Category Archives: Consultation Response

Holyrood Park Consultation – LSE 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

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

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 comments on ‘Travelling Safely’ consultations, July 2022

Living Streets Edinburgh Group supports the general aim of the ‘Travelling Safely’ programme – to provide healthy, environmentally friendly alternatives to travel by private car. We therefore support the retention of all remaining schemes (whether closure of streets to traffic such as Cockburn Street, or pop up cycle lanes such as on Lanark Road) where they are well used, and where they do not cause unacceptable problems for other priority road users such as buses and disabled people. For the avoidance of doubt, we do not consider private car parking to be ‘priority road users’.

We are not in a position to comment on which of the individual schemes currently being consulted about meet these criteria; however, we have previously emphasised the need to collect (and publish) monitoring data in order to carry out appropriate evaluation (see for example: bit.ly/3aajyje). This continues to appear to be largely absent.

We must repeat our regret that almost all town centre ‘walking schemes’ (widened pavements) were removed ‘en bloc’ in 2021: they are therefore not subject to the current consultation. The decision to remove them was made without any plan to replace them with more permanent measures fit for the future and without any consultation with the community or with stakeholders such as ourselves. As such it breached the policy placing walking and wheeling at the top of the sustainable travel hierarchy, and we urge the council to come forward with new plans to improve pedestrian spaces in town centres as a matter of urgency. 

Finally, with regard to this consultation, we are sceptical that the current method of asking people to comment on somewhat obscure statutory procedures (ETROs) is likely to engage the wider public effectively. The schemes have already changed branding from ‘Spaces for People’ (which they are probably still best known as), to ‘Travelling Safely’, and now ‘ETRO’s. While we recognise the difficulties involved in public consultation exercises, we would suggest that the most effective way of gauging public opinion to date has been the ‘Common Place’ method used in 2020. This generated a very high volume of public comments, many of which are still very relevant and still to be acted on. We note that ‘wider pavements’ was one of the most commonly requested interventions. 

David Hunter

Convenor

Smokey Brae Consultation – LSE Response

LSEG supports the proposals for Smokey Brae in the consultation advertised in April 2022: https://consultationhub.edinburgh.gov.uk/sfc/smokey-brae-improvements-developed-designs/

Smokey Brae is currently at total odds with the transport hierarchy. It feels like a hostile environment for anyone not moving in a car. The current layout puts pedestrians in as an afterthought and is particularly unsuitable for anyone pushing a pram or using a wheelchair. The pavement is too narrow, and traffic moves incredibly quickly and close to those using it. The pavement creates a pinch point that when two adults walk through in opposite directions on foot, they struggle to pass. If a pram or wheelchair is involved, one party must give way. Currently, walkers and wheelers who choose to avoid this junction due to its inadequacies must make a 15-minute detour.

LSEG greatly welcomes the proposals to redesign Smokey Brae and create a space that respects the transport hierarchy more.

We strongly support the introduction of continuous pavement with raised table junctions. We would like you to implement these using pavement materials rather than road material as this will emphasise pedestrian priority.

The designs appear to reduce the overall footway space available for pedestrians by removing the pavement on the eastern side of the road. However, this seems to be a reasonable compromise as there is currently no safe crossing near the railway underpass, and the existing footway is too narrow.

If it’s possible to make the proposed new pavement even wider, LSEG will welcome this. However, we appreciate this may not be easy to do given the overall width available and the welcome introduction of safe infrastructure for cyclists. Perhaps you could achieve this by closing the road from the T-junction to the Meadowbank House entrance to both northbound and southbound traffic, except for emergency vehicles only. This change would allow the fire service quick access to the south and create ample room for walkers, wheelers and cyclists alike.

LSEG members have noted that the Jock’s Lodge crossroads have abysmal pedestrian crossing times. Those who need to cross the road must wait for 2-minutes between signals and only have 7 seconds to cross. People who want to go down Smokey Brae will need to use these crossings. Pedestrians coming from Portobello Road will now have to as the pavement has switched sides. Therefore we think it should be a requirement to adjust the timings of these crossings to give more priority to pedestrians; 7 seconds isn’t enough!

Lastly, we’ve mentioned in our other answers to the survey that we would like the introduction of seating and wildflowers. Due care should be given to the seating positioning so as not to obstruct the natural movement of people through the area.