February 2015

Bus lane cuts: what you say

We now know of many people who have objected to the Council’s plans to scrap bus lane operation all day Saturdays and off-peak on weekdays.  If you don’t like it either, please join them!

You can find the full story in our news items of Feb 6 and Jan 31.

The full combined objection from Spokes, Living Streets [Edinburgh and Scotland], Greener Leith and Friends of the Earth Scotland is here [pdf 311k].

One of our original tweets has now been RT’d over 30 times.  See here – and please add another RT if you agree!


  • Update:  The closing date for formal objections has passed – so now is the ideal time to contact your councillors.  A report on the formal objections goes to the Committee in a few weeks time, and Councillors then make a final decision on the scheme.  So tell your councillors now what you think and ask them to speak to their party’s Transport Spokesperson.  If you have time, ask to meet your councillors at their surgery, or to speak on the phone.  Find your councillors at www.writetothem.com.  Interestingly, one member who has already contacted his 4 councillors found that 2 didn’t even know about the plans!
  • [omit this section – this closing date is now passed]  Object to the order(s) by Feb 18.   Email… trafficorders@edinburgh.gov.uk, stating that this is an objection to ETRO/14/38B and/or ETRO/14/38A.   Then give your reasons.  Your objection should include your own postal address.  If you are short of time, it is not essential to look up the Orders, but if you wish to do so, the links are in our Jan 31 story.   A lengthy objection is not necessary – just say what you think, and why.
  • If you use twitter  please RT the link above.
  • Do you know a group that is concerned?  For example a local cycling, community or parents’ group.   Please urge them to contact their councillors.  We would be very pleased to hear of any groups that do this.


Below are just a few examples of what others have done.  Please join them! Most are objections, others blogs, tweets and emails to councillors.  Don’t feel you have to write something lengthy.  A simple objection, and/or email to your councillors, saying what you think is fine.

SNP Cllr David Key – tweeted to his followers

 LAB  Cllr Cammy Day and Cllr Karen Keil – retweet & favourite re Gyle area


Sent to:

Dear Sir/Madam,

I am writing to object to the changes to the bus/cycle lanes covered by ETRO/14/38B and ETRO/14/38A, for the reasons as follows:

  • there is currently no issue with off-peak congestion in Edinburgh, so what problem are these changes attempting to solve?
  • it goes against the council’s own Local Transport Strategy (LTS) of encouraging public transport use and cycle use over private car use.
  • the LTS also states that bus lanes should be extended & enhanced where possible (and not degraded)
  • it will discourage off peak cycle journeys as cars & heavy lorries will be using the lanes
  • it will discourage pupils from walking home from school, as cars & heavy lorries will be passing close by the pavements making the roads seem more dangerous & uninviting.
  • increasing the road capacity for private motor vehicles will encourage modal shift toward the private car, increasing pollution (which Edinburgh is already illegal on)
  • no proper consultation or study was carried out to evaluate pollution, modal shift, illegal parking, cycle use or any ‘unintended consequences’
AN OBJECTION [which shows they can be short yet good!]

I am objecting to ETRO/14/38A (Permitted Vehicles Experimental Order) and ETRO/14/38B (Times of operation of bus lanes).

I cycle regularly along Leith Walk, Leith St, North Bridge and South
Bridge. I value the space that bus lanes give me. Where they exist, bus
lanes mean that I do not have to worry much about HGVs, cars and
motorcycles passing close to me. I also suspect that the air quality is
better than it would be if other vehicles were allowed in bus lanes.

I observe that peak-hours bus lanes are not often used by vehicles other
than buses and cycles outwith peak hours, and that there is not much
traffic congestion that would be helped by allowing other vehicles into
bus lanes. I would therefore suggest that the greenways concept of
all-day bus lanes should become the norm, rather than peak-hours bus
lanes. This would reduce driver confusion and help to continue the
progress that Edinburgh has made in encouraging cycling and walking.


I am stunned to read that you propose to curtail the operating times of bus lanes in the city & to open them up to more classes of traffic. Surely bus lanes are there to assist the buses in passing congestion making the bus more attractive as a quicker way to get around the city?

I note that this experimental arrangement is against your own stated policies – viz:
PubTrans1: The Council will presume in favour of giving buses and Trams priority over other motorised traffic.
PubTrans7: The Council will continue to maintain the bus lane network, review it regularly and extend it or enhance it where opportunities arise.
Now unless “giving negative priority” and/or “negative extensions” and/or “negative enhancements” are the way forward – you should presume against the curtailing of the hours of operation and against the opening of the bus lanes to more classes of motorised traffic. 
Indeed you should probably be looking further to exclude taxis since those are typically only going to be carrying a fare in one direction yet can presumably use the lanes at all operational times (and who does an empty taxi benefit?)
Further reading of your local transport strategy document reveals sections on cycling and walking:
The attractiveness of cycling is dependent on the degree to which the road network is dominated by moving or parked motor vehicles.
Allowing more vehicles to use them is not increasing the attractiveness of cycling in the slightest – unless you are about to repurpose all bus lanes as dedicated cycle only lanes? (But clearly you aren’t since you’re talking of curtailing the hours of operation in order ETRO/14/38B & opening to more vehicles in ETRO/14/38A) – either way it is not going to positively impact on your stated aim of 10% journeys made by cycle by 2020 (that’s 5 (FIVE) years time)
The Council will seek opportunities to improve pedestrian facilities…
Because opening more lanes to more traffic always makes the pavements more attractive to walk along. Why just have one solid lane of traffic belching out fumes when you can have two?
I write this as a motorist, a cyclist and pedestrian in your city – although I live outwith your boundaries, I am a frequent visitor, shopper & commuter and would like to see your city improve the lives of its residents, workers & visitors.
Do the right thing – yes simplify the operational hours of the bus lanes. Make them all 24 hours, 7 days per week. No grey areas for those that transgress (I thought it was 6.59pm…) & make them all bus & cycle only.
You’re headed the right way with the presumption for 20mph limits (but not far enough in my view) – implementing either of these orders is a step backwards, implementing both is two steps backward.

[interesting bit in bold type showing a person who currently uses the bus lanes at offpeak times only]

I’m writing to object to the plan of removing the all day bus lanes in some areas. ETRO/14/38B.
The bus lanes provide a safer lane to travel in for cyclists, and the buses are unhindered.  This would discourage use.  I opt to cycle on the cycle paths, but for off peak times, I consider a more direct route where there are bus lanes.  I feel safer in a bus lane with buses and taxis as these drivers by and large are used to cyclist being in that lane.  Non bus lane users are less used to cyclists and would therefore be seen as an issue.
Pedestrians can also feel safer that cars are not speeding past.
Furthermore, the A8 Glasgow Road bus lane is peak times only, except most times when in off peak, cars will use not use the lane, save the savvy drivers who read the signs and use it to get ahead, undertaking.
Therefore there is maybe more of a need to move bus lanes to full time, as opposed to changing full time to only peak times.
There are just no good benefits apart from speeding up traffic and encouraging motorised forms of transport.
I therefore wholeheartedly object to this proposal and find this traffic experiment a waste of money and resources.

From the Scottish Assn for Public Transport.







Dear my Councillors,

I am very concerned about the proposed bus lane changes, to make all lanes part-time only. This will have an adverse impact on me as pedestrian and cyclist, since general traffic will be closer to me, making air pollution worse, splashing me at every puddle, and putting me in greater danger. The same applies to all pedestrians and cyclists, and would most likely result in reducing the number of cyclists, since the lanes would no longer be attractive.

These proposals are contrary to the city’s policies as laid out in the Local Transport Strategy (see especially PubTrans1, PubTrans 7, and the section on Cycling, 9.2). There has also been too little consultation, and the Report to the Transport Cttee doesn’t even mention the impact on pedestrians and cyclists.

I am also annoyed at the proposal to allow motor cyclists into bus lanes on this same experimental basis. A similar trial in London resulted in an increase in m/c casualties, in m/c speeds. and in numbers of motorcyclists exceeding the speed limit, which even after interventions, was as high as 40-60%. Again, this will act as a deterrent to cycling, and worsen conditions for pedestrians.

Instead of the present proposals, there should be wide public consultation on the several possible options – all-day bus lanes (which would also rationalise the operation of the lanes), 24/7 bus lanes (ditto), or peak-hour only. Bus lanes are not just for buses; there are knock-on effects for other road users, especially cyclists and pedestrians.

I would be grateful if you could convey these views to the Transport Cttee which is due to consider the proposals shortly. It’s very hard to understand why Edinburgh, which broadly has a good reputation for encouraging active travel, should even be thinking of such retrograde steps, which are contrary to otherwise-good transport policies, and which would do nothing towards achieving the modal shift the city aims for.


Dear Councillor,

I am extremely disappointed to see that the Transport and Environment Committee are recommending that the Council approves the promotion of an 18 month experimental Traffic Regulation Order to trial peak periods bus lanes, in place of all-day bus lanes;  and also approves the promotion of an 18 month Experimental Traffic Regulation Order to trial allowing motorcycles access to with-flow bus lanes during their operational hours.

I was absolutely astounded when I discovered this, as I had expected the opposite – that to reduce confusion and help meet the recommendations of the Local and National Transport Strategies, all bus lanes would be made all day or permanent!

The decision appears to have been made purely on a small survey of bus flows, and has not looked at all on the effect upon cyclists and pedestrians.  I am astonished if there is really “little effect” on flow as they seem to suggest as I have certainly sat on buses in traffic jams during the “school run” and well before 4pm (very anxiety provoking when on the Airport bus to catch a plane).  Also, have they considered the effect on traffic flow and amount of car use, of the parking that would be possible if bus lanes are not all day?  I expect not.

I am absolutely certain that if made, this decision will deter cyclists and make it more unsafe for them travelling, particularly if motorcycles are allowed in to the lanes.  Incidentally, I would like to point out that although the report cited motorcycles as being more fuel efficient, there is little difference between the fuel efficiency of a car and a large motorcycle.

Importantly also, any survey of bus lanes should look at public perception of the effect of bus lane operational hours, as this is more important as an influence to behaviour as effects in reality. i.e. if the public perceive that bus lanes allow buses to travel more freely and cyclists to move around more safely, then people will use buses and bicycles rather than cars, whether or not this is reality.  Regardless of perception or reality, the most important point is that Local and National Transport strategies have been designed to reduce car use and increase active and public transport travel, in order, amongst other things to try and reduce air pollution which exceeds EU safety limits and causes thousands of deaths per year, and to tackle the growing obesity crisis which the NHS and social services increasingly will not be able to cope with.  Clearly this decision would fly in the face of these strategies!

In case you are not familiar with local and National Transport strategies here are some excerpts from them:

National Transport Strategy:  “modal shift from car to bus use” a “desire to increase the proportion of journeys made on foot and on bicycles”….”reducing emissions, improving air quality and contributing to improved health by increasing physical activity levels”.

Local Transport Strategy: “encouraging the use of alternatives to the car, and seeking to reduce emissions from motorised travel” a “range of actions aimed at encouraging both walking and cycling. This includes giving greater priority to pedestrians and cyclists in street design and management”.

I have attached the Local and National Transport strategies in case you wish to look at them in more detail.

I shall finish with the quote from Councillor Lesley Hinds, Convenor for Transport and Environment, from the introduction to the local transport strategy:

About a quarter of domestic carbon dioxide (CO2) and other greenhouse gas emissions in Scotland come from transport. That’s just one important reason why we will continue to make significant investment in infrastructure for walkers and cyclists and to give priority to buses on the city’s road network. We will also be exploring other options to reduce air pollution on Edinburgh’s streets during 2014 and 2015.

Please do whatever you can to ensure that this decision is not made, and if possible make all bus lanes all day.

I look forward to any comments.

Best wishes…

OBJECTION [from a scientist involved in designing experiments]

I am writing to object to the implementation of these two orders
(ETRO/14/38B and ETRO/14/38A) both of which in my opinion will have serious adverse impact on cyclists and even pedestrians in Edinburgh.

Further, even if I was only suspicious there was a risk of POTENTIAL
adverse impact, I can find nothing in anything I’ve read in or about
these orders which reassures me that some sort of sensible due diligence has been done to evaluate the impact on those groups.  Instead there seems to be a presumption that simply implementing the order for an experimental period IS the evaluation.  Please, it is people’s safety you are experimenting with here.  As someone who’s occupation involves development of safety critical medical equipment, I can assure you thatwe do not simply try out new ideas by releasing them in product for 9-18 months and seeing what happens to the users, and indeed it’d be considered outrageously reckless to take such a course of action.

To give some more details on particular things which concern me:

– Any increase in motorized traffic in bus lanes makes Edinburgh a less
attractive city to cycle in.  Given the council’s ambitious objectives
for cycle use by 2020, it seems incredible that any changes to road use
which might dissuade novice or would-be cyclists from taking to bicycles on the roads are even being contemplated.  As someone who considers themselves quite a cautious cyclist and often takes a longer route than necessary to make use of cycling-friendly infrastructure (including bus lanes), I can assure you that the (currently) relatively traffic free bus lanes are crucial to feeling like I can complete cycle journeys safely.  In my opinion the bus-and-cycle lanes are crucial to making city centre cycling tolerable and safe and allow various other bits of cycle infrastructure to be linked without needing to share lanes with dense fast moving traffic.  I suspect they also have a key role in giving people more confidence to try city cycling too.  An 18 month experiment could be a disastrous setback to the council’s own Active Travel Action Plan and Local Transport Strategy goals for cycle use (which are to be applauded).  And yet I can find no documents associated with these traffic orders which reassure me that the impact on these plans has been considered.  Clearly the council is aware of the POTENTIAL impact as organizations like Spokes have been consulted, but I think it’d be reckless to go ahead with such a large scale experiment without attempting to evaluate that impact in a less drastic way than the “try it and see” apparently being proposed.

– The possibility of motorcycles using bus lanes (at all hours) is
particularly objectionable.  As a cyclist when I am at an advanced stop
line box in an otherwise normal lane of traffic, the thing which makes
me most nervous is not a taxi or a “white van man” behind me, but a
motorcyclist on account of their extreme acceleration and
unpredictability.  Further, normal “defensive cycling” tactics such as
occupying the “primary position” and “owning the lane” – which are
effective in 4-wheeled motorized traffic flow – do not work on
motorcycles who seem almost as likely to undertake as overtake, and at
high speed.  I would rather not have to worry about motorcycles
full-time in bus lanes.

– As someone who has cycled for decades in urban environments, I am
concerned about my exposure to pollution, especially exhaust
particulates.  My understanding is the impact of these falls off rapidly
with distance, therefore I would greatly resent being more likely to
find myself immediately behind a diesel lorry/van in a bus lane.

– When I’m a pedestrian in Edinburgh, I quite like the fact that on many
streets, I am separated from the main flow of traffic by a relatively
quiet “buffer zone” of a bus lane.  In my opinion pedestrians’
experience in our lovely city will be much reduced by any increase in
traffic in bus lanes, something which should surely concern a council in
favour of more “active travel” including walking and also in preserving
the attractiveness of the city to tourists.

– A change of this magnitude deserves MUCH more publicity and proper public consultation than it appears to have received.  For example, many many more people seemed to be aware of the 20mph consultation (which was very well done I thought).

– Both orders “reasons” documents contain some “If the trial is
successful” text, but the criteria for “success” appear to be completely
undefined!  (At least so far as I’ve been able to determine).  Given the
outcome of the trial could well be an decrease in average journey times
for motorized traffic at the expense of cyclist numbers, cyclist safety
and cycling uptake, I think it’s important the council define what
outcomes would actually be considered “successful”.  For example: would the council actually be prepared to give up some cycling gains in favour of increased motorized traffic flow?  If so, what would be considered a reasonable trade-off?  Is the experiment proposed even intending to measure cycling impact so it could make such a decision based on sound data?  Again, as a professional scientist I am horrified to see any proposal for an “experiment” which does not set out clearly what hypothesis it is attempting to test from the outset.

– While the documents refer to bus-lane practices in other cities, I
note that Glasgow currently appears to be considering *extending* the
scope of it’s bus lanes rather than eroding them

Thank you for considering this objection

Comments are closed.