MACS Letter to Daniel Lafferty 28 October 2022

Dear Mr Lafferty

Thank you for meeting with a number of members of MACS on 2 August 2022 to brief us on the ‘Fair Fares Review’ initiative.

We felt it would be useful for us to outline our own initial thoughts on what we would like to see the initiative encompass, so that these can be considered as the scope of the project becomes more clearly defined. In the broadest terms, this aligns very much with one of MACS‘ key principles - that transport should be Available, Accessible and AFFORDABLE.

These comments are made in three sections - firstly some general points on the importance of the review to wider Scottish Government policy, secondly, issues about concessionary travel arrangements and finally some comments on fares more generally.

Policy considerations

From conversations with various Ministers (Minister for Transport, Minister for Active Travel, Cabinet Secretary for Social Justice, Housing and Local Government, Minister for Equalities and Older People) and officials, the Fair Fares review has been cited as the vehicle to deliver affordable transport, to assist with keeping people connected (reducing social isolation and loneliness, improving health and well-being) and enabling the modal shift from private car to public transport to support various government policies (Child Poverty Delivery Plan, A Fairer Scotland, National Transport Strategy 2, Low Traffic and 20 minute neighbourhoods, the Sustainable Transport Hierarchy, 20% reduction in car kms by 2030, tackling the climate emergency etcetera).

To enable the delivery of the commitments and ambitions from these policies and strategies the "Review” needs to keep in scope actions that are bold and break down the financial inequalities between urban, rural and island areas, the cost variance between modes of public transport and assist with making transport more available, accessible and affordable for all. In particular, there should be a focus on delivering affordable public transport options for those who rely on and currently struggle the most to use public transport (disabled people, older people, people on low incomes, island and rural communities).

Of course, the Review can also make a vital contribution to tackling the cost crisis, the over-riding theme of the recently published Programme for Government.

Travel Concessions

Regarding concessionary travel, we recognise that the national bus concession scheme for older people and disabled people is a huge benefit for people in Scotland. It is simple, free and has few limitations in time of travel or geographical limitations (dependent on the availability of bus services).People who require companions to travel can also travel free.

In contrast, concessions for most other modes of travel - rail, taxis (including private hire cars), tram/subway, community transport, ferry and domestic air - are either a postcode lottery or are largely absent. Moreover, information on what is available is extremely difficult to find in one place.

We appreciate that this is because most concessions applying to such modes are the responsibility of local authorities rather than national scheme although there are of course exceptions - blind people travel free by rail nationally (although whether the companion can travel for free too depends on the local authority area).

However, one of our chief hopes for the Fair Fares review is to see a coherent, consistent and logical set of concessions for all modes in place across Scotland, to remove the ‘postcode lottery’ and to provide a simple set of concessions, which apply everywhere.

We would also want all concessionary schemes to take a consistent approach to discounts or free travel for carers/assistants as a matter of course. We appreciate that this would be easier to introduce for some modes of travel than for others.


For Edinburgh trams - probably Scotland’s most accessible public transport service - it should be relatively simple, and not overly expensive, to end the current anomaly whereby free travel is available only to Edinburgh residents. This anomaly will become ever more evident and hard to justify as the tram network grows - including from next year to the Scottish Government building
at Victoria Quay.

Entitlement for all disabled people in Scotland to concessions on the Edinburgh trams would also make a modest contribution to Scottish Government aim to reduce car travel by 20% by 2030, providing as it would a new attractive option for disabled motorists to use park and ride at Ingliston instead of entering the city, including the new Low Emission Zone. Similarly, extending geographic eligibility for concessions to the Glasgow subway should be administratively and financially simple.


For rail, we understand that in early 2022, while passenger ridership had reached some 70% of pre-pandemic levels, the use of the excellent passenger assist service had reached only around 30%. A national concession scheme would encourage many disabled people to resume rail travel and again, in some cases to switch away from private vehicles especially now that ScotRail has come under public ownership.

Of course, we would ideally like to see free rail travel throughout Scotland for all disabled people (as it has long been for blind and people with sigh loss) but if this is unaffordable, there are other options which could be explored such as ones based on distance, percentage or capped fares.

Rail has the most developed passenger assistance programme of any public transport service and has many benefits for disabled people such as shorter journey times, accessible toilet facilities, ability to travel with mobility equipment such as power chair, wheelchair add on, nonstandard bike, mobility scooter etcetera.

These all make it easier for disabled people to complete a door-to-door journey by a more sustainable mode. However, many disabled people can’t afford to travel by rail even with the current disabled persons discount and annual fee to receive the discount.

Travelling by rail can offer more direct and quicker journey times than by bus (assisting with chronic pain management) and is more reliable for wheelchair users whose journeys can be delayed or abandoned due to only one wheelchair space per bus and the tension between wheelchair users, buggies and luggage storage. Disabled people cannot travel by bus with their
mobility equipment other than a self-propelling wheelchair, which can limit connections due to distances.


Many disabled people need door-to-door transport and are therefore heavily dependent on taxis (which are used by disabled people approximately twice as much as by non-disabled people). We therefore advocate the setting up a new national taxi scheme, which could be a gold standard scheme for Scotland in promoting accessible travel. It would also increase passenger demand for taxi drivers, many of whom have suffered severe income loss since the pandemic and encourage
taxis (and private hire cars) to remain viable, especially in marginally-profitable rural and island communities.

Community Transport

For community transport, legislative change may be required for full entry to the current national scheme as while ’Section 22’ services can access the national concessionary bus scheme, ‘Section 19’ services cannot. However, there may be scope for helpful interventions within the current legal framework, which should be explored. Any concessionary scheme for CT would need
to be different from that which applies to bus as different ‘generation factors’ will apply between commercial and community services.

Again we consider it to be an unacceptable anomaly that disabled people may have to pay often significant fares for community transport trips which would be free on regular bus services. This is a particular concern in accessing essential services such as to Health and Social Care facilities, where the passenger may pick up the volunteer’s reimbursement fee and this can be costly and
prohibitive (in contrast to patient transport service which would be free - if available). An associated complication here is the healthcare travel reimbursement system, which does not function well in our view and should be brought within scope of Fair Fares Review.

Ferry and air

For island travel (and some mainland areas like Cowal), we understand there to be a range of ferry discounts and entitlements, some funded by local authorities, some centrally. There does not appear to be a single source of information on all concessions and this is something which requires attention and ideally simplified and made as consistent as possible as part for Fair Fares. Air travel in Scottish islands attracts a discount of 50% off fares for all resident islanders. We are not aware of any further discounts for disabled people or older people, but the cost of flights and impacts on disabled people should be included within the scope of Fair Fares Review, consistent with Island Connectivity Plan and associated strategies and objectives.

Non-concessionary fares issues

Concessionary travel schemes are of course only one tool to aid affordability of travel. Commercial transport providers have always structured fares to provide a range of discounts and incentives including discounts for:

  • return fares
  • child fares,
  • family tickets,
  • season tickets,a range of railcards (including of course, for disabled people), etcetera.

More recently, the widespread use of smart ticketing has enabled daily fare ‘capping’ to become common. For example, Lothian Buses’ ‘tap tap cap’ system has a daily cap of £4.40 and a weekly cap of £20.00. Some of these fare arrangements can offer significant savings, but may not help some people who are least able to afford them. For example, people who cannot afford to pay the upfront cost of season tickets, or people who use cash, rather than smartcards. This may be similar to the well-known problem with energy costs where people who have the lowest incomes may rely on prepayment meters, which exclude them from cheaper tariffs. The distribution of these kind of fare benefits of such commercial schemes is something which Fair Fares Review needs to explore.

We appreciate that the viability of many public transport services, especially but not exclusively in rural areas, is fragile. While we accept this is outwith the scope of Fair Fares Review, it is vital that other measures to boost public transport ridership should be encouraged which will enhance our aspirations for ‘available’ as well as ‘affordable’. Most obviously this would involve effective plans to stop buses getting caught in traffic congestion, for example through new Bus Partnership arrangements, which extend and better enforce bus lanes.

No doubt the Fair Fares review will encompass opportunities presented by smart and integrated ticketing, which has the potential to especially benefit many disabled people by allowing seamless ticketed travel, whether this is simply changing from one mode to another or a more fully developed ‘Mobility as a Service’ (MaaS) type system.

The Fair Fares Review will no doubt take full account of the distinctive needs of rural and island communities but a full Island Inequality Impact Assessment (as well as Equality Impact Assessment) should form a core part of the Review. This will need to take account of ferry and domestic air fares for both passengers and vehicles and consider the place of Road Equivalent Tariffs (RET).

Finally we note some ambitious national schemes to promote free or discounted public transport, for example in Luxembourg, Germany and Spain. We hope that Scotland will match such ambitions, and also be alert to the lessons and opportunities of UK initiatives such as in Manchester, as described in the appendix.

We look forward to hearing more about Fair Fares Review soon and to contributing further to the
Review in the future. Our door is open and we stand ready to assist.

Yours Sincerely,

Linda Bamford
Mobility and Access Committee for Scotland (MACS)

Appendix - Manchester

16 June 2022: Greater Manchester Mayor Andy Burnham has brought forward plans to reduce bus fares in Bury and the rest of the region. Mr Burnham has announced his intention to accelerate the introduction of reduced bus fares to help people with the cost-of-living crisis. From 1 September 2022, he intends to cap single journey fares at £1 for children, £2 for adults and for
daily tickets to cost £5, which will allow unlimited travel across all operators.

The new fare structure is subject to agreement with government and bus operators, but if plans go ahead it will come in a year earlier than originally planned, also applying across all of Greater Manchester from day one rather than a gradual roll out. Mr Burnham said: “In March, I announced our plans for £2 capped single fares for adults and £1 for children, to be
introduced from autumn 2023 as we began to franchise our bus network. Given the immense financial pressure the cost-of-living pressures are putting on the people of our city-region, I am announcing my intention to introduce these fares on 1 September this year, subject to agreement with government and bus operators. Alongside these affordable single fares, we will also introduce a £5 daily ticket which will offer unlimited travel on all bus operators within Greater Manchester.”

He added: “My message to the people of our city-region is simple: Greater Manchester needs you. Use public transport and make the most of these affordable fares. Only you can make this sustainable. To make affordable fare caps permanent, we need people to take the bus. We’re on an exciting journey and we need the whole of the city region to get behind it. Franchising our buses, bringing them back under public control, and lowering fares are a key part of creating the Bee Network– the London-style transport system - that our region needs and deserves. However, we now need more people to support our public transport system by using it.”

Gary Nolan, Chief Executive of OneBus, the Greater Manchester Bus Operator’s Association, said: “Local bus companies are keen to play their part in encouraging more people to use buses as an easy, environmentally friendly way of getting around the region.
“This financial support to cap bus fares across the region will help do this and will benefit the bus network and passengers in the long run. We’re pleased to support it.”

These plans come as part of the wider ranging Bee Network scheme, which aims to implement a London-style conurbation-wide transport system.