MACS - Island Connectivity Plan - Strategic Enviornment Assessment Response - March 2025

MACS – Ferries and Aviation, Mobility and Access Committee for Scotland

Review of the Strategic Environmental Assessment:

MACS understands that the majority of this document is for the purpose of a technical environmental evaluation, a small part logistics planning of ports, some policy compliance and a nod to social & accessibility considerations - this isn't unusual and MACS wouldn't expect this to be a document which comprehensively addresses accessibility.

I think an Equalities Impact Assessment would be more fruitful to provide a response to in due course but there are a couple areas to address outlined below:

"Unknown Impact" on Marginalised Groups (Page 34, Outcome 2.1)

• The environmental assessment marks the impact of fair and safe access as 'unknown', which is unacceptable given the legal obligations under the Equality Act 2010.
• Why has this been marked as unknown? Has feedback from disabled individuals been actively sought and incorporated into the planning process?
• If data is lacking, the consultation should extend its outreach to disability advocacy groups.

Potentially Ableist Assumptions (Page 80, Outcome 1.2)

• There is no explicit mention of disabled passengers or the specific accommodations required for them, which raises concerns that the assessment assumes an able-bodied perspective.
• Outcome 1.2 discusses people getting to where they need to go, but does not explicitly consider disabled passengers who may need additional support, step-free access, or mobility accommodations.
• Does Outcome 1.2 assume an able-bodied perspective? How has the assessment ensured that disabled passengers' unique needs are considered?