Summary of responses

Responses to the BRIA were received through Citizen Space, email and one-to-one discussions. At the close of consultation, seven responses relating to the BRIA were received from:

British Ports Association (BPA)
Confederation of Passenger Transport (CPT)
Logistics UK
Perth and Kinross Council
Scottish Chambers of Commerce
Tactran

One further response was received from an organisation which chose not to be named.

Several consultees highlighted the need for a more coordinated approach across TS departments and timescales. Highlighting that the delivery plan should tie-in to other strategies and governance structures more clearly. The Scottish Chambers of Commerce specifically commented that:

“It is likely that longer-term strategic issues will be picked up by the STPR2, however, given the NTS2 Delivery plan operates over the shorter-term, it should be bolder in its approach to tackling these issues.”

The potentially inadequate level of government support necessary to deliver on the ambition of NTS2 was an issue raised by respondents. The BPA drew attention to this in relation to freight exports:

“Without major investment or regulatory stimulus policies won’t have a big impact.”

The sufficiency of government support levels was particularly prominent in relation to the importance of COVID-19 recovery measures. The Scottish Chambers of Commerce highlighted recovery from the pandemic as a key issue, which was considered to not be fully addressed by the Delivery Plan, stating that:

“Our overarching response to the Delivery Plan is that it fails to fully recognise the magnitude of the post-pandemic landscape and many of the policies outlined seem to respond to a business-as-usual situation, rather than the one we find ourselves in currently. From a business perspective, recovery from the pandemic is of the highest priority at present.”

The CPT also raised concern in relation to bus operators re-establishing market share in the aftermath of the COVID-19 pandemic whist also decarbonising their fleet operations:

“The ability of operators to meet other government aims such as the decarbonisation of the bus fleet will depend not only on the quantum of continued additional support but on the flexibility within that support to enable operators to fund the investment needed to accelerate fleet renewal.”

The impact on local authorities of not having the resource available to implement actions within the Delivery Plan was raised several times, including by the CPT, who stated that:

“there will be an impact for local authorities as they do not currently have the resource to pursue bus franchising options.”

Tactran also raised this issue, stating that:

“Without additional resources, it remains uncertain whether Local Authorities and their Regional partners will have the ability to adequately resource the delivery of NTS2.”

Other frequent comments drew attention to the importance of recognising wider UK interdependency, particularly in relation to freight logistics and decarbonisation of aviation. Logistics UK commented that:

“A huge proportion of the goods leaving Scotland for non- UK destinations are moved by ships and planes which leave from England. The most significant airport for the Scottish supply chain is Heathrow, and the most significant ports are the English southern ports (Felixstowe, London Gateway, Southampton, and Dover).”

Potentially overburdensome requirements was raised in relation to bus franchising and fleet decarbonisation, with the specific needs of rural bus operators being of particular concern in this respect. To this effect, the CPT commented that:

“Forcing compliance will counterintuitively lead to businesses either striving to afford new vehicles by increasing fares and reducing services or will lead to business closures”

The role of the planning system was raised as a potential barrier to implementation of the 20-minute neighbourhood concept, with Logistics UK urging that planning policy:

“accounts for and fully value logistics when considering housing and other development proposals.”

The Scottish Chamber of Commerce asserted that the planning system had a role to play in responding to changing behaviours whilst also keeping traditional centres alive, stating:

“The 20-minute neighbourhood concept is likely to favour those in urban areas with access to shops and services but be irrelevant for those operating in rural communities. The NTS2 Delivery Plan could therefore do more to promote travel to and from town and city centres.”

With changing behaviours around shopping, home deliveries and the role of town centres as commercial and social hubs, a potential impact on small firms was identified, which is not fully recognised in the Delivery Plan. One community organisation who responded to the consultation, articulated this concern:

“the cost of implementing and maintaining digital solutions can be a financial burden for many smaller bus operators and the benefits for their area of operation may not outweigh the costs.”

On occasions where government funding or a support payment was considered, the potential for subsidy control implications was raised, especially in relation to the impact on incumbent operators of externally funded market entrants. The BPO commented specifically that:

“Grant funding may be good for market entrants but bad for the incumbent, who may have invested heavily to get where they are.”

The ability of the market to respond to the requirements of NTS2 in relation to freight modal shift was raised in relation to changing consumer patterns, with the Scottish Chambers of Commerce stating that:

“The concept of ‘reverse logistics’ should be explored along with the altered role of city centre retail spaces as showrooms, offering a consumer experience and encouraging use of town and city centres while also offering deliveries which can be consolidated into fewer trips overall.”

it was highlighted that procurement methods should be closely considered when planning for electric car charging infrastructure, in order to ensure fair competition, with Tactran stating that:

“Targeted interventions are required to kickstart more investment and unlock competition, particularly in remote areas, where the commercial case for investment is weak, which means there’s a risk these will be left unserved and in on-street charging where roll-out is slow and local monopolies could arise if the market is left unchecked.”

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