I’m writing in connection with the Bus Services (No. 2) Bill and in particular on the proposals to introduce guidance on the accessibility of bus stopping places. I am an independent consultant specialising in travel and mobility of disabled people www.nfpplanning.com. I am also the Convener of the Living Streets Edinburgh Group, although I am writing in a personal capacity.
The ‘floating bus stop’ design where a bus passenger needs to cross a cycleway when boarding a bus is fundamentally problematic for many people, especially older and disabled people. Passengers boarding - and especially alighting from - a bus value the sense that they have reached a safe, pedestrian space where they do not face the prospect of conflict with a vehicle of any sort, which is a risk inherent in the concept.
Organisations representing blind people have been particularly vocal in opposing them and the reasons are well explained in this research by UCL for the Guide Dogs for the Blind Association: https://www.guidedogs.org.uk/how-you-can-help/campaigning/our-current-campaigns/streets-ahead/. However, many other people - who cannot move quickly, are deaf or have cognitive impairments (such as dementia) - are likely to face similar anxiety using this design. All design guidance from Cycling by Design to LTN1/20 acknowledges this potential conflict between disabled pedestrians and cyclists.
On the other hand, many cycling advocates emphasise the benefits of the floating bus stop for the safety and convenience of cyclists. There are undoubtedly benefits to cyclists in removing the need to either wait behind, or overtake, a stationary bus at a bus stop. However, these benefits must be weighed against the disadvantages to bus passengers, especially those who are older and/or disabled.
The balance to be struck between the interests of bus passengers on the one hand and cyclists on the other must, in my view, be heavily weighted towards the bus passenger. The importance of floating bus stops to cycling appears to me exaggerated to the point of absurdity by some campaigners. For example, it has been asserted that if these bus stops were to be banned “it would end cycling as a form of transport” bit.ly/4nvqHLT. Most cycling doesn’t even take place in a segregated cycle lane but on the carriageway. We know that side road junctions pose a significant risk to cyclists even with a segregated cycle lane, but I am not aware of evidence which shows that overtaking a bus is an especially hazardous manoeuvre.
The case for installing floating bus stops can be made where there are especially hazardous conditions for cyclists - for example, where a segregated cycle lane is on a fast, busy road (e.g. a dual carriageway with a speed limits of 40mph). There, the risk to a cyclist overtaking a stationary bus is clearly much greater than it would be in a single carriageway street with a 20mph limit: which is where floating bus stops are typically (and unfortunately) installed as a matter of course in Edinburgh.
For these reasons, I would therefore encourage the Committee to legislate to discourage the use of floating bus stops, unless there are especially compelling reasons why they are needed in particular circumstances.
David Hunter
Not for Profit Planning
July 2025