Pavement parking: deputation from Living Streets Edinburgh Group

Walking, disability and cycling organisations have campaigned for a ban on pavement parking for well over a decade, It is also now four years since the ban was legislated for in the Transport (Scotland) Act 2019. On the eve of the ban finally coming into effect, it is essential that it is administered as effectively as possible, so that we see an end to vehicles parked on pavements and blocking dropped kerbs.

We would like to give full credit to councillors who adopted a policy last August that the ban should apply to all streets, with no exemptions. We are encouraged to hear the determination to stick to this position. We want to see the additional revenue generated by penalties re-invested in effective enforcement – especially in those areas in the city where parking attendants don’t currently patrol.

However the report before councillors is extremely disappointing. It not only fails to acknowledge this ‘no exemptions’ policy, but also asks councillors “to note” an approach which permits the possibility of exemptions – contrary to council policy.

The report seems to assume that current parking capacity must be accommodated; that the Council must ensure that people who currently park on the footway are able to either park somewhere else, or must be allowed to continue to park on pavements. How can a council with a target to reduce car use by 30% countenance such an approach?

When footway parking is no longer permitted, then the responsibility lies with the owner to find somewhere else to park safely and legally. No doubt many people who currently park on the pavement won’t be able to park outside their home and will have to walk further to a suitable parking space. But if someone has nowhere to park safely and legally, then it calls into question whether they should own that car at all.

The Council’s Project Centre consultants advise that they have recommended “cost-effective mitigation measures to alleviate footway parking” for all the problem streets which they have identified (Para 2.3.9 of the Appendix). One of these mitigations is ‘exemption’: in other words, to alleviate pavement parking, it should be permitted!! This is an incredible feat of logic. We have asked to see the full list of these recommendations and suggest that they must be made available to all councillors, and to the public.

The report makes no mention of the need to assess the impacts on disabled people of continuing to permit footway parking which we believe fails to conform to the Public Sector Equality Duty. The Scottish Government’s statutory disability transport advisors (the Mobility and Access Committee for Scotland, MACS) has called for all councils to adopt a ‘no exemptions’ policy.

It would be unforgivable if the long-awaited ban on irresponsible parking was undermined at the eleventh hour by allowing streets to be exempted because of displaced parking. Cars belong in a driveway or garage, or on the carriageway. Pavements are not places where vehicles belong. It really is that simple.

Living Streets Edinburgh Group

November 2023

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

Minute of Living Streets Edinburgh Annual General Meeting

Quaker Meeting House, November 14, 2022
Approximately 25 people were present.

  1. A number of apologies were recorded
  2. The Minute of LSEG AGM 2021 was approved and adopted. There were no matters arising.
  3. David Hunter noted LSEG’S significant activity of the previous year.
  4. Isobel Leckie noted that financial activity this year was minimal. The bank account balance with Bank of Scotland is £1144.36.
  5. DH outlined the current structure of the Living Streets Edinburgh Group having no formal committee structure but individuals taking responsibility for particular aspects. A requirement of Living Streets is that local groups have two named office holders. It was agreed that David Hunter and Isobel Leckie continue in respective posts as Convenor and Treasurer.
  6. Guest speaker Cllr. Arthur made the point that personal transport is about having choices and that these should focus on sustainability. Although walking is the main mode for a third of the population it arouses least public comment. He wanted to get away from an ongoing battle between cyclists and motorists. and to focus more on walking and public transport.
  7. A number of questions were raised from the floor which Cllr Arthur responded to.
  8. DH spoke to a paper indicating LSEG proposed priorities for 2023:
    – Campaign for increased budgets for the pedestrian environment (capital and staffing)
    – Secure better enforcement of controls on parking
    – Support specific local campaigns for placemaking and traffic reduction – LTNs, 20 min – Neighbourhood plans
    – Develop walk friendly- environments at and around schools
    – Influence planning policy and practice to aid walking and wheeling and reduce motor traffic
    – Grow number of our supporters and range of our campaigns.
    – DH described ways in which individuals could become involved with LSEG campaigning and encouraged anyone interested to get in touch.
  1. There was no further business and the meeting was closed.

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

Consultation on Enforcement Regulations for Local Authorities – Comments from LSEG

Scotland’s Pavement Parking Prohibitions; Consultation on Enforcement Regulations for Local Authorities. Comments by the Living Streets Edinburgh Group

General Comments

We are disappointed that this consultation document focuses almost entirely on administrative processes rather than seeking views more widely on how to make the prohibitions on irresponsible parking as effective as possible.

We are content with the proposals as set out in the 13 specific questions in the consultation. However, more importantly, we would like to make a small number of points which need to be taken account of int he Regulations and/or guidance which will accompany them.

We seek assurance that the intended date of implementation already announced by Scottish Ministers (1st December 2023) will be adhered to. We are extremely disappointed at the slow progress in implementing these parking prohibitions and any further delay cannot be justified.

Exceptions  for Royal Mail, commercial loading, etc.

Certain types of vehicle and certain types of activity are excepted from the irresponsible parking provisions by way of Section 55 of the Act, for example ‘loading for commercial purposes’. However, these exceptions are qualified in a number of respects: notably that such excepted activity is only permitted where parking on the pavement could not reasonably be done on the carriageway; that the parked vehicle leaves a minimum of 1.5 metres of clear footway and; that ‘loading’ is limited to a maximum duration of 20 minutes.

It is essential that these factors are recorded so that excepted vehicles and activities comply with these requirements.

Appeals

The appeals process must not permit any ‘loopholes’ to be exploited (without hindering, of course, legitimate appeals). In this regard, we therefore seek more clarity on how contraventions are recorded (as per Question 1). It is important that sufficient evidence is obtained to demonstrate why a PCN was issued to ensure that illegitimate appeals cannot succeed. An example of this may include recording the start and finish times of observed pavement parking so as to ensure that the 20 minute loading clause noted above is not exceeded. Photographic evidence may also have an important part to play.

Grace Periods

We believe that no grace periods (allowing a short delay before enforcement) should not apply to irresponsible parking on pavements or at dropped kerbs: an observed offence should be ticketed immediately. They may be acceptable for double parking under some circumstances.

Camera Enforcement

The Act permit ‘approved devices’ (presumably cameras) to be used to detect contravention of parking regulations. We are surprised to see no mention of this in the consultation document.

LSEG supports the use of cameras to assist with enforcement of the responsible parking provisions. Parking attendants will not be able to enforce  the provisions everywhere. Cameras could be an important tool, especially in suburban areas where there are persistent infringements which cause significant problems but which are difficult to address in person.

Regulations should therefore specify what devices are approved so that they can be used in enforcement activity from the outset in December 2023.

Living Streets Edinburgh Group

June 2023