All posts by Living Streets Edinburgh

Low Emissions Zone – LSE Response

Living Streets Edinburgh Group (LSEG) welcomes the Council’s plans to move forward with introducing a Low Emissions Zone (LEZ) in Edinburgh but we are concerned that the current proposals are not sufficiently ambitious and will have a serious detrimental impact for some residents, particularly those that live outside the boundaries of the currently proposed City Centre LEZ. We strongly believe that the boundaries of the LEZ should be increased in order to benefit a larger proportion of the residents of Edinburgh.

The area of the proposed LEZ currently covers only 2.5% of the City and excludes many areas of the City with the greatest density of residents. It will also not include the designated Town Centres, which form such an important element in the development of 20-minute neighbourhoods outlined in the recently approved City Mobility Plan. In setting the boundaries of the LEZ, more consideration has been given to providing convenient diversionary routes for non-compliant vehicles than maximising the health benefits for people living in Edinburgh. Pollution levels have been considered on an absolute basis without any consideration of the number of people that will be exposed to that pollution. LSEG is particularly concerned that there is no recognition of the risks to pedestrians from vehicular emissions in areas outside of the proposed LEZ; some of which have very high levels of walking including children walking to school.

The Council report that was considered by the Transport and Environment Committee at their June 2021 meeting states non-compliant vehicles will increasingly use the roads immediately outside the LEZ resulting in increased pollution on these routes. The SEPA forecast attached to the report shows an increase in atmospheric pollution on Queen Street, London Street and Abbeyhill; all areas on the edge of the currently proposed LEZ. We note that the Council has included an objective to “minimise the impact from traffic displacement across network, related to LEZ scheme”. No detail is provided on the mitigating actions that will be taken or how achievement of this objective will be measured. Before any final decision is taken on introducing a LEZ it is critical that there are clear plans in place to limit the negative impact of displaced traffic to reassure residents living near the LEZ.

The current plans are focussed on reducing levels NOx pollution from vehicles within a small part of the City to meet current legislative limits. In our view, this goal does not go far enough. Other forms and sources of pollution need to be both more closely monitored and reduced, in particular the levels of particulate pollution and continued use of temporary diesel generators within the LEZ. We would like to see the Council setting more ambitious and wide ranging targets for reducing pollution given the accepted health benefits of such a reduction. This is the time for bold action that supports the Councils plans to encourage walking, wheeling and cycling across the City.

Despite the title of a ‘low emission zone’, the proposals do not address the need to reduce carbon dioxide emissions. Plans that only address pollution are essentially backward looking, whereas we should be looking forward to a future where fossil-fuel vehicles are completely eliminated and levels of all motor traffic are reduced.

Finally, while we recognise that the plan includes proposals to encourage compliance with the new restrictions for vehicles entering the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. In the case of idling vehicles, it would be clearly wrong to turn a blind eye to such behaviour while at the same time introducing the significant controls required by the LEZ.

Finally, we note that the enforcement regime will be based on the use of automatic number plate recognition (ANPR) cameras. From our review of Appendix 7 of the report presented to the 17 June 2021 Transport and Environment Committee meeting, we note that the recommended approach is to install these cameras on only 16 routes of the identified 48 entry points to the City centre LEZ. One mobile unit will cover the other 32 entry routes. Given that the LEZ is intended to operate 24/7, we are concerned that this approach will affect the levels of compliance required for the LEZ to achieve the intended reduction in atmospheric pollution and health benefits for those living and working within the City centre. We are further concerned that this approach will encourage the drivers of non-compliant vehicles to use the non-arterial routes to avoid detection thus increasing traffic further in the many residential streets bounding the proposed LEZ. We believe that to achieve the required compliance for the success of the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. We do not believe that the currently proposed arrangements are adequate. 

CAMPAIGNERS SLAM ‘HOPELESS’ LEITH WALK PAVEMENTS

Campaigners for better walking in Edinburgh have slammed the plan for pavements alongside the tram on Leith Walk as ‘hopeless’. It has emerged that the pavements, which are being rebuilt as part of the tram works, will be so narrow that in many places they don’t even meet the council’s own standards for minimum width. The campaigners have been told that over 250 metres of footway,  in 11 different sections, will be below this minimum – in one place (just north of the Pilrig Street junction) as little as 1.8 metres wide.

David Hunter, Convenor of Living Streets Edinburgh Group said: “We’re incredibly disappointed to learn of the hopeless final design for many sections of Leith Walk’s pavements.  These pavements should be at least 3 metres wide, with a stipulated minimum of 2.5 metres.  As the main link between Edinburgh and Leith, and an important local street in its own right, Leith Walk needs quality pedestrian space. We are big supporters of the tram project, and welcome the benefits it will bring to people walking in other places. But having engaged with the tram team regularly over the past two years, it’s a bombshell to hear – right at the point of construction – just how poor the the street will be for pedestrians.

This is frankly unacceptable and at odds with the repeated claims that “walking and wheeling” are top of the ‘Sustainable Travel Hierarchy’, both in Edinburgh and in Scotland as a whole. Even at this, the eleventh hour, we’re calling on the council to revisit the plans to give pedestrians the space they need.”

Climate Strategy consultation – Response by LSE

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 as a safe, enjoyable and easy way of getting around the city. We welcome the opportunity to respond to this consultation, which reinforces the need for a number of our ambitions for the city such as to:

  • reduce the volume, size and speed of traffic
  • encourage planning policy to make walkable (’20-minute’) neighbourhoods
  • provide access to green spaces, inclusive environments (for disabled/older people etc)
  • enable walkable commutes to schools and workplaces, businesses (incentives?)

Section 3 – Vision

4)

Vision              AGREE

Principles        AGREE

Actions                        AGREE

5) Comments and suggestions:

Vision Charging hubs will need to be sited and designed very carefully should they not introduce new, additional hazards for pedestrians i.e. by increasing already problematic pavement clutter or leading to charging cables lying across walkways.

Principles We are encouraged to see that travel is mentioned in the Vision and Actions of the strategy but are concerned that it does not feature in the principles.  None of the principles can be met without wholesale changes to the movement of people and goods around the city.  A 20-minute neighbourhood for instance will only be possible if walking is made easier and more attractive.

Actions Whilst we welcome ’prioritising investment’ in expanding walking routes this is not ambitious or specific enough.  The actions should explicitly state which measures will be taken to make walking an attractive and accessible mode of transport i.e. wider pavements, removal of road-related clutter from pavement space and priority for pedestrians at road crossings.  Including more targeted/specific milestones would also be welcome.  Lastly, we question how the whole city can become net zero by 2030 if only TWO neighbourhoods will have been piloted by that time?

Section 4 – Citizens

6)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

7) What other actions could help you make sustainable choices?

Other positive actions include explicit and practical steps to facilitate walking and wheeling as a means of transport – vital to the 20-minute neighbourhood concept.  These actions would be removing clutter (e.g. unused or un-necessary signposts and poles or boxes) from pavements, removing other obstacles on pavements (i.e. illegally parked vehicles, illegally placed planters, chairs, tables and other business paraphernalia), extending green man times at signalled crossings, increasing all forms of pedestrian road crossings (esp. Zebra crossings), reducing traffic speeds (through narrower roads and enforcement of the 20mph speed limit), keeping hedges AND roadwork signs off pavements and ensuring minimum widths are maintained (especially during development and construction works). All this will require a dramatic improvement in routine street maintenance.

8) What barriers limit you from taking climate action?

9) Information about barriers?

10) How should citizens be involved in governance of the strategy?

Perhaps prioritisation to concerns of most vulnerable or marginalised citizens of the city?  i.e. poor, disabled and ethnic minority groups.  School pupils and young people could also be prioritised given that regrettably it is their climate to inherit… To (literally!) “walk the talk” a major programme on encouraging safe travel (especially walking) to school is needed (see later).

11) Other suggestions on engaging and empowering citizens

Transport is a huge source of carbon emissions.  If citizens are to reduce their footprints then it has to include more walking.  More citizens will walk (or wheel) further and more often if it is made safe, attractive and accessible.  This requires a reallocation of space, investment and attention from inefficient and polluting modes of transport like personal, private car use to walking, cycling and public transport.

Section 5 – Development & growth

12)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

13) Comments/suggestions:

Next Step (NS) 3 needs to recognise and prioritise the needs of pedestrians and other pavement users.  NS4 needs to recognise pedestrian needs –  too often during development and construction works the interests of pavement users are overlooked, sidelined or neglected.  Thinking also about how new developments can be reached on foot or on wheels would help many more switch to a more sustainable mode of transport.  NS5 needs to redesign infrastructure too (not just services); amenities need to be accessible on foot if the 20-minute neighbourhood is to be realised.  NS6 also needs to recognise that net zero housing developments will require adequate (i.e.  wide, pleasant and connected) pavement networks with easy and regular road crossings.  This should then be included in the demonstrator project of NS7.  Again the NS13 development will have to be accessible and navigable by pavement. Far too often, current Planning activity fails to secure S75 funding to improve the walking and wheeling environment.

14) What is LSEG doing for net zero, resilience and growth?

N/A

Section 6 – Buildings

15)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

16) Comments/suggestions

Strategic approach Given that “the greenest building is one that is already built”, we should discourage the construction of new, cheap, short-lasting buildings as is so common with student housing for example.  in the necessary building work to transform the buildings VITAL adequate provision given to pedestrians i.e. adequate space on both sides of the carriageway AND crossing points AND no signs on pavements etc.

17) What is LSEG doing in relation to net zero generation and energy efficient buildings?

N/A

Section 7 – Transport

18)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

19) Comments/suggestions

Outcomes In addition to making foot, wheel or bike the easiest and cheapest travel option a key, and currently missing aspect is that it should be the SAFEST option too.

Next steps great for EV advocates and public transport users but not currently enough listed for pavement users: priority at crossings, reduced (electric) vehicle speeds, reducing the size and volume of traffic (even once electrified).  For example, in line with the City Mobility plan and City Centre Transformation plans, removing large vehicles like bin lorries from as many city streets as possible. Further even those using public transport require need safe, usable and connected routes to and from bus and tram stops as well.  NS8 mentions a Workplace Parking Levy but none of the next steps explicitly address the School Run – what will be done to disincentivize driving cars to schools and opting to walk or wheel there instead?

We need a specific plan to encourage safe and sustainable travel for children to every school.  Edinburgh has one of the highest proportions of children walking to school at 61% (Scottish average 52% – TaTiS, 2019). This plan should include car-free areas and/or much wider pedestrian spaces at school gates.

20) What is LSEG doing in relation to net zero transport?

N/A

Section 8 – Businesses and skills

21)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

22) Comments/suggestions

Outcomes should be expanded to recognise that workers and consumers can participate in the city’s circular economy by foot or wheel.

Next steps NS3 businesses could reduce their emissions by encouraging and rewarding staff, customers, clients and partners to reach premises by foot or wheel.  One practical step to realign operations towards net zero would be to ensure premises are accessible by pavement and ideally incentivise all parties to use pavements.

A big omission in the plan is the approach to tourism. A complete review of tourism policy, post-pandemic, is needed to emphasise sustainability and inclusion. This would include travel. such as to reduce reliance on long haul inbound touring from overseas (to reduce air travel) and housing (avoiding over-provision of short term letting).

23) What is LSEG doing in relation to business and skills?

N/A

Section 9 – Investment

24)

Strategic approach     AGREE

Outcomes                    AGREE

Next steps                   AGREE

25) Comments/suggestions

Next steps NS5 should include Active Travel too if EVs are to get their own mention outwith the transport category then the preferable, lower carbon, option of walking/wheeling also needs to be explicit especially because the capital costs required, relative to the emissions saved per journey are much better from walking and other forms of active travel. Investment must reflect national and local ‘transport hierarchies’ – with walking and wheeling at the top – which it consistently fails to do at present.

26) What is LSEG doing in relation to investment in change?

N/A

Section 10 – Offsetting

27) Does LSEG currently offset emissions?

N/A

28) Do you think offsetting should…?

Other – be dealt with at all levels

29) What opportunities could a city-wide approach contribute?

The payments received could be put into active travel programmes – measures that will reduce rather than reallocate emissions.

30) What risks could a city-wide approach present?

A city-wide approach risks allowing for continued car and polluting vehicle/practices use by individuals and businesses/organisations.

Section 11 – Decision making

32) Comments/suggestions

Current processes are lengthy, sometimes extremely so.  Further, given the inequalities in the city’s current transport system (allocation of space and risk/safety due to the dominance of private motor vehicles) we would advocate for greater consideration to be given to the views of the most vulnerable modes of transport i.e. walkers and wheelers as well as people who cycle and public transport.

I am not sure we could say current processes are OK. There doesn’t seem to be enough weight given to all types of active travel, and the decision making process does seem extremely lengthy at time.

Section 12 – Equality and diversity

33) Positive impacts

If the strategy proposals lead to the realisation of 20-minute neighbourhoods across Edinburgh (not just in 2 pilot communities) then elderly and disabled groups will potentially benefit as well as those from poorer areas and lower income households.  If walking or wheeling, the cheapest, most sustainable mode of transport, is made pleasant, accessible and crucially safe then the city will be a more equal place because more of its citizens will have ready access to the services and facilities they need. The Council needs to demonstrate its commitment to inclusive travel and mobility through its actions in order to overcome the current significant levels of scepticism.

34) Negative impacts

The repeated mentions of provision for Electric Vehicles suggest that those who cannot afford, don’t have access to, or choose not to use an EV will benefit less from the strategy than those who do.  Similarly, although EVs produce less pollution than petrol/diesel powered vehicles their introduction does little to address the size, volume and speed of road traffic – it is these three dimensions that are crucial when organising to make walking and wheeling more attractive, accessible and safe.  For short journeys (i.e. within the 20 minute neighbourhood) there is no lower emitting mode of transport than walking or wheeling.

While we recognise the emphasis on engaging schools for training and skills programmes there appears to be a gap concerning journeys to and from schools in the city.  A negative impact of the strategy as it stands is that businesses, developers and investors benefit more from the proposals than students and young people who need clean, safe routes to school.

LSEG

August 2021

Tackling Pavement Clutter: Concluding Report by Living Streets Edinburgh Group

Introduction

In 2019, Living Streets Edinburgh Group launched a major project to tackle pavement clutter; this essentially had three distinct phases. The initial phase involved trying to understand what is ‘pavement clutter’, what causes it and what the council (in particular) can do about it. We identified 293 items (original target 100!) and reported this to the council.

The second phase of the project involved production of a report and video in 2000 to share awareness of the project and the problem that pavement clutter causes more widely. These resources and further links can be accessed on our website here: https://bit.ly/38GtAVW. We are grateful to both the City of Edinburgh Council and Paths for All for their support and funding (Smarter Choices Smarter Places).

However, until 2021, very little action had been taken to actually remove pavement clutter, including the 293 items which we originally identified. It was not until January 2021, after persistent lobbying by LSEG, that the City of Edinburgh Council identified a specific budget (£300,000) to remove unnecessary pavement clutter, as part of the Spaces for People scheme. By June 2021, when the scheme ended, the Council reported (https://www.edinburgh.gov.uk/cuttingstreetclutter) that the following items had been removed:

226 bollards
139 signs and poles
300m of guardrail
64m of barriers
18 large car park signs
2 cycle racks

This has been very welcome; however there has been a degree of mis-match between the clutter removed by the Council and the main types of problem identified by our own ‘Cut the Clutter’ report: the latter found that the most prevalent problems were signage / poles, followed by vegetation, bins and then guard rails. The first and last have been tackled by the Council, but not the widespread problems with vegetation and bins. Bollards did not figure as a problem in our report, but appear to have been the Council’s main focus.

We were delighted that Living Streets took our local campaign to a national (UK) level (https://www.livingstreets.org.uk/get-involved/campaign-with-us/cut-the-clutter). We hope that this will contribute to a change in culture among the professional roads community nationally which values clear pavements more highly. Of course, there are also other important changes needed to streets which are connected to pavement obstructions – notably, the need for wider footways (the problem of clutter being especially severe where pavements are narrow – as too often in Edinburgh). There is a fundamental need to reallocate road space from vehicles to pedestrians.

However, this paper aims to draw our current project on ‘tackling pavement clutter’ to a conclusion by recording some specific ‘lessons learnt’ and by making a number of detailed suggestions to the City of Edinburgh Council for better management and reduction of pavement clutter in the future. Despite the welcome progress by the council in removing clutter noted above, only £180,000 of the council’s Spaces for People budget was spent; and hundreds of items of clutter, both fixed and temporary, continue to litter Edinburgh pavements.

Recommendations

1) Request a report to committee reviewing the approach to identifying managing and removing pavement clutter. The aim should be ensure council practice follows best practice including the Edinburgh Street Design Guidance (ESDG), the communal bin policy and the statutory Traffic Sign Regulations and General Directions (TSRGD 2016, which specifically aimed to reduce signage clutter).

Key recommendations should be to:

  • ensure that new clutter – especially signage poles – is minimised (saving money as well as protecting pedestrian space),
  • ensure that decluttering is an integral part of all routine road maintenance operations
  • establish a dedicated decluttering budget as part of the new Active Travel Action Plan
  • put in place a stronger street management regime, with a clear focus on surveys, monitoring and enforcement.

2) Request that the council shares widely our ‘Cut the Clutter’ video/report among staff, contractors and other stakeholders; reinforce through internal training.

3) Utility companies (especially telecoms) – ask for the council to take a tougher line on the location of cabinets etc.

4) Phone kiosks – engage with BT to maintain damaged phone kiosks and remove unneeded ones (collaborating with appropriate national groups, including Living Streets, either in Scotland or ideally across the UK).

5) Royal Mail – establish where postal ‘holding boxes’ are no longer used and ask for removal (again, collaborating with appropriate national groups, including Living Streets, either in Scotland or ideally across the UK).

6) Roadworks – use existing agreements with utility companies, liaison with the Scottish Road Works Commissioner etc to improve the enforcement of statutory roadworks guidance standard of roadworks, to reduce signage clutter on footways etc. CEC should also press the Scottish Government for the stronger powers (including tougher penalties) that would make such action cost-effective.

7) Hedges/vegetation – council to initiate a programme for monitoring/cutting back hedges. Involve residents, community councils, etc. with the aim of residents understanding the problems caused by encroaching vegetation, and taking action themselves.

8) Bollards – remove where unnecessary, unless specific safety requirement. But take into account risk of pavement parking and also introduction of pavement parking ban, possibility of enforcement through ANPR camera etc.

9) Guardrails – remove unless there is a specific safety requirement which justifies their retention; for example at schools gates. A systematic process of assessment and removal needs to be continued, within a fixed timeframe, until all guardrails citywide have been covered.

10) Cycle parking – in line with new detailed Street Design Guidance adopt a presumption that cycle parking is to be located on carriageway rather than footway.

11) Goods /merchandise on display – need for co-ordinated action to enforce Section 129(9) of the Road Scotland Act 1984 which forbids the placement of goods for sale on the public sections of the street.

12) Bins – ensure domestic and commercial bins do not encroach onto pavements, or block crossings (especially where ‘dropped’) etc.

13) Tables and chairs outside cafes and restaurants – Following the pandemic, re-assess permits (many of which will have been granted a long time ago) to ensure that the balance is right between clear, safe walking space for pedestrians and the amenity offered by outdoor eating and drinking facilities.

14) Signage: generally, signs should not be mounted on their own poles unless absolutely necessary. There should be a presumption against some specific types of sign:

  • “No loading” (without time limit – no longer policy/required);
  • All signs on double poles;
  • Pairs of signs/poles on each side of the road – eg for ‘dead end’ sign, 20 mph etc (single signs have been legal/recommended since revision of TSRGD in 2016);
  • Repeated bus lane signs;
  • ‘City centre attractions’ (usually on double poles – replace with smaller ‘city centre’ sign on lamp posts);
  • ‘Temporary’ signs mounted on 1000kg yellow concrete blocks should be discontinued (they are often in place year after year). They should generally be mounted on lighting columns etc.

15) Other signage policy to be reviewed:

  • Cycle lane signs only to be attached to existing lighting columns etc (not mounted on separate poles);Review size (and number) of Controlled Parking Zone signs ;
  • Review the need for Greenways signage as part of a renewed bus priority strategy – for example “No Stopping at any time” signs which are very common in many streets;
  • Remove remaining obsolete parking real time displays (eg Dalry Road at Haymarket) and redundant VMS signs;
  • Remove ‘Safer Routes 2 School’ signs erected circa 2000;
  • Clear away old yellow housing development signs;
  • Review all ‘new roundabout ahead’, ‘new junction ahead’ signs – many have been in place for years; IT systems should flag up all such signs for automatic removal after (at most) 2 years;
  • Review need for large directional traffic signs, invariably on double poles, and in line with increased use of Satnavs etc.
  • Many street signs have their own lighting – but this is no longer required in most case (by law). Can we have a wholesale review to reduce the number of lit road signs (replacing them with reflecting surface) to reduce maintenance costs, energy consumption, etc?

16) Ensure that the risk of new types of clutter – for example from e-scooters or EV charging points – is identified and managed to ensure pedestrian interests are protected.

Living Streets Edinburgh Group
August 2021

21/02941/PPP Gogar Link Road/Active Travel Route

Comments offering observations and suggestions.

The supporting planning statement indicates that the proposal “will also serve to improve active travel links within the wider area.” Within the boundary of the scheme, this does not appear to be the case. The link will however improve active travel links to HSG19 and HSG 20. The most direct active travel routes for the existing communities East of Maybury road will continue to be via Maybury junction on Glasgow Road which is dangerous and exposed to air pollution.

Living Streets ask the Council if there is an opportunity to work with the West Craigs developers to see if there is scope or feasibility for junction and crossing improvements of active travel links South and East of Edinburgh Gateway station.

There is also a concern that the proposals will encourage motorised users to use the link as an opportunity to avoid busier junctions such as the various other road approaches onto Gogar Roundabout.

We also ask if there is an opportunity to re-design the route layout to ensure a more direct route to the rail crossing to HSG19 and HSG20 and Myreton Drive. The current design indicates that the route is made unnecessarily longer for those wishing to walk or cycle to IBG.

We support the proposal’s inclusion of segregating cyclist and pedestrian users