Friends of the Earth HRSC0005
Friends of the Earth (England, Wales & Northern Ireland) response to the Environmental Audit Committee on heat resilience and sustainable cooling.
Friends of the Earth is a campaigning organisation seeking, amongst other things, policy changes to ensure the UK delivers on domestic and international carbon reduction goals and carries out necessary adaptation measures. We are pleased to submit this evidence to the inquiry.
What evidence exists on the relationship between heat and human health (mortality and morbidity), and which communities are worst affected?
1) Neighbourhoods at risk - Friends of the Earth worked with Professor Sarah Lindley at Manchester University to identify the neighbourhoods most at risk from heat and therefore most in need of adaptation support.
2) Professor Lindley brought together data at a small neighbourhood level (LSOA, average population 1,700 people) on future heat projections for England and Wales under different amounts of global warming (1.5 degrees, 2 degrees, and 3 degrees) with social and geographical data (e.g., proportion of elderly people, crime rates, green space). The social and geographical data encompassed 17 domains and over 40 indicators and was used to identify socially vulnerable neighbourhoods. From this she was available to:
a) identify that 15,662 neighbourhoods in England would typically be exposed to ‘very hot weather’ (an average of 27.5 0C or more for five or more days over the summer period) in a 1.5 degrees global warming scenario and a slightly higher number of neighbourhoods would be typically exposed to ‘dangerously hot weather’ (an average of 30 0C or more for five or more days over the summer period) under a 3 degrees scenario. These figures equate to roughly 50% of all neighbourhoods.
b) Identify that 3007 of these neighbourhoods in England are ‘high risk’. These are highly socially vulnerable neighbourhoods typically exposed to very hot weather under a 1.5 0C scenario. 6 million people live within these neighbourhoods.
3) Using Professor Lindley’s data together with data from Leeds University on carbon footprints and UCL on ethnicity, Friends of the Earth also identified that these ‘high risk’ neighbourhoods typically had lower carbon footprints and are therefore less responsible for causing climate change than other neighbourhoods. And that people of colour are 4 times more likely to live within one of the priority neighbourhoods for adaptation than white people (a 1 in 3 chance, compared to a 1 in 12). The average proportion of people of colour in high-risk neighbourhoods for heat is 28% compared with a national average in English neighbourhoods of 9.5%.
4) A briefing on the research is available at: https://policy.friendsoftheearth.uk/insight/who-suffers-most-heatwaves-uk, which also has links to data downloads.
5) Natural cooling - Additional research on the urban cooling provided by trees and cool space, commissioned by Friends of the Earth from mapping experts TerraSulis, shows that trees and green space can provide up to 5 degrees of cooling on a summer’s night (based on modelling from five English cities). The research is at: https://policy.friendsoftheearth.uk/download/urban-cooling-trees-and-green-spaces-research-findings. Using TerraSulis’s research Friends of the Earth identified that people of colour make up 65% of the population in neighbourhoods with the least cooling and that people living on lower incomes are also disproportionately affected by a lack of natural cooling near their homes.
6) Heat and air pollution combined - We also found worse air quality in the hottest areas. Air pollution and heat are known to have a synergistic impact on health.
How can sustainable cooling solutions and adaptation strategies be implemented in such a way as to minimise overheating, reduce energy consumption and prevent overloading of the electricity grid during peak demand?
What actions can be taken to protect those most vulnerable to the impacts of extreme heat?
7) Friends of the Earth is advocating several policy responses to the heat adaptation challenge:
a) A programme of street-by-street home insulation targeted in the areas most at risk - Insulation keeps homes cooler in summer as well as warmer in the winter. We believe at least £60billion of public expenditure is needed for housing retrofit over a 10-year period (including for switching from gas heating to heat pumps or other electric heating), alongside regulatory measures (for example, in the rented sector). Sensibly, any retrofit programme should encompass adaptation measures as well as carbon cutting measures.
b) More tree cover in urban areas - Natural England is developing guidance to councils on how they should apply the Urban Tree Canopy Cover Standard in the non-statutory Green Infrastructure (GI) Standards. We are advocating for a minimum of 20% tree cover in urban neighbourhoods. It is critical that the Natural England guidance properly reflects the need for urban cooling and that it responds to the disproportionate lack of benefit from urban trees (and green space) felt by communities of lower income and higher proportions of people of colour. We would encourage the Committee to seek from Natural England oral evidence on the GI standards and guidance being produced which, we think, should be mandatory.
c) The provision of cool spaces - Winter 2022-23 saw thousands of warm spaces open up to enable people who could not afford to heat their home a warm space to get some respite from the cold. These were often churches, community centres and libraries. A network of cool spaces is similarly needed, which could be places cooled by air conditioning, when necessary. This would be less energy intensive than every home having an air conditioner (which in any case is beyond the financial means of many people). As well as providing respite, these spaces also provide social interaction which is known to be beneficial for mental health and addressing the growing issue of loneliness.
What extent do the Government’s Climate Change Risk Assessment and National Adaptation Programme (as well as other related strategies such as the Net Zero Strategy and Heat and Buildings Strategy) identify and address the risks from extreme heat?
8) Government plans – the Adverse Weather Health Plan, published by the UK Health Security Agency on 27 April 2023, states (paragraph 5.7, page 25) that “At-risk groups include older people, the very young and people with pre-existing medical conditions as well as those whose health, housing or economic circumstances put them at greater risk of harm from adverse weather.” National Adaptation Programme (NAP3) states (page 73) that “The main climate risks to health and wellbeing in the UK are those resulting from high temperatures, changes to air quality, and flooding. These directly impact on people’s health and wellbeing as well as on the delivery of health and social care services. These risks also impact on food safety, water quality and water supplies, and an increased likelihood of vector-borne disease in the UK. These are also more likely to negatively impact on some members of the population, including people with disabilities and older people. Of the UK population, 38% of disabled people are 65 and older.”
9) These plans, alongside content in the Carbon Budget Delivery Plan and Heat and Building Strategy, illustrate that the government is well aware of the scope and scale of the issue. Yet we do not see an adequate plan to address the issue. The government has not identified how far the actions and policy gaps identified in the CCRA3 are addressed in the NAP3.
10) In our view, vulnerable people need to be identified, including where there are concentrations of vulnerable people. Measures such as home retrofit, changes to the urban environment, and the provision of cool spaces are needed to provide some protection. And there needs to be a clear strategy that ensures GPs, regional and local agencies, care providers and other trusted intermediaries and networks reach out to vulnerable people ahead of forecast higher heat to ensure they know how to gain respite, because many of these people may be socially isolated and will need to be contacted.
11) The National Risk Register 2023 covers High temperatures and heatwaves (pages 146-7) and gives these an Impact level of 4 and a Significant Likelihood level of 3 (1 - 1.5 per cent). It is unclear how these ratings are arrived at and how accurate they are for the ‘reasonable worst-case scenario’ approach adopted throughout the Register.
Does the current planning framework do enough to encourage heat resilience measures such as cooling shelters, water bodies, green infrastructure and shading to be integrated into urban planning? Where such measures are incorporated, how accessible and successful are they?
12) National Planning Policy Framework (NPPF) – this does not address heat, resilience, and adaptation adequately, although the issue is mentioned. For example, “Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures” (paragraph 153, page 45), and “New development should be planned for in ways that: a) avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure...” (paragraph 154, page 45). More explicit guidance is needed, for example in the following chapters: 8. Promoting healthy and safe communities, 11. Making effective use of land, 12. Achieving well-designed places, and 14. Meeting the challenge of climate change, flooding and coastal change.
13) Green Infrastructure Standards - We are particularly concerned that these are voluntary. Our view is that they should be mandatory and calibrated to achieve clear outcomes including to address heat. Our view is that the current voluntary approach to green space provision in planning and development risks continuing to be casual, cosmetic and an afterthought rather than an integral part of planning that specifically aims to address heat.
14) National Design Guide and National Model Design Code (NMDC) – these set quality standards including for how new development should enhance the health and wellbeing of local communities and how green infrastructure and biodiversity should be approached. But there is little explicitly on heat in the Guide and the Code. They also do not address avoiding the loss of front gardens to hard surfacing which adds to heat and the loss of green space including for cooling and reducing flood risk, as has now been recognised by the National Infrastructure Commission. We are of the view that these should be updated to reflect the importance of designing with a warmer and wetter environment in mind.
What can be done to protect the UK’s existing public and private sector housing stock from the impacts of extreme heat while ensuring that homes are sufficiently warm in the winter months?
15) NAP3 refers to “the overheating requirement introduced through the Building Regulations in June 2022 to enhance the resilience of new homes to high temperatures” (page 20), but the main action for existing homes is for DLUHC, DESNZ, DHSC and the UKHSA to conduct more research, as set out on pages 74-79. While new research may be useful that should not hold back a housing retrofit strategy which provides public funds (at least £60 billion over 10 years) in addition to regulations on e.g., rented homes. This programme needs to encompass both heating and cooling.
What role might reversible heat pumps (which can act as both heating and cooling systems) and other emerging technological solutions, such as the development of smart materials, play in meeting future cooling demands?
16) Cooling approaches such as insulation, green infrastructure and designated cool spaces should be the priorities for adaptation. Reversible heat pumps are a useful technology for some spaces (e.g., designated cool spaces) but if used widely will both be very expensive for the users because they are energy hungry and will increase the demand for electricity production, with the associated carbon impacts. In a future energy system, there is an important role for excess renewable energy generation in the summer (when solar energy is plentiful) to be used to produce green hydrogen as an energy store for use in the winter. Excessive use of air conditioning in the summer weakens our ability to build energy stores for the winter.
How can cleaner refrigerants with low or zero global warming potentials support the UK’s cooling needs while contributing to the national emission reduction targets?
17) Heat pumps are a critical technology for future heating and sadly the UK is lagging other European countries in deployment, manufacturing, and innovation. Increasingly, newer models are using refrigerants with low global warming potentials while maintaining or increasing efficiency (e.g., R290, propane). But as we describe above, we believe air conditioning should not be a widely used technology, although if countries do not increase and meet their international climate commitments, we will have a much warmer world and many more expensive adaptations will be needed (and adaptation will be impossible in some instances). We note that the government’s Carbon Budget Delivery Plan admits current policies fall well short of the UK meetings its international carbon cutting commitment.
How effectively is the Government working across departments and with local authorities to ensure a coordinated approach is taken to heat resilience?
18) NAP3 states “The UK’s national and local government bodies continue to work closely together to tackle climate change at both national and local levels” (page 8) and that, “Collaboration between the UK government, local government, and local partners is critical to making adaptation work locally” (page 118). Although NAP3 also talks extensively of the role of local authorities on pages 16, 21, 30, 79 and 115-6, our experience of working with local government organisations in the Blueprint Coalition is that local government lacks the powers or resources needed to address climate change – both mitigation and adaptation – adequately. The recent Local Government Association report on adaptation states that “To make meaningful change and apply sufficient resources to delivering on climate action plans (both mitigation and adaptation), local authorities need additional funding or the ability to generate finance opportunities.” And “Lack of funding/available finance” was also the top identified barrier (93 per cent) faced by authorities in addressing impacts to both communities and service delivery.” The government’s Local Net Zero Forum with councils discusses the role of councils on climate change, but this is moving incredibly slowly, and we are sceptical that it will address barriers to council action properly.
Does the UK need a dedicated Heat Resilience Strategy? What lessons can be learned from other nations when it comes to national strategies for heat resilience?
19) Friends of the Earth has not had the resources to assess plans within the devolved nations. However, we are strongly supportive of nations and English local authorities (working together at the appropriate level) taking a lead on adaptation where local knowledge is central to the appropriate response, backed up with necessary powers and resources and UK or English standards where necessary. We are agnostic on the issue of whether there should be a separate Heat Resilience Strategy or a combined Adaptation Strategy. What is more important, obviously, is whichever route is taken it is fit for purpose and is properly resourced.
August 2023