City Mobility Plan – Consultation Response
Posted on: April 27, 2020
Our detailed response to Edinburgh City Council’s consultation on its City Mobility Plan
Between 31 January and 7 May 2020 Edinburgh City Council sought responses on their ‘City Mobility Plan – Draft for Consultation’ a ten year strategy intended to transform the way people, goods and services travel around the city.
Following extensive consultation between members of our Policy and Development committee and our individual and affiliate members and other stakeholders, this is our official response to this consultation exercise.
The City Mobility Plan ‘Connecting people, transforming place’
When presented to the City of Edinburgh Council for consideration, the draft City Mobility Plan was premised on the statement that more people in Edinburgh use public transport and active travel modes (walking and cycling) than in any other Scottish city and most UK cities and that the public transport companies operating in the city such as Edinburgh Trams and Lothian Buses are generally regarded as being both popular and affordable. This is part of the successful foundation on which the draft City Mobility Plan is based.
On the other hand, Edinburgh is now consistently rated as one of the most congested cities in the UK. As reported to Council committee 19% of peak driving time in Edinburgh is spent in congestion, which adds 40% travel time to each peak time journey (Inrix traffic scorecard report, 2016). The cost of Edinburgh’s congestion to the local economy is estimated at £225m per annum (Tom Tom Traffic Index); air quality as a result of transport-related emissions across parts of the city is worryingly low and has been consistently so for some time, bus use is declining, car use is increasing with no sign of congestion easing.. The cost of public transport is also increasing while arguably accessibility and utility for some user groups is declining.
The draft SEA Environmental Report which accompanied the draft City Mobility Plan highlights that in addition to congestion there are several other issues affecting the city’s transport system resulting in the system operating below its capabilities. These include roads in need of maintenance, a limited cycle network, a limited bus lane network and poorly maintained public transport facilities in some locations. A fuller detailing of these issues and opportunities for their resolution would be an appropriate addition to the final City Mobility Plan
In addition, given the anticipated short-term significant population growth for the city and the numerous recent or consented low density housing developments in and around Edinburgh and the city region – many with limited or not sustainable transport infrastructure – the existing transport related problems seem intractable. A radical transport intervention would seem to be required.
The Cockburn welcomes the overall vision and objectives of the City Mobility Plan. When considered in conjunction with the draft policy revisions in the City Plan 2030, there is clearly an emerging potential for the city to take major steps forward toward a lower carbon, climate-ready and more sustainable city with a diversity of sustainable travel opportunities.
Taken in the round, the draft City Mobility Plan arguably does show ambition, proposing concrete measures to reduce/manage demand for car trips into the city and to promote and encourage the use of sustainable transport modes. It includes plans to develop high-capacity transit corridors and cycle routes on major arterial roads, tackle freight transport issues, and enable transhipment hubs and green last-mile deliveries.
However, the Cockburn does not believe that this is a plan nor even a strategic framework. It reads like a project list, a wish list or an infrastructure and Investment programme. But on this last and fundamental point, there is almost a complete lack of detail. An infrastructure and investment programme is not the same thing as a mobility plan. There needs to be much more focus on the underlying actions and behaviours of individuals, and how to influence those. It would also be reasonable for such a plan to be accompanied with an indication of cost and how it will be funded. In addition, since turning policy/plan into action is often problematic.
The draft SEA Environmental Report which accompanies the draft City Mobility Plan makes clear that “the CMP plays a pivotal role in linking national, regional and city policy context through to guiding delivery plans and resourcing across the city”. On the other hand, the draft City Mobility Plan lacks any detail on how this linkage will facilitated and monitored to achieve tangible and positive transport benefits particularly in the context or the emerging City Plan 2030 and in relation to the Edinburgh City Centre Transformation Programme and the Sustainability Strategy 2030.
We would also like detail to be provided on a process to measure success/failure of the draft Mobility Plan set within the context of the success/failure of the Local Transport Strategy 2014-2019 and associated land-use planning policies and with an indication how the draft Mobility Plan addresses previous failures and builds on established successes.
More than ever, climate change adaptation actions, for environmental, ecological and health reasons also need to be included in the final version of the Mobility Plan by not at the expense of the safely and utility of streets for pedestrian and cyclists.
When the draft plan was written no consideration had to be given to the dramatic change in circumstances represented by the current COVID-19 pandemic. Now, the Scottish and UK Government’s measures to slow the spread of COVID-19, including closing schools, advising working from home and restricting personal freedoms, have created enormous uncertainty for projects and construction in terms of how these restrictions apply to site operations. At this stage it is impossible to know how big an impact the pandemic is going to have on the projects listed within the draft mobility plan, how long the impact will last and what its full impact is going to be. However, the impact may be significant and long-lasting. Given that the draft Mobility Plan is essentially an infrastructure and investment plan, the impact of COVIS-19 must be addressed. It may be that a “do minimum” infrastructure and investment option must now be considered which focuses on how to achieve significant behaviour change and modal shift without large-scale new investment and projects.
In addition to all of the points made above, we encourage the council to ensure that the approved City Mobility Plan is amended to specifically highlight the importance good and timely maintenance of transport infrastructure, both existing and proposed, the maintenance of good road surfaces, pavements and pedestrian routes and of cycleways which are essential for active travel.
We particularly emphasise the importance of the timely and high-quality maintenance of existing pedestrian-focused infrastructure including pavement surfaces, kerbs, setts, crossing points and road markings is a pre-requisite of people friendly streets. The provision of new infrastructure is not a substitution or replacement for the maintenance and upgrading of existing pedestrian infrastructure or for any of the other issues identified in the draft SEA Environmental Report which detract from the performance of Edinburgh’s transport system. We believe that it is essential that the final City Mobility Plan included a costed and timetabled maintenance plan for Edinburgh current and future transport infrastructure.
Contributors to the Cockburn’s series of “Our Unique City” soapbox sessions which were run over the last twelve months made a point which is highly relevant to the City Mobility Plan which the draft plan acknowledges but should address more fully. The way residents and commuters travel around the city has changed and is still changing. The days of simple home-to-work or home-to-shop linear point-to-point journeys are a thing of the past for many people. Life has become much for complex. 24/7 working, caring responsibilities and the challenges of the gig economy can mean that the individual journeys undertaken by residents and commuters have become more multi-functional and convoluted. This complexity will not be easy to address in a manner that fulfils the needs of most citizens and it is not a challenge that can be address by traditional infrastructural interventions alone. But it is a challenge which the City Mobility Plan must rise to.
However, turning policy into action is the big issue with the plan. Most of the proposed actions to 2022 are in progress or are in development. Although the scale and nature of their impact in terms of a tangible improvement to sustainable travel is a matter of debate and conjecture, to a degree.
Even before the advent of COVID-19 the actions listed in the plan as ‘bolder actions’ and ‘a city transformed’ looked ambitious in a 10-year delivery context when compared with the time taken on comparatively minor projects to date – some of these are also likely to be wishful thinking, contentious, difficult or now impossible to deliver or fund and relatively minor in terms of a positive contribution towards city-wide sustainable transport and carbon reduction targets.
Nevertheless, over time, other cities have managed a transformational change in their transport infrastructure and there is no real reason why it could not happen in Edinburgh if there were to be the political will at a national and local level, community support and cultural change and funding.
Specific Comments on Consultation Questions
5. To what extent do you support or oppose the vision set out for 2022
The Cockburn supports the Council’s vision set out for 2022 the majority of which are being implemented or actively progressed And we have welcomed the opportunity to contribute to and participate in associated consultation activities and stakeholders’ events that have help to shape the nature and details of major programmes coming forward begore 2022 such are the City Centre Transformation Programme and the Edinburgh Waverley master planning process. We continue to engage with the project team working on this latter initiative and, at this point, are still seeking resolution of a number of our concerns and issues
Arguably, the provisions set out for 2020 are relatively limited and will make a consequentially limited contribution towards the council’s 2030 carbon reduction targets However, it must be acknowledged that the City Mobility Plan both builds on the foundation of practical sustainable development infrastructure and opportunities which have already been implemented in the city and the plan’s objectives will be assisted by proposed policy changes coming forward in City Plan 2030.
But, we welcome the council’s wish to roll out Low Emission Zones as a means of reducing the many dis-benefits associated with high-polluting vehicles, such as large vans, pickups and HGVs. This should encourage residents and commuters to use cleaner vehicles, such as hybrids and electric cars, and ultimately improve the quality of the air. However, the cost of hybrids and electric cars and other vehicle is still prohibitive for many drivers.
The absence for the draft City Mobility Plan of a specific programme to support and facilitate the use of electric vehicles, or those using hydrogen technologies, in Edinburgh is notable and this omission should be addressed. Electric mobility is widely seen as a way to improve air quality and meet climate goals. But it is unlikely that market forces alone will be able to significantly increase the use of electric cars and other vehicles across Edinburgh by 2030. The public sector and its key partners will need to be involved in promoting a local electric vehicle infrastructure that related to the city’s energy system, residents’ needs, mobility culture and patterns. The draft City Mobility Plan should seek to more actively prioritise and incentivise the electrification of high-use vehicles such as taxis and public transportation. This is likely to have a positive impact in reducing carbon and polluting emissions. These types of vehicles are driven far more than personal-use vehicles, so commercial and public electric fleet development should be encouraged. In addition, provision must be made in the City Mobility Plan, or in other plans with which it is being linked, to ensure that electric vehicle charging infrastructure is developed along roads, at destination points and close to public transportation nodes in advance of user demand. This will ensure that current electric vehicle users always have access to charging points and promote the transition to electric vehicles in in commercial and private market.
6. To what extent do you support or oppose the vision set out for 2025?
The Cockburn supports the Council’s vision set out for 2025 but with some reservations.
Given the very limited timeframe available for the implementation of the City Mobility Plan we would have expected to see a significant ramping up of city-wide project activity and sustainable travel interventions if serious inroads into the substantial contribution made by transport- related emissions to the city’s carbon footprint are to be achieved. In this context the vision set out for 2025 does not seem ambitious enough.
However, we welcome the fact that a detailed plan will be in place to reallocate road space on all arterial routes to deliver improved public transport and dedicated active travel infrastructure. If this can be implemented, this is a positive development which will improve the active travel experience of many residents.
It is particularly welcome to see an ambition to improve the conditions for pedestrians. If a city-wide and meaningful delivery of the Edinburgh street design guidance policy and a rigorous approach to enforcement can be achieve this will also be positive.
We note that funding from a workplace parking level will be a source of funding for sustainable travel interventions. Such levies may indeed be a useful source of funding and their implementation may have the beneficial effect of making more land available for other uses such as “pocket parks” or additional active travel infrastructure. However, building support for a workplace parking levy will require careful planning while the implementation of a comprehensive exemption scheme could also help win support citywide. We believe that the roll out of a workplace parking levy by 2025 will be challenging in Edinburgh. But we accept that in such a congested city workplace parking levy may be a relatively fair and efficient way to raise the money needed to improve citywide sustainable transport infrastructure.
As vehicular technology becomes cleaner and more sustainable and as travel patterns evolve across the city it may be appropriate to consider to develop additional residential and general parking proposals that keep pace with these changes and that are designed to encourage residents to switch to cleaner, more sustainable modes of transport whilst support the needs of residents and commuters that require everyday car and parking access.
We also welcome the council’s plan for sustainable neighbourhoods and in this context new policy with the City Plan 2030 will be very importance. Nevertheless, it will be extremely challenging in the available timeframe to deliver transport sustainability to new built residential estates on the urban fringe or within the city region which have, in so many case, were limited access to sustainable travel opportunities at this time.
The impact of COVIS-19 must be addressed, and, in this context, the Council’s vision set out for 2025 should only be included in the finalised Mobility Plan if, on reassessment, there is a realistic possibility of delivering this vision. It may be that a “do minimum” infrastructure and investment option must now be considered which focuses on how to achieve significant behaviour change and modal shift without large-scale new investment and projects.
7. To what extent do you support or oppose the vision set out for 2030?
The Cockburn supports the Council’s vision set out for 2025 but with some reservations.
If the proposed the mass transit network can be developed by 2030 this will be a positive development.
However, we are concerned that building additional parking, for example additional park and ride spaces on the outskirts of the city or elsewhere in the city region, without managing the existing demand for car based commuting could encourage driving, increase the demand for even more parking in the longer term and do little to reduce the environmental and carbon dis-benefits associated with car based travel in general terms albeit it may alleviate these issues in the city centre.
In this context we note that there is no reference to the planned major road schemes that will take place during the plan period at Sheriffhall and Gogarburn. These and similar transport initiatives around the city being brough forward through the City Deal have the potential to generate more car-based traffic. The council’s ability to co-ordinate with local authorities across the city region and with the Scottish Government is vitally important is the City Mobility Plan is to achieve its aims.
If the city’s cycling network and associated cycling infrastructure is improved by 2030, as proposed. There can be every expectation that rates of cycling will improve. But in the limited timeframe available the anticipation of “mass commuting” is pre-mature. When the densities of pedestrians and bicycles are low, pedestrian cyclist conflicts are relatively infrequent. But since both the number of residents in Edinburgh is projected to significantly increase and the number of cyclists is expected to increase it is reasonable to assume that the potential for conflicts among road space users may become more frequent. It is timely for the draft City Mobility Plan to include clear and specific provisions to reduce conflict and remove the potential for conflict between cyclists and pedestrians on existing paths, pavements and road crossing-points and when new facilities are being designed.
We contend that it is unrealistic to aspire to a car free city centre by 2030, except in a very restricted sense of what constitutes the city centre. The draft City Mobility Plan is simply not ambition enough to bring about truly radical changes to citywide travel behaviour. A more achievable and appropriate goal for a city like Edinburgh would be to seek to achieve a car free “central business district” rather than the whole “city centre”.
On the other hand, the implementation of seamless ticketing and a much-improved cycling network by 2030 should be possible, will be beneficial to many and is to be commended.
We urge the council to press ahead with the development of goods micro-distribution hubs across the city. The Cockburn has been supportive of this idea for some time in the context of city centre brownfield development, but the opportunity should be taken to facilitate such innovative delivery option across the city in conjunction with the city’s emerging sustainable travel infrastructure.
And we further welcome any increase in the provision of strategic walking and cycling networks that can be achieved by 2030. But note how difficult and time-consuming the implementation of similar, existing schemes has been. Within the limited timeframe of 10 years, achieving significant beneficial change will be challenging. In parallel, existing city guidance will need to be updated and revised to ensure that the expansion of walking and cycling infrastructure adds to, never detracts from, the unique sense-of-place of communities. Neighbourhoods and conservation areas across the city and always supports Edinburgh built and natural heritage.
Particularly when considering the longer terms aims of the mobility plan, it is important to emphasis that mobility, travel and transport management and infrastructural development is not an end in itself. At a city and city-region level mobility and transport planning relates directly to wider aspects of local and regional land use planning, architecture, landscape urban realm design, urban economics and social policy. It touches all aspects of city and city-region life such as economic development, quality of life, social equity, public health and ecological sustainability. It is a prerequisite for the successful and sustainable mobility planning for Edinburgh that city-based actions are clearly and explicitly set within a city-region and national context.
As above, the impact of COVIS-19 must be addressed, and, in this context, the Council’s vision set out for 2030 should only be included in the finalised Mobility Plan if, on reassessment, there is a realistic possibility of delivering this vision. It may be that a “do minimum” infrastructure and investment option must now be considered which focuses on how to achieve significant behaviour change and modal shift without large-scale new investment and projects.
8. To what extent do you support or oppose the following proposals to enhance public transport?
The Cockburn strongly supports the following proposals:
- Co-ordinate bus, tram and bike hire operations to better serve the city and wider region
- Expand the tram network in the city and potentially into the wider region in order to carry high volumes of people in a clean and efficient way
- Introduce smart contactless payment options across all public transport and operators
- Support the introduction of shared transport options to complement timetabled public transport – this could include community run buses, car clubs and bike hire
9. Please use the space below for any comments or suggestions on what we are doing, or propose to do, to enhance public transport
Clean, safe, efficient public transportation that means the travelling needs of residents and commuters will be an important contributing factor to Edinburgh’s sustainability and carbon neutrality by 2030. But transport does not exist in a vacuum and at all times public transportation must consider issues such as accessibility affordability; connectivity; holistic transportation and land use planning; and planning with the environment in mind if it is to be truly sustainable in the 21st century.
We are particularly mindful of points made by contributors to our recent ‘Our Unique City’ discussions relevant to the City Mobility Plan which the draft plan acknowledges but should address more fully. The way residents and commuters travel around the city has changed and is still changing. The days of simple home-to-work or home-to-shop linear point-to-point journeys are a thing of the past for many people. Life has become much for complex. 24/7 working, caring responsibilities and the challenges of the gig economy can mean that the individual journeys undertaken by residents and commuters have become more multi-functional and convoluted. This complexity will not be easy to address in a manner that fulfils the needs of most citizens and it is not a challenge that can be address by traditional infrastructural interventions alone. But it is a challenge which the City Mobility Plan must rise to. It is not clear to us that the draft Mobility Plan does rise to this challenge in terms of its proposals for public transport.
10. To what extent do you support or oppose the following proposals to create people friendly streets?
The Cockburn strongly supports the following proposals:
- Create direct, segregated cycling routes along main arterial roads to provide for safe and quick journeys by bicycle
- To support the transition to cleaner vehicles, develop a comprehensive network of electric vehicle charging points
- Minimise the number of freight vehicle trips by developing distribution centres and click-and-collect hubs across the city
11. Please use the space below for any comments or suggestions on what we are doing, or propose to do, to create people friendly streets.
We fully endorse the comments by Living Streets Edinburgh relating to absence of references to the ‘movement hierarchy’ in the draft mobility plan.
We particularly agree that the draft plan makes insufficient reference to the needs, requirements and expectations of pedestrians and to the promotion of ‘everyday walking’ by improving pedestrian infrastructure across Edinburgh as a while.
Here we particularly emphasise the importance of the timely and high-quality maintenance of existing infrastructure including pavement surfaces, kerbs, setts, crossing point and road markings is a pre-requisite of people friendly streets. The provision of new infrastructure is not a substitution or replacement for the maintenance and upgrading of existing pedestrian infrastructure.
Walking is the most environmentally sustainable and healthy mode of travel. For many people in Edinburgh walking remains the most convenient and pleasant way of getting around the city for work or pleasure.
However many of the city’s road are significant barriers to pedestrian movement and where pavements are present these may be too narrow in busy areas or pedestrian movement may be restricted in other ways by such by Illegally parked cars, street furniture, high kerbs, cycle lanes, absent or poorly maintained street and road marking etc.
In addition, we believe that increasingly roads, streets and paths will also need to find a way of accommodating actions to address the Climate Emergency. Space for additional trees, shrubs, flowerbeds, grass and sustainable urban drainage to make streets more resilient to a changing local climate and more attractive and safer for active travel modes such as walking and cycling. More than ever, climate change adaptation actions, for environmental, ecological and health reasons also need to be included in the final version of the City Mobility Plan by not at the expense of the safely and utility of streets for pedestrian and cyclists. We signpost taking an urban ecology approach to understand and demonstrate how nature and greenspace can permeate Edinburgh’s transport infrastructure, contribute to sustainable everyday urban living, and how streets and paths can be managed to make Edinburgh a climate-resilient and healthier place in which to live and work.
Finally, we reiterate the important point that the draft City Mobility Plan must clearly demonstrate how it links to, benefits from, and adds to the associated national, regional and city policy context.
12. To what extent do you support or oppose the following proposals relating to planning new developments?
The Cockburn strongly supports the following proposals:
- Introduce transport hubs in major new developments to accommodate public and shared transport, and to enable co-ordinated deliveries and click-and-collect hubs
- Control the level of parking in and around new developments and include requirements for car club, electric vehicles and bike hire provision
- To change travel behaviours, require travel plans for major new developments, workplaces and schools that include targets for walking, cycling and public transport use
13. Please use the space below for any comments or suggestions on what we are doing, or propose to do, regarding planning new developments.
The delivery of the City Mobility Plans objectives regarding planning new development will be high dependant on the new policy framework emerging from the City Plan 2030 consultation. On this we have made a separate representation.
14. To what extent do you support or oppose the following proposals to manage travel demand?
The Cockburn strongly supports the following proposals:
- To create space for public transport, walking and cycling, reduce the level of on-street parking in areas well-served by public transport whilst enabling parking for residents and people with mobility difficulties
- Explore the introduction of road user charging within the city to reduce the number of vehicles
15. Please use the space below for any comments or suggestions on what we are doing, or propose to do, to manage travel demand.
We are particularly keen to ensure that the council meets the legitimate and reasonable expectations and needs of residents, people with mobility difficulties, essential car users and low-paid workers in the gig economy.