Category Archives: Consultation Response

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.

Strategic Transport Projects Review/ STPR2 – Comments by LSE

Living Streets Edinburgh Group is the local voluntary branch of the national campaign for everyday walking and wheeling. We welcome the opportunity to comment on the Scottish Government’s draft proposals for capital investment in transport over the next 20 years (STPR2).  https://www.transport.gov.scot/our-approach/strategy/strategic-transport-projects-review-2/

Walking and Wheeling

The draft STPR2 proposals completely fail to recognise the importance, or scale of the task, of improving pedestrian spaces in Scotland. With ‘walking and wheeling’ top of the Scottish Government’s own sustainable travel hierarchy, the lack of any coherent programme to improve the everyday pedestrian experience is a serious omission which, unless rectified, would greatly undermine the opportunity to achieve the Government’s social, economic and environmental objectives.

There is a wealth of evidence on the negative effects of, and inequalities caused by, poor walking environments. Given the emphasis in STPR2 on ‘evidence-based’ decision-making, it is essential that an ambitious programme to improve the legacy of inaccessible, inadequate and poor quality infrastructure is adopted as a strategic priority.

In particular, we call for:

  • the inclusion of local roads in the scope of the STPR2. This is vital for the achievement of many of the recommendations, including ‘Connected Neighbourhoods’ (#1) and ‘Increasing Active Travel to Schools’ (#8).
  • a specific theme on improving pavements – both widening them and improving the surface quality. The wider pavements introduced by the City of Edinburgh Council in local town centres as part of ‘Spaces for People’ have almost all been removed. We wrote to Ministers in 2021 (jointly with Spokes Lothian) asking that capital funding is made available to councils to ensure that infrastructure is introduced to replace temporary schemes which is fit for purpose in the long term: bit.ly/3vJkoJZ The STPR2 is the opportunity to address this.
  • investment in walk-friendly junctions. Scotland (like the rest of the UK) has a massive legacy of street design which favours vehicles, not people. Junction splays in many residential areas are wide, favouring 30+ mph speeds even where those limits have been reduced to 20 mph. There is a huge job to redesign junctions with a tighter radius and shorter crossing route for pedestrians.
  • investment in traffic signals and pedestrian crossings. Much signalling infrastructure is out of date and cannot easily be adapted to give priority to travel modes which we need to put first – public transport, cycling and especially of course, walking.  We have documented pedestrian wait times at dozens of signalled crossings in Edinburgh and found many to be quite unacceptable: bit.ly/35xMRHp. On a positive note, there is a massive opportunity to improve them at relatively modest investment.
  • a national programme of investment in dropped kerbs and continuous footways. In Edinburgh, we have been told that 17,000 out of 22,000 junctions have no, or substandard, kerb arrangements. These make pavements dangerous – or simply unusable – for many pedestrians, especially disabled people.
  • a national effort to reduce pavement clutter (and to stop adding to it). This includes management of temporary obstructions such as hedges and bins, and removal of unnecessary fixed structures such as signage poles and guard rails, many of which persist despite changes in legislation (TSRGD 2016) and recognised best practice. New threats to pavements such as telecoms cabinets and EV chargers must be avoided. See our reports and video resources for further information here: bit.ly/3rMTqPD.
  • an initiative to encourage the provision of seats and toilets, especially in high footfall areas. Both of these simple, modest measures are important to many pedestrians – and especially for older people, children, disabled people and women. A national programme which increased such provision would make many areas more attractive and inclusive at modest cost.

Cycling

We support investment in cycling infrastructure, especially in routes which will encourage more people to commute into Edinburgh by bike, rather than by car. However, the recommendations under the ‘Active Travel’ theme do not have the right balance between walking/wheeling on the one hand, and cycling on the other, and this section does not properly reflect the agreed ‘sustainable travel hierarchy’.

Influencing Travel Choices

We strongly support the wider rollout of 20 mph speed limits in residential and shopping areas. However, they need to be accompanied by both engineering and enforcement measures. Many streets are designed for 30mph+ travel and driver compliance is known to be lower in such circumstances. There is enormous scope for imaginative use of new technology to assist with compliance, education and enforcement.

Measures to encourage active travel to school are very important. Our comments under the first active travel theme are relevant here. Official data (TaTiS 2019) shows that 52% of children currently walk to school in Scotland, which is an encouraging basis to build on. Only 2% of children cycle and while there is certainly scope to increase this figure, this data underlines again the need for active travel efforts to focus much more on safe walking environments.

Public transport

We support investment in the public transport measures with two qualifications. It is vital that good quality public transport is available if car reduction targets are to be achieved. However, we don’t support the recommendations on ‘DRT and MaaS’ (#20) or ‘mobility hubs’ (#22) as they stand.  We consider these initiatives to be over-hyped and lacking an evidence base that they will make a significant contribution to improved public mobility. We suggest instead that investment in DRT focuses on exploring opportunities there may be to develop existing DRT services such as community transport (which is under-funded), taxis and private hire cars. ‘Mobility hubs’ should be seen simply as one aspect of better transport interchanges (#21) rather than as a separate recommendation in its own right.

Increasing …resilience

The STPR2 has far too many ‘get out clauses’ which could be used to justify further significant investment in trunk roads and motorways, especially under the ‘Increasing safety and resilience’ theme.  For example, “Junction improvements, carriageway widening, route realignment and provision of overtaking opportunities” (#30) are not the priorities Scotland needs. These recommendations are not consistent with the ambitious national targets to reduce motor traffic, and would have an enormous opportunity cost in reducing the scope for investment in everyday walking and wheeling.

Planning policy

Investment in infrastructure needs to be accompanied by complementary planning policy. The ‘Infrastructure First’ principle, advocated in the draft NPF4, is essential so that new developments do not proceed until suitable sustainable transport options are in place. This is especially important around Edinburgh; for example the housing developments around West Craigs and Winchburgh where it appears that the essential new railway station may be in doubt despite massive housing expansion.

This document can be downloaded as a pdf here

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

LSE Response to Corstorphine Connections Consultation

While supportive of low traffic neighbourhoods in principle, we are disappointed that CEC has not taken on board many of the suggestions from our first consultation response submitted earlier in the year.

Living Streets Edinburgh has walkability criteria that we have assessed against south Corstorphine and feel that there is still ample opportunity for “quick wins” to help improve the pedestrian environment at low cost. This includes:

  • Adding double yellow lines to deter drivers from parking over dropped kerbs and obscuring sightlines for people walking
  • Addressing problem areas for pavement parking
  • Improving junctions and crossing points for pedestrians on key thoroughfares, such as Saughton Road North
  • The removal of barriers along traffic-free routes
  • The removal of pavement clutter and furniture along key pedestrian routes
  • The tightening of junction radii along key pedestrian routes

We provided a list of hot spots regarding these points in our first consultation response, and are disappointed we have not seen these quick wins and low-cost solutions implemented as part of the scheme designs. Is there scope to include any of our original suggestions for improvement?

We note that other suggestions to improve the pedestrian environment have not been addressed as part of the Corstorphine Connections designs. We are keen to see more applications of wider permanent pavements, resurfaced pavements and new signalised crossings across the area to ensure walking is an attractive and safe option for residents and visitors.

With respect to the designs as presented, we have split this into its constituent parts in order to comment. The vast majority of interventions proposed focus on a small section of the proposed LTN – is there a reason further pedestrian improvements are not being consulted on across the wider LTN area? Walking is at the top of the sustainable transport hierarchy and CEC has stated on multiple occasions that it is number one priority for transport policy – with this context in hand, it is disappointing that potential interventions are limited and we can’t comment on a more ambitious scheme with additional residential streets filtered to remove intrusive traffic, improve the pedestrian experience and increase local walking journeys.

Modal Filtering Featherhall/Manse Road

We are supportive of modal filters to help improve the pedestrian environment on the streets identified in the scheme designs. The removal of intrusive traffic on these residential streets will help to make the pedestrian environment safer and more accessible. We would like to see pavement widening and improvements along Manse Road in particular, as it is incredibly narrow and an important route to the local primary school for families.

Corstorphine and Carrick Knowe Primary School Streets

We are supportive of the school streets proposed, to help families walk, wheel and cycle to school.

The filters could do with being more attractive; at the moment they look like road works and it would be good to make the filters feel more welcoming to pedestrians.

Corstorphine High Street Option A/Option B

The better option for pedestrians is option B – the bus gate. The widened pavements and removal of through traffic would significantly improve this street for people on foot. There is the potential for drivers to use adjacent residential streets like Castle Avenue and Dovecot Road to avoid the bus gate, which would need to be addressed.

Placemaking

Placemaking interventions should include seating where appropriate for pedestrians who need to pause and rest. Any placemaking interventions need to avoid adding clutter to existing pavements, provide clear sightlines for pedestrians at junctions and give sufficient grip to the road/pavement surface (ie paint/decoration).

Kirk Loan

It’s surprising to see no attempt to tackle the persistent pavement parking problems at the north end of Kirk Loan. This is an important pedestrian route but has narrow pavements and is blighted by drivers blocking the pavement with their vehicles. The south junction tightening is welcomed – dropped kerbs should be provided here to help people with mobility aids to cross the road safely.

Saughton Road North Traffic Calming

This street is generally quite hostile for pedestrians. Traffic calming measures are welcomed in principle, but without details it is difficult to comment. It would be very helpful to see improved crossing options for pedestrians at the north end of Saughton Road North, between Dovecot Road and Kirk Loan.