Roseburn to Leith Walk Cycle Link Consultation Response from Lothian Buses Summary of response Lothian Buses is the main bus operator within Edinburgh and operates services along two-thirds of the roads covered by this consultation. Our business relies on being able to move people around Edinburgh without encountering congestion and we support initiatives that encourage people to make less use of cars. The proposals for a cycle link from Roseburn to Leith Walk being consulted upon have a commendable aim of making cycle travel within Edinburgh a more attractive option, but the link appears to have been designed with only cyclists in mind. There is no evidence of any consideration for other road users (pedestrians, cars, taxis, buses, trams and emergency services), traffic issues that currently exist, how Edinburgh functions throughout the year or improvements for the non-car user such as bus lanes and the transport interchange at Haymarket. The full response describes Lothian Buses’ principal areas of concern and then details forty areas of particular concern at various locations along the route of the proposed cycle link. Background Lothian Buses are the main operator of bus services in Edinburgh and the surrounding area, operating over 70 routes using over 700 buses and on an average day carry over 350,000 passengers. As a key stakeholder in the operation of the road network, particularly in the city centre, Lothian Buses has for many years been invited by the various departments of City of Edinburgh Council (CEC) to meetings to discuss the impact of roadworks, events and developments and to plan mitigation measures of any impact on the road network. From this involvement, and its own monitoring of the operation of the roads network, Lothian Buses has a relatively unique insight into what affects the ability of the road network to flow (in normal circumstances and when roads have to be closed) and the viewpoints of all others involved. To meet the demand for their services, Lothian Buses operates buses that are in general 12 metres long with a 2.55 metre wide body and fitted with swing doors. Other operators use similar vehicles but most long distance services are operated with buses up to 15 metres long which are fitted with plug doors that swing out from the bodyside occupying 500mm of the footpath as they do so. The width of road a bus requires increases as it turns a corner due to the length of the wheelbase and the front and rear overhangs; this imposes constraints on the design of roads used by busess. Principal Concerns Lothian Buses’ principal concern regarding these proposals is that they will impose significant constraints on the road network that will result in traffic getting stuck in a high level of congestion. This congestion will become a daily occurrence because it is not caused by a fluctuation in traffic volume but a permanent loss of roadway. Buses are legally required to operate services within the parameters of 1 minute early and 5 minutes late relative to their published timetable. At present this is difficult for Lothian Buses to achieve despite having a number of systems in place to manage the running of services so that they meet their timetable. The key question that has to be answered by the designers of this scheme is will the road network be able to cope? Without evidence to the contrary, Lothian Buses’ view is that it most certainly won’t. The first piece of evidence that is required is modelling of the traffic flows on the revised road network. This needs to take account not only of the steady state situation but also foreseeable disruption such as a broken down vehicle on Princes Street approaching the East End junction; this is required to prove that the roadwork has adequate resilience to cope with such incidents and does not immediately come to a standstill when there is an unplanned event. The second piece of evidence is tracking of all the manoeuvres at each junction that has been altered so that it can be shown that buses can not only make the required manoeuvres but can do so easily. Another significant concern is over the choice of route and the justification for trying to squeeze a cycle route onto roads that already have space constraints. In particular Haymarket Terrace where the additional constraints imposed by the proposed cycle route will make the road unattractive to all, including cyclists. Why does the route to the City Centre not go via Magdala Crescent and Eglinton Crescent? Could the developer of Donaldson’s School not be encouraged to enhance the required cycle routes within their site so that there is a through link from Wester Coates to Eglinton Crescent, thus linking the Roseburn cycle route with the City Centre? If the reason is that this fails to provide a cycle link to Haymarket Station then the existing cycle route via Balbirnie Place and Haymarket Yards should be enhanced so that it extends to Haymarket Station (perhaps to an entrance opposite Platform 0). What evidence is there that the cycle route along Haymarket Terrace will be used and if so will the number justify the inconvenience to the tens of thousands of Lothian Buses’ passengers that use this corridor each day? The evidence from the George Street experiment was that cyclists who used George Street were positive about the experience but the majority of cyclists travelling between the East and West Ends continued to use Princes Street; if cyclists didn’t want to use George Street why will they want to use Haymarket Terrace. Finally, Lothian Buses is concerned that the Transport Hub that emerged with the opening of the new Haymarket Station concourse, the tramline and the relocation of the taxi rank and the eastbound bus stop will lose its appeal to the travelling public. While far from perfect, and having been created more by accident than design, this transport interchange is the only one in Edinburgh that brings together train, tram, long distance coaches, local buses and taxis (including transport links to the airport) in an effective manner. There has to be scope in the future for improving this interchange and the surrounding area so that it can accommodate the demands arising from the promised increase in use of Haymarket Station and expansion of the tramline. If the cycle route is implemented without this being considered, possible improvements (widening both footpaths would be one) will not be feasible. Specific Concerns The following concerns have been identified by looking at the drawings and applying Lothian Buses’ knowledge and experience of the road network. They are listed in an approximate order going from west to east along the route and take into account not just what will affect buses but where it is known they will affect mitigation measures used for events and road closures etc. 1. At the bus stop on the north side of Roseburn Terrace the shelter is shown as being moved about 8 metres to the west of its current position. Depending on the style of shelter passengers expect a bus to stop before the shelter or in front of it, but not past it. As proposed a bus stopping at this stop will block the pedestrian crossing which is neither desirable nor legal. What is the justification for creating this situation? 2. The loss of one of the eastbound lanes on Roseburn Terrace east of Roseburn Cliff leads to a situation that will need to be carefully managed if vehicles waiting to turn right into Roseburn Street are not to obstruct the predominant traffic flow heading for West Coates. How is it intended that this be managed? 3. The three lanes on Roseburn Terrace west of the Roseburn Street junction are shown as being 3 metres wide. Has it been verified that east and westbound buses can proceed past a large vehicle sitting in the right turn lane? 4. The remodelling of the Roseburn Street junction creates the risk that it will not be able to meet traffic demand because of the additional pedestrian phases and the loss of a westbound lane. Has the capacity of the proposed junction been checked? 5. The provision of bus lanes is part of City of Edinburgh Council’s policy to encourage use of public transport. The westbound bus lane from West Coates to the start of the left turn lane to Roseburn Street reduces bus journey time by allowing buses to get past the traffic queue. The loss of this facility will increase journey times for buses and taxis; has this been quantified and if so what is it? 6. West Coates (and Haymarket Terrace) are used after events at Murrayfield Stadium to get large crowds to Haymarket Station and beyond. Currently to move such crowds quickly and safely the road is closed to all traffic except pedestrians. What legal basis is going to be used to close the cycle route to provide a pedestrian only area? 7. Due to the nature of Haymarket junction it is vulnerable to closure and congestion; it would be unrealistic to expect the operation of the junction to improve if these proposals are implemented and therefore a strategic diversion route that can be used needs to be identified for use in such an eventuality. Currently eastbound buses would divert via Magdala Crescent or Rosebery Crescent to Palmerston Place and then back to Shandwick Place via Grosvenor Street or Manor Place depending on the location of the closure. Where possible westbound traffic would be kept on Haymarket Terrace but if necessary would have to divert via Palmerston Place, Glencairn Crescent and Coates Gardens. The alternative to these diversions is via Ravelston Dykes, Murrayfield Road and Ellersley Road which is a significant section of bus route not to be serviced. The proposals show that Rosebery Crescent is to be for southbound traffic only; will the design of the “Copenhagen style junction” at Magdala Crescent and the junction at Coates Gardens prevent buses using these routes – of particular concern due to the low ground clearance of modern buses is if there is any raised road surface at a location where a bus is turning? It should be noted that these diversions will also be required for any major roadworks on Haymarket Terrace. 8. The bus stop east of Magdala Crescent has been moved from its current layby location into the running lane. Buses using this stop will block the running lane; has there been an assessment of the effect on traffic (including express buses which do not use this stop) of a bus blocking the running lane? 9. Coates Gardens is described as a one way street with a contraflow cycle facility but no detail is shown of where the contraflow cycle facility will be. 10. A taxi feeder rank is shown west of Coates Gardens but there is no taxi rank for it to feed into. Assuming that this is an oversight, what use will be made of this road space? It is suggested that it be used to accommodate a longer filter lane for vehicles waiting to turn right into Haymarket Yards to reduce the number of occasions when eastbound traffic flow is blocked. 11. Cycle reserves are shown at the eastbound and westbound stop lines approaching Haymarket Yards junction. Are these not redundant if there is a cycle route with crossing facilities across Haymarket Terrace? This is particularly relevant in the westbound direction where it is difficult to see how a cyclist can safely access the reserve and the roadspace gained by its removal could marginally improve traffic flows. 12. The lane widths on Haymarket Terrace between Haymarket Yards and the pedestrian crossing east of Rosebery Crescent are shown as being 3 metres wide. Depending on design modern buses are in general between 2.9 and 3 metres wide (measured between mirror extremities). What consideration has been given to how westbound traffic (including buses) is going to flow along the middle lane of Haymarket Terrace when eastbound traffic (including buses) could be moving, or queued, in the northern lane and buses are stopped in the southern lane at one of the bus stops? It should be noted that in a similar situation in Queensferry Street, traffic does not flow well and there the roadway is approximately 1.8 metres wider and traffic levels are lower. 13. The first of the pair of westbound bus stops is allocated to long distance and express services. By their nature these services take longer to board than local services because of cash fares, passengers with luggage and design features such as plug doors which take longer to operate. It is not in any bus operator’s interest to spend more time than is necessary at a bus stop. Initiatives introduced by bus operators such as electronic ticketing will help reduce boarding time, but there will still be occasions where a bus pulls up at the bus stop before the previous bus has left particularly during evening peak hours. At present this is accommodated by buses queuing in the roadspace prior to the bus stop but in these proposals this area has been changed from roadway to footway. What consideration has been given to the effect on the operation of the Haymarket junction and the tramline when the second bus (and any subsequent buses) block the westbound running lane until the layby clears? 14. Rosebery Crescent is shown as one way southbound with a right turn only exit onto Haymarket Terrace. A reference is made to “Gateway Entry treatment” and there is a raised table shown on Lansdowne Crescent but little detail provided; will these be of a design that will allow buses to cross without causing annoyance to local residents or vehicle damage? 15. The signage at the junction of Rosebery Crescent and Haymarket does not show a banned left turn sign to be seen by eastbound traffic on Haymarket Terrace and the sign on Rosebery Crescent is of the wrong orientation. To prevent excessive queueing on Rosebery Crescent should there not be a half yellow box marked in the eastbound lane of Haymarket Terrace? 16. As a result of the traffic issues with the Haymarket junction it is very difficult for traffic to turn right from Morrison Street into West Maitland Street. Buses have taken up to twenty minutes to make this manoeuvre during the evening peak but general traffic moves out of the queue and turns right into Rosebery Crescent to get to Palmerston Place. What consideration has been given to what will happen to this traffic flow when Rosebery Crescent is made one-way with no right turn from Haymarket Terrace? 17. Between the widened crossing east of Rosebery Crescent and the Bus Stop Clearway markings further east there are no parking restrictions shown. In other locations in Edinburgh where this has happened recently, car drivers have taken the opportunity to park in this space restricting access to the bus stop and impeding general traffic flows. Is this an oversight? 18. The taxi rank shown in lane 1 on the approach to the traffic signals at Grosvenor Street will force traffic onto the tramline. Since the introduction of the trams, Haymarket Junction has proved to be one of the two locations on the on-street section of the tramline where the interaction between trams and other road users does not work well resulting in issues for pedestrians, general traffic, buses and trams. These issues manifest themselves in undesirable actions such as pedestrians crossing during a red man phase, general traffic making banned turns or, along with buses, blocking yellow boxes as well as blocking the progress of trams. What consideration has been given to the effect of locating the taxi rank here on the operation of Haymarket junction and on the attractiveness of Haymarket Terrace as a transport hub/interchange to the user of public transport? 19. A bus stop is shown on the south side of Melville Street while the existing bus stand on the north side of Melville Street has been removed. The bus stand is the location provided by CEC to bus operators as a West End terminus. While Lothian Buses are aware of issues with the current location and are actively pursuing alternative suitable locations with CEC and other operators, it is not possible to comment on the proposed arrangements for buses on Melville Street until the location of the terminus is agreed. Will the proposed design of Melville Street be amended to reflect the location of the West End terminus? 20. The stop line of Melville Street at Queensferry St currently has a left hand filter lane and a separate straight ahead/right turn lane. Due to the low volumes of traffic wanting to turn right and go straight ahead, the length of green time given to this manoeuvre is very short. The green time for a single combined lane will need to be increased to accommodate the combined traffic flows. What consideration has been given to the effect of this increased green time on the available green time for northbound traffic exiting Queensferry Street, the interaction with the junction of Randolph Crescent, and the level of eastbound traffic using Drumsheugh Gardens to get to Queen Street or the Dean Bridge? 21. The segregated cycle route at the north end of Hope Place and the narrowing of the roadway on the south side of Charlotte Square has resulted in a “squaring off” of the turn from the south side of Charlotte Square to Hope Street. This manoeuvre is required to be made by buses and is available to general traffic. Has the proposed layout been tracked to show that the left turn manoeuvre can be made by full size buses and other large vehicles and has there been an assessment of the risk to a cyclist waiting to cross over to the cycle route. 22. Currently the traffic signals on the east side of Charlotte Square do not interact well with the traffic signals at the South Charlotte St/Princes St junction particularly when there is a tram crossing that junction. The effect of this is on the principal north-south route for general traffic is that traffic backs up affecting the Lothian Road/Princes St junction. What consideration has been given to the effect on traffic flows of the alteration of the configuration of the existing junctions and the addition of a third signalised junction on this stretch of road? 23. There are currently two southbound lanes on South St David St and the proposals show these as being reduced to one. South of Meuse Lane, lane 1 is for turning left and lane 2 is a bus lane to enable buses taxis and cyclists to turn right onto Princes Street. Bus lanes are provided as part of CEC’s policies regarding public transport and allow buses and taxis to get past queuing traffic. The Waverley Bridge junction is the second location on the on-street section of the tramline where the interaction between trams and other road users does not work well. It can take up to fifteen minutes for traffic wanting to turn left from South St David Street to get to the stop line at Prince Street. Due to the development works currently taking place on the south side of St Andrew Square, lane 1 on South St David St has been temporarily closed off between St Andrew Square and Meuse Lane. The loss of what is in effect an extension to the bus lane causes delays to buses turning right onto Princes St because they are held up in the single queue and are not at the stop line during the brief periods of green time when a tram is in the area. These delays to general traffic turning left and buses turning right can only get worse when there is one lane of traffic crossing the stop line. What consideration has been given to the ability of the proposed design to cope with the traffic demand at the stop line at this junction? Why is the cycle route not routed to Princes Street via South St Andrew Street allowing South St David Street to have two lanes throughout? 24. The footway has been widened east of the pedestrian crossing at South St Andrew St to accommodate the cycle route. The current kerbline has a taper which allows an inside lane to be formed so that buses waiting to access the first bus stop can wait clear of the running lane. This is important to maintain traffic flow in this congested area particularly as the road has been effectively narrowed from 5 lanes to 4. Is there a reason why the original kerb configuration can not be maintained? 25. Consideration should be given to moving the second bus stop further east towards West Register Street to reduce the risk of buses blocking the running lane. It should be noted that these stops are likely to be busier when the St James Development is completed because of a possible reduction of bus stops on Leith Street. 26. As drawn there is very little space (from 1 metre to 300mm) between the bus shelters and the cycle route at the east end of Princes Street. The design of these new shelters (and the previous shelters) is such that the northern face is open to provide the necessary capacity at these busy bus stops; this open face is less than one step away from the cycle route. The proposed design also creates the situation that was deemed unsafe by cyclists and pedestrians during the George Street experiment whereby pedestrians emerged from behind a fixed structure into the path of a cyclist. What consideration has been given to the risk posed by cyclists to pedestrians accessing and waiting in the shelter? 27. What is the purpose of the right arrow in the westbound lane on Princes Street at West Register Street? Any vehicle waiting at this location may have to wait some time for both eastbound lanes to be clear at the same time and in the meantime it will block the westbound lane makes it even less likely that the eastbound lanes will clear. If West Register Street is to be two way, access should be limited to a left turn in from the west. 28. The proposal shows a cycle reserve on the eastbound lanes at the stop line for the East End junction that replicates the current design. Why is the opportunity not being taken under these proposals to extend it to the full width to remove the risk (albeit there is no evidence that there is a current problem) of a cyclist waiting to turn right blocking the straight ahead lane? 29. The East End junction (i.e. the junction of Princes St, Leith St, Waterloo Place and North Bridge) does not operate well at present. For buses it is noticeable that during the evening peak the traffic signals can be set to favour either Waterloo Place or Leith St but not to treat both equally. This leads to a queue that is unable to progress and significant delays to buses. While other initiatives such as the remodelling of Leith St provide opportunities to make the junction operate better the proposals for the cycle route contain features, such as the narrowing of the southbound lane on North Bridge, which could make matters worse. What consideration has been given to the ability of vehicles to manoeuvre through the junction, whether the traffic signals will be able to operate in such a way that queuing traffic does not block other traffic flows and that any queues that do form are not excessive? 30. There are two westbound lanes shown at the stop line just east of North Bridge with only one lane at the far side of the junction. There is no indication across the junction as to how traffic is to merge. In other locations in Edinburgh where this situation has been created, there have been near misses, and possibly accidents, because there is no indication as to which lane has priority. What will be done to avoid this becoming another location where this happens? 31. The capacity of the footway at the corner of Leith Street and Waterloo Place is known to be inadequate for the current demand of pedestrians walking down Leith Street and pedestrians waiting to cross at the pedestrian crossing. The proposals show a wide traffic island at the west end of Waterloo Place. Why is the opportunity not being taken to address the issue of pedestrian capacity by reducing the width of the traffic island and widening the footway on Waterloo Place to create an angled pedestrian crossing with the waiting zone clear of the corner? 32. A banned right turn is shown preventing a turn from Waterloo Place into Leith Street. Where is traffic that currently performs this manoeuvre expected to go and if that is via Princes Street and South St David St will the road network have capacity? 33. The footway on the north side of Waterloo Place has been widened after the end of the cycle route. How will this affect the access to the bus stop immediately after this? 34. At the George Street/St Andrew Square junction a banned right turn is shown. George Street is the strategic bus diversion route for events and incidents occurring on Princes Street and there is no reasonable alternative. The junctions on Queen Street are not configured to have adequate capacity and St Andrew Square is regularly closed as a through route for events; even if these routes were available the additional time to transit them would exacerbate the delays to public transport. What is the justification for the banned right turn? 35. To cater for the closure of the route round St Andrew Square the north side of the square is currently configurable for two way traffic. Is this to be retained? 36. The cycle route has been routed via North St David St when the cycle route along the north side of St Andrew Square could be extended to link with the existing cycle route on South St Andrew St. What is the justification for reducing the lane widths on North St David St and has it been verified that the new layout will accommodate the wide sweep of buses turning from Queen Street? 37. On Elder Street there are two northbound lanes shown with lane two shown for turning both left and right. Can it be assumed that this will be corrected when the design associated with the St James development is agreed? 38. On York Place two lanes are shown approaching the Elder St junction. The acceptability of the cycle route proposals can not be judged until more detail is known about the traffic flows and demand associated with the St James development. How do CEC propose to ensure that the cycle route proposals are not approved until such time as they can be assessed against the effect of the St James development? 39. At the east of York Place the westbound bus stop has been shown as being removed with a probable relocation to Picardy Place. Early on in discussions about Picardy Place that involved Lothian Buses, it became clear that it was unlikely that adequate bus stopping facilities would be available on Picardy Place. It is therefore disingenuous to present this proposal showing a bus stop being removed without showing a confirmed position for its relocation. CEC need to produce a design that shows the bus stop in York Place with the cycle route passing it or with the bus stop in a suitable location on Picardy Place area that will not be changed by the development in Picardy Place. What consideration has been given by CEC to the potential situation where the cycle route proposals are implemented before any work related to the development in Picardy Place has started? 40. The proposals do not show the location of any ancillary equipment that might be installed at the time of implementation. Recently cycle racks have been installed in inappropriate locations which place a bike in the way of a bus trying to access a bus stop. Examples are brackets mounted on kerbside parking poles and pavement mounted hoops designed for one bike but due to inadequate capacity are used by two with one of them creating a hazard at the kerbline. Will CEC ensure that any ancillary equipment is designed and installed so that it does not create a hazard for other road users? Conclusion Lothian Buses supports the principle of encouraging bike use but the creation of improved facilities for cyclists needs to recognise the requirements of other road users. Out of necessity this will need compromises to be made and Lothian Buses will be happy to participate in any discussions regarding the issues that have been raised with the aim of working together to find a solution that mitigates any increased journey times for public transport users. What must be avoided is the creation of a white elephant unloved by all – including cyclists.