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NTS2 Delivery Plan falls short of ambition to protect rights of individuals & advance equality of opportunity

Published 06 January 2022 by Transform Scotland

Transform has published its response to Transport Scotland’s impact assessment of its National Transport Strategy Delivery Plan, noting that the timing of this to be “unusual and unfortunate”, and raising concern regarding the absence of a Strategic Environmental Assessment (SEA) of the Plan.

We welcome the human rights approach embodied in the document, and fully support the stated commitment to adopt a legal framework that protects the rights of individuals and advances equality of opportunity. However, “we feel that the NTS2 Delivery Plan falls somewhat short of that ambition. Transport policy and proposed delivery in Scotland remains significantly skewed towards those that have wealth, assets and an existing high quality of mobility. The balance of spend, both through capital investment and revenue support, while paying lip service to the hierarchy of investment remains stubbornly fixated on a high carbon and largely exclusive transport system. This needs to change if Transport Scotland is to become an active agent for a just transition.”

Our response states that“The point of impact assessments, particularly on those groups with protected characteristics, is to inform policy development and correct any undue bias or inadvertent discrimination before adoption of the policy. To undertake impact assessments after adoption and publication of the policy or plan is a missed opportunity and could lead to the acceptance of a flawed approach or policy in practice when earlier efforts to undertake the impact assessments would have resulted in a more considered understanding of the likely impacts.” Impact assessments should instead be carried out before, or at least in parallel with, the development of policies and plans.

With regard to SEA, Transform’s response “consider[s] it an imperative that all strategic transport policies and interventions now require an SEA and would encourage Transport Scotland to undertake one either in retrospect (as per the current impact assessments) or certainly at the next iteration of the Delivery Plan.”

Our response goes on to consider climate change, air pollution, and the affordability, accessibility and availability of public transport. It makes a number of practical suggestions for action, including:

  • That every local authority should be encouraged to adopt mobility share schemes that cater for a range of incomes and cycling abilities which do not depend on the ability to pay.
  • The widespread adoption of a uniform and consistent modelling tool such as SCATTER, with specific proposals to reduce carbon inequalities in transport provision.
  • The Scottish Government to bring its pollution limits in line with the World Health Organization, following the dramatic world-first coroner’s ruling that the death of 9-year-old, Ella Kissi-Debrah, was caused by air pollution.
  • The acceleration of efforts to decarbonise all modes of travel including bus, rail, ferry and air travel, with clear action plans, and target dates accelerated for the decarbonisation of each mode.
  • Whilst commending the Scottish Government’s decision to introduce free bus travel for the under-22s, for it to also consider wider application of free public transport schemes in certain circumstances, in particular linked to poverty allieviation interventions.
  • The introduction of a national smart ticketing system available to all, building on the success of the multi-modal transport passes issued to COP26 delegates.
  • The establishment of a ‘Fair Transport Commission’ to build on the work of the Fair Work Commissions around the country and working with the proposed Future of Transport Forum. One of the key tasks of the Fair Transport Commission and the Future of Transport Forum would be to set minimum standards for the availability of transport to all communities across the country.