Living Streets is the UK Charity for Everyday Walking. Living Streets Edinburgh Group aims to promote walking as the safe, enjoyable and easy way of getting around Edinburgh.

These comments on this application are from Living Streets Edinburgh Group.
https://www.livingstreets.org.uk/get-involved/local-groups/edinburgh

Scottish Planning Policy clearly sets out the hierarchy for transport modes (para 273) – walking, cycling, public transport and finally private cars in that order. It goes on to say that planning permission should not be granted for significant travel-generating uses (para 287) at locations which would increase reliance on the car, where walking and cycling networks are not available, and where public transport to local facilities involves walking more than 400m. Designing Streets: A Policy Statement for Scotland reinforces this policy and clearly states (pg15) that the street user hierarchy should consider pedestrians first and private motor vehicles last. The National Transport Strategy states (pg5) that walking, cycling and shared transport take precedence ahead of private car use. It goes on to illustrate this position with reference to The Sustainable Travel Hierarchy (Fig14 pg43) – walking and wheeling, cycling, public transport, taxis & shared transport, private car. So, the Scottish Government position is quite clear that people walking and wheeling are the priority, with the expectation that this is delivered by developers and local authorities via their planning and highways functions.

The City of Edinburgh Council Local Development Plan 2016 does not articulate or follow this national policy as it should, but there are references within it to providing for walking and cycling, new road space not encouraging greater car use, bringing accessibility by and use of non-car modes up to acceptable levels, opportunities for ‘car free’ housing developments e.g Policy Des 7, Policy Tra 1, Policy Tra 2. The Council has adopted Street Design Guidance which has much useful content and is stated as embracing Scottish Government’s Designing Streets document, but it is not always adhered to in practice.

The recent consultation on CityPlan 2030 has highlighted a wide preference for development of brownfield sites, greater provision for walking and cycling, reduced use of private cars and less car parking provision. The Council is currently proceeding to draft the next Local Development Plan on this basis and in 2020 stated that ‘pedestrians are at the top of the urban transport hierarchy.’

The COVID-19 pandemic, although a dreadful event, has provided an opportunity for people to take stock and consider what is important to them. There have already been changes to the way we all live and work, and the likelihood is that much of this, as reflected in the CityPlan 2030 consultation, will be here to stay.

Scottish Government Policy has clearly articulated walking as a priority for several years, whist developers and the Council have at best paid it lip service and often ignored it completely. Now that emerging Council planning policy and public expectations are becoming aligned with national policy it is vital that the opportunity is taken to reset the clock and reflect this in all planning decisions.

Having set out the context for consideration of this application, and without commenting on other non-walking aspects, Living Streets Edinburgh Group makes the following constructive comments:

• The location of the site in Portobello is extremely accessible by walking, cycling and public transport.
• The site adjoins the seafront and is accessed by a network of narrow streets already congested with parked vehicles.
• The additional vehicle movements will compound an existing unsatisfactory situation when there is no need to do so.
• The site therefore justifies a car free development which is permitted by Council policy and it is requested that approval is only granted if the parking spaces are removed, other than for disabled parking, and this will in turn give scope for more landscaping and amenity space.
• The Council now acknowledges that pedestrians are at the top of the urban transport hierarchy, so to accord with Council expectations the proposals must reflect this position.