(The following is the text of NTBCC's response to the 'connecting our city, transforming our places' consultation, submitted in mid November 2018)
NEW TOWN & BROUGHTON COMMUNITY COUNCIL Response to Connecting our City, Transforming our Places
- We support the general ambition of CCTP to reduce traffic, and improve air quality and public transport.
- Public realm in the centre should be enhanced – but with safeguards in place to protect the amenity of the Second New Town and surrounding areas which are vital assets for the city.
- The measures must not result in increased traffic, parking and pollution in areas adjoining the centre.
- Councillors and officials should find ways of working more effectively together to ensure that delivery of policies fully meets the commitments made at the start.
- A reduction in bus services through the centre of town should only be considered at a later stage.
- Preservation of existing public realm is more important than developing new spaces.
- Planning and delivery of all initiatives should include meaningful engagement with local residents and businesses.
We support CEC’s aspiration that Edinburgh should be a 'world class environment for its residents' and believe that if sensitively implemented, the proposed measures should help to improve the public realm, promote more active lifestyles and make the city a healthier place to live.
The residential centre
The built environment of the New Town is an essential part of Edinburgh’s appeal for visitors and its attractiveness as a place to live an important factor in the city’s wider economic success. We believe that to preserve these, traffic reduction and enhancement of the public realm should take place across both the First and Second New Towns and their surrounding ‘town centres’ such as Picardy, Broughton and Stockbridge, as defined in the prospectus. We are concerned that reducing traffic in the city centre will have the effect of increasing it in the surrounding areas, with the attendant issues of parking and pollution.
Achieving the CCTP aims will be dependent on other actions and we ask the Council to address these as well.
Overall management of development and events
In addition to traffic volumes, we feel the city centre is adversely affected by over- development, over-provision of events, and difficulties on occasion in enforcing planning control. We believe that addressing these existing issues would help the Council to enhance the public realm.
Further, there are two important workstreams which will determine the success or otherwise of CCTP: future parking controls; and the quality of traffic modelling of the 3 key North/South routes through the city centre.
The Council says it wishes to 'dissuade non-essential driving trips into and across the city' (page 28) and that 'the use and location of parking controls will have to be examined as part of any preferred strategy' (page 8). We welcome this commitment to reappraise parking controls in the light of the final CCTP strategy. This is likely to involve a more robust approach to parking in the central zones which allows for residents’, commercial and public transport needs but dis-incentivises other vehicle journeys as much as possible. The Parking Action Plan and the St James project both appear to involve the creation of additional parking spaces in the NTBCC zone, which can only increase the number of journeys made: we ask that the Council should consider this when it examines the use of parking controls in the light of the final strategy.
Key North/South routes
We also ask that modelling work on the key North/South routes is carefully planned and carried out to ensure that the results are robust. Reducing traffic and improving air quality on East/West routes, especially Queen Street, is equally important and we look forward to the Council’s proposals to deal with that.
We support 'improving the quality of places' and agree that in some cases like Bristo Square this has been achieved. Other examples quoted such as Mound precinct are in our view less successful. Some current proposals such as those for East and West Princes Street Gardens have provoked considerable public concern. We suggest that to achieve greater consistency in the delivery of sensitive projects, a way is found for councillors and officials to work together more effectively to ensure that final outcomes match the public expectations raised by the initial proposals.
We agree that ‘town centres’ should be ‘nurtured’ to maintain and enhance those environments. If this happens, it is likely to help relieve the pressure of events and footfall in the centre of the city.
We support the measures aimed at traffic reduction, namely introduction of more car-club and bike hire locations, promotion of peer-to-peer car hire, car sharing, a workplace parking levy, reduction in the volume and size of commercial traffic (which can have an adverse effect on road surfaces and/or be a hazard for cyclists), the introduction of freight depots, proposals for temporary vehicle-free streets (‘Open Streets’) and the development of strategic walking and cycling routes across the city. Each of these measures could help improve the residential character of streets in the New Town and Broughton areas, which has suffered in recent years.
Traffic reduction will help improve air quality but we also support the specific measures aimed at doing so such as investment in electric vehicle charging points, implementing a Low Emission Zone, restricting access to the centre of the most polluting vehicles, and encouraging the use of smaller, cleaner vehicles for deliveries within the city.
The Council should continue to address pollution by taxis and buses – one of the most significant sources – but also look for ways to tackle other sources such as diesel plant, gas central heating boilers and the generators used in events. Responding to the recent Diesel Surcharge consultation we said private vehicles no more than 2-3 years old and meeting Euro VI/6 standards should not be penalised as they already represent a significant improvement on previous vehicles, and we recommended that targeting HGVs and LGVs might make the most difference.
The consultation asks for views on a reduction of on-street parking. There should be a sufficient number of dedicated spaces for residents and visitors alongside provision for necessary commercial vehicles. Beyond this, we agree that on-street parking should be minimised. This should apply particularly in the zones around the city centre. As noted above this policy appears to conflict with the direction of the Parking Action Plan and we ask that this contradiction is resolved. Increasing the number of car journeys into the periphery of the city centre will not reduce traffic or improve air quality.
We also support the measures aimed at expanding public transport such as the development of transport hubs, through-ticketing, the expansion of the park and ride network and incentivising drivers to use it.
Bus congestion on key streets in the city centre is part of the current problem and we agree it should be addressed within a reasonable timeframe. However this should be balanced against the need to maintain levels of service for residents in the outer areas of the city.
We agree that bus services should, in time, be realigned in the context of any extended tram service however as noted in our responses to both Tram consultations, we cannot comment on proposals to alter bus services without sight of detailed proposals from Lothian Buses.
Many residents feel that the quality and ambience of public realm in central Edinburgh has, overall, declined markedly in recent years. There are likely to be many causes, some beyond the control of the Council, however over-commercialisation, poor planning control and an apparently unrestricted growth in events also play their part.
We support the practical measures suggested such as widening pavements, creating new public spaces and enabling views to be enjoyed (page 12). However we would ask the Council to make it a higher priority to protect existing views and historic public spaces like Princes Street Gardens from intrusive and unnecessary development.
There are some measures which do not feature in the prospectus which we believe essential for improving the public realm: these include maintenance of existing pavements, reclamation of pavement space from commercial use, greater sensitivity in firmer control of restriction of street furniture, protection of the public realm from undue commercial activity, sensitive management of the city’s tree heritage (surprisingly not in the prospectus), firmer control of the size and duration of events, and regulation of short-term lets.
Edinburgh has lost a third of its 'street trees' in the last twenty years: it should be a priority to prevent any further loss and to restore the deficit. We support the Edinburgh Tree Time project and urge that its work is aligned with that of any CCTP initiatives.
'Arm’s-length external organisations'
We do not support the Council making arrangements with commercial bodies (such as Essential Edinburgh) which break the line of accountability between electors and councillors, and put decisions about parts of the public realm beyond the control of elected councillors. The recent almost unanimous public rejection of the proposal to run West Princes Street Gardens through an ALEO ('arm’s-length external organisation') is clear evidence of public opinion on this. We would not support any initiative which involves further erosion of democratic accountability in this way.
We support the measures aimed at reducing traffic and air pollution. We believe that enhancing the public realm need not always involve new developments, and much may be achieved by protecting and conserving existing assets.
The core question in the prospectus is 'what level of change and innovation we should embrace' and three levels of intervention are described: 'business as usual', a 'strategic approach'’ and – most boldly – 'transformational change' by which 'you would be able to go to, but not through the city centre'.
There will be support for each of these however we suggest that for now, CEC adopt a pragmatic, middle path – a 'strategic option'; and consider more radical actions when more moderate ones show signs of success.
We welcome the promise of further consultation early in 2019.