Brighton & Hove City Council





Appendix 1 – Strategic Risk 36 report





Economy, Environment & Culture





Print Date: 06-Dec-2022











Risk Details


Risk Code


Responsible Officer

Risk Category

Initial Rating

Revised Rating

Eff. of Control


Not taking all actions required to address climate and ecological change and transitioning our city to carbon neutral by 2030.

Executive Director - Economy,
Environment & Culture

Transport & Sustainability Committee






L4 x I5









L4 x I4




Revised: Uncertain


Link to Corporate Plan 2020-23 - Outcome 5 ‘A sustainable City’, action 5.1 ‘Become a carbon neutral city by 2030'.
The climate is warming and studies recommend that actions must be taken to keep global warming to under 1.5 degrees to avoid negative catastrophic impacts on biodiversity and the ecology of the planet.

Potential Consequence(s)

If this is not addressed local impacts are:
- Sea-level rise affects Brighton & Hove as a coastal city.
- Coastal protection assets challenged by sea level rising which affects the seafront, city roads, and homes.
- Increases in local flooding due to extreme weather events and prolonged periods of heavy rainfall, inefficiencies in our urban infrastructure and built environment
- Water shortage
- Crop failure and food insecurity
- Depletion or threat to local species and their natural habitats
- Ocean acidification
- Disproportionate impact upon groups suffering inequality
- Impact on public health due to increased temperatures

Existing Controls

First Line of Defence - Management Actions
1. The Net Zero Carbon Strategy launched in 2021.
2. Brighton & Hove is part of the UNESCO biosphere designated area with a biodiversity plan overseen by the Biosphere Delivery Board who meet three times p.a. As at January 2020 the Board is chaired by Martin Harris CEO of Brighton & Hove Buses, the deputy chair is Sean Ashworth of Inshore Fisheries Conservation Authority (IFCA).
3. BHCC, the Brighton & Hove Economic Partnership and the Chamber of Commerce have agreed an Economic Strategy which includes creating a sustainable city and moving towards a circular economy as a core objective.
4. BHCC owns 12,000 acres of downland and agricultural farmland surrounding the city and works in partnership with Southern Water and the South Downs National Park Authority on initiatives to protect the chalk acquifer and city water supply.
5. BHCC and the Transport Partnership work together to deliver sustainable transport policies through the delivery of the Local Transport Plan (LTP).
6. Flood and Coastal Erosion risk management - Brighton Marina to River Adur coastal protection scheme undertaken in partnership with the Environment Agency (EA), BHCC, Adur District Council, Shoreham Port Authority.
7.  Administering the Carbon Neutral Fund overseen through the Carbon Neutral 2030 Programme
8. Circular Economy (CE) Routemap agreed by P&R Committee in December 2020.  CE Programme established and overseen by programme manager.
9. Biosphere Management Plan agreed September 2020 and being implemented and being monitored by the Biosphere Delivery Board.

Second Line of Defence - Corporate Oversight
1. BHCC's Environment, Transport & Sustainability (ETS) Committee is responsible for the council’s functions in relation to coastal protection and flood defence; sustainability; parks; open spaces; sustainable transport; highways management and environmental health
2. Biosphere Delivery Board oversees delivery of biosphere management strategy
3. BHCC's Policy & Resources (PR) Committee approved the 2030 Carbon Neutral programme in Dec 19 and a Member working group to develop a high-level carbon neutral plan by June 2020
4.  The Council's Corporate Plan includes a section of priority actions around the theme of ' A Sustainable City' and the target to transition to carbon neutral by 2030. 
5. Air Quality Action Plan overseen by the Air Quality Programme Board.
6. Greater Brighton Economic Board’s Infrastructure Panel has oversight of Energy and water plans
7. Communications & Engagement officer agreed to support carbon neutral programme.
8. A Climate Assembly (Citizens Assembly) was held as part of a deliberative engagement process to identify and prioritise actions which will support the delivery of the 2030 Carbon Neutral Programme, starting with a focus upon Transport. 
9. The risk was reviewed at A&S Committee in January 2020, October 2020, September 2021.

Third Line of Defence - Independent Assurance
1. Environment Agency (EA) in respect of flooding and monthly reports made to EA on how the city council spends the monies received from EA includes schemes such as coastal protection; Property Level Protection; sustainable urban drainage SPG (policy); Strategic Flood Risk Assessment.
2. Internal Audit acts as first level controller to support three EU funded projects part of whose remit is to address some elements of this risk. These are Solar Adoption Rise In the 2 Seas (Solarise), Shaping Climate change Adaptive Places (SCAPE) and Sustainable Housing Initiatives in Excluded Neighbourhoods (SHINE). All claims during 2020/21 were certificated in accordance with EU processes.
3. Local Air Quality Management reports submitted regularly to the Department for Environment, Food and Rural Affairs (Defra)

Reason for uncertainty in effectiveness of controls - A significant element of the transition to carbon neutral requires national and/or international policy change and transformation at scale across the city in partnership with City partners, as well as significant behaviour change amongst communities.


Risk Action



Responsible Officer




Deliver Fleet Strategy



Assistant Director - City Environmental Management






 • Delivery of six new electric vehicles in Parking Enforcement has been affected by long delays caused by external global factors - grain and fuel deliveries by boat are being prioritised over vehicles.
• Ordered new electric vehicles for the Cityclean Senior Supervisors.
• First two electric cage tippers for Cityclean arriving soon.
• New electric vans for the Public Toilet Team are soon to be delivered, and are currently with the dealership.
• Ordered the new electric Side Loaders for Communal Bin Collections.
• Ordered the first electric Toploader for Cityclean.
• Replaced workshop Land Rover with an electric van.
• All the depot chargers installed and soon to be commissioned.

Last Updated: 06/12/2022


Deliver the 2030 Carbon Neutral City Programme



Executive Director - Economy, Environment & Culture





The 2030 Carbon Neutral Programme was agreed by P&R Committee in March 2021. Budget Council in February 2022, agreed to make £14m capital funding available in 2022-23 and 2023-24 to support climate action and biodiversity projects. This funding was allocated by P&R Committee in July 2022, including £8.2m to be agreed through the Carbon Neutral Fund prioritisation approach. In October 2022 P&R Committee agreed the allocation of this Fund to 29 projects addressing carbon reduction, biodiversity, adaptation, and circular economy.
Other recent actions include:

-          E-learning on climate change delivered to more than 750 Council staff and 1-day carbon literacy training delivered to over 60 senior officers

-          Greater Brighton Economic Board agreed to commission a Blue/Green Investment Plan in February 2022 - work now underway to revise the Infrastructure Board to drive this work.

-          LCWIP and Direction of travel for LTP5 approved by ETS Committee in March 2022 (see other risk actions)

-          The SOLARISE Interreg Programme final conference hosted by the Council in May 2022 – the programme funded solar PV pilots in council housing to increase access to renewable energy for tenants.

-          Introduced new planning policies in 21/22 on carbon emissions, circular economy, tree planting, active travel, biodiversity, sustainable drainage, renewable energy

-          Council officers presented at the Footprint event for construction professionals in June 2022.

-          Supported Brighton & Hove schools to launch Our City, Our World, the new sustainability, climate change and environmental education strategy

-          BHCC Circular Economy Route Map published in June 2022, outlining milestones for the Council through to 2035.

-          Reported on progress towards carbon neutrality to CDP (Carbon Disclosure Project) and received an A- score for 2022

-          Submitted 2030 Carbon Neutral Programme Annual report 2021-22 to P&R Committee in July 2022, showing a 9.5% reduction in the city’s carbon emissions between 2019 and 2020.

-          Scoping and market testing for commissioning a Climate Risk and Vulnerability Assessment, which will report in 2023 and will shape a lot of how we manage this risk going forward.

-          Presenting all climate-related information and media in one place on the council’s website

Last Updated: 01/12/2022


Deliver the priorities within the Local Cycling and Walking Infrastructure Plan (LCWIP)



Assistant Director City Transport





The LCWIP sets out strategic ambitions for the city's active travel network covering a ten-year period and beyond. Officers are continuing to work on securing suitable funding for delivery of the LCWIP routes and areas for improvement, as well as progressing a range of live projects. Current funded improvement projects include the A259, Marine Parade, A23, Western Road, Hanover & Tarner Liveable Neighbourhood, and the Mini Holland feasibility study. Work is ongoing to embed the LCWIP into wider projects, including highway maintenance. The approved LCWIP document is available on the BHCC website at A refreshed approach to the LCWIP Member Working Group is being put in place.

Last Updated: 30/11/2022


Develop a new sustainable transport strategy (LTP5) for the city



Assistant Director City Transport





The ETS Committee approved the LTP5 ‘direction of travel’ document in March 2022, available on the BHCC website at  This will inform development of the full LTP5 document, which will be subject to further consultation. The Council is currently awaiting the publication of new government guidance for the preparation of LTPs, setting out key requirements of the document.  This has been delayed, and initial guidance for consultation with local authorities is now expected by the end of 2022, with the final guidance being published in early 2023, and new LTPs expected by the end of Spring 2024. In the meantime, work continues on progressing interventions included in the initial consultation document including a Liveable City Centre, Low Traffic Neighbourhoods, and Mobility Hubs.

Last Updated: 30/11/2022


Develop a whole Downland Estate plan



Assistant Director - Property & Design






Public and stakeholder engagement on the development and vision of the City Downland Estate Plan (CDEP), facilitated by Planning for Real, took place in 2020/21 and a vision was agreed by Members and the Asset Management Board (AMB) in July 2021. Further engagement took place with internal stakeholders, political Leaders and Groups, AMB, external stakeholders, South Downs National Park (SDNP) and the Downland Advisory Group (DAP) on the draft CDEP, and a second round of public consultation was held in in May/June 2022. Feedback from this consultation informed the final CDEP which has been agreed by P&R Committee in December 2022. The aim is for the Plan to be endorsed by SDNP in early 2023. The Plan contains approx. 54 actions that will be prioritised into short, medium and long term and will then be captured in an Implementation Plan.

Last Updated: 30/11/2022


Improve rates of recycling and develop business cases to increase the range of materials collected for recycling and composting



Assistant Director - City Environmental Management






• The 2021/22 outturn has been published by Defra. BHCC’s recycling rate was 30.1% - this is an increase from 29.2% in 2020/21.
• The 2021/22 landfill rate was 0.75%. This continues the trend of reducing the volume of waste which is sent to landfill: 2020/21 = 1.2%; 2021/22 = 0.8%
• Continued to recruit Circular Economy Champions through the volunteer scheme to promote sustainable actions and educate residents on different waste streams through collection of pledges. In person engagement events held at locations such as Open Market, Seafront and Preston Park.
• Held three community pop events with a focus on textiles, food waste and electrical waste.
• Developing a digital app to encourage users to waste less, reuse, repair and recycle more
• Joint work with communications team to highlight and educate around specific issues resulting in contamination of waste streams
• Keep Britain Tidy Student Waste research project – delivery of research and recommendations for BHCC.
• Developing a trial to standardise the communal bin system in Brunswick & Adelaide and Regency wards, placing refuse, recycling and glass containers at each site
• Supporting the introduction of new community composting schemes at Lynchet Close, Princes Terrace, Adelaide Crescent, Wish Park, Hollingdean Community Centre, as well as additional bins at existing sites.
• Awaiting outcomes of government consultations on the Environment Act.
• Received draft feasibility study of the material recovery facility to inform options for accepting new materials.
• Identifying transfer station for food waste.
• CMDB business case on project support to move forward on implementing the Environment Act.

Last Updated: 06/12/2022


Roll out a network of electric vehicle charging points (EVCP) - Directorate Plan ref. 4.38



Assistant Director City Transport






There is a rolling programme of Traffic Regulation Orders for exclusive charging bays being advertised every 3 months with 39 having been advertised and lined and signed in this quarter.
There is a steady increase in monthly usage for all charger types as more charge points are installed and become operational.

Meetings have been held with the Director of the Racecourse and the Office for Zero Emission Vehicles who have part funded the project to build a taxi hub at the Racecourse with a solar powered canopy. It has been agreed that the original project cannot proceed as planned due to the ongoing use of the Racecourse as a vaccination centre. Instead, the funding will be used to fund three rapid chargers to be installed in streets close to the Racecourse. Two sites have been identified at the top of Elm Grove and bottom of Pankhurst Avenue. Work is underway to identify a third site before March 2023.

A successful bid for 60% funding for an additional 50 lamp post chargers has been made to the On Street Residential Charge Point Scheme. These are being installed before the end of the year. A report to November’s Procurement Advisory Board about the second phase of procurement for charge points has been agreed. This will be considered at January’s ETS Committee.

Last Updated: 06/12/2022