Having considered the information provided in support of the final scheme and in particular the Council’s responses to the comments submitted by the various stakeholders, while the New Town and Broughton Community Council continues to support the principle of introducing a Low Emission Zone, we can no longer support the current proposals due to their adverse impact on residents.
Given that none of the issues that we highlighted in our previous consultation response submitted in September 2021 have been addressed to our satisfaction, we wish to largely resubmit those comments but also highlight our concerns about the consultation process.
Despite clear reasons for change, there is no evidence that the City of Edinburgh Council has seriously considered any of the issues that we (and others) raised about the current plans. Some of the issues (lack of effective enforcement) were completely ignored and others (displacement of traffic into predominantly residential areas) are dismissed on the basis that it is too difficult to make changes to the current arrangements.
This approach is contrary to the Scottish Government’s efforts to encourage community empowerment and their intent to introduce meaningful changes to reduce atmospheric emissions from traffic in Scotland’s four major cities.
We therefore object to the current scheme for the reasons set out below.
Following further discussion at the September NTBCC meeting on our response to the current consultation on the proposed city centre LEZ, we have now finalised our submission.
In summary, we are supportive of the introduction of a LEZ in Edinburgh but do not believe that the proposed scheme goes far enough both in terms of its geographical spread and in its ambitions to reduce pollution from vehicles. There are specific issues with some sections of the proposed boundary which we believe should be addressed before the LEZ is finalised. We are also concerned that the proposed enforcement regime will not be sufficient to ensure proper compliance.
We look forward to continued engagement in the development of the Low Emission Zone.
Please note that this consultation is open for comments from members of the public until 20 September 2021 – it can be accessed on the Council’s Consultation Hub here.
Below is the full text of our submission. A pdf version can also be downloaded here.
Response by New Town and Broughton Community Council to Edinburgh Council’s Consultation on Proposed Low Emission Zone
The New Town and Broughton Community Council (NTBCC) welcomes the Council’s plans to move forward with introducing a Low Emissions Zone (LEZ) in Edinburgh but we are concerned that the current proposals are not sufficiently ambitious and will have a serious detrimental impact for some residents, particularly those that live outside the boundaries of the currently proposed City Centre LEZ. We strongly believe that the boundaries of the LEZ should be increased in order to benefit a larger proportion of the residents of Edinburgh.
The area of the proposed LEZ currently covers only 2.5% of the City and excludes many areas of the City with the greatest density of residents. It will also not include the designated Town Centres and areas such as Broughton Street, which form such an important element in the development of 20-minute neighbourhoods outlined in the recently approved City Mobility Plan. In setting the boundaries of the LEZ, more consideration has been given to providing convenient diversionary routes for non-compliant vehicles than maximising the health benefits for people living in Edinburgh. Pollution levels have been considered on an absolute basis without any consideration of the number of people that will be exposed to that pollution. We are particularly concerned that there is no recognition of the risks to pedestrians from vehicular emissions in areas outside of the proposed LEZ; some of which have very high levels of walking including children walking to school.
There are three sections of the currently proposed boundary within the NTBCC area where we believe that further consideration is required before the plans are finalised – these are :