MACS response to the consultation on the draft Scottish National Transport Strategy

MACS welcomes the opportunity to comment on the draft Scottish National Transport Strategy.

The Mobility and Access Committee for Scotland (MACS) is a Scottish Government Ministerial Advisory body. Our aims are:

To give Scottish Ministers advice on aspects of policy affecting the travel needs of disabled people;
To take account of the broad views and experiences of disabled people when giving advice on travel needs;
To encourage awareness amongst disabled people in Scotland of developments which affect their mobility, choices and opportunities of travel;
To work closely with the Scottish Government and ensure the Committee’s work programme complements the work being undertaken by the Disabled Persons Transport Advisory Committee (DPTAC), the Scotland Office of the Equality and Human Rights Commission and other organisations and voluntary and statutory agencies;
To promote the travel needs of disabled people with transport planners, transport operators and infrastructure providers so that these are taken fully into account in the delivery of services; and
To monitor and evaluate the effectiveness of the Committee’s work against the above aims in improving travel opportunities for disabled people in Scotland.

In general terms, we are delighted to see that equality is one of the four pillars of the draft strategy. This document should be used as a catalyst to make Scotland an exemplar country for inclusive, accessible transport in which all disabled and older people can travel as freely, easily and frequently as everyone else. The aspiration to “Ensure transport in Scotland is accessible to all” (‘Enabler’, p50) is welcome, and ambitious.

However, the want to emphasise the vast gap between this ambition and the current position; the challenge represented by closing that gap must not be underestimated. Transport provision (or lack of it) in Scotland fails to meet disabled peoples’ needs in many respects; to take only a few examples:

many rural areas in Scotland have limited or no accessible public transport;
high-floor coaches used as local bus services;
a complete absence of wheelchair accessible taxis in many areas;
a lack of audio-visual information in buses and trains;
a general failure to apply provisions of the BSL (Scotland) Act 2015 to transport;
a legacy of grossly-inaccessible infrastructure, including bus stops and stations (rail and bus);
narrow, broken pavements, often littered with obstructions and hazards.

We acknowledge that there have been important recent improvements in the inclusiveness of Scottish transport. For example, Scotrail now has the shortest requirement for advance booking of passenger assistance, at one hour, of all UK rail services). However, the Delivery Plan, which will put the NTS into practice will need to have a strong focus on practical measures which improve access.

Although MACS strongly supports the Scottish Accessible Travel Framework, published in 2016, it is essential that improving access and inclusion is ‘mainstreamed’ in all transport planning and delivery, rather than confined to a small number of specific initiatives. The mobility problems that disabled people face are often compounded by other factors, notably rural environments and poverty, as the strategy acknowledges.

The strategy is right to note that the numbers of ‘very old’ people will increase significantly in the next decade (Figure 1, p16). If older people are unable to participate in their local communities (visiting family, friends) or access the services they need (healthcare, banking, shops, leisure, volunteering etcetera) not only will they experience more loneliness and social isolation, but they will become less independent. This will have a significant direct impact on health and social care systems, and increase unnecessarily the demand for and cost of both residential and community services.

While it is noted (p37) that spatial planning policy has an important role to play with regard to transport policy generally, it is also important to recognise the value of designing mixed and inclusive neighbourhoods, where people can access what they need on their doorstep. This is as important for rural communities (retaining village shops, banks, post offices, libraries, doctors’ surgeries, accessible toilets, etcetera) as for urban areas.

We recognise the importance of Scotland’s concessionary travel scheme (p17). However, the scheme does not benefit disabled people who cannot use local bus services, for example because a high floor coach is used on local registered bus services (as in North East Scotland),because the person cannot get from their home to or from the bus stop, or because the bus service does not run at the time they need it (for example to get to medical appointments).

People who need door-to-door transport, for example from taxi, private hire or community transport services, often have to pay high fares, while those with less (or no) mobility impairment travel free. This is an anomaly that should be ended.

MACS suggests that Transport Scotland (driven by the NTS principles) should explore and pilot a range of ways of making travel more affordable, such as subsidising community transport costs and/or radically widening access to concessionary travel.

We acknowledge the part that new technology has to play (p25) in enhancing mobility. Many tech-savvy disabled people use apps with real time information to aid their mobility and the development of such services is to be welcomed and encouraged. However, we do not wish to see the benefits of technology overstated. Many mobility-impaired people do not have smart phones or any other access to digital services; moreover, for disabled (and indeed non-disabled) people who are anxious or who lack confidence, an essential requirement of a transport system is the presence of helpful staff.

MACS is contributing to a number of technology initiatives from ‘Mobility as a Service’ to Connected Autonomous Vehicles, but a suitable human presence throughout transport services will remain vital. This includes all stages from acquiring tickets and throughout the journey including the need to retain staffed bus and rail stations and on board assistance for rail travel.

The strategy’s attention to tackling the decline in bus services is very welcome (p27). Bus services in both rural and urban parts of Scotland are a lifeline for many disabled people, who in many cases have few if any alternative options. We welcome the recent commitment in the Programme for Government to make significant investment in bus priority and look for opportunities for this to also make bus infrastructure more accessible. We would also like to see measures to ensure that bus services which disabled people particularly rely on (perhaps indicated by high levels of use by concessionary permit holders) are protected and enhanced.

We also suggest investigating other tools which could make bus (and community transport) services more “affordable, accessible and available”; in particular to see if the Bus Service Operators Grant (BSOG) can be used better to achieve these outcomes.

We note and welcome the aspiration to ensure that transport contributes to public health (particularly in relation to active travel), and also the focus on access to hospital outpatient services set out in Figure 10 (p38). However, disabled people face particular problems in accessing healthcare, as evidenced by a recent survey by Disability Equality Scotland.

The transport barriers for disabled people booking and accessing healthcare services stretch across urban, rural and island communities and span across the availability, accessibility and affordability of our health (primary/community services, Scottish Ambulance Service, and hospital) transport, community transport and our public transport system.

The particular barriers which disabled people face in accessing healthcare demand specific attention; we see no tangible progress towards improving access to healthcare since the Audit Scotland reported on the unsatisfactory situation in its 2011 report.

This is therefore a topic which MACS will focus and advise Scottish Ministers on, over the next few years.

The strategy notes correctly that many disabled people are especially reliant on cars (as a driver or passenger) for their mobility (p40). This is important to recognise, as over the next few years more attention will inevitably focus on measures to reduce unnecessary car use, to cut congestion and improve air quality (for example, through Low Emission Zones).

Indeed, many disabled people are forced into car ownership as public transport does not meet their needs and we should recognise and acknowledge that a “fit for purpose” public transport system could eliminate forced car ownership and thus reduce congestion and costs by reducing single occupancy car journeys.

We would also draw attention to a major potential opportunity for Scotland associated with the devolution of certain social security benefits from Westminster. This may enable Scotland to develop a new form of ‘Motability scheme’, which is more accountable and responsive to service users, and offers better value for money than the current UK scheme.

This is a significant opportunity given the scale of money involved (pro rata, Scotland’s share in Motability is likely to be over £400 million per annum -more than twice all concessionary travel spending).

The particular needs of disabled people should be taken into account in discussing Active Travel (p42). The most important form of active travel for disabled people is usually walking (or wheeling) around their neighbourhood, to shops, friends, or the bus stop for example. Poor pavements or opportunities to cross the road are a problem across Scotland, which inhibits inclusive communities and active travel.

We would also draw attention to the exclusion of disabled people in many Active Travel initiatives (example: the recent e-bike initiative at the Kelpies in Falkirk failed to consider the needs of disabled people and offer any adapted e-bikes, excluding those least mobile and most in need from benefitting from the initiative thus leaving them still unable to access the improved infrastructure).

This leads us to believe that the promise of accessibility running through all Programme for Government (PfG) commitments often fails to be translated into plans and actions.

The draft strategy notes the importance of monitoring and evaluation (p58). We must be able to measure the progress in delivering the Accessible Travel Framework but also to understand disabled people’s experience of travel in the context of the 4 pillars of the National Transport Strategy (in particular the Vision for a public transport system that promotes equality and ensures disabled people have fair access to the services they need, is easy to use and accessible to all).

It is therefore essential that Scotland develops the capacity to monitor how, and how much, disabled people travel. There is currently no robust reliable baseline data at present on this, nor on how much this varies by area, and by mode. Until we have the ability to measure and monitor this over time, it will not be possible to tell if the desired outcomes are being achieved.

It is therefore important that resources are identified, which enable Indicator 2 in Appendix 2 to be reported at regular intervals.

We are interested to see the discussion on transport governance in Chapter 5. An aspect of governance, which needs to be considered, isthe extent to which diverse interests and voices contribute adequately to decision-making in transport.

Our experience is that too often, people who plan and operate transport services do not sufficiently address mobility and access considerations; this is a failure of governance. We therefore recommend that there should be a ‘champion’ for access and inclusion interests represented on the Transport Strategy Delivery Board.

Too often statutory obligations under the Equality Act and Fairer Scotland Duty are given superficial attention -or ignored completely (for example by failing to produce Equality Impact Assessments or engage with people with protected characteristics).

MACS would therefore like to see a nationally standardised Equality Impact Assessment “toolkit” and strengthened monitoring and enforcement.

This process should also ensure meaningful engagement with disabled people and/or their representatives at the concept stage of services designs or changes to service provision to ensure our transport system responds to people’s needs.

Effective involvement of disabled people in decision-making is not simply a question of representation on committees and structures, it is also about creating professional cultures at all levels (from political and non-executive levels through senior management to front-line staff), which acknowledge and understand the importance of access, inclusion and equality matters. We note that the Equality and Human Rights Commission (EHRC) has identified access to public transport by disabled people as one of its five strategic themes.

To conclude, MACS supports the Poverty and Inequality Commission’s position of a rights based approach to transport and that this should start from the principle that access to suitable transport, no matter your needs, level of income or where in Scotland you live, should be seen as a necessary requirement in order to achieve other human rights.

The present transport system does not yet deliver this level of access to transport for all.

MACS feels that although encouraging, the draft National Transport Strategy could be more ambitious and should aim to place Scotland as a world leader on accessible, affordable and available public transport.

This might be achieved by exploring the possibility of a range of ambitious pilots including free public transport for all(such as Luxembourg and Estonia) to “trigger” the behavioural changes needed to reduce the use of private cars, reduce congestion and take effective action on climate change.

We propose this in the knowledge of the impact/balance on economic viability but would draw attention to the greater potential for this initiative to tackle the climate emergency and assist with improving health and wellbeing. This call is linked to the ambition for a nation’s success to be measured against the need for all our citizen in Scotland to achieve their full potential, stay connected and support our nation to focus on inclusion and wellbeing as a measure of success.

MACS is disappointed that the Programme for Government (PfG) 2019/20 was light on accessibility and the needs of disabled people in Scotland. We understand that this provides a basis for all areas of work to have accessibility, equality and inclusion at the core but this is not always being translated into actions. Disabled people are not generally perceiving improvements in the availability and accessibility of public transport.

As such, and to support the National Transport Strategy’s commitments, we would make a call for actions to improve the accessibility of our transport system to be cited more strongly within future PfG commitments. In order to achieve the goal of ensuring transport in Scotland is accessible to all, the Delivery Plan, which will put this draft Strategy into effect, will need to include significant practical measures to turn words into actions.

Yours sincerely,
David Hunter
Planning and Strategy Workstream Co-Lead