Summary of responses
Summary of Responses
This section sets out a summary of feedback from the consultation, highlighting the main issues raised.
SEQIA Feedback
The SEQIA consultation feedback covered a range of issues. However, the most common response across all consultees was to highlight the importance of transport affordability for socio-economically disadvantaged and protected characteristic groups.
Feedback supported the extension of National Concessionary Travel to include priority low-income groups, including women aged 22 to 59, those aged under 26, single parent families and larger families. While it is recognised that free bus travel for people aged under 22 supports a reduction in child poverty, Perth & Kinross Council suggests that extending concessionary travel to those aged under 26 could help to counteract the age-related impacts of the COVID-19 pandemic. They evidence that under 26-year-olds experienced a higher chance of furlough, precarious unemployment, disrupted education and work in low paid sectors.
Further support from the Institute for Financial Studies revealed that nearly a third of all employees in sectors most affected by COVID-19 were under the age of 25. Thereby, free transport could remove financial barriers to employment, education and training to assist recovery from the pandemic. Poverty Alliance also stated that extending free bus travel to women aged 22 to 59 would improve opportunities to access employment and education.
Further reference to transport affordability is made by Sight Scotland and Sight Scotland Veterans, who specifically advocate for concessionary travel for blind and partially sighted people and their companions. A review of the National Concessionary Travel Scheme for disabled and elderly groups is encouraged ahead of ScotRail’s move into public ownership, because this provides an opportunity to assess the budgetary implications of this inclusion.
Mobility and Access Committee for Scotland also stated that the SEQIA;
“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”.
Associated with transport affordability issues, Perth & Kinross Council advocate the inclusion of sustainable transport in the school curriculum;
“so that active and sustainable transport is the aim for all [rather than because you are seen as] too poor to own a car”.
Accessible transport for the elderly and disabled people was also a common response topic. The Community Transport Association (CTA) highlighted the importance of Community Transport for disabled and elderly groups. They stated that this service is often neglected in legislation and excluded from funding opportunities. For example, CTA express that the new Blue Badge legal guidance does not recognise Community Transport operators as care providers which has influenced local authorities’ refusal to renew long-standing organisational Blue Badges.
Furthermore, the Smart Pay Grant Fund is only available to commercial transport providers which does not include Community Transport operators. Consequently, CTA advocate an extension of this funding to support the digitisation and modernisation of Community Transport as a social service which does not operate for a profit. They also noted that there are significant up-front capital costs associated in purchasing and retrofitting Electric Vehicles which meet accessibility standards, especially for small local operators. The full roll out of the Plugged-In Communities Grant Fund should therefore also consider financially supporting the cost of Electric Vehicle uptake within Community Transport organisations.
Tactran makes additional reference to elderly groups, focusing on the importance of accessible transport for mobility, wellbeing and independence. They encourage a more nuanced understanding of what constitutes mobility, in replacement of conventional understanding that emphasises mobility as movement in physical space. Mobility, wellbeing and independence should be recognised as intricately connected, especially in later life, so that;
“Mobility allows older people to engage in everyday activities outside the home that are meaningful and enhance wellbeing, whilst independent living gives older people control over the times and places in which activities are carried out.”
Losing mobility does not only compromise physical mobility, but adversely affects fundamental psychology including life-satisfaction, happiness and sense of self. Thereby, loss of mobility can be perceived as;
“significantly diminishing wellbeing for the elderly.” (Tactran).
The health, safety and wellbeing of passengers with protected characteristics was also raised as concern with regards to vulnerable passengers.
“The first and last mile is often a barrier to accessing public transport and often individuals in the protected characteristic groups will utilise taxi and private hire vehicles to access public transport for their longer, onward journey. It is suggested that taxi and private hire vehicles are therefore included and also safety concerns highlighted about their use and this being a potential barrier – particularly if it is one passenger travelling alone in a taxi/PHV”. (Perth & Kinross Council)
The vulnerability of those with certain protected characteristic groups at bus or rail stations which are unstaffed and relatively remote was also raised. Further issues were highlighted with regards to the ability for social distancing on public transport and community transport services.
Intersectionality and systemic barriers for different groups were also raised, with particular reference to ethnic minority groups being disproportionately affected.
“The issue around intersectionality that often affects those from the BAME communities hasn't been mentioned or captured in this report… also there is no acknowledgement of the systemic barriers such as the systemic racism that affects people from the BAME communities.” (Radiant and Brighter Community Interest Company)
General feedback on the overall NTS2 Delivery Plan and structural process was also provided.
“In order to explore the options of making transport more affordable and accessible, we would suggest the Scottish Government establish a “Fair Transport Commission’ building on the work of the Fair Work Commissions around the country and working with the proposed Future of Transport Forum.” (Transform Scotland)
The importance of meaningful engagement with different groups and understanding the ‘lived experience’ of vulnerable groups rather than basing evidence on statistics was also raised as part of SEQIA (and other impact assessment) feedback.
HIIA Feedback
One of the main feedback response topics for the HIIA was the importance of community transport for vulnerable groups, especially elderly and disabled people. CTA recognise community transport as a;
“preferred mode of transport, compared to public or even private transport, for elderly, disabled or vulnerable people as they offer a safe, high-quality, personalised and door-to-door service”.
The important role of Community Transport in accessing healthcare facilities was highlighted, for example:
“The journey length and required public transport connections, would not make public transport a viable option for many people requiring to attend these [healthcare] facilities. This is why Community Transport and Hospital Care Schemes are a crucial service in this regard and this should be incorporated here […] Co-ordination and timing of hospital appointments by geographical location of the patients should also be planned in partnership with community transport providers and the local bus network. This would result in one Community Minibus or car being able to take several people from one area for their appointments all in the one day for example.” (Perth & Kinross Council)
Perth & Kinross Council also share feedback on the intersectionality of policies to reduce travel and accessing affordable healthy food. Some communities may have to travel lengthy distances to access affordable healthy foods, which conflicts with targets to reduce the need to travel. To counteract this conflict, the Council suggests that by supporting local businesses in providing healthy food, the 20-minute neighbourhood model will also be encouraged.
Feedback on policy actions targeted at narrowing health inequality gaps through the promotion of active travel were raised. For example:
“Evidence suggests that many broad public health campaigns, including various active travel initiatives, have higher take-up among already healthier people, hence improving overall public health but widening inequalities between groups. The strategic policies need, therefore, to be more specific, challenging and ambitious about narrowing gaps with regards health inequalities. We want all to travel healthily, but there is a strong need to put more focus on some communities than others. It is not clear that the set of actions in the strategy are specific enough to achieve this.” (Tactran)
ICIA Feedback
Although a limited number of responses were received to the ICIA, a key issue was raised around the accessibility of island transport for elderly and disabled passengers. The Mobility and Access Committee for Scotland (MACS) specifically link the limited provision of public transport with disabled populations’ vulnerability to exclusion, social isolation and loneliness. Disabled islanders’ reliance on ferry services with onward rail travel indicates the importance of rail information to journey planning, especially where alternative modes of transport may not be appropriate.
Furthermore, MACS recommend that active travel options make inclusive provisions for disabled people, such as cycling infrastructure (e.g. storage and cycle paths) appropriate for disabled tricycles. Consequently, these considerations highlight that the;
“lived experience of disabled people is critical and will greatly inform any development of accessible travel”.
CTA emphasise that;
“transport affordability is a significant challenge in island communities”
This is especially challenging for disabled and elderly populations accessing healthcare services. Community Transport provides a demand-responsive service for isolated, less mobile residents, however some are not funded or supported by a public body. This exacerbates health inequalities for those with chronic or serious health conditions whose only alternative method of transport are lengthy and expensive journeys to the mainland.
CTA advocate reforming the existing National Concessionary Travel Scheme regulations to enable Community Transport operators to be eligible for reimbursement. This would not only increase access to free travel services for the elderly and disabled residents, but also provide financial security for the Community Transport sector.
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