Mobility and Access Committee for Scotland (MACS) Response to Transport Scotland’s consultation on the Strategic Transport Projects Review (STPR2) - April 2022

Read the consultation on the Strategic Transport Projects Review (STPR2).

A: Introduction

The Mobility and Access Committee for Scotland welcomes the opportunity to respond to the consultation on the STPR2. We believe that the 45 measures proposed have significant potential for improving accessibility, as well as meeting other key transport goals. Access and inclusion are central to a ‘just transition’ and also to achieving the key objectives closely aligned with the priorities in NTS2, notably ‘reducing inequalities’.

Our response is in three sections. After this short introduction, we comment on the specific STPR2 recommendations, focussing especially on those which we see as having the greatest impacts on accessibility and inclusion, in line with our statutory remit. We conclude with some brief comments on the STPR2 process and next steps.

There are of course, a huge range of personal mobility preferences among disabled people. Physical barriers to travel caused by unsuitable infrastructure are unfortunately prevalent in all areas of transport, but access problems are often also caused by inadequate systems for communications, information or staff support. It is essential to take into account not only physical barriers, but also obstacles to mobility faced by people with sensory or intellectual impairments. Good design of transport systems will benefit everyone: the principle of ‘inclusive design’.

In assessing the scope for measures to improve accessibility for disabled people, we would like to see due prominence given to how disabled people currently travel. This is evidenced in Disability and Transport and also several UK publications which all point to similar travel patterns. Disabled people travel less than non-disabled people, and less far: a key aim for MACS is to support initiatives to close this ‘mobility gap.

The evidence from such research is clear that overall, the modes most commonly used by disabled people are private car (especially as a passenger), bus and walk/wheel. In addition, taxis and community transport are used more than by non-disabled people. Disabled people tend to use rail and cycling significantly less, although there is clearly potential to increase their use by disabled people by removing barriers and increasing accessibility options (read an example on interest in adaptive bike sharing). It is essential that all modes of transport are inclusive, but it is likely that overall, disabled people will benefit more from investment in those modes which they use most.

We hope that this response will influence the further development of the STPR2 process, so that the detailed business cases for each component explore these opportunities in greater depth.

B: Comments on selected STPR2 priorities

The comments below are grouped by the six themes (in bold) and numbered recommendations as set out in the STPR2 summary document.

Improving Active Travel Infrastructure (1-5)

1: Connected Neighbourhoods

MACS has been active in advocating the ’20 minute neighbourhood’ concept, for example through a series of events with the Health and Social Care Alliance and Disability Equality Scotland.

We therefore welcome the emphasis on connected localities which we believe could be one of the most significant of all the STPR2 recommendations, so long as it is backed up with interventions to remove barriers to pedestrians and to make local areas more inclusive. Designing services and facilities that are close to people’s home has considerable potential to make communities more inclusive and accessible for disabled people - and everyone else - as well as contributing to environmental objectives and the Scottish Governments drive to reduce social isolation and loneliness. The STPR2 is an opportunity to address this legacy of poor access in public spaces, but the enormous scale this task (not least in terms of budgets and timescales) needs to be recognised.

All over Scotland, the pedestrian environment is often inaccessible to disabled people. 94% of people responding to a poll on 20 Minute Neighbourhoods by Disability Equality Scotland in 2020 said that they currently cannot access local services in this time. Major barriers reported were issues associated with the accessibility of the local pedestrian environment (quality of footways, obstructions, pavement parking, etc). In addition, crossing the road is often a major problem for disabled people: many pedestrian crossings and traffic signals make people wait too long to cross the road and/or give too little time for the pedestrian to cross.

The implications of ‘connected neighbourhoods’ in rural and island areas need further careful consideration. For example the journey between villages or a village and surrounding amenities should also be reflected in the dialogue. The challenges of walking, wheeling or cycling on a minor road can be no less difficult than on an urban trunk road.

2: Active Freeways/Cycle parking hubs

We would welcome greater clarity on what the ‘Active Freeway’ concept means. We understand from the STPR2 documentation that these will principally be urban radial routes which are principally envisaged as quick commuter routes for cyclists and potentially e-scooters, mobility scooters etc. In such case ‘shared use’ cycle/walk design, which is widely recognised as hostile for many disabled people (including people with visual or hearing impairments) needs careful thought. Shared use paths are generally contrary to current design principles (as advocated for example by Sustrans, Cycling by Design etc.) in urban environments.

These facilities will be helpful for disabled people who use a cycle as mobility aid but are unlikely to greatly enhance pedestrian mobility. Measures to ensure that they are inclusive may include provision of places to rest for people out walking, as well as the proximity and accessibility of toilets. Routes should not be solely designed for the cyclist who wants to travel 20-30 miles.

3-5: Other active travel interventions

The STPR2 is right to note that investment in long distance active travel networks etc can open up opportunities for disabled people who cycle, or who would like to cycle. This should be complemented by ensuring the wider availability of cycles which disabled people can use, for example through shared bike and hire schemes.

Influencing Travel Choices and Behaviours (6-10)

It is essential to recognise that not every person has the same opportunity to change travel choices and behaviours. Many disabled people are very reliant on private cars for travel (as a passenger or driver). This is evident from the Disability and Transport study 2021, Transport Scotland) and a point which MACS has emphasised in relation to the specific ambition to reduce private car km by 20% by 2030. Communication around behaviour change initiatives also needs to be careful to consider how messages will be received by disabled people - exhortation to use alternatives to private car will not be well received by people who are excluded from alternatives because they are inaccessible to them and who are therefore dependent on cars for their mobility.

Two things are needed in order to ensure that this themes is inclusive of disabled people:

Firstly, alternative travel options must be accessible. This means removing barriers which currently hinder disabled people. Examples of what this means in practice include:

ensuring that rural bus services which do not have to meet PSVAR conditions are replaced by more accessible vehicles
repairing or widening inadequate neighbourhood pavements
making available non standard bikes in hire/share schemes
removing barriers at stations, ports and other infrastructure

Such measures can enable disabled people to contribute (and feel involved in) the collective switch away from dependence on the private car.

Secondly, for those disabled people who cannot make such switches, measures need to ensure that disabled people who continue to rely on private cars are able to do so.

Enhancing Access to affordable public transport (11-23)

11-13: UrbanMass/Rapid Transit Networks

We welcome investment in these networks, which have major potential to raise the bar in terms of public transport accessibility, amongst other benefits: this could be more explicitly stated in STPR2, and developed further during development of subsequent business cases. Improving transport equity will require them to be affordable as well as accessible. We note for example that the use of NEC cards on the Edinburgh tram - perhaps the most accessible public transport service in Scotland - is currently restricted to Edinburgh residents alone; while non-Edinburgh residents can use NEC cards on Edinburgh bus services.

We would also point to the Glasgow subway and rail systems which many disabled people and people with poor mobility are currently excluded from, as most of the stations are not accessible. It is essential that new mass transport systems meet the highest standards of access - a consideration which will be especially important in option appraisal if using existing track. We assume that this is the expectation, but would welcome this to be stated explicitly. It is also crucial that there is investment in the accessibility of existing urban transport networks, as well as of new facilities. We need to avoid a ‘two-tier’ system where a small number of flagship mass transport schemes lie incongruously beside a network of old, inaccessible and generally poor quality public transport services.

We recognise the integration benefits of mass transport systems being capable of carrying bicycles, trikes etc (as well as mobility scooters). We would however caution that design of vehicles and services needs to ensure that there are not unintended adverse impacts, for example from people boarding vehicles with bikes, or occupying wheelchair spaces etc.

14: Strategic Bus Priority measures

Disabled people tend to be more reliant on buses than the rest of the population (see Disability and Transport, 2021). Investment in bus priority measures should therefore significantly improve mobility for disabled people, especially if associated, as we would advocate, by investment in quality bus infrastructure, such as seats, shelters and information resources. Improved punctuality - and frequency - resulting in reduced waiting times and journey times on the bus itself, will disproportionately benefit disabled people, who are more likely to experience pain, discomfort or anxiety. In this context, we would disagree with the statement in the EqIA document that level boarding and other measures to improve access “could be a slight beneficial impact” (p21): we see this initiative as potentially having a major beneficial impact.

18: Supporting integrated journeys at ferry terminals

We fully support this recommendation, which along with other improvements to interchanges (see 21/22 below) has significant potential to improve accessibility and joined up journey planning. Improving access (not only physical, but also ensuring the interchange processes are as simple, intuitive and easy as possible) should be a key objective of investment in terminals. We suggest that the commitment to consider the accessibility of onward journeys highlighted in Recommendation 19 for railways stations is matched by a similar commitment to consider systematically the accessibility of onward connections at ferry terminals.

19: Infrastructure to provide access all at railway stations

Although disabled people currently travel less by train than non-disabled people do, this aim naturally has great potential to improve the mobility of disabled people. Many Scottish (and UK) railway stations have very poor physical access: for example, into the station itself, from platform to train, between platforms, and in the vicinity of the station. We particularly welcome the recognition that onward journeys from railways stations by bus and taxi are important issues as interchanges can present a particular problem for many disabled people. We would also particularly wish to highlight the importance of the onward journey on foot or by wheeling, as well as bus and taxi (and, where appropriate, by ferry).

The Department of Transport has commissioned an accessibility audit of all UK stations including all Scottish stations. We agree that this should inform decisions on where investment is most needed, taking account of costs and benefits (including levels of passenger use). We will be looking for Great British Railways to commit to a timetable to bring every Scottish station up to a minimum accessibility standard by an appropriate date.

We are unsure what is in mind by the reference to the “potential for new technology” to improve safety and access at railway stations and would be keen to see further information on what is envisaged. However we would also wish to highlight the crucial role that people play in accessibility - helpful, well trained staff are so often the key to making inclusive, joined up journeys and making people feel safe. While we appreciate that this is outside the scope of STPR2, it is important to emphasise that technology is not always the most effective investment. This message came through strongly in the consultation on closing some ticket offices in Scotland.

20: Investment in Demand Responsive Transport and Mobility as a Service

We support this recommendation, but believe that it should also embrace taxi and community transport services. These forms of travel are heavily used by disabled people, many of whom need door-to-door travel. We consider that the emphasis on ‘smart technologies’ is over-stated; while there is certainly scope for more user-friendly digital innovation, the most basic need is for good quality vehicles and well-trained helpful staff. While we appreciate that some of this is outwith the scope of STPR2, the concept of DRT must be widened to include taxi, private hire and community transport, and to explore how they could meet passenger needs, especially disabled people. The study by SEStran in 2019 on DRT services is a useful reference document for this. We also need to ensure that accessibility is built into MaaS systems - including the accessibility of apps and web interfaces and also fares (such as ensuring that concessionary entitlements apply appropriately). This warrants particular investigation as part of the forthcoming ‘Fair Fares’ initiative.

21/22: Interchanges and Mobility Hubs

As noted above in connection with ferry ports (#18), seamless, easy to use interchanges can make travel much more accessible for disabled people - not only in connection with physical proximity of modes, but in terms of intuitive layouts, good signage, joined up information and staff support etc. We are not entirely clear on the distinction made between a ‘transport interchange’ and a ‘mobility hub’ - nor are we clear from the document that such a distinction is helpful. We therefore suggest that these two recommendations (#21 and #22) are merged, and also expanded to include key bus stops, where shelters, seating and information should be available. There is a case for also merging a number of other recommendations (#18 ferry terminals, #42 Investment in port infrastructure and #43 major station masterplans) into a widened ‘interchange’ recommendation, given that ferry ports and railway stations are by definition multi-modal transport hubs.

We suggest also giving special attention to the need for more good quality and accessible toilets at interchanges, which can make an otherwise inaccessible journey feasible for some disabled (and non-disabled) people. These should be ‘Changing Places’ toilets at the busiest locations.

23: Smart integrated ticketing

This recommendation has potential to make journeys easier, cheaper and more straightforward for many people, which can bring significant benefits in terms of accessibility. Careful attention must be given to digital accessibility, with appropriate investment in user testing, not only for technical reasons, but for usability, including among people who have particular communication needs (visual, hearing), intellectual impairments (eg dementia), etc.

Decarbonising transport (24-28)

For most of these recommendations, the chief impact on transport accessibility will be providing opportunities to introduce new vehicles and ferries which should meet best possible accessibility standards. (We would welcome explicit assurance that this will be the case). It will be important to understand the impact of new fuel systems on vehicle design, for example, if hydrogen systems are introduced on buses, how they might affect key aspects such as vehicle door widths and floor height. The access standards for public transport (PSVAR) are old and will shortly be reviewed - it will not be sufficient simply to comply with 20 year old PSVAR rules.

Recommendation 28 (Zero Emission Vehicles) has a whole host of accessibility dimensions which need to be explored in further detail, especially in view of the commitment to end the sale of new petrol and diesel vehicles by 2030. These include the ability of disabled people to afford switching to EV vehicles, given the known correlation between poverty and disability. The Scottish Government’s Accessible Vehicles and Equipment Scheme could have a key role here. Other aspects include the distribution and availability of EV charging facilities, the physical accessibility of EV charging points and the impacts of EV charging on pedestrian areas (potential additional pavement clutter).

Increasing safety and resilience (29-38)

While there may be few direct implications of these measures on accessibility, it is worth emphasising that disabled people will be especially affected by fragile transport systems, whether by road, rail or ferry. For example, disruption because of landslips at the Rest and Be Thankful or the cancellation of a ferry, can be problematic in terms of toilet facilities, control of pain, medication/care timings and anxiety as well as the inconvenience in terms of time. Disabled people very often need to plan journeys much more carefully the non-disabled people and therefore disruption to plans often has disproportionate negative impacts.

However, we note that the case is made in a number of places, both here and in the ‘Strengthening Strategic Connections’ section for potentially significant new investment in trunk roads and associated infrastructure, including new fixed links, carriageway widening, route re-alignment, etc. We would have to question whether such investment should be prioritised, considering the scale of the task needed to achieve other goals - not least the need for major investment in everyday walking and wheeling noted above with regard to No 1 (Connected Neighbourhoods). We would generally favour prioritising practical, high-use improvements over expensive ‘flagship’ infrastructure projects.

Strengthening Strategic Connections (39-45)

Many points made above with regard to interchanges and railways stations apply to these recommendations. We would advocate that major station masterplans adopt an inclusive approach with stakeholders involved at the earliest possible stage in the process including disabled travellers to maximise accessibility and simple, user-friendly interchange to other modes. Similarly, simple, easy interchange at ferry ports is vital to facilitate accessible journeys. Investment in port infrastructure (#42) needs to go hand in hand with investment in ferries (Recommendation 24). This is a long overdue commitment to improve the ferry services to islands and will support the emerging Island Connectivity Plan.

C) Comments on the STPR2 process and Conclusions

The STPR2 process is a necessarily complex one. However, at the end of the day, it is a question of deciding priorities. We would hope that future stages of the process are made as simple, accessible and transparent as possible, so that engagement in future decision-making is as appealing as possible to a wide audience.

Clearly, considerable work is needed to turn the finalised recommendations of the STPR into tangible, costed projects before they can be put into effect. We would like to see accessibility benefits given significant weighting in the process of selecting priorities and allocating budgets. We hope that our comments in this document can contribute to that process.

We have carefully considered the STPR2 Equality Impact Assessment prepared by Jacobs and AECOM for Transport Scotland. This contains some useful observations, many of which we would agree with although some of the assessments are open to question. Crucially however, we believe that the EqIA process resulting in this document and its ‘Further Considerations’ are inadequate. We do not see any evidence that people with protected characteristics have been involved in making the judgements on the 45 recommendations. Rather, a ‘desk exercise’ seems to have been undertaken to make judgements, apparently with little or no involvement of people with protected characteristics themselves.

Moreover, under ‘Further Developments’, the development of detailed EqIAs is envisaged on similar lines: ‘collecting evidence’, assembling ‘demographic baseline information’, etc. The statement that it should “where possible include appropriate engagement with protected characteristic groups to understand specific requirements” is completely inadequate. This engagement is a fundamental requirement which needs to take place before decisions are made.

One aspect of the STPR2 process which we would welcome greater clarity on is in the relationship between Scottish Government/Transport Scotland budgets and those of local authorities. We note that local roads are deemed ‘out of scope’ (alongside other significant areas, such as aviation). However, the powers to deliver on many of the STPR2 draft recommendations - and many of those which have the greatest implications for disabled people, and potential to improve accessibility - lie with local authorities. For example the investment in footways, road crossings etc. needed to achieve inclusive connected neighbourhoods (#1) or to encourage active travel to school (#8) require investment in local roads by councils. We would like to understand how local authorities will be supported so that they can deliver the strategic aims set out in STPR2 at a local and neighbourhood level.

In conclusion, we would especially wish to highlight:

We welcome the preparation of a long-term plan for investment in transport. As the STPR2 is refined into more specific plans and budgets, we encourage significant weight being given to options which enhance accessibility and inclusion. These should be as central to investment decisions as carbon reduction goals, so that the ‘just transition’ includes everyone.
We generally favour a focus on remedying the huge, persistent problems of ‘everyday mobility’, rather than on major infrastructure projects which we believe will be more effective in achieving the desired goals.
We wish to see the greatest possible focus on a ‘joined-up’ approach to journeys, so that travel is as seamless as possible, not only physically, but taking account of information, communications, the role of staff etc. These elements must be considered alongside capital investment decisions, in order to anticipate their real-world effect.
We want to see closer involvement of people with lived experience in the next steps of decision-making, rather than relying wholly on analytical exercises, so that disabled people feel - and are! - involved in the transition to Scotland’s low-carbon, inclusive transport system.