Below is the full text of Lil’s response to the consultation on the Climate change strategy for East Lothian.

The consultation closes at 5pm today (22nd July 2019) and if you haven’t responded yet please do pop a quick email to climatechange@eastlothian.gov.uk . The key point in all areas is that ELC need to go further. They need to provide the leadership our county needs and drive change across all sectors faster and further for us all to avoid the consequences of the climate emergency.

Thank you for seeking feedback on the draft strategy. We appreciated the opportunity to input and we also appreciate the work that has gone in to develop the strategy so far. It is a monumental task to consider all aspects of climate change! However, we do not believe that the current targets and actions are ambitious enough to achieve the rapid and sizeable change that the climate emergency requires.

We welcome your approach to an integrated view of the roles different sectors and levels of our society must play in addressing climate change. We absolutely agree that ‘success will depend on accepting responsibility and working in partnership’ but also strong leadership is required. ELC are in a unique position to provide this leadership. This will mean implementing some policies which are unpopular with some sectors.

Vision

You cite 4-35cm sea level rise around our coasts but some predictions suggest it may be much greater.  The Royal Society predicts that the effects of rising sea level will be felt most acutely in the increased frequency and intensity of occasional storm surges. If CO2 and other greenhouse gases continue to increase on their current trajectories, it is projected that sea level may rise by a further 0.5 to 1 m (1.5 to 3 feet) by 2100[1]

Climate Central predicts it may be as much as 5ft by 2080 (possibly 2050 and that’s with  moderate carbon cuts - the median projection for when sea level rise leads to a 20% accrued risk of flooding above 5 ft at Dunbar is 2050-80[2]). With pollution levels unchecked this drops to a median of 2060. So even if we act extensively and quickly you are still looking at parts of East Lothian (Musselburgh in particular) being flooded on a regular basis within this century.

·         There is a lack of urgency and ambition in the current Vision. It needs to motivate and inspire everyone to support the delivery of the strategy.

·         Not ‘more prosperous’. Driving continued economic growth and associated consumption is part of the problem. There needs to be balance between the economy and environmental and social outcomes. We need a vibrant, fair & sustainable East Lothian.

·         We should be pushing to the forefront in innovation to drive our low carbon economy. This is a real opportunity to shift away from damaging activities to positive carbon & community objectives.

·         ‘Contributing to effort’ demonstrates a lack of ambition. Let’s actually drive and lead the change. What is a vision if not ambitious?

 

Outcomes & Actions

The outcomes included in the strategy are commendable and the actions will go some way towards achieving them. However, so much more can be achieved and must be to make any significant difference. Our thoughts on the outcomes and actions are noted below.

Outcome 1: A Low Carbon and Sustainable Council.

East Lothian Council will reduce its overall carbon emissions from the Council’s own estate and operations by 2.5% per year relative to population size, over the 5 year period of the Climate Change Strategy.

The Scottish Government is likely to legislate for net-zero emissions by 2045, with a 70% emissions reduction by 2030 and 90% by 2040. We do not believe that the current target of 2.5% reduction relative to population size per year over 5 years is ambitious enough to achieve these targets.  It may also be clearer to the public to set clear targets of tonnes of CO2e per head of population.

There are many co-benefits of taking action to adapt to the impacts of climate change whilst reducing emissions to net zero. These include improvements to physical and mental health through increased green infrastructure, resilient homes with excellent indoor environmental quality, less noise thanks to quieter vehicles; more cycling and walking; and healthier diets.

This should be clearly embedded within the East Lothian Council strategy and policies across all areas. This could include everything from local procurement contracts to a duty in all employment contracts for staff & office bearers.

We are faced with an emergency – climate change is more frequently referred to as climate chaos, climate emergency or climate breakdown – these titles stress the urgency and scale of the action required but the target set for incremental change will be too little, too late.

Declare a climate emergency and create an emergency response plan for the Council whilst instructing and supporting local communities, possible via the Area Partnerships or at Community Council scale to produce their own plans.

Politically, to declare a 'Climate Emergency' is an acknowledgement of this crisis. It would mean immediately prioritising action across local government to end support for fossil fuels, invest in the clean economy and restore nature at home and abroad.

We are already witnessing the devastating impacts of climate change, from life-threatening wildfires and Arctic ice melt, to intense hurricanes and floods. If emissions continue to rise at current rates, we’ve only around a decade before 1.5°C of warming is inevitable and we face climate breakdown.

Parts of our county are likely to be permanently submerged before the end of the century, quite possibly sooner under worst case scenarios and certainly the victim of significant and repeated flooding. We do not have time to waste.

Outcome 2: A Resource Efficient and Sustainable East Lothian.

Sustainable East Lothian will be a place of social equity underpinned by sustainability; working towards a zero waste East Lothian, and a low carbon and energy efficient county; ensuring the next generation has the resources they need to thrive.

Awareness raising, information provision and behaviour change are what we do and there is much that is needed to support and persuade communities to alter their lifestyles but it needs to be taken to them and start where they are on their journey. For instance, we have seen significant uptake of plastic free and low waste initiatives across the county but much more can be done to promote these and support more disadvantage communities to take up the opportunity.

Building and consumer energy efficiency can bring massive benefits to total energy demand and the consumers’ pocket. Greater promotion is welcomed.

ELC should back onshore wind and solar - these are the cheapest forms of electricity generation (not just the cheapest renewables).

There are also opportunities to promote more domestic renewable energy opportunities in new and existing developments. Strengthen new-build standards to ensure they are designed for a changing climate, are future-proofed for low-carbon heating and deliver high levels of energy efficiency.  Domestic or community scale renewable energy options should be required for all new developments.  East Lothian is also lucky to have a wonderful resource of heritage buildings and conservation areas but these designations restrict renewable energy installations, particularly solar. Retrofitting renewable energy applications, where they do not substantially alter or damage the heritage, should be allowed.

Recycling is only the backstop solution. We also need to encourage reduced consumption and greater reuse of materials. There are growing opportunities to access waste free food and other commodities and communities should be encouraged to adopt these and refuse waste. Encouragement for circular economy business models should be included as an action, working with Zero Waste Scotland.

‘Plastic free communities’ status is a commendable objective and given that 8% and rising of global oil production is for plastics production contributes to the carbon footprint of our county. Could the Council go on further and support communities to become net zero carbon? This sort of initiative would encompass all that you strategy suggests at a local level. Enabling local community council scale initiatives for carbon cuts, sequestration and adaptation could move communities towards this enviable status.

East Lothian should have a zero waste events policy. This should include a ban on single use plastics – not just ‘reduce reliance on single use plastics’ – and where possible the promotion of reusable options over disposable, promote renewables e.g. the Edinburgh Climate Festival ran all food operators from onsite mobile solar panels, high standards of waste separation and disposal and requirements for provision and promotion of sustainable travel for attendees.

Outcome 3: Active Travel and Sustainable Transport are used for Everyday Journeys.

East Lothian will have well-connected communities with increased use of active travel and sustainable transport modes to access services and amenities.

Transport needs to be addressed as a matter of urgency. It is one of East Lothians greatest challenges with a sizeable Edinburgh commuter population and a lack of a sustainable transport network to support it.

We agree information needs to reach people. Greater use of existing networks and promotion of opportunities such as interest free loans and grants would motivate more people to engage. At present only the interested go looking for information – it needs to be delivered to them in engaging and imaginative ways.

There are so many opportunities to encourage more sustainable transport use but where do the public see messaging about this on the street?  It is interesting to note that bicycles that are donated via ELC recycling centres at Kinwegar & North Berwick are collected and distributed in Edinburgh by Changeworks when we have local communities that could benefit. This does not deliver the message we need, especially to our more deprived communities.

ELC should prioritize zero carbon transport in all contracts and make this a criterion in tender assessment for school transport and other contracts.

Supporting EV charging is really important and we welcome the ongoing work of the council in doing this. Objective 3.3 is high priority. You should also be looking at future transport fuel technologies such as green hydrogen and considering how the county can take advantage of the opportunities by encouraging such industries to locate here and future proofing the refuelling network to enable early adoption when available.

Outcome 4: A Place Encouraging a Low Carbon Lifestyle.

East Lothian will be a place which encourages the transition to a low carbon lifestyle and reduces inequalities in our communities, by promoting green networks, active travel and outdoor play, local food growing, local amenities, and community meeting places, where everyone is connected to the outdoors and nature thrives.

This is critical across all communities. Small organisations such as Lil have insufficient resources to support as many schools and communities as we would like but the demand is there. The Council could facilitate such support through existing organisations. There is no shortage of information available but unless you take it to people and support their change uptake is poor.

Low Carbon is not the only lifestyle choice to be promoted as a result of the climate emergency. Scottish Water has access to only 5% of the rainfall we receive. As drought becomes more prevalent water efficiency will also be required.

Food growing space should be included in all new residential developments and its development supported in all existing communities wherever possible. Encouragement of food growing and wildlife gardening/rewilding should be county wide.

Many small groups are working to make changes but there is no coordination or support across the county. We welcome the Councils action to pull together the network so that they can move forward with shared experience and resources.

Outcome 5: A Low Carbon and Sustainable Economy.

East Lothian will have a sustainable and digitally-connected local economy, with thriving, low carbon and sustainable businesses, at the heart of vibrant local communities, contributing towards a sustainable, fair and equitable East Lothian.

The section talks a lot about encouraging economic growth. We should be aiming for economic stability and greater equity across our communities.  An area of land has a maximum carrying capacity for human activity. This can be increased via innovation and smart planning but there remains a limit. Indefinite continued growth cannot be sustainable.

New industry and employment opportunities will arise from the development of a low carbon economy and we need a workforce capable of grasping these opportunities. ELC should promote and support skills development to support adaptation of the economy.

Agriculture has a major influence on our county, the economy and landscape. The sector needs additional support to adapt to low carbon food production and land management systems and ongoing promotion of East Lothian Food and Drink and a local food economy should be included.

A key objective for East Lothian and Scotland as a whole is to reduce travel and switch essential travel to low carbon alternatives. This means ELC should be investing in and supporting the development of local business centres which enable commuters to travel shorter distances and still complete their work. Partnerships could be created with major employers to facilitate ‘home’ or ‘hot desk’ working.

‘Encouraging’ businesses to consider sustainability is insufficient. It should be a compulsory criterion in every decision the local authority (or Business Gateway) makes in supporting business from funding to planning permission.  Engage Business Gateway & Scottish Enterprise to support businesses to be climate change ready in a similar way to supporting them to be Brexit ready.

As an example, Lil is planning to launch a county wide initiative to support businesses who are implementing sustainable businesses practices alongside promotion of the national Refill scheme encouraging reusable water bottle refills once we have funding confirmed.

Outcome 6: A Healthy and Resilient Natural Environment.

East Lothian will have healthy, diverse natural ecosystems that support biodiversity and the wellbeing of our communities, functioning to off-set carbon emissions, acting as a key force in adapting to climate change, and resilient to changes in climatic conditions.

Changes in CAP support post-Brexit need to reflect the importance of this outcome. East Lothian Councillors and our MSP should make this a high priority. The current situation of agriculture across large swathes of the county means a large land area is under a monoculture and there are high rates of pesticide, herbicide and fertiliser use.  ELC should take every opportunity to reduce carbon and nitrogen emissions from fertiliser production and use. You should advocate for a reduction in use of pesticides and herbicides in agriculture to support environmental and human health and encourage biodiversity to flourish and support carbon sequestration including tree planting.

The LBAP should be published as a matter of urgency. It does not appear to be publicly available yet?

Two of the sites you mention– Aberlady Bay and Tyne Estuary - are likely to be inundated in the next 50 years and face significant chance of habitat loss due to increased storminess and sea level rise, how are you planning to manage these and other sites to enable adaptation to new conditions? Flood management can offer significant habitat creation opportunities and in many parts of the coast this is the logical solution to flood management. It’s good to see that this is being considered around Musselburgh but sea level rise predictions suggest that more areas of our coast will need to be managed in this way.

High visitor use of the coast and the associated impacts will always be challenge but there are opportunities to enhance and promote inland nature sites for amenity visits to help distribute visitors away from the honeypots. There are also many ways to encourage positive visitor behaviour and these should be explored.

Communities and visitors also have a key role in gathering biodiversity data. An East Lothian wide promotion of citizen science opportunities would add detail to existing data sets and offer greater detail on the changes taking place.

Outcome 7: A Well-Adapted East Lothian.

East Lothian’s natural environment, buildings, infrastructure and society will be adapted to the effects of climate change, and its communities will be resilient to further changes in the future.

The objectives and actions noted here only consider adaptation to change within East Lothian but the climate emergency is a global crisis resulting in global change. Wider consideration should be given to these global impacts on food security, human and species migration and economic impacts eg pressures may increase significantly in terms of tourism as our coast becomes more attractive to holiday makers and/or Edinburgh citizens may find the city too hot and look to move further into the cooler climes of a greener, coastal East Lothian.; climate refugees may become an increasing humanitarian crisis; we may lose critical species, some crops may not be successful as there may be insufficient irrigation water , golf courses may also suffer from water shortage and for coastal sites, inundation by the sea or more regular and severe flooding.

See previous comments regarding increased connectivity and natural flood management, not forgetting the latter starts in the hills and should affect all land areas particularly hard surfaces and large open areas of farm land.

Take the opportunity to be bold in developing the green networks and natural flood management initiatives. Ensure these approaches are included in every development to a greater extent.  As a small scale multi-benefit example of pushing boundaries a little further see https://www.independent.co.uk/news/world/europe/bus-stop-plants-green-roof-bees-holland-utrecht-a8997581.html Perhaps all East Lothian verges and pavements could adopt a greener, more biodiverse approach alongside educating our citizens why it’s important and that ‘neat’ is not always ’good’.

ELC should take steps to protect people from the dangerous effects of overheating in homes, schools, care homes and hospitals, including a review of Building Regulations. This will be crucial in delivery equity across the county.

Agriculture is critical to East Lothian. We need to support adaptation in farming to new methods and crops that support a low carbon, local food economy and a healthy environment.

[1] https://royalsociety.org/topics-policy/projects/climate-change-evidence-causes/question-14/?gclid=CjwKCAjwmtDpBRAQEiwAC6lm42btB5TumKIdYInWBqHOyLwTNOXSkHIQt98f6VMV0sqZKb223FkLZxoCO-gQAvD_BwE

[2] https://ss2.climatecentral.org