1. Introduction

1.1      Living Streets Edinburgh Group welcomes the publication and consultation on the Edinburgh City Centre Transformation Strategy.   We would like to thank the Council for its leadership in bringing this forward and the bold nature of the vision, which has the potential to transform the walking environment.

1.2      We have taken the opportunity to respond to the consultation under the following headings:

• General comments on the Strategy;
• Need for City-wide Transformation;
• Detailed Comments on the Strategy.

1.3      We are happy to meet with Council staff and Jacobs to explain and expand on our comments.   We would also like to be involved in the preparation of the final strategy and the detailed design process for individual elements within it.

 

2. General Comments on the Strategy

2.1      Walking (with or without an aid) is something we all have in common; at some point we have to get out of the car, off the bus or off the bike and walk.  Despite this we have, as a city, long accepted and planned for the private car as the dominant transport mode. A strategy that reverses this, puts people first and gives priority to travelling on foot is long overdue.

2.2      Transformation brings with it expectation and responsibility.  Delivery will require serious intent and ongoing commitment by the Council.  The scale of physical and behavioural change involved is significant, but eminently capable of achievement in the city that conceived and delivered the New Town.

2.3      This is a project that will span a number of Council terms and must not be subject to the vagaries of different political administrations that may come and go over its lifetime.  It requires “buy in” from all parties for the long term.

2.4      The focus of the strategy is on the city centre, but it cannot take place in isolation and must require significant change throughout the city to make it work and ensure that benefits are widely shared (see next section).

2.5      The strategy has no statutory basis, yet it will have to be delivered through a variety of statutory plans/processes including City Plan 2030, the City Mobility Plan and Low Emission Zones.  It is therefore essential that there is a clear pledge by the Council to see it through, ensuring that it underpins the statutory plans and that all internal structures and processes are joined up and remain so.  We have already seen examples of opportunities to deliver wider benefits for every day walking being missed on simple small-scale projects because of lack of dialogue between sections of the same Directorate.  The scale and complexity of transformation in this strategy is such that this just cannot be allowed to happen.

2.6      It is regrettable that the Delivery Plan is still under preparation as it is an essential part of the package.  The strategy promises a range of potentially exciting changes over a relatively short timeframe, yet a costed programme of projects and interventions is not available.  Consequently there is a risk that expectations have been raised and may yet be dashed before the strategy is off the starting blocks.  The Delivery Plan may be more bedded in reality if it has a clear sense of priority, distinguishing between short-term essentials and what may be longer-term desirables e.g. lifts and the tram line extensions. The experience from Leith Walk suggests some streets can’t accommodate public realm for walking, segregated cycle infrastructure and tram tracks so the detail on what can actually be delivered is important.

2.7      The Delivery Plan will be at the heart of the transformation project and the scale is such that the Council, with budgets constantly under competing pressures, will have difficulty in finding and maintaining the necessary resources to fund delivery on its own.

2.8      Edinburgh is the capital of Scotland and is iconic in UK terms. It is therefore hoped that commitments have already been secured from Scottish Government to enhance the Council’s spending settlement for the duration of the project and to make additional ring-fenced funding available for specific elements, ideally with additional buy in from UK Government. There is a case for the business sector to contribute, as a beneficiary from transformation.  The Council can also secure funding via a workplace parking levy, congestion charging, more rigorous enforcement of parking and road restrictions, and more targeted developer contributions.

 

3. Need for City-wide Transformation

3.1      In order to be meaningful transformation cannot take place in isolation in the city centre alone, it has to extend across the city and the timing is opportune to start this process.

3.2      SESPlan Strategic Development Plan 2 has recently been rejected by Scottish Ministers on transport grounds, one of them being that the plan does not take sufficient account of the relationship between land use and transport. The rejection letter from the Chief Planner dated 16 May 2019 makes specific reference to paragraphs 272-275 of Scottish Planning Policy. Para 273 prioritises modes of travel in the following order of priority: walking, then cycling, then public transport and finally use of private cars.   The reality is that, despite this unambiguous hierarchy, planning in the city has followed a reverse order of priority and the private car continues to dominate.  The Transformation Strategy can be a start in putting matters right, but it will not work in isolation.

3.3      The rejection of SDP2 reflects Scottish Government’s intention to deliver its policy and sends a clear message that City Plan 2030 and the City Mobility Plan should take the reasons for that rejection on board.  If the hierarchy in Scottish Planning Policy is applied across the city it means that transformation must extend to communities beyond the city centre, sharing the benefits and ensuring they do not suffer the consequences of any displacement of vehicular traffic from the city centre as a result of this strategy.

3.4      A significant reduction in car use is essential to make transformation work and ensure Edinburgh truly is a city with people at its heart.  In practical terms this means there has to be a change in mind-set in and around the city with acceptance that the private car no longer has priority.

3.5      There is plenty of good practice to draw on from within the UK and beyond.  For example, there is potential for mini-Holland style projects in neighbourhoods across the city, including Leith and Gorgie https://walthamforest.gov.uk/content/creating-mini-holland-waltham-forest or take a lead from the Barcelona Super Blocks http://www.bcnecologia.net/en/conceptual-model/superblocks

3.6      An extensive city-wide programme of physical, fiscal and legal interventions is needed including:

• widen pavements;
• introduce continuous footways as standard;
• create a network of segregated cycle lanes;
• reduce the width of carriageways and increase street planting;
• significant removal of on street parking;
• prioritise pedestrians at crossings;
• congestion charging;
• a workplace parking levy;
• city wide low emission zone;
• rigorous enforcement of parking controls, speed limits, bus lanes;
• expand and enhance the bus fleet replacing diesel with hydrogen or other zero emission technology;
• review the bus network within and around the city, where necessary introducing new routes/improve frequency;
• review train timetables and enhance services where possible;
• provide/enhance park and ride provision as required.

 

4. Detailed Comments on the Strategy

4.1      It is appreciated that this is a strategy, but it also identifies a range of specific measures and interventions without going into great detail.   It is stated that the Delivery Plan will provide a costed programme for individual elements over a 10 year period.   Having expressed disappointment that the Delivery Plan is not available as part of the current consultation, we consider it critical that it is the subject of further consultation when it is eventually produced.  This will allow scrutiny of the detail of the various projects and interventions and an opportunity to assess whether any of the ambition in the strategy has been lost or diluted.

4.2      The six principles on p16/17 are supported. However, the aims and objectives in the Interim Report that they are intended to deliver should have been repeated in the strategy so that anyone reading it can make a clear link to them from individual interventions via the principles.

 

4.3      The principle of People First (p16) and priority given to walking, cycling and public transport is most welcome.  With this in mind, and before embarking on detailed design, it is important to decide how to manage, not only private cars, but a variety of other traffic which contribute to unpleasant conditions for walking:

• taxis/private hire cars;
• bin lorries;
• vans;
• HGVs;
• tour buses (incl ‘City sightseeing’);
• long distance coaches.

4.4      To have a liveable (p17) and resilient city centre there should be a target to increase the residential population. This will have to be facilitated through planning decisions and controls over Air BnB type uses.  It will also to be necessary to have the necessary community facilities in place e.g. schools, doctors.

4.5      On p22, specific reference to and acceptance of the hierarchy of movement with people on foot first is welcome.  More detail is required on how pedestrian priority zones will be delivered, particularly the concept of vehicles as “guests” (which vehicles?), and there must be recognition that the city centre is a first phase, with pedestrians eventually prioritised across the city as required by the hierarchy.

4.6      The Pedestrian Priority Zone should cover the entire length of the Royal Mile and include Holyrood Palace/Scottish Parliament.  Its exclusion is illogical as it is that last section with narrow footways and constant traffic that is particularly difficult and unpleasant for the large number of pedestrians who use it.

4.7      There are no proposals to improve walking provision on Queen Street; this should be addressed.  It is one of the most important streets in the New Town, on the edge of the city centre, yet poor air quality, high traffic volumes and excessive waiting times at crossings create a hostile pedestrian experience.

4.8      The new pedestrian and cycling bridge between Jeffrey Street and Calton Road (p24) is welcome and it is hoped that reference to “vehicle free” extends to the currently unsafe junction with Leith Street thereby creating a more pleasant and safer approach to the station from Calton Road.

4.9      On p24 there is reference to “segregated and safe cycling routes”.  It is taken that this means all the cycle routes indicated will be segregated, including Cowgate despite its restricted width.

4.10   Does “full implementation of current Active Travel Plan” on p27 only refer to the cycling parts?   For the avoidance of doubt, the Council should commit to all outstanding walking elements in the ATP.

4.11   Public transport is key to the reduction in private car use and delivery of improved journey times and efficiency for buses accessing the centre (p28/29) is welcomed.  However, it also states that there will be a “reduced volume of buses crossing the city centre without a loss of service provision” with no indication of how his will be achieved.  The service improvement commitment to bus services is focused on the city centre, whereas people need to find it easier to use buses throughout the city.  Bear in mind that individual trips to the city centre may require more than one bus so it is essential that service enhancement is consistent across the city.

4.12   Is it correct to assume that “taxi” is used as a generic term to include all private hire companies?  As there is significant taxi usage in the city, incentives and controls should be in place to ensure vehicles are low or zero emission.  Is it possible to explore this as a condition of licencing?

4.13   The public transport interventions (p30/31) require careful assessment to ensure that they deliver benefits to all and that those who currently rely on these services do not lose out.

4.14   Bus priority can also be enhanced through bus lane extensions and greater enforcement, including parking at bus stops.  These are actions that can be taken now.

4.15   The concept of buses ‘kissing’ the centre needs to be illustrated to show how it will work and to ensure that people don’t have to change buses unnecessarily.  Many existing routes work and are supported because they cross the city centre (e.g. between Western General Hospital and Edinburgh Royal Infirmary) so introducing a change of bus may act as a disincentive.

4.16   More detail is needed on the proposed hopper service and the problem it is intended to solve. Likewise with the tram extensions on Lauriston Place and North/South Bridge which are surely unlikely to be delivered in the 10 year timeframe.

4.17   The desired 25% reduction in private vehicle movements in the city centre is noted (p32), but surely we can be more ambitious than that.  Apart from a few exceptions there is little need to bring a car into the city centre or to assume that residency in the centre requires it.  This target has to be revisited as well as consideration given to city-wide targets.

4.18   There is no target for reducing the commercial vehicle movements which contribute significantly to making walking unpleasant.  Traffic passing through the centre should be re-routed without detriment to other areas.  Vehicles coming into the centre will face greater kerbside restrictions, but this has to be accompanied by the rethink in vehicle types identified in the final bullet point on p32.

4.19   Reducing on-street parking (p34/35) is a key feature which is welcomed as it will increase space at a stroke for walking (and cycling) and will reduce car traffic looking for on-street places.  This has to involve more than lip service and a radical removal programme is required.  It must be accompanied by a work place parking levy, as well as a campaign to persuade businesses to voluntarily remove parking provision and replace it with incentives for employees to walk, cycle or use bus/tram/train. There is significant scope to apply this approach throughout the city and dramatically reduce the amount of on street parking in any location where public transport and walking/cycling are practical alternatives.

4.20   The Council has a policy that allows for car free developments, but it has been timid in applying it.   It should be the default position for new developments unless it can be demonstrated that the modes above cars in the hierarchy are not available.  Certainly within the city centre it has to be clear that no new off street parking is created aside from Blue Badge, car club and delivery bays. Otherwise new developments will generate more traffic growth. This must be set out in City Plan 2030. The space saved can go towards more housing (including affordable), more landscaping/gardens and allow for additional developer contributions towards public transport and other active travel infrastructure.   Developments such as the Engine Yard at Shrubhill on the edge of the city centre with its extensive underground car park should not be repeated.

4.21   The creation of an integrated transport and data management centre (p36/37) is noted, but more detail is required on what it involves and how it will operate to ensure it will be effective and provide all the data required.  This is critical as at present there is, for example, no proper monitoring of modal share.

4.22   The operations management plan is essential and it is surprising it does not already exist, but that would explain missed opportunities to enhance the walking experience.

4.23   It is assumed that the management of commercial bins includes the communal Council bins, but there also has to be management of private bins on the pavements.

4.24   The improvements in place (p38/39) are broadly welcomed.  There are however a number of specific comments:

• The 4 vertical lifts will be an innovation, but it is hoped that their inclusion is based on reality and not vague ambition so as to avoid disappointment if they don’t happen.
• The designated traffic free streets should be expanded to include Calton Road from the station car park to Leith Street and the eastern section of the Royal Mile.
• Main Public Space Improvement should include all of the Royal Mile, Calton Road, Leith Street, Cowgate, Market Street, Lauriston Place, all of Princes Street, Waterloo Place/Regent Road and the full length of Queen Street.

4.25   The concept of catalyst areas is a useful means of showing in more detail at this stage what can be achieved, but it is important that these areas do not become the sole focus and the principles of transformation are applied across the entire strategy area. Living Streets Edinburgh welcomes the commitment to develop detailed proposals in close consultation with relevant stakeholders and wishes to be part of this process.

4.26   The diagram on p48 identifies Morrison Street for public realm improvement, but not as a walking route although many people use it as a direct link to Lothian Road. It is a busy and deeply unpleasant street, totally dominated by several lanes of traffic. The public realm improvements will not change this unless accompanied by wider pavements and a reduced number of lanes carrying less vehicular traffic. The rationalization of the Haymarket junction is welcomed, it is currently a nightmare for pedestrians and the improvements must put people on foot first.

4.27   It is appreciated that Lothian Road (p56) is a challenge and the decision to instigate change is welcome. If it is truly to become a tree-lined boulevard then people have to be the focus, yet it appears from the information available that there will still be 4 lanes of traffic. This should be reduced to allow the tree planting on areas that are currently taken up by road with the pavements on both sides widened to improve the pedestrian experience. There is reference to reallocation of traffic lanes on a number of roads, including the West Approach Road, which requires clarification. Again the detail of what is proposed for this area is important and we look forward to involvement in that process.

4.28   The First New Town Strategic Plan (p64) identifies public realm improvements on Princes Street, George Street and parts of other key streets, but then excludes key streets where improvement is also required.   Given that Queen Street, Frederick Street, Hanover Street, and North/South St David Street are all also identified as key streets they should be assessed for public realm improvement, both in terms of improving the fabric (e.g. cobbles on Frederick Street) and giving pedestrians priority. (e.g. the St. David Streets being particularly poor).

4.29   As the strategy is intended to provide a high-quality pedestrian focused environment across this area, it is assumed that the specific active travel routes identified on the plan are focused on cycling. In which case, it would be better to make segregated provision on George Street and The Mound (as currently proposed) and also create similar provision on Princes Street. Rose Street could then be enhanced to create a high quality pedestrian street, surely an early priority given that there is a longstanding commitment which is now many years overdue.

4.30   Despite rationalization of bus services and stops there will still be 4 lanes of traffic/tram. This should be reviewed to identify any opportunity to widen the pavement on the south side of Princes Street that is currently too narrow for the volume of people using it.

4.32   The introduction to the section on the Old Town (p71) correctly identifies that the primary aim is to enhance the experience for pedestrians and the principle impediment is the presence of vehicles in an area that was clearly never intended to accommodate them. Within this context drastic measures are called for and there is an argument for restricting access solely to vehicles necessary for servicing and disabled people. Residency in this part of the city should not be qualification for keeping a vehicle in it, particularly on the street. Comments on other aspects of the Old Town proposals have been made earlier in this submission.

4.31   Proposals for George Street and Meadows to George Street schemes are at an advanced stage of preparation having been subject to consultation. It is assumed that they are compatible with and reflect the ambition of this Strategy.

4.33   The Waverley/Calton proposals (p78) embrace the area covered by the emerging Waverley Station Masterplan.  This strategy has a 10 year timescale and the Masterplan, covering a smaller area, is for a period of 30 years.  Ideally both projects would be implemented in the same timeframe so it may be worth exploring if the Masterplan could be condensed into 10 years, at least the significant and most disruptive elements.  Alternatively, a more realistic timeline for both projects may be 15 years, but in any case delivery has to be aligned.

4.34   Proposals to enhance the walking experience in and around the station are generally welcome, but detail is required.  For example, what does pedestrian priority mean on Waverley Bridge?  Tour buses will be removed, but it is unclear which buses if any will still be permitted, although it was understood from the Masterplan consultation that they would all be removed.

4.35   The issue of service traffic for the shopping centre and station has to be addressed as there is potential for conflict.  The possibility of servicing by rail, including short haul from other stations around the city, should be investigated.  There should be no provision for car parking other than bluebadge holders.

4.36   The eastern end of Princes Street is currently an unpleasant place for pedestrians with a combination of traffic volume, fumes, barriers, narrow footway on southern side and conflict with the large volume of people entering and leaving the station via Waverley Steps.   This Strategy and the Masterplan can address this situation.  Space should be taken from the road to widen the pavement on the southern side, traffic has to be reduced and the public realm enhanced.

4.37   The North Bridge/Princes Street/Leith Street junction is one of the worst pedestrian experiences in the city centre.  It is difficult to navigate and confusing for the unfamiliar.  The plethora of barriers should be removed, traffic reduced, and the pedestrian crossings redesigned to ease navigation and give walkers priority.

4.38   The redevelopment of Edinburgh St James had potential to transform Picardy Place and Leith Street, but that ship has sailed, the opportunity is lost and the works currently underway are the polar opposite of what this strategy intends.  There is still an opportunity to mitigate matters with public realm improvements, including significant tree planting, prioritise pedestrians at all crossings and close Calton Road to traffic.

4.39   With the intended reduction in traffic entering the centre and closure/restricted access in several streets there is likely to be some displacement.  It is possible that this may impact negatively on the Bridges/Nicolson Street, which are understood to already have the worst accident records in the city.  North Bridge is to have reallocation of traffic lanes, but it is unclear how it will be transformed for pedestrians.

4.40   It would be useful to have sight of the traffic modeling that was presumably undertaken as part the strategy to ascertain if displaced traffic would ‘evaporate’ or end up on this corridor.  The issue of displacement is part of the case for tackling transformation across the city and not only in the centre.

4.41   The Innovation Mile (p86) covers an area where walking is not subject to the same level of competition for space, but there is still scope to enhance the experience and that is welcomed. Public realm improvements to Lauriston Place are appreciated, but there are also locations (usually at junctions) where pavements should be widened to accommodate the number of pedestrians.  South Bridge/Nicolson Street requires enhancement and pavements widened.  There would appear to be an intention to remove the rather brutalist over/underpass at Bristo Square which is welcome.  There is no mention of the long standing Causey project which is a gateway to Nicolson Street and the “Innovation Mile”.  It is 10 years over due and should be included as an early priority.

5. Conclusion

5.1      This Strategy and the actions that flow from it can transform the walking environment in the city. The Council is to be congratulated for instigating the project, now Living Streets Edinburgh is keen to work with the Council and others to realise the ambition within it.