MACS Response to the CHFS3 Consultation - January 2024

Reliability and Resilience

Community feedback highlighted that the resilience & reliability of ferry services needs to be addressed as a priority due to the impact on business & communities when ferry services are disrupted.

Question 1: Do you think that the current performance measures of the ferry services are the right ones?

Answer: No. Too narrow a set of performance measures.

Please explain your answer:

MACS appreciate the monthly performance statistics published on the Calmac website with respect to reliability and punctuality. It is clear from the statistics that particular routes are regularly affected by cancellations, and we are concerned that disabled passengers will be severely impacted by these.

As part of the custom reporting, MACS would welcome the monitoring and publication of statistics for passengers booking assistance i.e. wheelchair, wheelchair and lift, lift, presenting as turn up and go requiring assistance or other.

Question 2: Are there any additional or alternative performance measures that you think could be introduced to improve resilience and reliability of ferry services?

Answer: No.

Please give us your views:


Capacity and Demand

Fares have significantly reduced and made Scottish Islands more accessible to everyone through the Road Equivalent Tariff (RET) however, we understand there is a balance to be struck between vessel capacity and passenger demand, therefore we need to find a better way to manage the number of users and the available space.

Community feedback has highlighted the high demand for ferry services during summer. Therefore, there is a requirement to consider the balance between capacity and demand to ensure car spaces are available to make essential or urgent travel.

Question 3: We know that vehicle space capacity is at a premium during peak time sailings. Do you have any suggestions that could be introduced to reduce vehicle space demand?

Answer: Yes.

If yes, what are your suggestions?

Reliable, affordable, and accessible onward connections (public transport) to and from ferry terminals.

Passenger assistance from bus or train to board ferry.

Targeting Mobility as a Service (MaaS) and Demand Responsive Transport (DRT) funds and pilots to support sustainable and shared transport to ferry terminals.

CalMac working closer with Regional Transport Partnerships to use the Active Travel Transitional Funding (and the evolving People and Place Plans) to drive and support behavioural change and the use of more sustainable modes of transport by a combination of enhanced infrastructure, information provision, innovation, and measures to reduce car use.

Question 4: To reduce the number of cars on deck at peak times, would you be willing to travel to and from a port using public transport?

Answer: No.

If no, please explain your answer:

Disabled passengers often require additional equipment such as mobility aids and medical equipment. It is therefore necessary to travel by private car.  They should be a priority group for securing deck space on ferries.

Question 5: To reduce the number of cars on deck at peak times, would you be willing to travel to and from a port using active travel modes (walking, wheeling, cycling)?

Answer: No.

If no, please explain your answer:

Public transport from ferry terminals is unreliable. Timetabled services have no flexibility, leaving passengers stranded in the event of a delay. Disabled passengers need to plan journeys around their care needs and be fully confident that their needs can be met in the event of a delay or cancellation. Public transport is therefore a last resort.

Passenger assistance is inadequate. Disabled passengers travelling solo can struggle with boarding methods, particularly when linkspan is out of use.

Question 6: Should operators be required to hold dedicated vehicle deck spaces on busy routes for the use of island residents and key worker personnel required to travel at short notice?

Answer: Yes.

If no, please explain your answer:


Community Voice, Transparency and Accountability

Community feedback suggests there could be more dialogue and consultation carried out across the network, giving local communities a better opportunity to provide feedback, which will aid decisions related to ferry services.

Community feedback highlighted that ferry services need to be appropriately timetabled to balance the needs of different users.

Question 7: How could communities be provided with a stronger role in providing input on ferries related decisions?

Please give us your views:

Communities have been expressing their frustration with ferry services, particularly in relation to resilience and reliability, through various media channels for a number of years. They feel they are not being listened to.

We often hear of Equality Impact Assessments being conducted for service changes or design without the input of local communities or those who identify as sharing protected characteristics under the Equality Act 2010. It is critical that these impact assessments (including Island Community Impact Assessments) are not conducted in isolation (without input) of the communities reliant on ferry services. Anything short of this level of meaningful engagement is a tick box exercise and runs counter to the Democracy Matters agents championed by the Scottish Government.

Question 8: Are there ways in which Operators’ engagement with local communities can be improved?

Please give us your views:

Calmac Community Engagement Officer would be beneficial as a contact for community groups and other organisations. Visits to community groups would provide a platform for people to share their concerns and offer suggestions for improvements.

It would also provide an opportunity for Calmac to promote services and gather helpful information. Equality Impact Assessments and Island Community Impact Assessments should ensure input from local communities or those who identify as sharing protected characteristics under the Equality Act 2010.

It is critical that these impact assessments are not conducted in isolation (without input) of the communities reliant on ferry services. Taking this collaborative approach will improve and strengthen engagement, which will in turn lead to the design of better ferry services that meet islander’s needs.

Question 9: Is the Ferries Community Board representative of island populations?

Answer: Yes.

If no, please explain your answer:


Question 10: Does the Ferries Community Board reflect your interests for the next contract?

Answer: Yes.

Please explain your answer:

Ferries provide a lifeline service for island communities. The needs of these communities should be prioritised when planning timetables.

Carbon Reduction and Environmental Impact

We are making good progress towards a net zero future; however, low carbon ferry engine technology is still being developed so we need to think of alternative ways to reduce our carbon footprint and our impact on the environment.

Question 12: In what ways can ferries reduce their carbon emissions in line with Net Zero targets?

Answer: As a regular ferry passenger, I would agree that CalMac are doing their utmost to reduce their carbon footprint on board vessels and at terminal buildings. Their carbon footprint will be reduced further as older vessels are replaced.

Please give us your views:


Question 13: Would you consider reducing your car use when travelling by ferry?

Answer: No.

If no, please explain your answer:

As stated earlier, disabled passengers often require additional equipment such as mobility aids and medical equipment. It is therefore necessary to travel by private car. They should be a priority group for securing deck space on ferries.

Onward and Connecting Travel

Looking at how onward and connecting travel can be promoted will enable us to provide opportunities for better connectivity and ferry user-access via active travel, public transport, and other more sustainable transport modes.

Question 14: What do you think could be introduced to improve public transport connectivity between ferries, rail, and bus operators?

Please give us your views:

Service providers need to coordinate their timetables in order to meet the needs of passengers. Transition from one mode of transport to another should be safe, seamless, and accessible for all. Passenger assistance between modes should be available as needed.  

The additional time for some disabled passengers and older passengers to transfer between modes needs to be factored into cross modal timetabling.


Community feedback showed that some equality groups face additional challenges when accessing and using ferry services.

Question 15: Would you support a regular accessibility audit taking place with accessibility groups such as Mobility Access Committee Scotland (MACS), with the aim of improving accessibility at ports and onboard vessels?

Answer: Yes - MACS are committed to working with service providers to improve accessibility and support services for disabled passengers at ports and onboard vessels.

MACS would also suggest that Disabled Access Panels, local to ferry terminals, should be involved in these audits i.e. Oban Access Panel have already audited cross modal connection from Oban bus and train stations to the Ferry terminal, including interchange times and signage. Access Panel Orkney have worked with NorthLink. Most Island and mainland ferry terminal have a local Access Panel.

What else you think could be done to improve accessibility on our ferry services?

A case study is being submitted as part of our response to this consultation. The study recommends a number of measures/actions to improve the passenger experience in terms of accessibility.

This focuses on taking a person centred, and lived experience, approach to improving ferry services.

Freight Services

Feedback provided by the community has highlighted that freight bookings can impact available vehicle spaces on vessels.

Question 16: Are there ways to improve the Operator’s collaboration with hauliers and businesses to better plan commercial traffic volumes?

Please give us your views:

Regional Transport Partnerships - RTPs - (including those covering island and ferry terminal areas) have specific projects looking at the movement of freight (Freight Strategy) as part of their Regional Transport Strategies. Ferry operators should engage with RTP Partnership Directors.

Question 17: Do you have any suggestions to better manage or reduce the demand on routes which experience high freight volumes?

Answer: N/A

Please give us your views:


Monitoring and Review

Feedback has highlighted that communities would like greater clarity and accuracy on performance reporting to be embedded within the next contract.

Community feedback indicates that the true passenger experience is not reflected in the way the operator reports performance.

Question 18: Would you welcome the opportunity to provide feedback to improve services?

Answer: Yes.

If yes, how often should this happen and how should this be conducted?

Service users should have a means of submitting feedback for every journey taken. We welcome the opportunity to submit feedback for journeys booked online.

Passengers booking in person should also have access to paper feedback forms within the terminal building. 

Each vessel should offer passengers a means of submitting customer satisfaction feedback, this could be through a QR code, similar to the QR codes for the menu on the tables.  Some passengers may prefer a paper option and that should also be available.

Question 19: Do you have any suggestions on how the Operator could provide a more accurate reflection of the passenger experience?

Please give us your views:

Regular monitoring of feedback. Publish results and use feedback to improve services.

Utilise the complaints process to rectify issues and drive improvements i.e. use the complaints process as a learning tool.

CHFS3 Response - Debbie A Case Study

Debbie was born and brought up on the Isle of Lewis. She has a rare genetic condition called Bardet Biedl Syndrome. Some characteristics of the syndrome include learning difficulties, obesity, restricted mobility, and sight loss. Debbie is registered blind and suffers from severe joint pain.

She has been living on the Scottish mainland for the past 16 years to access a facility that allows her to thrive and provides care services designed to meet her specific needs. This arrangement is not unusual for island families as services for adults with special educational needs and disabilities are limited on the island. Families occasionally opt for a mainland placing if the individual's needs cannot be met on the island.

This is not a decision taken lightly as it restricts time spent with family. Over the years, Debbie has been travelling back to Lewis for regular visits, but due to her worsening mobility, the journey is becoming more challenging and particularly stressful if there are travel disruptions.

This case study is based on a return journey from Ullapool to Stornoway on the MV Loch Seaforth; therefore, some of the challenges are localised. However, most of the issues here can be applied to any ferry journey undertaken by a disabled passenger.

Stage of Journey - Booking

We set up an online account for Debbie and added her blue badge card and concession card details, but the discount isn't applied at checkout.

Both concession and companion tickets are listed as options online. However, when selected, it states they are not available on this route.

Despite several calls and excellent support from Calmac Customer Services, the issue remains unresolved.

Proposed Solution

Online system requires further trialing, updating and regular monitoring.

(If it helps to test the system, Debbie and her plus one would be happy to trial with her cards)

Stage of Journey - Arrival and departure at port

There is no accessible parking at the ticket office. The only option is to stop in the drop-off area and cross two bus lanes to enter the ticket office, which is unsafe.

Proposed Solution

Discussions with the Ullapool Harbour Trust and exploring a funding application to the Ferries Accessibility Fund for accessible parking spaces are recommended.

Stage of Journey - Ticketing

Concessionary tickets can only be obtained on the day of travel, requiring a visit to the ticket office. Debbie holds a National Entitlement Card (NEC) for a person with a visual impairment plus a companion and is unable to travel independently. Despite this, her travel companion is required to pay on the route.

Proposed Solution

Disabled travellers should be treated equally and be allowed to get their tickets in advance of travel, consistent with other travellers. Consistency in the use of concessionary cards for disabled travellers is necessary. Travellers requiring a companion should have their NEC honoured regardless of the mode of travel or geographical location.

Stage of Journey - Boarding (Ullapool)

No issues were noted specifically for boarding at Ullapool.

Stage of Journey - Seating

Fixed armrests are unsuitable for people with limited mobility.

Proposed Solution

Folding armrests should be considered if possible.

Stage of Journey - Toilets on Board MV Loch Seaforth

Changing Places are designed to be completely accessible for those who have severe disabilities. They provide sufficient space and equipment for people who are not able to use the toilet independently.

Proposed Solution

Additional accessible/changing place toilets for independent use should be an extra facility in addition to accessible toilets.

Stage of Journey - Disembarkation (Stornoway)

The linkspan at Stornoway has been out of use for months. Embarking via the car deck is challenging for older, anxious, and disabled passengers, including passengers with hidden disabilities.

Proposed Solution

Consider providing passenger assistance/transport from the terminal building to the lift for foot passengers requiring assistance and their luggage when the linkspan is out of use.

Stage of Journey - Boarding (Stornoway)

Disabled passengers travelling in cars are last to board the ship. For passengers with reduced mobility, this can result in difficulties transferring from cars to lifts as walkways are narrowed or impeded by parked vehicles. There have been occasions when disabled passengers (and their plus ones) have struggled to find a seat. It is common that plus ones need to stay seated beside the disabled passenger.

Proposed Solution

Provide priority boarding to disabled passengers. If not possible, crew should be on hand at lifts to ensure disabled passengers can access suitable seating. Consider introducing a system to facilitate reserving seats for disabled passengers and their plus ones on booking.

Stage of Journey - Delays and Cancellations

These are inevitable, often unavoidable and pose challenges for all passengers. For a disabled passenger the main challenge is finding affordable, accessible accommodation at short notice in the event of a cancellation. There can also be issues around medication, pain  management and care plans. Until recently, passengers affected by cancelled sailings would turn up for the next sailing and expect to travel. The new policy of having to rebook is not beneficial to passengers and causes additional stress for disabled passengers.

Proposed Solution

Consider prioritising disabled passengers and those needing assistance if a sailing is cancelled. For a disabled passenger, the main challenge is finding affordable, accessible accommodation at short notice in the event of a cancellation. 24-hour access to customer services would also help passengers make alternative arrangements in the event of a cancellation outside office opening hours. Some helpful information online and in the ticket office, such as local services and accommodation providers, would also assist passengers affected by delays and cancellations, as would the ferry operator being responsible for sourcing and booking accessible accommodation if required.