Category Archives: Consultation Response

General response to various cycle schemes under ‘spaces for people’

This is a general response to the various cycle schemes advertised under the ‘spaces for people’ initiative (eg Wester Hailes Road, Ferry Road, Comiston Road, etc).

We support improvements to cycling infrastructure which encourages cycling and reduces motor traffic, so long as it is not detrimental to the actual and potential walking environment. Organisations like Spokes have rightly been very clear that new space for cycling must come from space for motor vehicles, rather than for walking. We therefore wish to record our support for the overall programme. However, we have two significant qualifications.

Pedestrian improvements

It is hard to see *any* improvements for people walking in these schemes? While general pavement widening may be difficult to achieve simultaneously with installation of cycle lanes, this should be a priority where pavements are especially narrow (eg south side of Ferry Road). We would expect to see at least significant efforts to remove pavement clutter such as signage poles and guard rails and simple measures such as cutting back hedges, sweeps of roadworks debris (traffic cones, sandbags, etc.) We also want to priority for pedestrians increased at all signalled junctions. Given that almost everyone is a pedestrian in their own neighbourhood, such measures are also likely to increase local support for these schemes, including among people who don’t cycle.

Floating Bus stops

We note that there are dozens of ‘bus stop bypasses’ or ‘floating bus stops’ proposed in these cycle schemes, which route cyclists between the bus stop and the pavement, rather than on the road. There appear to be at least: 13 on Comiston Road, 10 on Ferry Road, 9 in Wester Hailes, 7 on Meadow Place Road and 5 on Fountainbridge.

As the Council’s Active Travel team is well aware, the Living Streets Edinburgh Group has never been happy with this design concept which means that bus passengers boarding – and especially alighting from – buses have to cross a cycle way and may therefore unexpectedly encounter a cyclist, possibly travelling at considerable speed. While we recognise the benefits for cyclists, this design can only disadvantage bus users and pedestrians, especially older people and blind people, many of whose representative organisations have objected to the design concept.

Living Streets Edinburgh did not object to the first Leith Walk examples, on the understanding that a full monitoring and evaluation was carried out. The Council eventually agreed to this in 2017 but although we understand that this exercise has long been completed, it has never been published. It is wholly inappropriate to use the Covid19 pandemic and ‘spaces for everyone’ programme as the means for the sudden mass installation of these controversial bus stop designs at virtually no notice and with minimal consultation.

We therefore strongly oppose their inclusion in the Council’s current proposals. We suggest that instead, a much wider review exercise is taken at a later date, to consider the use of floating bus stops in the city strategically, once evaluation evidence is in the public domain. This should involve all relevant interests – walking, cycling, bus passengers, disability groups, etc.

Shopping Streets – LSE response to Edinburgh Council

Thank you for the opportunity to comment on the various schemes to widen pavements in shopping streets (eg Corstorphine, Portobello, Morningside etc). This is a general response to all these schemes, although where we are able to, we will add supplementary comments on specific streets/locations.

First of all, we strongly support the initiative to widen pavements, which in many ‘town centre’ streets are grossly inadequate. This can only be done in many cases by removing on-street parking and loading, except for essential requirements (such as Blue Badge spaces where appropriate). We appreciate that some shops will want to see these parking and loading spaces retained, but crowded narrow pavements cannot possibly be an attractive environment for encouraging shoppers, may of whom arrive on foot or by public transport. Too much space in high streets is occupied by stationary vehicles.

We welcome the acknowledgment of the problems caused by clutter and guard rails and would encourage the council to take a much more vigorous approach to removing or relocating items including unnecessary phone boxes, royal mail boxes, telecoms cabinets etc as well as vertical signage on poles, many of which are no longer required since the Traffic Sign Regulations were changed in 2016.  Decluttering should take account of the various surveys and audits which Living Streets and others have carried out in recent years in many of the locations.

Design details will need to carefully consider and monitor access at bus stops especially for disabled people. We generally support bus priority measures including bus gates.

Where more outdoor space for businesses is provided (eg ‘tables and chairs’) it is essential that adequate clear space is provided for pedestrians and that the benefits to walking of widened footways are not swallowed up by added obstructions. It may be that ‘tables and chairs’ should normally be on reclaimed carriageway space, allowing the pavements themselves to be kept clear.

While we appreciate that these are temporary measures which need to be installed urgently, the extensive use of cones, barriers etc will make many streets look like roadworks, and thus risk making shopping streets look pretty ugly – if we actually want them to contribute to moving discussion forward it’s important that opportunities are taken to make things look better. Suitable gateway features / signage information for the public on the purpose / benefits of the scheme would be useful.

Effective management of schemes is essential, so that cones or barriers that fall over are quickly dealt with. Enforcement of parking and speeding, including a visible role of Police Scotland is important too.

Temporary bike parking should be installed at suitable locations, where they do not add to pavement clutter.

Monitoring of schemes must collect robust data on walking/footfall.

Promoting walking during social distancing (supplementary paper)

1) Introduction

This paper supplements the ‘5 Point Plan’ we produced on 7 May 2020, outlining steps we’d like to see to make walking attractive, safe and accessible during the Coronavrus crisis and its aftermath. It should be read in conjunction with that Plan: http://www.livingstreetsedinburgh.org.uk/2020/05/09/a-5-point-plan-for-city-of-edinburgh-council-to-promote-walking-during-social-distancing/

We want to see early implementation of the measures outlined in the Council Report and amendment approved on 14 May, especially those which focus most on walking improvements: widening pavements, improving crossings, etc https://democracy.edinburgh.gov.uk/ieListDocuments.aspx?CId=135&MId=5511&Ver=4.

This paper adds to the suggestions in the ‘5 Point Plan’ following further feedback and highlights some specific locations we’d like to see given early and urgent attention to. Living Streets Edinburgh Group is keen to contribute ideas on how Edinburgh should respond, in line with council decisions of 14 May.

2) Pavement Widening

In addition to those already suggested, we want to see consideration given to widening pavements in all of Edinburgh’s ‘town centres’. These are now experiencing queuing on pavements as more shops open and often leave insufficient space for people walking.  Key public transport routes (notably at Waverley and Haymarket) should also be given priority. Other streets which should be widened include Broughton Street and Balgreen Rpad.

3) Road closures

Our ‘five point plan’ suggested closing many residential roads through barriers (‘filters’, which allow people to walk or cycle through) – rather than by banning motor traffic completely, (as at Silverknowes Road, Braid Road etc).  We would like to see a response to this suggestion which could transform many neighbourhoods.

We don’t support the plan to close Viewforth (canal section) to motor traffic, owing to the impact this will have on Yeaman Place, a busy pedestrian street (outside of school times) which is full or parked cars and lacking in any kind of pedestrian crossing facilities. We would prefer to see Yeaman Place itself closed; or at least with mitigation measures such as formal pedestrian crossings introduced.

We want to see the council to show some urgency re-opening the established right of way at Holy Corner, Bruntsfield/Morningside (McLaren’s pub, the former Bank of Scotland).  Signature pubs have illegally blocked this Right of Way for over six months and yet the council has taken no enforcement action, despite the added need for social distancing on the busy, narrow pavement.

4) Guardrails

We welcome the council’s plans to start removing some guardrails as part of temporary cycle schemes (such as Crewe Road South, Old Dalkeith Road). Guardrail removal should not be solely as part of cycle schemes but should also be undertaken where it has particularly adverse impacts on walking.  There are numerous suggestions for guardrail removal in the ‘Tackling Pavement Clutter’ reports sent to Locality Roads Managers in 2019. Other specific locations we want to see guardrails removed are:

  • Morrison Street / Gardners Cres (with associated widened footway). Also north side of Morrison Street, east of Dewar Place.
  • Slateford Road between Ashley Terrace and Robertson Ave (with associated widened footway).
  • Roseburn Street under rail bridge (with associated widened footway).
  • Murrayburn Road (West of Hailsland Road).
  • Polwarth (at roundabout).
  • Colinton Mains Road (at Tesco roundabout)
  • West Port (North side).

5) Enforcement

Many LS supporters have asked for more enforcement of traffic laws, especially speeding (a police matter). Parking enforcement is also going to become even more important to ensure that temporary pavements and cycle lanes are not compromised by illegal parking, loading or waiting. We suggest that a zero tolerance approach is take to such infringements (ie removing any ‘grace period’) so that motorists quickly understand that new traffic restrictions will be enforced rigorously.

In some areas, traffic calming should be introduced. In recent years, there has been too little focus on engineering measures to support compliance with speed limits and we would like to see measures introduced in speeding problem areas.

6) Schools

Although it appears that schools will not generally begin to open until mid-August, we want to see early planning for school re-opening. Measures that should be considered include:

  • extension of the Council’s ‘School Streets’ initiative to ban cars from near the entrances to more schools;
  • engagement with Police Scotland to ensure that a degree of police presence is available to achieve effective enforcement of traffic laws;
  • very clear and early messaging to parents encouraging children to walk, scoot, wheel or cycle. Car drop-off’s should be explicitly discouraged, and not permitted in the vicinity of school gates.

7) Other measures

We have not yet seen any response to our request for removal of street clutter as a ‘quick win’ to aid walking and social distancing. As with guardrails the Council already has a policy of de-cluttering which should be accelerated at the present time.

We want to see public campaigns by the council asking residents to cut back hedges which block pavements and are illegal. Many residents probably do not realise this, or the problems that encroaching vegetation can cause. The council should also take enforcement measures itself, recovering costs where voluntary compliance cannot be achieved.  Due regard should be given to protecting wildlife and nesting birds in particular.

We want to see urgent improvements for people to cross the road, especially in reducing ‘wait times’ for the green man. We look forward to seeing a list of locations where these will be trialled as soon as possible.

Choices for City Plan 2030 – LSE Comments

Introduction

Living Streets Edinburgh Group (LSEG) is the local voluntary arm of the national charity, Living Streets, which campaigns for better conditions for ‘everyday walking’. In LSEG our key aim is to promote walking (including “wheeling” (on wheelchairs) and similar pedestrian mobility) as a safe, easy and enjoyable way of getting around the city.

For LSEG the focus for City Plan 2030 has to be delivering for people.  The purpose of planning is to manage the development and use of land in the long-term public interest, which is commonly accepted as being the welfare or well-being of the general public.  In other words, to provide for people, a species designed to walk on 2 legs, it is our default mode of transport.  Walking is by far the most common and universal travel mode, forming an essential part of many journey chains by bus, train, car, bike etc, as well as ‘walk-only’ journeys.

Yet we have a planning system that for too long has bent over backwards to prioritise and accommodate motorized transport, principally the private car.  Finally, this is now widely accepted as not being in the long-term public interest.    So there is an opportunity for City Plan 2030 to press the reset button and actually plan for the long-term public interest, putting people first.

As well as reversing a longstanding failure of planning as a discipline, this will actually result in a local development plan that complies with Scottish Government policy.   Walking is unambiguously top of both the ‘movement hierarchy’ as laid down in Scottish Planning Policy i and the ‘Sustainable Travel Hierarchy’ in the new National Transport Strategy 2ii. However, while lip service is often paid to the theoretical primacy of walking, it is rarely put into practice and when there is mention, walking is often conflated with cycling.

Despite being Scottish Government policy, Choices for City Plan 2030 regrettably makes no mention whatsoever of the movement hierarchy or the Sustainable Travel Hierarchy – this is an unforgiveable omission, which, unless addressed, must bring into question the Council’s commitment to everyday walking and adherence to national policy.

City Plan 2030 must work in tandem with the City Mobility Plan and deliver the principles of the movement hierarchy across the whole city applying them to established streets and places as well as new developments.  Successful places are those which work for people, not just vehicles, so comprehensive delivery is required across the city to get an integrated package working for the whole community, not only those in new developments.  This is critical in order to address the past failure of the planning system.

The consultation started before the current emergency, so in preparing City Plan 2030 it would be an abdication of responsibility for the Council not to take account of relevant lessons learnt.  It has been demonstrated that many jobs can be carried out from home, it is therefore perfectly feasible that employers may build on this experience and change working patterns as there will be cost savings, enhanced efficiency and, as a by-product, less pressure on transport infrastructure.  It is abundantly obvious to all that current traffic reduction has meant the streets have been more pleasant places to inhabit and this, combined with the likelihood of long term social distancing requirements, means that more space is needed for walking.  It is therefore beholden on the Council to grasp reality, to actively encourage far more home working, to reconsider where new housing should be located, to seriously restrict private vehicle movements and to invest much more in walking and public transport infrastructure.  There may also be reduced demand for new office space and the possibility that some existing office space could be converted to housing or other suitable community uses.  All of this has to be carefully considered and assumptions re-evaluated.  Living Streets Edinburgh Group would like to be part of this process.

 

Detailed Comments

Introduction

p3 – Support the 4 aims for 2030, particularly “a sustainable city” and “a city where you don’t need a car to move around”, but this obviously requires the services, infrastructure, development locations and quality of environment to allow it to happen.  The Choices for City Plan 2030

p5  – Generally support the choices under the aims, but need to go much further:

  • 1 should be revised to “Making Edinburgh a sustainable, active and connected city based firmly on the movement hierarchy as set out in para 273 of Scottish Planning Policy”.
  • 2 should be revised to “Improving the quality, density and accessibility of development and ensuring that all new development in the city centre is car free apart from essential parking provision for disabled, visitors and car clubs. This policy shall apply across the whole city by the end of the plan period.
  • 6 should be revised to “Creating places and enhancing existing streets and places to focus on people not cars”.
  • 7 should be revised to “Supporting the reduction in car use in Edinburgh to those which are essential”.
  • 8 should be revised to “Delivering new walking and cycling routes and enhancing existing streets and paths to ensure that walking has priority”.
  • 12 should be revised to “Building our new homes and infrastructure in locations and with layouts where walking is the most viable means of movement, including good routes to a variety of public transport options.

 

Choice 2 – Improving the quality, density and accessibility of development

p9  – Support the thrust of the changes, strongly agree with increased density objective in “B”, but “A” should include specific reference to car free developments and “C” should refer to the movement hierarchy in para 273 of Scottish Planning Policy as well as the six qualities of successful places.

A city where you don’t need to own a car to move around

p13 – Strongly support the objective, but if it is intended that you don’t need a car to move around, then there should be specific reference that new developments will be car free and no provision made for parking other than disabled, servicing and essential visitors.

Choice 5 – Delivering Community Infrastructure

p15/16 – Transport Infrastructure section should make it clear that infrastructure will be provided in line with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.  Whilst specific walking routes are welcome, there also has to be reference to improvements to the fabric and management of all streets in the city, new and existing, to accommodate walking as the priority means of movement.  Within this context “A” should have specific reference to walking infrastructure.

Choice 6 – Creating places that focus on people, not cars

p18 – Strongly support Choice 6 Creating places that focus on people, not cars.  In the supporting text there has to be specific reference to the movement hierarchy in Scottish Planning Policy and the National Transport Strategy, with the movement hierarchy set out in the correct order of priority with walking first.  There should also be reference to enhancing established places across the city to reflect the same priorities so that benefits will be enjoyed by the entire community, not just those in new developments.  The target referred to in “A” should be zero car use other than provision for disabled, servicing and essential visitors.  If new development cannot deliver this, then it should not be permitted. Within this context “B” needs to be reworded to delete reference to appropriate parking levels, you must not use phrases that allow wriggle room for either developers or decision makers.

Choice 7 – Supporting the reduction in car use in Edinburgh

p19 – Support Choice 7 but it has to be strengthened so suggest rewording it to read “Help to deliver significant reduction in car use in Edinburgh”.  Proposed changes “A”, “B” and “C” require revision to make it clear that there will be no provision in any development for car parking other than for disabled, servicing and essential visitors. This must be in tandem with phasing out of on street parking across the city.  A start should be made by defining a central area car-free zone, within which no new residential parking permits wold be issued.

Choice 8 – Delivering new walking and cycling routes

p21 – Support Choice 8, but it has to be strengthened so suggest rewording it to read “Delivering new walking and cycling routes and enhancing existing provision for walking throughout the city”.  The Plan needs to recognise that for most people on foot, their “walking network” consists of the pavements around their home, place of work or education.  The emphasis on new cycle routes is disproportionate and “delivering new walking and cycle routes” is much less important than improving existing ones: this means improving pavements, widening them, more road crossings, traffic calming, etc. S75 opportunities.  In recognition of the importance of everyday walking this should be reflected in the proposed changes and there should be specific reference to the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.

It is appreciated that the provision and enhancement of walking infrastructure has a cost attached.  This should be secured via revisions to the Council’s policy and guidance on developer contributions.  The existing supplementary guidance ignores walking, contrary to the Scottish Government hierarchy.  Delivery of Choices 6, 7 and 8 will require significant investment which must come from developers as part of individual developments and/or via developer contributions in Section 75 Planning Obligations.  Higher density developments with less car parking and fewer contributions towards traditional road schemes will assist with delivery for walking.

Choice 10 – Creating sustainable communities

p26 – Revise para 3 in text box to read “reduce the amount and type of student housing…”

Choice 12 – Building our new homes and infrastructure

p28 – Point “C” in the text box under Choice 12 should be revised to read Where we will deliver the homes in the most sustainable way to conform with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy”.

p30– Strongly support the Council in preferring Option1 Delivery within the Urban Area as it is the only option that can provide for walking in accordance with the movement hierarchy as well as helping to deliver on wider sustainability objectives.

p31 – Having set out its preferred Option, it is disappointing that the Council chooses to focus on the difficulties in delivering it, rather than the benefits that will accrue if it is delivered.  Delivery in accordance with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy is only possible with this Option.  Any other option will fail to comply with Scottish Planning Policy.  The Council must embrace the same spirit that lies behind the City Centre Transformation project, and be resolute, bold and focused beyond the short term.

p32 – If the Council pursues car free developments and is imaginative with design, layout and density, the available space will generate more than the 17600 new housing units quoted.

p35-46 – The options set out in Maps 9-14 and supporting text will fail to deliver in accordance with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy, and most certainly lead to an increase in car use which is contrary to national planning policy and the stated thrust of the City Plan process.

Choice 15 – Protecting our City Centre, Town and Local Centres

p54 – Fully support Choice 15 and note reference to active travel and walking distance with regard to new shops outwith centres.  However, the best way of protecting our existing centres is to acknowledge that they are primarily places for people, so policy has to be led by the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.  Is there evidence to support the new hotel provision proposed in “E” given the identified need for more permanent housing?  There is a need for more city centre homes as well as more housing across the city and the increased density proposals will help to deliver this, but it has to be prioritised over hotel and Air BnB type provision.  The proposed changes need to be reworded to reflect this and introduce proposals for established centres to prioritise people and walking.

Choice 16 – Delivering Office, Business and Industry Floorspace

p56 & 59 – Choice 16 should make it clear that office, business and industry floorspace will only be provided in locations where it can be easily accessed by public transport and where there is good infrastructure for walking and cycling.  It should be made clear that onsite parking will be restricted to that required for disabled, servicing and essential visitors.  In addition to minimising vehicle movements, this will allow more efficient use of land and free up space for enhanced green infrastructure.  As stated in our initial comments, there also has to be recognition that more provision should be made for homeworking, in new and existing housing – perhaps one positive to come out of the current COVID-19 crisis.

The plan should make provision for developing a new role for out of town retail and parking, through conversion to higher density, mixed used (especially residential) focused around public transport interchange hubs.

 

Living Streets Edinburgh Group

April 2020

 

Notes/references

i Paragraph 273 of Scottish Planning Policy (2014) states: ‘The spatial strategies set out in plans should support development in locations that allow walkable access to local amenities and are also accessible by cycling and public transport. Plans should identify active travel networks and promote opportunities for travel by more sustainable modes in the following order of priority: walking, cycling, public transport, cars. The aim is to promote development which maximises the extent to which its travel demands are met first through walking, then cycling, then public transport and finally through use of private cars. Plans should facilitate integration between transport modes.’ https://www.gov.scot/publications/scottish-planning- policy/

ii The 2020 National Transport Strategy 2 (NTS2) places walking at the top of the ’Sustainable Travel Hierarchy’, followed by cycling, public transport, taxis and shared transport and the private car. https://www.transport.gov.scot/media/47052/national-transport-strategy.pdf

 

Draft City Mobility Plan: comments by Living Streets Edinburgh

Living Streets Edinburgh Group (LSEG) is the local voluntary arm of the national charity, Living Streets, which campaigns for better conditions for ‘everyday walking’. In LSEG our key aim is to promote walking (including “wheeling” (on wheelchairs) and similar pedestrian mobility) as a safe, easy and enjoyable way of getting around the city.

Walking is unambiguously top of both the ‘movement hierarchy’ as laid down in Scottish Planning Policy and the ‘Sustainable Travel Hierarchy’ in the new National Transport Strategy. However, while lip service is often paid to the theoretical primacy of walking, it is rarely put into practice. For Living Streets Edinburgh the principal aim of the City Mobility Plan should be to ensure that walking priority is delivered on the streets. Regrettably, the draft plan makes no mention whatsoever of the movement hierarchy or the Sustainable Travel Hierarchy – this is an unforgiveable omission, which must bring into question the Council’s commitment to everyday walking.

Walking is also by far the most common and universal travel mode, forming an essential part of many journey chains by bus, train, car, bike etc, as well as ‘walk-only’ journeys – and therefore is drastically under-reported in many official statistics which focus only on ‘main mode’.

 

We welcome the vision of making Edinburgh far less dependent on motor vehicles and to make streets much more people-friendly. We also commend the Council for its leadership in starting and pursuing the public debate about future mobility in the city, as we cannot go on as we are.

However, the Draft City Mobility Plan appears to be more a statement of largely welcome intentions, rather than a delivery plan. It does not indicate the resources, capacity and skills needed to deliver it, or how these will be acquired.

The Plan does not give sufficient emphasis to the need to promote ‘everyday walking’ by improving pedestrian infrastructure across Edinburgh – in the centre, in ‘town centres’ across the city, and in residential areas. The Plan is misguided in its ill-thought-out approach to buses.

We would like to see the final Plan, to be approved by the Council later this year, take account of our comments, and to focus much more on practical measures, such as widening pavements and enforcing traffic and parking rules, and less on aspirational but wooly visions.

 

You can read the full response here – Living Streets Edinburgh response to Draft City Mobility Plan