Cockburn Response

Consultation Comments

Background

Over the past twenty years or so the City of Edinburgh Council, in conjunction with many formal and informal partners, has brought forward or enacted many sustainable development  and climate change related strategies, policies, action plans and initiatives.  These all built upon similar strategies prepared by the former District Council and Lothian Regional Council, notably including  the Agenda 21 initiative, the Rio Declaration on Environment and Development adopted by more than 178 Governments at the United Nations Conference on Environment and Development (UNCED) held in Rio de Janeiro, Brazil, 3 to 14 June 1992.

Many of these earlier strategies and plans, including the recent 2016 to 2020 Edinburgh Adapts Plan, have addressed climate change adaptation to a greater or lesser extent.  It would have been helpful and instructive if this latest Draft Climate Ready Edinburgh Plan 2024-2030 had clearly illustrated how it intends to build on the success of previous adaptation  plans and initiatives and how it will work to rectify any past failures and so ensure  a positive and effective contribution to citywide adaptation going forward.

The Draft Climate Ready Edinburgh Plan 2024-2030 signposts to some other citywide strategies and plans that as relevant to climate adaptation. However, the city has many economic, social, and environmental strategies, plans and action plans which have some relevance to citywide climate adaptation. In view of this complex policy landscape, the draft Climate Ready Edinburgh Plan 2024 requires a much clearer indication of where  it sits in  relation the city’s policy hierarchy and what authority it has in relation to other approved plans. This must  include local and national land use planning policies and guidance that can serve as aa exchange for climate related mitigation, adaptation, and sustainable development objectives.  We agree, for  example, with RIBA’s an ICE’s recent policy position that demolition of existing building should not be allowed in all but the most extreme circumstances. This represents a considerable saving in terms of embedded carbon but may require careful and considered adaptation interventions thereafter to ensure climate resilience in retained buildings.

Edinburgh’s 2030 Climate Strategy,  which sets out a city-wide approach to reducing greenhouse gases in Edinburgh,  to deliver a net zero, climate ready city by 2030 is mentioned. However, it is important to note that mitigation initiatives aimed at reducing carbon emissions can also have additional climate resilience benefits. Mitigation and adaptation strategies should be complementary to maximise their climate change impact. Therefore, it is important that they are integrated to avoid wasteful and unnecessary policy conflicts and make the best use of all available resources.  More clarity on how the 2030 Climate Strategy and the Draft Climate Ready Edinburgh Plan 2024-2030 complement each other would be helpful.

As the IPCC made clear in a recent report: “Many adaptation and mitigation options can help address climate change, but no single option is sufficient by itself. Effective implementation depends on policies and cooperation at all scales and can be enhanced through integrated responses that link mitigation and adaptation.”

In addition, community-based climate activities have built momentum in relation to practical adaptation actions over an extended period.  The draft Climate Ready Edinburgh Plan 2024 should acknowledge this invaluable contribution to adapting Edinburgh to a changing climate. The Edinburgh Adapts Partnership has an opportunity to engage with and integrate into Edinburgh’s communities of place and of interest to ensure that community interest is at the heart of its decision making and governance processes.

Vision and Priorities

We are supportive of the Vision and Priorities identified in the Draft Climate Ready Edinburgh Plan 2024-2030.  In any case, these have generally  been embedded in many the city’s existing visions, strategies, and action plans  already. However, as previously indicated, although the draft plan signposts to some of the wider policy context in which the plan will operate, it fails to explain how exactly how this plan will be integrate with existing large and diverse range of relevant policies and related activities and whether it has any  authority within this large policy ecosystem. More importantly, it does not articulate what is new and value added in  the draft plan over and above initiatives which are committed elsewhere.

We believe that effective and meaningful monitoring and evaluation are key factors in achieving real climate adaptation and are critical to demonstrate effectiveness and accountability and the best use of resources.  We acknowledge that there are challenges associated with monitoring and evaluation of climate adaptation, related to the long timescales of climate change and its impacts. However, many of the actions listed in the Draft Climate Ready Edinburgh Plan 2024-2030 are clearly suitable  for short-term monitoring and evaluation. This deficit should be rectified before the draft plan is approved.

The Case for Adaptation and Climate Ready Edinburgh

These two sections provide a useful introduction to Edinburgh’s changing climate and  to what needs to be done to successfully adapt to these changes. However, both are too brief.  The Draft Climate Ready Edinburgh Plan 2024-2030 needs to articulate in a more inclusive way what the challenges of Edinburgh’s changing climate might look like. An obvious way to do this would be through the inclusion of case studies based on actual past events and through illustrative projections of what climate risk might look like on the ground across the city in the future.   This section should be a springboard for the rest of the plan and should set out a clear indicative illustration of the key features which Edinburgh should aspire to as a well-adapted city in the future. It simply fails to do this and requires a thorough reworking.

Climate Ready Edinburgh Action Plan and Implementation Plan

At first sight, these plans seem thorough and comprehensive. But a closer reading reveals many points of real concern which beg the question of how real, relevant, and meaningful the content of Action Plan and Implementation Plans is. Some of the proposed actions are so broad and nebulous that they are almost meaningless.

It must be acknowledged that many of the actions listed in Implementation Plan are of value. But an overarching lack of specificity means that almost any activity, large or small, could be counted as addressing the actions listed  here.  A SMART action plan incorporates 5 characteristics of a goal: specific, measurable, attainable, relevant, and time-based.  These characteristics are not comprehensively achieved in the draft.

We would like to see:

• Specific actions to increase the climate resilience of city-wide built heritage
• Greater clarity and urgency on what is being done to counter storm events and flooding
• More specific and tangible action to  the challenges of sea-level rise
• Specific interventions to address heat and storm event impacts on public transport, road, and active travel
• More pro-active action to secure a biodiversity-rich future environment for Edinburgh
• Pro-active selection of more suitable tree species to safeguard the city’s greenspace and streets
• Early engagement with the increased day-to-day maintenance burden of greenspaces, parks, and street trees
• Fuller articulation and stakeholder engagement on the impact of climate change on the local economy, both positive and negatively
• A much greater degree of participation by residents and other stakeholders at an early stage of the detailed design and implementation of the proposed actions
• An equal role for residents in the proposed review group and in the identification of key indicators of success
• Greater transparency on which actions are fully funded and committed
• Greater transparency on how the draft plan adds value to ongoing activities which are not directly driven by a climate adaptation agenda

Meaningful Monitoring and Evaluation

Monitoring and Evaluation is given a passing mention in the Draft Climate Ready Edinburgh Plan 2024-2030   but is essentially  absent.  A draft Monitoring and Evaluation process for comprehensively assessing the performance and effectiveness of the actions contain in the Draft Climate Ready Edinburgh Plan 2024-2030   should have been presented as part of the current consulting  . This process must  require  the collection and objective analysis of the plan’s activities, outputs, outcomes, and impacts to determine whether the desired results have been achieved.

Monitoring and Evaluation  is essential for ensuring that actions are effective, efficient, and accountable. By monitoring and evaluating the Draft Climate Ready Edinburgh Plan 2024-2030, the Edinburgh Adapts Partnership  and citywide stakeholders and funders can identify successes, challenges and failures and so make informed decisions to improve future  plans, outcomes, and impacts.

There is no need to delay the presentation of  Monitoring and Evaluation framework with key measures of success for Draft Climate Ready Edinburgh Plan 2024-2030. This work does not need to originated from scratch.  The largely generic content of the Draft Climate Ready Edinburgh Plan 2024-2030  means that similar plans with approved   Monitoring and Evaluation frameworks can readily form the basis of a suitable framework for the Edinburgh Adapts Partnership.  Presenting such a framework now, before the Draft Climate Ready Edinburgh Plan 2024-2030   is approved is highly desirable and will ensure timely monitoring of the plans process.

Role of Residents

We believe that residents need a much greater involvement in Draft Climate Ready Edinburgh Plan 2024-2030 at all levels, from governance to action on the ground. The plan and the Edinburgh Adapts Partnership should empower residents, communities, and business stakeholders  to identify climate impacts, and to discuss interventions to adapt to them. This will lead  to a better awareness of, engagement with  and preparedness for future climate change events across the city and help build a common understanding and ownership of climate adaptation plans and actions, which is key to their successful delivery. As the Draft Climate Ready Edinburgh Plan 2024-2030 is rolled out, inclusive community engagement should be supported. In part this might be achieved through an online community engagement platform to facilitate the review of ongoing actions and the working up of new actions. However, real world engagement is also required to access traditionally unheard voices and groups. “Think globally, act locally” was a core principle of Local Agenda 21 which aimed to inspire local authorities, their partners, and citizens to work towards sustainable development. The same principle is applicable to the Draft Climate Ready Edinburgh Plan 2024-2030.