Richmond and Twickenham Friends of the Earth – response to the LB Richmond draft Climate and Nature Strategy – May 2025
Richmond and Twickenham Friends of the Earth is a local group affiliated to Friends of the Earth England, Wales and Northern Ireland with approximately 300 local supporters. Thank you for the opportunity to comment on the draft Climate and Nature Strategy.
Name
We don’t think it is a good idea to remove the word “Emergency” from the name of the new strategy as the emergency has become even more serious since 2019. Therefore we would prefer the name “Climate and Nature Emergency Strategy”.
Introductory sections
We agree with the focus of the strategy as expressed on page 4 “We focus on reducing carbon emissions: our efforts are concentrated on areas where we can achieve the greatest reduction in carbon emissions, driven by the scientific evidence” and also the statement on page 12 “Initial priority areas for the Council are domestic buildings and transport as these are the two largest sources of greenhouse gas emissions in the borough and are sectors where the Council [has] direct and indirect control and influence to enable the delivery of interventions to meet net zero”.
We think that what subsequently follows wanders away from this focus sometimes, particularly in the sections on “Our Nature”, where the Council’s stewardship of green spaces does not contribute to carbon emissions and where there is limited scope for measurable carbon reductions, and in the section on “Our Resilience” which duplicates the Adaptation and Resilience Strategy. The section on “Our Resources” is useful and we accept that these ideas may not appear in another strategy but only 1% of emissions come from waste (page 9).
On the other hand the Strategy seems to have nothing much to say about the 30% of carbon emissions coming from industry and non-domestic buildings. We were not clear what the 16% of emissions from “industry” (page 9) comprises as LB Richmond does not appear to have much industry in the traditional sense and industry was not really mentioned in previous strategies. We would like to see this 16% explained in the final draft with an outline of the key industries and sites and some specific action points to address these emissions.
The Net Zero Roadmap set out on page 13 illustrates the scale of the challenge and we were pleased to see actual figures for the type of actions that will need to be taken. We would like to see the subsequent sections and other strategies refer back to these figures. We think the actions in the Roadmap need more explanation in the final version of the strategy. To give two examples:
- what is a “deep retrofit” and what is a “medium retrofit”?
- what does “Passivhaus newbuild 8700 domestic” by 2030 mean? We calculate that LB Richmond’s entire housing target for 2025-30 is only 2600 new homes.
Our Buildings
Net Zero Roadmap
As stated above we think this section needs to refer back to the Net Zero roadmap and its targets for buildings, including number of deep and medium retrofits, new builds, % of heating systems needing to be electrified. These could be set out in the “vision” sections for 2030 and 2043 on pages 24-25.
The figures in the Roadmap also need to be reproduced in the Retrofit Strategy.
Communications
We agree that the Council has a very important role in encouraging retrofit as set out on page 26 and that there is a pressing need for communications campaigns to reach homeowners and landlords.
Planning
In relation to planning (page 26) the strategy seems to be stating that this is fairly minimal as a barrier to retrofitting. We do not agree and think that, given the extent of the need for retrofitting of the Borough’s housing stock, there is a pressing need to prioritise removing the barriers rather than clinging to the usual Richmond focus on keeping things “looking nice”. We would like to see a Borough-wide presumption in favour of allowing all solar, external wall insulation and heat pumps and a major reduction in the current cost and time hurdles for residents looking to install renewables or retrofit.
Many people only think about replacing their gas boiler when it breaks down and they are left with no heating or hot water, so the process of replacing it with a heat pump has to be equally easy with no planning barriers or it is unlikely to happen. At the moment statistics that we have seen indicate that gas boilers are being replaced by the thousand every year but heat pump installations are in the very low hundreds.
Permitted development rights don’t apply to listed buildings or in conservation areas (there are 85 of the latter in the Borough). Thus, it appears that residents in listed buildings or conservation areas will still have to go through a time-consuming and expensive planning process. It also appears that some residents will need an acoustic report for heat pumps. These are very powerful disincentives to installing heat pumps or solar panels and completely at odds with the declaration of a climate emergency.
It’s disappointing that the recent Domestic Retrofit Task and Finish Group’s final report (https://cabnet.richmond.gov.uk/documents/s500014043/Final%20TG%20report%20Domestic%20Retrofit%20HG%20Final%20PPRB%20reportb.pdf) has limited its planning related recommendations to
“Ensure where possible that planning policies and processes support residents to retrofit their properties:
- Recommendation Eleven: Update planning application validation checklist to remove the need for an acoustic report where not needed
- Recommendation Twelve: Subject to resources commence work on a number of sustainability-focused SPD’s including Biodiversity SPD, Trees SPD, Sustainable Construction Checklist and planning obligations SPD with retrofit ambitions embedded”.
Community Energy
We welcome the mention of community energy (page 28) although there is very little information provided on this. We would like to see the Council working with local community energy organisations, such as CREW Energy, to set up a service that can advise community organisations and buildings on the best way of retrofitting to reduce carbon emissions and energy costs. The Council is the freeholder of some of these buildings and there is much work to do to improve them. Priority should be given to this work in distributing local funding such as the community infrastructure levy and the Council should consider setting up a carbon fund as have many other London local authorities.
Community Energy advice services, such as South West London Energy Advice Partnership (SWLEAP) run by CREW and Habitats & Heritage, also have a very valuable role to play in advising residents but the funding available to these services tends to be focused on those in fuel poverty and more funding is needed to create a service for “ordinary” homeowners and landlords.
Heat Networks
We also hope that the Council can work on the introduction of heat networks. These are needed in social housing but also in many older blocks of flats in the Borough where oil fired communal boilers are failing.
Funding
We welcome the possibility of ‘innovative funding’ and ways for residents to invest to fund retrofitting (page 29).
Skills
The skills action plan (page 30) is welcome. However, once trained the trainees will need a steady flow of retrofit work to employ them. We would urge the Council to explore ways of facilitating this, possibly in partnership with local housing associations.
Council capacity and advisory group
Finally, we agree that the Council will need more staff with relevant knowledge, skills and capacity to work on the very large task of meeting the 2043 targets in relation to buildings (page 31).
It should consider setting up an advisory group of those working in the sector to meet regularly with Council employees to discuss progress and challenges with meeting the actions needed to retrofit buildings in LB Richmond, as outlined in the relevant sections of the Strategy, action plan and Retrofit Strategy.
Our Travel and Air
Active travel
We welcome the aim of encouraging walking, cycling and active travel over private vehicles, and the target (page 33) for 75% of trips to be by sustainable modes by 2041. This will require continued shift of road space away from parking and vehicles in favour of pedestrianisation and protected cycle and e-scooting lanes. There will also need to be communication with residents explaining why car and van journeys need to be discouraged, including the co-benefits of better air quality, fitness and safety as well as the carbon emissions reductions that have to be made.
To achieve an increase in cycling there will also need to be more provision for cargo bikes of all types. Page 34 talks of e-cargo bikes but what about non-electric ones? There are currently far too few parking places for all cargo-bikes in destination areas such as town centres, and some cycling routes are barred by barriers that don’t allow cargo bikes to pass.
There also needs to be provision for charging of cargo bikes and privately owned e-scooters.
Electric vehicles (EVs)
EVs are preferable to older internal combustion engine vehicles and can reduce emissions of NOx. However, they are not a panacea, given the high levels of embedded carbon in their manufacture, and the higher levels of particulate matter produced by them (due to the greater weight). A switch to EVs also does nothing to ease congestion or demand for parking.
We therefore give a cautious welcome to the intention (page 35) to support and encourage options for easier home charging. However, we would encourage you to publicise the issue of particulate matter air pollution from EVs so that residents understand that they are a ‘least bad option’, not a solution.
Parking
We were pleased to read (page 35) talk of plans to “review our approach to car parking to incentivise EVs and multiple car households”. We trust the latter means actively disincentivising multiple car households through higher parking charges?
Speeding
The introduction of the 20mph speed limit which we campaigned for has been very successful in our view. However, we would welcome more action on speeding vehicles, such as more cameras. Reducing speeding will reduce carbon emissions as well as improving safety.
Our Nature
Does Nature belong in this strategy?
Carbon emissions locally are not caused by stewardship of local green spaces (net agriculture and land use is said to cause 0% of emissions on page 12). We welcome the approach outlined in this section but feel that as it is not mainly dealing with carbon emissions’ reduction, it would be more sensible to have a separate Nature Emergency Strategy published with and linked to the Biodiversity Action Plan setting out actions needed for biodiversity, connectivity, public involvement etc. The Climate Emergency Strategy could include a short summary with cross referencing to the Nature Emergency and Adaptation and Resilience Strategies.
Biodiversity
There is a nature crisis as well as a climate crisis and we agree that it is imperative that the Council does all within its powers to improve biodiversity within the Borough. We would like to see more reintroductions and restoration of habitats with the Council working with groups that have an expertise in rewilding to achieve this.
Chemicals
The aim (page 38) that “we will do more to avoid using chemicals” in our green spaces does not go far enough. This needs to stop as a matter of urgency, given the harm to wildlife and potential to harm human health.
Active tree and hedge planting
We welcome the promise (page 39) to “maintain our street trees and increase their number, to maximise their environmental benefits”. We would encourage the Council to also consider a programme of hedge planting, especially along main roads, to form a barrier between traffic and active travellers. There is good evidence that this can reduce pollution, and hedges can also provide habitat and corridors for wildlife.
Connectivity
We welcome (page 39) the facilitation of more connected networks and corridors of green infrastructure and an increase in street trees. We would like to see this extended with a change to the maintenance of parks and verges, with a “no mow” policy not just limited to May.
Lighting
There is a potential conflict between the need for lighting to ensure safe active travel, and the needs of nocturnal wildlife for dark corridors. We suggest that the Council explores wildlife friendly lighting. https://theilp.org.uk/publication/guidance-note-8-bats-and-artificial-lighting/
Canopy Cover
One possible metric that could be utilized which is found elsewhere is percentage of canopy cover across the Borough with a target to increase this. We are not sure if a baseline figure for this currently exists.
Allotments
Finally, we note that there is no mention of allotments, despite these being mostly Council owned. There is potential for increasing biodiversity here by requiring or encouraging more wildlife-friendly growing and management of communal areas.
Our Resources
We think the Council needs to continue intense efforts to improve rates of food waste recycling which are truly shocking (40% of residual waste is still food waste and we understand that the cost of disposal is nearly 10 times that of food waste going for anaerobic digestion and will rise further when incineration is taxed more). The Council needs to heavily promote the difference in cost and make it clear that failing to deal with food waste properly by composting at home or using the separate food waste collection is highly anti-social and imposing higher Council taxes on everyone. This is another area where brave action is needed. We would encourage a move towards fortnightly collection of residual waste, which is the norm in most local authority areas now, and charging for its collection by weight or volume (per person in household).
In relation to the circular economy there are already some great initiatives in the Borough, including the Library of Things and various repair cafes, and we welcome the extension of this with the establishment of a Circular Economy Hub (page 45). Additional libraries of things around the Borough would be welcome so that heavy items can be accessed more easily.
We also welcome plans to campaign against single use plastics (page 46).
The Council could also consider offering discounted Council tax for shops that use zero packaging to help reset the balance with the big chains and reflect their lower use of waste disposal services.
Our Resilience
As this section does not deal with carbon emissions reduction and there is a separate Adaptation and Resilience Strategy, we think that a summary page with cross referencing would be sufficient here.
We recognise that adaptation and resilience is potentially a big issue for our area, with high levels of flood risk in some parts of the Borough, the risk of vulnerable residents overheating in summer, and the potential for devastating wildfires in e.g. Richmond Park.
Flood resilience and water management
We welcome the vision (page 37) of less paving over front gardens and the promise (page 40) to encourage residents not to pave over gardens. However, we would encourage the Council to be bolder on sustainable urban drainage solutions. It would be good to consider introducing annual charges for cross-overs (which allow private use of pavements), with renewal of permission (post a well-publicised future date) being dependent on the parking space on the resident’s property being porous and not draining onto public roads. This should also be a pre-requisite for permitting any new cross-overs.
The Council could also consider porous pavements and road surfaces, for example (https://greenblue.com/gb/permeable-pavement-the-pros-and-cons-you-need-to-know/) . If practical these could be introduced when pavements are replaced or roads resurfaced. This could also benefit street trees if the resulting drainage was accessible to their roots.
In the light of the likelihood of wetter winters and dryer summers, there may need to be water storage solutions, for example, more lakes/ponds in parks.
Other resilience issues
There will be a need to use the planning system to require new homes to be resilient e.g. not on floodplains and to be designed to not need further retrofitting.
There will also be a need to plan to help vulnerable residents get to the proposed public refuges if necessary.
Accelerating actions
Carbon Neutral Council by 2030
Procurement – We welcome the use of procurement to drive a reduction in the Council’s scope 3 emissions. This can be a powerful driver for change, especially if other public bodies also prioritise social and environmental value when tendering contracts.
Pension Fund – One area of operations that is contracted out is the Council pension fund. We note that there is no mention of the choice of pension provider. Will this be included in future social value procurement, and will the Council take an active stance on promoting responsible investment?
Offsetting – There is (page 55) talk of offsetting but no details of how this will be done. We note that the quality and efficacy of offsetting schemes is often dubious.
Renewable Energy – We welcome the use of a dedicated renewable energy company (page 56).
Our communities – supporting climate action
Sustainability Forum – it would be good to see this developed further as engagement is fairly limited at the meetings with presentations taking up a lot of the time. For example, task groups of local residents could be set up to consider issues that are of concern to a lot of attendees at the Forum and which would help to progress actions in the Climate Action Plan.
Council use of social media – the Council often posts positive stories about climate change on its own social media, e.g. a recent story about money obtained from the Public Sector Decarbonisation Fund to retrofit five public buildings. Sadly, these often attract negative comments, (e.g. waste of public money, climate change is a hoax, Sadiq Khan is robbing us, all the money is going directly not the pockets of politicians, no point because of China!). The Council never seems to attempt to counter these comments and it is left to chance as to whether sympathetic local people, including our members, spot the posts and add rebuttals. We think the Council needs to be a lot more proactive about monitoring comments on its posts and countering misinformation.
Richmond and Twickenham Friends of the Earth
Email: richtwickfoe@gmail.com or info@rtfoe.org.uk