Tag Archives: City Centre Transformation

Low Emissions Zone – LSE Response

Low Emissions Zone, , , ,

Living Streets Edinburgh Group (LSEG) welcomes the Council’s plans to move forward with introducing a Low Emissions Zone (LEZ) in Edinburgh but we are concerned that the current proposals are not sufficiently ambitious and will have a serious detrimental impact for some residents, particularly those that live outside the boundaries of the currently proposed City Centre LEZ. We strongly believe that the boundaries of the LEZ should be increased in order to benefit a larger proportion of the residents of Edinburgh.

The area of the proposed LEZ currently covers only 2.5% of the City and excludes many areas of the City with the greatest density of residents. It will also not include the designated Town Centres, which form such an important element in the development of 20-minute neighbourhoods outlined in the recently approved City Mobility Plan. In setting the boundaries of the LEZ, more consideration has been given to providing convenient diversionary routes for non-compliant vehicles than maximising the health benefits for people living in Edinburgh. Pollution levels have been considered on an absolute basis without any consideration of the number of people that will be exposed to that pollution. LSEG is particularly concerned that there is no recognition of the risks to pedestrians from vehicular emissions in areas outside of the proposed LEZ; some of which have very high levels of walking including children walking to school.

The Council report that was considered by the Transport and Environment Committee at their June 2021 meeting states non-compliant vehicles will increasingly use the roads immediately outside the LEZ resulting in increased pollution on these routes. The SEPA forecast attached to the report shows an increase in atmospheric pollution on Queen Street, London Street and Abbeyhill; all areas on the edge of the currently proposed LEZ. We note that the Council has included an objective to “minimise the impact from traffic displacement across network, related to LEZ scheme”. No detail is provided on the mitigating actions that will be taken or how achievement of this objective will be measured. Before any final decision is taken on introducing a LEZ it is critical that there are clear plans in place to limit the negative impact of displaced traffic to reassure residents living near the LEZ.

The current plans are focussed on reducing levels NOx pollution from vehicles within a small part of the City to meet current legislative limits. In our view, this goal does not go far enough. Other forms and sources of pollution need to be both more closely monitored and reduced, in particular the levels of particulate pollution and continued use of temporary diesel generators within the LEZ. We would like to see the Council setting more ambitious and wide ranging targets for reducing pollution given the accepted health benefits of such a reduction. This is the time for bold action that supports the Council’s plans to encourage walking, wheeling and cycling across the City.

Despite the title of a ‘low emission zone’, the proposals do not address the need to reduce carbon dioxide emissions. Plans that only address pollution are essentially backward looking, whereas we should be looking forward to a future where fossil-fuel vehicles are completely eliminated and levels of all motor traffic are reduced.

Finally, while we recognise that the plan includes proposals to encourage compliance with the new restrictions for vehicles entering the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. In the case of idling vehicles, it would be clearly wrong to turn a blind eye to such behaviour while at the same time introducing the significant controls required by the LEZ.

Finally, we note that the enforcement regime will be based on the use of automatic number plate recognition (ANPR) cameras. From our review of Appendix 7 of the report presented to the 17 June 2021 Transport and Environment Committee meeting, we note that the recommended approach is to install these cameras on only 16 routes of the identified 48 entry points to the City centre LEZ. One mobile unit will cover the other 32 entry routes. Given that the LEZ is intended to operate 24/7, we are concerned that this approach will affect the levels of compliance required for the LEZ to achieve the intended reduction in atmospheric pollution and health benefits for those living and working within the City centre. We are further concerned that this approach will encourage the drivers of non-compliant vehicles to use the non-arterial routes to avoid detection thus increasing traffic further in the many residential streets bounding the proposed LEZ. We believe that to achieve the required compliance for the success of the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. We do not believe that the currently proposed arrangements are adequate. 

Making Spaces for People permanent? Response by LSEG

Consultation Response, , , , , ,
Available as a downloadable PDF hereDownload

Note by Living Streets Edinburgh and Spokes Lothian, March 2021 to Transport Scotland, requesting funding to make successful Spaces for People schemes permanent through the Strategic Transport Projects Review 2 – http://www.spokes.org.uk/wp-content/uploads/2021/03/2103-STPR2-letter-from-Spokes-and-Living-Streets.pdf 

Introduction

  1. Living Streets Edinburgh Group supports the principle of ‘Spaces for People’ schemes continuing in the future. Better facilities to encourage walking, wheeling and cycling are essential in order to achieve the objectives in the City Mobility Plan and to contribute to making Edinburgh the great walkable city that it should be.
  2. We have been disappointed that more priority was not given to promoting walking, especially in the first months of the programme, not only in view of the agreed ‘sustainable travel hierarchy’ but also given that the emergency measures were passed in order to ensure public health and promote physical distancing. Nevertheless, we recognise that many of the measures have been helpful for people to walk and cycle, and we appreciate the very significant efforts of staff and councillors to introduce these extensive measures during the pandemic.

Process

  1. Before commenting on the retention of particular schemes, or types of schemes, we want to make some general observations about ‘process’. Firstly, many schemes need very detailed consideration – for example on whether particular loading bays are in the right place? – before they can be made permanent. The current consultation exercise isn’t adequate to enable this detailed assessment to take place. There needs to be further opportunities for stakeholders (and especially local communities) to consider retention, alteration or removal.
  2. We would also like to see data published on the use of temporary measures (both walking and cycling). We note from the report to Transport and Environment Committee in August 2020 that £256,000 was budgeted for surveys and monitoring. While we agree that we should look to the future and accept that some schemes may be more used in the years ahead than they have been during the pandemic, evidence on the actual use of measures should help inform decision-making on retention or removal. This will also be important for local communities to understand and accept the decision making process. It also important to acknowledge that some schemes which benefit one type of road user may have negative effects on other road users, so the benefits and negative impacts therefore need to be assessed as transparently and objectively as possible. We must also accept that there is a significant degree of uncertainty over to what extent travel patterns will, or won’t, return to pre-pandemic patterns.
  3. We would have preferred for the City Mobility Plan to include targets for modal share, which would have provided a strategic context for the relative importance attached to investments to support different modes – especially walking/wheeling, cycling and bus. If the CMP had aimed to increase cycling rates threefold for example, then there would be a much stronger case for investing in cycling infrastructure. If the aim is to encourage walking or bus, then measures to support walking or bus should get more priority, etc. But because targets haven’t been set, there is no strategic rationale for making the SfP decisions.

Retention, Removal or Adaptation?

  1. Many measures introduced under Spaces for People can and should be retained and made permanent. In many cases, this can be done at relatively little cost: in particular, cycle lanes, road closures and school measures. We cannot comment on each of the dozens of measures which have been introduced, but we support a presumption in favour of keeping them.
  2. For LSEG, the most important benefit which SfP has brought is the ‘footway widening’ in town centres. Generally, these have brought significant benefits to pedestrians, especially to enable ‘physical distancing’. They have also proven beyond doubt that there is insufficient pedestrian space in many town centres, perhaps noting Morningside, Corstorphine and Stockbridge as particular examples. Wider pavements have not caused traffic to grind to a halt as some predicted.
  3. These wider pavements must therefore generally be retained; there may be some exceptions (eg the eastern side of Earl Grey Street?) where the current pavement is sufficient, and taking more carriageway space for walking is not a priority. However, the temporary measures understandably introduced at short notice are not of sufficient quality for the longer term; they are too ‘stop/start’, they are inaccessible to many disabled people, in places ambiguous (so that for example cyclists use them) and introduce trip hazards.
  4. Once the pandemic is over, ‘proper’ wider pavements are therefore needed, with level surfaces, proper kerbs and the necessary changes to drainage. We appreciate that this will be expensive and we have written to the Scottish Government (jointly with Spokes Lothian) asking that funding is provided to enable councils to make successful Spaces for People schemes permanent as a priority for investment through the STPR2 . Our particular concern is the significant cost of converting temporary footways into permanent quality spaces.
  5. We are pleased that the amount of time which pedestrians have to cross the road at crossings is finally being investigated, with £100,000 approved in January for this purpose. We want to see shorter wait times for people to cross the road at signalled junctions and pedestrian crossings, and we want to see longer ‘green man times’ across the city. There needs to be a permanent change to give pedestrians priority, in line with the modal hierarchy agreed in the City Mobility Plan. The automatic pedestrian phases (that remove the need to press the button) will no longer be needed following the pandemic.
  6. The need to remove unnecessary pavement clutter is only now being addressed at scale within the SfP scheme; we assume (and hope) that changes to clear obstructions from pavements will be made permanent.
  7. As noted earlier, we strongly support measures at schools to encourage children to walk, cycle, scoot, etc. to school. According to the latest (2019) Transport and Travel in Scotland statistics, 61% of Edinburgh’s schoolchildren currently walk to school – a fantastic platform of active travel which needs to be protected, prioritised and built on. We would encourage more – and more ambitious – permanent measures to remove traffic in the vicinity of school gates, to widen pavements, ban dangerous turning manoeuvres, make crossings safer, etc.
  8. The limited closure of some city centre streets to motor traffic (eg Cockburn Street) is generally welcomed, especially where they contribute to the vision of the City Centre Transformation. We therefore support making all these closures permanent, with proper management and enforcement. They should use quality materials and street furniture, instead of temporary and ugly barriers, signs on yellow 1,000kg blocks, etc.
  9. We also strongly support the introduction of Low Traffic Neighbourhoods in principle, to reduce the dominance of motor traffic in residential areas. However, there needs to be a sufficient degree of public support for them to operate effectively in local communities, and we need to understand the impacts of any displaced traffic on adjacent streets and neighbourhoods. We are pleased to have representation in the three areas currently being considered as an LTN (East Craigs, South Corstorphine and Leith). Similarly, where there is local support, significant benefits for cycling or walking and no unacceptable other impacts, we would support the closure to motor traffic of suburban/residential roads (such as Silverknowes Road, Braid Road etc).
  10. We support the retention and enhancement of segregated cycle ways where they have demonstrated success, or potential for success. Success measures should include how safe they are (for cyclists as well as other road users), how well they are used, the impact on other road users (especially buses and disabled motorists and passengers), and the contribution they make to a joined-up strategic cycle network. There are some places (perhaps Ferry Road and the Mound are examples), where the pavement adjacent to the cycle lanes is too narrow and should be made wider. If making a cycle way permanent reduced the likelihood of addressing inadequate pavements, then this would be a concern to us.
  11. We are unhappy with some impacts of SfP measures on bus services and do not support their retention as currently implemented. For example, on George IV Bridge, while we support the continuation of the wider footways and cycleways in principle, the removal of busy bus stops (eg southbound near Chambers Street) and shelters, and the dysfunctional bus boarders are all regrettable. We also oppose the loss of important bus lanes, eg northbound on Bruntsfield Place and Leven Street, where the space has been used for new walking / cycling lanes despite most of the footway already being of reasonable width. Assuming that Edinburgh streets once again become busy with locals and visitors, bus services will resume their central role in keeping the city moving.

Summary

  1. In summary:

• We support the principle of retaining Spaces for people schemes and reducing the dominance of motor traffic on city streets (both when moving and when parked).

• We especially want to see:

  • permanent, ‘proper’ wider pavements on busy streets (especially ‘town centres’)
  • traffic signals and pedestrian crossings changed to give pedestrians more priority
  • streets at schools improved to encourage active travel and especially walking
  • city centre traffic management schemes retained and enforced.

• We generally support retention of:

  • cycle lanes
  • residential street closures
  • Low Traffic Neighbourhoods.

(subject to understanding local community views, any negative impacts on other road users/areas and the extent of their use/potential use).

• We don’t support:

  • measures which adversely affect bus passengers, unless there are compelling reasons why these are necessary to achieve other important objectives
  • making ‘automatic phases’ on pedestrian crossings permanent.

15.3.21

City Mobility Plan – comments by Living Streets Edinburgh Group, February 2021

City Mobility Plan, , ,

Due for approval by the Transport and Environment Committee on 19 February 2021, this Plan will guide the Council’s transport plans and investment over the next decade to 2030. The fundamental message is the need to shift how we move about, by reducing traffic, and increasing options for walking, cycling and public transport. With Edinburgh still growing fast, this can only be the right path to follow. Present levels of traffic cannot be sustained and already have a severe negative impact on the city; for example in terms of congestion, on public health and safety and the quality of the environment in all senses. It is good to see a heightened level of ambition in investment in public transport, especially an extended tram network and in the city centre public realm, so we unambiguously give our support to the Council in adopting, and of course implementing, the Plan’s goals.

We have two main reservations – and these are significant ones.  Unlike the previous Local Transport Strategy, the CMP contains no targets for ‘modal share’. It seems extraordinary that there is no assessment of whether those previous targets were met, and if not, why? The intention is to provide targets in a future ‘Technical Note’. But modal share targets are fundamental to a transport strategy, not a technical detail. The interventions required to double the use of walking, cycling or public transport for example, will be very different to the interventions required to bring about a 10% increase. 

Secondly, we remain sceptical that the Council grasps the scale of the challenge in renewing the pedestrian environment so that it is fit for purpose by 2030. There are a number of welcome comments about the importance of walking – for example by confirming walking’s primacy at the ‘top of the travel hierarchy’ (p24) and noting that “Walking is by far the most common way of making local journeys (i.e. to the shops, post office, doctors) in the city” (p31). But all over Edinburgh, there are pavements barely a metre wide, frequently with poor surfaces and blocked by all kinds of obstructions; with wide junction splays at side roads often without dropped kerbs. Pedestrians are hemmed into cramped ‘town centre’ pavements, which are at the heart of local communities. Tackling this legacy from 50 or more years ago must be central to making Edinburgh the truly world-class walkable city that it could and should be – pavements are far more important for everyday walking and wheeling for most people than shared walk/cycle ‘active travel’ routes. 

The Plan’s main policy measure (#14) for ‘everyday walking’ is a timid “Enhance and where necessary expand the walking/wheeling networks to serve and connect key destinations across the city”. This completely fails to acknowledge the dire state of pavements across the city in residential areas, not only ‘key destinations’.  There appears to be nothing about transforming the pedestrian environment in the Implementation Plan, where the ambition appears to be no more than ‘to maintain paths and streets’ within current budgets. Instead, we’d like to see an additional commitment that by 2030, all city pavements (except any formally exempted for specific reasons) meet the Council’s own standards, as set out in the excellent Street Design Guidance.

LSEG response to Council review of communal waste bins

Consultation Response, , , , ,

CEC COMMUNAL WASTE BINS REVIEW Project: Comments from the Living Streets Edinburgh Group (LSEG)

LSEG welcomes the current review of the location of Communal Waste Bins in the city, and the intention to create bin hubs and rationalise the scattered locations of the various types of bin. Under existing conditions there are far too many such bins that are poorly located or left mislocated on pavements, so creating unnecessary obstacles for pedestrians. In numerous instances they also collect other clutter items around them.  This review is timely in the context of the covid virus with  heightened concern over clutter and the need for more space on pavements to allow social distancing. The reduction of bin clutter is also central to the realisation of the council administration’s objective (27), to tackle clutter and pavement parking.

We have a number of questions and concerns however, about the specifics of the review and how successfully they will be translated into practice.

One particular concern is the intention to go with wheeled communal bins everywhere, rather than the ones with fixed positions that can then be lifted automatically with the lorry correctly alongside. The latter are all in the carriageway of necessity and, unlike wheeled bins, cannot be left out of position on pavements! Given the frequency with which wheeled bins are currently so left as obstacles to pedestrian movement, both on pavements and in the carriageway where blocking crossing points, we would wish to see fixed positions retained wherever this is practicable.

As of now wheeled bins are to be found out of position all over the city. Even when in the carriageway they are often to be seen too close to junctions or where they obstruct dropped kerb crossing points for pedestrians or block cycle lanes. They are left there after emptying by contractors, or they are subsequently moved or sometimes blown there.  Can we please therefore be informed as to what additional measures will be taken to ensure that bins are repositioned within the defined hub positions? Under the current regime, even where there are defined areas for bin location, all too often these are ignored or treated as only approximate indicators.  We are not convinced that the new bin hub settings will be sufficient to ensure that contractors do correctly reposition the bins. So without exception the hubs should be in roadway rather than on pavements. If gradients are a problem for this then regrading of the carriageway is the answer, not putting bins on pavements. Where there is a sufficient excess of pavement space to allow bin hubs to be located there without inconveniencing pedestrians, then it would be acceptable for that space to be used, but it must then be regraded to carriageway level in the process; otherwise there will still be out of position bins rolling around on pavements.

The current review is seen to only be covering communal bins. It does not embrace the residential or trade waste bins that are equally of concern for pedestrians, given that these bins are also frequently left on pavements for periods of time out of all proportion to the needs for collection, and in excess of the times authorised by the CEC.  We call for a complementary review to be undertaken of ways to reduce the problems and clutter associated with these bins also.

There are problems arising from both residents and retailers leaving bins out permanently or semi-permanently in some cases, and for excessively long periods in many others. The situation with trade waste bins does seem to have been improved somewhat over recent years, but the levels of regulatory and enforcement activities are still far from adequate. Woeful conditions for pedestrians are being created on pavements as a result, whereby wheelchair users and other vulnerable pedestrians are at times simply unable to use them. Council policy should make it clear that residential bins must be left on the roadway side of the kerb where the pavement width is less than 1.5m. The council should also seek powers to levy fines on residents who leave bins out permanently.

In many instances residents’ bins are also left blocking pavements after emptying by the contractors, and it is clear that insufficient efforts are being made to encourage compliance with or to enforce the rules. At the very least there surely should be clear instructions that emptied bins must not be left anywhere on pavements narrower than 2m, with penalties introduced for contractors who fail to ensure that their staff follow this in practice. Equally if bins are replaced on pavements where they are wider than 2m, there should be penalties imposed for placing them in obstructive positions.

 

There is also a need for the current review to be followed up with a much wider review aimed at minimising the extent to which bins of all kinds are located on streets in Edinburgh, where space is so often limited and in demand for multiple other uses, and in scarce supply for pedestrians in particular. There is potential for bins to be relocated off street in many places, and for space demands to be reduced by underground storage; as can be seen in a number of the cities with which Edinburgh both competes (e.g. for tourism) and likes to compare itself with. It is accepted that underground storage can be too expensive and will not be an option everywhere, but opportunities to introduce it arise continually in association with development and redevelopment processes, and CEC should initiate a system to take these opportunities.

This wider review should also embrace the waste management objectives set out in the finalised Edinburgh City Centre Transformation report of 12 September 2019, which approved early action to address waste collection through “operating plans for residential, commercial and public waste collection, including operators, vehicle restrictions, time restrictions and consolidation” (para 5.3.5). Potentially these plans will help deliver the aspirations in the ECCT to make a more walkable city, less dominated by traffic, especially heavy vehicles. 26 ton bin lorries have no place in many of Edinburgh’s streets and alternative ways of collecting waste must be explored, as already agreed by the Council.

Choices for City Plan 2030 – LSE Comments

Consultation Response, Council Policy, , , , , , ,

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