Tag Archives: Consultation

LSEG: Comments on the City of Edinburgh Council’s Draft Public Transport Action Plan 2023

City Mobility Plan, Consultation Response, , , ,

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

Pavement Parking,

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

Living Streets Edinburgh Group response to draft Council plans, May 2023

Consultation Response, , , ,

The City of Edinburgh Council has issued a number of important draft plans related to its overall ‘City Mobility Plan’.  You can read our comments here on the plans for Active Travel, Road Safety and Parking.

You can see the Council’s draft plans, and how to comment on them here: https://consultationhub.edinburgh.gov.uk/sfc/cmp/ The deadline for responses is 9 July 2023: please have your say! We also welcome your feedback on our comments. 

LSEG Parking Action Plan 2023Download
LSEG ATAP 2023Download
LSEG road safety 2023Download

LSEG comments on proposed development Yeaman Place, November 2022

Planning Permission, , ,

The Edinburgh chapter recently made representation to the CEC planning department in respect to comments on the planning application for new student housing at Yeaman Place and in proximity to the Union canal.

The representation was supportive of the development in principle, given the net benefit to pedestrian access in the area, as well as increasing personal security for vulnerable users of the canal towpath. We would however, like to see this access being formalised and that waymarking signage should be applied given that the access might not be obvious or intuitive.

The application could improve and crucially, the developers have indicated that they cannot provide direct ramped access between Yeaman Place and the canal. The access will only be stepped, which will be a significant disadvantage to those with additional mobility needs. In our representation, we asked that the CEC planners interrogate the engineering constraints outlined by the developers as to why they could not provide ramped access.

Finally, our representation also acknowledged that the development does not provide parking provision, which is welcomed so that it does not “bake in” car-dependency, but we have asked that the CEC planners be considerate of the impact that drop-off/pick-up could have on the pavement and cycle lane on Dundee Street.

If there’s a planning matter which you’d like to bring to our attention in your local area, then why not touch base with us to see how we can help you. Please contact planning@livingstreetsedinburgh.org.uk.

Tollcross Primary School – Travel Survey 2022

Road Safety, Street Audit, , , , ,

Tollcross Early Years Campus is a combined nursery/primary-level educational setting – comprising Tollcross Primary School  (est. 1912), Tollcross Nursery and Lochrin Nursery School – with an approximate combined attendance of 300 students. 

Within this most recent travel survey, the families of Tollcross Early Years Campus sought to reflect on our school run and highlight solutions which place safe, convenient and active travel at the centre of the school run.

Our data highlights that the majority of respondents – 73% – walk to school over a distance of less than 2 miles. However, many respondents reported that shortcomings in the quality of infrastructure made active travel unpleasant at best or impossible at worst. Looking toward solutions, respondents indicated that widening pavements and improving cleanliness (e.g. emptying over-flowing bins) would make them more likely to choose active travel modes to get to school. More ambitiously, overhauling the design of Tollcross Junction to prioritise pedestrian throughput would bring positive, sustainable and long-lasting improvements to the lives of many of our families and to the safety of our children.

The full report can be read here – 2.2mb PDF