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New Green Plan guidance published

30th June 2021 – In June 2021 NHS England released new Green Plan guidance to all NHS Trusts and ICS’s (Integrated Care Systems).

The aim of the revised guidance is to ensure Green Plans are consistent and align with the goals and objectives set by NHS England in the ‘Delivering a net zero national health service’ document published in October 2020. This set out trajectories and actions for the NHS to reach net zero carbon by 2040 for the emissions it controls directly, and 2045 for those it can influence.

Green Plans replaced Sustainable Development Management Plans (SDMP) in 2020, NHS England expects the new suite of Green Plans to match the increased net zero ambition and renewed delivery focus. The guidance explains how NHS Trusts should construct their Green Plans.

Here, we discuss some of the new updates and what they might mean for your Trust:

Trusts are asked to submit a Green Plan to its ICS by 14th January 2022, each ICS is then asked to collate and submit an overarching ICS Green Plan to their regional Greener NHS team by 31st March 2022.
Previously no firm deadline had been put in place for a Green Plan and certainly, there wasn’t a mandate previously to collate a Trust’s Green Plan with the wider ICS. Trusts who currently don’t have a Green Plan in place will need to act quickly to develop one that meets the criteria set by NHS England before the end of the year.

If you already have a published Green Plan or SDMP you don’t need to draft a new plan until the current 3 year cycle is complete; however, you are encouraged to update your current one formally to align with the guidance in the ‘Delivering a Net Zero national health service’ document.
Updating your existing plan is not mandatory (unless it was created prior to 2019) however there is a clear desire for all Trusts to be working towards the same goals as soon as possible, the guidance states Trusts with an existing plan should “…focus on accelerated delivery of their existing plans”.

Development should be led by a board member net zero lead and approved by the Trust board or ICS.
Previously Green Plans should have been approved by the board but often the creation sat with another department within the Trust, such as the Estates team. This new requirement makes a clear statement that the 2040 net zero goal should be high on the agenda at the highest level of each Trust. Selecting the right person to lead this is key and Inenco encourages the chosen board member to participate in all meetings related to the development and implementation of Green Plans.

Trusts must meet the minimum foundations set out in the NHS standard contract 21/22 and ‘Delivering a net zero national health service’ document by the end of the current financial year, before publishing their Green Plan.
These requirements include appointing a board level net zero lead to oversee the development of a Green Plan, procuring 100% renewable energy from April 2021 and reducing desflurane in surgery use to less than 10% of its total volatile anaesthetic gas use, by volume, to name a few.

Green Plans should be developed with the involvement of various internal departments, not just the Estates team. Should also engage with external stakeholders.
Similarly, to the previous criteria, NHS England has acknowledged that for the net zero goals to be met, each department needs to be involved and actively participate in finding ways to reduce a Trusts carbon footprint. As discussed in a previous webinar Inenco have always encouraged a multi department approach to Green Plan development. Worryingly a recent survey suggested many Trusts are still heavily reliant on the Estates team alone to development sustainability strategy.

Green Plan structure should align with the chapters of the ‘Delivering a net zero national health service’ document.
Trusts were previously asked to cover certain topics within the Green Plan but now there is clearer guidance on how to structure the Green Plan and more specificity of what should be included. Within the guidance, Trusts are encouraged not to pursue carbon offsetting and instead focus on efforts to tangibly reduce carbon emissions.

Green Plans to be submitted to NHS England and NHSI for peer review ahead of publication.
Previously a Trusts Green Plan required approval from the board before publication however the wider ICS Green Plan must be submitted for peer review, suggesting checks will be made that all Green Plans align with the wider net zero goals before they reach the public domain.

Trusts to update their regional Greener NHS team on progress, at national level progress against net zero emission targets will be reported twice a year to public NHS boards.
Much more stringent governance will be in place moving forward, with Trusts likely to be held accountable over a lack of progress, as stated in the new guidance.
“The regional teams will hold ICSs to account on delivery of the latter’s Green Plans, and ICSs will be tasked with holding organisations within their system to account in a similar fashion”.

Carbon footprint calculations at regional and ICS levels should be available by the end of September 2021, followed by Trust level carbon footprints.
To increase the accuracy of the carbon footprint recorded Inenco would encourage Trusts who have data on their carbon footprint to submit this data to ‘The Greener National Programme’ as soon as possible.

In Summary

The development of a Green Plan is no longer an option to Trusts, the new deadlines put in place mean that some will have to act quickly to have a plan with tangible goals in place before the end of the year. With much stricter governance in place and board members being held accountable for the progress of the net zero goals, sustainability will need to be at the top of all Trusts agenda’s moving forward. Given the public nature of progress reports, there could also be some PR challenges for Trusts who are not making adequate progress in reducing their carbon emissions.

Co-ordination with other organisations within a Trust’s ICS could also present several challenges, Trusts will need to open dialogue as soon as possible in order to meet the deadline for submission of an ICS wide Green Plan by March 2022.

To speak to one of our NHS experts on how we can help you develop your Green Plan contact us on 01253 785294 or email us at