Thanks for the opportunity to comment on the latest version of Liverpool’s MAA
documents.
Although we welcome Liverpool’s drive to incorporate a low carbon economy within
their MAA, their focus on climate change mitigation is a very narrow perspective on
the environmental agenda. From Defra’s perspective, Liverpool should also be
thinking about the wider resource efficiency agenda linked to low carbon i.e. action
on waste, water, etc and adaptation to climate change.
With regard to the Economy platform, the document could look to embed adaptation
to climate change into the growth plans. It isn’t particularly clear or specific about
what the climate change impacts could be for Liverpool as a city region and therefore
what risks (and potential opportunities) the city may be facing, when considering its
future development. There is no adaptation indicator amongst the KPIs, but a
significant amount of the planned activity could benefit significantly from taking future
climate impacts into account in planning how to take the work forward – not least
given that the MAA includes plans for major developments to infrastructure and the
built environment which are likely to last for a very long time.
Specific elements of the MAA which could potentially be impacted by climate change
include the plans for the Superport, housing growth and regeneration and the plans
in relation to transport infrastructure. All are likely to have long lifetimes and will
therefore ultimately need to be resilient to a climate which may be significantly
different from today’s. It is not clear that the MAA will be delivered in a way that will
ensure that this happens.
Specifically:
- On the Superport they need to be thinking about its location, design, and how
it is built with long-term climate change impacts in mind, to ensure that it is
climate resilient in the long term and remains operational (e.g. the height of
harbour walls need to be built with future sea level rise/ increased storms in
mind). This is potentially a really interesting project for us, as we think it could
potentially provide a useful test of how big infrastructure can be built in a way
that is resilient to long-term climate change.
- On housing growth, low carbon is embedded but thinking about how to make
new housing developments resilient to future climate change doesn’t appear
to be, for example, it would be good to see how thinking on green
infrastructure can be incorporated into these plans. If Liverpool starts to
experience problems with urban heat in the future, green infrastructure has
significant potential for future cooling alongside a range of other benefits, such
as helping with urban flood resilience. This can include measures such as
individual urban trees, greening of grey space, as well as the more
conventional thinking around large areas of green space. Where high density
urban developments are planned, planning in green space for cooling can
have real potential future benefits.
- Transport infrastructure also needs to be resilient to future climate change
impacts such as heat (which can, for example, melt roads, interfering with rail
travel, and result in very high summer temperatures on urban transport
systems), flooding, storms, etc.
There are also other opportunities – for example as Liverpool gears itself up to
develop new skills and industries around low-carbon it might also want to think about
whether there are opportunities to develop a skills base in relation to adapting to
climate change. The Superport in particular presents an excellent potential
opportunity on this front.
Ask 3 under the Economy platform refers to agreeing a strategy and initial action
plan to implement a low carbon economy; both the strategy and action plan should
take account of the wider resource efficiency actions on waste, water, materials, etc
that will be needed to decarbonise the whole economy to meet the ambitious long-
term climate change targets.
With regard to the Transport platform, colleagues that deal with air quality policy
have liaised with DfT colleagues and DfT will be sending you amendments to Ask
11.
It would be really helpful if Liverpool could give some further thought to our
comments above. When Julie Hitchcock attended the Liverpool MAA meeting on 18
May, she suggested that Liverpool should consider embedding thinking on climate
change adaptation in their growth plans, and they did appear to be receptive to that.
We could offer to help Liverpool embed thinking on adaptation into the MAA.
I should be grateful if you could let us know how this could be taken forward. I
understand that you were trying to set up a telekit between Liverpool and Defra (Julie
Hitchcock) so that we could convey our thinking to them – are you still able to set this
up?
Finally, thanks to policy colleagues within Defra for their comments and responding
so quickly in order for us to meet CLG’s deadline on this.
Carol
