Membership of the National Smart Ticketing Advisory Board - Consultation Analysis

Background

Smart ticketing is an important element of a modern public transport system and is increasingly prevalent in major cities in the UK and in countries around the world. In September 2017, Transport Scotland sought the views of stakeholders and the wider public through a consultation on various aspects of smart ticketing, ‘the Future of Smart Ticketing in Scotland’.

This 2017 consultation looked at:

• the scope of smart ticketing schemes in Scotland;
• how individual smart ticketing schemes operate and the legislation required to facilitate this;
• governance arrangements for smart ticketing in Scotland.

Most respondents thought that a consistent smart payment option would encourage the use of public transport and also highlighted the convenience of not having to use cash.

Respondents also felt that Transport Scotland should establish a single governance group so that the technology implemented across Scotland for smart ticketing schemes is standardised.  They felt that this group should be established on a statutory basis.  These views informed the smart ticketing provisions in Part four of the Transport (Scotland) Act 2019.

During the development of the Transport (Scotland) Act 2019, consideration was given as to how a formal governance body for smart ticketing should be established and what role Scottish Ministers should play.  It was decided that a formally constituted body, supported by legislation, would allow Ministers to set out their expectations for the group, such as membership, frequency of meetings and what the outputs should be, in order to deliver this aim.

The 2019 legislation gives Scottish Ministers the power to establish an advisory board, to be known as the National Smart Ticketing Advisory Board (“NSTAB”). As well as providing advice for the national technological standard, it was determined through the legislative process that the Board will also advise Ministers on the strategic direction for smart ticketing in Scotland.

This consultation sought to gather views on how those expectations be established in practice, and the overall basis for this new public advisory board.

---

Overview of Respondents

The consultation on establishing NSTAB was launched on the Transport Scotland Website and Scottish Government Consultation Hub on 10 August 2021

The consultation ran for a standard twelve week period, closing on 13 October 2021. Overall fifty-three responses were received, fifty-one electronically and two direct responses.

Twenty-seven of the responses came from organisations, and twenty-six from individuals. The responses from organisations included major bus and rail operators, passenger groups, Regional Transport Partnerships (“RTPs”) and Local Transport Authorities (“LTAs”), cycling and disability groups, a transport campaign group and two organisations concerned with data and data standards. Three organisations and three individuals declined to give permission to publish their responses. A full list of public respondents excluding these six is given in Appendix A.

Main Findings

Overall, there was support for the suggested framework for NSTAB, and many of the responses provided very detailed insights into the practical considerations of establishing such a board. The responses received were largely in favour of establishing NSTAB, with only a single response opposing ‘smart ticketing’ as a general policy area. On the basis of this consultation, we are content to make the following recommendations to Scottish Ministers:

Recommendations

Board membership will be open on a sectoral basis, with a specific view to seek relevant representation from supplier/technical members, alongside passenger and mobility groups, as well as transport operators and related public bodies.

We recommend that a Chair be appointed initially on a three yearly basis.

We propose that secretariat duties be handled predominately via Transport Scotland officials, with support from NSTAB members, also on a three yearly basis.

We recommend that these arrangements are reviewed after an initial period of three years, with a view to amending the arrangements if necessary.

We propose that NSTAB operate with twelve voting members, comprised of six operator representatives and six passenger group and public sector members. We further recommend there be three non-voting advisory posts, for the purpose of directly informing the board on key technical and accessibility matters.

NSTAB members will have the right to write to Ministers independently where they dissent from the formally agreed recommendations put forward by the Board. We will require the board to have a written policy on a standard form and procedure for this.

We will provide for members to apply for reasonable out of pocket expenses when required, including provision for a small ex gratia payment for time spent. Board positions are offered on a volunteer basis, remuneration for expenses is not a wage, and members will not enter into an employer/employee relationship with Transport Scotland or the wider Scottish Government.

Costs for any Transport Scotland secretariat support will be met by Transport Scotland.

NSTAB will be constituted to allow members to make recommendations to Ministers on appointment, removal and replacement of board members, and also to recommend expansion of membership when appropriate.

Question 1

Do you think the following organisations should be represented?

• Public transport operators
• Regional Transport Partnerships (RTPs)
• Local Transport Authorities (LTAs)
• The Confederation of Scottish Local Authorities (COSLA)
• Organisations representing passengers
• Disability organisations
• Active travel organisations
• Other organisations or bodies with an interest in Smart and Integrated Ticketing and Payment – please state

Please briefly explain why you think they should, or should not be, represented

The majority of responses were supportive of some or all of the above list being included, however, one respondent gave no response to this specific question at all, noting that:

I do not agree with smart ticketing”
Individual response

Of the remaining fifty-two responses received, twenty-five agreed that the entire list, public transport operators, RTPs, LTAs, COSLA, passenger organisations, disability organisations and active travel organisations should be represented on NSTAB.

Within this group, a further fourteen also specifically noted ‘other organisations’ as being necessary. One response by an individual neglected to select the specific options for membership in Question one, but noted in free text that they supported the above list in principle, and provided a suggestion in Question 2 for alternate bodies. This has therefore been manually recorded as support for each of the options listed above.

The majority of respondents supported Public Transport Operators, RTPs and LTAs forming part of the NSTAB board. There was further support for disability, passenger and active travel organisations to hold board posts. The least supported suggestion was for COSLA to form part of the board. There was wide support for ‘other’ suggestions, the majority of which are detailed in the analysis of Question 2.

Table 1: Support for proposed board membership

Organisation	Responses	Percentage
Public Transport Operators	49	92.5%
Regional Transport Partnerships	45	84.9%
Local Transport authorities	43	81.1%
COSLA	29	54.7%
Passenger Organisations	42	79.2%
Disability Organisations	41	77.4%
Active travel organisations	37	69.8%
Other organisations or bodies with an interest in Smart and Integrated Ticketing and Payment	30	56.6%
Gave no answer	1	1.9%

Question 2

Which other organisations do you feel should be represented on NSTAB? Please list the organisations and briefly explain why you think they should be represented.

In response to this question, a total of thirty-four respondents gave views, of which twelve were simply references back to the original list or to confirm no other bodies are required. One response noted the list could be longer, but outlined the difficulty in making ‘abstract’ suggestions, without a reference list and made no further suggestions. There were therefore twenty-one unique responses suggesting at least one new organisation or sector not already directly listed.

From these twenty-one responses, three requested involvement by Mobility as a Service (MaaS). Three responses called specifically for representation from age groups, citing the need for an alternate for smart where traditional ticketing is ‘more accessible’, and one further response requesting either permanent or advisory guidance that covers the needs of youth groups. Five responses called for greater representation by technology and infrastructure providers, either generally or by naming specific organisations.

A wide variety of reasons were given to explain the rationale for these suggestions, including one organisation who recommended their own organisation on the basis of providing current services in this field and therefore representing suppliers generally. In some cases the expanded list was simply a suggestion for a named group within one of the existing categories, and in some cases it was a suggestion for a new group type – for example representation from groups representing ‘genuine’ passengers or alternate modes, such as e-scooter users.

Some respondents gave very detailed answers to the ‘other’ question, for example, one individual responded:

...All RTPs. All LAs. Bus/Rail/Ferry directorates of Transport Scotland. ScotRail operator. Transport for Edinburgh (Lothian bus / Edinburgh tram), First Bus (Glasgow, East), Stagecoach (West, East, Highland, South), McGills, and other bus operators - ideally the respective RTP or LA should have overall say on bus needs and views and treat the bus operators as a single network in their area as to avoid disagreements between operators or allowing bus operators to derail plans or improvements…."
Individual response

A full list of suggestions from this question is included at Appendix B at the end of this document. Grouping the suggestions by ‘sector’ type, the following make up is proposed.

Infographic 1 shows a voting tier of six posts, six from operator groups, four from the public sector and two from groups representing passenger bodes. This is complimented by a non-voting tier, made up of one supplier representative and two third sector/non-profit representatives, and finally a board chair. The Chair is a non-voting role. The chair will receive a vote only in the case of a tied vote, in which the Chair will provide the casting vote. Secretariat support offered by Transport Scotland is also a non-voting role.

Group Breakdown

Operators Group: (6 posts)

We will be seeking nominations for individuals from organisations which operate the following services:

• Bus
• Rail
• Ferry
• Subway
• Tram
• Bike / Active Travel / Shared operators
• other shared mode providers (example: community bus providers)

Public Sector Group: (4 Posts)

We will seek nominations for individuals from organisations which represent the public sector, including but not limited to:

• Transport Scotland (excluding neutral secretariat support)
• Local Authorities and Local Authority Organisations
• Regional Transport Partnerships
• Community Councils

Passenger Bodies Group (2 Posts)

We will seek nominations for individuals from organisations which represent passengers, such as:

• Transport Focus
• Age UK
• Youth Groups (Example: Young Scot)
• Edinburgh Bus Users Group
• Bus Users Scotland
• Mobility and Access Committee Scotland (MACS)

3rd Sector / Not for Profit Group: (non-voting) (2 Posts)

We will seek nominations for individuals from organisations which represent the third sector, to occupy two of the non-voting membership posts, from organisations such as:

• City Region Deals
• MaaS Scotland
• Traveline Scotland
• Transform Scotland
• CoMoUK
• Academic Institutions (Example: Scottish Association of Public Transport)
• Confederation of Passenger Transport

Suppliers Group (Non-Voting) (1 Post)

We will seek nominations from the technology sector, such as Google, Apple, ITSO, Ticketing Providers, and other smart technology providers

Not all responses were in favour or expanding the original list, one organisation responded as follows:

None - the wider the scope and membership of NSTAB, the less likely that meaningful, deliverable progress will be made. Care needs to be taken to ensure that the membership does not give disproportionate weighting to those organisations with the least resource commitment in developing, implementing and maintaining any resultant smart ticketing/payment output.”
a bus operator

There seems to be clear support for widening the membership of the board to include technology and infrastructure providers (‘suppliers’), and also for representatives of passengers, including those with a specific age focus.  Some groups with overlapping focus from alternate perspectives were listed, e.g. individual bus operators and the Association of Transport Coordinating Officers (ATCO). 

A review of final membership will include the suggestions above, and specifically involvement by suppliers and groups representing passengers. Transport Scotland will engage with the other named organisations to discuss ways in which their views can be made available to NSTAB, with reference to question six on non-voting members.

Question 3

Question 3(a)

What arrangements should be made for the NSTAB Chair?

• It should be nominated at the start of each year
• It should rotate around members
• Another arrangement.  If so, please explain

While there was clear support for a yearly nomination (twenty-nine of fifty-three responses) over a rotational arrangement (ten of fifty-three responses), eight respondents supported an alternate arrangement. Within this group, six responses requested the Chair be neutral, including one suggestion that it be undertaken by Transport Scotland directly, and one counter suggestion that it be neutral and also independent of Government.

Other observations noted than an annual appointment was too frequent, and that efficiency would arise from have a two or three year placement as opposed to a ‘musical chairs approach’.

Table 2: NSTAB chair arrangements

Organisation	Responses	Percentage
It should be nominated at the start of each year	29	54.7%
It should rotate around members	10	18.9%
Another arrangement	8	15.1%
Gave no answer	6	11.3%

It would seem appropriate that a recurring nomination system be taken forward, with a recommendation that the Chair be a three year post. The duration of the chair appointment can be reviewed after the first three years of the Board being established.

If after that period a shorter (annual) occupancy seems appropriate, Transport Scotland will review on the matter of Chair appointment length.

The post of Chair will be established as a non-voting post, except in the case of a tied vote, where the Chair shall be granted the casting vote.

Question 3(b)

• What arrangements should be made for the Secretariat?
• An organisation should be nominated at the start of each year
• It should rotate around members
• Another arrangement.  If so, please explain

In terms of the board secretariat, there was strong support for an annual nomination system, with twenty three of fifty three responses in support of this arrangement. Ten responses, three from organisations and seven from individuals supported a rotational arrangement, one organisation further noting that a yearly rotational arrangement may work better in practice, which could be considered caveated support for option one, an annual nomination.

Fourteen responses outlined an alternate arrangement for the secretariat, eight of which specifically naming either Transport Scotland, the wider Scottish Government/Civil Service or a Government funded post holder to undertake this function on an ongoing basis. Concerns around continuity and length of term were again raised, citing the same two/three year period and the need to have an ‘unbiased’ secretariat taking on the administrative burden of the board.

As the purpose of NSTAB is to advise Scottish Ministers on the strategic direction for smart ticketing, consideration needs to be given to ensuring that all interests are represented in a fair and equitable way and that no single interests dominates. Question 1 above seeks views on the types of organisations that should be represented which also requires giving consideration to the number of member organisations on the Board to ensure this balance is achieved…”.
A Regional Transport Partnership

Table 2: NSTAB secretariat arrangements

Organisation	Responses	Percentage
It should be nominated at the start of each year	23	43.4%
It should rotate around members	10	18.9%
Another arrangement	14	26.4%
Gave no answer	6	11.3%

Of each of the options under consideration, no single proposal secured the support of the majority of respondents. While there is clear support for an annual nomination, the need for a neutral and consistent secretariat in practice was highlighted by a quarter of respondents. That being the case, we propose a joint secretariat, primarily provided by Transport Scotland, with additional support from NSTAB members, nominated on an annual basis.

More specifically, this would allow for a Transport Scotland supplied secretariat, most likely a Transport Scotland official but not precluding a directly funded external resource. In either case this post would undertake routine secretariat tasks, including preparing the minutes of meetings, organising the boards diary, providing necessary administrative report in reviewing board created papers and circulating documents to members.

It is envisaged that NSTAB will operate based on separate work streams or sub-committees for detailed work, and so the requirement for a secretariat may exceed the reasonable capacity of a single post. In those circumstances we would anticipate a nominated NSTAB member taking over some of those tasks temporarily.  We also anticipate a degree of flexibility over day to day administrative arrangements after the board is established.

Question 4

How many member organisations should sit on NSTAB?

• Minimum
• Maximum

Please briefly explain the reason for your answer.

One individual responded that the maximum number should be ‘all’ which may be understood to mean one organisation of each type given in question one, (seven organisations), but is otherwise not reasonably quantifiable. This response has been set aside for the purpose of analysing this question. Thirty-eight responses provided a numerical value for the minimum number and thirty-two for the maximum.

Responses to this question were varied, and often caveated or otherwise amended by supporting text. Seven respondents provided a minimum figure but no maximum. One response provided a maximum but no minimum. Of those who provided a figure in both categories, supporting commentary suggested that a maximum in excess of twelve to fourteen seats would become ‘unwieldly’, ‘unmanageable’ and prove ‘hard to reach decisions’.

7 should include chair, secretariat and a minimum of 5 people to make a majority decision. More than about 20 in the same meeting can get hard to manage / communicate”
Open Transport Forum

…the board may become quite large very easily”
Local Authority

It should comprise a sufficient number of no less than 8 and no more than 12,  able to bring experience and expertise and to offer challenge and robustness to proceedings while not being too large so as to render it unwieldy.”
Public Body

On this basis, although there was a common call for ‘no more than twenty’ with some individual responses suggested even larger numbers, the associated commentary makes clear that the need to have a manageable and effective board is the key driver. In this context, a maximum board size of twenty appears to be an absolute maximum and not actually a preferred number in terms of attendees.

In keeping with other public Boards and Non-Departmental Public Bodies, no maximum of no more than twelve voting members appears appropriate. The ability to request an expanded membership covered in Question ten should therefore also be framed in the context of future expansion capped at 20, but with an ongoing assumption of a far lower number.

Some suggestions were made on numbers required for a quorum, or for a core sector representation, with a recognition that larger numbers may be required to be representative of a range of stakeholders and geographical areas.  Some responses specified that the chair and secretariat should be exclusive of the maximum and minimum suggested. One individual noted that:

This is a ‘how long is a piece of string’ type question. There needs to be enough to have a reasonable range but, not too many to become difficult to manage. The number can be changed in the light of experience”
response by an individual

The most supported suggestion for a minimum number of organisations was ten member organisations, with six being the next most supported number of posts.

Table 3: Breakdown of suggestions for minimum number of Board members by organisation

Minimum Board Compliment	Responses
Zero	1
One	1
Three	4
Four	1
Five	4
Six	6
Seven	2
Eight	4
Ten	9
Twelve	4
Fifteen	1
Twenty-five	1

The most supported suggestion for the maximum number of organisations was twenty, with twelve being the next most popular option, however in the breakdown of responses, it is clear that this has been suggested as an absolute maximum, with a preferred number far lower in the interests of efficiency, highlighting the difficulty in balancing sector wide representation with the ability of the board to reach a consensus.

NSTAB should be able to discuss, debate and agree positions without forever 'taking it off line'"
Individual Response

A minimum number of ten has most support, with the second most supported option being six. The number required to reach a quorum is a separate consideration, which will form part of the standing orders for the Board.

Table 4: Breakdown of suggestions for maximum number of Board members

Maximum Board Compliment	Responses
Five	2
Six	1
Eight	2
Nine	1
Ten	1
Eleven	1
Twelve	5
Fifteen	3
Sixteen	2
Eighteen	1
Twenty	9
Twenty-one	1
Twenty-five	2
One Hundred	1

It would appear more efficient to constitute the board closer to the minimum number required, and expand upwards after review, than to start at the maximum and then have to remove members if a smaller maximum number is agreed. We have identified the need to balance the right to representation of the groups listed in Questions one and two, and the need to effectively manage decision making, we therefore support recruiting to this board on the following basis, exclusive of both Chair and Transport Scotland secretariat.

A Board of twelve voting members and three non-voting members, with scope to expand either voting or non-voting membership if required in the first three years to an absolute limit of up to twenty, is recommended.

Question 5

Should dissenting members have the right to make written representations to the Minister along with the formal NSTAB advice?

• Yes
• No
• Not sure

Please briefly explain the reason for your answer.

Responses to this question supported strongly the right to a written representation to the Minister. It was noted that minority views, or expert views, may be contrary to commonly held opinion (may be a view point which ‘others simply do not understand’), and that where any member or group of members dissents, a written representation should be the ‘route for grievance’. It was noted that Ministers will ultimately make their own decisions on how valid a minority or dissenting view is.

It was also noted that as an advisory body, it should not be considered a ‘route for bypassing or undermining the collective NSTAB recommendations’ and that the board’s governance arrangements should prevent excessive written representations.

• Seven of fifty-three responses noted being unsure if this right should be conferred or not. It was noted by two of these responses that the governance arrangements of the board should make such approaches uncommon, and that ‘fragmentation’ should be avoided
• Six of fifty-three responses objected to this right being conferred on members. A seventh ‘no’ response was supported by a statement that while dissent should be recorded by the board in formal minutes, the individual should also be able to write to the Minister directly if they wish. That being the case, this response is being analysed as ‘yes’
• Thirty-six responses supported ‘yes – dissenting members should have the right to make written representations to the Minister
• Four respondents opted not to answer this question at all

Important that operators are able to feel that their views are being accurately presented to CabSec and Government.”
Rail Operator

We therefore support the right to written dissent for board members.

Question 6

Should NSTAB have non-voting members?

• Yes
• No
• Not sure

Please briefly explain the reason for your answer.

We sought views specifically on non-voting members, reasoning that arrangements could be put in place to provide for the appointment of such members to the Board. A non-voting member is defined here as one who can advise the board in an expert capacity and may be from an organisation that would not normally be represented on the Board. Non-voting members would not count towards the quorum.

Table 3: NSTAB Non-voting members arrangements

Should NSTAB have Non-Voting Members?	In Favour	Percentage
Yes	29	54.7%
No	12	33.6%
Not Sure	7	13.2%
Did Not Answer	5	9.4%

Of those that objected to having non-voting members, seven responses came from organisations, and five from individuals. Objections focused on the need for Board members to have equal status and the potential for delayed decision making. One technical organisation noted:

...Inclusion of non voters has a 'talking shop' risk."
tech organisation

Seven respondents were not sure if arrangements should be made for non-voting members. It was noted that non-voting members raised the possibility of vote ‘exchanges’, and that it may be simpler to allow the board to seek expert advice on an ad-hoc basis without becoming board members.

The most popular suggestion was to allow for non-voting members as part of the NSTAB constitution, with twenty-nine respondents in favour. It was noted that as a ‘technical’ area, the board will require updated information as technology progresses, and non-voting members provides an avenue for experts, to contribute. We therefore recommend that non-voting members be accounted for, with a reasonable review after three years.

Question 7

Should all NSTAB members receive reasonable and/or appropriate out of pocket expenses?

• Yes
• No

Please briefly explain the reason for your answer.

As the legislation gives the Scottish Ministers the power to decide the appropriate remuneration, or payment for NSTAB members, this question sought views on how that should be achieved. While NSTAB members remain volunteers, it is reasonable that members be able to claim for some level of out of pocket expense when appropriate. Six respondents gave no view at all on this matter.

Table 7: NSTAB expenses arrangements

Should all NSTAB members receive reasonable and/or appropriate out of pocket expenses?	In Favour	Percentage
Yes	38	71.7%
No	9	17%
Did Not Answer	6	11.3%

There was strong support for reasonable or out of pocket expenses to be paid to board members (71.7% in favour), nine responses objected to this practice. On further analysis, three of the nine objections were caveated that expenses should be covered for volunteer or third sector organisations, but not for commercial or government members.

Employees of government should not be included. All others should receive recompense for out of pocket expenses. Zoom (or similar) should be used to keep costs down."
Individual response

Given that the membership of NSTAB may change over time, and in particular the ad-hoc inclusion of non-voting members, it may be difficult to categorise membership ‘type’, and in particular for user or community groups without a registered charitable status. One approach may be to allow every member to apply for expenses at a set rate, but to minimise the need for expenses by requiring that board meetings be accessible virtually and to support ‘blended’ face to face and electronic meetings when required.

Question 8

Should NSTAB members be remunerated for serving on NSTAB?

• Yes
• Yes, but for voluntary or third sector groups only
• No

Please briefly explain the reason for your answer

On the subject of direct remuneration, there was clear support for having no directly ‘paid’ members, but a number of queries were raised on arrangements for members whose parent organisation does not currently compensate their time with a salary. Board positions are intended to be voluntary posts, there is no scope to have certain posts attract a ‘wage’ or be offered on a non-volunteer basis.

Only five responses supported remuneration for time for board members, with one caveating that a ‘small honorarium’ would be appropriate. A further nineteen responses noted that an ex gratia payment may appropriate for organisations or members not already being paid a salary to encourage their attendance. It was generally noted that such payments should not be available for anyone already compensated by a parent organisation in terms of salary. One local authority response described it as:

As stated above; I'd not anticipate any serving officer salaried to be double paid, unless it was clearly agreed that participation is outside their salaried remit and in own time.”
Local authority response

Twenty-four responses objected to remuneration, largely focusing on the potential for members to be financially motivated, which was seen as detrimental to the boards make up. One individual supported their stance with this text:

Having a commitment to improve peoples' lives should be the motivation"
Individual response

Table 8: NSTAB salary arrangements

Should members be paid, in addition to any expenses, for serving on NSTAB?	In Favour	Percentage
Yes	5	9.4%
No	24	45.3%
Yes - Volunteer and third sector only	19	35.8%
Did Not Answer	5	9.4%

As Board membership is intended to include organisations and groups whose representative may not be in receipt of a salary from their organisation, we consider there is an inherent socio-economic imbalance between proposed members. One way forward may be to offer a small, ex gratia sum to members, as a token recognition of their voluntary participation on the Board.

Question 9

Once NSTAB is established, should NSTAB be able to make recommendations to the Scottish Ministers regarding appointing, removing, and replacing member organisations of NSTAB?

• Yes
• No
• Not sure
• If no, please explain your answer

The majority of responses supported NSTAB having a role in providing advice to Ministers on future appointments, replacements and removals. On this basis it would be our intention to constitute NSTAB with this function from inception.

Table 8: NSTAB ongoing membership arrangements

Should NSTAB be able to make recommendations to Ministers on member organisations?	In Favour	Percentage
Yes	39	73.6%
No	1	1.9%
Not Sure	8	15.1%
Did Not Answer	5	9.4%

The single ‘No’ response noted that it should be for NSTAB alone to determine future membership, with no role for Ministers in the process at all. As an advisory board established by Ministers, Ministers have ultimate responsibility for membership. The question is aimed at asking if NSTAB should be able to inform that decision, with the default being that Ministers make that decision alone.

Question 10

Once constituted, should NSTAB be able to recommend expanding the number of member organisations?

• Yes
• No
• Not sure

Please briefly explain the reason for your answer.

Five of the fifty-three responses received supported this function not being made available to NSTAB. Two of those responses specifically noted the perceived danger of expanding the membership to a point where efficiency in decision making is lost. One individual who also supported a ‘one in, one out’ model of membership noted specifically:

Too much scope for the NSTAB to lose focus if it expands.”
individual response

Thirty-nine of the fifty-three responses received believed that NSTAB should have the ability to expand membership after being established. Eleven of these responses noted specifically the need for NSTAB to remain current, in terms of both technological standards and for newly formed stakeholder groups. A further three noted that as this would take the form of a recommendation to Ministers, the provision was sufficiently caveated. Although the question was structured around expansion, two responses also noted the need to respond to non-attending or non-contributing members, which is an existing requirement for public board governance. On this basis, it would be our intention to similarly constitute NSTAB with the power to recommend expanded membership from inception.

Table 9: NSTAB role in future membership arrangements

Once constituted, should NSTAB be able to recommend expanding the number of member organisations?	In Favour	Percentage
Yes	39	67.9%
No	5	9.4%
Not Sure	6	11.3%
Did Not Answer	6	11.3%

Question 11

Are there any other issues you wish to raise which are not covered in the points or questions above?

This free text question allowed respondents the opportunity to raise issues directly that were not part of the consultation specifically. Thirty-two respondents opted not to provide further commentary.

Twenty-one responses provided additional context, in some cases to build on information given in earlier questions, and in some cases to provide entirely new points for discussion. Four responses noted the perceived slowness of Transport Scotland to deliver a smart ticketing system, with reference to other current systems in the wider UK and beyond.

...it is reassuring that the value of input from disabled people has been recognised. This may need to include both digital and print tickets, electronic and cash payment, communication, taking account of visual, hearing and intellectual impairments etc. Particular importance should be given to the need for joined up arrangements between modes which are often a problem for disabled people travelling.”
Disability Group

Five responses focused on the need for an inclusive board, which takes into consideration different needs for different geographical areas, including areas of low mobile connectivity. One response also noted that a perceived ‘bus dominance’ not be allowed to ‘continue’. Three responses were centred on governance and the need to save costs, for example taking advantage of ‘virtual’ meetings. Two responses objected to the acronym ‘NSTAB’, on the basis that it contains the word ‘stab’.

Specific questions were asked on expanding the scope of smart ticketing to cycle hire schemes, how disputes between operators or operators and passengers would be handled, on the role of the group in terms of spend (advisory only, or involved directly in financial decision making) and on provisions for innovations.

Other comments received were as follows:

To ensure self-regulation and accountability:
-Need a stringent conflicts of interest policy
-NSTAB reviews its effectiveness regularly
-NSTAB publishes an annual workplan, setting out its key objectives, what success would look like, how it’s going to measure its performance against its objectives and success criteria and report on workplan and delivery”
Non Departmental Public Body

This consultation is welcomed but the provisions already in place within the 2019 Transport (Scotland) Act, in particular the provisions relating to 'Information about Bus Services' should be advanced at the earliest opportunity to compliment the work to establish NSTAB and ensure that advances in smart ticketing can be allied to comprehensive journey planning information in support of developing a wider MAAS ecosystem.”
Regional Transport Partnership

It is not clear that "smart ticketing" (as defined by the document) includes the way contactless credit/debit cards are used by TfL. The inclusion of contactless credit/debit cards should be clearly stated and made a clear requirement for any system.
It is vital that any organisations representing passengers do so from an unbiased viewpoint - for example, organisations (such as "bus users uk") that are reliant on funding from bus operating companies should not be allowed to participate as "passenger representatives", and in particular passenger representative groups not funded by bus operators MUST be included.”
Individual response

These further points will be used to inform the proposed remit of NSTAB, and in the overall development of smart ticketing policy.

Next Steps

We will now seek Ministerial approval for the recommendations listed in ‘recommendations’ on page four. We will then progress a draft NSTAB terms of reference and framework agreement as part of establishing the body and in preparation for supporting legislation on the matter.

We thank each of the organisations and individuals who took the time to respond to this necessary consultation, and we are grateful for the range of views provided on this topic, which supports the development of the National Smart Ticketing Advisory Board.

Appendix A - list of respondents

The following organisations provided responses:

• Improvement Service
• Scottish Borders Council
• Mobility and Access Committee for Scotland
• Edinburgh Bus users Group
• Chair of Glasgow Smartzone Ticketing Limited and Chair of One Ticket Limited
• The Open Transport Initiative
• Cycling UK in Scotland
• Scottish Borders Council
• Moray Council
• First Bus (Scotland)
• Tactran (Tayside and Central Scotland Transport partnership
• ScotRail
• The Highlands and Islands Transport Partnership (HITRANS)
• Bus Users - Scotland Office
• Transport for Edinburgh
• Strathclyde Partnership for Transport
• South East of Scotland Transport Partnership (SEStran)
• CoMoUK
• Lothian Buses
• Glasgow City Council - Transport Strategy

Three further organisations, a technology supplier, one local authority and one small business opted not to share their response publicly.

Twenty six individual responses were received from members of the public. Twenty-three of these were content for their views to be published openly.

Appendix B - list of suggested organisations for membership

• Academics/thought leaders
• Apple/Google
• ATCO
• Bus operators including First, McGills and Stagecoach
• Business Groups
• Community Councils
• CoMoUK
• Cycling and active travel hires scheme operators (Nextbike)
• Data protection Controllers
• Edinburgh & South East Scotland City Region Deal (Workforce Mobility Manager)
• Glasgow Smartzone Ticketing Limited
• MaaS
• One Ticket Limited
• Open Transport Initiative
• ScotRail
• Scottish Association for Public Transport
• Siemens Mobility
• Society of Chief Officers in Transport Scotland (SCOTS)
• Technology suppliers including providers of Apps/Cards
• The Department for Transport
• The Edinburgh Bus Users Group
• Transform Scotland
• Transport Focus
• Transport for Edinburgh
• Transport Scotland (including specific calls for ferry and rail directorates)
• Traveline Scotland
• Youth Groups/Age UK/Young Scot