View Consultation ‘Cycling framework for active travel’
1. Do you agree with the above statement of strategic priorities for driving the development of cycling for transport in Scotland?
MACS welcomes the vision for Active Travel in Scotland but is disappointed to note that the top priority for the achievement of that vision does not refer to wheeling – “communities are shaped around people, with walking and cycling the most popular choice for everyday short journeys”. Any reference to active travel should always include wheeling so that any policy or strategy is inclusive.
2. The diagram above sets out how the Cycling Framework is aligned to the wider policy context. Do you agree that this captures the key policy linkages and/or should any policy areas be added or removed?
MACS appreciates and recognises that there is an abundance of Scottish Government policies that could be aligned to the Cycling Framework but would offer the following – ‘Community Empowerment’ including participatory budgeting if communities are to be involved in the provision of an accessible cycling network within their areas. Other policy areas linked to the framework could include ‘Community-led Regeneration’ and ‘Town Centre Regeneration’ and the ‘Inclusive Design’ guidance (due to be published 2022) on town centres should be included so that any cycling infrastructure is inclusive from the design stage. The ‘National Walking Strategy’ should be referenced, as ‘walking and wheeling’ are the other side of the Active Travel equation.
Delivery Plan - Strategic Themes
3. Six strategic themes have been identified based on stakeholder feedback, as above. These themes illustrate the overarching approach for cycling for transport in Scotland. Do you agree with these strategic themes as priority areas for action in this framework?
MACS welcomes the equity of access to cycles and cycle opportunities as long as this equity extends to non-standard cycles and electric non-standard cycles.
MACS feels that a definition and explanation is required for the term – high quality cycling infrastructure - as this phrase may mean different things to different people / users. For example, a designer may think that a good quality piece of cycling infrastructure includes ‘floating bus stops’ which are dangerous for many disabled people.
MACS would also welcome a definition for the term ‘fair access’.
Delivery Plan - Safe Cycling Infrastructure
4. Do you have any comments on the substance of the delivery plan actions in this section?
MACS welcomes the delivery plan and the commitment to the provision of a safe cycling infrastructure – accessible and useable by all.
When working with local authorities and other partners it would be good to reinforce the correct terms of adaptive cycling – non (e) standard cycles and non-standard (e) cargo cycles. This term is the preferred term used by disabled cyclists and campaigners.
There needs to be a consistency in the design of infrastructure as there can be variations from LA to LA. In terms of the production and development of design guidance – this needs to include disabled people and disabled people’s organisations.
MACS supports active communities where all members of the community can take part if they wish. In relation to road closures this would need to take account of blue badge holders access and access in any emergency situation.
5. Do you have any comments on the agencies identified to lead and support these actions?
MACS broadly welcomes the plan, but notes the lack of any involvement of disabled people’s organisations / disabled cycling organisations and would urge that these important stakeholders are included.
It is important that cycling infrastructure does not adversely affect disabled people who don’t cycle – disabled people can be affected as pedestrians, users of public transport or as drivers / passengers of private cars. This issue does not appear to be considered sufficiently at present which can build in more barriers for disabled people, but undermine wider public support for measures to encourage cycling.
6. Do you have any other comments on this section of the delivery plan?
MACS welcomes the uses of cargo cycles for use by businesses in line with the aim of reducing car kilometres and the 20 minute neighbourhood, but has concerns about the supporting infrastructure for storage of cargo cycles. Cargo cycles are quite large and currently there are very few accessible cycle storage facilities in town centres for non-standard bikes / trikes and non-standard electric bikes etc. Where will the cargo bikes be stored by businesses when collecting goods for delivery and when not in use? – Potentially blocking the footpaths and introducing more barriers for those with low mobility and wheelchair users, e.g. some businesses do not have facilities to store rubbish bins that end up on the pavements.
Delivery Plan - Effective Resourcing
7. Do you have any comments on the substance of the delivery plan actions in this section?
MACS welcomes the increase in the active travel budget, but to date there is little evidence that past budgets have catered for disabled cyclists and ramblers with many pieces of infrastructure remaining inaccessible for many people. MACS would welcome a commitment that a certain percentage of the budget was allocated to mitigating the negative impacts picked up within the Equality Impact Assessment, which would be required for the vast majority of infrastructure projects.
8. Do you have any comments on the agencies identified to lead and support these actions?
MACS would like to see disabled people’s organisations as part of the supporting delivery partners and / or identified as key stakeholders / consultees.
9. Do you have any other comments on this section of the delivery plan?
Engagement with the potential end user is key in ensuring that any infrastructure is accessible to as many people as possible and delivery partners need to ensure that effective and meaningful engagement is carried out PRIOR to the start of any scheme design and throughout the design of the scheme.
Delivery Plan - Fair Access
10. Do you have any comments on the substance of the delivery plan actions in this section?
MACS welcomes the commitment to enable fair access to cycling by all and that infrastructure needs to be built quickly, and that everybody’s needs are accounted for at the design stage. Whilst this is welcome there is concern regarding the commitment to building infrastructure quickly – often if projects are brought on board quickly there is a lack of meaningful engagement and consultation and depending on how the design has been procured there may not be a requirement for an Equality Impact Assessment (EQIA). This is vital to ensure that as many people as possible have been considered and any negative impacts mitigated.
MACS also welcomes the expansion of the cycles through cycle share schemes which will also include non-standard cycles and non-standard electric cycles together with the supporting infrastructure to support people using these types of cycles within town centres.
The carriage of cycles on ferries should also be included.
11. Do you have any comments on the agencies identified to lead and support these actions?
MACS welcomes the plan but would again urge disabled people / disabled people’s organisations being involved in discussions around delivery and fair access.
12. Do you have any other comments on this section of the delivery plan?
MACS welcomes the plan to allow more cycles on trains and rural bus routes as long as this plan allows and encourages the safe carriage of non-standard bikes and non-standard electric bikes, as these pieces of equipment can be expensive if damaged in transit. There is a presumption that drivers will be able to assist in the loading and unloading of equipment. The carriage of cycles on rural bus transport systems will be of benefit to islanders and tourists alike. That said, often the provision on islands and rural areas is by coach rather than bus (traditionally coaches are not accessible) – great idea if adaptive bikes etc can be carried but not if the wheelchair user cannot board the coach.
MACS would also like to see engagement with Community Transport providers, so that their vehicles can also support people wishing to take non-standard and non-standard electric cycles with them on journeys including MAAS.
MACS welcomes the proposal to support cycling journeys to and from public transport hubs as part of a multi modal journey, however not at the expense of drop off / pick up areas being relocated further away from station entrances, including blue badge parking moving further away. Multi modal hubs should also include accessible secure storage.
Delivery Plan - Training and Education
13. Do you have any comments on the substance of the delivery plan actions in this section?
Meaningful community engagement is vital for this plan to succeed – proactive engagement with individuals who do not currently cycle or have not cycled in years is key. Stakeholders will need to think differently about engagement and not rely on usual responders as engagement may well be seen as tokenistic. Different forums should be approached to identify these individuals / families, e.g. local climate assemblies or net zero citizens assemblies.
14. Do you have any comments on the agencies identified to lead and support these actions?
In order to reach ‘difficult’ groups a disability umbrella organisation would be best placed to advise on engagement and perhaps provide support in this area, e.g. Disability Equality Scotland.
15. Do you have any other comments on this section of the delivery plan?
MACS welcomes the plan for training and education in the hope that more people are aware of the benefits of cycling, including using non-standard cycles in any training programme.
Delivery Plan - Network Planning
16. Do you have any comments on the substance of the delivery plan actions in this section?
MACS welcomes the approach taken to network planning and the involvement of the key stakeholders. Any strategies should have the community at the heart of the process, so that they have an input into the routes through their areas and every opportunity should be taken to engage with as many people as possible, so that any route is as accessible as it can be.
MACS welcomes the active travel digital mapping approach as long as any public interface is accessible for as many users as possible.
As many existing local strategies should be tapped into as possible including Local Development Plans and Local Outcomes Improvement Plans.
17. Do you have any comments on the agencies identified to lead and support these actions?
As previously mentioned, disabled people and disabled people’s organisations should be involved in this process.
18. Do you have any other comments on this section of the delivery plan?
Delivery Plan - Monitoring
19. Do you have any comments on the substance of the delivery plan actions in this section?
20. Do you have any comments on the agencies identified to lead and support the actions in this section?
21. Do you have any other comments on this section of the delivery plan?
Elements of the cycling framework are very much based on the Medical Model of Disability which is disappointing to read e.g. “although the Spaces for People programme was largely successful, it didn’t work for everyone, particularly those with accessibility requirements”.
MACS would argue that the Spaces for People programme built in barriers that prevented people with ‘accessibility requirements’ from accessing the area – the person(s) may have an impairment and be totally independent were it not for the introduction of barriers preventing them from going out and about as they normally would.
It was noted that the document was produced by a wide range of partners but none of these stakeholders included disabled people or disabled people’s organisations. We would recommend adopting the social model of disability.
Active Travel Transformation Project
To what extent do you agree with the following statements:
22. For large infrastructure projects, conditions of funding should be delivery on agreed targets for: timescales, expenditure and meeting project objectives.
23. In order to ensure maximum value for money and impact, active travel funding in the short term should be prioritised for those local authorities with the greatest capacity to deliver, with capacity building support offered to those with the least.
This approach may leave some rural areas and smaller local authorities without the benefit of any infrastructure improvements being undertaken for many years. Active travel can incorporate walking, cycling and wheeling, but may just be infrastructure improvements to improve existing routes by removing barriers which would help many disabled people to get out and about.
All local authorities have capacity to improve pedestrian space – for example as set out in our guidance – Small Changes can make a Big Difference. It would therefore be quite wrong to favour some local authorities over others with regard to the distribution of active travel funding.
For information – MACS are currently conducting on a piece of work in relation to Local Authority bike hire schemes with results from a questionnaire due in the new year 2023. MACS would be happy to discuss the outcome of this survey in relation to provision and accessibility.
24. Future funding for active travel infrastructure should include a mechanism for re-distributing investment from local authorities unable to deliver to agreed standards and timescales.
Neither Agree or Disagree
22. Do you have any comments on the draft Social and Equalities Impact Assessment?
The Equality Impact Assessment fails to adequately recognise that some cycling facilities can have a negative effect on some disabled people. Examples of some of the barriers include additional pavement clutter that can be difficult to detect and or manoeuvre around, ‘bus stop bypasses or boarders’ which put some disabled people in the path of cyclists whilst trying to get on or off buses, shared spaces where some disabled people have no traditional physical guidance (e.g. pavements, controlled crossings) to know what areas they are on. Often cycle lanes replace accessible car parking provision for blue badge holders.
The Impact Assessment should explicitly recognise these negative impacts so that they can be addressed, acknowledged and mitigated. The promotion of cycling should not have a negative impact on some disabled people’s ability to navigate their local areas.
23. Do you have any comments on the draft Business Regulatory Impact Assessment?
24. Do you have any comments on the draft Island Communities Impact Assessment?