Carbon Copy: What new green plans guidance means for local leaders

Every NHS organisation must refresh their net zero plans over the next few months with a hard deadline set by NHS England for the end of July, system leaders announced this month.  

The refreshed plans will need to be more ambitious than the original ones from 2022 to meet NHSE’s targets of reducing emissions by 80 per cent by 2032 and reach net zero for its direct carbon footprint by 2040. 

There had been lingering questions over the impact of the first set of “green plans”, many of which expire over the coming months. 

The sustainability agenda was still finding its feet when they were created three years ago. The result was that some plans were much more detailed than others, and it was unclear to what extent leaders paid attention to them.  

But this month, leaders have been told to produce refreshed plans detailing what action will be taken in order to hit the many additional climate targets that have been introduced since the first plans were produced three years ago.  

These include: no longer using the carbon-intensive anaesthetic gas desflurane; only buying zero-emission vehicles from 2027; and complying with new net zero building regulations.  

The requirements for these refreshed plans are set out in the guidance published by NHSE.  

However, the document appears to be more of an attempt to bring together all the existing green asks in one place – rather than a vehicle through which to make any exciting big new asks. Although, as discussed below, a couple of new recommendations are sprinkled in.    

Bring the laggards up to speed  

Indeed, Carbon Copy understands the main priority for system leaders is to drive improvements to those plans lagging behind the pack, rather than adding new requirements to an already long list of asks.  

Just by way of a reminder, key actions organisations should already be focusing on include: replacing fossil fuel heating systems with lower carbon alternatives; reducing emissions from patient pathways; cutting nitrous oxide waste; and developing a sustainable travel plan by the end of next year.  

The new guidance does, however, include useful suggestions for how to achieve these. For example, trusts are told to hone in on at least one clinical area for reducing emissions in their plans, with mental health, emergency care, and diagnostics recommended as focus areas.  

There are also case studies signposted and suggestions of ways to monitor progress, which local sources said were useful pointers. This includes keeping an eye on average inhaler emissions per 1,000 patients, and on the amount of food waste produced. 

There are many different metrics bandied about for tracking sustainability progress (in lots of different areas, e.g. waste, medicines, etc). So, this part of the guidance should help trusts know what to bring out in the plans and make it easier to compare against others, if all use the same data.  

But there are also some interesting hints on the future direction of travel. For example, trusts have been told to focus on investing in renewable energy generation.  

And there should be no cutting corners – at least, not yet. It says organisations should not consider carbon offsetting but instead focus all efforts on reducing emissions. This is welcome, although it will inevitably make hitting targets harder.  

That is not to say offsets will not be needed in the future. Recent delays to new hospitals has made the net zero carbon footprint target even harder as old facilities will not be replaced until after the net zero target.  

A key omission 

The main disappointment, according to local sources, was NHSE maintaining its stance that organisations do not need to calculate and report their own carbon footprints.  

This has sparked fears from those who insist having this knowledge is key to progress. 

It is currently a mixed bag in terms of whether providers know their footprint or not, with previous HSJ research finding around a third of the largest trusts did not. 

But Carbon Copy understands national leaders would prefer organisations to use their limited resources on action known to reduce emissions, rather than to work out individual footprints, with NHSE instead estimating the overall system footprint annually. 

More emphasis on climate change adaption  

One notable shift in the guidance is a greater emphasis on adaptation to a changing climate. This is really important as extreme weather events — such as flooding, storms and heatwaves — become more frequent and intense. 

The health service needs to be prepared to cope with the aftermath of such events and not collapse because of them. IT systems at a major London trust were brought down by the 2022 summer heatwave. 

The asks in the initial 2021 green plan guidance were minimal, with organisations told to summarise actions they would take to mitigate the risks of climate change and extreme weather.  

However, the new guidance is clearer on the importance of this agenda, as well as the asks.  

It says: “Climate change threatens the ability of the NHS to deliver its essential services in both the near and longer term. Resilience and adaptation should be built into business continuity and longer-term planning to avoid climate-related service disruptions.”  

Much of these issues should already have been addressed, because organisations were told to have prepared for these sorts of scenarios in the NHS emergency preparedness standards, which saw adaptation introduced in 2022-23.  

One of the requirements in the emergency preparedness standards was for “worst case” scenarios for adverse weather to be shared within local resilience forums in which the NHS plays a part.  

However, this month’s guidance updates the asks of organisations to include new requirements, such as using a recently introduced interactive tool to identify local climate risks, inform actions to prepare for severe weather, and improve climate resilience of the service.   

Trusts are also encouraged to track overheating and flooding incidents in its plan for the first time, to check how well adaptation efforts are going.  

Trusts are now explicitly told to factor in the effects of climate change when building new facilities, such as by including passive cooling and drainage systems.  

It is hoped organisations would have already been thinking about this even before this most direct ask to date. 

But with so much focus on cutting costs in the immediate, it cannot hurt to drive home the importance of investing in the future.