Category Archives: Consultation Response

Dalry Living Well – LSE Comments

20 minute neighbourhood, Consultation Response, News,

Introduction

Living Streets Edinburgh Group welcomes the opportunity to respond to the consultation on ’Dalry Living Well Locally’. [1] We strongly support the concept of the ’20 minute neighbourhood’ – with the philosophy that most everyday services and needs are located on your doorstep and reached within a c.20 minute round trip walk. We recognise that the idea is in its infancy and that quite what a 20 minute neighbourhood looks like is still subject to debate.

To be successful, a “20 minute neighbourhood” needs to provide high quality infrastructure for pedestrians. We are thinking here not just of the fit and able, but the mother wheeling a pushchair and leading a toddler; the elderly who are finding walking more difficult and maybe using a wheeled aid; the users of wheelchairs and powered mobility chairs. A major concern with the proposed scheme is that a high-quality pedestrian infrastructure is not provided consistently throughout the area.

In this context, we do have serious misgivings about the approach proposed by the City of Edinburgh Council both with regard to the overall concept, and to design details, which we outline below. We hope that these comments will help the council to develop an improved vision of a ’20 minute neighbourhood’, and what features should be included in the Dalry scheme.

Overall concept

We are surprised at the scale of the project – from Haymarket to the Westfield area of Gorgie. This is over a mile long and is in our view far too large to be considered as a local neighbourhood, even accepting that this is proposed in separate ‘chunks’ (this section being from Haymarket to Tynecastle High). We would prefer to see designs based on much smaller neighbourhoods, such as the ‘town centre section’ in this scheme (from Caledonian Road to Dalry Place).

The scale of the proposal suggests that the project is envisaged more as a travel corridor than a neighbourhood improvement. If the mantra of ‘place not movement’ is to have any meaning, surely it must be for a neighbourhood placemaking scheme? The Council commissioned a ‘Public Life Assessment’ of Gorgie Dalry in 2016, presumably at significant expense, which includes a lot of useful, detailed observations and suggestions for placemaking. [2]  We see little or no influence of these suggestions on the scheme and recommend that it should be revisited.

One consequence of the ‘travel corridor approach’ is that, apart from the small ‘town centre’ section, there appears to be a perceived need to include segregated cycle ways along the whole route (because it is conceived more as a ‘route’, than a ‘place’). While we of course want to see more and better facilities to encourage cycling, this is problematic in that it forces compromises to be made in all other uses of the street and modes – including walking and wheeling. This contradicts the ‘sustainable travel hierarchy’ and in some respects, mirrors the widely-discredited approach taken in Leith Walk.

Another consequence is the bus gate at Haymarket, which will stop motor traffic other than buses and taxis using Dalry Road in the daytime. We certainly want to see less traffic on Dalry Road and other busy residential streets, and agree with the strategy to divert as much traffic as possible onto the Western Approach Road. We recognise that there is a case for a bus gate to achieve this. However, we would want to understand much more about how much traffic will be diverted to other streets, and where. The closing of such major road artery to general traffic will have significant consequences for traffic across western Edinburgh, especially given the 1.5 ton weight restriction on the WAR.

Requiring general traffic from the east, as well as the west, to access Dalry Road at the Ardmillan Terrace junction will put enormous pressure on this junction and we are sceptical that it will be able to cope. There is also the issue that traffic entering Dalry Road from the west will need to do U-turns and exit the same way, putting further pressure on this junction. And of course, where will traffic including HGVs, bin lorries, etc.perform these U-turns safely during the restricted hours?

Finally with regard the bus gate, we know that the ’15 minute city’ concept has been subject to numerous conspiracy theories claiming that it is designed to stop people travelling outwith their neighbourhood. These concerns have broadly been dismissed, emphasising that the concept is rather about providing better access locally, The restrictions at Haymarket will affect all drivers (those who need to drive equally as much as those who have other options) and is likely to add weight to those conspiracy theories rather than dispel them.

Apart from the bus gate, the other particularly challenging aspect of the scheme will be parking. We strongly support the removal of all general parking from Dalry Road itself – this space is too valuable to be occupied by private car parking – although there will of course, need to be appropriate provision for loading and for blue badge holders. However, densely populated, tenemented streets have very little off-street parking available, in contrast to other areas of the city where many houses have driveways and garages.  Parking spaces are at a premium in Dalry. The local community may accept reduced parking capacity on Dalry Road more easily if some additional off-street parking – for example at the under-used Lidl car park? – can be found.

Details

We are pleased to see the plan feature a number of wider footways, especially in the central ‘town centre’ section. Adequate pavements should be the absolute priority of a ’20 minute neighbourhood’.  Similarly, we like the provision of seating, trees and sustainable drainage facilities, all of which will greatly enhance the town centre. The use of continuous pavements giving pedestrians priority at side roads is also very welcome as are numerous opportunities to cross Dalry Road, including the welcome use of zebras.

This ‘town centre’ section is the part of the scheme which in our view works best. If the scheme is to broadly remain in its current form, we suggest that it should be extended at least to include Dalry Primary School in the west and eastwards to Haymarket.

We are however, very disappointed that other sections of pavement do not meet these standards. There are long sections of pavement which are currently well below the council’s own ‘absolute minimum width’ of 2 metres as specified in the council’s own street design guidance. This is most obvious on the south side of Dalry Road at the cemetery. It is frankly inconceivable that these plans do not intend to address this: if inadequate pavements are not going to be improved in a scheme like this, they will never be. We have seen this failure to meet minimum standards in several other ‘sustainable travel schemes and this undermines the Council’s professed commitment to the sustainable transport hierarchy. We also understand that there is no widening of the extremely busy pavements towards Haymarket.

There are ten bus stops along the route, five on each side and of these eight will be of the ‘floating’ design, requiring passengers to cross a cycle way immediately when boarding or alighting. This design is known to present significant difficulties for blind and disabled people especially.  The explanation that “Bus stop bypasses will mean that bus users will not have to wait on the main pavement and allow pedestrians and cyclists to safely pass” is misleading at best: they offer no advantage whatsoever for pedestrians. The space at some of the bus stops is so constrained that we understand they do not conform to the Council\s own Design Guidance and have no shelters. We would like to see normal bus stops which do not require pedestrians to cross a cycle way throughout.

We have significant concerns at the suitability of the Ardmillan Terrace junction design, although we completely agree that it is dysfunctional at present. These concerns relate not just to the capacity as noted above, but also we query why a ‘CyclOps’ (‘cycle-optimised’) design is appropriate here, rather than one which gives pedestrians priority. Again, we believe that many pedestrians, including older people and those with visual impairments will find this junction hard to cross, as they will have to cross not only the road but also cycle lanes, sometime several times, in order to get to the other side. It is also not clear what pedestrian ‘wait times’ will be.

It must also be acknowledged that disabled people’s parking opportunities will be limited by the extensive use of segregated cycle ways. The Council has just established an Accessibility Commission, designed to “ensure the city’s streets are as accessible as possible to disabled people”. It is paramount that these concerns about the ability of disabled pedestrians to use the proposed streets are addressed.

Finally, we are very disappointed that our suggestion to develop a new western access point to Haymarket Station, probably from Distillery Lane, does not form part of the proposals. This would bring the station much closer to the Dalry community and encourage its use by pedestrians and cyclists. We understand that this has been explored and is supported by the Scottish Government, Network Rail and Scotrail in principle. We recognise that there are challenges (ownership of Distillery Lane, funding, etc.) but we believe that this is feasible if there is the will to bring partners together. We urge the Council to pursue this unique opportunity which will not come around again.

Conclusion

We support the broad aims behind the proposals – to enable the local community to access their needs and service easily and sustainably and to reduce the dominance of Dalry Road by traffic. However we think that there are very significant problems with what is being proposed; some of these are matters of detail, but others fundamentally stemming from a flawed vision of what a ’20 minute neighbourhood’ should be.

We would therefore encourage a fundamental re-think of the scheme, to direct resources to more local, tangible improvements especially to the pedestrian environment. We are open to the concept of the bus gate at Haymarket if the significant questions about the impact on both displaced traffic, and local access can be satisfactorily answered. If these can’t be, then we would like to see a more modest, cheaper but practical alternative based on bus lanes – which as well as providing much needed priority for bus passengers would also improve safety for cyclists.

June 2024

[1] https://www.edinburgh.gov.uk/news/article/13951/consultation-opens-on-future-dalry-town-centre-proposals

[2] https://planningedinburgh.files.wordpress.com/2024/03/gorgie-dalry-r.pdf

Meadows-George Street: LSEG objection to TRO

City Centre Transformation, Consultation Response, News, Traffic Regulation Orders

Objection to TRO/21/32

The Living Streets Edinburgh Group reluctantly objects to this TRO. We recognise that the Meadows to George Street scheme is both complex and ambitious, putting into effect important aspects of the Council’s ‘Our Future Streets’ strategy, There are many aspects of the project which are very welcome including widening of George IV Bridge footways and the semi-pedestrianisation of Forrest Road.

However, we are very disappointed that the footways on the Mound are barely improved from the current unsatisfactory state. The eastern footway will be only 0.5 metres wider while the western footway remains below the ‘absolute minimum’ width of 2.5 metres. The Mound is designated in Our Future Streets as a ‘walking priority street’ and it is inconceivable to us that such a comprehensive and expensive scheme does not bring pavements up to at least the ‘desired’ width of 3 metres’ stipulated by the Edinburgh Street Design Guidance. The Council’s report from March 2020 rightly acknowledges that these streets “carry very high footfall levels throughout the year and especially during the festivals. This results in the pavements being often over-capacity and people having to stray onto the road.” (para3.5)

Footway widening should have more priority than installation of a very wide (3 metre) cycleway, given that the street has a 20mph speed limit, and especially given that most motor traffic will be removed owing to the bus gate, which makes cycling on the carriageway far safer and more appealing. We are also unhappy with the Hanover Street footways, which although widened significantly, are bisected by cycleways on both sides. Again, the low volume of motor vehicle traffic, owing to the bus gate, must call into question the need for these cycleways at all. We also are disappointed to see the footway significantly reduced on the east of George IV Bridge at the NMS Tower restaurant corner.

Other than footway widths, our main objection is to the floating bus stops, especially at the foot of the Mound and on Hanover Street where cycling speeds are likely to be especially high. National guidance Cycling by Design states that “Bus stop bypasses on steep downhill gradients should be avoided, as cycle users are likely to approach these at higher speeds, creating interactions that are more difficult to manage” (p97).

All design guidance notes that these bus stops can be problematic for pedestrians/bus users, especially the most vulnerable people who particularly value safe, walk-only space such as blind people, older people with poor mobility, dementia etc. We accept that this factor needs to be balanced against the argument that bypasses protect cyclists from potential collisions with traffic when overtaking buses. However, given the big reduction in motor traffic as a result of the bus gate, this argument is much diminished. We therefore wish to see traditional bus stop designs on these locations in particular.

The project must reflect the status of ‘walking and wheeling’ at the top of the movement hierarchy both nationally and locally. We have been raising the points above with Council staff for over five years without any significant change and we must now therefore object formally to the Traffic Orders. We hope that future major active travel schemes will ensure that more priority is given to improving all walking environments and we intend to object to any future scheme which fails to meet at least ‘minimum’ standards.

Holyrood Park Consultation – LSE Response

Consultation Response, , , ,

Dear HES

We would like to make the following comments regarding the current consultation on the Outline Strategy for Holyrood Park. We are focussing on the use of the Park as a traffic route. We acknowledge the huge importance of the Park as a precious resource for Edinburgh residents and visitors.

Our view is that motor vehicles should not be allowed through the Park. The Park would be enhanced by being vehicle-free in every respect including pollution, safety and ambience. Access needs to be retained to the Park periphery to enable people to reach the Park who depend on cars, most obviously Blue Badge holders, and options need to be developed to provide appropriate environmentally-friendly access within the Park.

However, decisions on traffic through the Park need to be taken in the context of wider Edinburgh traffic plans (“Circulation Plan/Future Streets”). Closing the Park to through traffic will have impacts on the surrounding areas. In the short term at least, without further measures being introduced, it would increase motor traffic in heavily populated areas such as St Leonards, Abbeyhill and Meadowbank. It would mean more vehicles passing Preston Street, Holyrood and Abbeyhill Primary School, increasing congestion, pollution and road danger. A traffic-free Park must be part of an Edinburgh-wide traffic plan.

In the immediate future, the Park should be enhanced for people walking and wheeling. Priorities should be to re-introduce zebra crossings (or ‘informal zebras’ without beacons) across the many desire lines, especially in the vicinity of Holyrood Palace and the Royal Commonwealth Pool, where pedestrians struggle to cross the road. Speed reducing measures are also needed to combat the widespread non-observance of speed limits.

Finally, we wish to see an immediate re-opening of the Radical Road. The closure of the whole section is absurdly disproportionate to the risk of injury.

David Hunter
Convener

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

City Mobility Plan, Consultation Response, , , ,

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

Living Streets Edinburgh Group response to draft Council plans, May 2023

Consultation Response, , , ,

The City of Edinburgh Council has issued a number of important draft plans related to its overall ‘City Mobility Plan’.  You can read our comments here on the plans for Active Travel, Road Safety and Parking.

You can see the Council’s draft plans, and how to comment on them here: https://consultationhub.edinburgh.gov.uk/sfc/cmp/ The deadline for responses is 9 July 2023: please have your say! We also welcome your feedback on our comments. 

LSEG Parking Action Plan 2023Download
LSEG ATAP 2023Download
LSEG road safety 2023Download