City Hall
The Queen’s Walk
London SE1 2AA
Switchboard: 020 7983 4000
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Web: www.london.gov.uk
Boris Johnson
Mayor of London
(Climate change adaptation strategy response)
Our ref: MT/KR
Your ref:
Date: 7 May 2010
via email to: adaptation@london.gov.uk
Dear Boris,
The Draft Climate Change Adaptation Strategy, February 2010
I welcome the opportunity to comment on your consultation on a draft Climate Change
Adaptation Strategy. I am responding on behalf of my colleagues Dee Doocey and
Caroline Pidgeon as the lead on Environment issues for the Liberal Democrat Assembly
Members.
Overall the key points of our response are that the next draft of the strategy should:
 Put adapting to climate change at the heart of a range of policies, across Mayoral
strategies and GLA functional bodies, to transform London into a sustainable
low carbon city by 2050
 Engage Londoners and businesses to raise public awareness of climate change
adaptation. This should also include highlighting the potential costs and benefits
of both adaptation and inaction
 Contain a plan for effectively cooling London’s transport
 Accelerating progress on and funding of initiatives to increase the number of
drinking fountains, street trees and green roofs.
Policy Context
We welcome the publication of this strategy as the first climate change adaptation
strategy for London, as it is vital that agencies across London work together to help the
city adapt to the effects of climate change.
Overall the strategy would benefit from more detail on the cost of proposed actions and
how they will be funded. Alongside this it is important to estimate the cost-benefits of
climate change adaptation so that, conversely, likely costs of inaction are made clear and
the benefits of taking action are highlighted. For example, installing additional green
roofs may reduce the need for more costly improvements to drainage infrastructure.
Additionally, the strategy should go further in emphasising that any new development
in London must be sustainable and increase the city’s resilience to climate change. In
particular it is concerning that so much housing development is still taking place in
areas of flood risk. According to the Environment Agency, London has the highest
regional percentage of new dwellings built in areas of high flood risk (22% of all new
dwellings in 2008 compared to an England average of 9%) and the highest area of land
changing to residential use within areas of high flood risk than any other region in
England (11% in 2008 compared to an England average of 6%). 1 We have previously
advocated that new homes in the Thames Gateway should utilise innovative building
techniques which are resilient to flooding.2
The strategy could also go further in dealing with the increasing likelihood of winter
storms and their potential impact on London. These storms are cited as a hazard for
insurers (Fig 8.1), and recent evidence has shown how disruptive they can be for
London’s transport infrastructure in particular.
We recommend that the next draft of the strategy should:
 More clearly articulate the importance of sustainable development in London
 Include further detail on other climate change impacts, such as winter storms
Flooding
We welcome the progress made in beginning to co-ordinate work on flooding in
London, particularly around the establishing of the Drain London Forum to tackle the
increasing problem of surface water flooding.
In terms of surface water management, the strategy states that the GLA is working
with the boroughs to support them in producing their surface water management plans
and encouraging boroughs facing a shared risk to work together. 3 The strategy could
usefully set out how the GLA will ensure that there is an integrated approach to surface
water management, which does not simply displace the problem from one area to
another and to work to ensure that plans in one borough do not increase risk to
neighbouring areas.
The emphasis in the strategy of the importance of urban greening is welcome. However,
the strategy should provide more detail about how existing green spaces, and trees, will
be improved and retained. The Mayor could also offer leadership around how to
See, Environment Agency, State of the Environment in London, February 2010, p.22
http://www.environment-agency.gov.uk/research/library/publications/34083.aspx
1
2
http://www.gla.libdems.org.uk/news/000278/homes_in_thames_gateway_should_be_built_on_stilts.ht
ml
3 Draft climate change adaptation strategy, February 2010, p.30
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3
ameliorate the problem of the predominance of impermeable surfaces in the capital. For
example, a scheme to ‘reclaim’ paved over front gardens for food growing, or simply as
green spaces, could form part of the Capital Growth initiative. The strategy’s comments
around the improvements to hospitals and schools with regard to overheating could
also extend to encouraging the permeability of car parks and playgrounds; and
emphasise the cross-benefits of greening hard landscaping in reducing overheating.
Overall this chapter would benefit from a clearer integration with the Mayor’s draft
Water Strategy. The documents are by nature complementary, but they are also
overlapping, and it would be helpful if proposals (and then policies) in the Water
Strategy were clearly referenced. For example the Climate Change Strategy states that:
“The Mayor supports the principle of the Thames Tideway Tunnel to reduce the
impacts of CSOs”.4 Whilst the Water Strategy, goes further: “Proposal 10 The Mayor
will work with Thames Water and other partners to support the construction of the
Thames and Lee Tunnels, in a cost-effective way and minimizing disruption, as a means
of greatly reducing storm discharges from the combined sewer system and improving
the quality of the water in the River Thames”. 5
We recommend that the next draft of the strategy should:
 Provide detail as to what the new Surface Water Management Plan for
London will achieve
 Ensure that there is an integrated approach to surface water flooding
 Set up a scheme to ‘reclaim’ paved over front gardens and return them to
green and growing spaces
 Clarify the links to the Water Strategy, and reference key policies, actions and
implementation timetables
Drought
We agree that water companies must work even harder to reduce their levels of water
leakage. We also support the introduction of water meters, although we encourage the
Mayor to examine the use of smart meters and to ensure that London’s poorest
households do not suffer disproportionately.
We recommend that the next draft of the strategy should:
 Set out a timetable for the implementation of water efficiency measures in
London and what interim targets the Mayor has set for reducing water
consumption
4
5
Draft climate change adaptation strategy, February 2010, p.99
http://legacy.london.gov.uk/mayor/environment/water/docs/draft-water-strategy.pdf
Direct telephone: 020 7983 4362 Fax: 020 7983 4417 Email: mike.tuffrey@london.gov.uk
4
 Clarify what measures the Mayor will be lobbying the water companies to
deliver
Overheating
The strategy is clear that overheating presents a high risk to London. We welcome new
policies in the London Plan such as the proposed ‘cooling hierarchy’ which has
recognised the significant challenge of adequately adapting the design of new building
developments to ensure that they do not rely on unsustainable air conditioning going
forward. However, what the strategy does not yet do is quantify what difference its
proposed actions will make on overheating in the capital. In particular it would be useful
to have a measure of the impact of the urban greening programme. We appreciate that
much more research needs to be undertaken to better understand the urban heat island
phenomenon and what actions can be taken to mitigate it. But as overheating presents a
significant risk to the capital in the future, this strategy needs to both set out what scale
of problem London is facing in terms of likely temperatures and their consequences, and
a range of further actions which could be put in place.
A key aspect of the chapter on overheating, which should be expanded upon, is the
impact of higher summer temperatures on London’s transport network. (It may be that
this will be included in Transport for London’s forthcoming climate risk assessment –
Action 33 – but this should be made clear). The strategy should set out what range of
temperatures are probable on buses and the underground in future and what effect the
actions proposed will have upon these temperatures. Currently it is unclear what is
regarded as an acceptable temperature (although it is noted that a train above ground
reached in excess of 40˚C in the 2003 heatwave). It would be useful it Transport for
London’s process for monitoring of temperatures on the network were explained.6
Given that funding was cut for some aspects of the Cooling the Tube programme, the
strategy should explain whether temperatures on the network are sustainable in the
short, medium and long term. We would welcome further detail on the timescale and
funding available for “investing further opportunities to use groundwater cooling
systems” in London Underground stations. 7
If it is the case that overheating on certain parts the transport network will potentially
alter Londoner’s travel patterns in the future, this should be linked to the chapter on
London’s economy (flexible working may allow people to travel at cooler times of day)
and other Mayoral strategies which contain policies on reducing the need to travel. The
The answer to MQ2382/2009 states that “LU monitors temperatures at 95 strategic locations in central
London stations.” http://mqt.london.gov.uk/mqt/public/question.do?id=27444
7 Draft climate change adaptation strategy, February 2010, p.113
6
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5
importance of reducing Londoners’ need to travel does not just apply to overheating;
lessening distances to travel to work, school and shop would equate to a more resilient
London, less disrupted by the effects of severe weather. As such the strategy could,
throughout, usefully expand on the organisational and behavioural change implications
of climate change adaptation. The section below will cover the importance of improving
public awareness of climate change adaptation, but in this transport context we note
that the City of London have proposed that temperature displays outside tube stations
would be useful for subsurface lines to inform passengers before they travel of what to
expect.8 We would support such temperature displays, and the strategy should include
more detail on how communications with the public can be improved.
Additionally in this chapter, the importance of appropriate urban greening and shading
could also be extended to include London’s transport authorities (e.g. appropriate
shading at bus garages). The strategy also mentions ‘cool roofs’, but should provide
more detail on the timescale for implementing this technology in London and what
assessment has been made of where it should be encouraged.
We recommend that the next draft of the strategy should:
 Contain an estimate of the impact of urban greening, and other proposed
actions, on overheating
 Include steps to be taken by Transport for London in the Heatwave Plan9
 Detailed plans about what steps Transport for London are taking to manage
overheating on transport in the short, medium and long term
 Examine greening and shading on the transport network
 Explore the organisational and behaviour change consequences of adapting to
climate change
 Provide detail on the applicability of ‘cool roofs’ to London
Cross-cutting
The section above has largely dealt with issues regarding transport infrastructure.
Although we would welcome the Mayor extending his looking for opportunities to
install publicly
accessible drinking water fountains to station refurbishments (and other Transport for
London projects), and other public bodies such as the NHS and schools.
Rising to the Challenge - The City of London Climate Change Adaptation Strategy, First Published May 2007,
Revised and Updated January 2010, http://www.cityoflondon.gov.uk/NR/rdonlyres/ECD1C5D2-A6454D5F-AD03-F9B17BC1D14C/0/SUS_AdaptationStrategyfinal_2010update.pdf
9 Note that steps such as London Underground distributing water are already mentioned in the NHS
Heatwave Plan, 2010.
http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/@ps/documents/digitala
sset/dh_114423.pdf
8
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6
The strategy may also benefit from more references to what other cities in similar
positions are doing to adapt to climate change. 10
Overall, we think that there are two key crosscutting issues which are not sufficiently
addressed by chapters 6-9, these are firstly the linkages to other strategies and the GLA
Group and secondly the issue of public awareness of climate change adaptation. In terms
of joined up working across strategies it is, for example, concerning that there is no
mention of the Homes and Communities Agency in the entire strategy. Whilst it is
understandable that the strategy should not replicate or simply repeat the London Plan
and the Housing Strategy, the Mayor’s role in housing and urban development is a
significant tool to be used to ensure that new development in London is at the forefront
of sustainable design and construction. Similarly the strategy could reference what steps
the police are taking to adapt their estate and operations to flood risk. 11 Likewise the
strategy could say more about the role of the LDA, and the Economic Development
Strategy, in making sure that London’s businesses can benefit from aspects of
adaptation (e.g. as specialising in new technologies such as retrofitting). The LDA also
has a role to play in helping small businesses become more resilient and adapt to climate
change.
The strategy is clear in the need to raise awareness of climate change adaptation,
particularly around flooding where there is a low level of public awareness of
flood risk and what action to take to prepare for, or respond to a flood. 12 This need to
raise public awareness has broader implications. Given that the public consultation draft
of this strategy has adopted new forms of public consultation, it will be interesting to
see an evaluation of the effectiveness of the new website format and of the range of
adaptation ideas submitted in the next draft of the strategy. Within the strategy itself,
and across many Mayoral strategies are actions and initiatives which involve raising
public awareness. It would be useful to group actions together which involve
Londoners. For example: home retrofitting could be used as an opportunity to look at
front gardens and the proposal for a public air quality website could also consider the
future need for warning people of heatwaves.
Linked to this issue of raising public awareness, is that of setting out practical steps of
how Londoners and indeed developers and businesses can adapt to climate change.
An example of this approach is Adapting to climate change: Lessons for London, July 2006 (London Climate
Change Partnership). http://www.london.gov.uk/lccp/publications/adapting-jul06.jsp
11 The strategy highlights that 27% (or 46 out of 169) of London’s police stations are at risk of flooding.
(Key social and civil infrastructure at tidal and fluvial flood risk (source: GLA Regional Flood Risk
Appraisal). Draft climate change adaptation strategy, February 2010, p.45.
12 Draft climate change adaptation strategy, February 2010, p.35, 44, 46.
10
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Currently the strategy does not offer a checklist of practical steps – this may have been
seen as unnecessary or ineffective but it could link to, or update, existing guidance. 13
We recommend that the next draft of the strategy should:
 Look to install drinking water fountains more widely across London
 Evaluate what policies have been successfully used by other cities
 Ensure that relevant policies and actions from other Mayoral strategies are
referenced
 Outline how the GLA is working with the functional bodies and other public
sector agencies
 Set out what steps will be taken to raise public awareness of climate change
adaptation
Implementation
We welcome that this draft of the strategy has in part 4 a ‘Roadmap to Resilience’ for
implementing the strategy. This section should in addition set out: when and how the
strategy’s actions will be monitored; what funding will be available and when for the
actions.
We recommend that the next draft of the strategy should:
 Make clear what funding is allocated for climate change adaptation
 Consider setting interim targets, e.g. for increasing tree cover, which will assist
in monitoring the implementation of the strategy
We look forward to your response.
Yours sincerely,
Mike Tuffrey AM
Leader, London Assembly Liberal Democrat Group
For example: Your home in a changing climate, February 2008, (London Climate Change Partnership),
http://www.london.gov.uk/lccp/publications/home-feb08.jsp. Adapting to climate change: a checklist for
development. Guidance on designing developments in a changing climate, November 2005 (London Climate
Change Partnership). http://www.london.gov.uk/lccp/publications/development.jsp
13
Direct telephone: 020 7983 4362 Fax: 020 7983 4417 Email: mike.tuffrey@london.gov.uk
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