MACS - Bus Open Data Response - June 2025
Submitted to The Scottish Bus Open Data Consultation
Submitted on 2025-06-01 17:27:25
S1 Type of services
1. Do you agree with our approach that only services registered with the Traffic Commissioner, or within a Local Transport Authority franchise area should be required to provide open data?
No
2. If ‘No’, which of the following services not in scope would you like to include, with the understanding that there is no central list of these services?
Long distance coach services, where stops are more than 15 miles apart If 'Other', please give your answer here.:
S2 Use and disclosure of information
3. Do you have any concerns over the use of the open data in this way?
No
Box to provide additional context if required:
S3A The prescribed information - passenger views
4. Do you consider yourself as having additional access needs when using public transport?
Yes
5. From the following list of routine information, please tick any that you would find useful if made available to you when planning a bus journey.
Who operates the bus service (e.g. which bus company runs the service), The name or number of the services (e.g. the X8, ‘The Town Service’, etc), The names of the bus stops the bus will call at, in order, The days and times the bus will arrive/depart from each bus stop, The ways that you can pay the fare (e.g. cash, contactless, etc), The cost of the ticket, The difference in price if you bought it in another format or in another way**, Where you can buy tickets (e.g. online, in person at a shop, or only on the bus, etc)., Other
If 'Other', please give your answer here.:
For people using screen readers timetable information online ought to provide the list of stops and the arrival times as a list and not in a table. Traveline Scotland continues to be an inaccessible website. So if Traveline is the source visually impaired passengers are to find timetable and other information then the Traveline website needs to be made accessible for screen readers. Given there appears to be little progress with Traveline becoming accessible for screen readers we would encourage bus operators to continue publishing timetables for their own services on their own websites which are often more user friendly and more accessible than Traveline. We would ask bus operators publish timetables that include every stop rather than the principle stops as this will provide users with more confidence about the arrival time for the bus at their specific stop.
6. Assuming all of the routine information you would find useful were available, how would you prefer to obtain a ticket for travel?
Ticket buying options - I would like to obtain a paper ticket for a specific journey, using cash, contactless payment, or mobile payment (for example, Apple Pay):
Ticket buying options - I would like to ‘tap’ a personal bank card or electronic bank card to make unlimited journeys up to a set fare cap:
Ticket buying options - I would like to hold a physical (plastic) card that I can add a balance to or that would result in a ‘Bill’ at the end of a set period: Ticket buying options - I would like to use a app on an electronic device which allows me to pre-pay for a journey (or a number of journeys):
Box to provide additional context on ticket types:
7. Which of the following ‘real time ’information would you find useful in planning your use of a specific service/services, if it were available?
Live bus stop arrival and departure times, Live disruption updates, On-board capacity (e.g. how full the bus is), Number of wheelchair accessible spaces and if they are in use, If there are toilets on board, and if they are operational, If the bus has audio/visual capability*, Which payment types the bus can accept e.g. cash, contactless, card, etc.
If 'Other', please give your answer here.:
I would like info about availability of services with Audio announcements announcing the next bus stop. These announcements assist many people and are essential for blind people to travel with confidence independently by bus.
8. Specifically thinking about the bus stop or stopping place of the bus, which of the following would you find useful to planning your journey, if it were available?
Accessibility features, Name of the bus stop (for the purposes of finding it on a timetable), Location description (busy streets may have multiple similarly named stops), All of the above
If you have any comments, please leave these below.:
Information should advise if the bus stop is a "floating bus stop" so passengars can choose to avoid using such stops where an alternative exists. Information should advise whether the bus stop has a shelter or whether it simply has a pole without a shelter. Information should advise if the bus stop provides for level boarding so it's accessible for wheelchair users.
9. The remaining questions are not likely to be of interest to passengers, relating to the more technical aspects of data exchange. If you would like to skip to the end of the consultation, please select 'yes' below.
Yes
Any other comments
40 Are there any other comments you wish to provide in relation to bus open data?
Please answer below.:
MACS recommends that the open data requirements are extended beyond local bus services to also include long distance coach services so that disabled passengers have information about the estimated timetable, physical accessibility of the vehicle and availability of on board next stop announcements, which would empower them to decide whether long distance coaches are a travel option for them. Real time information about these services will be particularly important given the potential for long distance services to be delayed.
MACS is concerned that open data on bus services currently appears to exclude many rural services and that the consultation appears to continuing this status quo. MACS recommends the availability of data is made mandatory for all scheduled bus routes so that there isn’t a rural/ urban divide.
Open data is only empowering if it is usable. MACS would stress the importance of ensuring that Traveline Scotland’s website and app are fully accessible for all disabled people, especially screen reader users, and that this is audited involving disabled people periodically testing it. Traveline Scotland should invite screen reader users to regularly test accessibility as over time technology updates and changes to websites and apps can change, and this often affects and alters accessibility.
MACS recommends Traveline Scotland include a feature in the app which alerts disabled passengers that their specified bus is approaching the bus stop. Some passengers with disabilities will benefit from having all the information about stops and services whereas others may find this level of information overwhelming. With that in mind MACS recommends the Traveline Scotland website and app allow users to opt in or out of the level of detail they are seeking. For instance some users may simply want to know the bus times at a particular stop; others may want to know more.
MACS stresses not everyone will be able to access websites or apps so the provision of open bus data while beneficial for many people should not supersede providing information at bus stops as printed timetables, or information screens.
About you
41 What is your name?
Name:
Redacted
42 Are you responding as an individual or an organisation?
Organisation
43 What is your organisation?
Organisation:
Mobility and Access Committee Scotland
44 Further information about your organisation's response
Please add any additional context:
Our Committee advises Scottish Ministers on accessibility. Our Committee is made up of members that are non-disabled people as well as those who have disabilities.
45 The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference:
Publish response only (without name)
46 Do you consent to Scottish Government contacting you again in relation to this consultation exercise?
Yes
47 What is your email address?
Email:
Redacted
48 I confirm that I have read the privacy policy and consent to the data I provide being used as set out in the policy.
I consent
49 Where did you hear about this consultation?
Scottish Government website
If other, please say where: