Consultation response - Implementing Part 3 of the Transport (Scotland) Act 2019: Bus Services - Mobility and Access Committee for Scotland (MACS)
Purpose of this Consultation
The responses to this consultation will help shape the regulations and supporting guidance for implementing the new bus provisions contained in Part 3 of the Transport (Scotland) Act 2019. These provisions will provide a toolkit of options that can be utilised effectively by local transport authorities to support the resurgence of a vibrant public transport network. Responses to this consultation will help to inform the Scottish Government’s considerations regarding the implementation of the bus provisions contained within the 2019 Act, as well as the development of supporting guidance.
MACS Role and Response
"MACS believes in a Scotland without the barriers that isolate and exclude disabled people from making their choice of successful door to door journeys"
Much of the consultation is looking in detail at how the different structures would work e.g. the bus partnerships. This is beyond MACS scope or area of expertise therefore our response will focus on accessibility and the specific needs of the disabled community as a whole. Rather than answer the questions per se this document focuses on the areas that need to be taken account of to ensure all services and infrastructure (like bus stops) meet the needs of disabled people.
Bus Services Consultation
MACS welcomes the opportunity to respond to this document.
- However services are offered in the future there are several crucial conditions to take account to ensure all disabled peoples needs are met. All must provide accessible, affordable and available bus services that meet the needs of communities in both rural and urban areas.
- The requirements of the 2010 Equality Act applies at all times. LA must consider the impacts on disabled people of changes to how bus services are configured. Disabled bus users should be involved at all stages of local service plans. ‘Disabled people’ includes people who have difficulty walking, wheelchair users, people with cognitive impairments like dementia, people with sensory impairments etc. Many disabilities are hidden such as people who are neurodivergent or like Crohns disease, a hidden physical illness.
- Bus design should take account of needs of all users such as providing low floor for those with poor mobility and wheelchair users. They should also look to accommodate small mobility aids like scooters to enable door to door journeys.
- Equality Impact Assessments (EqIA) should be used to ensure the changes do not worsen inequalities and accessibility.
- Look to the future e.g. where will these bus partnerships fit with approaches like (MaaS) Mobility as a Service and (DRT) Demand Responsive Transport and other community transport initiatives? Shared planning informed by users will improve outcomes for disabled people.
- Communication strategies should be inclusive, so that all passengers understand what services are available and any changes that have been made, ideally in advance. For example, if possible, inform passengers if toilets are closed or access has changed. Communicate using an easy read approach and with video and audio technology wherever possible. Guidance should also encourage the provision of onboard audible announcements alongside visual display providing information about the next stop as without this provision services are inaccessible for many people with sensory impairments.
- Guidance should necessitate LTAs to provide accessible information in a range of formats such as Braille, Easy Read, and online information compliant with web accessibility standards such as WCAG, about the availability, location and frequency of their services.
- Communication should include the provision of online information. Ensure digital approaches can also be shared off line for those without suitable technology. Ensure apps are accessible to all, Travelline for example is currently not accessible.
- Develop holistic approaches that link to the range of transport needed for end to end/door to door journeys in an integrated way.
- Develop targets around accessibility to ensure equitable services throughout Scotland.
Link to the vision and ambitions of the Accessible Transport Framework: “All disabled people can travel with the same freedom, choice, dignity and opportunity as other citizens.”
Going Further: Scotland’s Accessible Travel Framework - linking to these ambitions will support excellent outcomes for all involved. As the population ages, many older people do not see themselves as disabled, but they do require support to have successful journeys by bus. Consequently, any improvement to accessibility in future bus services will enable a wider proportion of the population to use buses more readily.
This vision is supported by four outcomes:
- more disabled people make successful door-to-door journeys, more often
- disabled people are more involved in the design, development and improvement of transport policies, services, and infrastructure
- everyone involved in delivering transport information, services and infrastructure will help to enable disabled people to travel
- disabled people feel comfortable and safe using public transport – this includes being free from hate crime, bullying and harassment when travelling