LSEG: Comments on the City of Edinburgh Council’s Draft Public Transport Action Plan 2023

introduction and Summary

We broadly support the new draft Public Transport Action Plan and the central aim to increase modal share of public transport. Good environments for walking (and wheeling) are absolutely fundamental to successful public transport systems because (as acknowledged in this draft Plan) virtually every public transport journey (certainly for bus) begins (and ends) with a pedestrian phase.

However, as with other City Mobility plans (such as for Active Travel, Parking and Road Safety), we think that many of the proposed actions are too slow, too vague – and possibly too numerous. The proposals – and especially the envisaged timescales – cannot possibly deliver the scale of change needed to achieve the 2030 target of a reduction of car travel by 30%.

Delivery of essentially sound plans has been problematic for the Council for at least a decade and we suggest that the 40 “actions” should be reduced to the most important ones so that budgets, staff time and energy are directed to the most effective measures. Accordingly, we suggest that several ‘actions’ could be omitted: around ‘Behaviour change’ (PC1), MaaS (PT12), ‘Data Driven Innovation’ (PT13) and City Centre Transformation (PV 1 and 2) for example. We would favour a tighter focus on tangible service improvements to bus priority and public realm infrastructure including bus stops.

Safety and Accessibility

We welcome the intent to improve access to bus and tram stops (PT1), but the action should be more ambitious, in line with the EASI (Edinburgh Accessible Streets Initiative) outlined in the draft ATAP.  The focus on improved lighting is welcome, but other aspects of the quality and accessibility of pedestrian routes to stops need to be included too. Previous versions of the ATAP included targets (not delivered) to improve at least 20 routes a year to public transport stops and we would like to see a similar target maintained.

Bus Services

We strongly support the proposed measures to give buses more priority, particularly through PG3, PG4 and PG6. We want to see early implementation of the 7-7-7 model of enhanced bus lanes (bus lanes operating seven days a week, from 7.00am to 7.00pm). It should be noted that bus lanes also give significant improved protection to cyclists from other traffic. We would like to see the Plan say more about enforcement of bus lanes (and protection of bus stops from parking). We welcome the PG4 intent to give buses priority at signals and suggest that this should also consider enhanced pedestrian priority ‘ABC’ measures outlined in the ATAP.

We welcome the various references to the Bus Service Improvement Partnership and the Council’s intention to access the Scottish Government’s £500 million fund to promote bus use. However, we would like to see a clear explanation of what the Council’s plan is for this fund (or a date when it will be produced).

On the other hand, we do NOT support the notion of seeking to stop buses crossing the city (“to not through”, referred to on page 32); and we suggest that the action referring to ‘bus stop realignment’ (PG5) should be deleted. Bus stops which are unnecessarily close together can be removed but a wholesale programme to review the spacing of bus stops is unwarranted and would be a waste of valuable staff resource.

Bus stops

The plan does not give enough priority to the need to improve bus stops. PT7 focuses solely on ‘continuing bus shelter replacement’ which is inadequate. We need to improve the standard of bus shelters and seats. Crucially, build-outs (sometimes termed ‘boarders’) are needed at many bus stops. These ensure that passengers can have level boarding onto the bus, act as a strong deterrent to stopping/parking at bus stops and provide more space on the pavement for pedestrians to pass. The lack of such a programme is a serious omission in the plan at present.

The Plan (like the ATAP) is silent on the conflict with pedestrians which can be introduced at bus stops by cycle infrastructure. ‘Floating bus stops’ undermine the confidence of some bus users, especially blind people, to the extent that some people will avoid using them altogether. Their value in terms of providing priority and safety to cyclists needs to be balanced against the risk to pedestrians/bus users. We consider that the best way to manage these conflicts is to use floating bus stops sparingly: only where the case for cyclist safety is especially compelling. This may mean, for example that they should not be used in low-speed or low traffic streets (certainly, for example, where bus gates significantly reduce general traffic).

Trams

Living Streets Edinburgh has been a strong supporter of the tram for many years. However, with the welcome completion of the Newhaven extension, it would be prudent to pause and consider whether future major developments should take the form of tram or ‘Bus Rapid Transport’ (BRT). The cost, disruption and amount of public space taken up by the trams (which are poorly integrated with bus stops) are significant downsides. We note an inconsistency in the draft Plan which should be clarified: in the text, the section on Mass Rapid Transit (PR6) refers to a “mass rapid transit solution” which could be tram or BRT. However in Appendix A, PR6 refers only to tram.

Living Streets Edinburgh Group

June 2023