Category Archives: Consultation Response

LSEG response to Consultation on the National Speed Limit Review, March 2025

Consultation Response, Press Release, ,

Consultation Submission submitted on behalf of the Living Streets Edinburgh Group (LSEG)

This submission is being made as a direct email rather than through your standard consultation form since the design of that form does not allow us to be able to adequately express our concerns for pedestrians. We trust that our views, as below, will nevertheless be considered seriously.

The LSEG very strongly supports the proposed lowering of the default national speed limit from 60 to 50 mph on single carriageway roads. Scotland has a very poor safety record on these roads, with a large proportion of all fatalities and serious injuries occurring on them, as evidenced in the Consultation Review report. The 60 mph limit is far too high for safe driving, other than where there are long stretches of strait road without intervening property entrances or side-road junctions. A 50mph limit will result in safer speeds on these roads and all the more so if the new limit is properly enforced. We note that an even lower, 60 kmph, national limit is now being introduced on rural roads in Ireland, many of which have similar characteristics to those in Scotland.

The benefits for pedestrians on such roads is unlikely to be great however, since traffic speeds at up to either 50 or 60 mph intimidate pedestrians, and without the protection of segregated paths, on what are mostly narrow rural roads, there is little pedestrian activity. Our principle concern therefore is that the introduction of the 50mph limit does not go nearly far enough to make conditions safe for pedestrians or to reduce the levels of suppressed pedestrian trips along these roads.

In many places there are extensive stretches of bends with the current 60mph limit but where the maximum safe speed around the bends is no more than 40, or 30, or even 20mph. All too often only ‘Slow’ markings on the carriageway are in evidence. For conditions to be considered at all safe for pedestrians, with their visibility restricted by bends, speed limits need to be set at the appropriate lower levels that match the road design / conditions, not simply set to 50mph. There are also still many places, in particular on the approaches to villages or other settlements, where the prevailing speed limit needs to be reduced from 60 to well below 50mph; and, as in the Scottish Borders, 20mph in the villages themselves  We therefore call for there to be a comprehensive review following on from the introduction of the 50mph limit, with the aim to have speed limits set to appropriate levels for safe driving throughout the network, and whether or not there have been casualties in a particular location. This is a fundamental necessity if more walking is to be encouraged, in line with government policy. 

Even with the setting of the most  appropriate speed limits conditions will still be challenging for pedestrians and potentially dangerous without the provision of segregated routes. There is also a clear need in many places for the provision of pavements or off-road paths alongside rural roads. This provision could encourage many more walking trips, for example between adjacent villages or from villages to the nearest town where distances are not too great. It is also the case that more recreational walking, by visitors as well as residents, would be encouraged by the provision of more off-road footpaths in rural areas throughout Scotland. It is notable that many of the islands are very suited by size for recreational walking (and cycling) trips, yet still with very little provision of safe, segregated routes. Provision of such routes could encourage the leaving of cars behind on the mainland perhaps, or even altogether. Promoting such active travel would help increased tourism to take place without a comparable increase in car use.

Finally much intensified efforts to enforce the improved speed limits are essential in order to eliminate excessive speeding. Funding for these efforts needs to be resourced by means that are protected, otherwise grant cuts are likely when, as now, overall national and local public sector resources are under pressure. Without this the Vision Zero aim to have no serious injuries or fatalities will remain just a vision. The current enforcement system is simply not fit for purpose and needs reform, as the LSEG has argued elsewhere:   https://www.livingstreetsedinburgh.org.uk/2021/11/17/slower-speeds-safer-streets-for-edinburgh-an-action-plan/

We need to have a more comprehensive approach, with policies for the road safety of walkers (and cyclists) integrated with those for tourism and wider economic development.           

Leith Connections (Hawthornvale-Salamander Street): Comments from LSE on draft proposals

Consultation Response, ,

Thank you for the opportunity to comment on the new ‘Leith Connections’ proposals from Lindsay Road in the west through Commercial Street, Bernard Street and Baltic Street to Salamander Street in the east. https://consultationhub.edinburgh.gov.uk/sfc/leithconnections/  

We acknowledge that the proposals would bring some significant improvements for pedestrians – such as ‘continuous footways’ over side road junctions, a single-stage crossing over North Junction Street at the Ocean Drive junction, and a new pavement at the eastern side of North Junction Street. 

However, it is also very concerning to see some sections of pavement actually reduced, and no improvement to many pavements that are already less than 2 metres wide – the “absolute minimum” that the Council normally considers acceptable. These seem to include these streets (the number in brackets refers to the drawing sheet):

  • N Junction St 1.5m (1)
  • Lindsay Rd (S) 1.54m (2) 
  • Lindsay Rd (N) 1,67m (3)
  • Commercial St (N) 1.8m (3)
  • Salamander St  (N) 1.85m (14)
  • Salamander St  (N) 1.8m (14)
  • Salamander St  (S) 1.95m (16)
  • Salamander St  (N) 1.27m (17)
  • Salamander St  (S) 1.5m (17)

Pavements which are at least two metres wide is also the minimum recommended in national UK guidance such as Inclusive Mobility, allowing for adequate use by pedestrians using mobility aids including walking sticks and wheelchairs as well as by parents with small children, etc. bit.ly/IncMobility

There also appear to be ten ‘floating bus stops’ (which mean people getting on and off the bus have to cross a cycle lane when boarding or alighting).  We know this design is a serious concern to many disabled and blind people, as evidenced by calls from all the major visual impairment charities (RNIB, Guide Dogs for the Blind and the National Federation of the Blind UK) for a halt to their use and/or removal of existing stops.  Some of the bus stops proposed do not even appear to conform to the minimum standards for footway and/or island width as defined by the Council’s own Street Design Guidance. 

The plan would also remove some bus stops altogether, as well as significant sections of bus lane on Lindsay Road and Commercial Street. Many of these changes are not highlighted on the Council’s consultation. Many were raised as concerns needing to be addressed in earlier consultations for example in the minutes of the 2021 Community Reference Group. 

The size of the cycleway itself is also limited by the constrained street space, and is not continuous owing to the Bernard Street pinch point in particular.  We understand also that some parts (especially in Salamander Street) would require additional land take which brings a significant degree of uncertainty over the viability of the whole scheme.

In view of these multiple problems, we query whether this is the best route for the cycleway at all, and whether a different east-west route would be better. For example, running behind the buildings to the north of Commercial Street, over the newly traffic-free Sandport Bridge and along Leith Links, where there is already a well established cycle route which could well be enhanced. 

This would avoid introducing unwelcome impacts on pedestrians and bus passengers by trying to accommodate too many travel modes in an insufficient space – the problem we have seen all too clearly on Leith Walk. This would also provide more traffic-free sections for the cycle route and presumably be significantly cheaper to build.

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