ELCAN response to the Council’s Draft Climate Change Strategy 

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EAST LOTHIAN CLIMATE ACTION NETWORK (ELCAN’S) RESPONSE TO EAST LOTHIAN COUNCIL’S 

CLIMATE CHANGE STRATEGY   

11TH DECEMBER 2024

The following response has been developed by ELCAN members (which represent over 70 groups and organisations across East Lothian), facilitated by East Lothian Climate Hub, and endorsed by ELCAN’s Chair. 

Tim Hetherington, ELCAN Chair

Bobby Pembleton, East Lothian Climate Hub Manager

4. Do you have any feedback on the Purpose, Structure, and Contents of the Climate Change Strategy?

Please use this text box to tell us what you think about the first sections of the Strategy, which explain its Purpose, Structure, context, and Our Plan. 

1. Whilst recognising the resource constraints faced by the Council, we believe the strategy should look beyond a limited organisational focus; and that this should be the next priority – with a clear target date for delivering a strategy beyond the Council’s estate, created in collaboration with the Climate Hub, ELCAN members, the wider communities and other stakeholders. In the interim, lessons that can be learnt from the datelined action plans should be shared to inform community groups and non ELC organisations
2. Whilst adaptation is crucial and needs to remain a key focus, we think that mitigation should be prioritised on page 1, within the Assets box and following the four themes diagram in order to give clear leadership about the need for mitigation. 
3. We welcome many of the proposed actions. However, whilst the quantity of actions is ambitious, many of the actions are vague and lack ambition. Whilst a bottom-up approach is to be welcomed, this seems to have resulted in a rather random and imbalanced collection of actions with some areas that have not been covered. We would expect the Strategy to have clear priorities based on criteria including urgency and potential impact. 

There is also more of a focus on inputs (such as providing advice, writing guidance, and policies) rather than outcomes. Our view is that all actions need to be explicitly linked to measurable outcomes to make a positive difference.

We ask that clear concrete outcomes, targets and timeframes are specified against each action, as detailed as possible and articulated as SMART objectives.   For example: G4.5 ‘Consider the Circular Procurement Hierarchy (Reduce, Reuse, Recycle and Recover) at an early stage as part of commodity strategy development’ could be made much stronger ‘reduce waste at source by xyz% by (insert year) by ensuring that by 2025 the Circular Procurement Hierarchy (Reduce, Reuse, Recycle and Recover) is integral to commodity strategy development.’   A1.5 ‘Identify high water usage areas and respond’ could be made much stronger ‘Reduce water wastage by xyz% by 2025/2026 (different targets per year) by identifying high water usage areas and working with Engineering services to implement the necessary measures as defined by……’ 

1. Pages 9-11 lay out three different scenarios for emissions budgets – the Climate Hub and ELCAN’s position is that only the transformational option is acceptable in order to meet climate targets. 
2. The term ‘climate resilience’ is used often. We would like to see this defined. 

5. What does local authority ‘Leadership’ in a climate emergency look like to you?  Please use this text box to tell us what Leadership looks like to you.

1. It means prioritising climate & biodiversity action in the delivery of all other Council strategies. G1.5 should be re-drafted to reflect this. Climate and biodiversity emergencies should be central to all decision making, and one of the highest priorities (alongside poverty and food insecurity) in the Council’s policies and strategies. As the Local Development Plan 2 is prepared (and when the East Lothian Plan is renewed in 2027), ELCAN and the East Lothian Climate Hub recommend that the Climate and Biodiversity emergencies are made integral to it, including net zero targets.
2. Climate implications will be listed and considered for all council decisions at Full Council.  Net positive and biodiversity positive outcomes should be the default position in all decision making. Mitigation and adaptation measures should be clearly described in all decision requests by Council.
3. This means a change in approach, especially in relation to planning where decisions have been made that ignore previous policy on climate change and biodiversity, examples including, among many, housing development being approved at Dunbar Golf course without any adoption of proposed mitigations against NPF4 by the community council; the decision to remove hedgerow at North Berwick High School; the removal of the Bunds in Cockenzie; the approval of housing on the woodland at Herdmanflat despite knowledge of proposals for a Community Asset Transfer to save woodland. This means ensuring that all staff understand the climate change strategy and are committed to making change; and more joined up thinking between East Lothian Council’s aspirations and some of its decision making. This apparent disconnect has a detrimental impact on the credibility of East Lothian Council’s approach and the trust and support from the community.
4. The Council identifies the role of climate action in delivering other objectives.  This is key to the just transition through job creation, and the Wellbeing Economy.  For example, in delivering more circular practices more employment opportunities are created higher up the waste hierarchy (up to 296 jobs for Reuse).
5. The council commits to holding itself to account where/when policies/decisions/actions contravene the Climate Change Strategy, with a defined process for doing so. This would also include, within the climate change strategy, a community-driven process whereby there can be active monitoring of the implementation of the strategy. This could include 
   1. Strengthening existing Community organisations such as community councils, and local area partnerships in their role and ability to influence and implement
   2. A community forum with ELCAN representatives feeding into the implementation/monitoring it’s implementation
   3. Ongoing feedback via online pages and physical suggestion boxes in communities
   4. Consideration of broad-based welfare of future generations in all decisions. The UNCRC which has been incorporated into Scots Law states that across all policies, decision making and plans, leaders should respect, protect and fulfil children’s human rights. General Comment 26 confirms that children have a right to a clean, healthy, and sustainable environment.
   5. Attachment of financial value to biospheric capital to create a more level playing field with economic/job/development decisions in planning
   6. Actively promoting publicly that communities and council officers can highlight and request a review of any decisions by the scrutiny committee and cabinet.  
   7. Investigating if the Climate Change Strategy can be included as part of the Local Development Plan 2 to be able to have teeth.
   8. Legal clarity is provided on how the Climate Change Strategy is relevant to planning legislation and whether it can be used as a valid reason to refuse a planning application.   
   9. Within the Communications strategy there should be a requirement for departments and the planning committee to explain their decisions when there is a conflict in decision making e.g planning, finances, economy vs climate – for transparency.  
6. Leadership means addressing other sources of carbon emissions and environmental pollution that damages biodiversity and the potential to sequester carbon in East Lothian, notably agriculture, and ensuring food security in the county through prioritising arable land use for this purpose. East Lothian Council should commit to using its’ soft powers to support community efforts in partnership working with Scottish and UK Governments, national and local agencies including SEPA, farmers, landowners and managers, and communities in moving towards regenerative land management and farming practices, including via changes to subsidies.   
7. The Council commits to lobby higher levels of Scottish and UK Government when it comes across limitations of legislation or finance which impede it from taking action on the climate and nature crises.  
8. We ask that the Council joins a growing global coalition of councils, organisations, parliamentarians and countries calling for the Fossil Fuel Non-Proliferation Treaty.
9. We appreciate that the Council is underfunded and that resource constraints will limit what can be done. We appreciate the work that has already been done on decarbonising housing stock and would like this to continue to be built on, with a commitment to campaign for additional resources to continue to implement this. A programme of installing PV solar panels, the implementation of the district heat network, and installing of heat pumps in harder to reach areas that can’t be covered by the district heat network, would tackle climate change and fuel poverty as well as create skilled jobs in the county. What plans does the Council have for raising this with both the Scottish & UK governments and GB Energy? Is the Council working with COSLA on such topics? Surely the Strategy should include measures such as this for addressing the resource shortcomings? 

6. What are the most important steps to improve the Adaptation Capability of East Lothian? Please use this text box to tell us how the Council can improve its ability to adapt to climate change.

1. Within this section there is quite a heavy emphasis on the creation of plans and strategies.  We would like there to also be some clear targets for the implementation of these, for example G2.3, G2.6, and G2.12.
2. G2.1 to develop and publish a Climate Risk Register is very welcome and should be prioritised. This should include Climate Risks both within and outwith the Council’s control.
3. Within adaptation, it should be emphasised that a holistic approach should be taken to helping the environment become more resilient to climate change, by increasing biodiversity, and planting more trees, hedgerows and restoring river catchments. 
4. Adaptation measures should focus on nature-based solutions.

7. What Council operations would be most improved by better understanding of the causes and effects of climate change?  Please use this text box to tell us what the Council does that should be more Carbon Literate.

1. G3.5 We welcome the clear target of delivering Carbon Literacy training for 500 council staff by 2027, particularly in the context of time and money constraints.  We would recommend assessment of literacy level for all staff followed by appropriate practical training where required which can be implemented, prioritising the Lord Provost, the elected leader of the Council, senior managers, elected representatives, those on committees, all council officers feeding into planning decisions, and those on the scrutiny committee. We also suggest a target to include carbon literacy training for every new recruit/transfer/promotion to/within the Council staff to be built into the induction process if this is not already the case. 
2. In addition to G3.3 there must be agreement amongst all council departments that the Climate Change Strategy is recognised as a core cross-cutting strategy across the Council’s entire operations and decision-making processes.
3. Alongside Climate literacy training, elected representatives and relevant staff (those named in 7A) should receive training on planning policy, including a thorough understanding of NPF4 and policy 3 of NPF4 which is currently being ignored in decision making.
4. ELCAN and the Climate Hub welcome that the Wellbeing Economy is now part of the Council’s Economic strategy, and the recent Community Wealth Building strategy which has been passed.  We recommend that the Council ensures that key officers, senior management and elected representatives have a clear understanding of Wellbeing Economy and Community Wealth Building.
5. We appreciate the measures East Lothian Council is taking to reduce its’ mowing and spraying; and urge the Council to reduce this further, taking the lead of other local authorities regarding the spraying of glyphosate and how hedges are maintained. 
6. There is no mention of schools or Learning for Sustainability in the Carbon Literacy section of the Action Plan. This omission should be rectified.   We would expect there to be training for those with responsibility for the Learning for Sustainability curriculum in each school.

8. Where can the Council’s procurement make the biggest difference for local people & for climate change?  Please use this text box to tell us how the Council can buy better and more sustainably.

We recommend the following be added to the Procurement action plan: 

1. Introduce a mandatory carbon footprint assessment for all major procurement decisions (contracts over £x) and set specific targets for reducing Scope 3 emissions.
2. A commitment to stop buying, or selling on premises, single use plastic products such as cups and bottled drinks, and make it clear, in conditions of hire, that anyone using Council premises such as community centres, Enjoy Leisure and the Corn Exchange in Haddington, must not use these products either (as reiterated into 17 c)   We would like to see this as a condition of all hires & licencing.
3. Locally grown food should be procured for school meals and home economics classes wherever possible.  
4. Specified requirements for the provision of outsourced food and drink, such as for school meals, and catering, regarding locally sourced produce and moving towards greater vegetarian menus. 
5. G4.6 Tendering for construction contracts could include ‘projected carbon emissions’ and ‘whole-life carbon including decommissioning and removal’ and ‘supply-chain carbon’ within criteria for considering any contracted bodies (not just the construction activity itself).  Also to add a reduction in virgin materials used.
6. The Council’s tendering procedures should include a commitment to community benefits from contractors.
7. Promote / have targets for re-use of stock / second hand procurement of stock for council use e.g computers, desks and other stock  This would show real leadership and would also help save the council money.  
8. G4.5 Move to a circular procurement strategy that shifts from replace to repair and from ownership to hire/lease for equipment / vehicles.  For example, move to a lease/rent rather than purchasing for IT infrastructure. As a minimum revise G4.4 to extend product lifespans through repair and upgrade rather than replacement or lease equipment. Procurement could also look to organisations like the Edinburgh Remakery for refurbished IT equipment.

9. How can the Council use its existing resources to improve climate change outcomes? 

Please use this text box to tell us what the Council can do more sustainably using its available resources. 

1. ELCAN and the Climate Hub recommend that the Climate Change Strategy states that principles of a Wellbeing Economy and Community Wealth Building will be integrated centrally into council policies.
2. The Climate Change Strategy to explicitly state that climate and biodiversity-positive Community Asset Transfers will be proactively supported by the Council. We would welcome more lateral thinking on Community Asset Transfers which can be onerous for communities, whereas renting from the Council can be more straightforward.
3. The strategy to state that any cuts / budgetary constraints should be considered against the impact on climate mitigation, adaptation or community resilience, and if it is seen to negatively impact on any of these it be reconsidered by appropriate committees and officers.
4. The strategy could identify and specify ways of raising funds to enable some of the transformative actions needed to be delivered, for example through investors in infrastructure projects, a workplace parking levy, property developers and other sources.
5. The school estate and amenity services can be used to improve biodiversity and community food growing, particularly in areas of poverty. The availability of amenity services to support biodiversity should be publicly promoted so that communities are able to better identify areas for biodiversity and work collaboratively with amenities.  
6. A simple waste & cost reduction change could also include asking young people in schools to bring a container to take their cooking home rather than the Council supplying singe use containers.

10. Any other feedback or comments on Governance.  Please use this text box to share any other thoughts on this topic.

1. We understand that the Council has urged its Pension Fund to divest from fossil fuels but to date some partners do not yet have a majority in favour of divestment.  The strategy should advocate for a commitment to continue to argue for this divestment with other Lothian Pension Fund members under the Leadership section. In light of apparent increased investments of the pension fund in fossil fuels, has the Council considered separating out it’s own share of the overall fund’s investments into a separate structure and divesting it?
2. The strategy should require East Lothian council to only bank with a bank which has entirely disinvested from fossil fuels or other significant climate-negative activities; and similarly with any funds it holds that these are disinvested from fossil fuels. 

1. We recommend that the Council follows its’ own Governance guidelines and raises awareness of existing council Governance guidelines both internally and publicly.  Where Councillors and/or staff have representations on other bodies, such as charities, to declare any conflict of interest/governance that may arise between ELC governance policies and that of the charities that they may be a trustee or a board member of, particularly if these may compromise either East Lothian Council or the charities’ good governance guidelines.

11. What sustainable practices would like to see us use with our buildings?  Please use this text box to tell us what the Council should do with our buildings that would improve sustainability and climate readiness.

1. Decarbonising Council offices and depots, schools and the housing stock must be a priority. Taking A1.17 a step further, preparing and costing a programme of retrofitting, installing PV solar panels, and connecting council buildings to the district heat network to provide anchor heat loads should be a high priority. The capital investment would result in significant revenue savings for the Council and reductions in the cost of living for tenants. 
2. A1.8  We request that this is made stronger to include: all electricity consumed should be from renewable sources e.g the strategy should commit that the council will ensure that its energy supplier sources electricity from 100% renewables; and that gas is phased out within 10 years. 
3. A1.9 A commitment to generate as much solar electricity as possible, and hydro where it doesn’t have an impact on biodiversity (with a clear target and time frame)
4. The Council should investigate overall efficiencies and options for cutting costs and emissions, such as heating the person not the place, a lights out when you leave policy, no equipment left on standby.
5. A1.21 needs to be prioritised in order to achieve the aspirations to decarbonise the estate.
6. A1.23 needs to be made stronger, with a commitment to at least 60% or more of housing to be EPC C or above within an identified time frame. 
7. A1.1 A commitment that all new Council buildings to be at Passivhaus standard within a specified time
8. All council buildings to provide readily and publicly accessible mains drinking water and bottle-filling facilities. 
9. School playgrounds to be climate adapted, and to be of a consistent quality to enable children to play outside and in nature.  UNCRC General Comment 26 confirms that children have a right to a clean, healthy and sustainable environment. There are huge links between the quality of the environment, children’s ability to play outside and long term health. 

12. What sustainable practices would you like to see us adopt in terms of transport?  Please use this text box to tell us what the Council should do when it comes to transport that would improve sustainability and climate readiness.

1. Reduce the need for transport by creating working hubs closer to where people live.
2. A focus on 10/20 minute communities for development and planning.
3. The statement ‘over the next 5 years, we will prepare to transition to a fleet of vehicles that produces zero tailpipe emissions’ is vague. What does ‘prepare to transition’ mean? As the Council already has Electric Vehicles this process has begun. Can a more specific target be agreed. 
4. The Council should require contractors, such as school transport providers, to transition to zero tailpipe emissions. 
5. The Council should require contractors not to leave polluting engines to idle in school grounds when children are walking past them
6. The Council should promote its’ no idling campaign across the county, working in partnership with ELCAN members and other stakeholders.
7. The transportation of school children to service providers to be planned so that buses and minibuses are used rather than individual taxis. 
8. All schools to have cycling proficiency training. 
9. The strategy to have clear targets to work with other agencies for an improved bus and train service, including better connectivity between more rural areas, reliability,  frequency and reduced cost.  
10. The strategy should commit to improving the pedestrian and cycling experience; for example through pedestrians first in town centres, wider pavements, no street furniture eg chairs and tables if the pavement is not wide or is uneven; more designated cycle lanes (as with Edinburgh council)
11. As part of its’ leadership, the Council should trial a lift share scheme for its’ employees which can then be promoted and rolled out across the county, for example  https://liftshare.com/uk 
12. The Council to respond to local residents requests to reduce speed limits encouraging active travel and improving safety.
13. A strong campaign for driver awareness of others on the road
14. Traffic volumes travelling through our communities must be reduced.  Private Car use must be de-incentivised and where viable alternative routes are available these must be prioritised over town and village high streets for through traffic.  

13. Any other feedback or comments on Assets. Please use this text box to share any other thoughts on this topic.

1. The Action Plan for Buildings includes many important aspirations. Given the significance of buildings in terms of the proportion of the Council’s emissions they create, there should be an indication within the Strategy of how they will be prioritised compared with other sections.  
2. There is, perhaps unsurprisingly, overlap between this section of the Action Pan and the one on Homes. We suggest there needs to be a more ‘joined-up’ approach. For example, how does A1.11 relate to A1.23, and how do they relate to P5.7 in respect of EPC level? 

14. What climate change topics should we consider in education delivery?  Please use this text box to tell us what climate change topics should be covered in education.

1. We request that the strategy commits to the Learning for Sustainability curriculum being embedded within Primary and Secondary Education across all subjects in the curriculum. In addition that schools must do all they can to support children to develop deep connections with nature, and the practical skills and personal resilient that will be necessary as climate impacts are increasingly felt.  
2. We urge the Council to take a leadership role with schools to deliver the Learning for Sustainability curriculum and action plan. We note the quality of Outdoor Learning in different pockets of East Lothian. However, there is much scope for further delivery of this across East Lothian for all schools for consistent access to the same opportunities; as well as to further develop and embed the other aspects of Learning for Sustainability throughout the curriculum.   We recommend that this can be achieved through:

• Actively committing to and leading on the delivery of the Scottish Government’s 2030 target for Learning for Sustainability. 
• Collective agreement and leadership by the Council for Learning for Sustainability being part of school plans.
• All staff in schools being trained, rather than there just being one champion for Learning for Sustainability within the schools, including East Lothian Council hosting teacher conferences 
• Study visits to local farms especially those adopting regenerative or organic methods would provide an opportunity to learn about the impact of agriculture on the climate and nature.  

1. Schools to support and involve pupils in improving their carbon footprint, the biodiversity and quality of their school environment and in conducting waste and plastic use audits of their schools.   Article 12 of the UNCRC states that children have a right to express their views and have them taken seriously. 
2. Commitment to training and upskilling the workforce to transform the local economy in green jobs with a clear plan on how this will happen e.g who could provide the training, creation of green apprenticeships, partnerships with schools, QMU; upskilling careers services; and with a council staff member designated to oversee green skills jobs and upskilling/training  

1. S1.11 Wallyford’s Regional Construction Skills Academy to become a leading training centre for vocational skills, including new technologies and skills needed for climate change mitigation and adaptation. 
2. At S1,15 There is mention of Investment in circular economy training, skills and technology. This is welcome but the action is currently very vague. Who is this for and what Circular Economy training, skills and technology does it refer to? 

15. Who would most benefit from education and training on sustainability?  Please use this text box to tell us what groups the Council should look to provide with education & training.

1. Whilst we welcome the Action Plan’s coverage of Early Years provision, there is no equivalent emphasis on Primary and Secondary education. Schools, apart from buildings, appear to be missing from the Strategy. Given the impact that climate change will have on future generations and climate anxiety amongst young people this seems to us to be a very serious gap in the Strategy. We request that there are clear references to Eco Schools; and also the embedding of the Learning for Sustainability curriculum across all subjects in the curriculum, especially as both were included in the previous Strategy.  This is critical to prepare school leavers for careers in the just transition.
2. The Council to use its’ influence for the QMU innovation hub to focus on the climate challenges in mitigation and adaptation strategies

16. How can the Council use its collection service to reduce waste around the county?  Please use this text box to tell us how the Council can collect waste in a way that reduces waste and improves recycling.

1. To reduce waste at source, include an ambition for a circular economy strategy to include a waste reduction target across the council. Households should be encouraged to reduce all waste (including recycling) to reduce collection and transport costs. Set an objective to work with community based groups to achieve these outcomes. The Council already works with Reuse Scotland at the Recycling Centres.
2. Set a waste reduction target across all Council services.
3. We applaud the relationship that the Council has with Caledonian Horticulture and welcome the fortnightly collection of garden waste. Has the Council learned from other areas about good practice in engaging with communities where recycling rates are lower?  For example encourage competition among local communities for reducing waste. 
4. To influence the phasing out of the use of incineration in waste disposal, whilst utilising the existing heat whilst it exists as part of the district heat network.
5. The council to lobby the Scottish Government to be able to legally stop charging small businesses for using recycling centres. 
6. At S2.2 ‘Improve Kerbside Recycling’, we would like to see this clarified and with clear targets: Reduce recyclable material going in residual waste bins; Increase the resources being reused; Reduce total household waste.
7. Publicise convictions for flytipping and littering. 
8. We suggest that there be a link to sustainable procurement and a ban on single use plastic products within Council premises including schools.  
9. We are aware that holiday lets frequently lack recycling facilities and call on the Council to require owners through the licensing scheme to ensure that visitors are encouraged to recycle. 
10. Provision should be made for recycling facilities in public places especially at tourist attractions, potentially using a Transient Visitor Levy to help fund these.  
11. Is the Council able to require take away businesses to offer reusable containers/packaging, enable customers to utilise their own containers, or to provide biodegradable containers for customers that don’t take up these offers.
12. Support/information to be provided/made available on reusable nappies and sanitary products

17. How can the Council’s customer-facing services be more sustainable and help you be more climate-positive?  Please use this text box to tell us how libraries, parks, and sports facilities can be more climate-positive places.

1. We commend the Action Plans S4.8 & 9 regarding Lend and Mend Groups and Tool libraries, and suggest that the wording changes to include other types of sharing libraries, such as toy libraries, and libraries of things.  In the context of limited Council funds, we urge the Council to seek funding to support this, working in partnership with communities and other stakeholders where possible to assist in the delivery of this.
2. We strongly recommend that the strategy states that libraries need to be kept open as a priority rather than reduce their hours: given their important and increasing role in supporting the circular economy, creating community connectedness and resilience, and in being a warm space for people to come to during the energy crisis.  In the context of limited funding, we encourage the Council to explore cooperating with the voluntary sector eg day care centres, community centres to help in operating the hours of opening. 
3. Where possible, make Libraries a supplemented book exchange. There are thousands of books in the community that could be shared. Purchasing of books only where titles aren’t otherwise available would save funds, energy and paper.
4. Libraries to look into providing desk space and co-working space, where voluntary and community based groups can benefit, in turn increasing footfall.
5. Stop the selling and use of single use resources within these services
6. Reduce the use of pesticides and herbicides, including glyphosate only to areas where no other option is feasible.

18. What changes to planning would enable climate action?  Please use this text box to tell us what planning can do to make climate action easier.

1. We request that the strategy states that planners, both officers and Councillors, will prioritise both nature and climate.  This includes more robust planning requirements especially around NPF4 compliance; and putting mitigation and adaptation as a prime requirement of assessing planning applications. Carbon calculations should be mandatory. 
2. The Planning Focus Area text begins with ‘planning for the effects of climate change’. Whilst obviously this is hugely important, mitigation measures should also be central to planning. Specific and measurable sustainability requirements should be in place and implemented on all future housing developments, to adopt the highest net-zero standards (silver or gold building standards). Guidance should be more ambitious – it should ‘require’ renewable energy rather than merely ‘support’ it.  
3. The Council to enact and adhere to its’ Housing Strategy
4. Developers to be required to carry out a whole life cycle carbon assessment of projects, including for example new build developments, battery storage developments among others.
5. Planners to ensure that appropriate infrastructure will support new builds are in place.  There is growing evidence of substandard sewage infrastructure and monitoring processes giving rise to pollution in environmentally sensitive areas for e.g. Aberlady Bay LNR
6.  Where possible, the council to explore where it can have greater influence on developers for example a mechanism to be put in place for developers to be held to account if they violate standards and legislation through potentially a Scottish new build ombudsmen.  Examples of violations of standards include, for example, footpaths not being built in good time with housing developments; the delivery of Blindwells housing by subcontractors due to time constraints.   Where these are beyond the remit of the Council’s powers, we urge the Council to lobby the Scottish Government. 
7. The Council to put conditions on housing developers to better support Biodiversity and climate for example installing swift boxes etc .
8. We are aware of variable standards being shown by factors with some evidence of a failure to behave in a nature friendly way. We urge planners to set planning conditions that require factors to comply with high environmental standards. 
9. In conservation areas barriers should not be put in the way of applicants who wish to install double glazing, solar panels and other renewables, in line with LHEES.  Energy efficiency should be as important as aesthetic planning concerns.
10. The Planning Committee to put conditions on approval of plans, based on environmental assessments, such as further drive-through fast food and drink outlets and for there to be a simple policy / guidance to support it in this. 
11. S3.1 replace ‘supports’ with ‘requires’.  Whilst there is a need for clear planning guidance to support renewable energy in suitable locations, there needs to be a requirement which  ensures any initiatives adhere to NPF4; and which proactively advocates for community ownership and high levels of community benefits, spent on local climate action and which adheres to NPF4 
12. S3.4 replace ‘support’ with ‘require’ 
13. S3.5 include guidance on water butts and other water storage systems and  natural flood defences such as wetlands, green roofs and rain gardens.
14. S3.6 add after ‘sustainable materials’ for example, hedges in place of walls or fences, green infrastructure such as green roofs, living walls, biodiverse landscaping and flood mitigation. Add to the list of targets planting native trees including fruit and nut trees in communal spaces.  Guidance on developments to also include NPF4, adherence to the new Scottish Government housing regulations, and biodiversity enhancement, with a requirement on a higher than minimum required biodiversity net gain.   
15. S3.7: In addition to developments assessing climate risk, we suggest that planning decisions also take these climate risks into account so that no new developments can go ahead if there is a risk of flooding / it’s on a flood plain. 
16. The council removes minimum parking requirements for new housing developments to promote living streets and disincentivise the use of the car. 
17. The Local Development Plan 2 will commit to establishing 15/20 minute neighbourhoods, with a policy including the key services required within 15/20 minutes of communities, specifying how it will be measured, either by bike, walking or bus

19. How can care delivery be more sustainable and climate-ready?  Please use this text box to tell us how we can deliver care more sustainably.

1. To be sustainable care needs to be provided in communities close to family members to avoid the need for visitors to travel with the associated emissions. The loss of the Abbey care home, Belhaven community hospital, and the ward at the Edington Hospital undermine the aspiration to make care delivery sustainable. 

20. Any other feedback or comments on Services.  Please use this text box to share any other thoughts on this topic.

 

21. How can we make community climate action easier to do and more effective?  Please use this text box to tell us what the Council can do to support community climate action.

1. When community groups raise concerns about planning applications because they consider them to be opposed to the Climate Change Strategy, we urge Council officers and Members to be more willing to discuss the issues and seek alternatives, and that there is a mechanism which is adhered to for community dialogue and appeal, including the use of the Scrutiny committee (as we suggest in 5c).  
2. P1.4 – This needs to be a bit clearer in terms of how communities will be supported to be resilient to climate change.  Will this be through any particular mechanism? We recommend that emergency and resilience planning is reviewed and revised, considering how to work with the community on this without putting undue burden on them.  Reference 27A for what we consider sustainable communities. 
3. P1.6 – ‘explore including climate action in area plans’ – this needs stronger language. For example:  ‘require Local Area Partnerships to develop local climate action plans, with guidance provided
4. P1.9 – ‘identify land for community climate action’ needs to be a bit clearer about what it means, or is this deliberately vague? Some targets would be useful : how much land / how many plots?  We would also recommend facilitating community adoption of small urban greening spaces.
5. A commitment to resources and infrastructure to support in particular communities which are vulnerable to sea level rise, coastal erosion and flooding; and those in isolated settlements vulnerable to losing power
6. Further engagement with ELCAN members and East Lothian Climate Hub in the implementation of the Climate Change Strategy and working with the Climate Hub and ELCAN who have a vital role in engaging with communities.

22. How can the Council reduce the amount of commuting within and outwith East Lothian?  Please use this text box to tell us what the Council can do to reduce the amount of commuting in East Lothian.

1. Reliable public transport which is close to people’s homes and takes them to where they need to go is a key element. The Council should use whatever power/influence they have with bus and rail companies to improve reliability, affordability and the range of destinations, particularly across East Lothian between rural communities; and to key services such as Royal Infirmary 
2. More affordable housing is essential. The high number of holiday lets contributes to the shortage of homes to rent. (Please see the recommendation that a sustainable tourism policy be developed at Question 27) 

1. P3.6 – ‘reduce staff commuting by car’ – make clear how this can be achieved, for example through a workplace parking levy; liftshares…

23. What steps can we take to encourage using low-emissions travel?  Please use this text box to tell us how we can encourage people to travel more sustainably through and around East Lothian.

1. P3.18 – ‘increase school streets’ – make this more measurable with clear targets
2. The practice of promoting East Lothian as a motor-driven holiday destination should end with a target date.  Public transport links must be emphasised when promoting holidays in the County.  All tourism must be sustainable tourism if the Council is to be taken seriously.  Sustainable tourism should be proactively promoted by the Council.  Tourists should be made aware – before they reach East Lothian –  that sustainable travel alternatives are widely available and the Council supports their use through the journey hubs. 
3. The Coastal route is seen as an attractive route for tourism.  However, tourists should be encouraged to travel using public transport, and buses from train stations.  There needs to be better integration using the journey hubs. 
4. The creation of a Sustainable Tourism policy. 
5. Proactively discouraging private car use and taking through traffic out of our communities
6. Reducing speed limits where requested by communities to encourage walking and cycling
7. Pedestrians and cyclists to be viewed as first priority, vehicles second priority 

24. Where and how should nature be restored for climate benefits?  Please use this text box to tell us where and how we should restore the natural environment.

1. The Council should use whatever influence it has with the farming community to encourage nature friendly farming to both reduce carbon emissions and the harmful effects of fertilisers such as nitrogen which pollutes our rivers and the Forth undermining efforts to sequester carbon. 
2. Reduce the use of pesticides and herbicides to only essential situations.
3. Improve the diversity of the natural habitat on the Lammermuirs
4. Rewild as much land as possible where land is not being used in the production of food directly for human consumption (rather than animal feed, or non-essential crops such as beer prerequisites). 
5. At P2.2 ‘Enhance green spaces in built up areas’ add ‘and facilitate community adoption of these spaces for nature and food growing to include nature based solutions for climate mitigation and adaptation’.
6. Increase tree canopy and meet the aims of the Tree and Woodland Strategy. P2.6 – ‘support tree planting across the county’ – : what is meant by this? Needs to be clearer – through provision of land? Of trees? Through amenities staff time? Make clear this is against the Tree and Woodland strategy.  Where trees have to be felled to leave the trunk standing for biodiversity, where it is safe and practical. 
7. Actively participating in reversing the loss of hedgerows through the Amenities services. 
8. p2.9 – ‘aim to use peat-free compost and soil’ – we request that this is more strongly worded, to ‘ only use peat free compost and soil’
9. P2.11 ‘ LDP2 will identify nature networks’: could the strategy include that these nature networks will be adhered to in decisions made in planning
10. We welcome P2.1 ‘greening the grey’. A loss of gardens when they are turned into car parking spaces is an issue for drainage and biodiversity. Does the planning committee have any powers to prevent the paving over of gardens (for example see Edinburgh council)? 

25. How can we help create a low-emissions and climate-ready economy?  Please use this text box to tell us what the Council can do to transition East Lothian to a climate-positive economy.

1. The council to ban high carbon advertising on site it controls, by introducing a low carbon advertising and sponsorship policy, as Edinburgh City has done. 
2. Providing or working with other agencies to provide district heating 
3. P4.16 – what measures are taken in schools to reduce food waste? How could this point include schools? 
4. Proactive support for small local businesses e.g through office spaces, reduction in rates for small businesses; with higher tax rates for businesses that are polluting / have a detrimental impact on the Environment
5. Proactive support for community initiatives that support the development of local wellbeing economies. 
6. Facilitate the green transition by focussing on green skills development, and promote green careers in schools

26. How can we help you use less fossil fuels in your home and become climate-ready?  Please use this text box to tell us how we can help improve sustainability in homes.

1. We welcome the work that has been done on a heat and energy efficiency strategy but are disappointed that there is no detail about this in the climate change strategy.  Providing district heating would be an excellent step towards this and mention of this is recommended. 
2. A target to retrofit all council owned and managed homes, with a target date
3. Any learnings the Council identifies from retrofitting different types of housing stock should be made publicly available, for residents who privately own previous social housing –  to identify common/typical changes that can be made to different types of housing stock. 
4. The Council to compile a directory of tradesmen with expertise they have worked with in eco-building, retrofitting for energy efficiency, renewable energy generation, and to make this publicly available for private homeowners to make use of. 
5. Provide a subsidised and approved insulation package. 
6. P5.4  ‘The LPD2 will guide housing developments to locations that minimise their vulnerability to climate change’ – this needs to make explicit that this will not not just be a guide, but will insist on strict adherence and a refusal of any properties being developed in locations which are particularly at higher risks to climate change
7. P5.7 ‘build new housing to a high energy efficiency standard’ – make clear that these need to be against particular standards agreed by the Scottish Government
8. P5.6 – given the aim to build more than one Passivhaus surely the review needs to be carried out much sooner than 2030? 
9. P5.1 ‘reduce the number of homes below EPC rated C’ – we request that this is specified clearly, to less than 40% of housing stock or with targets to reduce the number of homes below C rating that are linked to the scale of the problem, e.g. reduce by 50% in three years and by 75% in 6 years?  
10. P5.2: ‘increase number of homes with solar PV’ – strengthen this to a clear target – potentially linked to suitable roofs (South, South East or South West facing); and also create a target for a minimum requirement for on-site renewable energy generation for new building development 
11. P5.11, 12  and 13 are very desirable but need to be more specific. 
12. The council establishes a scheme to enable residents to purchase renewable energy cheaply, through collective buying. For example, through Solar Streets https://www.frometowncouncil.gov.uk/fromes-solar-streets/ 
13. Is there any scope for ELC to entirely ban the burning of coal in open fires in East Lothian, e.g. on health grounds re. atmospheric pollution?  

27. Any other feedback or comments on Place.  Please use this text box to share any other thoughts on this topic.

1. We welcome Action Plan points P1.1, 2 and 3. The Council should be commended for its’ existing work on community resilience. The text on requirements for community sustainability and resilience is great, and many of the Council’s policies contribute to this, as would many of the recommendations included in this response. We feel strongly about P1.4 – the aspiration to support communities to be resilient is very important. However, relying on emergency plans to achieve this is inadequate. 

We believe that for a community to be sustainable it needs to have strong social networks and mutual support structures and have high levels of trust and co-operation developed through friendliness, neighbourliness, caring and a shared sense of purpose. It also needs to be able to offer affordable homes to attract a range of people who can meet the local skills needs. 

We do not consider a number of towns meet these criteria at present because of an imbalance between principal homes and holiday lets & second homes. This imbalance results in some residents feeling isolated and disconnected and in a shortage of affordable homes to rent as recognised in the Council’s housing strategy. 

We recommend that the Council should develop a sustainable tourism policy as a matter of urgency to address these issues as well as those associated with transport. [The World Tourism Organisation defines sustainable tourism as:  

“Tourism that takes full account of its current and future economic, social and environmental impacts, addressing the needs of visitors, the industry, the environment and host communities.” https://www.unwto.org/sustainable-development ]         

28. Do you have comments on any of the proposed actions? You may comment on multiple actions in this text box. Please make reference to the Reference or Action description that you want addressed. Please use this text box to tell us what you think about actions in the Action Plan and tell us which actions you are referring to.

We would like to reiterate that all the actions in the strategy should be more specific and with SMART objectives and clear outcomes.