Read the text of this document (22 pages)
1
Appendix - Consultation on
Hillingdon Draft Climate Action Plan
2025 to 2028
Comments from
Hillingdon Friends of the Earth
January 2025
Contents
Hillingdon Friends of the Earth – who are we? ................................ ................................ ...... 3
Hillingdon Friends of the Earth general comments on consultation document ....................... 4
Comments by section of consultation document ................................ ................................ ... 5
Foreword ................................ ................................ ................................ ........................... 5
Preface ................................ ................................ ................................ .............................. 5
1. The Need for Continued Action ................................ ................................ ...................... 6
2. Our Vision................................ ................................ ................................ ...................... 8
3. Our Progress ................................ ................................ ................................ ................. 9
Theme C1: Community Leadership ................................ ................................ ................ 9
Theme C2: The Council’s Own Operations ................................ ................................ .... 9
Theme C3: Building Better Places ................................ ................................ ................. 9
Theme C4: Using Clean and Green Energy ................................ ................................ . 10
Theme C5: Waste Management ................................ ................................ .................. 10
Theme C6: Climate Change Adaptation and Mitigation ................................ ................ 10
Theme C7: Carbon Offsetting ................................ ................................ ...................... 11
Theme C8: Sustainable Transportation ................................ ................................ ........ 11
Theme C9: Transparency, Communication and Reporting ................................ ........... 11
4. Our Own Operational Carbon Footprint ................................ ................................ ....... 12
5. Wider Climate Action Progress ................................ ................................ .................... 13
6. Actions for 2025-28 ................................ ................................ ................................ ..... 15
Theme C1: Community Leadership ................................ ................................ .............. 15
Theme C2: The Council’s Own Operations ................................ ................................ .. 16
Theme C3: Building Better Places ................................ ................................ ............... 16
Theme C4: Using Clean and Green Energy ................................ ................................ . 17
Theme C5: Waste Management ................................ ................................ .................. 17
Theme C6: Climate Change Adaptation and Mitigation ................................ ................ 18
2
Theme C7: Carbon Offsetting ................................ ................................ ...................... 18
Theme C8: Sustainable Transportation ................................ ................................ ........ 19
Theme C9: Transparency, Communication and Reporting ................................ ........... 19
Hillingdon Friends of the Earth conclusion ................................ ................................ .......... 21
Appendix 1 ................................ ................................ ................................ .......................... 22
Friends of the Earth Local Action Group Charter extract: ................................ ................. 22
3
Hillingdon Friends of the Earth – who are we?
Hillingdon Friends of the Earth (HFoE) has been a local group affiliated to Friends of the Earth (FoE)
for more than 35 years. Following an initiative from central FoE, HFoE set up a Climate Action Group
in January 2020 with over 60 people attending the first meeting. Subsequently FoE consolidated the
original local groups, and the climate action groups into “local action groups”, leaving Hillingdon FoE
with an enhanced brief but a continued focus on local climate action.
FoE make resources available1 to help those groups lobby and work with their local councils. Those
resources include research undertaken by FoE alone, or in partnership with organisations such as
Ashden2. Some research is specific to each local authority so relevant figures specific to Hillingdon
are easy to find3.
To better understand and inform ourselves about issues relevant to the climate emergency, we set up
a number of sub-groups looking at specific issues, including energy, waste, trees & land use,
transport and buildings & homes. This response to the consultation on the Hillingdon Draft Climate
Action Plan 2025 to 2028 has been informed by this material and these acti vities, and so involves
contributions and insights from several people.
We were pleased that Hillingdon Council declared a climate emergency in January 2020, and then
adopted its Strategic Climate Action Plan in July 2021. At that time the Council had a d edicated
climate change resource, David Haygarth, Climate Action Manager. That first version of the Plan
incorporated much of our feedback and is a strong document. When the Climate Action Manager’s
role was ended the Borough experienced a long period when progress on meeting the actions and
objectives in the Plan seemed minimal. Our group had little dialogue with the Council despite many
offers to meet and assist with implementing the Plan. This made the publishing of the plan feel like
just a paper exercise. More recently Ian Thynne (Head of Environmental Specialists - Hillingdon
Council) has been meeting with us to hear feedback on Council climate progress and hear our offers
of assistance. We hope the meetings have not commenced merely to tick boxes owin g to the
imminent review of the Plan.
We would like to think that there will be processes under which we can continue to make suggestions
as more detailed plans are developed, and that the same engagement will be possible for all parts of
the community. We continue to hope that the knowledge we can draw on from the wider FoE
organisation, and the partners they work with, is recognised as something that might be helpful, so
that those developing future plans do not hesitate to contact us for comments, insig hts and so on
when appropriate.
Please also see Appendix 1: Friends of the Earth Local Action Group Charter extract.
1 See for example Get your Council to adopt a Climate Action Plan
2 See Affordability, co-benefits and carbon saving: the top Climate Actions for councils
3 See “How climate friendly is your area?” – entering a Hillingdon Borough postcode gives information
for the Borough
4
Hillingdon Friends of the Earth general comments
on consultation document
We stated the points below in our response to the first Strategic Climate Action Plan in 2021, and
need to reiterate them now:
Some of the commitments in the draft Climate Plan are to deliver a net zero or carbon neutral
outcome. Whilst it is reasonable to have this as a goal to achieve, it should no t be the final goal. The
ambition should be to work towards as near zero carbon emissions as possible rather than only net
zero. Net zero could still hide significant carbon emissions because it relies on being able to deliver
good results on carbon offsetting. A continued reduction of emissions towards zero must always be
the aim, given the problems we have indicated in our comments, on Theme C7 in particular, of too
much reliance on offsetting.
● Addressing the nature emergency, as well as the climate emergency, is essential.
● Actions should also help to deliver sustainable development.
● The ambition should be to work towards greenhouse gas emissions as near zero as possible,
with targets for the whole Borough, not just the Council.
● Action is needed because of the impact of climate change everywhere in the world, not just
because of the impact in Hillingdon.
● Full and effective engagement with all parts of the community, including vulnerable people ,
particularly people with Protected Characteristics as defined by the Equality Act 2010, must
underpin how actions are developed.
● The lead Council officer must have access to the resources needed to ensure all Council
decisions take account of the climate and nature emergencies.
Brunel University of London is one of the three largest employers in the borough. The Council should
show a bottom-up level of support for effecting a shift in Brunel’s market positioning to be an eco-
university. The changes to immigration law which mean postgraduate students cannot bring family to
the UK has led to a loss of income for Brunel. This leads to job losses. This leads to less money in the
local community. This leads to increased political pressure for lower Council Tax. This means
Hillingdon Council has less money to spend on climate action. Brunel could focus on making its local
offer to Hillingdon residents more appealing. For example, by buying two pages of advertising space
in Hillingdon People. This has Borough-wide reach and could encourage Hillingdon residents to
consider Brunel as a way of getting local solutions to the climate crisis.
The document should be improved by having numbered paragraphs. This will allow references to the
document for questions in Hillingdon Full Council meetings and enable discussion as people can
easily locate what is being discussed.
Accessibility to the Plan should be improved by editing it using the Plain Language Commission’s free
download section 15 tips, in particular Point 6.
The Planning Department should actively engage in a training and education programme about what
the Borough will be like with 2 degrees warming. The use of the physical space in Hillingdon will need
to change depending on how far past the Paris commitments the planet gets. This means that
planning decisions need to recognise that groups with different protected characteristics under the
Equality Act 2010 might be adversely affected, and disproportionately so. The removal of green
spaces in the Borough for property development could have an adverse impact on resident's mental
and physical health.
5
Comments by section of consultation document
Foreword
The foreword is appropriately strong, we agree with the bold statement that “Further action remains
essential. The impacts of climate change continue to become more apparent.”
We applaud the Council for:
● keeping the broad aims and objectives unchanged.
● maintaining the promise to be carbon neutral by 2030.
Preface
We are very pleased that the Council is:
● continuing to embed climate action across your services.
● still committed to leveraging all available grant funding to mitigate and adapt to climate
change.
● committed to keeping the plan under review.
Although it is stated that the Council is not markedly altering the approaches adopted in the 2021
Plan, we feel there are some areas where the strength of the language has been markedly toned
down, targets lowered, and actions dropped.
“In July 2024 the Council adopted its Strategic Climate Action Plan” needs correcting to 2021 and
there is a typo in last paragraph: “subject to”.
6
1. The Need for Continued Action
The wording needs to be amended to better reflect the urgency of tackling our current clima te
breakdown “concentrations of greenhouse gases in the atmosphere are rising [insert “significantly”]
and [insert “rapidly”] making the natural greenhouse effect more pronounced”.
“The changing climate has significant [insert “negative”] repercussions that are experienced by all our
communities.”
Change wording to emphasise that climate change is already uncontrolled:
“Uncontrolled climate change [replace “will lead” with “is already leading”] to higher global
temperatures...”
Change wording to emphasise that climate change is already killing people:
“Vulnerable populations, including those with pre-existing conditions, the elderly, and underprivileged
communities, are [replace “likely to be” with “already the”] worst affected. [Add “People are already
dying owing to climate change. Between 2030 and 2050, climate change is expected to cause
approximately 250,000 additional deaths per year. 4] ”
Under “Here are some of the key impacts identified by the UK Health Security Agency: ” the two
impacts below are listed at https://ukhsa.blog.gov.uk/2023/12/11/11-things-to-know-about-the-health-
effects-of-climate-change-report/ but have been omitted from the Plan. They should be included:
“Vector-borne diseases
“A warming climate could expand the range and survival of disease-carrying ticks and mosquitoes in
the UK. This raises the risk of diseases like Lyme disease, tick-borne encephalitis; and potentially
even dengue, chikungunya, and Zika if non-native mosquito species establish themselves. Modelling
suggests that London is currently suitable for the survival of these non-native species due to
temperature levels.
“Increased biting from mosquitoes coupled with warming temperatures could also lead to outbreaks of
diseases like West Nile virus in the future.
“Wildfires
“Climate projections indicate an increased risk of larger, more severe wildfires due to hotter and drier
summers. If global temperatures increase by 2°C, the Met Office projects a doubling of days with a
high risk of fires in the UK, with the wildfire season potentially extending into late summer and
autumn.”
Local examples of the impacts of climate change should be included:
1. The UK experienced five heatwave periods during the summer of 2022 with record -breaking
temperatures of over 40°C in England. This was not an anomaly, but part of a warming trend:
extreme heat events are projected to become more likely as the climate con tinues to change5.
Hillingdon residents were impacted by the heat and poor air quality owing to wildfires at
Philpots Farm Open Space and in neighbouring counties.
2. On 23 September 2024, there were floods in the Borough "The frequency of such weather
events is expected to increase with changing climates which is why we've been taking steps
to try and minimise risk to households in the borough including the adoption of a flood risk
management plan.6”
4 World Health Organisation Climate Change Fact Sheet
5 The London School of Economics: Turning up the heat: learning from the summer 2022 heatwaves
in England to inform UK policy on extreme heat.
6 Council rises to challenge following flash flood crisis
7
3. Water pollution is increasing in the Borough’s rivers because the combined sewerage and
rainfall systems can’t cope with increased rainfall owing to climate warming 7 (warmer air holds
more water vapour, which then falls as rain).
The source of the circular diagram on page 9 must be stated. The diagram must be clearer as it
raises a number of questions. Greenhouse gases, however generated, are the cause of climate
change. There is no mention here of fossil fuels which are the main source of their generation , that
must be mentioned. We have never seen “aerosol emissions” quoted as a driver: Our understanding
is that aerosols release greenhouse gases other than CO2 in relatively small quantities, in no way
comparable with CO2 or even methane. Again, surely land use change can release greenhouse
gases (so already covered) but otherwise has impacts such as poor soils, which are not a direct result
of climate change. However, that impact does not appear in the middle circle.
Under “Poor outdoor air quality” take the opportunity to state that the Council is against the use of
wood burners and bonfires because they unnecessarily cause climate heating owing to inefficiencies
in generating heat and disposing of waste, but also dramatically worsen outdoor air quality. Car
journeys should be carefully considered and alternative healthier options such as walking or cycling
used whenever possible. The council has a responsibility for providing safe and convenient options
for those who would like to walk and cycle more. Every litre of petrol consumed by a car causes 2.3
kg of carbon emissions. 6000 miles a year in a highly efficient petrol car (60 mpg) would require 450
litres of petrol, and would generate a ton of CO2 emissions. Older, less fuel-efficient cars would be
considerably higher. The council has a role in encouraging take up of electric vehicles for those who
still wish to drive.
7 Preparing for the future – Ofwat’s climate change policy statement
8
2. Our Vision
We congratulate the Council on keeping its vision “To become the greenest London borough”, but
there are no measures comparing how the Council is performing compared to other boroughs. The
Council must reconcile its performance using Climate Emergency UK's Council Climate Action Score
Cards in a comparison with other London Boroughs. We would like a League Table to be published
along with the Plan Update each year, which sets out the Borough's ranking.
We also believe that Hillingdon Council needs to be crystal-clear in what it means by “the greenest
London borough” To quote from the Council website, Friday 21 July, 2023: “Hillingdon Council has
retained its status as one of the greenest boroughs in the country after receiving 67 Green Flag
Awards - the most held by any local authority.” This is praiseworthy, but it interprets “greenest” as
“having the most green flags”, or at a stretch, “the most green space” (although even there, the two
are not the same). This is not the same as being the most eco-friendly, or the most energy-efficient
borough, or the borough with the best route to net zero.
Correct the typo where theme C9 has been renamed “Transparency” when it was originally
“Transparency, Communication and Reporting”.
Under “Our Carbon Neutral Target”, for items iii and iv, the abbreviation “i.e.” (“that is”) should be
replaced by “e.g.” (“for example”), because in both cases you are giving examples .
9
3. Our Progress
We congratulate the Council on reducing its carbon footprint by 54% since 2020.
We feel the financial climate was only one reason the Council has not been able to deliver on all its
aspirations. There have also been missed low-cost good value opportunities to work with the
community and lead residents towards progress, so the wording should be changed:
“The challenging financial climate [replace “means” with “is one of the reasons”] we have not been
able to deliver on all our aspirations and we have focussed on delivering tangible outcomes that we
have direct control over. [insert “We have also missed low-cost good value opportunities to work with
the community and lead residents towards progress].”
To accurately and transparently measure progress, all the Actions from 2021 should be listed and the
progress stated for each. This should be peer-reviewed or independently verified.
Theme C1: Community Leadership
Considering in 2021 it was stated that “Community leadership is the overarching commitment in this
plan” there has been a stark lack of progress. This is particularly disappointing when a lot could have
been achieved with little financial outlay or effort, and the use of the community could have led to low-
cost dramatic progress towards meeting objectives in the Plan.
"The focus has been on getting the Council’s ‘own house in order’ which means further development
of the work on community leadership is required" has no reference to the decarbonisation of private
sector homes. The decarbonisation of private sector homes has so far largely been ignored; this must
be rectified.
Please amend “Work has been undertaken with the Friends of the Earth...” to “In 2024 the Council
started meeting with Hillingdon Friends of the Earth...”.
"Work is necessary to determine whether the current cost of offsetting 1tCO2 (i.e. £95) from new
development is sufficient" needs to be more specific, and more contextual information is required,
including the source of the £95.
The commentary states “further development of the work on community leadership is required” but
progress has been classed as Moderate - Progress has been made against a small number of the
actions. But of the objectives set in 2021 (listed below), only C1.4 has been progressed resulting in a
tangible output. So, Community Leadership should be classed as Further development required, to
match the commentary and lack of progress. Or progress that we are not aware of should be stated.
Theme C2: The Council’s Own Operations
We congratulate the Council on good work on these objectives. Residents are aware of the
substantial progress against C2.5 for buildings like sports centres and the Civic Centre, an d C2.7 for
street lighting. However, simply stating “The progress against this objective is very positive” with no
justification or detail relating to the objectives set below contradicts the theme of “ Transparency,
Communication and Reporting”. There is no detail presented to demonstrate that 2030 targets are
likely to be met. Please state what progress has been made against each objective and explain why
future dates are realistic.
Theme C3: Building Better Places
Again, we congratulate the Council for positive progress. It is good that the Council implements the
policies of the London Plan and is securing Section 106 funds. However, these funds need explaining
10
to lay people. Housing progress only mentions new development. It must be stated what has been
done to improve the Council's social housing stock.
Please state what progress has been made against each objective.
Theme C4: Using Clean and Green Energy
We agree progress has been positive and are extremely pleased that work on renewable e nergy
generation at your sites is ongoing.
However, it’s disturbing that the cost of electricity from certified renewable energy sources has
become cost prohibitive when it is the cheapest energy to produce. We still expect the Council to
secure energy supplies from low or clean forms of generation by 2030 as prices will drop compared to
more polluting generation.
Where is the Commitment to supporting local residents to set up Community Energy programmes
themselves?
Theme C5: Waste Management
It’s good that progress has been made but evidence should be provided about how each of the
objectives have been progressed, as we have not been made aware of any progress. Any progress
on reducing waste appears to be absent despite being the main theme of the comme ntary.
“Development is required to capture the waste management progress in the context of climate
change" requires explanation.
Food waste needs a Quarterly campaign in schools in the Borough. League tables should be
available for each street for food waste recycling by ward – this might increase take up (a low effort
tally of number of bins collected?)
There is no mention of green waste collections being left outside to decompose in Harefield – surely a
source of significant methane emissions. What is being done to measure, minimise or eliminate
these?
Theme C6: Climate Change Adaptation and Mitigation
It is disappointing that the climate change adaptation and mitigation action plan is still being pushed
down the road with no progress made.
“Progress against this objective is positive largely due to the work on air quality [insert “by the Mayor
of London”]”
Progress on the objectives below must be listed:
C6.4 To run a campaign to get residents involved and sharing ideas with the council to find
solutions for climate mitigation and adaptation in the community.
C6.5 To investigate opportunities to integrate environmental improvements into existing
buildings for example, living walls, green roofs, habitat walls, bird, and bat boxes.
C6.6 To run an annual campaign to raise awareness of the impacts of reducing green s paces,
paving over gardens and increasing hardstanding.
11
Theme C7: Carbon Offsetting
The level of tree planting and ongoing green space management is adequate. We agree that more
work is required to align this work with the objectives of the plan with particular focus on the
biodiversity work, which needs to be progressed further. Progress or lack of needs to be stated for
each of the objectives.
It needs to be stated whether the tree planting figures include HS2 net tree planting.
Theme C8: Sustainable Transportation
"Work against this theme needs to be captured in the context of this Plan so as to ensure there is
alignment against the climate change objectives" needs to be explained.
The original commentary was “The survey clearly told us that we need to do more to promote walking,
cycling, public transport and electric vehicle infrastructure. Residents were keenly aware of the need
for safe cycle routes and facilities to encourage a reduction in vehicle usage, which in turn would
improve air quality by reducing other harmful emissions.” yet very little has happened other than the
work with TfL.
The school campaigns mentioned should be listed and the outcomes measured.
The Cycle Strategy has been written but is very weak and lacks any substantial or impactful plans.
We agree that further work on a sustainable transportation strategy needs to be programmed to
ensure all the sub objectives of this theme are given attention. And that importantly the work against
this theme needs to be captured in the context of this Plan to ensure there is alignment against the
climate change objectives.
Again, progress for each of the original objectives needs to be evidenced.
The Council should request more digital displays at bus stops, possibly by suggesting TfL could also
use them for adverts. This would lessen the need for people to get their mobiles out at night to check
bus times. Important in a borough with lots of Heathrow Airport shift workers.
Theme C9: Transparency, Communication and Reporting
We agree this is an area where progress needs further development. Please state if there has been
any progress on any of these other than C9.4?
12
4. Our Own Operational Carbon Footprint
We congratulate the Council for:
● moving to LEDs for street lighting.
● replacing 1,000 illuminated bollards with non-illuminated types.
● securing £13,751,385 through Phase 3 of the Public Sector Decarbonisation Scheme (PSDS)
to fund heat decarbonisation and energy efficiency measures.
It is good to see the falls in electricity and gas use, and the graph that shows how carbon emissions
reduced as gas use swapped to electricity.
Detail should be added about what the Council intends to apply for in the next phases of the PSDS
and other funding.
How the baseline has been altered must explained in detail.
The following statement is made in this section:
“As renewable energy becomes more common place in the grid, the amount of carbon associated
with generating a unit of electricity is reduced. If the National Grid conveyed 100% of electricity from
renewable sources, our carbon footprint from our electricity supplies would be 0tCO2 ”. Please explain
what assumptions are being made in subsequent calculations about the energy efficiency of the grid,
and the changes to that efficiency, particularly in the graphs on street lighting and fleet operations.
It is good to hear of the reduced vehicle mileage owing to improved routing, but the Plan must be
changed from switching to more efficient vehicles with lower emissions to vehicles with zero tailpipe
emissions. Lease prices of battery electric vehicles plus the cost of electricity are less than the annual
fossil fuel bills alone. In processions, it’s very embarrassing to be following the Mayor of Hillingdon’s
car with its autobesity and combustion engine when it could so easily be replaced with a fully electric
vehicle. We do accept that the Council has not pursued low-emission vehicles at all costs as electric
heavy goods vehicles (HGVs) are relatively new, scarce and consequently exceptionally expensive,
however “large” needs changing to “HGV” in the document because only HGVs are dramatically more
expensive.
Brunel University has ongoing significant research investment into hydrogen fuel for larger vehicles.
There are within the environmental community serious doubts about the use of hydrogen, unless it is
genuinely GREEN HYDROGEN (i.e. water broken down into hydrogen and oxygen by electricity,
which in turn should be from renewable sources). However, we are left wondering whether any
partnership working with Brunel is happening, or being considered, to take advantage of the expertise
based at Brunel?
Small typo p16. “Commonplace” is one word. Typo page 20 “bollards” repeated.
13
5. Wider Climate Action Progress
The excellent tree planting statistics and number of Green Flag awards are very pleasing. Plans to
keep trees alive should be added (in particular saplings) along with flagging the risk that more
frequent wildfires may destroy the carbon sync, so this carbon offsetting should not be heavily relied
upon.
Leveraging in funding from external sources to identify and prioritise areas for flood risk management
is good.
The progress on levels of Waste Electrical and Electronic Equipment (WEEE ) recycling is impressive,
we applaud the new facilities at libraries and for Council staff. The same goes for increasing food
waste recycling. WEE is a typo in your Plan. In fact, there are many typos on your page of waste
examples.
“Energy from Waste facilities offer a modern treatment process that means your waste is used to
generate energy in the form of both heat and power (electricity). This waste is used instead of coal, oil
or gas to produce energy.” This is now the most carbon-intensive means of creating energy in the UK.
For waste the carbon emitted by incineration needs to be stated and compared to that of landfill.
“Waste sent to be incinerated just north of Bristol” – need to explain why waste is sent so far from
Hillingdon and state whether it is sent by train or lorry.
Liaising with businesses about the importance of food waste collections and waste segregation is
good but the Plan must state how businesses progress towards less waste and more recycling is
measured. Explain what will be done to encourage retailers to provide less packaging and no single
use plastics. Similarly good work with schools, but measures need to be stated.
On the page of waste examples, please change us to Hillingdon Friends of the Earth. On page 30,
13,000 is a heck of a lot of roadshows!
It is good that The London Plan sets out the planning policy for all new major development to be zero
carbon and that the Council is implementing the recent planning changes to secure biodiversity net
gain. The document states “We will continue to develop how to exploit the biodiversity net gain
opportunities within the borough to maximised benefits for our own natural environment ” which is an
objective, so this need to be more specific, timebound and measured.
We applaud that the Council will continue to oppose runway expansion at Heathrow due to the
extensive negative environmental and social impacts. The Plan must also specify how the Council will
act to ensure fewer flights to and from RAF Northolt/London VIP Airport.
Instead of
“We have links to the neighbouring counties as well as central London and with less public
transportation than other boroughs, the car remains a vital part of life.”
Change to
“We have links to neighbouring counties as well as central London and with less public transportation
than other boroughs, the car will remain a vital part of life for many residents unless high -quality
alternatives are provided.”
For “…less public transportation than other boroughs…”, the measure and Hillingdon’s position in the
list must be specified (is Hillingdon bottom of the list?) Surely the main problem with public
transportation in the borough is that it is more available for east-west journeys than for north-south
journeys, particularly in the north and centre of the borough, in a borough which is about three times
as “high” as it is “wide”?
14
It’s noticeable that there is no reference to achieving better public transport. Even if the borough has
limited influence over Tube and rail routes, there must be ways of achieving better bus routing,
through TfL or not, and these must be specified. And for services to/from neighbouring boroughs,
explain how difficult it would be to improve those.
Instead of
“This means actions to enforce a dramatic modal shift away from the car is likely to have significant
negative social and economic impacts.“
Change to
“A dramatic modal shift away from the car should be facilitated (not enforced) because the Council
acknowledges that in other similar conurbations where car use has reduced, there have been
significant positive social and economic impacts.”
The defeatist and negative Cycling Strategy offers very little to feed into this Plan and misses many
great value opportunities. It could have reduced car dependency and provided significant positive
social and economic impacts. The School Travel and Road Safety (STaRS) Team training, Cycle
Skills Sessions and Dr Bike events are great but in order to support active and safe cycling they need
to be part of a much stronger Cycling Strategy that delivers many safe routes across the borough.
Page 34. “Efficient boilers”, there needs to be an explanation of why all boiler replacements in
housing stock appear still to be new more efficient gas boilers rather than any heat pumps at all.
15
6. Actions for 2025-28
The removal of all the “Commentary” sections not only takes away the context, but it makes the
revised plan less “user-friendly”, we cannot see any logical reason for its removal. It should be
possible to repeat each Commentary verbatim, or to explain where and why it’s changed, as part of
this “update” process.
Various comments have been made in what follows about specific actions being dro pped. However, it
has been implied that there are some actions that need to be taken – especially with business –
beyond 2028. It is not clear whether these will be new actions to be added later, or whether some of
them are among the items that have just been dropped. As it stands this is confusing, because it’s not
clear which items have been dropped because they will no longer be done, and which because they
will be done beyond 2028.
Theme C1: Community Leadership
The community engagement section appears to have become less detailed, with fewer specific
actions aimed at involving residents in the climate response.
All in all, the reduction in this Theme from 14 Actions to 6, whatever the rationalisation that has been
carried out, gives a clear impression that the Council is pulling back from the Leadership aspiration
that was such an integral feature of the original Plan. If this a fair conclusion, the reason why must be
explained, or that impression must be changed.
The 2021 Plan focused heavily on community engagement, with a goal to empower residents,
businesses, and organisations to take climate action. It included plans for a comprehensive
communication strategy to educate residents on sustainable living. In the 2024 Consultation,
community engagement remains a focus but with less emphasis on concrete actions to involve
residents. There's a reduction in the level of detail regarding public campaigns or workshops. There is
a stronger focus on "local leadership" from councils and businesses, rather than directly empowering
communities to act. Community Leadership must be dramatically strengthened in this Plan as it can
be coordinated with low cost and effort but yield high-value outcomes.
Why have the following objectives from 2021 been dropped with no explanations? Reasons must be
given.
C1.1 Align our service delivery to support and promote zero carbon community outcomes.
C1.4 Devise strategies to improve existing buildings, with access to government funding for
energy efficiency and decarbonisation of residential properties and businesses.
C1.6 We will prioritise actions for fuel poor and vulnerable households, needing assistance with
accessing grant funds to improve energy efficiency and reduce their energy costs.
C1.9 To provide a dedicated online resource that is aimed specifically at children. To
complement this with an annual schools climate action competition, to support learning
and development in schools, offer opportunities to see real world examples of action being
taken to tackle climate change and to identify ‘young climate champions.’
C1.11 To support, promote and raise awareness of the use of sustainable transportation and
ensure resources are available to allow communities to make transport changes that do
not rely on polluting private transportation
16
C1.13 By the end of 2021 to develop and implement an annual engagement strategy that covers
all interested stakeholders (e.g. residents, resident groups and associations, community
groups, environmental bodies (i.e Sustrans, Friends of the Earth and businesses) .
Theme C2: The Council’s Own Operations
Why have the following objectives from 2021 been dropped with no explanations? Reasons must be
provided.
C2.4 We will introduce a green staff travel plan that encourages and promotes less business
travel and commuting and the increased use of low or zero carbon travel methods.
C2.5 Undertake feasibility studies and act to install small scale low and zero carbon
technologies in our own building stock.
C2.6 The procurement of all our new equipment and services will be measured against the
objectives of this strategic plan.
has been replaced with
“R2.5 To ensure procurement practices align with the objectives of this Plan
Action Revised for short to medium-term recognising the Council motion that 2035 is the target date
for Scope 3 emissions (i.e. those embedded within the supply chain)” This is too far away in a climate
emergency.
Theme C3: Building Better Places
Presumably C3.1 to 3.6 should be R3.1 to 3.6, for consistency?
Objectives need to be set to improve the Council social housing stock. Please state what progress
has been made against each objective.
It’s disappointing that “C3.7 To identify and promote opportunities for the increased provision of
allotments” has been dropped as they reduce food miles.
The 2021 Plan had a commitment to retrofitting existing housing stock, incentivising the installation of
renewable energy technologies like solar panels, and supporting low-carbon heating systems. In the
2024 consultation, the action items are less aggressive in terms of implementation timelines and
financial commitment. There’s a shift toward encouraging "energy efficiency im provements" rather
than specific targets for retrofitting and renewable energy installations. The language surrounding net -
zero energy standards in new buildings has softened, with less emphasis on pushing developers to
adopt high energy-efficiency standards immediately. Specific and aggressive but achievable targets
must be added.
The Council's own housing stock has been omitted in assessing the Council's carbon footprint since
2022. The Council's target for decarbonising its stock must appear in this pla n, even though the
Private landlords are now obliged to meet this minimum standard by 2030. Page 34 identifies some
progress but must identify a target for reaching EPC ABC for all homes.
The list of Council assets must not omit Council Housing Stock.
17
Upgrades of Council housing stock are seemingly very reliant on efficient (gas) boilers. It must be
explained what, if any, consideration is being given to heat pumps.
"It is becoming clear that there is a good investment case for the combination of heat pump, solar and
battery (either in the car or the house) when combined with a smart meter and time of use tariff. For
many, their energy bills with this kit will be half their current gas-based bills, enough to repay the
capital investment in a reasonable time period." (5 March 2024 Housing Today - Chris March, chief
executive and founder of Climatise). The council must specify how it will help people obtain these
technologies. Particularly as the Council says “We want to use our leadership role to assist residents
in making sustainable choices on their own properties”.
Theme C4: Using Clean and Green Energy
It’s a shame that
C4.1 To ensure and certify that the council secures energy supplies from low or clean forms of
generation by 2030.
has become
“R4.1 To ensure and certify that the Council secures energy supplies from low or clean forms of
generation by 2030 [add] where feasible.”
Even as an environmental group, we still do not fully understand why local authorities must pay more
for clean energy when it is cheaper to produce. Please provide a full explanation so that our group
and residents can understand.
An objective must be added to install solar photovoltaic canopies over Borough car parks. Consider
council property for a decent sized brownfield solar park (Gutteridge Works?)
Theme C5: Waste Management
This section has been oversimplified, with fewer bold actions or specific reduction targets included.
In the 2021 Plan a strong commitment to reducing waste, promoting recycling, and moving towards a
circular economy was in place. Emphasis on reducing single-use plastics and encouraging
businesses and residents to adopt zero-waste practices. Whereas in the 2024 Consultation waste
reduction is still a priority, but the 2024 consultation lacks some of the concrete actions such as
specific recycling targets or waste diversion goals. It focuses more on general strategies for waste
management rather than specific waste reduction initiatives (e.g. plastics generally should be added,
including reducing single-use plastics).
Why have the following objectives from 2021 been dropped with no explanations? Reasons must be
provided.
C5.3 Provide an online resource for educational facilities to develop and implement waste
reduction strategies. Monitor, record, and report on progress.
C5.6 Develop a community campaign to manage waste more sustainability and explore the
potential to lead or support reuse and repair workshops for residents.
C5.7 Promote the importance and value of growing food, either individually or through
community groups.
These objectives should be included “Avoiding the production of waste in the first instance is the ideal
position to be in. We want residents to become more conscious about the role waste production plays
18
in decision-making. We also want residents to understand how waste generation can be red uced, we
want to work with businesses and major generators of waste in the borough to identify creative and
innovative ways to reduce waste and raise awareness. Resources and awareness campaigns will be
run to support these objectives.”
Theme C6: Climate Change Adaptation and Mitigation
It is a shame that
C6.2 To put in place a water efficiency strategy for all Council operations (such as green space
watering, depot operations and corporate buildings) then monitor, record and report year
on year savings.
has become
“R6.2 To review the Council’s water consumption for its own operations (such as green space
watering, depot operations and corporate buildings) and put in place measures to reduce
consumption” to be more feasible.
Why have the following objectives from 2021 been dropped with no explanations? Reasons must be
provided.
C6.4 To run a campaign to get residents involved and sharing ideas with the council to find
solutions for climate mitigation and adaptation in the community.
C6.5 To investigate opportunities to integrate environmental improvements into existing
buildings for example, living walls, green roofs, habitat walls, bird, and bat boxes.
C6.6 To run an annual campaign to raise awareness of the impacts of reducing green spaces,
paving over gardens and increasing hardstanding.
Theme C7: Carbon Offsetting
It should perhaps first be said that “offsetting” as a principle has had an increasingly bad press, and
that it appears that most carbon offsetting schemes don’t achieve their objectives. However, the entire
idea of “offsetting” something is entity A paying entity B for taking carbon reduction measures that
would not otherwise be taken. But by now, the scale of the problem is such t hat all those measures
that might not otherwise have been taken NEED TO BE TAKEN anyway. So, we don’t need just to
plant trees in Hillingdon to offset carbon reductions that are otherwise too difficult, we need to plant
trees in Hillingdon regardless.
Here's what Friends of the Earth said about offsetting, as long ago as 2020:
“The reality is that we – government, businesses and individuals – need to cut our emissions by as
much as we can, as fast as we can. We also need to invest in projects that will re move carbon
emissions from the atmosphere. It’s not either/ or, it’s both. The same is true of nature. We need to
protect what nature we have left, and we need to restore habitats, not one or the other.”
While nature and biodiversity remain important, the 2024 version lacks the same ambitious vision for
expanding green spaces or increasing tree planting at the scale of the original plan.
The original Plan had strong commitments to protect and enhance green spaces, improve local
biodiversity, and increase tree planting. The goal of making Hillingdon a "green borough" with a focus
on natural carbon capture (e.g., tree planting). While in the 2024 Consultation biodiversity and green
19
space preservation remain key priorities, but the focus has shifted slightly to managing the impact of
climate change on existing green spaces, rather than aggressive expansion or rewilding efforts.
The 2024 consultation doesn’t mention the specific target for increasing tree planting or biodiversity
restoration as clearly as the 2021 version.
Why has the following objective from 2021 been dropped with no explanation? The reason must be
provided.
C7.3 To promote carbon reduction practices and carbon offsetting opportunities for
businesses and communities, linked to measures to tackle climate change in Hillingdon.
Theme C8: Sustainable Transportation
We are pleased no actions have been dropped. However, the transportation section has been
somewhat watered down in terms of specific actions and timelines, particularly regarding ambitious
electric vehicle (EV) targets and cycling infrastructure.
In the 2021 Plan there was a strong focus on reducing transport emissions through enhanced public
transport options, cycling infrastructure, and EV adoption. Ambitious targets for expanding EV
charging networks, encouraging car-sharing, and reducing car dependency.
The 2024 Consultation has a continued focus on reducing transport emissions, but the actions are
less specific. For example, while there is still a mention of EV infrastructure, the 2024 version lacks a
clear target for the number of charging points. The number of chargers available in Hillingdon should
be benchmarked annually with other London Boroughs. Competition amongst charge point providers
should be encouraged with the aim of providing a diversity of options and lower costs to the
consumer. Neighbouring boroughs have multiple providers, and options such as lamp post charging
which is currently not an option in Hillingdon. The option for council approved cable gullies, which are
being trialled in other local authorities, should be available to Hillingdon residents.
There’s a noticeable reduction in the urgency of expanding cycling infrastructure. The language has
become more general, with less specificity about how to reduce car dependency or promote
alternatives.
Reducing overall car use should be an aim that is clearly stated, and met rics should be provided
through which progress can be measured.
ALL Councillors should attend full Council meetings by public transport twice a year.
A Transport Survey should be conducted amongst the population using a full page of Hillingdon
People. It should be made into a competition to encourage people to enter – e.g. a shopping voucher
for a shop in the Borough. It would assess residents perception of the safety of using public transport
and the reasons why they do not use public transport.
Theme C9: Transparency, Communication and Reporting
Why have the following objectives from 2021 been dropped with no explanations? Reasons must be
provided.
C9.3 In July 2024, undertake a review of this strategy which will be open to public consultation
and engagement.
20
C9.4 To develop and undertake a sustainability appraisal of each of the action plans to ensure
they are aligned to the objectives of this plan.
C9.5 Provide a climate action plan programme detailing target dates for the development of
supporting action plans.
“R9.3 To establish a People’s Assembly to consider review of the Actions necessary to meet the
Corporate Climate Commitments. Revised 2026 (Oct/Nov)” This is too far away, we’ll be at 3 degrees
of warming by then, so this must be brought forward.
The motion adopted by the Council in November 2021, i.e. four years ago, committed to “holding an
annual ‘people’s assembly’ with residents and relevant organisations to discuss and shape revisions
to the climate change action plan”. It is really unsatisfactory that this has not been done, it is not being
done now to “discuss and shape” revisions proposed NOW, and it is being kicked down the road until
Oct/Nov 2026, i.e. five years after the motion was passed. There may be genuine reasons for this, but
it really doesn’t look good, it looks like paying lip service to residents’ opinions. This failure should be
addressed head-on in the revised Plan. Regular meetings with HFoE are really welcome, but they
don’t fill this void!
There should be an annual Green Transition Festival involving the Council, local groups and business
to encourage change.
With reference to the omission of C9.4 and C9.5, in the original Climate Action Plan, Section 6 “The
Action Plans” identifies a plethora of downstream plans, explained as follows:
“The Strategic Plan is therefore a catalyst for a series of other more detailed plans that will include
actions and targets following the consultation on this document. An Action Plan tracker will collate all
the actions into one place and will be available online for a transparent understanding of the ongoing
actions.” This has completely disappeared from the revised Plan, which presumably explains the
omission of C9.4 and C9.5. It must be explained why? Is it not happening? If not, specify what’s
replaced it.
21
Hillingdon Friends of the Earth conclusion
Establishing a People’s Assembly must be brought forward to as soon as possible this year, as it is
essential, low cost and effort – and we are in a climate emergency. HFoE can look to other Boroughs
for best practice and research whether third party organisations can be brought in to facilitate them if
required.
We have concerns about the reduction in urgency and specificity in key areas such as building
retrofitting, transport infrastructure, and biodiversity restoration. The plan must have stronger
commitments, clearer action steps, and specific targets that hold both the local council and
developers accountable to the climate goals.
Much more must be done to support residents in the choice to be less reliant on cars, educate about
the benefits of reducing consumption and lead them into taking action that lessens global heating.
It needs to be clearer which actions have been dropped and commentary from the original plan needs
to be carried forward to this plan to keep the context and justify the importance of the effort . It should
be possible to repeat each Commentary verbatim, or to explain where and why it’s changed, as part
of this “update” process.
There are dropped or watered down objectives that need to be strengthened:
● Retrofitting of buildings and ambitious renewable energy adoption has been toned down.
● Strong language around achieving net-zero standards in new developments has softened.
● Specific, measurable actions for expanding EV infrastructure, cycling, and waste reduction
have been reduced or generalised.
● The scope of biodiversity actions (e.g., tree planting, rewilding) has been narrowed.
● Weaker emphasis on Targets and Specificity:
● The urgency and specificity of some actions have been weakened, particularly in terms of
timelines and measurable targets for waste reduction, EV adoption, and nature protection.
HFoE, Climate Emergency UK and the Council must work together to put pressure on the Ministry of
Housing, Communities and Local Government to make taking climate action a statutory requirement
on local authorities, as this would open up many funding opportunities.
There must be a summary page in the consultation where de-prioritised actions are documented for
future consideration/prioritisation.
There should be an annual Green Transition Festival involving the Council, local groups and business
to encourage change.
22
Appendix 1
Friends of the Earth Local Action Group Charter extract:
We are:
Justice-centred: we understand the climate crisis disproportionately affects those least responsible
for it and is linked to other social justice and rights issues.
We understand many of us have benefitted from the mechanisms that have caused the cris is. To help
right these wrongs, we must continue to learn and question our existing belief systems.
Inclusive: to build a fairer greener future for everyone, we need to make sure everyone can be
involved. We work in a way that’s accessible, welcoming, and respectful of all. We reach out to people
from communities that are under-represented, and we actively speak out against any form of
discrimination.
Brave: we won’t solve the climate crisis by sticking to the status quo. We need to step out of our
comfort zone to stand up for what we believe to be right. We’ll be open to new ideas, challenging
ourselves to think and act innovatively. We won’t be afraid to fail and will learn from our mistakes.
Collaborative: we need to work together to tackle the climate crisis. In our local action groups, we
enable members to take on leadership roles, we share responsibilities, and we create opportunities
for people to get involved. We’re generous towards other movements and recognise the experience
and value of others. We’re open to building bridges, uniting communities and people, supporting each
other, and sharing our knowledge and skills.
Action-focused: we’re committed to securing action, and not settling for empty promises. Once a
commitment is made, we’ll be there to make sure it’s seen through. And in our own campaigning,
we’re committed to being active and creative to help maintain a vibrant and lively movement.
Fun: it’s a big crisis we’re facing, but that doesn’t mean we can’t have fun solving it. We’ll seek out
the things we enjoy doing throughout our campaigning and work together to make our community
action groups safe and exciting places for people. And we’ll build our resilience by looking after
ourselves and each other.
Text extracted automatically from the PDF, so layout, tables and images are not shown. Open the original PDF on LB Hillingdon’s website.