Below is the Living Streets Edinburgh response to the Scottish Government’s consultation on Road Safety in Nov 2020
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.
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.
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.
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
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
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.
- 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.
- 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.
- 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;
- 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.
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.
LSE strongly supports and welcomes the general thrust of the City Centre Transformation proposals and is making a separate submission to that effect. With regard to this consultation, the design proposals embodied in the Concept Design for the Meadows to George St. Project are particularly welcome. The enhanced priorities for walking, cycling and public transport envisaged are essential for the improvement of the Meadows to George St. Route and for the city centre as a whole.
Traffic Reduction and Pedestrianisation
The proposals to remove general traffic from George 1V Bridge and part of the Mound, and to eliminate the outmoded Forrest Rd./Teviot Place/ Bristo Place gyratory scheme are particularly welcomed. So too is the intention to restrict access along Forrest Rd primarily to walking and cycling, with restricted loading/ unloading hours for deliveries. This would release the potential to create a vastly improved environment for pedestrians in and around Forrest Rd. The extent to which that potential is realized will depend on there being effective management and enforcement regimes in place regarding both access for deliveries and the disposal of waste. All too often such good management and enforcement have been lacking to date. We therefore would expect to see proposals for effective scheme management and enforcement advanced in parallel with the detailed designs for this scheme. We also have reservations as to whether all bus services should be removed from Forrest Rd, as discussed below.
The diversions of general traffic away from George1V Bridge via Chambers St and Market St are very welcome in principle, but it seems obvious that this will mean higher traffic levels on the Bridges and Jeffrey Street. Not all of the diverted traffic can realistically be expected to evaporate. It therefore seems reasonable to expect to see some analysis of the expected impact, especially on the Bridges route, since it is already operating under stress, with a poor accident record, being often congested, and where current conditions for pedestrians are as bad as or worse than those on George 1V Bridge. Until these impacts are clarified, we cannot unreservedly support these traffic proposals.
The design concept proposals envisage a 3 metre wide, 2-way cycleway along the east side of the route, through George 1V Bridge, the Mound and Hanover St. This is preferable to the alternative of 1-way cycleways along both sides of the street, in that it allows more space for wider pavements, and reduces the conflicts between pedestrians and cyclists at bus stops, halving the number of such locations. There remain nevertheless some serious difficulties associated with the floating bus stop design, and at the east side stop at the foot of the Mound in particular.
Floating Bus Stop Provision
Our concern over floating bus stop design centres on the conflicts they introduce between cyclists and pedestrians crossing the cycle lane to board a bus, or alighting from buses into the cycle lane. It is worth noting that the recent re-introduction of rear door exit buses by Lothian Buses is almost certain to make the alighting conflicts greater. Moreover we are still awaiting the findings from the promised evaluation of the Leith Walk floating bus stop.
We are not aware of any precedents of busy two-way cycle lanes at floating bus stops, either in Edinburgh or elsewhere in the UK. The Council’s own street design guidance (Factsheet C4, Segregated Cycle Tracks) only addresses one way cycle tracks at bus stops. This design therefore does not appear to conform to Council design standards.
The proposed design for the crossing points at the floating bus stops has included some highly desirable elements that LSE would regard as essential. The two raised and zebra striped crossings of the cycleway, linking to the floating platform on either side of the stop/shelter position, are of vital importance. Sufficient width, height, and ramping will all be critical to how well they help to reduce conflicts with cycling. A standard crossing width will not be adequate given the peaked nature of crossing at bus boarding times, and we suggest that they should be of at least twice the standard width, if not more when based on current and forecast passenger pick up and drop off levels.
At the foot of the Mound, and to a lesser extent in Hanover St., cyclists would be approaching the bus stop downhill, at speed in many cases, and creating severe conflicts with pedestrians at the stop. This is unsafe. At the 3rd June workshop cycling representatives also raised concerns about the suitability of the 2-way cycleway provision over this steep downhill section, and it was suggested that downhill cyclists should use the carriageway instead. We would strongly endorse this suggestion, as it would reduce the most severe conflicts that are otherwise likely to arise.
The platforms associated with the proposed floating bus stops would provide some additional space for awaiting passengers, but at the busy stops and pavements involved there is concern that this space would still be inadequate to allow for the concentration of conflicting pedestrian movements, and for safe interactions with cyclists in particular. Moreover those concentrations are being intensified at some of the busiest stops, in Hanover St and at the bottom of the Mound, by having a single stop and a single shelter for all bus services. The loss of already inadequate shelter and seating space at these stops will inevitably mean worse conditions for waiting pedestrians, and for those with mobility impairments in particular. We can see no justification for this and wish to see these losses compensated for by the provision of additional shelter and seating. That provision should be informed by an analysis of pedestrian flows and passenger usage at peak times of the year for the stops involved. It is difficult to believe that this has been undertaken for these stops to date (if it has can we please see the results?), but it should become a routine procedure wherever a reduction in stop and/or shelter/ seating provision is under consideration.
Other Bus Services and Stops
A similar reduction in provision of bus stop facilities is seemingly proposed in shifting the provision of bus services from Forrest Rd. to Teviot Place, and gives rise to similar concerns. This shift is also likely to result in longer walks to most destinations and have adverse effects on the growing proportion more vulnerable bus users who are mobility impaired as pedestrians. We would wish to see a thorough analysis of this issue being undertaken before a commitment is made to the move. More generally this is an important issue that has not been receiving sufficient attention as yet in developing the wider City Centre Transformation proposals.
At the workshop we were informed that under the revised bus stop arrangements there would be no breaches of the CEC standard for the maximum walking distance between stops, which we understand to be 400m. It is understand that only one bus stop is to be removed under the concept design proposals, that being at the uphill stop on the Mound close to the junction with Market St. LSE does not object to this change since this stop is little used and does not serve any significant destinations. However, with no compensating changes being made to the stop locations along the route on either side, the distance to the next southbound bus stop (National Library) is about 500m. There will be pedestrians undertaking a longer and steep uphill walk, so there should be seating provided at intervals to help ease them on their way. The additional space proposed for pedestrians at the junction with Market St., and in association with the welcome closure of St Giles St. to traffic from Bank St., would seem to offer suitable locations. Such provision is especially important given the heavy demand for bus passengers and other pedestrians to visit the High Street.
The loss of the median strip, which currently enhances the crossing opportunities for pedestrians throughout George 1V Bridge, is regrettable, but is seen to be acceptable given the wider pavements and reduced 6.5m carriageway width envisaged, provided that the current number of locations for crossing facilities is retained.
More formal enhanced crossings are proposed, light controlled at the Chambers St junction and with a zebra facility approximately half way along. It seems that dropped curb crossing points are envisaged at the other locations, but it is not clear from the on-line consultation drawings that this is the case, so we would appreciate clarification. There is a high demand for crossing next to the Victoria St. Junction and a clearly designated crossing facility is needed at this point in particular.
The proposed crossing of Bristo Place, Bedlam to the Museum, will provide a welcome and much needed facility.
Wider pavements and other additional pavement space are an integral and very much needed feature of the concept proposals, and we look forward to the detailed development of these proposals.
There remain nonetheless some pavements where widths that are sub-standard remain; specifically along the Mound beside the RSA and National Galleries, and in Bristo Place. The space available at the east side Hanover St junction with Princes St also remains inadequate for the intense concentrations of pedestrians wanting to cross there.
The Mound galleries section is a particular concern. It is only ~ 2m wide, in contrast to the 3m minimum desirable width specified by the Council’s Design Guidance. This pavement serves many pedestrians, especially at peak seasons for visitors. Those numbers can only be expected to increase, and a wider pavement should clearly be provided here. It would also be running alongside the proposed 3m wide cycleway serving many fewer cyclists, unless that section is modified to allow downhill cyclists to use the carriageway. Such a modification would have the added advantage of making it easier to accommodate the widened pavement that is needed.
The Bristo Place east side pavement is only ~ 2.5m wide, and can be expected to have to accommodate substantially more pedestrians if the relocation of the Forest Rd bus stops to Teviot Place goes ahead. We would therefore wish to see a wider pavement included here in developing the detailed designs. All the more so, and essential, if a loading area is to be part of the design. From the exhibition drawings it would appear that a loading area is envisaged that overlaps with the existing pavement, and would take up most of the existing pavement width! This would be totally unacceptable for pedestrians.
It is claimed that a SUSTRANS analysis concluded that “all pavements reach the desired comfort level of the Edinburgh Street Design Guidance”. It is difficult to understand how this conclusion could have been reached in regard to these particular sections of pavement, and we can only surmise that the analysis was undertaken at an off peak time of year and with no allowance for the increases in activity that are to be expected over the years to come. We would like some clarification on this and would appreciate the analysis being made available.
The numbers of worshipers arriving at the wee dug’s statue, to stand and stroke and photograph him, have long resulted in severely obstructed space for pedestrians with crowds spilling over into the carriageway much of the time. The increased space it is proposed to provide will help to alleviate the current conditions, but will not eliminate the problems. Those problems moreover can only be expected to grow as the numbers of tourists continue to increase. It is surely therefore time, in association with this project, for Bobby to be provided with a new home, away from the street and safer for all concerned. Preferably perhaps this should be in Greyfriars Kirkyard, where he can be re-united with his master and where the worship can take place in appropriate peace. Please make him party to the project too.