Appendix B - Consultation responses and actions
Name/Organisation
Withheld
Comment/Feedback
I fear they will be used by bad actors to frustrate and delay the process as with CCWEL. Mechanisms must be put in place to not allow a handful of spurious objections to derail progress for the many
Actions
Adequate provision for consultation and input into active travel projects, in line with Scottish Government guidance, has been referenced in order to ensure opportunity to gather a balance of opinions.
Name/Organisation
Withheld
Comment/Feedback
It has proved to be a great mode of public transport in more advanced countries, delivering benefits to social aspect of life, health in all forms , local finance , happiness levels , crime reduction and so on. Stop the bureaucracy, deliver quality active infra ASAP & of a good, smooth, quality
Actions
Further details of the evidence for cycling interventions are contained within the SEQIA and the final Cycling Framework and delivery plan will set out the priorities for investment over the next 5-10 years.
Name/Organisation
Withheld
Comment/Feedback
Too much focus on cycling and not enough focus on disabled access and the right infrastructure to support their travel. Let’s get disabled people more easily to their work or holidays and, in turn, that should also benefit cyclists and other road users.
Actions
Access to adaptive bikes is referred to under the theme of 'Fair Access' and further scrutiny of all policies in regard to disabled access is incorporated into the SEQIA.
Name/Organisation
Jon Jewitt
Comment/Feedback
Why do we need an impact assessment when we know what the impact would be. Look at the Netherlands...! Just look at what they have achieved and copy them. Don't spend half the budget on thinking about what we need to do. Just do it. Spend the money on the ground, not glossy brochures.
Actions
Purpose and rationale for the BRIA is contained in Section 1.3.
Name/Organisation
Daniel Trotter
Comment/Feedback
Be wary of unfounded opinions about active travel infrastructure having a negative impact on business. The opposite has been shown the case from studies conducted worldwide
SEE https://www.highstreetstaskforce.org.uk/resources/details/?id=07ec60d8-8884-4859-ad49-f2ade6bd8972
Actions
The assessment relates to the possible impacts of removing or truncating the TRO/ETRO process, rather than the implementation of cycle friendly infrastructure which, as commented, may have positive impacts on businesses. Positive impacts of cycling on businesses are noted in the assessment as follows: "Cycling Framework are expected to have a broadly positive impact on business, by encouraging local journeys to small retailers and the high-street, as opposed to out of town shopping centres, which are more easily accessed by car. "
Name/Organisation
Withheld
Comment/Feedback
I fear more businesses will suffer and the moment looks like it’s about money building exercises with fresh air being thrown in
Actions
Potential negative impacts on businesses are noted in the assessment: "Some businesses, sectors, markets, products or services may be affected by the infrastructure provision for active travel if, for example, it removes space for other travel modes (adverse effect) or improves access for a wider range of employees and consumers (positive effect). Micro and small businesses may be more vulnerable to any potential adverse effects."
Name/Organisation
Withheld
Comment/Feedback
Clearly a biased report not grounded in reality and taking inspiration from areas with climates more suited to cycling
Actions
Evidence gathered to support the assessment, and reference within the assessment table, are UK-based and, wherever available, specific to Scotland.
Name/Organisation
Withheld
Comment/Feedback
I hope that these will not place additional regulations on businesses to make them more expensive to run and that customers are able to access businesses with a car. Especially disabled drivers.
Actions
Potential negative impacts on businesses are noted in the assessment: "Some businesses, sectors, markets, products or services may be affected by the infrastructure provision for active travel if, for example, it removes space for other travel modes (adverse effect) or improves access for a wider range of employees and consumers (positive effect). Micro and small businesses may be more vulnerable to any potential adverse effects." Potential impacts on disabled drivers have been assessed as part of the SEQIA.
Name/Organisation
Withheld
Comment/Feedback
This illustrates the problem of throwing money at random infrastructure projects without considering how they link together. It would be considered crazy to build isolated stretches of a few hundred metres of motorway, yet until very very recently that's precisely what has been done with most cycle infrastructure. I am tentatively hopeful for the developing/planned network in Glasgow with the South City Way, Garscube Road, St Georges Road, Woodlands, Byres Road, Queen Margaret Drive etc, but that's still far from being completed and it's that kind of large scale integrated design that should be the goal for new development.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
Minor negative effects identified in CI.6, CI.8 & CI.11, again relating to reduced opportunity for consultation and engagement; how will these be mitigated?
FA.3 relating to smaller private, rural and island bus operators accessing funding to meet additional requirements also has a minor negative effect which could be a major effect if if affects the viability of already marginal services. Any funding available must be straightforward to access and any requirement to carry cycles must be developed in collaboration with operators.
TE.5 relating to alternatives to school bus; in rural areas free school transport is not usually provided within 1.5 - 2 miles of the school & distances beyond this are not conducive to active travel. How will impact on smaller operators and communities be mitigated, when the school bus is often the only bus service provided in a rural community?
Actions
Assessment has been updated to include recommendation that wording be added to ensure opportunities for consultation are retained, in-line with Scottish Government Guidance: https://www.gov.scot/publications/consultations-in-the-scottish-government-guidance/
Assessment has been updated to include recommendation for requirement that cycle carriage is developed in collaboration with bus operators.
The action relating to replacement of bus services has been removed from the Framework.
Name/Organisation
Withheld
Comment/Feedback
The draft Business Regulatory Impact Assessment is detailed and explains well the possible implications of the new framework and delivery plan. Three points that are notable are:
> The framing of cycling infrastructure as a market is intriguing and is a unique way to talk about future plans. This change of language implies more as a business opportunity rather than one simply of getting more people cycling in our villages, towns, and cities.
> The recognition of the role and potential negative impact on the bus sector is good to see, especially around smaller private companies which may be the lifeblood of communities. It is important that they get the support they need to help keep them going whilst also supporting them to be part of a more integrated approach with cycling and active travel in the communities they serve.
> The impact that new infrastructure could have on tourism is a positive too. It would be interesting to build on this and find out what is needed to make places attractive to visit for those who are thinking of having a cycling holiday in Scotland.
Actions
Noted, assessment of impacts on bus operators updated in line with the above.
Name/Organisation
Withheld
Comment/Feedback
As I understand it, this doesn't currently include an Environmental Impact Assessment. This is essential.
Actions
A Strategic Environmental Assessment (SEA) Screening exercise has been completed and submitted to the SEA gateway. Screening assessment determined that a full SEA is not required of the Cycling Framework. However, Transport Scotland expect all partners to conduct an applicable assessment of environmental impacts associated with any active travel planning or project. There would also be an expectation that any likely significant effects identified through these processes would be monitored proactively at the plan and project level
Name/Organisation
Aberdeen City Council
Comment/Feedback
The wording of the actions subject to assessment does not match the wording of the actions in the overarching consultation document. While this is unlikely to impact on the overall assessment outcomes, consistency in the wording of the actions would be expected.
Actions
Wording corrected and assessment cross checked against previous order of actions. As noted, the outcome of the assessment is not significantly altered.
Name/Organisation
Withheld
Comment/Feedback
Taking away parking is killing small businesses and discouraging people shopping at hard to reach shops.
Actions
Potential negative impacts on businesses are detailed in the assessment: "Some businesses, sectors, markets, products or services may be affected by the infrastructure provision for active travel if, for example, it removes space for other travel modes (adverse effect) or improves access for a wider range of employees and consumers (positive effect). Micro and small businesses may be more vulnerable to any potential adverse effects."
Name/Organisation
MRC/CSO Social and Public Health Sciences Unit
Comment/Feedback
26.1 Newly published evidence on the health impact of physical inactivity may be considered here (Santos et al., 2022). The rationale for intervention may be strengthened by an acknowledgement of the evidence beyond climate issues and ‘market failure’. We encourage you to carefully consider the use of terminology with market connotations (e.g. market failure, and consumers of physical activity), which emphasise individual lifestyle decisions and detract from the systemic nature of the physical inactivity issue (Rigby, 2022ab).
Actions
It is acknowledged in the assessment that increasing levels of cycling is a systemic issue and multiple factors must be addressed in a coordinated way, in order to increase uptake of physical activity on a day-to-day basis.
Name/Organisation
Cycling UK
Comment/Feedback
We disagree with the assessment that changes to the TRO process (Refs CI.6 and CI.8) will negatively impact businesses. Each situation where any sort of TRO is applied has a different impact. Whilst there may be change for some business the consultants should not have concluded that these will be negative. Rather, evidence points to the fact that cycling benefits local economies and local businesses. Cycling UK’s Getting There With Cycling report outlines some of the evidence for this, for example, cycle parking delivers 5 times the retail spend per square metre than the same area of car parking. https://www.cyclinguk.org/sites/default/files/document/2022/04/getting_there_with_cycling_stage_3_single_pages_0.pdf
Actions
The assessment relates to the possible impacts of removing or truncating the TRO/ETRO process, rather than the implementation of cycle friendly infrastructure which, as commented, may have positive impacts on businesses. Positive impacts of cycling on businesses are noted in the assessment as follows: "Cycling Framework are expected to have a broadly positive impact on business, by encouraging local journeys to small retailers and the high-street, as opposed to out of town shopping centres, which are more easily accessed by car.