This section sets out a summary of feedback from the consultation, highlighting the main issues raised, a full record of responses and actions taken is contained in Appendix A.
Within the SEQIA, ICIA and BRIA respondents answered the following question on the basis of their review of each draft IA:
Do you have any comments on the draft Social and Equalities Impact Assessment / Business Regulatory Impact Assessment / Island Communities Impact Assessment?”
The SEQIA consultation feedback covered a range of issues, with one of the most common being concerns regarding disabled users and how cycling infrastructure may negatively impact their ability to travel safely.
- This concern was voiced by the Mobility and Access Committee for Scotland who highlighted creation of “additional pavement clutter” resulting from infrastructure such as bus stop bypasses which may put disabled people in the path of cyclists while accessing buses. As such, there is a suggestion that individual safety amongst disabled and other protected characteristic groups may be negatively impacted, an issue raised by multiple respondents citing the fact that people may face restricted accessibility to key services.
- Sustrans Scotland and Aberdeen City Council also highlighted the need to account for disabled people’s needs but indicated that proposed actions aimed at making the ETRO and TRO process more efficient would help to remove barriers to active travel for disabled and non-disabled people alike, while retaining the opportunity for consultation.
In addition, questions, and comments regarding the impact of cycle paths on the local environment were raised with particular focus on local habitats.
- In relation to the local environmental impact, one respondent noted the specific impact of recreational cycling on litter which is said to have increased since the Covid-19 pandemic with a need for litter collectors to be deployed to mitigate against negative impacts on pathways and local wildlife.
Multiple responses focus on the concern that women are not actively identified as a key group within the Framework.
- A respondent noted the fact that women are less likely to meet recommended physical activity levels and less likely to cycle due to safety concerns, leading to suggestions that cycling investment may only benefit those who already cycle the most.
- Sustrans Scotland note that improved safety is of particular benefit to women and young adults when choosing to cycle. Therefore, actions within the framework aimed at making it easier to switch to cycling and help remove safety related barriers are welcomed.
In the ICIA feedback, multiple responses focused on the concern around the quality of active travel infrastructure which is negatively impacting some vulnerable groups and a need to further advance the road and path quality across the islands to ensure women feel safe and comfortable to take part in active transport.
- Safety amongst women is raised as a concern with a group of respondents noting the lack of sufficient sports and exercise facilities meaning walking and cycling are the key methods for staying active. However, the lack of dedicated pathways is said to discourage women in island areas and as such is creating a barrier to active travel.
- Respondents also highlighted safety concerns for families with young children with one comment noting that friends in a rural area have had to “fight to get the school bus to pick the kids up at a safe spot, they were having to stand on the verge with traffic going by at 60mph”
The BRIA consultation feedback included concerns related to additional regulations on businesses and the ability to access businesses by car, particularly for disabled drivers.
- One respondent noting that there is not enough focus on disabled access for work or leisure travel. In support of this, a further respondent indicated the need to ensure that car accessibility to businesses remains straightforward particularly for disabled groups.
Furthermore, the subject of physical inactivity is raised in relation to the systemic nature of public health interventions.
- The MRC/CSO Social and Public Health Sciences Unit stated that the rationale for intervention may be strengthened by an acknowledgement of the evidence beyond climate issues and ‘market failure’, highlighting from the systemic nature of the physical inactivity issue.
Cycling UK highlighted that the effects of a more efficient TRO/ETRO process should not be seen as necessarily detrimental to business but highlighted that increased active travel could provide highly positive outcomes for local highstreets and business.