LEZ Consultation: more polluting traffic for Holyrood Park

City of Edinburgh Council is currently consulting on the LEZ and it’s proposed boundary: https://consultationhub.edinburgh.gov.uk/sfc/low-emission-zone/

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Proposed LEZ boundary in Edinburgh

While we are in support of the LEZ, Car Free Holyrood Park is concerned that the boundary as proposed will increase traffic in the park, which will negatively impact this historic site, SSSI and park users’ experience.

Summary

We strongly disagree with the proposed LEZ boundary. The boundary should be much more ambitious and expanded to include Holyrood Park to protect this vital greenspace from traffic volume increases of the most-polluting vehicles, including from non-compliant commercial vehicles that are not allowed inside the LEZ nor on Holyrood Park’s private road network.

According to modelling completed on the Council’s behalf, traffic will increase in Holyrood Park and then continue to increase over time rather than use the LEZ boundary along the Pleasance.

Yet there are no mitigation measures in the road management strategy which address concerns about increased traffic, including commercial traffic, in Holyrood Park. Increased traffic would negatively impact both park users and their wellbeing as well as discourage active travel in and through the park.

Why do we strongly disagree with the proposed boundary?

1. Increased Traffic in Holyrood Park

The LEZ boundary is the Pleasance, Holyrood Road, a short section of Queens Drive, Holyrood Gait, and up to Abbeyhill.

However projected traffic modelling from committee papers (see Appendix 5, pages 101-158 in the document) submitted to the Transport and Environment Committee on 17 June anticipates diverted traffic will travel along Queen’s Drive from Horse Wynd to Commonwealth Pool, not along the LEZ boundary along Holyrood Gait/Holyrood Rd. 

Figure 4.8 in committee papers (Appendix 5, page 20; document page 130) showing 7% increase in traffic on Queen’s Drive within the park’s private road network.

Traffic modelling in Holyrood Park of the proposed LEZ boundary shows that traffic volumes will immediately rise during the morning peak, interpeak, and afternoon peak, and increase in both AM and PM peaks over the next few years.

Therefore, according to modelling completed on the Council’s behalf, traffic will increase in Holyrood Park and then continue to increase over time rather than use the LEZ boundary along the Pleasance, yet there is no stated mitigation strategy of this negative impact on a historic site, SSSI, and beloved greenspace.

Table 1: Traffic Modelling in Holyrood Park (Queen’s Drive) – Proposed LEZ Boundary, according to committee papers (Appendix 5)
20192023
AM+3%+7%
IP (Inter Peak)+10%+3%
PM+4%+5%

2. Increased Commercial Vehicle Traffic in Holyrood Park

Fleet modelling from the committee papers (Appendix 5) also projects that non-compliant LEZ traffic — the most polluting vehicles not permitted to enter the LEZ boundary — will also not use the LEZ boundary through St Leonards/Pleasance/Holyrood Rd, but will instead travel through Holyrood Park’s Queen’s Drive from Commonwealth Pool to Holyrood Gait, see Figure 4.18 below. 

Figure 4.18, AM Original LEZ + ECCT, from Appendix 5, page 37

Figure 4.18 from the committee papers shows the proposed LEZ boundary fleet composition at morning peak with ECCT in place. The red lines show where LEZ non-compliant traffic will travel. Figures 4.17-4.28 all show Queen’s Drive (Commonwealth Pool to Holyrood Gait) taking the LEZ non-compliant traffic rather than the LEZ boundary through St Leonards/Holyrood Rd.

LGVs, largely used for commercial purposes, make up a significant portion of the estimated non-compliant LEZ traffic (see paragraph 4.57):

  • 16,000 cars (diesel) (22% of diesel cars forecasted to be non-compliant in 2023) 
  • ~3610 LGV (18%) 
  • ~120 HGV (8.4%)

Commercial traffic, including Light Goods Vehicles and Heavy Goods Vehicles used for commercial purposes, are not permitted to use Holyrood Park’s private road network. The Holyrood Park Regulations 1971 prohibit driving or using any vehicle designed to seat more than seven passengers (in addition to the driver), or constructed or adapted for the purpose of any trade or business or as a dwelling, effectively prohibiting commercial vehicles.

However, this commercial vehicle ban is consistently ignored, according to HES’s traffic surveys and from resident observation. Historic Scotland (the park managers at the time) commissioned a traffic survey in 2006 which showed commercial vehicles comprised approximately 5% of traffic at weekends and 9% on weekdays (ISIS Holyrood Park Traffic Survey 2006). Ranger correspondence from 2019 also confirmed that “volume of traffic increases year on year.” Despite some enforcement efforts and a campaign by Historic Scotland in 2011, commercial vehicles continue to use the park with regularity and minimal enforcement. 

The modelling from the committee papers about the LEZ shows the vast majority of non-compliant LEZ traffic will use Queen’s Drive from Commonwealth Pool to Holyrood Gait, unlawfully in the case of LGVs and commercial traffic, rather than the LEZ boundary along Holyrood Rd/Horse Wynd.

The committee papers however do not include mitigation measures to encourage use, particularly by commercial vehicles, of the intended diversion or for the negative impact of non-compliant LEZ traffic on park users and active travel journeys in the park.

A final note…

The roads in Holyrood Park are private, owned by the Scottish Ministers and operated by Historic Environment Scotland has a Property in Care. The Council’s transport policies, including the LEZ, must be viable without the use of the private Holyrood Park road network. Modelling completed on the Council’s behalf should reflect this.

With a potential LEZ boundary pushing traffic into this beloved historic site, SSSI and greenspace, the Council and HES should work together to close Holyrood Park to motorised through-traffic. This will protect against future traffic increases that have been modelled in the committee papers, encourage behavioural modal shift changes, and end an inequitable and undesirable status quo.

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