“Business Bulletin – Communal Bin Project” – NTBCC deputation to Transport & Environment Committee

The following written deputation was submitted to the Council’s Transport & Environment Committee on 27 January 2022 in response to an item contained within the Committee’s Business Bulletin which covered an update to the Communal Bin (Hub) Project and the £7.7m grant from Zero Waste Scotland’s Recycling Improvement Fund. 

The verbal deputation and discussion along with verbal deputations from Edinburgh World Heritage and the Cockburn Association, who supported the view of the community council, can also be viewed in the webcast of the meeting, starting at 5:45 minutes in.

(A note of caution – the full discussion on this topic runs for over an hour).  


Deputation to the Transport & Environment Committee meeting  : 27 January 2022 on item 6.1 Business Bulletin

Introduction

Since April 2021 when the City of Edinburgh Council (“the Council”) made its original decision to impose Communal Bin Hubs right across the New Town, the Council has refused to consult, engage or listen to the residents, their associations, Community Councils and Heritage Organisations.

The Business Bulletin before the Transport and Environment Committee today (“TEC”) is just another example where the Council has, again, failed to listen to experts or those affected by its decisions. Based on lengthy interactions with Edinburgh World Heritage (“EWH”) and Historic Environment Scotland (“HES”), the Council had an opportunity to re-think its extremely unpopular policy and consider some small mitigating suggestions. But it has failed to do so, ignored the advice of these Heritage Organisations and taken a “we know best” approach.

The Business Bulletin misrepresents facts and has not fully explained the Heritage Organisations’ views. The Committee does not even have the opportunity today to debate the minimal amendments proposed by EWH and HES.

The Council have been made aware of the very strong objections there are to the decision to abandon doorstep collection of Gull-proof bags and recycling boxes. A recent survey carried out by Angus Robertson MSP (and Cabinet Secretary for Constitution, External Affairs and Culture) shows that just over 90% of residents do not support the imposition of Communal Bin Hubs. This is supported by our own NTBCC online survey and a recent door-to-door poll on India Street. In addition, the Council’s ‘Information Events’ also demonstrated how opposed the New Town community is to these changes.

However, the Council continues to ignore those it represents.

Before dealing with the details of the Business Bulletin, it is important to remind the Committee, how it reached this current decision in April 2021.

  • There was no consultation or even engagement with residents, residents’ associations, and community councils.
  • There was no consultation or engagement with Heritage Organisations
  • The Council has not conducted any impact assessments, despite the view of experts that such assessment should be carried out. It continues to refuse to conduct such assessments despite requests from EWH and HES.

New Town residents support the Council’s ambition of greater recycling, cleaner streets and less pollution. However, the way the Committee is taking these decisions is both undemocratic and lacking in transparency. As the Council will know, only too well, effective decision making involves and does not exclude those that are affected by its decisions.

Committee members will have received last week, our ‘Five-Year plan for Waste Management’ (attached to this deputation). This aims to approach the matter of waste and recycling in an imaginative way and looks to best practice nationally and internationally. The NTBCC wish to work with the Council to develop a system that not only carries the support of the community but also looks for a long-term and sustainable solution that will not permanently scar the streetscape of this beautiful City.

As a consequence, we are urging the Committee to just take a step back, pause and consider the lasting impact its decision will have on the unique heritage of Edinburgh. Once imposed, the Council will not be able to reverse its decision or if it did – it would again cost millions of pounds. Millions of pounds of public money.

Impact on the World Heritage Site

The Council has repeatedly and publicly stated that it was working closely with EWH and HES to lessen the impact on the streetscape. However, we now learn that apart from a change to the tone of the colour of the bin lids, none of the suggestions proposed by the heritage bodies are to be considered further or even discussed. It is now clear that the roll out of the Communal Bin Hubs will not make any allowance for the existence of the internationally important World Heritage Site. The Council’s obligation to protecting (and where possible enhancing) the City’s World Heritage Status lies in tatters. In 2017, the Council committed to a duty of care to the World Heritage site and conservation areas when it signed the current five-year management plan. It appears that the Council is failing in its duty.

The Committee should be reminded of the words of those Heritage Organisations, which are charged with protecting Edinburgh World Heritage status:

Edinburgh World Heritage says:

It is worth stating that any major decisions concerning changes to services in local areas should be taken with the consent of the community. While this may not be a statutory obligation in the case of waste disposal, we believe that moving forward without the support of local people and community groups would set an unfortunate precedent for the future.

…we are concerned that the current plan to locate numerous new bin hubs across the New Town represents a threat to the visual integrity of the New Town. Adding street clutter will negatively alter the character of our Georgian terraces. An Environmental Impact Assessment is being considered, which we believe is required.

Historic Environment Scotland states:

It is our view that the proposed roll-out of bin hubs throughout the World Heritage Site has the potential to have a significant impact, particularly within the carefully planned and consistent classical streets within the New Town

A one-size-fits-all strategy for the wider city, which includes the World Heritage Site will mean that a series of bin hubs will be sited on streets currently without any visible waste collection.

The introduction of standard designed bin hubs in these streets will have a negative visual impact on this part of the World Heritage Site and we would welcome an alternative approach.

Business Bulletin

Turning to the specifics of the Business Bulletin.

Engagement

The Business Bulletin boasts of the number of engagements it has undertaken. However, it significantly underplays the strength of feeling it received at these meetings and the extent to which it has just ignored the views of the Heritage Organisations.  For example, the Bulletin refers to 300 people attending the information events and expressing their views. As a matter of fact, there were many more than who attended these sessions but due the number of officials at each and the limitations of the selected venues only a small proportion were able to record their views. The Council’s own data (obtained by a freedom of information request) shows that the significant majority of those who did express an opinion were opposed to the current plans. This is consistent with all other surveys that have been conducted and referred to above.

The Bulletin refers to its “detailed discussions” with EWH and HES “to look at mitigating measures to reduce the impact of the bins in the Edinburgh World Heritage”. However, the report gives the misleading impression that while it accepts some, it has rejected others. The team has rejected every single measure put forward by EWH and HES with the exception of changing “the tone of the green lids”. After hours of discussion, with serious concern shown by these statutory organisations whose remit, among other things, is to protect Edinburgh’s World Heritage status and Outstanding Universal Value, the team believes the only improvement that should be made is to make the tone of green lids different.

Equalities Matters

The Bulletin implies concern from the Edinburgh Access Panel and Living Streets Edinburgh to some of the suggested mitigations. We understand the concerns about people with impaired vision having to cross the street to put their waste into a bin but believe that there should be a balanced consideration of the changes. At present people with impaired mobility or vision can place their waste and recycling outside their door for collection – this is surely significantly better than having to take the waste to a Communal Bin Hub. If the proposals are accepted, they will now need to carry their waste to the nearest hub, which could be 100m away from their home and then place it in the bin. Surely the least risk solution is to maintain kerb side collection for as many people as possible. It should be noted that there has still been no equalities assessment been undertaken about the loss of kerb side collection.

The Bulletin states that there cannot be an approach to placing the Communal Bin Hubs on “the garden side/other side of the street” since in the majority of the locations this is not supported by the “agreed parameters” and criteria to site bins across the City. But it is the Council who created these “agreed parameters” and criteria and it must be flexible to preserve the streetscape. No evidence has been provided to support the view that putting the bins on the garden side of the road on a limited number of streets will expose residents to any significant risk.

Pavement Clutter

With regard to the issues of additional pavement clutter caused by the recycling boxes, it should be noted that all 130,000 households that have kerb side collection are putting their waste on to the pavement outside their home for collection. Although we fully support the unnecessary cluttering of our pavements, it is not reasonable to remove everything from the pavement. There is no evidence in this Business Bulletin of eg how many accidents have been caused by Gull-proof bags (hanging from railings) on the pavements on those streets that have kerbside collection.

The recycling boxes and food waste bins in the New Town are generally on the street for a matter of few hours every week. Again, eliminating this short term use of the pavements should be balanced against the need to carry waste to the nearest communal bin where that waste will be stored for a number of days until collected and adds to the street clutter.

It should be noted that residents in the New Town – those affected by these decisions, remain completely in the dark, about all the locations the Council expect to place these Communal Bin Hubs. This is one of the most crucial pieces of information, and yet at the ‘Information Events’ – there was no information given. This is another example where residents and residents’ associations have been kept away from the process and unable to have any meaningful impact.

Zero Waste Hierarchy

The decision of the TEC at its 14 October 2021 meeting that residents should be supported to adopt a zero waste hierarchy has never been explained despite requests for clarification. We now learn that this will be met by including information on waste reduction and re-use in the planned communication campaign. This is an extremely disappointing outcome given the willingness of New Town residents to work with the Council to improve recycling and introduce sustainable waste management arrangements that minimise the impact on the streetscape of the World Heritage site. The Council needs to work more pro-actively with residents to fulfil these goals.

Conclusions

The NTBCC has looked to engage positively with the Council at every opportunity. But it is continually rebutted. The Committee refuses to consider ANY amendments to its policy – even when they are proposed by expert organisations such EWH and HES. It is now clear from numerous surveys that 90% of residents oppose the replacement of kerbside collection with Communal Bin Hubs.

The Council’s own mock-ups of these Bin Hubs show how overbearing and obtrusive they will be. They will permanently scar the Edinburgh streetscape and the Committee’s unwillingness to consider even the smallest of amendments demonstrates how it appears to be unable to listen and consider other points of views.

We would like the Committee to consider the following questions with respect to its Communal Bin Hub policy:

  • Will it achieve the stated goals of improving recycling and reducing safety risks?
  • Why has no heritage or environmental impact assessment been undertaken?
  • Why has there been no meaningful consultation?
  • Why does the Council continue to ignore the views of its residents and heritage organisations?
  • Why have not all aspects of the project been subjected to equalities assessment?
  • Are we managing our World Heritage site in accordance with our commitments to UNESCO and the commitment the Council undertook in 2017?
  • Is this plan the best value for money?

We urge the Committee to take a moment, pause and consider other alternatives. Not for just the sake of the residents it serves but also for the heritage of this City, before it is irrevocably damaged.

Carol Nimmo

Chair – NTBCC