Consultation response - National Transport Strategy 2 (NTS2) - Equality Impact Assessment - Mobility and Access Committee for Scotland (MACS)
MACS welcomes the opportunity to comment on the draft Impact Assessment for the NTS2 Delivery Plan (October 2021). In line with our remit, we focus on the impacts anticipated for disabled people and our comments focus particularly on the ‘Reducing Inequalities’ strategic theme. We also comment on some other policies, which we see as particularly relevant to disabled peoples’ mobility.
However, as the document highlights in a number of places (e.g. page 26), ‘intersectionality’ is an issue - disabled people’s mobility options may be especially affected where they combine with other characteristics, notably with (old) age, with living in rural areas, and with poverty.
Key issues
The document sets out ‘key issues; for people with protected characteristics under the Equality Act in Section 3, and disability in particular in section 3.2.2. We do not agree that the ‘key issues’ identified (page 17) are the right ones. In particular it is not apparent why the lack of cycle infrastructure for non standard bikes is cited as one of the four biggest issues facing disabled people.
We suggest that more significant strategic issues, which disabled people face are:
- accessing suitable transport to health and social care
- inaccessible and hostile pedestrian environments which inhibit walking and wheeling and which are often a vital link in the journey chain
- the inability to plan a journey due to the lack of pre journey and real time information as well as the functionality of and information available via the Traveline Scotland app
- the risk posed by the aspiration to reduce car journeys, especially in cities, bearing in mind the disproportionately high dependence of many disabled people on private cars (as mobility aids)
We would encourage Transport Scotland to refer to MACS’ website and in particular our Annual Reports and report on Transport to Health and Social Care, which show the priorities which MACS identify and which forms much of the advice we provide to Scottish ministers.
Delivery plan objectives
Reduces Inequalities 1 - Ensure active, public and sustainable travel access to employment, education and training locations
With regard to the section on ‘Barriers’, the emphasis on cycling (4 out of 5 barriers) seems disproportionate. However, one of the key issues for disabled people with regard to cycling is the absence of variety and choice of bicycles in shared/hire schemes, which means that many disabled people are excluded from using them.
Opportunities - As the document notes, many disabled people rely on bus travel. There is an opportunity to make bus travel more accessible, reliable and otherwise suitable for disabled people - in addition to reducing financial barriers.
Reduces Inequalities 2 - Consider additional support required for public transport and keep this under review in light of the uncertainty and other challenges presented by COVID-19
The document should acknowledge that disabled people (like people on lower incomes, and especially if living in rural Scotland) are often disproportionately reliant on bus travel: we therefore don’t think that a score for this policy as of “neutral/negligible effect” on disabled people is correct.
Opportunities - we would like to see an additional opportunity recognised to develop schemes to provide concessionary travel for disabled people who rely on door to door transport services, especially taxis and community transport. Many disabled people derive no benefit from the concessionary bus scheme and rely on such services, at significant cost, for their personal mobility.
Reduces Inequalities 3 - Ensure transport in Scotland is accessible for all
This is probably the most significant policy in NTS2 for disabled people. We are astonished to see under ‘Potential Barriers’ the statement “None Identified”! The NTS2 and Delivery Plan must recognise the enormity of the challenge of ensuring transport is accessible for all.
This includes every mode of travel but also requires culture change, joined up approach to making journeys accessible and tackling massive infrastructure legacy - from inaccessible railways stations to uneven narrow and cluttered pavements.
Reduces Inequalities 4 - Remove barriers to public transport connectivity and accessibility within Scotland
Again, we find the comment “No barriers identified” completely inappropriate. The Scottish transport system is highly fragmented and a common theme of MACS work is trying to make the ‘whole journey’ work for a disabled person. This can involve multiple transport modes (train, taxi, ferry etc), each operated by different provider with different staff, systems and communications; as well as frequently a pedestrian phase.
Many transport operators from taxi drivers to ScotRail staff do make significant efforts to assist in interchange phases of a journey, but the degree of organisational and cultural collaboration required is a major challenge, which needs to be acknowledged.
To cite one piece of evidence, a recent survey by Disability Equality Scotland on assistance for travel by bus (for the week beginning 6 December 2021) DES asked a question about passenger assistance at bus stations (a topic suggested by Transport Scotland). Answers indicated that although 89% required passenger assistance, almost no one (4%) received it.
Under ‘Opportunities’ we suggest adding: “invest in good quality public transport facilities such as bus shelters with seats, and in improved, accessible pedestrian environments.”
Reduces Inequalities 5 - Minimise the connectivity and cost disadvantages faced by island communities and those in remote rural and rural areas, including safeguarding of lifeline services
We suggest adding a reference under ‘Potential Barriers’ to the increasing economic fragility of public transport services in rural and island communities, especially in the post-Covid19 world.
We see an opportunity to “increase adoption of innovative transport solutions such as DRT and to invest in community transport services”
Reduces Inequalities 6 - Ensure that equality and a human rights approach is at the heart of all policy-making processes
Under ‘Potential barriers’, we are unsure what is meant by “There is a need to consider and balance the requirements of different groups without creating resulting adverse effects for other groups.”
We suggest that a significant barrier lies in the fact that industries such as passenger transport, streetscape design etc have not historically developed from an ‘equality and human rights’ perspective. To put these at the heart of all policy making processes is an enormous challenge to all stakeholders, from Transport Scotland to councils to every transport operator.
Another barrier which we believe needs to be acknowledged is that there may be a financial cost to achieving equality and human rights, whether in the provision of commercial transport services (bus, taxi etc) or the design and maintenance of infrastructure (from ferries to footways).
We signpost to the Poverty and Inequality Commission report of 2019 (Transport and Poverty) that is framed from a Human Rights perspective.
Reduces Inequalities 7 - Enhance the impact and accessibility of the Scottish Transport Statistics, and Transport Scotland’s Social and Economic Research publication
The SEqIA frames this issue as one requiring better accessibility to data. We suggest that rather, the problem is one of availability - where information and evidence is absent or inadequate, it cannot be accessed, or make an impact!
We therefore suggest adding to ‘Potential barriers’: “The data available on disability, transport and mobility is currently very poor. This has begun to be addressed through the publication of ‘Disability and Transport’ by Transport Scotland in July 2021 but needs to be built on by a) further annual reports to develop a longitudinal evidence base, and b) more detailed research on specific topics.”
Reduces Inequalities 8 - Improve sustainable access to healthcare facilities for staff, patients and visitors
Travel to health and social care is often a nightmare for many disabled people. Agencies do not collaborate effectively to enable disabled people especially to access appointments effectively and disabled people are often left to find solutions themselves, often at considerable cost both financially, by making trade offs between heating, eating or travel and in terms of stress and well-being. The lack of a person-centred approach is a major problem, which has been highlighted over the past two years by MACS, with a specific ‘Transport to Health’ workstream. We are disappointed that this is not referred to in this SEqIA, particularly as Scottish Ministers backed the recommendations from this work and the SG Health Directorate (Primary Care – Fergus Milne – is currently leading a task force to progress MACS recommendations and other known issues.
We would therefore welcome this being recognised as a specific opportunity in the SEqIA. We note that the Accessible Travel Framework Delivery Plan for 2022 includes an action to address this as does NTS 2 Reduces Inequalities pillar “We will improve sustainable access to healthcare facilities for staff, patients and visitors.
Takes Climate Action CA1 - Reduce emissions generated by the transport system to mitigate climate change and improve air quality
A key element in this policy is the ambitious objective to reduce private car mileage by 20% by 2030. This could - if not planned carefully - have significant negative impacts on disabled people, many of whom rely on private cars for personal mobility (more so than most non-disabled people). However, if planned carefully and with appropriate involvement of disabled people and Disabled Peoples’ Organisations, we are confident that the objective can be achieved without disadvantaging disabled people.
We suggest that an additional ‘Potential barrier’ should be: “Inadequate enforcement and management of Blue Badge parking”.
This policy also includes a commitment to better manage roadworks. This would have a significant benefit to disabled people, as roadworks and associated signage often represent a major obstacle for disabled pedestrians. We therefore suggest that this is scored at least as “Minor positive effect”.
Takes Climate Action CA2 - Support management of demand to encourage more sustainable transport choices
Measures to encourage more sustainable travel pose both an opportunity and a threat for many disabled people. Greater use of remote working, work from home etc may make participation in work, eduction and social activities more accessible and inclusive for many disabled people. Conversely, our experience with ‘Spaces for People’ showed that many disabled people were significantly disadvantaged by the quick implementation of temporary measures to encourage walking and cycling. We therefore suggest that this should be scored as “Neutral/Negligible effect”.
Takes Climate Action CA9 - We will support households and businesses to make the switch to zero emission vehicles (CA-9)
Disabled people may find it harder to make the switch to zero emission vehicles. This is partly because of the high correlation between disability and poverty (with disabled people identified as one of the 6 priority family groups within the SG Child Poverty Delivery Plan), and also because at present such vehicles are less available and affordable through Motability (which provides cars to over 60,000 Scottish customers at present). Motability is aware of these risks, but combined with uncertainty over the extent and accessibility of EV charging facilities, the conversion to zero emission vehicles could disadvantage disabled people. We therefore suggest that this should be scored as “Minor Negative effect”.
Takes Climate Action CA12 - Improve the quality and availability of information to enable all to make more sustainable transport choices
We suggest that this should be scored as “Major Positive effect”. Accessible information is a cornerstone of accessible travel. This has many aspects, from providing audio and visual information on buses and trains to ensuring that websites and apps meet appropriate accessibility standards.
We welcome the specific opportunity in the Delivery Plan to “undertake a full review of the accessibility of the Traveline website and app, to improve its accessibility for blind people”. (This is something which MACS has raised repeatedly in annual reports). We would also highlight that for wheelchair users, journeys cannot be planned using the app. MACS has raised this with Traveline Scotland over a period of several years as well as highlighting this to the Cabinet Secretary for Transport, Infrastructure and Connectivity (now Cabinet Secretary for Net Zero, Energy and Transport)
Economic Growth EG10 - Support Scotland to become a market leader in the development and early adoption of beneficial transport innovation
Many traditional public transport options - most obviously rural bus services - are struggling to survive, let alone better meet the needs of disabled people. We suggest that innovation should not be only seen in terms of alternative fuels but also more broadly to test innovative mobility solutions, which could better meet disabled people’s needs. These might include on-demand taxi (Uber-type) services, Demand Responsive community transport services, electric bike sharing, and a more accountable Motability-type scheme. Where qualifying criteria is met, these should be included and funded in the concessionary travel schemes.
For this reason, we suggest that this policy has the potential for a “Minor - or indeed major - Positive Effect” on disabled people.
Improves Health and Well-being 1 - Provide a transport system that promotes and facilitates active travel choices which help to improve people’s health and wellbeing across mainland Scotland and the Islands
For most disabled people, everyday active travel is ‘walking and wheeling’ - for example to the bus stop or the corner shop. Enforcement of pavement parking laws are far from the only barrier which disabled people face in doing this. We suggest adding an opportunity: “Stimulate investment in the public realm to make pedestrian environments more accessible, for example by widening pavements, introducing more pedestrian crossings, reducing street clutter, etc” We would also signpost to the recent work of MACS in partnership with The Alliance Health and Social Care Academy and Disability Equality Scotland on ’20 minute neighbourhoods’.
Overall and concluding comments
We appreciate that the document is part of a comprehensive suite of impact assessments and recognise the challenges in anticipating the impacts on disabled people (and people with other protected characteristics) of the Delivery Plan. However, we see little evidence of engagement with disabled people with lived experience and carers who arrange transport for disabled people they care for.
Moreover, we believe that the document seriously underestimates the challenge facing the transport sector - from policy makers to delivery partners - in addressing mobility barriers which disabled people face. It also generally underestimates the significant costs that disabled people incur using transport and this is a barrier for the disabled people who are on low incomes. While many disabled people benefit from free travel by bus via the national entitlement card for disabled people, the remaining modes of transport still affect disabled people financially when they are on low incomes.
Except where highlighted in this response, we would suggest that most of the policies in the SEqIA (for example, the policies to decarbonise rail, ferry and air) should be scored as “Neutral/Negligible”.
There is a high degree of uncertainty around many of the impacts - especially when these depend on how they are implemented. We therefore suggest that this impact assessment is used to inform the risk management process associated with delivering the NTS2. In particular, there is a risk that the planned reduction of car mileage by 20% by 2030 could adversely affect disabled and older people who are reliant on cars for their personal mobility. We suggest that this should be formally should be recorded as a risk, not only because of the potential impact on disabled people, but also because, if not implemented well, it could undermine public support for the objective.
We hope that the comments made in our response will influence the next (second) NTS2 Delivery Plan, to be published in 2022.