As submitted today in response to the Edinburgh Airport’s proposed new access road:
Planning application 21/00217/FUL – Formation of new access road and active travel route from east of terminal building to Gogar Roundabout
This objection is on behalf of Transform Scotland, the national alliance for sustainable transport. We campaign for walking, cycling and public transport to be the easiest and most affordable options for everyone. Our diverse membership brings together public, private and third sector organisations from across Scotland. We are politically independent and strictly science-based; we are a registered Scottish Charity (SC041516) and Company (SC181648).
We have carefully studied the application and the report on the environmental impact assessment.
As an organisation concerned with climate change and sustainable transport, we will specifically address those two related issues. For the purpose of this submission, we will set aside the major issues relating to aviation as a source of increasing climate emissions and focus specifically on the environmental issues raised by proposed road itself.
As regards the planning application, we object to it on following grounds:
1. The proposal is contrary to the relevant national, regional and local policy
All planning policies contain within them competing and contradictory objectives, but this application is clearly at odds with the following:
(i) National Transport Strategy 2 (2020)
The National Transport Strategy 2 sets the vision for Scotland’s transport system for the next 20 years as ‘a sustainable, inclusive, safe and accessible transport system, helping deliver a healthier, fairer and more prosperous Scotland for communities, businesses and visitors.’ Its four priorities in support of that vision include ‘take climate action’.
(ii) SEStran Regional Transport Strategy (RTS) Refresh (2015)
The RTS objectives include ‘promote sustainable travel’ and in particular ‘reduce the need of the car’.
(iii) City of Edinburgh City Mobility Plan (2021)
The City Mobility Plan stresses the critical importance of the global climate emergency and Edinburgh’s ambitious commitment to work towards net zero emissions by 2030.
It specifically recognises that transport is one of the biggest causes of carbon emissions. It further notes that in Scotland over 37% of carbon emissions are accounted for by transport. Road transport accounts for 68.1% of total transport emissions and that unlike most sources, where carbon emissions are reducing, those from transport, particularly road transport, have been increasing. It states that ‘[i]f carbon emissions are not significantly and rapidly reduced, climate change will, at best, cause severe disruption and significant cost for future generation for decades, if not centuries to come. Revolutionising how we move people, goods and services around places is essential to achieve this.’
(iv) Edinburgh Local Development Plan (LDP) (2016)
Although the LDP makes provision for some new roads, it does so in limited circumstances and stresses the need to reduce reliance on travel by private car and help meet climate change targets and sustainable development objectives.
2. Unsubstantiated assumptions and reputed benefits
The justification for the application makes certain broad and unsubstantiated assumptions as to increased air traffic levels in future years and thus the need for, and desirability of, the proposed access road to the airport.
It is stated that ‘[r]ecent figures for Edinburgh Airport, anticipate an increase from 13.4 million in 2017 to 17 million in 2022 and 21.2million in 2023. Due to the Covid19 pandemic, there has been a significant drop in passenger numbers over the last 9 months and therefore, currently levels are significantly different than what was expected. It is unclear what the near future holds, however, Edinburgh Airport are expecting that their passenger numbers will return to pre-pandemic levels within 3 years and growth in the medium to long term will be as anticipated’.
However, these figures are purely speculative and take no account of the very likely changes in travel patterns post-Covid as well as stronger national and international action to tackle the accelerating climate crisis.
The Edinburgh Airport Masterplan identifies the requirement for the new eastern access road by 2025 with its purpose being to reduce congestion and increase access resilience. However, there is a wealth of evidence to show that such a ‘predict-and-provide’ approach will ultimately lead to an increase in overall traffic levels and thus be ineffective in the long run. It is also worth noting that an increase in road capacity will increase competition with sustainable forms of transport to the detriment of the latter.
Some of the benefits put forward are also rather tenuous, such as the idea that less traffic on the A8 ‘may’ create a road environment which is ultimately less intimidating for pedestrians and cyclists and may even encourage higher levels of active travel use in the longer term and that a Significant Moderate Beneficial effect in terms of driver delay at the A8 Glasgow Road. ‘Driver delay’, in particular, plays no role in the City of Edinburgh Council’s policies or transport hierarchy and should not be regarded as relevant.
Equally lacking in strength is the argument that the delivery of the proposed development would enhance sustainable transport access to Edinburgh Airport, and more generally in the West Edinburgh area, since the design incorporates a segregated off-road shared use path for active travel and would also deliver potential journey time benefits for bus services. Firstly, it is entirely unreasonable to assume that large numbers of people will make their way to and from the airport by active travel and, secondly, the new access is not reserved to buses, which will have to operate in general traffic, often congested, traffic.
Much of the evaluation is written solely from the perspective of private vehicle traffic as the default mode of transport, which is prioritised to the cost of other modes of transport.
3. Alternatives already exist
Adequate public transport provision already exists with regular high-capacity tram and buses services and transfers to and from the nearby Edinburgh Gateway, which was built at significant cost and whose use is well under capacity. More frequent tram services, further expansion of dedicated bus lanes and a reduction, rather than an increase in private road traffic are all viable, more sustainable alternatives.
Of the options listed ‘No Development’ is the most appropriate. It is stated that in this case ‘[s]ome potential adverse effects associated with the proposed development would not occur. However, a number of beneficial effects of the proposed development would not come forward, primarily in relation to transport and access and the requirement of an increasing road capacity in order to support both Edinburgh Airport and that of West Edinburgh’. This argument is based on the erroneous premise that increased traffic levels are inevitable, rather than created, and that no alternative solutions are available.
Similarly, it is contended that ‘currently, the only way to reach Edinburgh Airport is by travelling along the A8 Glasgow Road then turning off onto Eastfield Road towards the airport itself’ and ‘[i]t is estimated that up to 54% of all airport-bound traffic may choose to use the new EAR once operational and will allow users to avoid what is currently a busy and congested stretch of the A8 during peak times.’ Again, the assumptions are based on the car being the default, priority means of transport, which is not a logical conclusion, but rather a clear choice.
4. The Climate Change imperative
Finally, the most significant argument against this proposal is the climate crisis and the way in which proposals such as this contribute to a cumulative increase in emissions at the very time when a drastic reduction is necessary. It is an established fact that there has been a failure to reduce emissions in transport over the last 30 years and this proposal, if implemented, will simply add to the problem. This realisation has led the Scottish Parliament to declare a climate emergency and pledge to lead by example by cutting carbon emissions and the City of Edinburgh Council to commit to becoming carbon neutral by 2030. These commitments need to be met by practical action if they are to have any genuine meaning and effect.
Consequently, Transform Scotland formally objects to this application on the grounds that is contrary to existing national, regional and Council policy, is based on unsubstantiated assumptions and reputed benefits, is not without viable, practical and less detrimental alternatives, and merely adds carbon emissions to an already very carbon-intense activity.