommendations to Government about raising standards.   Nowhere in the Birmingham document is there any recommendation to Government and Birmingham seems content to just go along with minimum standards required by Government.

B.4. The Birmingham document states that the City has been working on Climate Change for many years and, indeed, Birmingham signed up to the Nottingham Declaration in 2001.  Yet, despite stating at that time that, during 2002, emissions from CO2 and other greenhouse gases would be measured across the City, in this document it is stated that there is still no assessment of Birmingham’s carbon footprint.  A figure is given of 6.6 tonnes CO2 per annum derived from DEFRA (Department of Environment, Food and Rural Affairs) data which clearly does not include all emissions attributable to Birmingham residents.  Average emissions per capita in the UK are approximately 10 tonnes CO2 and it would be useful to have that piece of information stated alongside the relevant ratios for other comparators such as the USA (20); China (2) and India (1).

B.5. I could not find any proposal for a systematic determination of baseline data, just that the BSP would “seek to use a combination of data to measure performance”.  Reference is made to the Stockholm Environmental Institute (SEI) Ecological footprint data (which indicate that Birmingham’s ecological footprint is slightly below the national average) and other performance tools eg the University of East Anglia’s (UEA) CRed programme (or “similar systems”) without explaining how they will be used (or in the case of CRed, what it is).  This is one of several features of the document that detract from its usefulness, particularly to those with no specialist knowledge.  Though I welcome the proposal to report on an annual basis and revise the strategy in 2010, without the ability to properly measure performance, this has little meaning.

B.6.   It is also disappointing that there is nothing in the document to inspire local communities to take on the challenge of climate change following the lead of, for example, Ashton Hayes, a village near Chester (  Indeed, I am not aware that the consultation was even circulated to ward committees or neighbourhood forums.  Ashton Hayes is one of a number of communities working with the UEA’s Community Carbon Reduction Programme (CRed) to measure and reduce their carbon footprint.  They have received a £26,500 Government Grant to develop a toolkit for this purpose which may well be of use for us.

B.7. Therefore my first questions to those responsible for this report is:

Q.1. How will the City’s carbon emissions be systematically measured and progress towards targets monitored? 

Q.2. Would it be helpful to break this down by sector and locality (based on “vibrant urban neighbourhoods)?

Q.3. How will Local Agenda 21, that the City signed up to many years ago, be developed?


C.  Comments on themes

C.1. Sustainable Procurement

C.1.1. It is good that the BSP recognises the impact procurement policy can have on the environment and I look forward to the publication of the proposed buying guide and product miles measurement tool.  I am surprised that there is no specific mention of the importance of food and drink consumption as the SEI’s  (2006) ecological footprint model applied to Birmingham indicates that the largest proportion (21%) of our 5.3 global hectares consumption is from the food and drink sector.  This fact ought to be more widely promulgated.  It would also have been useful to have an assessment of the impact of the Council’s procurement strategy 2004-2006.

Q.4. When will the green buying guide and product miles measurement tool be produced and will it be in good time to achieve the 2008 target for baselines for procurement strategies?

Q.5. In what way will the Birmingham Guide differ from the Environment Agency’s sustainable procurement guide?

Q.6. In what way will the Council’s own experience of sustainable procurement feed in to this exercise?

Qs.7. & 8. What is the response to the Council’s own Overview and Scrutiny Committee Report that the Council has no sustainable procurement strategy in ethical purchasing or corporate social responsibility strategy, that the Council is not EMS, ISO14001 or BS8555 accredited, that there are no standards on paper purchase and no compulsory Fair Trade policy?  How do other members of the BSP match up on these criteria?


C.2. Transport

C.2.1. The main target under this heading would appear to be to ensure that the Local Transport Plan target of no more than a 7% increase in road traffic mileage is achieved between 2004 and 2010, whilst keeping any increase in CO2 emissions to less than 7%.  It would appear that the lower increase in the latter will be achieved by BSP member organisations purchasing and promoting low or no emission vehicles for their corporate fleets and encouraging the use of alternative low emission fuels.  Given the technological improvements taking place in vehicle performance and the prospect of strengthened emission standards from the EU, the BSP does not in this instance appear to have set itself a taxing target.  As in many other parts of the document, there is a lack of consistency between Sections 2 and 8.  Though not mentioned in Section2, Section 8 on transport talks about a target of a 7% reduction in CO2 emissions from transport by 2020 but this seems completely out of line with the overall 20% emissions reductions target for that date.

C.2.2. It is not clear whether emissions from aviation are included in the definition of transport though the context would indicate that it does not.  In accepting that emissions from aviation are set to grow and in supporting airport expansion but being silent on a fast train route to the channel tunnel, contradictory messages are being sent out.  Carbon offsetting, whilst welcome, should be seen as a last resort.  I am pleased that the proposed scheme will fund local projects targeted at the poorest communities.

Qs. 9. & 10. Why is the target that CO2 emissions from vehicles will be less than the increase in road traffic mileage so weak?  How will this assist with the 2010 and 2050 targets to reduce CO2 emissions by 20% and 60%?

C.2.3. Actions that are listed that would have the effect of minimising the increase in road traffic are: developing car share schemes and car clubs; investigating the role of car park availability and mileage rates in travel choice; promoting home working, video conferencing and the local sourcing of goods and services and promoting best practice in freight activity.  Such measures would presumably be incorporated into workplace travel plans and there are commitments given on the number of organisation that will have these.

C. 2.4. All schools are to have travel plans by 2011 compared to 130 out of 381 at present.

C.2.5. Unfortunately, only one assessment is made of the impact of such measures and that is the example (on page 39) of Mitchells and Butlers’ successful travel plan during their relocation in March 2003.  This is said to have resulted in 17% of staff giving up using their cars.  Given this excellent achievement and the enormous potential of reducing car journeys to school (from our knowledge of the big impact of school holidays on congestion),

Qs. 11. & 12. why are the targets on traffic so unambitious?  What has been the impact of the existing travel plans in a third of our schools and in the 220 companies affiliated to Travelwise?  One can only assume not much as it seems that there is a lack of confidence that the measures listed will actually take off in any meaningful way as to impact on car use.  Certainly I would question the targets on increasing bus use by 9%, and the cycling index

Q. 13. (what is the cycling index?) by 1% by 2011 given that the actions proposed are exactly the same as put forward when similar targets failed to be achieved in the past.  From my knowledge of council traffic improvement and safer routes to schools schemes in and around my constituency, I simply cannot accept the assertion that changes at and around schools (or elsewhere) are being made to improve provision for cyclists and it concerns me that even what seems a pathetic target is unlikely to be achieved.

C.2.6. I would suggest that the Council look to the achievements of cities like Freiburg and even San Francisco, where cycling and public transport are the normal modes of travel to and from work.  A third of all journeys in Freiburg are by bicycle and the public transport system is not only excellent, but cheap. I am sure there are many more examples from which we could learn. In San Francisco, I was told that 500,000 people cycle each day and maps are available allowing cyclists to avoid hills and accident blackspots.  In London, there has been a large growth in both cycling and bus use as a result of the congestion charge.  According to a recent written parliamentary answer, Transport for London will be spending £24.1 million on cycle facilities in 2006/7 and £36.1 million in 2007/8.  No data are available for other local authorities for these years but the total for ALL local authorities outside London for 2004/5 and 2005/6 are £40 million and £34.1 million.  In 2007/8 Cycling England forecast their expenditure on cycle facilities in 2007/8 will be £3.8 million in the cycling demonstration towns and on links to schools.

C.2.7. Despite the inadequacy of overall capital investment for transport which is largely controlled by Government, a city the size of Birmingham has the capability of doing far more to promote cycling and in encouraging walking and cycling to school.

Q.14. What is the City’s budget for cycling improvements in the three year capital plan?

Q.15. How many schools have walking buses and what measures will be taken to increase this to full coverage in primary schools?

Q.16.   Will all children have the opportunity of receiving cycling proficiency training?

Q.17. Are the proposed changes in CO2 emissions from road transport and aviation making an adequate contribution to the overall 2010 and 2050 climate change targets?


C.3. Buildings

C.3.1. If energy efficiency is a proxy for carbon emissions, the target for reducing emissions from domestic buildings by 30% between 1995 and 2010 (though the latter date is not actually stated in Section 2) seems to reflect the requirement under the Home Energy Conservation Act 1995.  As noted in the preamble, I have not been able to find out from the Council how they are performing on this target though the Council has given a figure of a 20% increase in energy efficiency to DEFRA as revealed in a parliamentary answer.  Even if this was a robust assessment (which I doubt, as the Director of Housing was not able to supply me with relevant information on the assessment) it would not augur well for achieving the 30% target by 2010, less than three years away.  There is also a commitment given to reduce emissions from all public buildings to the same extent but, again, no indicators are given as to progress or in assessing the likely effectiveness of the listed actions.  Section 8 does give a good assessment as to the extent of the problem, such as 63% of council homes and 35,000 in the private sector not meeting even the decent homes standard (itself a very low standard on energy efficiency) and the extent of fuel poverty.  However, there is no further detail given as to the likelihood of the actions proposed actually meeting the 30% buildings target, nor the contribution this will make to the overall targets.

C.3.2. On these issues and the related issue of Energy Use (I am not sure why they are in two separate categories), Birmingham has a lot to learn from Woking.  Woking have a fuel poverty strategy that focuses on making heat an affordable commodity and the Council has already achieved weekly heating costs to properties to which it provides heating of a small percentage of the state pension.  They are well on the way to achieving the 30% HECA target, having achieved a 26% increase in energy efficiency of domestic properties by March 2004.   It is not surprising that Woking’s former Chief Officer is now in charge of London’s Climate Change Agency.  I recommend that Birmingham looks to the example of Woking in terms of energy services and energy efficiency and also in planning policy.

Q.18. What progress has been made to date on the 30% target and what contribution will the affordable warmth capital programme, the domestic energy renewal scheme, the promotion of Carbon Trust programmes and the champions awards scheme make towards meeting the target?

Q.19. Are the energy efficiency measures in buildings making an adequate contribution to the overall 2010 and 2050 climate change targets? 

Q.20. Targets for energy use in Section 2.5 are given for 2020.  Given that energy efficiency is the most cost effective means of reducing carbon emissions, why are there no further targets on energy efficiency beyond 2010?


C.4. Planning and Land Use

C.4.1. This section is very weak. Table 7 on page 44 gives examples of how the planning system can contribute to climate change reduction/amelioration but the list of actions does not demonstrate that Birmingham is maximising the contribution planning policies can make, nor pressing for more powers to require maximum sustainability in developments.

C.4.2. In terms of actions, Birmingham is only “expected” to apply Planning Policy Position Statement 22 on renewable energy following the example of Merton.  Even then, it will not be until 2015 that Birmingham will even reach the “Merton Rule”, adopted in 2003 by that Council, requiring 10% of energy from on site renewables for all developments above 10 dwellings.  This is hardly the example of leadership the Council says it wants to demonstrate!  Furthermore, there is no mention of affordable warmth nor the contribution community heating or combined heat and power schemes could make, even for small developments (such as that in Northfield mentioned in my preamble).  Most heating in Austria is provided by district heating schemes using biomass.  In Germany, I visited biogas and biomass CHP facilities, one serving Mannenheim, a village of 200 dwellings and the other a new development outside Stuttgart of 10,000 dwellings.

C.4.3. It is good that the BSP partner organisations will support the City Council in using their powers to require developers to meet progressively higher environmental standards that include reducing the need to travel but are they prepared to help press for those powers to be extended?  As the CBI has acknowledged (February 2005) responsible businesses readily recognise that regulation (applied properly) can create a level playing field, stimulate innovation and deliver the environmental benefits valued by society as a whole at reasonable cost.

C.4.4. The highest standard for new buildings is the “excellent” standard so it is also very disappointing that the aim is only to require “very good” standards.   There is no mention that these standards should apply to extensions or major refurbishments to existing properties, nor of facilities for rainwater harvesting and recycling of grey water, though it is to be hoped that the proposed Climate Change Planning Guide will address these issues.  Woking produced a Climate Neutral Development Guide as long ago as December 2003, and Birmingham could do worse than to emulate this.  Woking is also advocating anti-light pollution measures and has a policy that a site’s environmental footprint must see a reduction of CO2 emissions of 80% compared to the previous use.  In Germany, standards for refurbishments are the same as for new build.

Q.21. Why will it take till 2015 for developments of 10 or more dwellings or more than 500sq metres to be required to have at least 10% on site renewables?

Q.22. Why is Birmingham not aiming for the “excellent” standard for all new buildings?

Qs.23 & 24. What new powers would be useful in maximising the ability of Birmingham City Council to improving the ecological footprint of developments?  For example should local authorities have powers to require higher standards in refurbished as well as new buildings, or to require new developments to make use of existing/planned localised energy capacity (powers for which Woking are pressing)? 

Q. 25. When will the Climate Change Planning Guide be published?

Q.26. Will the need for sustainable measures be incorporated to keep buildings cool in the warmer climate we can expect?


C.5. Energy Use

C.5.1. I welcome the proposals to improve on the (low) targets set by the West Midlands Regional Energy Strategy and the proposed establishment of a Climate Change Energy Agency following the model of London.  However, in Section 8 this is downgraded to only “looking to” and does not therefore seem to be a definite commitment.  The target of 15% electricity for corporate buildings to come from a green electricity tariff seems woefully unambitious as most Government Departments already achieve this and more.  Also, it is not clear from Section 2 whether the definition of Energy includes heat as well as electricity, although Section 8 does make reference to the Climate Change Agency’s role as promoting localised generation of power using combined heat and power plants.

Q.27. When will the Climate Change Agency be established and what resources will be allocated to it?

C.5.2. In a recent survey by the British Chambers of Commerce, time constraints, lack of information, a plethora of organisations and a failure to cater for small businesses accounted for 40% of the reasons given for not installing energy efficient measures.

Q.28. How will the needs of small businesses be catered for?

C.5.3. It should be clarified whether the Energy Services Company has been set up and whether the gas-fired CHP powering civic buildings “making a contribution to the target of ensuring that 30% of Birmingham’s energy is generated locally by 2020” is up and running and, if so, what lessons can be learned (does the plant, for example, provide for cooling as well as heat and electricity generation?).  Whilst the local generation target is laudable it is not clear how this fits in with the parallel target which aims for only 15% of energy use to come from renewable sources by 2020, which compares unfavourably with the 20% EU target, recently approved by the Government.  Also, it is not clear if it relates only to electricity generation or to total power for buildings, including heat, currently mostly generated by natural gas from the grid, which is not sustainable in the long term.  I have assumed that transport energy requirements are not included, but it is not clear.

Q.29. Does the CHP plant in the City Centre provide for cooling as well as heat and electricity generation?

Q.30. Do the targets for renewables and local generation cover all energy uses or just electricity generation?

C.5.4. There is massive potential for decentralised energy generation, yet compared to cities in Europe, or even Woking, Birmingham seems to have no vision for maximising local generation of heat and power (and cooling) from renewable sources.  Mention is made of a network of CHP stations that are 70% more efficient than conventional power stations, which implies gas as the source of fuel.  Utilising gas more efficiently is obviously beneficial but not if it is at the expense of “greener” options.  In the glossary, embedded generation is described a being typically smaller generation but it does not have to be the case!  Given the waste of energy from transmission along the national grid, this is a major fault in the document.

C.5.5. In contrast, the Mayor of London’s Energy Strategy envisages at least 27MWp photovoltaics and 6 large wind turbines by 2010, as well as anaerobic digestion and biomass CHP plants.  By 2020, the plan is for 500 small wind turbines.  Though there is insufficient attention to solar thermal and geothermal, this is a well thought out strategy led by the man behind Woking’s success and we know from other examples that it is not wishful thinking.  Munich has one of the largest district heating systems in Europe with a length of 550km and an output of 2570 MW.  A new district in Munich Riem is supplied with electricity and heat from a geothermal plant.  In Sweden 95% of new homes are fitted with ground source heat pumps.  In Dagenham, wind generators produce enough electricity to power Ford’s engine plant – and look beautiful too (certainly in comparison with the power stations and pylons in the vicinity).

C.5.6. So, whilst it is laudable that, in Birmingham, the use of renewable energy systems is to be promoted on public buildings and especially schools, the impression is that these are to be small and piecemeal projects rather than part of a major strategy.   It should be made clear, for example, that renewables will be incorporated as standard in the Building Schools for the Future programme.  Even better would be a plan to link up with other buildings and dwellings in the locality of a school.  In areas of fuel poverty/poor standards of heating and insulation the refurbishment or replacement of the local school could be an opportunity for heating or powering a whole neighbourhood.  Such schemes are taking place in mid Wales.  One example is the building of a new community centre which was turned into an opportunity to provide a biomass powered district heating scheme for the village school and surrounding homes.

C.5.7. If local power generation is to be more than tokenistic in a City of a million people, Birmingham should be joining in the campaign to change the rules that limit the capacity of local networks.  This is not mentioned.

Q.31. Will “excellent” building standards and embedded generation be mandatory in all Building Schools for the Future Projects?

C.5.8. On page 46, we are told that Birmingham City Council is a member of the Carbon Trust Management programme for local authorities and undertook a detailed assessment of actions required to decrease energy use.  It would be helpful if more information could be provided. The actions listed seem vague and inadequate.

Q.32. What was learned from the Carbon trust management Progamme’s detailed assessment of actions required to decrease energy use?

C.5.9. One of the actions to be taken by the Climate Change Agency will be to establish a finance mechanism to deliver localised power generation and there is also a mention of a domestic and small business renewable energy grant scheme but not how it is to be financed.   Not mentioned is the recently announced council tax rebate scheme for energy efficiency and solar thermal installations, which are already reasonably cost effective, following the successful example of Braintree.  This is a welcome development but I suspect the driver behind this was British Gas (anxious to be leaders in the Energy Efficiency Commitment) rather than the Council and it is likely to stimulate those who could afford to take these measures anyhow.  Also omitted is any discussion of Government policy in this area.

C.5.10. At present, in the UK, renewable electricity generation is supported through the Renewables Obligation (which provides a subsidy to renewable generation financed by a levy that works out at about £7 a year on the average domestic electricity bill) and the Low Carbon Buildings Programme, which involves grants financed by the taxpayer.  The latter, even with the £6 million addition announced in the 2007 budget, cannot meet demand for domestic level microgeneration and the RO has succeeded only in increasing renewable electricity generation from just under 2% in 1990 to 4.2% in 2005.  In contrast, most other EU countries operate a system of preferential feed-in tariffs for renewable generation.  At a cost of £12 a year on electricity bills in Germany, the remuneration arrangements for renewables have yielded much more impressive results.  Despite only being operational in its present form since 2004, by 2005 Germany was generating 10.2% of electricity consumed from renewables.  The legislation has stimulated considerable private investment, including within local communities. The village heating scheme at Mannenheim previously mentioned was the brainchild of two local farmers!  In Munich, the Local Agenda 21 Group established a solar club with over 660 citizens investing in PV plants.   In the Budget, the Chancellor announced tax breaks for income generated from renewable energy certificates (ROCs) from microgeneration, though in practice the process for individuals is too bureaucratic to be of benefit.   If, instead, there were to be tax exemption for income generated from a preferential feed-in tariff, then we could see a situation whereby investment in renewable energy would be more attractive than putting money into ISAs!  This could transform the incentives for investments in renewable energy.

C.5.11. Freiburg, already mentioned in connection with their go-ahead transport policy, is a also a good example of the success of German energy policy.  Since the 2004 change in the German Renewable Energies Act, which guaranteed a minimum of 45.7 eurocents per Kwh for photovoltaic installations going on stream in 2004, the rate of increase in the number of installations has been exponential.  Over the 2 year period to 2006, there has been more than a doubling from 6,000 sq metres to 15,000 square metres (10 Alexander Stadiums).  Solar thermal collectors, which are inherently more cost-effective at the present time, have also increased, but not at the same high rate as there is no similar mechanism for renewable heat (though CHP plants have a higher feed-in tariff than plants that generate only electricity).  The high unit payment is guaranteed for 20 years, making it worthwhile for small investors, like the farmers and their neighbours, to put their money into these developments (The tractor store next to the biomass plant is covered in photovoltaics.)  However, sensibly, there is a 1% a year reduction for installations in later years to encourage innovation to the point that solar electricity is of comparable cost with that generated from fossil fuels.

C.5.12. Freiburg is marketing itself as the centre of Germany’s solar region.  They have attracted more than 80 companies in the solar industry and several major research institutes (including the Fraunhofer Institute for Solar Energy Systems) are located there.  Freiburg is now the Headquarters of the International Solar Energy Society, founded in the USA in 1954.

C.5.13. If Birmingham is serious about supporting the development of renewable technologies in the West Midlands, detailed consideration need to be given to the factors that have led to the success of places like Freiburg and in removing any impediments are in our way.  Simply setting up an energy agency for a few flagship projects will not be enough to help the City remain competitive and attract investment.

Q.33. What is the Council’s and the BSP’s policy on energy efficiency and the use of renewables? 

Q.34. What changes would the BSP like to see in Government support for local generation and local energy networks and what has been Birmingham’s response to the consultation on the next stage of the Energy Efficiency Commitment requiring energy generators to provide measures to increase energy efficiency? 

Q.35. How might Birmingham work effectively with energy companies and grant-giving bodies to overcome customer suspicion as to their motives in offering subsidised installations and to make home and business energy audits available on a systematic basis?


C.6. Waste

C.6.1. Birmingham has a poor record on waste minimisation and recycling (coming 286th in the league table amongst local authorities) and there is evidence of a lack of commitment to the waste hierarchy (reduce, reuse, recycle) as a result of the contract with the Tyseley Incinerator.   A City the size of Birmingham ought to have a plastics reprocessing nearby but the Council has done nothing to attract such a facility whilst o feed the incinerator.  Though I welcome the proposal to “seek to utilise” the waste heat from the Tyseley plant by 2010, this should not be an excuse for not improving dramatically the performance on recycling.   The target of 30% by 2010 is risible and little detail is given about kerbside collections.  The introduction of green waste collections in addition to the paper round and the commitment (not mentioned in the document) to extend mixed kerbside collections of glass, metal and plastic beyond current pilots is welcome.

C.6.2. As a keen composter myself, who, with the benefit of the Bokashi effective micro-organism system, has recently starting composting kitchen waste, I am pleased that the Council wants to promote composting.   However, no detail is given and, as far as I am aware the only methods adopted so far has been the sales of plastic garden composters at cost price, which will not exactly revolutionise practice.  In any case, many citizens are not able to compost.  If Birmingham is to improve its performance to meet climate change targets, it needs to learn from those authorities, both in the UK and abroad, that have been more successful.  The first lesson is that people who recycle and compost should be rewarded for so doing.  The Local Government Association (with a Tory majority) has campaigned recently for councils to be given the powers to charge for excess amounts of waste. But no support for this has come from Birmingham City Council.  Variable charging schemes have had a massive impact in other European countries, such as the Netherlands and Germany and Belgium, and, if implemented carefully, would represent an equitable way of charging people and businesses for their waste collection services, as opposed to a fixed fee or council tax charge.  In Germany, where kitchen and green waste and other recyclables are collected free of charge, I met people who had halved their refuse collection charges by opting for fortnightly collection of residual inert waste.  In continental Europe, returnable deposits on bottles are the norm.

C.6.3. Even US cities do better than us.  San Francisco already recycles 65% of its waste and turns kitchen waste into compost to provide fertilizer for agriculture in surrounding districts.  They make no charge for collection of recyclable or compostable materials and give special concessions and services to senior citizens, disabled people and those on low incomes,  for collection of other types of household waste.  Munich collects thousands of tonnes of organic waste for biogas and biomass energy generation.  If Birmingham wants to set an example, instead of trailing behind, why can’t we do something similar?  

Q,36. What is the target for full coverage of doorstep collections, metal, glass and plastics, as well as the current almost universal paper and green garden waste schemes?

Q.37. Will Birmingham start collecting kitchen waste?  If so, when? 

Q.38. Will the study into the  production of energy from waste include organic waste?

Q.39. How will Birmingham encourage plastics recycling and minimise transport costs of recycling?

Q.40. How is it proposed to promote the use of washable nappies?  For example are maternity units and retailers being involved?


C.7. Water

C.7.1. I am concerned that, whilst noting on page 53 that impacts from flood risk from the total number of small scale developments are unknown, there seems to b e no challenge to the current position that these do not require flood risk assessment.

Q.41. What is the size of new developments that will be required to provide information during the planning process on the suitability of water efficiency and sustainable urban drainage systems (SUDS)?

Q.42. What is Birmingham doing about the cumulative effect of small developments, including those that do not require planning permission?

The document notes that the supply of water uses large amounts of energy.

Q.43. Why is there no target for reducing energy consumption from water supplies and what will be done to minimise this?

D. Conclusion

I hope efforts will be made to address the 41 questions I have raised in this response.   As the European Urban Development Performance Assessment of Birmingham pointed out as long ago as March 2004, the high profile the City is seeking of being a World Class City will always be undermined until positive progress on sustainability can be demonstrated.  The City needs to move away from flagship projects and tokenistic gestures to ensuring that energy management and the climate change agenda is mainstreamed.

I look forward to the final document which I hope will be of a sufficiently high quality to add to my pride in my City.

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