Comments on The City of Edinburgh Council’s draft Active Travel, Road Safety, Air Quality and Parking Action Plans

As submitted to the City of Edinburgh Council

In commenting on the Active Travel, Road Safety, Air Quality and Parking Action Plans, we submit this general statement which applies to all these Plans.

We have submitted separately comments on the Public Transport Action Plan, but note this general statement regarding overarching issues with all the Plans:

EBUG believes in a working partnership between the Council and bus operators which recognises that each should focus on what it can do, and what it does best.

The Council must increase the budget and capacity of the Council bus team and focus more pro-actively on delivering tangible improvements for bus users.


  • Improve coordination of bus and tram timetables and integrated ticketing
  • Radically improve the funding for “commercially unviable” routes such as services calling at key destinations and from poorly served rural and suburban communities.

Better Bus Stops

  • Complete a programme of bus stop renewal and improvement
  • Review the provision of bus shelters, always prioritising bus user needs
  • Complete early renewal/refreshment of real-time information on street displays
  • Reduce walking distances at interchanges (e.g. bus/tram/train).


In order to improve travel times and reliability, more bus-friendly highway infrastructure is needed;

  • Expand the overall number and extent of bus lanes, and their width where possible
  • Extend bus lane/gate operating hours to 7am-7pm, 7 days a week
  • Ensure that bus lane rules are properly enforced.

Bus Users’ Needs

Access to appropriate public transport is fundamental. Bus users are all pedestrians for part of their journey. Pedestrians are at the top of the urban transport hierarchy.

  • Protect the needs of people with visual, mobility or other impairments;

Current Floating Bus Stop designs do not meet these needs and should not continue to be rolled out

Cutting stops and increasing the distance between bus stops discriminates against older and less able bus users

  • Bus services should be reviewed, to meet user need /demand, including a focus on orbital routes and linking neighbourhoods
  • Bus services through the city centre must be retained, rather than cut back by a ‘to not through’ policy.


Additionally, with regard to the Active Travel Action Plan:

‘Action J17: Annually review & update of ESDG to align with emerging best practice/reflect lessons learned from use’
COMMENT: We would like to see a clear commitment that whenever the Edinburgh Street Design Guide is updated, proposed changes which may impinge on bus use are clearly flagged in advance.

‘ATAP EIA’ ‘Floating bus stops, floating parking spaces and continuous footways can be difficult for some people to navigate and there is some concern from user groups that these may increase pedestrian/vehicle conflict resulting in stress and/or confusion over user priority…

Mitigation: A fundamental principle of the floating bus stops is that the street markings clearly indicate to people cycling that they should give way to people embarking/alighting buses’

COMMENT: Note the widely cited phrase ‘Paint is not segregation’