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Scottish Region Policy Group response to the Scottish Executive Consultation on Scotland's National Transport Strategy

The responses below are those of members of The Chartered Institute of Logistics and Transport(UK) Scottish Policy Group who have contributed to the discussion on The Scottish Executive Consultation on Scotland's National Transport Strategy.

The Institute is the professional body for the full range of people who are engaged in logistics and transport. This includes freight and passenger transport operators, government and local government employees, consultants and academics. The consultation is welcome as is its comprehensive nature. Allowing for the breadth of coverage the commentary is readable and informative. The narrative is inevitably simplistic and it might have been helpful for reference to be made to more expansive Executive documents on some aspects. The annexes are excellent and would have been even better if section 10 of annex C had been expanded to identify transport matters reserved by the UK government together with those elements that are determined by the European Union.

The Consultation document relates to devolved responsibilities but the overall strategy should also cover advocacy relating to non-devolved matters. The strategy that emerges should also embrace all aspects of the Executive's and Parliament's powers. In particular planning decisions should always reflect transport policies as well as other activities such as health service activities and education. This does not always appear to have been the case previously. Taking account of our widespread interests we have responded to all of the questions but to be reasonably concise have restricted our response to fundamental points in each case. Annex 1. attached expands on certain aspects; in particular the need for better education relating to transport matters and long term public promotion of the main issues and how they can be dealt with. If elaboration is required on any aspect of our response we will be pleased to provide this. You will of course be familiar with our views on most of the main issues from our submissions on previous related consultations. Taking each in turn:

Consultation Question 1.
Are: facilitate economic growth; promote accessibility; promote choice and raise awareness of the need for change; promote modal shift; promote new technologies and cleaner fuels; manage demand; reduce the need for travel; and promote road safety the right goals for transport in Scotland?

We support all of the goals but how effective they are in delivering the Executive's high level objectives will depend upon the priority or ranking order accorded to each. We support the view that "facilitating economic growth" should be accorded a high priority but it would be helpful if, following analysis of the responses to the consultation, a clear indication is given of the relative importance/priority of each goal. We suggest the following should also apply:

i) promote transport safety; safety is necessary for all modes, not just road safety. Advocacy should apply where the Executive does not have direct responsibilities.
ii) education and information: the public should be made much more aware of the main issues relating to transport, including aspects such as the relative environmental effects and the full costs and risk attached to using the different modes, (see annex for expanded comment).
iii) training: action needs to be taken to overcome the shortage of professional expertise and practical skills in many aspects of transport, (see annex).
iv) holistic approach: all activities of the Executive and other public bodies should incorporate transport needs and implications when considering policies and development. Too often transport aspects are seen as problems to be overcome after fundamental decisions have been taken.

Consultation Question 2.
Do consultees consider that the aim, vision and objectives need to be amended, for example to reflect Scottish Ministers' expectations to see Health Improvement at the heart of Scottish Executive policy. The aim, vision and objectives are wide ranging and all deserve support. They should all reflect expectations at the heart of Executive policy. It should be demonstrable that a holistic approach is being adopted with the aim, vision and objectives amended as necessary to demonstrate linkages to other policy areas providing this can be done in a coherent, comprehensible fashion. Transport should not be considered as a justification on its own but as a means to achieve wider objectives. There could usefully be reference to

i) reducing crime and increasing personal security for those using transport services and facilities.
ii) the use of private finance, taxation and other fiscal policies to assist in meeting transport aspirations also deserves mention, including advocacy where appropriate.
iii) development gain arising from transport enhancement facilitating new property, and commercial and industrial development as well as enhancing the value of existing development. A mechanism is required to ensure that significant beneficiaries contribute to the costs of the improved transport facilities whilst ensuring this is not an unfair imposition when related to competition impacting on private interests from elsewhere in the United Kingdom and the European Union and beyond.

Consultation Question 3.
Are there areas of work in relation to local/regional transport that would merit the national dissemination of best practice examples? If so, what are they and who would be best placed to lead this?

Undoubtedly there will be examples of best practice in areas of work related to local/regional transport which could be transferred and adopted, we have insufficient knowledge to say what and where these are, we suspect there may be relatively few people with sufficient widespread, "across the board" knowledge to capture all best practice. A possible way forward here could be to select one area of work, e.g. real time information in western Europe to ascertain best practice. Part of the problem is that there are so many areas for potential survey that some prioritisation would be necessary.

The opportunity should be taken with the new organisational arrangements to create centres of excellence with specialist expertise in the NTA, RTPs and local authorities made widely available. As well as transport planning and project appraisal this could extend to procurement and implementation, with an holistic approach to embrace all relevant agencies and interests. There should be a reduction in delays which now occur during many stages of the transport development process which a spreading of expertise and experience would help to overcome. The public sector client should approach all initiatives as an intelligent buyer using best practice from the private sector, with easy access to the private sector specialists as required.

Consultation Question 4.
What issues must the NTS address, to ensure that the Strategic Projects Review (SPR) which will follow it is as effective as possible? For example, should the NTS identify key transport corridors, or key types of investment which are most effective at growing the economy to inform the SPR? If so which ones?

It is logical that the NTS should be the driver of the SPR, but the NTS must consider the impact of proposed private sector projects as well as public sector ones e.g. Hunterston Port, High Speed Rail Route and Airport developments. Such developments may well influence the designation of key corridors including cross border ones and will certainly have a positive impact on economic growth. Corridor "protection" within the planning guidelines should be considered in such cases.

It is considered that the main key corridors are already well known, but they should be kept under review in the light of potential developments. It is likely that best results will be achieved by targeting investment at inhibitors to free movement on these key routes e.g. the A8000 or the A74 at Carlisle. Where necessary, with respect to reserved matters, advocacy on behalf of Scottish interests should be made to the appropriate UK government Department/Minister. Advocacy is considered to be vital for the aspects raised in many of the following questions, notably questions 7, 8 and 9.

Consultation Question 5.
Do we have the balance of investment right between spending on new and existing infrastructure and other non-infrastructure activities and between different modes of transport? If not, how should it change over time?

There will always be departmental and modal interests wishing more to be spent for their benefit. It is hoped that the review and the application of the STAG principles in an unbiased manner across all projects will achieve the optimum outcome. It is, however, felt that some investment should be directed to making public transport as seamless as possible particularly rail to bus, but also between bus routes/operators. It is felt that there is too much emphasis on "headline" capital projects and too little on the resulting revenue effects. In particular, the very large payments for PPP/PFI projects may be depriving the existing infrastructure of revenue for maintenance.

Consultation Question 6.
To what extent should transport spending be targeted specifically at areas with significant potential for regeneration? How should transport spending be balanced between regeneration areas and other key areas, such as rural Scotland?

It is appropriate to target investment for regeneration purposes (Hunterston and Ayrshire regeneration align in this respect). STAG would be expected to level the playing field between different locations for investment taking account of social cost benefit as necessary with, perhaps, a weighting for deprived or remote areas.

Consultation Question 7.
What further steps need to be taken in Scotland to facilitate the development of connectivity both by air and sea?

1. Connectivity should not be seen solely as providing direct links between Scotland, the rest of the UK including Northern Ireland and Europe or further afield. It has to be recognised that the freight sector may have different views on this compared to the car driver and views may differ between inbound and potential customers. This will influence the viability of ferry links in particular.

2. Similar considerations between the inbound and outbound customer will apply to air links, particularly where contribution to economic growth is concerned. However, with air travel there may be environmental benefits in direct flights, particularly to main European destinations, compared to travel via London. The air development fund is welcomed in this respect. It may be worth considering whether a single Scottish hub for European flights is a better overall economic stimulus and environmentally more sound (lower emissions per passenger kilometre) than splitting the flights between Edinburgh and Glasgow. For both the air and sea modes, advocacy to Westminster Departments/Ministers in respect of Scottish interests is seen as important.

3. Where development responsibility for infrastructure to facilitate connectivity rests with the private sector, the Executive should ensure that regulatory and planning processes are clearly laid out with minimum bureaucracy. Perhaps a "road map" could be prepared for major infrastructure projects to ensure that most if not all questions are answered prior to planning application. This could reduce time delays and the need for lengthy inquiries, speeding up the process overall if structured in a way that it simplifies the process overall. Where the private sector takes the initiative to support projects the Government should ensure that they play their part by ensuring there is sufficient landside infrastructure investment to facilitate connectivity.

4. The Institute's response to the Consultation - "Proposals for a New Approach to Delivering Public Transport Infrastructure Improvements" dated 19th May 2006 is relevant here.

Consultation Question 8.
Do consultees consider that there are issues relating to cross-border connectivity by rail and road, and within devolved competency, that the strategy should consider?

It is assumed that the Scottish Executive will make representations to the Westminster Parliament in respect of reserved issues affecting Scotland. For example, the SE may make its views known with respect to access charges for the GNER and Virgin franchises and the effect of changes to Network Rail's Regulated Asset Base. It would be appropriate to extend this to rail freight issues across the border, including Freight Facilities Grants, enhanced gauge freight routes and, as mentioned in 4 above, to point out that there is a section of the main road link south at Gretna which is sub-standard for such a link.

Consultation Question 9.
What views do consultees take on whether there is a need for a faster Scotland to London rail service, to provide an alternative to flying in the long term?

Any NTS needs to consider the impact of potential major schemes as indicated in Question 4 above. There are likely to be significant environmental issues arising from expansion of airports (more so in SE England than in Scotland) as well as considering the opportunity cost of diverting airport expansion money to an alternative project which could, conceivably, under common appraisal criteria, show a better return. London should, however, not be considered as the only potential destination. Incremental developments to the rail infrastructure and to service provision could bring journey times between Scotland and the conurbations of Yorkshire, Lancashire and Merseyside, or even the East and West Midlands within the 3 hour time limit seen as necessary for significant business travel.

Consultation Question 10.
How do we ensure that all local authorities spend their Grant Aided Expenditure allocation for local roads on local roads? Do consultees think anything more needs to be done to ensure appropriate management, operation and maintenance of the Trunk Road Network?

If there is under-spending on local roads, there may be a need to review Grant levels against road condition for a significant proportion of local authorities and to reallocate the Grant. The main issue which appears to be neglected is the visibility of both direction and warning road signs which is clearly a safety issue (this applies equally to local roads). A further issue which should assist in mitigating congestion is the implementation of earlier SE proposals to introduce lane charges for utilities road works and improvement in the standards required for reinstatements. Again this also applies to local roads. Our views on these matters are expanded upon in our response to consultation on the new Roads and Street Works legislation submitted some time ago to the Scottish Executive.

Consultation Question 11.
What are the issues relating to the management and maintenance of the road and rail networks over the long term that the strategy should address?

It has already been suggested in Question 4 that investment directed at current inhibitors to free flow should be a priority and in Question 5 that consideration needs to be given to the long run revenue effects of capital schemes. In the longer term, robustness of the infrastructure in the face of climate change may become critical in ensuring that economic progress can continue. For rail it will be necessary to ensure that Network Rail makes the most of potential enhancements arising from the replacement of assets in modern equivalent form. There have been suggestions that NR have resisted the implementation of line speed improvements following renewals which would have allowed the higher speed. There may be reserved regulatory issues which need to be addressed here.

Consultation Question 12.
What should the NTS say about freight, bearing in mind that a freight strategy is under development? In particular, what should the NTS say about meeting the different needs of freight and passengers on the road and rail network, and how to balance these competing demands?

Since the NTS is dealing with transport and its infrastructure it cannot stand aside from the effect of or the provision for freight. A message which may be worth getting across to the public is that cars cause congestion because of their numbers. This may be a vital piece of education to ensure that all road users are seen as necessary. Road pricing with appropriate time banded differentials may be a method of ensuring that freight and passenger have access to the road network at suitable times to meet business and commuting needs. On rail the timetable can be an appropriate regulator with passenger preference at peak commuting times (important if rail is to carry more passengers). Outside peak commuting times paths should be allowed for freight movements including "conditional" paths which may be taken up by any freight train with the appropriate performance at short notice.

Also worth considering is the designation of certain routes as having freight primacy because of the importance to freight of the route or dominance of freight on the route. The Glasgow and South Western route from Kilmarnock southwards is a potential candidate for this treatment with the considerable coal flows from Hunterston to Yorkshire. With the Hunterston container terminal a possibility, this would be even more significant as a diversionary route for the WCML or even as a part of a Continental gauge route from Scotland to the Channel Tunnel. The connectivity and the potential emissions benefits arising from this could be significant not just for Scotland but for a wider area. If Scotland's current and planned transport developments are to figure large in the industrial base overall, then The Executive must give freight movement by rail and road a high priority, especially from major hubs such as ports.

Consultation Question 13.
What, if anything, should the NTS be saying about skills, bearing in mind the leading role that the Sector Skills Councils have in reducing skills gaps and shortages in the public and private sectors and the role Transport Scotland has in promulgating good practice across the industry? Is it right to integrate skills issues into the NTS?

It is to be expected that skills issues will be raised by some operators who have difficulty recruiting staff and it may be appropriate for this to be identified in the strategy if it is a common theme. It is felt that the skills issues should remains with the Sector Skills Councils, but these need to be advised of relevant issues affecting the transport sector.

Consultation Question 14.
Bearing in mind that investment in new transport infrastructure is not covered in the NTS, as it will be addressed in the forthcoming Strategic Projects Review, what specific steps, if any, does the NTS need to set out to support tourism?

Tourism is seen as one of the factors creating demands of the transport infrastructure and networks. Assuming that demand forecasts are robust it is not seen that tourism is likely to have a large influence on peak demands. Where appropriate, tourism demands should be embraced within STAG appraisals.

Consultation Question 15.
What are the key barriers to developing Demand Responsive Transport and how should they be overcome? For example, legislative, regulatory or operational barriers?

We agree expansion of DRT services is critical to improving accessibility. Such services need to be affordable and convenient, both by time and access points. The barriers highlighted in the text are all relevant. More encouragement is required to avoid demarcation in local authorities between education, social work and subsidised local services. There could be greater assistance from the Traffic Commissioner in permitting more flexibility in the routes of registered local services. More professional assistance, perhaps supported by grants for volunteers co0ordinating such services, including shared car initiatives would also help.

Consultation Question 16.
Where are there examples of particularly good practice in demand responsive transport?

Examples which embrace the above and deserve consideration for wider implementation include:

i) The Dyce Transportation Management Organsiation Liftshare scheme where several employers have collaborated in encouraging shared use of private transport with preferential car parking places.
ii) The Strathclyde Passenger Transport Ring and Ride services which cater for those in rural areas who do not have easy access to scheduled bus services.
iii) The Phone and Go service in Northumberland which uses small buses which carry parcels to offset costs.

Consultation Question 17.
Is accessibility planning something that should be considered for local or regional transport strategies in Scotland? If so, should it be compulsory, or (as at present), one of a suite of possible approaches.

Too often transport planning and developments have concentrated on speed of travel by the various modes rather than the complete journey time and convenience of movement of people and goods. This requires easy access both physically and financially to the various modes, good walking and cycling connections and efficient integration with convenient interchange. Such features are essential for good accessibility which should aspire to provide basic standards for everyone, including the less mobile, with efficient use of energy and low cost for users. Accessibility planning for people and goods is a fundamental requirement and should be compulsory for all local and required transport strategies. Such strategies should be holistic with accessibility a prime consideration for activities having significant transport impact, such as industrial, commercial and shopping developments and health, education and tourism initiatives.

Consultation Question 18.
How can we improve the accessibility of public transport to disabled people? For example, how far should concessions be extended for disabled people?

Access for disabled people should be provided in both physical and financial terms. Free concessionary travel by bus is of little value if there is not a convenient bus service or if the bus construction does not permit some disabled people to board it. There should be greater attention to construction and use stipulations, more funding of subsidised bus services to cater for those residing away from commercial routes and more flexible route services. Greater encouragement should be given, with financial assistance where justified to encourage more self-help and volunteer community transport services.

Consultation Question 19.
How do we make sure that transport operators and drivers follow best practice in dealing with older people, with disabled people and other groups who may have difficulties with transport? For example, should it be a condition of funding that such best practice is demonstrated? Guidelines should be given regarding best practice and these should be published on buses and advertised . Elderly and disability groups could be encouraged to report good and bad practice with this made known more widely perhaps by making awards.

Consultation Question 20.
What more could be done through transport means to tackle social exclusion in rural areas?

Demand responsive pilot studies and the Rural Transport Fund show benefits and could be extended with advantage. Relative to concessionary travel funding the costs of such services are not high. To cater for the needs of those who are not elderly or disabled lower standard fares than elsewhere might be justified bearing in mind the longer distance those in rural areas often need to travel for essential services. Greater patronage arising from lower fares could result in a lower average subsidy for each bus user.

Consultation Question 21.
What do we need to consider in reflecting on the future of the lifeline air and ferry network?

In addition to ensuring essential journeys can be made to and from the islands the level of service should also if possible provide a basic level of service to meet standards considered appropriate in modern society. For example a day return passenger facility to the mainland at reasonable cost should be an aim for at least some weekdays in the Inner Hebrides with a similar provision to and from Stornaway, Kirkwall and Lerwick for the outer isles. The present large ships could be supplemented by passenger only vessels, which would achieve this for a relatively small percentage increase in subsidy. There would also be tourism benefits.

Consultation Question 22.
What more should be done to ensure that there are connections from outlying estates to towns and cities?

Criteria should be identified related to the various types of area and the population served in respect of walking distance to bus services and the frequency of such services by time of day. There should be a presumption that this standard would be met in bus quality partnerships and where necessary subsidised local services. Variable route and community bus services should also have aspirational standards. A separate fund could be established to ensure basic standards of social need are met. Special attention could be given to discounted fares and or multi journey period tickets for such areas.

Consultation Question 23.
Are there any specific areas or events in Scotland where transport particularly well or particularly poorly supports access to cultural opportunities? Are there any specific societal groups disproportionately disadvantaged in accessing cultural activities because of transport issues?

Public transport is often not convenient for those attending cultural events. A greater onus could be placed on organisers to ensure that at least a basic level of provision is available. More attention could be given to combined entry and transport tickets with discounts and special services and/or dedicated transport for those attending such events.

Consultation Question 24.
Should travel plans be required of all "larger" employers? If so, how should we define "larger" and should Travel Plans be required of all public bodies such as local authorities and Health boards to show public sector leadership on this issue?

All larger employers should be obliged to produce travel plans and there should be a requirement in such plans to address sustainability. All of society needs to be aware of the need to avoid unnecessary adverse environmental effects and in particular reduce the extent of climate change. The difficulties highlighted in the text should not be used as excuses and travel plans could be incorporated in carbon trading. Employers with more than 100 employees should be considered large but travel plans should also apply for smaller employers. It is essential that the public sector provides a lead, not only for organisations but at more local level for hospitals and schools.

Consultation Question 25.
What should the relative roles of the Executive, regional transport partnerships and local authorities be in increasing the uptake and how might it be ensured that travel plans required of developers under the planning system are systematically enforced?

The Executive should define the approach to be followed with definitive guidance. Partnerships should refine the approach for their areas and ensure proper consistent advice and monitoring. Local authorities should ensure that all travel plans are carried out in accordance with Executive/Partnership requirements, in particular for new developments where an acceptable travel plan should be a pre-requisite before obtaining approval. Sustainability and accessibility standards should be at the core of all travel plans.

Consultation Question 26.
Should we be investing in "smart measures" to promote modal shift? If so, what degree of investment is required; what measures are most effective; and what should be the role of the Scottish Executive (for example, promotion of the concept, sharing best practice, running a scheme or funding others to run a scheme)?

There should be greater investment in "smart measures" to promote modal shift. Such measures should be implicit in education and training regimes and Executive documentation should advertise the relevant characteristics of the different modes and their personal and community impact. The Executive should promote and share best practice. A separate agency might be preferable to run a scheme with funding from operators in addition to the Executive.

Consultation Question 27.
Is there a need for single national travel awareness "brand" that the Executive, RTPs and local authorities could all use? If so, what should it be?

A consistency of approach is desirable and basic characteristics and relevant data could be identified for common use. Each RTP and local authority should desirably have discretion to reflect local circumstances in their own promotions.

Consultation Question 28.
We want to promote walking and cycling as healthy, sustainable ways to travel - what more should be done in this regard?

1. The application of the principles of Transit Oriented Design in urban planning will assist in reducing transport demand and reduce the distances between nodal points to produce journeys more acceptable by cycling or walking.
2. A more usable public transport provision will encourage passengers to walk to/from the public transport network. A consistency in provision of cycle storage facilities at public transport interchanges will also encourage cycling + public transport use as an alternative to car use.
3. Thought requires to be given to reducing the role of the car in the freight distribution chain to encourage both more use of walking and cycling to access retail facilities and to reduce car use for the transporting of goods on their final stage of the journey to the consumer's home.
4. As demonstrated in the Netherlands, extensive use of cycling within the national transport provision can be achieved but at considerable cost in terms of land provision for segregated cycle routes and for cycle parking areas at public places where people congregate (eg, bus/rail stations, places of work, places of entertainment). It is a sad reality that walking : cycling : rubber tyred road vehicle movements do not mix well with each other and each tends to require its own land space. The current provisions for cycling in Scottish urban areas are extremely modest in comparison with the facilities built up over many years in the Netherlands.

Consultation Question 29.
How can the NTS maximise its contribution to improving the health of the nation?

The two main areas for consideration are:

1. Encouraging/enabling less use of private motorised transport and more use of walking/cycling - see Q28,
2. Minimising the effects of transport damage to the environment, particularly in respect of air quality.

Consultation Question 30.
How do we make buses more attractive for people to use, and therefore allow them to make the choice to take the bus rather than using their car? How do we ensure that the quality of the travelling experience is made a priority by bus operators?

1. To make the bus more attractive, particularly to car users, the following steps are felt to be essential:

  • Reliability of service provision must be improved. Two aspects are identified - (i) published timetables must be adhered to and (ii) timetable changes must be limited to certain well publicised dates in the calendar. Anent point (i), local government can assist regularity of advertised bus journey times through the provision and protection of priority routes for buses. For some services, particularly in urban areas use of conductors would reduce delays and deserves consideration.
  • A consistency is required in the level of bus fares across the country.
  • A consistency is required in the stability of route structures offered to the public; post de-regulation, routes can, and do, appear and disappear very quickly, discouraging passengers from basing any aspects of their lifestyle upon transport by local bus.
  • Bus services must be provided when people need to travel; there is an increasing tendency by the dominant operators to withdraw from evening and weekend services.
  • The public need stronger assurances that it is safe to venture out on the streets in the evening; increasingly, the perception has been built up that "yob culture" has taken over the streets, and public transport, particularly local bus, has suffered significantly from this belief.
  • A flexibility in forms of ticketing is required to allow passengers the ability to move around a defined part of the national bus network without the penalty of having to pay again for each separate part of the journey. Scotland's bus operators are now adopting more flexible ticketing modes but some 40 years after such practices became commonplace elsewhere in Europe. In particular more provision of off street ticket purchase facilities would assist in overcoming some of the difficulties outlined.

2. In respect of assuring the quality of the travelling experience, experience with quality partnerships has been mixed and consideration is required of other mechanisms which could ensure the interests of all relevant stakeholders are catered for. Enhancement of resources available to the Traffic Commissioner to enable proper policing of nationally mandated standards and service specifications is required.

Consultation Question 31.
Is there a need for change in how the bus market operates, or are the current arrangements working? If so, what should this change be?

1. As touched upon in question 30 above, the bus market as presently constituted does not meet the expectations of many of those who use them or wish to use them. Amongst the greatest difficulties are the fragmentation of bus service provision and lack of overall direction of transport provision.
2. There is an EU expectation of local transport provisions being opened to market competition and this has been achieved in most countries by franchising individual routes or local networks. This approach has been very successful in London and deserves consideration in Scotland. The critical requirement for the travelling public is a reliable service; who provides the service is of secondary importance and it is of negative value to the public to have a "confusopoly" of competing services at certain times, each with its own ticketing regime, whilst at other times there is at best only one operator, sometimes none.

Consultation Question 32.
How do we make rail more attractive for people, and therefore allow them to make the choice to take the train rather than use their car?

1. Four sets of problems are identified which are seen as detracting from the attractiveness of rail transport:

I. Rail services offer a good coverage of the country but as the population has spread, there are increasing difficulties for potential passengers in getting access to/from the rail network. Having a "barrier free" form of transport, such difficulties are avoided by car drivers. The availability of add-on local bus fares for rail journeys on some routes within Scotland is very much to be commended but such options are not universally available at present.
II. The UK fares structure for rail service is arguably the most complex in Europe and unless it is possible to arrange the journey in advance and to travel outwith peak travel times, the cost can be very high.
III. Whilst there have been welcome improvements in the timekeeping of individual services, the reliability of rail services at weekends has deteriorated as more extensive infrastructure work has been undertaken.
IV. Rolling stock quality is often perceived as unsatisfactory, particularly on main routes between Scottish cities. Whilst early improvement would be difficult, comfort, space and ambience closer to that experienced on cross-country services to and from England should be aimed for. In response to these difficulties, the following options are offered:

i. Add-on local bus fares should become universally available for train fares to all major urban areas in Scotland. The "trein-taxi" concept as developed and extensively applied in the Netherlands should also become part of public transport provisions in Scotland.
ii. The rail ticketing system has to be simplified. One important factor which makes peak hour travel more difficult to provide is the size of the peak demand compared to off-peak; amongst other options to ease this problem, the staggering of working hours should be encouraged.
iii. Support for Network Rail's aspiration to move towards a 7 day railway with no discernible difference for passengers when travelling during weekdays or at weekend.

2. The present personal taxation regime confers advantage to private car use in comparison with the use of public transport; this imbalance must be reconsidered.

Consultation Question 33.
What else should be done at a national level to support improvements in travel information? How do we capitalise on the potential opportunities created by new technologies - such as 3G mobile phones - to improve the provision of travel information?

1. The view is offered that some stability in service provision should be in place before efforts are expended on high-tech methods of communication. The fragmented and sometimes ephemeral nature of bus operations has undermined confidence in the bus timetable as a useful document for the public and this loss must be recovered. As a high priority, the present ability of operators to change timetables at dates to suit themselves must be considered further with a view to, as a minimum, any changes of times or withdrawal of services being confined to a restricted number of dates in the year, perhaps quarterly. This would permit RTPs and/or local authorities to produce timetables at reasonable expense.
2. UK national train times are available through an established telephone number and also via the internet. These same facilities should be available on an area basis for other transport modes.

Consultation Question 34.
Do you consider that action needs to be taken on the cost of public transport fares and, if so, what?

1. Action does need to be taken on the cost of public transport fares, primarily to:

i. maintain consistency in rates of fare across the country for equivalent types of service provided, irrespective of operator.
ii. reduce the present complexity of fares, particularly rail fares.
iii. eliminate the present practice whereby passengers transferring vehicle/mode as part of the journey are treated as if they were making separate journeys for fare calculation purposes.

In response, it is proposed that a national ticketing scheme be established equivalent of the "strippenkaart" system in the Netherlands and other forms of national ticketing commonly found in neighbouring EC countries. Such a system must encompass bus, local rail and ferry operations.

2. Two general points are made on the level of fares:
i. In respect of rail fares, it is appropriate that the Executive understands, and, where possible, reacts to the factors which are adversely and inappropriately influencing the rail industry's costs.
ii. There are indications that fare levels are of increasing concern for rail customers. This reflects controversy highlighted in the recent House of Commons Transport Committee report on both Britain-wide and local fare levels. It is hoped the Executive will quickly utilise its responsibilities to ensure that "regulated" fares are set at sensible affordable levels.
iii. A major barrier to the adoption of a more flexible ticketing system is the attitude of the Office of Fair Trading (OfT); it will be incumbent upon the Executive to respond to any inappropriate influence by the OfT on the utility of Scotland's local transport provisions.

Consultation Question 35.
If you support lower fares, would such reductions need to be funded by tax revenue, or are there schemes which consultees consider could pay for themselves through modal shift (i.e. because more people would be travelling, albeit paying somewhat lower fares)?

1. Where there are sections of the community deemed to be worthy of subsidised transport, thinking particularly of those who are unable to participate in a sustainable manner in the mainstream economy, then the relevant government department must be prepared to bear the costs arising. It cannot be justified that the transport operator has to subsidise the provision of such facilities.
2. Whilst it is likely that a further modal shift from car to public transport can be achieved, it is likely that the transfer will be at the times of the morning and evening tidal flows of commuters to already crowded facilities. For the transport providers to respond to any increased demand will require the provision of additional resources, the cost of which can be expected to exceed any additional income from the fares of new passengers. Alternatives to such new investment are:

  • public acceptance of a higher degree of loading of existing vehicles ameliorated by better design of vehicles for more standing capacity.
  • staggering of working hours to achieve spread of the morning and evening tidal flows over a wider period of time.

Consultation Question 36.
How can we promote integrated ticketing between different operators?

1. A major barrier to through ticketing and the use of the more flexible forms of multi operator ticketing commonly found elsewhere in the EU is the attitude of the Office of Fair Trading. The nature of the public transport business is inherently different from, say, a grocery store, in respect of the nature of the form of competition which the public expects. Experience has shown that passengers will rarely wait long for an alternative bus service provider, should one be available. Moreover, it should be born in mind that in pre-deregulation days the "established" operator was under an obligation to provide an "adequate" level of service on a route and this obligation was actively policed by the Traffic Commissioners. The current legislative barriers to operator co-operation must be reviewed.
2. Whilst the public have been found from past experience both in the UK and overseas to respond very positively to more flexible ticketing, the sharing of financial risks, incomes and expenditures by operators participating in multi-operator schemes can discourage the practice. This difficulty suggests that a transport authority of some nature is required to establish and maintain the ticketing scheme on behalf of the participating operators.

Consultation Question 37.
How do we promote additional modal shift from road freight to rail and waterborne freight?

1. The Executive has sensibly retained the regime of Freight Facilities,Track Access and Waterborne Freight Grants. Whilst some of the easier to justify schemes have already been completed it is considered that there are likely to remain further schemes which will meet the criteria and bring about modal shift. We welcome The Executive's assessment that the administration associated with making claims for these grants has been streamlined but we believe that some still find the process somewhat burdensome. It is therefore suggested that the processes are kept under review so that the number of eligible applications is maximised.

2. It is noticeable that much of the additional freight moving by rail in recent years has been obtained for the railway by the haulier offering the service to the consignor in co-operation with the railfreight provider. It is suggested that the Executive forms a forum representing all freight transport modes to explore opportunities for enhancing co-operation, improving services, and gaining maximum environmental benefit. An ongoing issue is the availability of the service to operators who can only offer small tonnages, being unable to justify a complete train load, as generally required by the FOCs. This should be considered by the forum suggested above. In addition, the forum could also review the overall restrictions on rail capacity for accommodating freight movements. Relevant to this is the recent and ongoing proposal by a group of freight leaders in Scotland that a number of disused and other rail lines be re-opened and connected to form a Scotland - England dedicated freight route. Should The Executive wish to pursue this further, the Institute in Scotland can assist with the relevant contacts.

3. To facilitate modal shift for traffics suitable for sea transport, particularly for UK coastal shipping, The Executive should be reviewing the support for other modes to ensure similar support is available for the appropriate development of this particular form of transport.

Consultation Question 38.
How do we ensure that people are safe, and feel safe, on public transport, at stations and bus stops, and while travelling by foot, bike or car? For example, what needs to be done to tackle anti - social behaviour on public transport and on our roads?

1. Public security is an issue for society at large and it is not reasonable for transport operators to solve this problem, either on their own or in syndicate.
2. Public transport operators must play their part within the community in deterring anti-social behaviour, not only by the readily acknowledged methods of design of vehicles and design of boarding facilities, but also through such initiatives as improved liaison between operators and law enforcement agencies and on-board presence of uniformed staff at key times and key places.
3. It is known from studies in Birmingham and elsewhere that passengers who avoid paying their fare are very likely to be involved in anti-social activities elsewhere in the locality. There can then be a mutual benefit to transport operators and to the communities they serve through a stronger line being taken on fare avoidance.

Consultation Question 39.
Within a UK market, what, if anything, should Scotland specifically do to promote the uptake of biofuels?

1. As demonstrated by the successful conversion to lead free petrol a few years ago, the motoring public can be inspired to adopt a new fuel. The key requirements for such a transition are felt to be:

  • Endorsement by engine manufacturers
  • A network of retail outlets to satisfy demand.
  • A price differential in favour of the new fuel.

2. To test the efficacy of the above approach, the Executive should conduct a trial within one of its own departments which has a vehicle pool.

Consultation Question 40.
Where are the commercial opportunities for biofuels in Scotland? What, if anything, is the role for the public sector in supporting commercial biofuels developments? Are there downsides of an increased biofuel market in Scotland?

1. Biofuel use is being promoted in a number of EU countries, particularly for commercial vehicles. Outwith the transport sector, there may be no technical barrier to the use of bio-fuels in domestic heating systems and in other applications where mineral oil is presently used as fuel.
2. As demand for biofuel increases, there will be good opportunities for production and future development of not only the fuel itself, but also the bio materials required. Scotland has the same potential as other EU countries to make an impact in this future market.
3. The public sector will/should have an important role in providing leadership for the country in:

  • persuading individuals and organisations of the merits in making the change of fuel.
  • where necessary, encouraging investment in the new processes, offering "pump priming" funds where appropriate.

4. In respect of downsides of an increased biofuel market in Scotland, it has to in the long term best interests of Scotland, and elsewhere, to reduce society's current level of reliance on hydrocarbon fuels.

Consultation Question 41.
Within the context of a UK regulatory framework, what more, if anything, should be done to make motor vehicles in Scotland cleaner to run?

1. Enforcement of existing vehicle emission standards is proposed as the first action to be taken in this matter.
2. A greater use of electric traction would reduce exhaust gas emissions in the street; given the different processes available for the generation of electricity, electric traction would help Scotland's endeavours in fuel diversity.

Consultation Question 42.
Where are the potential gains in terms of new transport technology in Scotland? How do we capture the potential economic benefits of developing them in Scotland? What, if anything, is the role for the public sector in supporting the development of such new technologies?

The issues arising from this question are viewed as being identical to those stemming from Question 40 above.

>Consultation Question 43.
What needs to be done to ensure that parking policy - on-street parking, bus and rail park and ride and so on - is more effective in managing demand and promoting modal shift?

1. The ability to leave a motor vehicle for an indeterminate length of time on the public highway has been accepted as a quasi right for the last 100+ years and, accordingly, many aspects of contemporary living having been based on the assumption that such a right is present, and will continue. Changes to this established practice have economic as well as social effects upon society and must be addressed with some care and sensitivity.

2. The view is offered that the purpose of roads is to facilitate exchanges between people and exchanges of goods. It is only since the arrival of personal transport by motor car that roads have also become long term depositories for vehicles and for which use it was the exception rather than the rule that a supplementary charge was payable by the user. As the centres of urban areas were built before the days of the motor car, the road infrastructure was not designed to accommodate such abuse and the result has been the increasing conflict and congestion which society has grown accustomed to.

3. Past parking policy has, at best, sought to divert the problem of excessive demand for parking places "elsewhere", or, has been seized upon by private and public agencies as a means of introducing revenue streams to support activities not always related to parking. One regrettable consequence of the failure to treat parking as part of an overall transport problem has been the encouragement of "out of town" commercial activities; whilst the immediate problem of parking was solved in the urban centre, much additional travel demand was created which public transport was poorly placed to serve and for which the developers paid little contribution.

4. The subject of parking controls must be approached within the National Transport Strategy as a key constituent in delivering an integrated transport system and with an awareness of how parking issues reach far beyond the provision of places to leave a car. In the immediate future, parking policy must be applied such that:

  • the solution of one transport problem is not achieved at the expense of creating more elsewhere.
  • there is a consistency in the application of controls across Scotland.

5. Provision of parking at modal interchange points needs to be adequate to enable travellers to make the modal change from car to public transport. There are frequent examples of travellers who would otherwise use public transport to access city centres having to use the car because the parking at or nearby train stations is already taken. There are several rail stations in Central Scotland where the car parks are full to overflowing for much of the working day.

Consultation Question 44.
How might park and ride schemes best be developed to further encourage modal shift and reduce congestion? How should enhancements be funded and what should pricing policies be?

Park and ride sites need to be sited at strategic nodes and easy to get to and access. Again parking space needs to be sufficient to meet demand. The responsibility for determining the location of sites should be that of the Regional Transport Partnership.

1. Park and ride schemes could best be developed where:

  • urban road congestion relief is required.
  • public transport is capable of delivering additional passenger carrying capacity
  • land is available for a P&R facility at a location which is likely to be viewed with favour by car-users and is convenient for the public transport operator.
  • security is not likely to be a serious problem.

2. Generally, the payment for transport improvements AND their subsequent maintenance have not been given the level of thought which they deserve. In particular, new developments have taken place without adequate thought to how the activities being set up can be accessed in future by its staff, its customers and its suppliers of goods, all of which will create their own additional transport demands. The nation's planning processes must recognise the cost of such transport demands and demand financial contributions from developers as a contribution to the area's transport budget.

3. Enhancements such as park and ride schemes should be paid for by a combination where necessary of contributions from users, transport operators, the community benefiting from the road traffic relief, and road user taxation. It may be appropriate that a reasonable charge be made for the use of the facility but this should not be so high as to discourage usage. A more uniform regime for setting parking charges would allow incentives to be developed for the greater use of park and ride. There may be a case for applying higher charges at facilities situated nearer the cities and cheaper further away.

Consultation question 45.
Should we pilot new approaches to improving demand management on the trunk road network? If so, which approaches should we pilot (for example, bus priority measures, multiple occupancy vehicle and heavy goods vehicle preference, metering, more park and ride) and do you have any views about where and when they should be piloted?

Some demand management measures should be piloted. However in some cases evidence already exists, e.g. the high occupancy vehicle lane in Leeds and shared lorry and bus lanes in cities such as Newcastle and London. A thorough study of these earlier schemes might expedite decision making in some cases. In addition to the technical information gathered by these pilot studies there needs to be sufficient political will to make them happen. For example a shared lorry and bus lane scheme proposed for the north of Aberdeen was abandoned at the last minute because of political nervousness despite all the calculations showing that traffic flow would be improved for drivers of all categories of vehicle. The examples highlighted are generally on non-trunk roads but deserve consideration for trunk road application; perhaps on the soon to be built new sections of the M8 and M80. It would be appropriate for the Regional Transport Partnerships to come forward with proposals.

Consultation Question 46.
Given the difficulties in managing demand for road space by other means, do consultees agree that, in principle, national and/or local road pricing in Scotland could be an effective way to manage demand?

Road pricing could be a way of managing demand but great care is required in the development of the detail of such a scheme. As well as issues surrounding time of day class of road and other geographical and environmental issues there are questions of fairness. For many people the nature of their journey makes it impractical to use public transport. This can be the case even in cities where the provision of frequent public transport is on radial routes rendering some origins or destinations difficult to travel from and to. In rural areas the car is sometimes the only realistic option where the number of trips renders the provision of frequent public transport services uneconomic or impractical.

Consultation Question 47.
Does the Executive need to do more to build support for road pricing? Should there be funding made available to local authorities and regional transport partnerships which wish to promote local/regional road pricing schemes. If so, what model should be used to provide such funding?

Where the Executive considers that there is a viable case for a road pricing scheme in a given area then there is a case for the provision of a pump priming grant to aid the local authority or regional transport partnership but it should be for the party proposing the scheme to make a preliminary case. One issue of concern for vehicle operators is that there should be interoperability between schemes and that no or only one type of special equipment should be required to be fitted to a vehicle for the purposes of recording journeys. In that regard, automatic number plate recognition (APNR) would seem to be a simpler solution.

Consultation Question 48.
What should be the objectives of any future national road pricing scheme? For example:

  • Should it primarily be concerned with cutting congestion levels?
  • Or should it also reflect environmental concerns about CO 2 and other emissions?
  • Should it be a means by which, in Scotland, we try to achieve our aspiration of stabilising road traffic volumes at 2001 levels by 2021 (see Chapter 4)?
  • Should it aim to reflect better the true cost of motoring (including the costs to other people, the economy and the environment), or should it cost about the same to drive overall as at the moment?

The primary objective of road pricing schemes in the future should be the reduction in congestion and greater journey time reliability as a result of the elimination of unnecessary or gratuitous journeys. This will as a side effect have an impact on emission reduction. However the greater reduction in emissions will probably come from continued improvement in engine design and use of greener fuels. Road pricing should be used to assist in meeting road stabilisation aspirations. Whilst initially a cost neutral position might be necessary to gain public acceptance the aim should be to move towards charges which better reflect the true cost of motoring, as the public become more aware of the full extent of these costs.

Consultation Question 49.
If there were no UK-wide national road pricing scheme, should a Scotland-only scheme be considered?

Great care would require to be exercised in the adoption of a Scotland- only scheme in the absence of any similar scheme south of the border. The economic implications of such a move could be severe. Inward and indigenous investment could be discouraged. The production of job opportunities by the development of Scottish ports as logistics hubs which is being considered at present could be severely hampered. Tourism would also be adversely affected.

Congestion in Scotland is generally confined to the main urban areas and initial attention should be directed here. Any wider application in the absence of a UK scheme would need to take account of the above points despite possible environmental attractions. Compensatory benefits to Scottish based hauliers would need to be considered, perhaps taxation reductions, but this would appear to be difficult to achieve with the limited devolved powers. {See also CILT(UK) publication "FRUSTRATINGLY SLOW: road congestion and the Government's plans to deal with it". A Report by the Road capacity and Charging Forum of CILT(UK)}.

Consultation Question 50.
Do consultees support the inclusion of surface transport in any future CO 2 emissions trading mechanisms? What impact could this have on transport's emissions of CO2?

There is a strong case for the inclusion of surface transport CO2 emissions being included in any future emissions trading regime as reductions brought about indirectly are just as valid as direct reductions.

Consultation Question 51.
What more, if anything, needs to be done to ensure that transport considerations are taken into account in the location decision, for example of health services and schools?

Relocation of schools and health service facilities can have a very large impact, real or imagined, on a community and a long term holistic approach must be adopted in any assessments. In the case of schools locations should be chosen where walking and cycling can be seen as the preferred travel mode for the majority. In the case of health facilities, it is suggested that public transport access should be assessed for the facilities which are replaced and equally good or better links should be guaranteed for the replacement facility.

Consultation Question 52.
What contribution can broadband and flexible working practices make to reducing individuals' need to travel? What else should be done to reduce the need to travel?

Home working should be encouraged in the interests of the environment. The Executive should consider possible incentives bearing in mind that in some circumstances flexible working practices can be a mixed blessing. It assists access for some but can make car sharing and use of public transport more difficult.

Consultation Question 53.
We are tackling road safety and are on track to meet our targets. But is there more that should be done at the national (rather than local) level?

Transport safety overall should be promoted rather than road safety as referred to earlier. At the same time the greater risk in travelling by road, in particular by private transport should be highlighted and publicised more. All of the activities outlined have been beneficial and should continue. The much greater risk and lack of improvement in motorcycling should be publicised more.

Consultation Question 54.
What more can be done to make our streets safer and more pleasant places to be?

A basic aim should be to reduce extraneous through traffic and "rat-runs". Greater attention to junction locations, prohibiting turning movements used by through vehicles and traffic management on streets to make through journeys more lengthy and time-consuming could help. This does of course require enforcement as does the increasing use of 20 mph zones, which is supported. The concept of home zones is also supported, with more use of cobbled surfaces, which are often preferable to speed humps.

Consultation Question 55.
What issues should be considered in implementing the NTS following its publication later in 2006?

In addition to the issues and factors laid out in the four bullet-point preamble to the question plus the Strategic Environmental assessment and equality proofing detailed in points 2) and 3) following the question the following issues could be considered:

1] Are there any parts of the Strategy which are "standalone", not "dependencies" of other parts of the Strategy which could be implemented on their own? If there are it would seem sensible to prioritise these for implementation.
2] Four factors : legislative change; further analysis; longer term analysis or research; changes in the balance of investment, have been identified as influencing or affecting implementation.

Another issue likely to have an effect on the implementation of the NTS is the linkages or "dependencies" between different parts of the Strategy, i.e. "before we can do this we need to do that". It would assist implementation if these linkages or dependencies are clearly identified and incorporated into the implementation planning process. The Executive should look urgently at these aspects including the need to resolve problems arising from reserved matters such as taxation.

Consultation Question 56.
Do consultees consider that "traffic intensity" is likely to be a useful overall indicator of our success with the forthcoming NTS? If not, what alternatives would be preferable?

The development of a "traffic intensity of the economy" indicator, particularly considered over time, is likely to be a useful overall indicator provided that its component parts, purpose and indeed shortcomings, are clearly understood and defined.

Consultation Question 57.
Are the indicators outlined for each transport goal useful? If not, what alternative(s) would be preferable?

The idea of setting out performance indicators rather than targets for the Executive's transport goals is welcomed, however it is suggested that once the indicators are in place, there is confidence that the right indicators have been selected and it is considered that the indicators are giving a reasonably accurate picture of what is happening it would then be appropriate to consider setting targets. Taking the indicators outlined in 8-20 incl. it is clear that some, e.g. 9, 18, 19 to mention a few, whilst clearly areas in which indicators would be useful equally clearly require further development.

With regard to 8 certainly measuring different journey times over time(for both passenger and freight) between locations in Scotland would be very useful as indeed would similar measurement of journey times to other parts of the UK and to Europe although the Executive's ability to influence the latter is limited. Rather than go to each indicator individually to respond to the question our response would be, "Yes, the indicators outlined for each transport goal are useful but require further development." It is suggested that this development be undertaken through consultation with the appropriate parts of the transport industry. The Executive may also wish to consider publishing comparative journey times by mode and variations from average journey time, something which affects road much more than rail.

Consultation Question 58.
Are consultees content that the target of quadrupling cycle use should now be reviewed? What, if anything, might replace it (for example local authority-level targets on the DfT model)?

The target for increasing cycle use should be reviewed and despite health and congestion benefits, relate to the accident risk for cyclists. Promotion of cycling should be much greater in traffic calmed areas and where there is special provision. This can best be determined at local level by local authorities who should have discretion to adopt different targets for the different types of area for which they have responsibility.

Consultation Question 59.
Are there other measures which should be considered in Scotland which would move us towards the target to stabilise road traffic volumes at 2001 levels by 2010, recognising that significant fiscal measures would have to be agreed by the UK Government.

It would be desirable to replace the traffic stabilisation target with one that more clearly reflects the environmental and anti-congestion goals. New technology and scope to vary times of travel and movement patterns demand more sophistication and efforts can be wasted in aiming for a headline figure with limited practical effect. The scope for modal shift is greater in some areas than others and different traffic reduction targets are appropriate. This suggests different regional traffic reduction targets would be sensible perhaps with refinement to cover the different types of area in some regions. Road pricing to reflect such differences commands wide support in principle and this should be pursued together with fiscal measures to avoid undue financial burdens. The necessary UK Government agreement should be pursued with regard to the latter.

Consultation Question 60.
Do consultees agree with the proposals to:

Continue to have stabilisation of road traffic as a high level aspiration?

Yes, but with recognition that different parts of the country and nature of development require different aspirations as outlined (Question 59)
Use indicators measuring modal shift to measure now our modal shift policies are working (and)
Redirect our efforts more clearly at the enviromental and congestion issues which underpin the traffic stabilisation aspiration, by:

  • considering new transport-related target(s) for CO2 (see further below); and
  • continuing to monitor congestion trends on our trunk roads as at present, and considering what further measures might be required.

Yes, in respect of both initiatives. The CO2 targets should be complemented by targets related to the different types of toxic emissions which can have more local damaging effects.

Consultation Question 61.
Do consultees have any views on the idea of a move to regional traffic reduction targets in place of a national target?

Yes, as outlined (Question 59).

Consultation Question 62.
Given the difficulties with the national traffic stabilisation aspirational target, do consultees agree that realistic, deliverable milestones towards its delivery cannot be put in place at present?

Targets are beneficial to concentrate attention and appropriate milestones help in raising awareness. Aspirations should be identified at the present time making it clear they could be subject to change.

Consultation Question 63.
Do consultees agree that setting a level of contribution for reductions in Scotland's CO2 emissions which are directly linked to the impact of our policies in areas which are devolved would be the best measure of the Scottish Executive's effectiveness in tackling transport emissions?

In principle separating the effects of action in devolved and reserves areas is desirable but the difficulty in identifying the separate contribution from each must be recognised.

Consultation Question 64.
What specific reduction level(s) for CO2 should be put in place for transport?

We do not feel qualified to specify reduction levels.

Consultation Question 65.
Do consultees have any views about the timing or scope of reviews of the NTS?

The NTS should be reviewed in a consistent fashion with review of Regional Transport Strategies allowing for objective input from the National Transport Agency and Local Authorities. The four level input for overall strategy needs careful attention to reduce repetition and/or abortive work, ensure efficient use of scarce professional staff and permit input from the general public. The review process should also relate to time cycles adopted by the Dept. for Transport in respect of UK developments to facilitate joint interpretations particularly related to cross border movement. A four yearly cycle to coincide with the parliamentary election cycle might be appropriate if other needs can be met.


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