MACS response to the consultation on 'Reducing car use for a healthier, fairer and greener Scotland'
Read the consultation on 'Reducing car use for a healthier, fairer and greener Scotland'
Question 1
Do you agree with the overall behaviour change approach, and do you have any comments on the four behaviours outlined above? Please explain.
Yes, we agree.
The key to ensuring a reduction in car travel which is inclusive lies in the ‘just transition’. As the Just Transition Commission concluded: “A fair low-carbon transport system will need to recognise…the needs of people living with protected characteristics, such as disability… fresh energy must be injected into existing accessibility strategies if we are to build a [fair] low-carbon transport system”. (See also our concluding comments.)
The behaviour change model (‘COM-B’) seems to be a useful approach especially in highlighting the importance of ‘Opportunity’. Many disabled people have very limited opportunity to access services in alternative ways. The plans to increase remote access (Intervention 1) and to ‘live locally’ (Intervention 2) could be especially valuable for many disabled people, but it is essential to understand the ‘opportunity’ available to disabled people in every measure which aims to contribute to the overall target.
This will require effective Equality Impact Assessments and a much higher level of engagement and involvement with people who have lived experience of disability than has been the norm up to now. These impact assessments also need to address areas where a negative impact on groups with protected characteristics has been “flagged” to mitigate and eradicate the negative impact, preventing inequalities and the mobility gap widening and hence support the “reduces inequalities’ pillar of NTS2.
Question 2
What are the key opportunities of reducing car kilometres?
A specific opportunity which does not yet appear to have been explored is for the Scottish Government to use its new relationship with Motability, which is now the sole accredited body providing mobility services for disabled people in Scotland under the new Accessible Vehicles and Equipment Scheme (AVES). Motability is the biggest purchaser of new cars in the UK, accounting for 1 in 10 of all new cars sold. This puts it in a unique position of influence with the motor industry. Most obviously, Motability could have an important role in enabling customers to access electric and hybrid vehicles (a challenge which it recognises). Moreover, Motability could broaden the range of mobility options which can be offered to customers under the scheme: currently these are limited to cars (including people carrier type vehicles) and powered mobility aids (scooters, electric wheelchairs etc). Motability does not offer bicycles or e-bikes to disabled people who find that these may meet their mobility needs best.
A strategic relationship between the Scottish Government and Motability (and any other body which becomes accredited under AVES) would provide an opportunity to exploit these opportunities, as well as addressing value for money and accountability concerns which MACS has raised.
Question 3
What are the key challenges faced in reducing car kilometres?
While many disabled people will be keen to contribute to environmental targets, many will also be sceptical about, or indeed hostile to, proposals to significantly reduce private car kilometres. The experience of many disabled people in recent years has often been that restrictions on the use of cars, for example to accommodate pop up cycle lanes and wider pavements, has made their lives more difficult (see for example Spaces for People). We welcome the assurance that "access [will be] maintained for those who may need to use private vehicles as a result of their disability”. However, many disabled people would query an assumption that the policy will necessarily have a positive impact on them overall.
It is essential to build the support of disabled people for this policy, both:
- to avoid inadvertently disadvantaging disabled people who rely on private car travel (as driver or passenger), and also by taxi, community transport etc; and
- to maximise public support for the overall goal of reducing traffic, which will be severely undermined if it is seen to discriminate against disabled and older people.
More broadly, it appears unlikely that the measures which are included in the Route Map, which are largely ‘carrot’ rather than ‘stick’, will deliver the extent of reduction required. Many measures such as ‘mobility hubs’ and MaaS initiatives are likely to have at best a marginal effect on traffic volumes. The Route Map is right to recognise that there needs to be discussions on new forms of motor vehicle taxation, including revisiting road pricing. If and when this stage is reached, there must of course be careful consideration of equity issues for disabled people, for example, taking account of people who are wholly or partially exempt from VED, or who no longer qualify for high level Personal Independence Payments or Disability Living Allowance since the 20m rule change by DWP.
The section of the Route Map on funding (3.7) grossly underestimates the challenge for local authorities in particular. For an equitable transition to be achieved there needs to be massive investment in a whole range of local infrastructure - notably pavements and bus stops/shelters/stations/lighting - which is completely unachievable within current resources. To take one example, we understand that of 24,000 side road junctions in Edinburgh, 17,000 have either no dropped kerb, or one which doesn’t meet the required standard.
Question 4
Are there any further actions you would like to see included in future to support behaviour change 1) - reducing the need to travel?
We support the actions in this section. In addition to the environmental benefits of digital connectivity in reducing the need for travel, this can significantly improve accessibility for disabled people. The extension of online services, meetings etc during the pandemic through the widespread use of Teams, Zoom etc. has enabled many disabled people to participate in activities and decision-making that were not previously possible. However. it needs to be acknowledged that many websites, apps and travel planning tools (including Traveline, as raised repeatedly by MACS) have accessibility problems and it is vital that they are designed to meet best accessibility practice.
We would also refer to MACS phase one work on Transport to Health and Social Care and the problems disabled people and older people face accessing medical and social care facilities. The roll out of “NHS Near Me” is an opportunity to address some of the transport issues and also provide a service closer to or at home for disabled people who choose this care pathways and reduce the need and cost of travel.
These environmental and accessibility benefits need to be consolidated into future policy and practice.
Question 5
Are there any further actions you would like to see included in future to support behaviour change 2) - choosing local options?
MACS is very supportive of the principles behind the 20 Minute Neighbourhood and the potential this has to increase accessibility of services and the inclusiveness of local communities. However, a major challenge, which the Route Map is largely silent on, is the need to improve local pedestrian environments. A poll of over 400 people by Disability Equality Scotland on the concept in November 2020 found that 94% of people couldn’t access local services within 20 minutes by walking or wheeling largely because of issues with the quality and accessibility of pavements, street clutter, pavement parking, etc.
The Route Map puts a lot of store on public sector tools, guidance, policy etc such as ‘the Place Principle’, local development plans etc. While this is welcome, the reality is that town centres are suffering massively from market-led changes, associated with wider trends such as the rise in internet shopping. Many High Streets are full of empty units, charity shops etc and it is very unclear that current policy tools will be effective in turning this tide. A wider discussion is needed about town (and neighbourhood) viability including fiscal measures to support corner shops, business rates, rents etc. in addition to planning tools
The Route Map highlights the role of ‘Mobility Hubs’. MACS has in its submission to the NPF4 consultation, asked that transport interchanges - bus and train stations - are given National Development status. These are effectively already ‘mobility hubs’ and often grossly under developed or neglected. Improving train station access is a priority of STPR2.
In terms of supporting behavioural change, MACS would welcome a national public education campaign to reduce the abuse of blue badge parking and inconsiderate parking (such as on pavements or over dropped kerbs), reinforced by effective enforcement.
Question 6
Are there any further actions you would like to see included in future to support behaviour change 3) - switching to more sustainable modes of travel?
With regard to encouraging a switch from private car to more sustainable modes, the Route Map needs to do two things:
- ensure that wherever possible, options to switch from private cars to sustainable modes specifically consider the needs disabled people so that disabled people can participate in the national effort to reduce car travel, and that
- disabled people who cannot easily or reasonably make that switch are not disadvantaged by wider measures to curtail traffic
The Route Map needs to more explicitly acknowledge the fact that many disabled people cannot switch to other modes (active and public transport etc) as easily as non-disabled people. This has been exacerbated by various organisational policies which have also forced disabled people into private car use. A notable example is the Scottish Ambulance Service change in carer policy and demand capping as organisational efficiency saving measures. These two actions alone resulted in many disabled people not being able to use ambulance patient transport services (shared mini bus style and multi uplifts) and being forced to use private cars for these journeys.
Many disabled people are disproportionately dependent on cars - as either drivers or passenger (or both). Measures to curtail car use may carry significant risks that they inadvertently discriminate against disabled people: we suggest therefore that a risk register is developed for the programme, and that this risk is included as a prominent risk. When individual measures are promoted aiming to help achieve the target, these risks should be considered in relation to that specific measure.
As noted above, the Route Map is extremely light on measures to encourage ‘everyday walking and wheeling’ despite acknowledging that evidence shows “that well maintained footpaths are one of the most effective interventions for increasing walking”. It is claimed that action to support walking and wheeling is covered in Section 3.2, but it is hard to see any such action in this section. The scale of the task to improve pedestrian environments has not been grasped - yet this is essential in order for many of the aims to be achieved, from enabling children to safely walk to school or to achieve 20 Minute Neighbourhoods, as noted above. It is hard to square the lack of investment in this area with the sustainable hierarchy or with the current patterns of capital spending which continue to prioritise trunk roads.
The Fair Fares Review (Intervention 3h) needs to include community transport and taxi - modes which disabled people are particularly reliant on, but which are excluded from most concessionary travel arrangements at present. The postcode lottery of concessions for rail and ferry travel also needs to be addressed. This focus also links to the ask of the Scottish Government that all public sector bodies consider in their strategies and policies how they can assist with reducing poverty and inequality.
Question 7
Are there any further actions you would like to see included in future to support behaviour change 4) - combining or sharing journeys?
We believe that of the four main interventions, this probably has the least potential for disabled people to contribute to deliver the 20% target. Mobility as a Service (MaaS) is still a largely untested concept which has not yet delivered any significant improvement to mobility options. While car clubs may have a useful role to play in reducing the time that vehicles are idle, we are sceptical that they necessarily will lead to increased trip sharing.
One aspect of journey-sharing which does not yet appear to have been much considered is how travel concessions will apply to them (see also comments on Fair Fares, taxis and community transport above).
Question 8
Do you have any comment to make on any of the specific policies contained within the route map?
With regard to the carriage of bikes on buses (mentioned under intervention 3.4), this is an example of a measure which needs a careful Equality Impact Assessment. While this could measure could be very valuable in inter-urban and rural environments, it could cause difficulties for older and or disabled people in busy urban environments. A discussion of carriage of mobility aids on buses should also encompass mobility scooters, which are not permitted on most bus services. We have seen some good examples of this south of the border but an absence of initiatives in Scotland.
Do you think that the proposals set out in this plan could have positive or negative impacts on any particular groups of people with reference to the listed protected characteristics?
MACS has responded separately to the draft Equality Impact Assessment. We do not agree that it can necessarily be assumed that the policy will have a positive impact on disabled people. However, this is achievable if it is implemented with proper involvement of disabled people and with effective understanding of the impact of associated measures. MACS believe that a current weakness in the route map is in fully understanding the problems before designing solutions.
Do you think that the proposals set out in this plan could have a particular impact (positive or negative) on island communities?
MACS has responded separately to the draft Island Communities Impact Assessment.
Do you have views you would like to express relating to parts of this consultation which do not have a specific question? If so, please elaborate
The document refers in a number of places to recognising the needs of “people with specific disabilities”. We suspect that the assumptions behind this phrase may be problematic, and could result in serious problems with implementation of measures to achieve the target. It is not clear which “specific disabilities” are in the mind of the report authors, but it reads as if some disabled people - perhaps people with angina, or arthritis? - have an inherent need to use cars more than other people, and may therefore be less expected to switch to active, shared or public transport. While there may be some truth in this, the focus on “specific disabilities” appears to view the issue through the lens of ‘the medical model’ of disability, rather than, as we would advocate, the ‘social model’ of disability. The social model sees the cause of mobility restrictions facing disabled people as not in the nature of an individual’s impairment, but rather in the failure of the environment, or society to accommodate their needs. So a disabled person may be more reliant on their car than a non-disabled person, not because of the medical origin of any impairment, but because the bus stop is too far away, or the pavement has no dropped kerbs. A person is disabled by their environment, rather than by any personal characteristic.
This alternative perspective on disability is absolutely central to understanding how to secure a just transition and to ensure that the 20% target doesn’t discriminate inadvertently against disabled people. We suggest replacing “people with specific disabilities” with simply “disabled people”. Moreover, the strategic challenge needs to be re-defined as envisaging an environment and transport systems which are accessible inclusive and joined-up, meeting everyone’s needs, instead of making exceptions for certain people with “specific disabilities” who might be exempted (or excluded) from programmes.
MACS supports the ambition to significantly reduce the volume of motor travel which we agree is important for environmental, social and economic reasons. We conclude with two quotations from the report of the Just Transition Commission in March 2021, which we very much support and would encourage to be kept in the forefront of the programme as it is implemented:
“Our vision is for a transition that is not solely about mitigating injustices that may arise because of climate change. We also seek to capture opportunities to address existing inequalities, making urgent climate action a driver of positive change” (P5)
“A fair low-carbon transport system will need to recognise the different needs of communities and users, and focus firmly on people not cars. For example, rural communities have very specific transport needs and challenges. Similarly the rights and needs of people living with protected characteristics, such as disability, must be respected. Building a transport system fair for everyone will need to be based on the principle of participation, and giving marginalised groups affected by any changes a voice. Renewed effort will be needed, and fresh energy must be injected into existing accessibility strategies if we are to build a low-carbon transport system that addresses this.” (p31)