Appendix B - Consultation Responses and Actions
Name/Organisation
Jill Belch
Comment/Feedback
This will help assuage inequalities as most people living along polluting road in lower SIMD and may not even own a car.
Actions
The assessment highlights that actions within the Cycling Framework have the potential to address some of the determinants of health inequalities by reducing traffic and improving access to alternatives. Evidence in support of this is outlined in Section 3.2
Name/Organisation
Withheld
Comment/Feedback
I trust that any new cycle paths will not interfere with local wildlife. Also, I suspect that the local authority will need several full-time litter collectors - as evidenced from the recent pandemic - recreational cycling seems to produce an abundance of litter.
Actions
A Strategic Environmental Assessment (SEA) Screening exercise has been completed and submitted to the SEA gateway. Screening assessment determined that a full SEA is not required of the Cycling Framework. However, Transport Scotland expect all partners to conduct an applicable assessment of environmental impacts associated with any active travel planning or project. There would also be an expectation that any likely significant effects identified through these processes would be monitored proactively at the plan and project level.
Name/Organisation
Withheld
Comment/Feedback
Many policies such as National Planning Framework 4 and others position Loch Lomond and Trossachs National Park as a key green/bluespace destination for large parts of the Central Belt - yet access by active and sustainable transport is currently not available, accessible and affordable by the majority - so is unlikely to be an inclusive destination.
Fully integrated multimodal network approach is required.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
Keep locals informed and listen to their views.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
The Impact assessment confirms that currently, the level of cycling is disproportionately high among white, non-disabled, young-to-middle aged men. The hypothesis that increasing the amount of dedicated cycling infrastructure will particularly benefit under-represented groups needs to be properly and objectively tested: it may be that instead, those who already cycle are the main beneficiaries.
The EqIA needs to recognise that some disabled people find aspects of cycling infrastructure (eg bus stop bypasses) highly problematic.
Actions
Action within the Framework to: “Provide ongoing development and governance of co-produced design guidance, including mitigation of unintended impacts on vulnerable road users and that infrastructure is suitable for non-standard cycles”, has been assessed as providing a positive impact in this regard and recognition of the specific needs of disabled users has been highlighted in the assessment, with specific reference to measures such as bus stop bypasses.
Name/Organisation
Neil Scoffield
Comment/Feedback
Does the assessment include the shortfall in financing for local authorities?
Actions
Funding to implement not directly related to equality impacts, though the action to allocate 10% of the transport budget is included within the Framework.
Name/Organisation
Withheld
Comment/Feedback
It has proved to be a great mode of public transport in more advanced countries, delivering benefits to social aspect of life, health in all forms, local finance , happiness levels , crime reduction and so on. Stop the bureaucracy, deliver quality active infra ASAP & of a good, smooth, quality.
Actions
Final Cycling Framework and delivery plan will set out the priorities for investment over the next 5-10 years.
Name/Organisation
Withheld
Comment/Feedback
Yes, current state of infrastructure is discriminative against families, pensioners, disabled, children and so on.
We need to catch up with Europe, as we are lagging behind at least 30/40 years.
Please deliver smooth, linked up, high quality, well designed, SAFE infra for everyone to enjoy.
Actions
Action within the Framework to: Provide ongoing development and governance of co-produced design guidance, including mitigation of unintended impacts on vulnerable road users and that infrastructure is suitable for non-standard cycles, has been assessed as providing a positive impact in this regard and recognition of the specific needs of disabled users has been highlighted in the assessment.
Name/Organisation
Withheld
Comment/Feedback
Disability and affordability issues should not exclude people being able to cycle. Cycle library would be great. Lots of bicycle and recycling groups would be able to help.
Actions
Actions within the Fair Access theme address access to bikes for a range of people including the action to: Expand access to cycles, including adaptive cycles, e-cycles and cycle share.
Name/Organisation
Withheld
Comment/Feedback
Too much focus on cycling and not enough focus on disabled access and the right infrastructure to support their travel. Let’s get disabled people more easily to their work or holidays and, in turn, that should also benefit cyclists and other road users.
Actions
Actions within the Fair Access theme address access to bikes for a range of people including the action to: Expand access to cycles, including adaptive cycles, e-cycles and cycle share.
Name/Organisation
Withheld
Comment/Feedback
The majority of responses you will get will be from cyclists as it's doing the rounds in cycling chats. The mass majority of people will not even know you are consulting, then you will say you have consulted and got say 80% in favour, it's a tick box exercise, no more equality than fly in the air.
Actions
Noted
Name/Organisation
Jon Jewitt
Comment/Feedback
Why do we need an impact assessment when we know what the impact would be. Look at the Netherlands...! Just look at what they have achieved and copy them. Don't spend half the budget on thinking about what we need to do. Just do it. Spend the money on the ground, not glossy brochures.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
The SEqIA is wholly inadequate and does not appear to have actually involved any people with protected characteristics; this is especially relevant to disabled people. Many (but not all) disabled people find cycling infrastructure problematic for example by reducing parking options and introducing pedestrian/cyclist conflict in shared spaces and at bus stop bypasses. It is also well-established that disabled people, women and some other groups cycle much less than non-disabled men. There is a risk that investment in cycling infrastructure will disproportionately benefit those who already cycle the most, especially non-disabled, professional men.
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here. The needs of disabled users is highlighted in the assessment of the action relating to design guidance development, with specific reference to measures such as bus-stop bypasses. The protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Withheld
Comment/Feedback
The assessment does not seem to have followed through with respect to other users and in particular pedestrians
Actions
Action within the Framework to: Provide ongoing development and governance of co-produced design guidance, including mitigation of unintended impacts on vulnerable road users and that infrastructure is suitable for non-standard cycles, has been assessed as providing a positive impact in this regard.
Name/Organisation
Withheld
Comment/Feedback
Yes, it does not deliver anything for the many and should not impact anyone it will not help. The money needs to be spent on more important things like eating and heating. Stop pretending it's for 'everyones' benefit when it clearly is not.
Actions
Noted
Name/Organisation
Graeme Robertson
Comment/Feedback
These are not in line withbageism and discrimination aims.
Actions
The evidence presented in support of the assessment process suggests older people and children benefit due to emission reduction and helps ethnic minorities who tend to live in more car dependant/heavily trafficked areas, making these safer for active travel improves inclusivity. Potential negative impacts arising from inappropriate design or reduction in consultation has been highlighted in the assessment.
Name/Organisation
Withheld
Comment/Feedback
Equality means seeing more groups involved to keep this fair and inclusive.
Actions
All protected characteristic groups are considered.
Name/Organisation
Withheld
Comment/Feedback
The assessment does not consider the differences between rural and urban areas when assessing social and equality impacts.
Actions
The potential for differential impacts on rural communities has been considered within the ICIA and, the potential for urban centric policies has been highlighted in this respect.
Name/Organisation
Withheld
Comment/Feedback
Has this even taken disabilities in to account? All measures introduced thus far would suggest not
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here. The needs of disabled users is highlighted in the assessment of the action relating to design guidance development and the protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Withheld
Comment/Feedback
It's bizarre that to reduce car usage the assessment suggests that space for cyclists should be increased when cyclists are entitled to the same space as other vehicles. Pripritising cycling discriminates against those who are unable to cycle - hence why it's better to share space instead of aiming for segregation.
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here. The needs of disabled users is highlighted in the assessment of the action relating to design guidance development and the protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Withheld
Comment/Feedback
I haven't read these but my experiences of this type of thing are too fierce disabled people to comply with new schemes rather than asking ALL disabled people what they need.
Until now there has been a thirst to install schemes without much thought about disabled people, their needs or equality laws with an attitude of let's see what we can get away with attitude.
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here. The needs of disabled users is highlighted in the assessment of the action relating to design guidance development and the protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Withheld
Comment/Feedback
There is evidence that cycle training increases the skill and confidence of trainees and may result in increased frequency of cycling after training. However, consideration of the barriers to child cycling suggests that cycle training alone is unlikely to result in more cycling.
Glad to see this point being stated so clearly. Training is probably worthwhile for kids, especially those completely new to cycling, but all the training in the world can't keep you safe from drivers.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
Minor negative effects have been identified in CI.6, CI.8, & CI.11 relating to loss of opportunity for consultation. How will these be mitigated?
Actions
Assessment has been updated to include recommendation that wording be added to protect opportunities for consultation are retained, in-line with Scottish Government Guidance.
Name/Organisation
Withheld
Comment/Feedback
We acknowledge that the SEQIA report has included women and their concerns within their assessment, however it is worrying that women are not actively discussed during this consultation. The SEQIA report states that women are less likely to meet their recommended physical activity levels, and women are less likely to ride a bicycle due to concerns over their safety. Therefore, we must question why a gendered lens has not been utilised throughout the proposed plans, and actively urge the Scottish Government to reconsider.
Actions
Impact assessment shows that proposed actions such as Cl.1 active travel strategies could include policies and infrastructure directly targeted at these underrepresented groups such as segregated infrastructure (Cl.3), supporting Scottish Road Safety Framework (Cl.20) and improved access to bikes through bike share (FA.1)
Name/Organisation
Withheld
Comment/Feedback
The Social and Equalities Impact Assessment is good at highlighting both problems and opportunities that the actions produced could create, the following three comments are worth making.
CI.6 & CI.8 recognise the demands of the blind and partially sighted population, when creating new infrastructure, which can disrupt their known behaviours. Therefore, it is important to do as much as possible in a scenario to make sure that new areas are safe spaces for those with a visual impairment, especially in the dense urban areas where this will be particularly important in order to keep blind and partially sighted citizens safe.
The colour code on CI.13 is wrong, it has been put down as minor negative but is shaded in light green so this should be amended. However, the points made in the section are valuable as safety in rural communities is something that has to be addressed sufficiently.
FA.2 highlights the potential of improving fair accessibility to areas of deprivation to have access to cycling opportunities. It is good to see it highlighted that 40% of low-income households in the UK have no access to a private vehicle. For those that do have access in low-income households, it can be a necessity but a significant financial burden. With the current cost of living, it is important to do as much as possible to increase cycling opportunities for the most financially disadvantaged in our societies.
Actions
The needs of disabled users is highlighted in the assessment of the action relating to design guidance development and the protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Noted.
Name/Organisation
Withheld
Comment/Feedback
Fellows agree that the plan has the potential to tackle inequalities. One Fellow emphasized that most people living along polluting roads located in more deprived areas identified in the Scottish Index of Multiple Deprivation may not even own a car.
Actions
Action point against Cl.7 emphasising pollution exposure and low car ownership among low income groups.
Name/Organisation
Aberdeen City Council
Comment/Feedback
The wording of the actions subject to assessment does not match the wording of the actions in the overarching consultation document. While this is unlikely to impact on the overall assessment outcomes, consistency in the wording of the actions would be expected.
CI.6 and CI.8 – assessment should balance the negative impacts mentioned with the positive impacts to various groups likely to accrue as a result of a speedier implementation of infrastructure.
CI.11 – again perhaps needs balanced with the positive impacts likely to accrue to various groups as a result of a speedier implementation of infrastructure.
CI.13 – ‘Minor negative’ rating does not match the narrative or colour-coding.
Actions
Wording corrected and assessment cross checked against previous order of actions. As noted, the outcome of the assessment is not significantly altered.
Assessment has been updated to include recommendation that wording be added to protect opportunities for consultation are retained, in-line with Scottish Government Guidance, while noting possible benefits of more timely delivery.
Name/Organisation
Mobility and Access Committee for Scotland
Comment/Feedback
The Equality Impact Assessment fails to adequately recognise that some cycling facilities can have a negative effect on some disabled people. Examples of some of the barriers include additional pavement clutter that can be difficult to detect and or manoeuvre around, ‘bus stop bypasses or boarders’ which put some disabled people in the path of cyclists whilst trying to get on or off buses, shared spaces where some disabled people have no traditional physical guidance (e.g. pavements, controlled crossings) to know what areas they are on. Often cycle lanes replace accessible car parking provision for blue badge holders.
The Impact Assessment should explicitly recognise these negative impacts so that they can be addressed, acknowledged and mitigated. The promotion of cycling should not have a negative impact on some disabled people’s ability to navigate their local areas.
Actions
The needs of disabled users are highlighted in the assessment of the action relating to design guidance development, with specific reference to measures such as bus-stop bypasses. The protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Withheld
Comment/Feedback
Disabled cannot ride bikes. The elderly and children cannot ride bikes easy due to balance issues and other limiting factors. The poor cannot afford a bike. Women in most dresses and skirts (nor men in these clothes) can ride a bike without ripping clothes. This policy really only favours able bodied, affluent men in their 20s to early 50s!
Actions
Many actions have positive impacts for disabled, women and low income groups by making cycling more inclusive.
Evidence suggests otherwise for business impact.
Name/Organisation
Sustrans Scotland
Comment/Feedback
We would welcome statistics on race that are specific to Scotland. While the English example gives a good overview of the issues, having Scotland-specific statistics would help in planning.
Sustrans welcomes the recognition that safety is one of the main issues when choosing to cycle, especially for children and young adult. We would also add women as a group particularly concerned about safety when choosing a transport mode. Convenience also plays an important role, with women making a lot more of the last mile journeys and multi-stop trips.
Regarding the ETROs change process, we absolutely recognise that this needs to account for disabled people’s needs. We would like to highlight that an ETRO process where the changes can be made quickly will benefit disabled people as changes can be done rapidly to accommodate their needs.
Regarding socio-economically disadvantaged groups, studies have shown that the main way to change transport habits is access to affordable and reliable public transport. The integration of active travel infrastructure with public transport is key to encourage people from low-income households to cycle.
Actions
Evidence gathered to support the assessment, and reference within the assessment table, are UK-based and, wherever available, specific to Scotland.
Noted, this is referenced in the evidence review in Section 3.1.
Assessment has been updated to include recommendation that wording be added to protect opportunities for consultation are retained, in-line with Scottish Government Guidance, while noting possible benefits of more timely delivery.
Noted, this is referenced in the evidence review in Section 3.2.
Name/Organisation
MRC/CSO Social and Public Health Sciences Unit
Comment/Feedback
25.1 Numerous socio-demographic factors are associated with physical activity levels. Currently, this impact assessment lacks consideration of sexual orientation, gender identity, or occupation. The PROGRESS-Plus framework, as applied to physical activity (e.g. Rigby, 2020), may be useful to consider the different strata against which to base this impact assessment.
Actions
The methodology outlined in Section 2.4 ensures that each action is checked against potential impacts on any relevant groups/populations. The assessment also highlights that actions within the Cycling Framework have the potential to address some of the determinants of health inequalities by reducing traffic and improving access to alternatives. Evidence in support of this is outlined in Section 3.2. The PROGRESS_Plus framework is noted as a useful reference in cross checking the assessment.
Name/Organisation
Withheld
Comment/Feedback
To be effective the SEQIAs must hold significant weight in the process and their implementation must be regularly reviewed to ensure that their intention of ensuring equitable access and no discriminatory impacts is being delivered.
Actions
Noted
Name/Organisation
Withheld
Comment/Feedback
How will the draft Social and Equalities Impact Assessment consider whether the Active Travel interventions have delivered water resilience?
Actions
A Strategic Environmental Assessment (SEA) Screening exercise has been completed and submitted to the SEA gateway. Screening assessment determined that a full SEA is not required of the Cycling Framework. However, Transport Scotland expect all partners to conduct an applicable assessment of environmental impacts associated with any active travel planning or project. There would also be an expectation that any likely significant effects identified through these processes would be monitored proactively at the plan and project level
Name/Organisation
Withheld
Comment/Feedback
We note that disabled people are more likely to express concerns about the impact of cycling infrastructure on their ability to travel safely, in particular by walking/ wheeling and when using public transport. We would like to see consideration of the particular importance of considering and including disabled people both as cyclists and otherwise when planning infrastructure and investment.
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here. The needs of disabled users are highlighted in the assessment of the action relating to design guidance development and the protection of consultation rights has been asserted under the actions relating to changes to the TREO/ETRO and compulsory purchase actions.
Name/Organisation
Edinburgh Access Panel
Comment/Feedback
Please ensure protected characteristics groups are involved in developing impact assessments and the assessments are published.
Actions
The assessment has drawn on consultation from a wide range of stakeholders and the public, including the feedback provided here.
Name/Organisation
Kenneth law
Comment/Feedback
You are not taking the impact that this policy will have on our elderly people into consideration. It is unfair that elderly people will just have to like it or lump it.
Actions
Measures to improve cycling will positively impact on traffic noise and air pollution and connections to public transport (older people more vulnerable to this) in Cl.4, Cl.17, Cl.18, ER.1, FA.3, FA.4, TE.1, NPM.1)
Action Cl.20 improving safety will remove a barrier older people feel towards cycling.
Name/Organisation
Withheld
Comment/Feedback
As a regular cycle commuter (over the age of 56) I am not surprised by the evidence of vulnerability to traffic as cars have been allowed to dominate for too long in the UK and this has had a particularly nefarious effect on the economically disadvantaged. For the physically disadvantaged, segregated cycle paths offer more travel options and this can be observed in The Netherlands. It is a sad reflection on our society that cycling has become the preserve of middle-class/income youngish men, and this has to change. Cycling has to have advantages over driving and given priority where possible, for example the negation of one-way streets/roads for cycles and lights which allow faster departure for bikes at crossings.
Cycling reduces expenditure on buses, which have become expensive in my city and cycle maintenance could be taught at schools and colleges to make cycling more affordable too Cycle storage is very important for older groups who often lose strength with age. In Scotland, due to the prevalence of tenements, no bike storage often means carrying your bike up a staircase at the end of your journey. This is challenging for any group with less upper body strength.
Rural roads are just too frightening for me, and this means I cannot visit a friend who live in the countryside. The distance is not a problem, but the speed and proximity of the cars is. There is too little cycle parking in the suburbs, so nowhere to secure your bike when visiting a friend.
Actions
Action Cl.3 states cycling infrastructure in every town and city will be "separate from traffic" with positive impacts on inclusivity and feeling of safety for vulnerable groups.
Action TE.1 is a comprehensive cycling training programme with positive impacts on currently low cycling groups.
Action Cl.10 is for appropriate cycling storage for every household.
Action Cl.13 is designation of quiet roads/cycle friendly roads in rural areas.