Carbon Co-op response to Manchester Climate Change Strategy 2016-50

Below is Carbon Co-op's response to Manchester Climate Change Agency's Manchester Climate Change Strategy 2016-50, the full call can be found here: http://www.manchesterclimate.com/2050consultation

October 2016

1. About Carbon Co-op

Carbon Co-op is a not-for-profit community energy organisation based in Manchester. Operating since 2007, we enable householders to makelarge-scale reductions in their energy usage. We have over 100 householder members paying £35 a year and interact with around 3,000 people a year with our products and services. Our Community Green Deal project demonstrated that deep, whole house retrofit is possible at scale and affordable prices and has been internationally recognised as an innovative and unique best practice exemplar.

2.Manchester: A Certain Future/Manchester Climate Change Agency - 2050 targets and citizen involvement

We acknowledge the need to frame carbon reduction activities within a 2050 strategy but are deeply concerned that a focus on 2050 risks negating action in the short to medium term. We would encourage Manchester Climate Change Agency (MCCA) to adopt an explicit 'carbon budget' approach on the same timetable as national carbon budgets that support the Climate Change Act. Importantly these include tough targets and independent oversight on proposed plans and achievement of these targets. We note with alarm that, according to the last two years of annual reports, the Manchester: A Certain Future (MACF) 2020 targets seem likely to be missed and would encourage a fuller, more open and honest debate about the reasons for this and engagement with civil society on how we might tackle this.

We are additionally concerned that MCCA and MACF are too insular and inward looking in their outlook and approach and their work lacks external, independent oversight. We encourage these two organisations to open up their decision-making and engagement structures, using co-operative principles of member control and ownership to involve Mancunian citizens and wider civil society groups, organisations and businesses it their work.

Only by involving citizens directly in their work will MCCA and MACF enable the kind of action necessary to meet challenging carbon reduction targets.

3. Domestic building energy efficiency

We refer MCCA to the recommendations made within the Greater Manchester Retrofit Strategy (published by Association of Greater Manchester Authorities in 2013) and urge them to lobby the Greater Manchester Combined Authority (GMCA) for its regular review and updating. In September 2016, Carbon Co-op and technical partners URBED published the Retrofit Factfile and we would encourage MCCA to review this document and where appropriate incorporate aspects in to your delivery plan.

In particular, it outlines the carbon impact of current domestic energy usage and the huge scope and scale of potential reductions.

In general, we believe the carbon savings possible from domestic energy efficiency have been underplayed. Our Community Green Deal retrofit programme delivered savings of around £1,000 per year in energy bills, reducing gas usage by 60% and achieving '2050 domestic emissions targets' of 17kgCO2/m2/year for an average £40,000 per property.

The deployment of whole house retrofit at scale across Manchester's housing stock has the potential to make huge inroads to the city's carbon emissions whilst improving health outcomes and generating jobs and skills and at costs that enable institutional investment.

We are concerned that the MCCA lacks an explicit 'fabric first' commitment to retrofit. Standard, well understood products and systems (insulation, windows, ventilation systems) are available today to reduce a home's energy demand by 80%. Yet too often, unproven technological solutions such as widespread deployment of heat pumps, are advocated. These technologies only make economic and environmental sense when deployed AFTER fabric improvements and their efficacy is often unproven.

4. Role of MCCA and MCC

While acknowledging the limits of local authority action, we believe Manchester City Council (MCC) and the MCCA have a crucial role in enabling more domestic energy efficiency works in Manchester.

We believe MCCA and MCC can:

i) Contextualise city wide carbon reductions possible from building energy efficiency

We encourage MCCA to carry out modelling and city-wide business planning to demonstrate the potential for domestic energy efficiency to meet carbon reduction targets. MCCA need to answer essential questions such as how many homes need to be retrofitted, to what level, by what date? Setting these kinds of targets provides a robust framework for action and a means to measure future progress.

ii) Benchmark energy efficiency reduction targets

We encourage MCCA to adopt a city-wide, domestic building emissions target of 17kgCO2/m2/year and to explain to Manchester citizens what this target means to them, why we need to achieve it and what changes are necessary to make to homes in order to make achieving the target a reality.

Iii) Use its tax raising powers to incentivise energy efficiency, 0% interest loans

We recommend MCC offer Council Tax reductions to householders who achieve benchmarked, low carbon improvements, ie linked to EPC ratings. Furthermore, it should extend its 0% interest HELP (Home Energy Loan Plan) loan scheme in scope and scale in order to encourage energy efficiency works.

iv) Create an eco Trusted traders scheme

The Manchester supply chain for domestic energy efficiency works is small, immature and at times prone to mis-selling and poor quality work. MCC and agencies such as Care and Repair have a crucial role in offering consumer confidence and running trusted trader schemes.

v) Communicate best practice and low carbon case studies

MCCA has a crucial role in communicating best practice exemplars, promoting eco-homes within the city and telling the stories of the householders who created those homes via its communication channels and via local and regional press and media.

vi) Deliver an ambitious local ECO (Energy Company Obligation) programme

We note the ambition of GMCA and MCC to distribute ECO funds locally. We encourage MCCA, GMCA and MCC to learn the lessons to the current, botched ECO (Energy Company Obligation) scheme – which Carbon Co-op has experience of delivering. Too often ECO has been used to deliver poor quality, single measure improvements that fail to achieve the carbon reductions necessary to achieve targets and risk 'time bombs' in the form of poorly specified and poorly applied measures. We urge GMCA and MCC to use ECO to stimulate a skilled, local supply chain, delivering high quality, whole house retrofit works.

5. Summary of Carbon Co-op recommendations

For amendments and additions to the strategy and its implementation plan.

  • Lobby GMCA for the updating of the Greater Manchester Retrofit Strategy
  • Engage Manchester citizens and civil society in MACF/MCCA via co-operative principles
  • Adopt an explicit commitment to 'fabric first' retrofit
  • Adopt a city-wide, domestic building emissions target of 17kgCO2/m2/year
  • Lobby MCC to incentivise energy efficiency via Council Tax
  • Extend 0% interest HELP loan scheme
  • Create an eco Trusted traders scheme
  • Learn the lessons of past ECO delivery and put in place ambitious plans for future local ECO delivery
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