My objection is below...
I would like to object to the above traffic orders regarding changes to the operation of bus lanes.
There are several reasons for my objection:
1. Unclear of the rationale for the change
2. Mixed messages vs 20mph limits
3. Negative impact on vunerable road users
Rationale for change
It is very unclear to me why the change is being made. I have been unable to find any strong reasons to harmonise to part time. The measures of success noted in the report at August's Transport & Environment Committee are
1. It amends ineffective bus lanes, of which 5 were noted already to improve traffic flow.
2. It reduces confusion on the operating times.
I recognise that success measure 1 has some merit in the case of ineffective bus lane, but this is only in isolated cases.
I also recognise that harmonising operating times would eliminate the confusion, I just cannot see any strong reasons for harmonising to part time.
If Lothian buses are comfortable that the don't need buses outside of peak hours then there can be very little congestion that would be eleviated by have 2 lanes of unrestricted traffic. Why can they not be harmonised as 24/7 bus lanes or 7am-7pm as a minimum? What evidence was used to determine that part time is the right answer?
I understand that this ETRO is not impacting current parking arrangements so it is likely that off peak the bus lanes won't be free for traffic anyway, so why create uncertainty for drivers about whether they should be in the bus lane or not.
Mixed Messages
I applauded CEC's bold step to move the default speed limit in our city to 20mph This will make it a more pleasant place for us all to live. Roads are for people and recognising that a very significant percentage of the population live without access to a car, it is good see that CEC have deprioritised the private car rushing through our city in favour of quality of life of those that live here.
The proposed change goes completely against this. It encourages private car use to the detriment of others.
I'm sure you are aware of the illegal levels of air pollution in our city and the council's Local Travel Plan and Active Travel Action Plan which are trying solve this amongst other benefits. The changes proposed is not only contradict these plans, I cannot see how this will do anything other than increase the air pollution which our city and it's population suffer from.
Vunerable road users
I don't consider bus lanes to be cycle infrastructure as they are shared with buses and taxis that travel at differing speeds. They are however a small haven from general motor traffic that are useful on direct routes into the city. Having to share these lanes with general traffic makes them much less appealing to cyclists (as does negotiating parked vehicles). With the 20mph change reducing speeds on many of these routes there is a real danger that bus lanes will be used by impatient drivers trying to undertake other road users and put them in conflict with cyclists.
Having general traffic driving next to the pavement will also make walking less pleasant. This will be especially important during school home time which won't be covered by the part time operation of the bus lanes.
I'm also very concerned by letting motorbikes into bus lanes. Using bus lanes as a cyclist means I don't have to share it with other road users. It simply isn't possible for a taxi or bus to give sufficient space to pass whilst still in the lane. This means they have to wait until there is space in the outside lane to pass, meaning that you don't get buzzed by close passes. By letting motorcycles use it they will more likely to overtake whilst in the bus lane and not give sufficient space. This will increase the risk to cycling and make it less appealing.
In summary, I can only see negative impacts on vulnerable road users, limited benefits and very mixed messages of what CEC is trying to achieve.
Regards,
Mr Hank Chief