Tag Archives: City Mobility Plan

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.