MACS Response to the Fair Fares Review Report - April 2024
First Impressions
On first impressions, MACS are concerned that the Fair Fares Review is lacking in ambition or innovative thinking on proposals or potential tailored approaches.
MACS are disappointed that many of their proposals were not picked up, for example, taxis as part of Demand Responsive Transport appears to have been overlooked. It is important to note that taxis are used by disabled people twice as much as non-disabled people.
MACS called for the Fair Fares Review to include a national Taxicard scheme to end the current ‘postcode lottery’, likewise assistance with the cost of community transport. Disabled people strongly rely on community transport in the absence of accessible and affordable public transport, particularly in accessing healthcare.
MACS are unconvinced by the inference of making public transport more affordable (or appear more affordable) by making travel by car cost more. Many disabled people rely on their car as a mobility aid and many people who live in areas not well served by public transport (routes, timetables, frequency, journey lengths/time) are forced into car ownership. Whilst MACS understand the need for a Just Transition, it is crucial that the needs of disabled people are considered.
MACS feel that the tone of the report alluded that people were “relieved and/or thankful” that they had held onto some of the supports/concessions they had fought hard to get, such as being able to use concessions to travel at any time and no introduction of flat rates. MACS believe that we should be looking for progress, not battling to retain a status quo.
Points Welcomed by MACS
MACS welcome the reference to a public transport journey being an active travel journey. We have been messaging on the need for this to be recognised for several years. This links to the need for improved pedestrian infrastructure, improved ‘first and last mile’ and intermodal connections.
MACS also welcome the expectation that ScotRail and CalMac will develop a partnership agreement that will deliver several benefits for passengers, including joint timetable development and exploring a future digital solution for ‘Rail & Sail’ tickets and improved collaborative working, especially during disruption.
MACS welcome the intent to recommend/introduce a Transport Governance Review with specific action on identifying changes to support improved public transport, however, we are yet to be convinced of its impact.
We further welcome the intent to consider establishing a National Forum on the Future of Public Transport, to coordinate the improvement of the delivery of a quality, accessible, available, and affordable (AAA) integrated public transport system.
We also welcome the intent to consider, based on evidence from the current Deck Space Reservation pilot project, whether a different approach to releasing vehicle space for booking will better facilitate island essential travel. This should allow greater opportunity for island communities and those who are required to travel at shorter notice and links to one of our asks around Transport to Health and Social Care.
MACS welcome the decision not to introduce financial means testing for access to National Concessionary Travel Schemes and the decision not to introduce the removal of concessionary travel at peak times, nor the introduction of flat fares into the concessionary travel scheme.
The introduction or reintroduction of means testing, peak time travel, and flat fares would have sent a very concerning message – but MACS are not convinced that celebrating retaining hard-won support measures equates to progress.
MACS Scrutiny Remit
Page 4
“We recognise that to achieve this, the cost of motoring relative to public transport needs to be addressed. The forthcoming route map to 20% car kilometre reduction will aim to set out our approach to support this objective.”
Question: Does this mean rather than reducing the cost of public transport, the aim is to further increase the cost to travel by car?
If so, how do MACS work to prevent increased travel costs for those whose travel by car is essential such as disabled people and people in areas not well served by public transport? It is worth noting that increasing costs to travel by car will also increase the cost of taxis, heavily relied on by disabled people.
Our work around a Just Transition needs to pick this up, as well as in our further engagements on the 20% car kilometre reduction strategy.
Page 4
“It is also important that we recalibrate government funding to better target priority groups and increase accessibility to our public transport services. However, we have limited room for manoeuvre given the extent of funding required to maintain the safe and efficient operation of our networks amidst the challenging fiscal climate.”
Question: The only section in the Ministerial Foreword which states ‘however’ - potentially meaning not prioritised or will not be tackled - is unsurprisingly on accessibility. Should accessibility have been improved/funded before widening concessionary travel to other groups? What should have the priority here?
Page 5
“The recommendations and actions of the Review build on these to set out a pathway towards a public transport system which is financially sustainable in the long term, and which provides affordable, frequent, and integrated services that are responsive to the needs of people and communities across Scotland, improving accessibility to employment, services and activities for lower-income households.”
Observation: MACS understands this as that the improved accessibility is more to do with availability (routes, times, reliability) and has missed the mark around actual accessibility - making the most accessible modes affordable for disabled people (trains, trams). One of the reasons for not extending the concessionary travel to trains/trams is that it would reduce bus patronage. MACS feel that it has been overlooked that this may change behavior and a switch from car to train/tram rather than bus to train. MACS also laid out the benefits to disabled people of shorter, more direct train journeys (over longer bus routes) in managing pain, companion/carer time, and traveling with mobility aids (easier by train/tram) but this has not been picked up.
Later in the review, it covers accessibility again but in a vague way with no actions or what accessible will look or feel like, be measured, other than the recommendation that it “will enable” it to happen. MACS feel that this is therefore not substantive.
Page 15
Question: MACS are pleased to have been mentioned, but as many of our asks/proposals were ruled out, will this infer our agreement on Annex A - Options not being progressed?
Page 16
“The section on the final element of the Review relates to work that has been undertaken to identify and develop potential Pathfinder Pilot schemes that take action on the cost and availability of public transport services, specifically by meeting a number of the following objectives:
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Lower the cost of transport on a targeted basis for specific lower-income groups.
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Address rail fares anomalies.
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Test alternative fares structures that reflect the changed patterns in public transport usage since the onset of the Covid-19 pandemic.
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Address ferry fares anomalies and make more efficient use of vehicle deck capacity on the busiest routes at peak times.
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Enable multi-modal journeys to be made more seamlessly between different modes/operators without financial penalty to the passenger.
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Simplify and cap single journey fares across modes.
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Demonstrate a more targeted approach to concessionary travel schemes.
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Reduce the cost to operators of providing public transport services and where such reductions in costs can be repurposed to either the taxpayer and/or passenger.
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Address gaps in the existing public transport network that inhibit communities` access to jobs, education, public services, retail, and social and leisure opportunities.”
Question: How will it enable modal shift and make journeys more seamless between different modes if there are no concrete actions in the review with proposed measures to show the shifts?
In reference to ‘Demonstrate a more targeted approach to concessionary travel schemes,’ MACS see no consideration of increasing the concessionary age from 60) now that retirement has been raised to 67. MACS also do not see the extension of concessionary travel to Taxicard schemes and community transport in areas where bus services provision is poor, not accessible, or non-existent.
MACS propose that concessions could be on retirement - not whilst still earning (excluding low incomes). This may also be the driver for the increase in concessionary travel for older people (still commuting but now as a concession rather than paying passenger - adding to the reduction through the fare box and increase in over 60 concession).
MACS had suggested that in a tight fiscal framework with many people between 60 and 67 eligible for concessionary travel but still work with earnings not in the low-income bracket - should we explore/reassess the age eligibility at the top end other end?
In reference to ‘Address gaps in the existing public transport network,’ MACS would be interested in hearing more about this – how, when, etc.
Page 22
“The m.connect app delivered by Moray Council enables the successful provision of demand responsive bus services across the council area.”
Observation: MACS’ understanding is that the m.connect scheme does not allow the use of concessionary travel and as it is online only, excludes those not aware of/confident in using apps leading to digital exclusion. Whilst MACS believe that this is a good initiative, we are concerned that both these issues (concessions/online only) widen the inequality gap rather than reduce it.
Page 25
“SPT has also modernised Subway concessionary travel. Concessionary passengers are eligible for a reduced fare and previously were required to purchase a discounted paper ticket.”
Point to Note: Only 2 of the 15 stations on the subway are wheelchair accessible and this issue is not addressed in the millions spent on station refurbs.
Annex A: Options Not Being Considered
MACS believes that for some of the assessments/appraisals to be ruled out may have been based on an “all or nothing” approach rather than a hybrid/modified/targeted solution that could work to develop the proposal.
Option 1 - Universal expansion of NCTS to rail, light rail, and ferry for those groups eligible for the existing NCTS.
Rationale for not progressing: Whilst this option scores well on most criteria it is a relatively untargeted policy measure to achieve government outcomes.
Question: So how do we target it rather than scrap it?
Option 4 - Expanding concessions to community transport
Rationale for not progressing: In relation to community transport specifically, services are often not open to the general public, and many do not charge a “fare” in the traditional sense.
Observation: MACS believe this does not consider the reliance disabled people have on Community Transport due to other modes of transport not being available, accessible, or affordable and having to pay when they are eligible for concessionary travel.
This scenario creates an inequality with the concessionary travel scheme as some people cannot benefit due to a lack of public transport. This was picked up briefly in the report as we have been raising this for some time.
Option 9 - Expand coverage of NCTS to include rail, for all disabled cardholders
Rationale for not progressing: This proposal would also likely provoke calls to extend free rail travel to all eligible NCTS cardholders such as over 60’s and would further increase the proportion of the population who qualify for free rail & bus travel.
Question: Why not pilot for disabled people and assess the outcome (i.e., potential modal shift from car to rail)?