Introduction

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 (including “wheeling” (on wheelchairs) and similar pedestrian mobility) as a safe, easy and enjoyable way of getting around the city.

For LSEG the focus for City Plan 2030 has to be delivering for people.  The purpose of planning is to manage the development and use of land in the long-term public interest, which is commonly accepted as being the welfare or well-being of the general public.  In other words, to provide for people, a species designed to walk on 2 legs, it is our default mode of transport.  Walking is by far the most common and universal travel mode, forming an essential part of many journey chains by bus, train, car, bike etc, as well as ‘walk-only’ journeys.

Yet we have a planning system that for too long has bent over backwards to prioritise and accommodate motorized transport, principally the private car.  Finally, this is now widely accepted as not being in the long-term public interest.    So there is an opportunity for City Plan 2030 to press the reset button and actually plan for the long-term public interest, putting people first.

As well as reversing a longstanding failure of planning as a discipline, this will actually result in a local development plan that complies with Scottish Government policy.   Walking is unambiguously top of both the ‘movement hierarchy’ as laid down in Scottish Planning Policy i and the ‘Sustainable Travel Hierarchy’ in the new National Transport Strategy 2ii. However, while lip service is often paid to the theoretical primacy of walking, it is rarely put into practice and when there is mention, walking is often conflated with cycling.

Despite being Scottish Government policy, Choices for City Plan 2030 regrettably makes no mention whatsoever of the movement hierarchy or the Sustainable Travel Hierarchy – this is an unforgiveable omission, which, unless addressed, must bring into question the Council’s commitment to everyday walking and adherence to national policy.

City Plan 2030 must work in tandem with the City Mobility Plan and deliver the principles of the movement hierarchy across the whole city applying them to established streets and places as well as new developments.  Successful places are those which work for people, not just vehicles, so comprehensive delivery is required across the city to get an integrated package working for the whole community, not only those in new developments.  This is critical in order to address the past failure of the planning system.

The consultation started before the current emergency, so in preparing City Plan 2030 it would be an abdication of responsibility for the Council not to take account of relevant lessons learnt.  It has been demonstrated that many jobs can be carried out from home, it is therefore perfectly feasible that employers may build on this experience and change working patterns as there will be cost savings, enhanced efficiency and, as a by-product, less pressure on transport infrastructure.  It is abundantly obvious to all that current traffic reduction has meant the streets have been more pleasant places to inhabit and this, combined with the likelihood of long term social distancing requirements, means that more space is needed for walking.  It is therefore beholden on the Council to grasp reality, to actively encourage far more home working, to reconsider where new housing should be located, to seriously restrict private vehicle movements and to invest much more in walking and public transport infrastructure.  There may also be reduced demand for new office space and the possibility that some existing office space could be converted to housing or other suitable community uses.  All of this has to be carefully considered and assumptions re-evaluated.  Living Streets Edinburgh Group would like to be part of this process.

Detailed Comments

Introduction

p3 – Support the 4 aims for 2030, particularly “a sustainable city” and “a city where you don’t need a car to move around”, but this obviously requires the services, infrastructure, development locations and quality of environment to allow it to happen.  The Choices for City Plan 2030

p5  – Generally support the choices under the aims, but need to go much further:

• 1 should be revised to “Making Edinburgh a sustainable, active and connected city based firmly on the movement hierarchy as set out in para 273 of Scottish Planning Policy”.
• 2 should be revised to “Improving the quality, density and accessibility of development and ensuring that all new development in the city centre is car free apart from essential parking provision for disabled, visitors and car clubs. This policy shall apply across the whole city by the end of the plan period.”
• 6 should be revised to “Creating places and enhancing existing streets and places to focus on people not cars”.
• 7 should be revised to “Supporting the reduction in car use in Edinburgh to those which are essential”.
• 8 should be revised to “Delivering new walking and cycling routes and enhancing existing streets and paths to ensure that walking has priority”.
• 12 should be revised to “Building our new homes and infrastructure in locations and with layouts where walking is the most viable means of movement, including good routes to a variety of public transport options.”

Choice 2 – Improving the quality, density and accessibility of development

p9  – Support the thrust of the changes, strongly agree with increased density objective in “B”, but “A” should include specific reference to car free developments and “C” should refer to the movement hierarchy in para 273 of Scottish Planning Policy as well as the six qualities of successful places.

A city where you don’t need to own a car to move around

p13 – Strongly support the objective, but if it is intended that you don’t need a car to move around, then there should be specific reference that new developments will be car free and no provision made for parking other than disabled, servicing and essential visitors.

Choice 5 – Delivering Community Infrastructure

p15/16 – Transport Infrastructure section should make it clear that infrastructure will be provided in line with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.  Whilst specific walking routes are welcome, there also has to be reference to improvements to the fabric and management of all streets in the city, new and existing, to accommodate walking as the priority means of movement.  Within this context “A” should have specific reference to walking infrastructure.

Choice 6 – Creating places that focus on people, not cars

p18 – Strongly support Choice 6 Creating places that focus on people, not cars.  In the supporting text there has to be specific reference to the movement hierarchy in Scottish Planning Policy and the National Transport Strategy, with the movement hierarchy set out in the correct order of priority with walking first.  There should also be reference to enhancing established places across the city to reflect the same priorities so that benefits will be enjoyed by the entire community, not just those in new developments.  The target referred to in “A” should be zero car use other than provision for disabled, servicing and essential visitors.  If new development cannot deliver this, then it should not be permitted. Within this context “B” needs to be reworded to delete reference to appropriate parking levels, you must not use phrases that allow wriggle room for either developers or decision makers.

Choice 7 – Supporting the reduction in car use in Edinburgh

p19 – Support Choice 7 but it has to be strengthened so suggest rewording it to read “Help to deliver significant reduction in car use in Edinburgh”.  Proposed changes “A”, “B” and “C” require revision to make it clear that there will be no provision in any development for car parking other than for disabled, servicing and essential visitors. This must be in tandem with phasing out of on street parking across the city.  A start should be made by defining a central area car-free zone, within which no new residential parking permits wold be issued.

Choice 8 – Delivering new walking and cycling routes

p21 – Support Choice 8, but it has to be strengthened so suggest rewording it to read “Delivering new walking and cycling routes and enhancing existing provision for walking throughout the city”.  The Plan needs to recognise that for most people on foot, their “walking network” consists of the pavements around their home, place of work or education.  The emphasis on new cycle routes is disproportionate and “delivering new walking and cycle routes” is much less important than improving existing ones: this means improving pavements, widening them, more road crossings, traffic calming, etc. S75 opportunities.  In recognition of the importance of everyday walking this should be reflected in the proposed changes and there should be specific reference to the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.

It is appreciated that the provision and enhancement of walking infrastructure has a cost attached.  This should be secured via revisions to the Council’s policy and guidance on developer contributions.  The existing supplementary guidance ignores walking, contrary to the Scottish Government hierarchy.  Delivery of Choices 6, 7 and 8 will require significant investment which must come from developers as part of individual developments and/or via developer contributions in Section 75 Planning Obligations.  Higher density developments with less car parking and fewer contributions towards traditional road schemes will assist with delivery for walking.

Choice 10 – Creating sustainable communities

p26 – Revise para 3 in text box to read “reduce the amount and type of student housing…”

Choice 12 – Building our new homes and infrastructure

p28 – Point “C” in the text box under Choice 12 should be revised to read “Where we will deliver the homes in the most sustainable way to conform with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy”.

p30– Strongly support the Council in preferring Option1 Delivery within the Urban Area as it is the only option that can provide for walking in accordance with the movement hierarchy as well as helping to deliver on wider sustainability objectives.

p31 – Having set out its preferred Option, it is disappointing that the Council chooses to focus on the difficulties in delivering it, rather than the benefits that will accrue if it is delivered.  Delivery in accordance with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy is only possible with this Option.  Any other option will fail to comply with Scottish Planning Policy.  The Council must embrace the same spirit that lies behind the City Centre Transformation project, and be resolute, bold and focused beyond the short term.

p32 – If the Council pursues car free developments and is imaginative with design, layout and density, the available space will generate more than the 17600 new housing units quoted.

p35-46 – The options set out in Maps 9-14 and supporting text will fail to deliver in accordance with the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy, and most certainly lead to an increase in car use which is contrary to national planning policy and the stated thrust of the City Plan process.

Choice 15 – Protecting our City Centre, Town and Local Centres

p54 – Fully support Choice 15 and note reference to active travel and walking distance with regard to new shops outwith centres.  However, the best way of protecting our existing centres is to acknowledge that they are primarily places for people, so policy has to be led by the movement hierarchy as set out in Scottish Planning Policy and the National Transport Strategy.  Is there evidence to support the new hotel provision proposed in “E” given the identified need for more permanent housing?  There is a need for more city centre homes as well as more housing across the city and the increased density proposals will help to deliver this, but it has to be prioritised over hotel and Air BnB type provision.  The proposed changes need to be reworded to reflect this and introduce proposals for established centres to prioritise people and walking.

Choice 16 – Delivering Office, Business and Industry Floorspace

p56 & 59 – Choice 16 should make it clear that office, business and industry floorspace will only be provided in locations where it can be easily accessed by public transport and where there is good infrastructure for walking and cycling.  It should be made clear that onsite parking will be restricted to that required for disabled, servicing and essential visitors.  In addition to minimising vehicle movements, this will allow more efficient use of land and free up space for enhanced green infrastructure.  As stated in our initial comments, there also has to be recognition that more provision should be made for homeworking, in new and existing housing – perhaps one positive to come out of the current COVID-19 crisis.

The plan should make provision for developing a new role for out of town retail and parking, through conversion to higher density, mixed used (especially residential) focused around public transport interchange hubs.

Living Streets Edinburgh Group

April 2020

Notes/references

i Paragraph 273 of Scottish Planning Policy (2014) states: ‘The spatial strategies set out in plans should support development in locations that allow walkable access to local amenities and are also accessible by cycling and public transport. Plans should identify active travel networks and promote opportunities for travel by more sustainable modes in the following order of priority: walking, cycling, public transport, cars. The aim is to promote development which maximises the extent to which its travel demands are met first through walking, then cycling, then public transport and finally through use of private cars. Plans should facilitate integration between transport modes.’ https://www.gov.scot/publications/scottish-planning- policy/

ii The 2020 National Transport Strategy 2 (NTS2) places walking at the top of the ’Sustainable Travel Hierarchy’, followed by cycling, public transport, taxis and shared transport and the private car. https://www.transport.gov.scot/media/47052/national-transport-strategy.pdf