Tag Archives: City Centre Transformation

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

 

Response to Edinburgh City Centre Transformation Strategy Consultation

  1. Introduction

1.1      Living Streets Edinburgh Group welcomes the publication and consultation on the Edinburgh City Centre Transformation Strategy.   We would like to thank the Council for its leadership in bringing this forward and the bold nature of the vision, which has the potential to transform the walking environment.

1.2      We have taken the opportunity to respond to the consultation under the following headings:

  • General comments on the Strategy;
  • Need for City-wide Transformation;
  • Detailed Comments on the Strategy.

1.3      We are happy to meet with Council staff and Jacobs to explain and expand on our comments.   We would also like to be involved in the preparation of the final strategy and the detailed design process for individual elements within it.

 

  1. General Comments on the Strategy

2.1      Walking (with or without an aid) is something we all have in common; at some point we have to get out of the car, off the bus or off the bike and walk.  Despite this we have, as a city, long accepted and planned for the private car as the dominant transport mode. A strategy that reverses this, puts people first and gives priority to travelling on foot is long overdue.

2.2      Transformation brings with it expectation and responsibility.  Delivery will require serious intent and ongoing commitment by the Council.  The scale of physical and behavioural change involved is significant, but eminently capable of achievement in the city that conceived and delivered the New Town.

2.3      This is a project that will span a number of Council terms and must not be subject to the vagaries of different political administrations that may come and go over its lifetime.  It requires “buy in” from all parties for the long term.

2.4      The focus of the strategy is on the city centre, but it cannot take place in isolation and must require significant change throughout the city to make it work and ensure that benefits are widely shared (see next section).

2.5      The strategy has no statutory basis, yet it will have to be delivered through a variety of statutory plans/processes including City Plan 2030, the City Mobility Plan and Low Emission Zones.  It is therefore essential that there is a clear pledge by the Council to see it through, ensuring that it underpins the statutory plans and that all internal structures and processes are joined up and remain so.  We have already seen examples of opportunities to deliver wider benefits for every day walking being missed on simple small-scale projects because of lack of dialogue between sections of the same Directorate.  The scale and complexity of transformation in this strategy is such that this just cannot be allowed to happen.

2.6      It is regrettable that the Delivery Plan is still under preparation as it is an essential part of the package.  The strategy promises a range of potentially exciting changes over a relatively short timeframe, yet a costed programme of projects and interventions is not available.  Consequently there is a risk that expectations have been raised and may yet be dashed before the strategy is off the starting blocks.  The Delivery Plan may be more bedded in reality if it has a clear sense of priority, distinguishing between short-term essentials and what may be longer-term desirables e.g. lifts and the tram line extensions. The experience from Leith Walk suggests some streets can’t accommodate public realm for walking, segregated cycle infrastructure and tram tracks so the detail on what can actually be delivered is important.

2.7      The Delivery Plan will be at the heart of the transformation project and the scale is such that the Council, with budgets constantly under competing pressures, will have difficulty in finding and maintaining the necessary resources to fund delivery on its own.

2.8      Edinburgh is the capital of Scotland and is iconic in UK terms. It is therefore hoped that commitments have already been secured from Scottish Government to enhance the Council’s spending settlement for the duration of the project and to make additional ring-fenced funding available for specific elements, ideally with additional buy in from UK Government. There is a case for the business sector to contribute, as a beneficiary from transformation.  The Council can also secure funding via a workplace parking levy, congestion charging, more rigorous enforcement of parking and road restrictions, and more targeted developer contributions.

 

  1. Need for City-wide Transformation

3.1      In order to be meaningful transformation cannot take place in isolation in the city centre alone, it has to extend across the city and the timing is opportune to start this process.

3.2      SESPlan Strategic Development Plan 2 has recently been rejected by Scottish Ministers on transport grounds, one of them being that the plan does not take sufficient account of the relationship between land use and transport. The rejection letter from the Chief Planner dated 16 May 2019 makes specific reference to paragraphs 272-275 of Scottish Planning Policy. Para 273 prioritises modes of travel in the following order of priority: walking, then cycling, then public transport and finally use of private cars.   The reality is that, despite this unambiguous hierarchy, planning in the city has followed a reverse order of priority and the private car continues to dominate.  The Transformation Strategy can be a start in putting matters right, but it will not work in isolation.

3.3      The rejection of SDP2 reflects Scottish Government’s intention to deliver its policy and sends a clear message that City Plan 2030 and the City Mobility Plan should take the reasons for that rejection on board.  If the hierarchy in Scottish Planning Policy is applied across the city it means that transformation must extend to communities beyond the city centre, sharing the benefits and ensuring they do not suffer the consequences of any displacement of vehicular traffic from the city centre as a result of this strategy.

3.4      A significant reduction in car use is essential to make transformation work and ensure Edinburgh truly is a city with people at its heart.  In practical terms this means there has to be a change in mind-set in and around the city with acceptance that the private car no longer has priority.

3.5      There is plenty of good practice to draw on from within the UK and beyond.  For example, there is potential for mini-Holland style projects in neighbourhoods across the city, including Leith and Gorgie https://walthamforest.gov.uk/content/creating-mini-holland-waltham-forest or take a lead from the Barcelona Super Blocks http://www.bcnecologia.net/en/conceptual-model/superblocks

3.6      An extensive city-wide programme of physical, fiscal and legal interventions is needed including:

  • widen pavements;
  • introduce continuous footways as standard;
  • create a network of segregated cycle lanes;
  • reduce the width of carriageways and increase street planting;
  • significant removal of on street parking;
  • prioritise pedestrians at crossings;
  • congestion charging;
  • a workplace parking levy;
  • city wide low emission zone;
  • rigorous enforcement of parking controls, speed limits, bus lanes;
  • expand and enhance the bus fleet replacing diesel with hydrogen or other zero emission technology;
  • review the bus network within and around the city, where necessary introducing new routes/improve frequency;
  • review train timetables and enhance services where possible;
  • provide/enhance park and ride provision as required.

 

  1. Detailed Comments on the Strategy

4.1      It is appreciated that this is a strategy, but it also identifies a range of specific measures and interventions without going into great detail.   It is stated that the Delivery Plan will provide a costed programme for individual elements over a 10 year period.   Having expressed disappointment that the Delivery Plan is not available as part of the current consultation, we consider it critical that it is the subject of further consultation when it is eventually produced.  This will allow scrutiny of the detail of the various projects and interventions and an opportunity to assess whether any of the ambition in the strategy has been lost or diluted.

4.2      The six principles on p16/17 are supported. However, the aims and objectives in the Interim Report that they are intended to deliver should have been repeated in the strategy so that anyone reading it can make a clear link to them from individual interventions via the principles.

 

4.3      The principle of People First (p16) and priority given to walking, cycling and public transport is most welcome.  With this in mind, and before embarking on detailed design, it is important to decide how to manage, not only private cars, but a variety of other traffic which contribute to unpleasant conditions for walking:

  • taxis/private hire cars;
  • bin lorries;
  • vans;
  • HGVs;
  • tour buses (incl ‘City sightseeing’);
  • long distance coaches.

4.4      To have a liveable (p17) and resilient city centre there should be a target to increase the residential population. This will have to be facilitated through planning decisions and controls over Air BnB type uses.  It will also to be necessary to have the necessary community facilities in place e.g. schools, doctors.

4.5      On p22, specific reference to and acceptance of the hierarchy of movement with people on foot first is welcome.  More detail is required on how pedestrian priority zones will be delivered, particularly the concept of vehicles as “guests” (which vehicles?), and there must be recognition that the city centre is a first phase, with pedestrians eventually prioritised across the city as required by the hierarchy.

4.6      The Pedestrian Priority Zone should cover the entire length of the Royal Mile and include Holyrood Palace/Scottish Parliament.  Its exclusion is illogical as it is that last section with narrow footways and constant traffic that is particularly difficult and unpleasant for the large number of pedestrians who use it.

4.7      There are no proposals to improve walking provision on Queen Street; this should be addressed.  It is one of the most important streets in the New Town, on the edge of the city centre, yet poor air quality, high traffic volumes and excessive waiting times at crossings create a hostile pedestrian experience.

4.8      The new pedestrian and cycling bridge between Jeffrey Street and Calton Road (p24) is welcome and it is hoped that reference to “vehicle free” extends to the currently unsafe junction with Leith Street thereby creating a more pleasant and safer approach to the station from Calton Road.

4.9      On p24 there is reference to “segregated and safe cycling routes”.  It is taken that this means all the cycle routes indicated will be segregated, including Cowgate despite its restricted width.

4.10   Does “full implementation of current Active Travel Plan” on p27 only refer to the cycling parts?   For the avoidance of doubt, the Council should commit to all outstanding walking elements in the ATP.

4.11   Public transport is key to the reduction in private car use and delivery of improved journey times and efficiency for buses accessing the centre (p28/29) is welcomed.  However, it also states that there will be a “reduced volume of buses crossing the city centre without a loss of service provision” with no indication of how his will be achieved.  The service improvement commitment to bus services is focused on the city centre, whereas people need to find it easier to use buses throughout the city.  Bear in mind that individual trips to the city centre may require more than one bus so it is essential that service enhancement is consistent across the city.

4.12   Is it correct to assume that “taxi” is used as a generic term to include all private hire companies?  As there is significant taxi usage in the city, incentives and controls should be in place to ensure vehicles are low or zero emission.  Is it possible to explore this as a condition of licencing?

4.13   The public transport interventions (p30/31) require careful assessment to ensure that they deliver benefits to all and that those who currently rely on these services do not lose out.

4.14   Bus priority can also be enhanced through bus lane extensions and greater enforcement, including parking at bus stops.  These are actions that can be taken now.

4.15   The concept of buses ‘kissing’ the centre needs to be illustrated to show how it will work and to ensure that people don’t have to change buses unnecessarily.  Many existing routes work and are supported because they cross the city centre (e.g. between Western General Hospital and Edinburgh Royal Infirmary) so introducing a change of bus may act as a disincentive.

4.16   More detail is needed on the proposed hopper service and the problem it is intended to solve. Likewise with the tram extensions on Lauriston Place and North/South Bridge which are surely unlikely to be delivered in the 10 year timeframe.

4.17   The desired 25% reduction in private vehicle movements in the city centre is noted (p32), but surely we can be more ambitious than that.  Apart from a few exceptions there is little need to bring a car into the city centre or to assume that residency in the centre requires it.  This target has to be revisited as well as consideration given to city-wide targets.

4.18   There is no target for reducing the commercial vehicle movements which contribute significantly to making walking unpleasant.  Traffic passing through the centre should be re-routed without detriment to other areas.  Vehicles coming into the centre will face greater kerbside restrictions, but this has to be accompanied by the rethink in vehicle types identified in the final bullet point on p32.

4.19   Reducing on-street parking (p34/35) is a key feature which is welcomed as it will increase space at a stroke for walking (and cycling) and will reduce car traffic looking for on-street places.  This has to involve more than lip service and a radical removal programme is required.  It must be accompanied by a work place parking levy, as well as a campaign to persuade businesses to voluntarily remove parking provision and replace it with incentives for employees to walk, cycle or use bus/tram/train. There is significant scope to apply this approach throughout the city and dramatically reduce the amount of on street parking in any location where public transport and walking/cycling are practical alternatives.

4.20   The Council has a policy that allows for car free developments, but it has been timid in applying it.   It should be the default position for new developments unless it can be demonstrated that the modes above cars in the hierarchy are not available.  Certainly within the city centre it has to be clear that no new off street parking is created aside from Blue Badge, car club and delivery bays. Otherwise new developments will generate more traffic growth. This must be set out in City Plan 2030. The space saved can go towards more housing (including affordable), more landscaping/gardens and allow for additional developer contributions towards public transport and other active travel infrastructure.   Developments such as the Engine Yard at Shrubhill on the edge of the city centre with its extensive underground car park should not be repeated.

4.21   The creation of an integrated transport and data management centre (p36/37) is noted, but more detail is required on what it involves and how it will operate to ensure it will be effective and provide all the data required.  This is critical as at present there is, for example, no proper monitoring of modal share.

4.22   The operations management plan is essential and it is surprising it does not already exist, but that would explain missed opportunities to enhance the walking experience.

4.23   It is assumed that the management of commercial bins includes the communal Council bins, but there also has to be management of private bins on the pavements.

4.24   The improvements in place (p38/39) are broadly welcomed.  There are however a number of specific comments:

  • The 4 vertical lifts will be an innovation, but it is hoped that their inclusion is based on reality and not vague ambition so as to avoid disappointment if they don’t happen.
  • The designated traffic free streets should be expanded to include Calton Road from the station car park to Leith Street and the eastern section of the Royal Mile.
  • Main Public Space Improvement should include all of the Royal Mile, Calton Road, Leith Street, Cowgate, Market Street, Lauriston Place, all of Princes Street, Waterloo Place/Regent Road and the full length of Queen Street.

4.25   The concept of catalyst areas is a useful means of showing in more detail at this stage what can be achieved, but it is important that these areas do not become the sole focus and the principles of transformation are applied across the entire strategy area. Living Streets Edinburgh welcomes the commitment to develop detailed proposals in close consultation with relevant stakeholders and wishes to be part of this process.

4.26   The diagram on p48 identifies Morrison Street for public realm improvement, but not as a walking route although many people use it as a direct link to Lothian Road. It is a busy and deeply unpleasant street, totally dominated by several lanes of traffic. The public realm improvements will not change this unless accompanied by wider pavements and a reduced number of lanes carrying less vehicular traffic. The rationalization of the Haymarket junction is welcomed, it is currently a nightmare for pedestrians and the improvements must put people on foot first.

4.27   It is appreciated that Lothian Road (p56) is a challenge and the decision to instigate change is welcome. If it is truly to become a tree-lined boulevard then people have to be the focus, yet it appears from the information available that there will still be 4 lanes of traffic. This should be reduced to allow the tree planting on areas that are currently taken up by road with the pavements on both sides widened to improve the pedestrian experience. There is reference to reallocation of traffic lanes on a number of roads, including the West Approach Road, which requires clarification. Again the detail of what is proposed for this area is important and we look forward to involvement in that process.

4.28   The First New Town Strategic Plan (p64) identifies public realm improvements on Princes Street, George Street and parts of other key streets, but then excludes key streets where improvement is also required.   Given that Queen Street, Frederick Street, Hanover Street, and North/South St David Street are all also identified as key streets they should be assessed for public realm improvement, both in terms of improving the fabric (e.g. cobbles on Frederick Street) and giving pedestrians priority. (e.g. the St. David Streets being particularly poor).

4.29   As the strategy is intended to provide a high-quality pedestrian focused environment across this area, it is assumed that the specific active travel routes identified on the plan are focused on cycling. In which case, it would be better to make segregated provision on George Street and The Mound (as currently proposed) and also create similar provision on Princes Street. Rose Street could then be enhanced to create a high quality pedestrian street, surely an early priority given that there is a longstanding commitment which is now many years overdue.

4.30   Despite rationalization of bus services and stops there will still be 4 lanes of traffic/tram. This should be reviewed to identify any opportunity to widen the pavement on the south side of Princes Street that is currently too narrow for the volume of people using it.

4.32   The introduction to the section on the Old Town (p71) correctly identifies that the primary aim is to enhance the experience for pedestrians and the principle impediment is the presence of vehicles in an area that was clearly never intended to accommodate them. Within this context drastic measures are called for and there is an argument for restricting access solely to vehicles necessary for servicing and disabled people. Residency in this part of the city should not be qualification for keeping a vehicle in it, particularly on the street. Comments on other aspects of the Old Town proposals have been made earlier in this submission.

4.31   Proposals for George Street and Meadows to George Street schemes are at an advanced stage of preparation having been subject to consultation. It is assumed that they are compatible with and reflect the ambition of this Strategy.

4.33   The Waverley/Calton proposals (p78) embrace the area covered by the emerging Waverley Station Masterplan.  This strategy has a 10 year timescale and the Masterplan, covering a smaller area, is for a period of 30 years.  Ideally both projects would be implemented in the same timeframe so it may be worth exploring if the Masterplan could be condensed into 10 years, at least the significant and most disruptive elements.  Alternatively, a more realistic timeline for both projects may be 15 years, but in any case delivery has to be aligned.

4.34   Proposals to enhance the walking experience in and around the station are generally welcome, but detail is required.  For example, what does pedestrian priority mean on Waverley Bridge?  Tour buses will be removed, but it is unclear which buses if any will still be permitted, although it was understood from the Masterplan consultation that they would all be removed.

4.35   The issue of service traffic for the shopping centre and station has to be addressed as there is potential for conflict.  The possibility of servicing by rail, including short haul from other stations around the city, should be investigated.  There should be no provision for car parking other than bluebadge holders.

4.36   The eastern end of Princes Street is currently an unpleasant place for pedestrians with a combination of traffic volume, fumes, barriers, narrow footway on southern side and conflict with the large volume of people entering and leaving the station via Waverley Steps.   This Strategy and the Masterplan can address this situation.  Space should be taken from the road to widen the pavement on the southern side, traffic has to be reduced and the public realm enhanced.

4.37   The North Bridge/Princes Street/Leith Street junction is one of the worst pedestrian experiences in the city centre.  It is difficult to navigate and confusing for the unfamiliar.  The plethora of barriers should be removed, traffic reduced, and the pedestrian crossings redesigned to ease navigation and give walkers priority.

4.38   The redevelopment of Edinburgh St James had potential to transform Picardy Place and Leith Street, but that ship has sailed, the opportunity is lost and the works currently underway are the polar opposite of what this strategy intends.  There is still an opportunity to mitigate matters with public realm improvements, including significant tree planting, prioritise pedestrians at all crossings and close Calton Road to traffic.

4.39   With the intended reduction in traffic entering the centre and closure/restricted access in several streets there is likely to be some displacement.  It is possible that this may impact negatively on the Bridges/Nicolson Street, which are understood to already have the worst accident records in the city.  North Bridge is to have reallocation of traffic lanes, but it is unclear how it will be transformed for pedestrians.

4.40   It would be useful to have sight of the traffic modeling that was presumably undertaken as part the strategy to ascertain if displaced traffic would ‘evaporate’ or end up on this corridor.  The issue of displacement is part of the case for tackling transformation across the city and not only in the centre.

4.41   The Innovation Mile (p86) covers an area where walking is not subject to the same level of competition for space, but there is still scope to enhance the experience and that is welcomed. Public realm improvements to Lauriston Place are appreciated, but there are also locations (usually at junctions) where pavements should be widened to accommodate the number of pedestrians.  South Bridge/Nicolson Street requires enhancement and pavements widened.  There would appear to be an intention to remove the rather brutalist over/underpass at Bristo Square which is welcome.  There is no mention of the long standing Causey project which is a gateway to Nicolson Street and the “Innovation Mile”.  It is 10 years over due and should be included as an early priority.

  1. Conclusion

5.1      This Strategy and the actions that flow from it can transform the walking environment in the city. The Council is to be congratulated for instigating the project, now Living Streets Edinburgh is keen to work with the Council and others to realise the ambition within it.

 

 

 

 

Waverley Station Masterplan – Our Response

Living Streets Edinburgh Group aims to promote walking as a safe, enjoyable and easy way of getting around Edinburgh.

Within this context we appreciate the opportunity to contribute to the discussion on the future development of Edinburgh Waverley Station.  We look forward to a masterplan that reflects both the outstanding location in a World Heritage Site and this unique opportunity to radically improve the experience for people using the station.

The focus of the station is walking, whether arriving or leaving by train, or simply passing through.  The walking experience in and around Waverley is not an easy one, especially for those unfamiliar with the station or the city.

The masterplan process offers an opportunity to address this and should revolve around people walking, both within and through.  The statistics show that the overwhelming majority of people arrive and leave on foot, so make it easier and more comfortable for them to do so.

As the masterplan evolves there will be conflicts to resolve, but this should always be within the context of the movement hierarchy set out in Scottish Planning Policy with walking, cycling, public transport and, lastly, private cars in that order of priority.

The focus must be on the station as a travel hub and not as an opportunity for commercial development unless in support of that raison d’être.

In addition to catering for the projected increase in train traffic and improving the walking experience within the station, there are wider opportunities to be taken, so it is important that the masterplan boundary is not tightly focused on the station itself and embraces surrounding streets. It certainly needs to be closely integrated with the City Centre Transformation project being led by the Council.

Some of the associated issues to be taken into account (not an exhaustive list) when preparing the masterplan include:

  • No car parking other than for drop off/disabled use, and this must be designed to avoid conflict with those walking.
  • Make it easier and more seamless to walk to/from buses and trams without enduring pinch points or having to cross traffic-dominated roads.
  • Provision will have to be made for taxis in a location that does not conflict with walking, but not inside the station.
  • Reinstate the historical link from the Old Town to Calton Road via a new pedestrian bridge, thereby allowing people to walk over on one level rather than the current convoluted route through the station.
  • Close the dangerous Leith Street/Calton Road junction except for pedestrians and cyclists.
  • Enhance the Calton Road route to the station to improve the walking experience and make it a more pleasant route at any time of day.
  • In addition, the opportunity must also be taken to prioritise pedestrians and enhance the walking experience on Princes Street (including exit/entry via Waverley Steps), on Waverley Bridge, and Market Street/East Market Street.
  • The servicing arrangements for the redeveloped station require careful thought in terms of location and future management.  Some of the ideas floated in the city centre transformation consultation regarding the size/type of vehicles used may be useful.

We hope that our input helps to inform the masterplan process and we look forward to continuing to work with others to create an outstanding future for Waverley Station and all who use it.

George Street Consultation: response by Living Streets Edinburgh (LSEG)

Introduction:

Living Streets Edinburgh Group 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 as a safe, enjoyable and easy way of getting around the city.

We welcome many aspects of the proposed design, which are way overdue: for example, removal of general parking, reduction of traffic space widening of pavements, removal of street clutter, and introducing seating. We append our general statement of preferences for street design, which the proposals generally meet well.

LSEG has a long-standing ambition to pedestrianise George Street – which we were told has widespread public support through the consultation. Edinburgh – perhaps uniquely for a European city of its size and history? – lacks any properly traffic-free space and George Street (and the Royal Mile) are the obvious candidates for this in the New and Old Towns respectively. The form that pedestrianisation should take depends on the type and volume of traffic that will use the street. Which parts of the street will be used by buses? Taxis? Private vehicles? The answer to these questions will determine the scale and type of appropriate pedestrianisation: for example, if buses are to continue to use the eastern section of George Street, then it would only make sense to pedestrianise the western two blocks.

We therefore believe that the design should follow decisions on the purpose of the street in terms of its ‘movement’ function, without of course undermining its crucial ‘place’ function. The emphasis on the ‘flexibility’ of this design (so that the street can accommodate traffic which is currently permitted, as well as options for reduced traffic levels) is a mistake and makes it hard to comment on the suitability of the proposed design. Decisions to restrict traffic should therefore be made now.

Having said this, we have the following comments on specific aspects of the design:

General parking:

We welcome and give unqualified support to the removal of general on-street parking. We note that a 1,600 space (?) car park will open soon in the St James Centre (regrettably). Careful consideration is needed for the provision of space for loading, service vehicles etc, and the management of such provision (see also ‘Enforcement’ below).

Blue Badge parking:

This should be provided ‘as appropriate’. To determine what is appropriate, detailed surveys of current Blue Badge parking patterns should be carried out, along with consultation with relevant disability groups. Provision is likely to consist of parking both on or near George Street (eg at the top of the steeply sloping streets like Castle St, Frederick St, etc) and also at the bottom, because some drivers/passengers will be heading for Princes St, rather than George St, and may be unable to manage the slope.

Crossings:

It is essential that all pedestrians can cross George Street easily, safely and with confidence. This should be both at the junctions with adjoining streets and also mid-block. We are not convinced that the design achieves this, as the ‘plazas’ do not appear to offer any formal pedestrian priority. Although we generally welcome the use of zebras to provide this, we doubt that the current crossing provisions adequately cater for the needs of people with visual impairments.  Our understanding is that there are only three signalled crossings – at the east and west ends, and at the Hanover St junction.

Cycle lane:

The cycleway as currently designed means very tight pavements on the south side of George Street at junctions, especially with Frederick St. It is essential that all pavements on this ‘flagship’ street fully meet the Street Design Guidance’s ‘desirable minimum’ width of at least 4 metres; this does not appear to be the case at these points. However more fundamentally, a 4 metre cycleway conflicts with the principle that George Street should be about ‘place’ not ‘movement’. If general traffic is restricted, as we advocate, this would remove the need for a separate cycleway at all, as cycling on the carriageway would be attractive and safe. This would also be more convenient for cyclists joining and exiting along George Street than a bi-directional cycleway.

We support provision of a safe and attractive cycling environment in the city, including to and on George Street. However, we question whether George Street is the right place for the major segregated west-east route catering for a range of cyclists including commuters, delivery cyclists etc as well as people arriving to enjoy George Street itself by bike.  Alternative, more direct options for a cross-city route include Queens Street or Princes Street. We therefore think that further consideration should be given to the best route for a segregated section of the National Cycle Network, as part of the ‘city centre transformation’ and the overall reduction in traffic in the city centre.

Management and Enforcement:

It is vital that plans for management and enforcement – of parking, waiting, loading, blue badge spaces, speeding, bins, ‘A-boards’, etc – is fully planned at the outset. Shops, bars and restaurants will need deliveries and waste collection etc and these need to be organised in a way (and at times) that does not result in vans, bin lorries, etc outwith designated times. Edinburgh does not have a good record of managing existing pedestrian priority spaces (eg Grassmarket, Castle Street, Rose Street). Without robust enforcement measures (which are likely to reduce with the removal of current pay and display parking), the intention to create people-friendly spaces will be defeated.

’Plazas’:

We agree that attractive spaces should be provided for both formal and informal events, social activity etc so that the vitality of the street is maximised as a lively place where people want to visit and stay at all times of the day, and year. However we need to have more detail on how such spaces will be managed – especially during the festivals (see also ‘Enforcement’ above) – to comment on whether the proposed design is suitable.

Trees:

We understand that tree planting on George Street is likely to be controversial, especially on ‘heritage’ grounds. However, we tend to favour the introduction of appropriate greenery which makes the space more attractive without compromising the historic and architectural appeal of the street.

Appendix: ‘Standard’ LSEG key principles relevant to George Street

A fundamental point is that all proposals and designs must explicitly conform to the Edinburgh Street Design Guidance (ESDG) for the category/categories of street affected. Until the adoption of finalised Detailed Design Sheets for the ESDG, the latter’s Design Principles (as already adopted by the Council) should be adhered to, for example with regard to:

Space:

1. An increase (or no net loss) of pedestrian space.
2. Footways meet recommended widths.
3. Conflicts with cyclists are avoided, with dedicated and well-defined space provided for pedestrians (including separated ‘tiger’ crossings).

Crossings:

4. Junctions make foot crossing easier by being raised, with radii of corners and widths minimised
5. In busier areas, controlled crossings are provided in convenient places, with acceptable waiting and crossing times.
6. Pedestrian priority is made clear at all the key crossing points of the cycle routes, eg with continuous footways across side streets at junctions.

Equalities:

7. The design meets the requirements of the 2010 Equality Act by including the reasonable adjustments that the Council is legally required to implement in order to make the streets accessible to people with disabilities such as dropped kerbs (where continuous footways are not feasible), seating and tactile paving.

Public realm:

8. The footway is made free from clutter.
9. Guardrails are avoided / removed.

Impact of traffic:

10. If the area is a residential or shopping street or busy pedestrian route the speed limit is 20mph and the design helps to achieve this as a maximum speed in practice.
11. The level of parking and access to motor vehicles is appropriate and does not dominate the space.
***

Edinburgh: connecting our city, transforming our places – Consultation response

Response to the City of Edinburgh Council Consultation

Edinburgh: connecting our city, transforming our places

28 October 2018

(The full document can be downloaded as a PDF here – 1mb)

The Role of Living Streets Edinburgh

1.1 Living Streets Edinburgh is the local group of Living Streets, the national charity for everyday walking. We aim to promote walking as a safe, enjoyable and easy way of getting around Edinburgh.

1.2 To achieve this we want to see:

  • Walking given the top priority over other forms of travel in all council transport and planning policies
  • Reduction in the volume of motorised traffic and its impact on people using the street
  • Better designed and maintained pavements, road crossings and other pedestrian facilities
  • More effective and joined-up monitoring and inspection of the walking environment by Edinburgh Council
  • Planning policy which encourages dense, sustainable housing over car-dominated development
  • More effective implementation of pro-walking policies ‘on the ground’.

1.3 Within this context we respond to consultations by the City of Edinburgh Council on plans and policy that impact on the walking environment and we also comment on planning applications.

1.4  The publication of the prospectus “Edinburgh: Connecting Our City, Transforming Our Places” is the most significant consultation that the Council has ever carried out in terms of:

  • Its timing against a backdrop of international, national and local acknowledgement that climate change and human health issues must be addressed now and cannot be left for future generations; and
  • As a consequence, the scale and nature of change required to our streets and public spaces, transport infrastructure, and the behaviour of everyone using them if Edinburgh is to be a city that truly has people at its heart.

1.5  Living Streets Edinburgh Group therefore wholeheartedly welcomes this consultation, the opportunity to contribute to the discussion, and looks forward to working with the Council and others towards meaningful change in our city.

Response to the Prospectus

The Big Picture

2.1  Sometimes bold decisions are required.

2.2  Now is such a time for the City of Edinburgh Council following publication of the Prospectus “Connecting Our City, Transforming Our Places”.

2.3  It won’t be the first time that a radical decision and change of direction has been taken to improve life for the people of Edinburgh and allow the city to prosper.  The 18th century saw the city fathers embark on the New Town development in response to overcrowding, poor quality buildings and insanitary conditions.  Not only did this improve the lot of citizens, it enabled the city to maintain its place amongst its European counterparts during the Age of Enlightenment, a time when Voltaire said “we look to Scotland for all our ideas of civilization.”  One wonders if he would say that if he walked around Edinburgh today.

2.4  Having created one of the most outstandingly beautiful cities in the world we have, since the advent of motorised transport, increasingly eroded the ability and opportunity for people to enjoy it.  Not only that, we have created an environment that is crowded, unsafe and unhealthy. The very attributes that the New Town sought to address.

2.5  In 1895 there were 15 motor vehicles in the whole of UK, by the 2011 census there were 181000 cars owned by Edinburgh residents alone.  Factor in additional commuter/visitor traffic, HGVs/commercial vehicles, buses and the scale/nature of the problem is apparent.  Instead of using the motor vehicle as a tool to be managed for the greater good, it has been allowed to dominate and shape our environment and dictate our relationship with it.  Some of us use cars, but all of us are pedestrians. Yet people are directed to move around the streets and public spaces in a way that minimises disruption to traffic flow – motor vehicles remain in charge.  This is a far cry from the philosophy of Patrick Geddes, who contributed so much to Edinburgh and the world and recognized the fundamental relationship between folk and place.

2.6  Our statutory planning system has now been in place for 70 years, yet this situation has been perpetuated across the country, including Edinburgh, and continues in the face of widespread evidence of the negative impacts and the existence of Scottish Planning Policy, which clearly prioritises travel modes  – walking, cycling, public transport, and cars in that order.  Despite being Scottish Government policy, this hierarchy has yet to underpin the local development plan and decisions on planning applications.

2.7  Disregard of the hierarchy and the need to change our behaviour is borne out by analysis of 2017 Household Survey Data for Transport Scotland that shows Edinburgh has experienced a sharp decline in walking as the main mode of commutes under 5 miles to work.  This is in contrast to the position in Glasgow and Scotland as a whole where walking has at least remained more or less constant.

2.8  There has been a realization elsewhere in Europe and further afield that this is no way to plan for cities and towns.  Slowly, but surely, streets and public spaces in many cities are being reclaimed for the people who use them, a process that in some cases has been underway for decades.  If municipal authorities in cities as diverse as Melbourne, Copenhagen, Ghent, Bologna, Utrecht, Madrid, Oslo and New York are able to face up to the challenge and pursue a transformational agenda that benefits people and local economies, then surely Edinburgh can do likewise.  It could be the beginning of a New Age of Enlightenment focused on people and place.

2.9 People and place: people are designed to walk, so provide places conducive to walking and the benefits that follow are significant.  Not only in terms of health, but also by facilitating people coming together, fostering a sense of community and helping to address social exclusion.  More than that, it is better for the local economy with greater footfall more likely to spend than those who drive past.  Look to Jan Gehl whose starting point has always been to design and plan for human proportions and speed of travel.  The Council is directed to the Living Streets report “The pedestrian pound –  The business case for better streets and spaces”. https://www.livingstreets.org.uk/media/1391/pedestrianpound_fullreport_web.pdf

2.10  It is accepted that the initial decision will require courage by the City of Edinburgh Council in the face of inertia, vested interests and fear of change.  But other cities have done it, Edinburgh has in the past, and can do so again.  Take a lead from the Spanish city of Pontevedra where a new mayor provided the catalyst to swiftly address longstanding problems and in a very short time radically transformed the historic city on the basis that cars don’t have an automatic right to occupy public space.  As César Mosquera, that city’s head of infrastructure so eloquently put it: “How can it be that the elderly or children aren’t able to use the street because of cars? How can it be that private property – the car – occupies the public space?”

2.11  Taking a wider perspective, the climate change agenda requires positive action at every level from Government down to the individual; we are all in it together.  However, with transport we are going backwards.

2.12  The independent Committee on Climate Change reports on Scotland’s progress towards meetings emissions targets, as requested by Scottish Ministers under the Climate Change (Scotland) Act 2009.  The most recent report found that transport emissions had actually increased by 2% in 2016.

2.13  The City of Edinburgh Council air quality monitoring identifies an overall reduction in vehicle pollutants, but acknowledges that there are many locations within the monitoring areas where safe levels are actually being exceeded.  Anyone experiencing Edinburgh streets as a resident or pedestrian knows that air quality is poor within the city centre and along several other routes in the city.

2.14  The Intergovernmental Panel on Climate Change recently published a Special Report on Global Warming of 1.5ºC.   The report finds that limiting global warming to 1.5°C would require “rapid and far-reaching” transitions in land, energy, industry, buildings, transport, and cities.  Closer to home the UK Government has committed to having zero emission new cars by 2040 and in light of latest evidence is under pressure to bring this forward to 2032.

2.15  Against this background, the consultation is timely and Edinburgh has an opportunity to once again be at the forefront of city planning.   As Councillor Lesley Macinnes says in her foreword to the Prospectus:
“Reducing congestion and vehicle-borne air pollution, improving journey times by public transport, realising the lifelong health benefits of walking and cycling, and creating streets and public spaces that support city living for all are key to sustaining our inspiring capital city.”

2.16  No one would argue with that and the case contained within the Prospectus clearly points towards the need for a radical change in direction.  The Prospectus states unambiguously that no change is not an option, but then offers business as usual and a strategic approach as choices which in effect amount to no change, given the scale and nature of the circumstances that face us.

2.17  Thankfully, transformational change is presented as the third option and it is clear on reading the document that this is really the direction the authors and Council consider to be necessary and hope to pursue if they receive support. The Prospectus states that a transformational approach would involve a radical rethink of how the city moves and operates.  Well, a radical rethink is exactly what is required; the time for tinkering around the edges and ignoring the evidence has long since passed.

2.18  The Prospectus sets a date of 2050 for achieving the kind of city we aspire to.  In light of the issues facing us as a city, nation and planet this is not nearly ambitious enough.  Once the decision has been taken to pursue transformational change, a date of 2030 should be set.  This will enable everyone involved to focus on planning and realising actions within a timeframe we can all relate to and benefit from.

2.19  Transformational change is an overarching decision of principle that should then provide a framework and context for the Mobility Plan, Low Emission Zones, Local Development Plan and other strategies/plans that follow.

2.20  Whilst it is appreciated that work on information gathering and identification of potential allocations has to continue, it is disconcerting to hear that the next Local Development Plan is currently being prepared in parallel with this Prospectus rather than taking a lead from it.  Transformational change will necessitate a fundamental rethink on, for example, movement patterns and infrastructure and the location of allocated sites.  It makes better sense for this to be reflected in the Main Issues Report (MIR): consequently publication/consultation on the MIR should not take place until the fundamental decisions on transformational change and likely range of consequential actions have been taken.

Comments on the Themes and Ideas

2.21  In broad terms the 3 themes and 15 ideas in the Prospectus should of course all be pursued, although there will be instances where the detail will need revision or adjustment to reflect the position of walking at the top of the movement hierarchy and to reflect comments in this submission.  One fact is abundantly clear; all of this can only be realised by transformational change.  In many ways the ideas therefore have to be more radical.

2.22  In terms of the position of walking in the movement hierarchy, and to reflect that this is a citywide aspiration, Idea 1 should simply refer to A Walkable City as the intention, with recognition in supporting text that the city centre has particular issues that must be urgently addressed. In this regard, Living Streets Edinburgh has adopted a 10 point plan for the city centre (Appendix 1 attached) which should be taken on board as part of the transformational change project.

2.23 The opening words of Idea 1, “reducing the dominance of vehicular traffic”, effectively constitute an overarching objective which will in turn enable the realisation of the other ideas in the Prospectus.  Recent actions such as the reconfiguration of Picardy Place and re-opening of Leith Street accommodate and perpetuate the dominance of vehicular traffic – so the Council really has to markedly change direction to show it is serious about this Prospectus.

2.24  A relatively straightforward early demonstration of intent would be the phased removal of a significant amount of on street parking.  The local transport strategy has a target of reducing car commuting from 42% to 29%.  The new St. James Centre will have parking for 1700 cars, so there is off-street parking available.  The removal of on-street parking, in and around the city centre in the first instance, is an action wholly within the Council’s control.  A similar programme is well underway in Oslo and has led to an increase in walking and wider active travel.  The removal of on street parking will in turn allow for the creation of wider pavements, on street cycle lanes and associated reconfiguration of streets to remove vehicle priority. These actions will complement other measures taken under Idea 14, Controlling the Impact of Commuter Parking.

2.25 Although it may be implicit in sections of the Prospectus, it is suggested that the document would benefit from a section on equality and the application of the Equality Act (2010) setting out how proper consideration has been taken during work on the Prospectus itself and how it will be intrinsic to the plans and actions that follow.  This is critical as transformational change has to benefit the whole community, including those who have been previously been forgotten when designing simple details for pavements, street furniture, pedestrian crossing times etc.

2.26 Under Idea 3 Strengthening our town centres, the economic benefits that tourism brings could be distributed more evenly by encouraging accommodation and associated provision across the city, with enhanced public transport and walking routes for people to get to the popular destinations.  This would alleviate pressures on the city centre, which, in tandem with prioritising walking in line with the Scottish Government hierarchy, would contribute to the wider transformation agenda.

2.27 Buses are a strength and a real success story for Edinburgh compared to other cities.  The Council should recognise this and build on it.  Idea 4 as written runs counter to this and potentially to Ideas 5 and 11.  There will certainly be scope for some rationalisation and route modifications as part of prioritising the city centre for pedestrians.  However, great care has to be taken to maximize the scope for through routes, as having to change buses will be a disincentive for many users and will run counter to the intention of Idea 4 to create better accessibility.

2.28 Contrary to what is implied in Idea 4, buses are not in themselves the problem. Given the air quality challenges and emission targets, it is better to concentrate on transforming the whole bus fleet to zero or low emission.  This along with some rationalisation, removal of cars and reduction in commercial traffic will help secure the improvements required in the city centre.

Conclusion

2.29  Transformational change requires the City of Edinburgh Council to state unambiguously that movement across all of Edinburgh will be based on the hierarchy set out in Scottish Planning Policy, with walking the first option, and that this will be reflected at all levels of decision making.

2.30  In preparing and consulting on this Prospectus the City of Edinburgh Council has taken an important step in securing transformational change for residents, visitors and the local economy.  It is critical that momentum is maintained and the transformational change becomes a reality, thus maintaining the tradition that started with the New Town, continued with being the first Scottish local authority to appoint a Medical Officer of Health in 1862, and more recently the implementation of smoke control areas, ban on smoking in enclosed public spaces, and the introduction of 20mph speed limits across the city.

2.31  Living Streets Edinburgh would very much like to sit down with the City of Edinburgh Council and others to work on the detail of the various ideas and a full implementation programme for bringing about transformational change by 2030.

2.32  Thank you again for the opportunity to contribute to this discussion. When the responses to the consultation are reported to the Council, Living Streets Edinburgh respectfully requests that this submission be reported in full without editing or précis.

Living Streets Edinburgh
28 October 2018