Questions 1-2: Wall Mounted EV Chargers
Q1. Do you agree with the removal of restrictions on Class 9E PDR, for wall-mounted EV charging outlets, in the specified areas currently listed in Class 9E(3)?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
Removing these restrictions will enable more people to make a switch to electric cars, although the focus should be on communal charging points on reducing the number of cars on the road. Collectively we need to move to active travel and shared car ownership. This is because the pollutants from tyre and brake vehicles are significant on any type of vehicle including electric vehicles. Additionally, electric vehicles, just like internal combustion engines, contribute to congestion, road safety issues and car parking pressures - a car spends 95% of its life parked and this space could be better used. We feel that if the Scottish Government is to meet the target to reduce car kilometres travelled in Scotland by 20% by 2030 there needs to be more work done in encouraging the population to move away from cars in general and into active travel.
Questions 11-16: On-street/Kerbside Charging
Q16. In relation to extending PDR for EV charging infrastructure in roads, what issues need to be considered regarding existing PDR, and rights to access the roads network, for infrastructure which are available to other sectors, such as electricity undertakers?
Please explain your answer
When extending PDR, attention needs to be paid to the access of people on bikes and pedestrians. Cycling infrastructure, as shown by Cycling by Design (2021) should coexist, without any intrusion into the cycling track. For example, where designated electric vehicle spaces are provided, the kerbed island between the cycle track and parking may need to be built out into the carriageway to accommodate electric vehicle charging units. Additionally, the flow of cycle routes should not be disturbed by cables running through cycle routes (for example by bumps on the tarmac). Equally, cables cannot be trailed across the footway as that presents a significant trip hazard to pedestrians.
The principles of 20-minute neighbourhoods should be considered to ensure there is connectivity between areas and so that people can use sustainable transport to get to their destinations rather than necessarily transitioning to electric vehicles. This is vital if we are to move to a wellbeing economy as overreliance on cars contributes to isolation, poor mental health and wellbeing and isolation from our neighbourhoods and communities. At the same time, active travel has shown several benefits such as increased exercise, improving our health and encouraging us to enjoy the outdoors. Approximately 34% of all car journeys in Scotland are less than two miles in length and could be covered by bicycle or on foot instead, increasing electric vehicle reliance will not help us reduce our car miles.
As the recent route map to reduce car kilometres has shown, pollution from tyre and brake wear also occurs from electric vehicles, so transitioning to electric vehicles is only a small part of what we need to do in our planning work to make a lasting change that will reduce our emissions.
The principles of 20-minute neighbourhoods should be considered to ensure there is connectivity between areas and so that people can use sustainable transport to get to their destinations rather than necessarily transitioning to electric vehicles. This is vital if we are to move to a wellbeing economy as overreliance on cars contributes to isolation, poor mental health and wellbeing and isolation from our neighbourhoods and communities. At the same time, active travel has shown several benefits such as increased exercise, improving our health and encouraging us to enjoy the outdoors. Approximately 34% of all car journeys in Scotland are less than two miles in length and could be covered by bicycle or on foot instead, increasing electric vehicle reliance will not help us reduce our car miles.
As the recent route map to reduce car kilometres has shown, pollution from tyre and brake wear also occurs from electric vehicles, so transitioning to electric vehicles is only a small part of what we need to do in our planning work to make a lasting change that will reduce our emissions.
Questions 19-22: Use Classes Order
Q19. Do you consider that a merged use class bringing together several existing classes would help to support the regeneration, resilience and recovery of Scotland’s centres?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
Merged use class can help ensure that our buildings, streets, and centres become more flexible when dealing with climate targets and can also help us to create more 20-minute neighbourhoods, hybrid working spaces and opportunities for outdoor learning and socialising. At Cycling Scotland, we feel that bikes have an important role to play in 20-minute neighbourhoods as 20 minutes on a bike lets you cover approximately 2.5 miles at a leisurely pace and can help us connect our neighbourhoods without relying on cars.
Flexibility and ease of planning requests to install adequate cycle parking and storage for building managers of all classes listed in section 3.13 should also be considered. The lack of residential cycle storage is currently being partially addressed through bike hangar schemes, however commercial properties will often have no private land on which to install cycle storage. The flexibility of planning requests could mean a chance for more secure spaces in places like health centres, near shops, restaurants and more. It should be clear that the use of space for cycle parking or storage supports the town centre first principle. We also feel that this could help us adapt to the effects of climate change and support adaptation as well as connect our cities, towns, and villages – creating shorter commuter journeys. An interesting example of this in action is the Place Standard Tool, which has been trialed to maximise co-benefits for fair and just solutions that also support health, wellbeing and equality.
Flexibility and ease of planning requests to install adequate cycle parking and storage for building managers of all classes listed in section 3.13 should also be considered. The lack of residential cycle storage is currently being partially addressed through bike hangar schemes, however commercial properties will often have no private land on which to install cycle storage. The flexibility of planning requests could mean a chance for more secure spaces in places like health centres, near shops, restaurants and more. It should be clear that the use of space for cycle parking or storage supports the town centre first principle. We also feel that this could help us adapt to the effects of climate change and support adaptation as well as connect our cities, towns, and villages – creating shorter commuter journeys. An interesting example of this in action is the Place Standard Tool, which has been trialed to maximise co-benefits for fair and just solutions that also support health, wellbeing and equality.
Questions 27-30: Moveable Outdoor Furniture
Q27. Do you agree with the proposed introduction of a PDR for moveable furniture placed on the road outside of (Class 3) food and drink premises?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
During the pandemic we have seen the impact that providing space for physical distancing – through measures such as road closures and outdoor dining – has had on our wellbeing and health. As well as protecting us from viruses, there is an opportunity to lower emissions, reduce car use and develop place-making principles to connect us with our neighbourhoods as well as support local economies. Spaces for People has also shown people the benefits of sustainable travel and the opportunities as well as encouraging people to cycle more. We should also consider the work of other cities such as Brussels in Europe that have been considering more car-free days to reduce the impact of oil prices as these kinds of interventions support a move to active travel. However, consideration will need to be given to people walking, wheeling and cycling to ensure that transit isn't compromised, for example, having to step off the pavement onto the road due to moveable furniture or risking trips.
Q28. Are there any conditions or limitations that you think such a PDR should be subject to?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
This should be subject to the equality impact assessments to ensure that adequate planning takes place to mitigate any negative consequences for disabled and older people.
Q30. Do you agree that important matters such as safety and inclusive access could continue be controlled through other regimes that would continue to apply?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
Matters like these could be continued through other regimes. However, it has been recognised that there is potential for certain measures under consideration to have negative impacts if taking them forward leads to uncontrolled provision of certain development/equipment/structures on or adjacent to pavements. Inclusion and accessibility should be a key consideration when making any legislative changes in this area.
Questions 31-32: Residential Accommodation
Q32. Are there any other PDR changes which you think could support the regeneration, resilience and recovery of centres?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
PDR changes could also include access to secure cycle storage and cycle parking, as well as a stipulation that calls for 20-minute neighbourhoods. The PDR changes should include the principles of a sustainable travel hierarchy and seek to increase active travel rather than focusing mainly on electric vehicles. There is a need to consider how to reduce travel and increase connectivity in Scotland which will also help reduce our travel emissions.
Q37-39: Assessments
Q38. Do you have any comments on the partial and draft impact assessments undertaken on these draft Phase 2 proposals?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Q39. Do you have any suggestions for additional sources of information on the potential impacts of the proposals that could help inform our final assessments?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer
Equipment housing upstands have the potential to encourage more people to make the switch to electric vehicles. However, we must make sure that these don’t block space for anyone who is walking, wheeling, or cycling.
About you
What is your name?
Name
Kate Samuels
Are you responding as an individual or an organisation?
Please select one item
(Required)
Radio button:
Unticked
Individual
Radio button:
Ticked
Organisation
What is your organisation?
Organisation
Cycling Scotland