MACS Response to the Islands Connectivity Plan - Strategic Approach Paper and Vessels and Ports Plan - May 2024

Consultation Identifier Questions

Question 1: Are you completing this on behalf of yourself or an organisation?

Organisation

Question 2: If an organisation, please list below

MACS is a non-departmental public body. Our strategic remit is:

• To give Scottish Ministers advice on aspects of policy, legislation and practice affecting the travel needs of disabled people.
• To take account of the broad views and lived experiences of disabled people when giving advice.
• To encourage awareness amongst disabled people in Scotland of developments which affects their mobility, choices and opportunities.
• To work closely with SG and ensure our work programme complements the work being undertaken by the Inclusive Mobility and Transport Committee (IMTAC), the Disabled Persons Transport Advisory Committee (DPTAC), the Scottish Human Rights Commission, the Equality and Human Rights Commission and other organisations, voluntary and statutory.
• To promote the travel needs of disabled people with designers including transport planners and operators so that these are fully taken into account in the development of vehicles and infrastructure and delivery of services.
• To monitor and evaluate the effectiveness of our work against the above aims and objectives in improving travel opportunities for disabled people in Scotland.

Question 3: What statement best describes your living situation?

I live on a Scottish island or peninsula the majority of the time

Question 4: If you live on a Scottish island or peninsula, please comment below which one

Isle of Lewis

Question 5: What age category are you in?

• 22 to 34
• 35 to 44
• 45 to 54
• 55 to 59
• 60 and over

 (These selections cover the age groups that make up the MACS committee.)

Question 6: Are your day-to-day activities limited because of a health problem or disability which has lasted, or is expected to last, at least 12 months?

MACS is responding to advocate the needs of disabled people. As such our response reflects disabled people whose day to day activities are limited because of a health problem and/or disability which has lasted or is expected to last more than 12 month under both the descriptors of “Yes - limited and lot”, and “Yes - limited a little”

We would also stress the need for an approach that embraces the Social Model of Disability in that it is the environment, infrastructure and service design that disables and limits people and not their disability.

Yes - Limited a lot

Yes - Limited a little

Question 7: What do you mainly use the ferry services for?

All of the above

Question 8: How frequently do you use the ferry services?

Occasionally

Main Consultation Questions

Themes, Vision and Priorities

Transport Scotland has gathered feedback from previous workshops and consultations to identify priorities for the future of Island transport connectivity: ferry networks, supported by the integration with other transport services. This information has contributed to the development of themes, which are the focus for the Islands Connectivity Plan.

The following key themes emerged:

• Community voice and transparency
• Reliability and resilience
• Accessibility
• Timetables, unplanned and essential travel
• Integration of services
• Capacity and demand
• Freight
• Vessels and ports
• Low carbon and environmental impact
• Ferry fares
• Local authority services

Question 9: Do you think these key themes capture the main aspects of transport connectivity for island and peninsula communities?

Yes

Please explain your answer.

MACS agree those key themes capture the main aspects of transport connectivity for island and peninsula communities. Integration of services must involve transport service providers working in partnership to deliver a fully accessible and reliable timetable of onward travel links that passengers have confidence in.

MACS also feel that the themes looking at Timetables, unplanned and essential travel and Integration of services need to link and underpin the work focusing on “onward connections” and developing accessible and sustainable public transport models and inclusive active travel initiatives to and from ferry ports.

Based on feedback and discussions with key stakeholders and drawing on Scotland’s National Transport Strategy 2 and the National Islands Plan, we have developed a draft vision and associated priorities for ferry services, supported by other transport services.

Draft Vision

Scotland’s ferry services, supported by other transport services, will be safe, reliable, affordable and inclusive for residents, businesses and visitors enabling transport connectivity, sustainability and growth of island and peninsula communities and populations.

Draft Priorities

Priority 1: Reliable and Resilient

Reliable and resilient ferry services that meet the needs of communities and businesses and support the transition to a well-being economy, which is fair, green and growing.

Priority 2: Accessible

Ferry services that are accessible and provide easy to use and affordable transport connectivity for all users. 

Priority 3: Integrated

Ferry services that enable sustainable and active travel choices which support our health and well-being and make our Island and other ferry dependent communities great places to live, work and visit.

Priority 4: Low Carbon

Ferry services that take actions to reduce the negative environmental impact of their operations and help to achieve Scotland's net-zero targets.

Question 10: Do you believe the draft vision captures the aspirations of island and peninsula communities for their future ferry services?

No

Please explain your answer.

MACS would also like to see the word ‘accessible’ included in the draft vision. ‘Inclusive’ refers to many different types of people and treating them all fairly and equally but we feel it doesn’t go far enough to demonstrate a firm commitment to improving accessibility for disabled passengers, through carrying out modifications to vessels and ports, providing equipment and improved support (and disability awareness/equality training) from crew and ticket office staff.

Question 11: Do you think the 4 draft priorities reflect what island and peninsula communities see for their future ferry services?

No

Please explain your answer.

We believe these 4 draft priorities reflect what communities wish to see but doesn’t necessarily reflect what they do see for their future ferry services.

The lack of investment in ferries over many years has had a detrimental effect on all Scottish islanders and peninsula communities and they have little or no confidence in the service.

We look forward to seeing a number of new vessels coming into service over the next few years and would expect to see a massive improvement, particularly in accessibility, reliability and resilience.  We do have concerns that the delay in delivering the Glen Sannox and Glen Rosa will be reflected in the standard of accessibility on board the vessels, given they were at design stage around 10 years ago and accessibility expectations are now much higher than they were at that time.

Community Voice and Transparency

We acknowledge the importance of empowering community voice and transparency in communications. The current methods of engagement that are used by operators to inform communities are through email and webpage updates, with further communications shared through relevant Ferry Committees and Transport Forums.

Local authorities and Scottish Government/Transport Scotland use engagement methods such as through project reference groups, stakeholder groups and webpage updates.

However, we have heard from communities that more can be done to take account of their views when it comes to decisions on ferry services and that there is a lack of clarity on how decisions are made.

Question 12: Are there other ways of engaging with communities and stakeholders that would benefit types/decision making on ferry services, including vessels and ports projects?

Yes

Please explain your answer.

Customer questionnaire surveys could be improved to gather more specific information from passengers, including those requesting assistance at the time of booking. This would provide a channel for disabled passengers to feedback on issues affecting them as well as supplying service providers with the evidence required to support improvements, particularly for any actions dependent on funding bids.

There is a network of Community Associations, Access Panels, Local Land Trusts and Community Hubs throughout Scotland, working closely with their communities.  They are a great way of connecting with community groups and engaging with the people most reliant on ferry services.

Accessibility

We propose introducing an Accessibility Standard that would be in addition to the legal requirements and could act as guidance for all ferry services. This is to ensure that our ferry services, vessels and ports are easy to use for all, while recognising that people have different needs and capabilities.

The Standard could include standards such as inclusive and disability training to be carried out frequently and an accessibility review carried out periodically on ferry services, ports and vessels.

Question 13: Do you think an Accessibility Standard is a good idea?

Yes

Please explain your answer.

MACS welcome this initiative to introduce an Accessibility Standard. 

As well as benefitting disabled passengers, it will assist passenger-facing staff and crew by giving them a better understanding of disabled passengers needs and the ways in which they can support them.  

For this to succeed and be effective, the standard must be consistent across the network. Key stakeholders should be consulted in the development stage of the Accessibility Standard.

MACS would welcome the opportunity to engage as the standard is being developed.

Question 14: What do you think should be included in this standard?

Please explain your answer.

• Consistency across the network with Concessionary Fares
• Passengers requiring a travel companion should not have to justify the reason they need a companion. This is an invasion of privacy.  The fact that they have been issued the card should be evidence of the need. MACS would like to see free companion travel introduced on ferries as standard.  This is being piloted on rail services, available on concessionary travel by bus and should also apply to other modes of travel.  More so with ferry travel as you cannot travel to an island by rail or bus.
• Priority boarding for passengers requiring assistance.
• Disabled passengers with concession cards should be able to get their tickets in advance like regular ticket holders and have the option to acquire a return ticket if required.  Having to go into the ticket office on every journey causes unnecessary stress, adds barriers in terms of accessibility and promotes an unequal service design model i.e. disabled passengers can’t access the same benefits as non disabled passengers.
• Crew should be on hand at lifts for passengers requiring assistance to ensure they are seated as close to the lift and other facilities as possible.
• Seating areas should be reserved to accommodate the disabled passengers sitting beside their companion. These seats should have flexible and not fixed armrests.

Reliability and Resilience

Community feedback highlighted that the reliability and resilience of ferry services needs to be seen as a priority due to the impact on communities, businesses and visitors when ferry services are disrupted.

Question 15: Do you agree or disagree that the first priority of the Islands Connectivity Plan should be to improve reliability and increase resilience of ferry services?

Disagree

Please explain your answer.

MACS agree that reliability and resilience should be the main priority.

Islanders have lost confidence in the service following a prolonged period of disruptions and cancellations due to technical issues with an ageing fleet and weather disruptions.

These disruptions are particularly distressing for disabled passengers when they get stranded and need to find accessible accommodation, often at short notice. Medical and care plans are also impacted, often involving several carers.

A reliable service would benefit the wellbeing of patients travelling to access healthcare at mainland hospitals. Fear of missing appointments is a real concern, and patients are often travelling earlier to ensure they are on time for appointments and treatment.  This incurs emotional and financial costs for that individual during an already difficult time.  They may be off work long term and have a compromised immune system which makes them more susceptible to complications arising from minor illnesses contracted from other passengers. 

A separate room for compromised passengers who are travelling for healthcare – such as those travelling for surgery and cancer treatment, would be ideal.

Timetable, Essential and Urgent Travel

We are aware that as ferry travel has become more popular, some services have become more difficult to accommodate short-notice spaces for essential vehicle travel by island residents and key workers.

Question 16: Do you have any suggestions as to how the booking process could release vehicle space on services when island travel with a vehicle is essential?

Please explain your answer.

MACS would suggest holding back up to five vehicle spaces on larger vessels and one or two on smaller vessels, during high season on the most popular routes.

Priority for those spaces should be for the following passengers:

• Patients travelling for health care and their escorts.
• Bereaved families.
• Family members visiting patients in mainland hospitals or care homes.
• Key workers.
• Disabled passengers.

Integration of Services

Journeys on our ferry networks are often only part of a longer journey between the traveller’s ultimate origin and destination.  The end-to-end journey can combine the use of several transport modes, which can include public transport and/or active travel (walking, wheeling, and cycling) or a private vehicle. An integrated transport network that allows easier transition between the ferry and public transport or active travel is a key enabler to encourage the use of our ferry networks without the need for a private vehicle. This has benefits to the user such as making the transport system more accessible, making better use of capacity on ferries and contributing to net zero.

Question 17: What would encourage you to use public transport or active travel as part of your overall journey when using the ferry services?

Disabled passengers may require additional equipment such as mobility aids and medical equipment. It is therefore often necessary to travel by private car. 

Cycle hire options at ferry terminal or close by transport hubs offer cycle hire but to date there is an absence of non standard cycles to hire i.e. trikes, tandems, mobility scooters.  This designs disabled people out of hire schemes, which are often supported by public funding and excludes them from choosing active or sustainable travel options.

Transport providers need to coordinate their timetables in order to meet the needs of passengers. Transition from one mode of transport to another should be safe, seamless, accessible for all and well signposted to assist with wayfinding, including tactile wayfinding. Passenger assistance between modes should be available as needed.

The additional time for some disabled passengers and older passengers to transfer between modes needs to be factored into cross modal timetabling.  Another concern is the lack of flexibility shown by bus companies in the event of the vessel being delayed. Passengers can be stranded at a port for hours until the next timetabled bus arrives.

Capacity and Demand

We have heard that the space for vehicles on busy ferry routes fills up quickly at popular times, especially in summer. This makes it difficult for residents of those islands, and visiting key workers, to travel with a vehicle at short notice. 

 We propose to address ferry capacity issues by:

• Using refreshed community needs assessments to identify different options for service frequencies and vessel size.
• Collaborate with operators and communities to identify ways of using existing and planned capacity better.
• Identify the key “pinch points” on the Clyde and Hebrides Ferry Service and Northern Isles Ferry Service networks and consider options for additional vehicle capacity where this is practical, beneficial, and affordable. 

Question 18: Do you agree or disagree with this approach to dealing with ferry capacity due to increased demand? 

Agree

Please explain your answer.

Shortage of deck capacity is not a new issue; this has been impacting on islanders lives for a long time. Disabled passengers find it particularly difficult to travel during these busy periods, particularly when they are last to board the vessel -depending on the location of lifts on the vessel. Accessible seating is limited, vessels are crowded – making it difficult to move around, and there are likely to be long queues for the cafeteria. MACS would like to see priority boarding at all ports for passengers requiring assistance.

MACS agree with this approach to dealing with ferry capacity and would like to see this assessment undertaken as a matter of urgency. Solutions, once identified, should be implemented as quickly as possible.

Freight

The Scottish Parliament’s Net Zero Emission Transport (NZET) Committee recommended reconsideration of wider policy on the provision of freight capacity on our ferry routes; and the point at which profitable businesses should no longer be reliant on public subsidy of their freight costs.

Question 19: In what way do you think the costs of island freight transport could be shared differently between users and public funding?

Island communities would cease to exist without lifeline freight services.  Citizens Advice Scotland reported on ‘The Postcode Penalty’ in 2012. The report highlighted the excessive delivery charges applied to some Scottish postcodes, including island and peninsula communities.  Some retailers refuse to deliver to Scottish Islands - disadvantaging the estimated 100,000 people who live in island communities. Delivery to these postcodes also take much longer than mainland Scotland – nothing has changed since the report was published.

As mentioned earlier, freight to island communities is a lifeline service. Haulage companies provide employment for a large number of people, enabling them to live and work on the islands -  companies have to be profitable in order to provide sustainable employment.

MACS would be concerned that a reduction in public subsidy of freight charges would see the already excessive charges increase and be passed on to island customers.   25% of working-age disabled people earn less than 50% of the median income, compared with 13% of non-disabled working people, higher delivery costs would severely impact their wellbeing.

Another concern is for CalMac’s flagship vessel MV Loch Seaforth which is operating round the clock, providing an overnight freight service in addition to its twice daily passenger service.  The vessel is now 10 years old and isn’t due to be replaced until phase 4 of the ICP 2036 -2045. This is a route already severely affected by lack of deck capacity during peak times, with numbers set to increase in years to come.

Vessels and Ports

To renew the vessel and port assets, required for the long-term sustainability of our current networks, prioritising where to invest is required due to budget constraints in the current financial environment. We are proposing that the following factors are taken into consideration when making decisions on prioritisation:

• The sustainability of ferry services by maintaining and increasing reliability and resilience.
• Ferry routes and services providing the primary transport connection for people, goods and services required for the sustainability of each community.
• Those communities identified as at greater risk of depopulation and economic decline.

Question 20: Do you agree or disagree that these are the right factors to consider when making decisions on prioritisation?

Disagree

Please explain your answer.

Decisions on prioritisation need to reflect on all aspects of island life, be it for business, residents, potential residents or visitors.

MACS believes in a Scotland without the barriers that isolate and exclude disabled people from making their choice of successful door to door journeys.

Our work promotes the importance of specific issues in reducing inequalities (a key pillar of the NTS2) to provide a public transport system that aligns with the Triple A check produced by MACS - that public transport is:

• Available
• Accessible
• Affordable for all

Question 21: Currently the factors above are not ranked. Do you think they should be?

Yes

Please explain your answer.

A sustainable ferry service - maintaining and increasing reliability and resilience, would go a long way in addressing most of the current issues. Additional investment is urgently needed to bring ferry services up to the standard required.

Low Carbon and Environmental Impact

A Strategic Environmental Assessment will be carried out on the of the Islands Connectivity Plan.  This process aims to ensure environmental and sustainability aspects of the Plan are captured and considered in the development of policies and plans detailed in the draft Islands Connectivity Plan.

Question 22: What environmental issues do you believe should be captured in the Strategic Environmental Assessment in relation to this plan

Please explain your answer.

While many disabled people will be keen to contribute to environmental targets, many will also be sceptical about, or indeed hostile to, proposals to significantly reduce private car kilometres. The experience of many disabled people in recent years has often been that restrictions on the use of cars, for example to accommodate pop up cycle lanes and wider pavements, has made their lives more difficult (see for example Spaces for People). We would welcome an assurance that "access [will be] maintained for those who may need to use private vehicles as a result of their disability”.

It is essential to consider the needs of disabled people when assessing environmental impact to avoid inadvertently disadvantaging disabled people who rely on private car travel (as driver or passenger).  Also, in order to maximise public support for the overall goal of reducing traffic, which will be severely undermined if it is seen to discriminate against disabled and older people.

Disabled passengers often require additional equipment such as mobility aids and medical equipment. It is therefore necessary to travel by private car.  They should be a priority group for securing deck space on ferries.

The Scottish Government committed in the Climate Change Plan to 30% of the ferry fleet, owned by Scottish Government, to be low emission by 2032. The Scottish Government is committed to looking at how we can use hybrid and low carbon energy resources for the fleet, which is currently taking place through the small vessels replacement programme.

Question 23: Do you have any other suggestions in how ferry services can contribute to the reduction of carbon emissions?

Please share your views.

We agree that ferry operators are doing their utmost to reduce their carbon footprint on board vessels and at terminal buildings. Their carbon footprint will be reduced further as older vessels are replaced.

Dependable, accessible onward travel links would encourage more people to travel without their cars.

Ferry Fares

The Road Equivalent Tariff (RET) system of fares is in place across the Clyde and Hebrides Ferry Service (CHFS) network for passengers, cars, coaches and small (under 6 metres long) commercial vehicles. A different fares structure remains in place for the Northern Isles. 

A key aim of RET was to allow ferry users to pay a fixed element plus a rate per mile travelled, which is linked to the cost of the equivalent journey length by road in a private vehicle. RET also resolved many previous issues of complexity in the fares offering and fare-inconsistency across routes, within the CHFS network. 

The 3 key principles of RET are:

• Simplicity and Transparency - the basis for fares must have an established rationale and simple for a user to understand.
• Comparability and Consistency - the basis for fares should be the same for each community.
• Public Sector Affordability versus Community Sustainability - fare-setting needs to balance the different requirements of public sector affordability with sustaining communities.

Question 24: Do you agree or disagree with retaining the current RET principles set out above, as the basis of a ferry fares structure?

Disagree

Please explain your answer.

Initiatives that standardise and simplify fare structures and welcome. This also provides a consistent approach to pricing across the CHFS routes. Island communities campaigned tirelessly to secure RET, therefore any changes would have to be carefully considered and widely consulted on, to ensure they do not impact negatively on island communities.

Introducing different levels of fares such as “islander fares” on Clyde and Hebrides Ferry Service routes, could increase overall fare revenue and keep services more affordable for islanders.  It could also allow use of different fare types to tackle overcrowding of vehicle-deck capacity, on busier sailings through the year.

Question 25: Do you agree or disagree with the option to create different levels of fares for different types of users, e.g. islander and non-island residents.

Yes

Please explain your answer.

This approach would align with the affordability element of a public transport system that is safe, available, accessible and affordable.

Evidence shows that it is more expensive to live on our islands and transport costs are significantly higher (and as such equate to a higher proportion of the household income). Any measures to make travel more affordable for island communities is welcome.

Question 26: Which of these groups do you believe should be eligible for islander fares?

• Permanent residents
• People who work, but do not live, on islands 
• Service providers 
• Nominated friends & family

Question 27: Do you agree or disagree with a fares structure that both encourages passengers to travel without a private vehicle and incentivises travel at quieter periods?

Agree

Please explain your answer. If other, please add further information.

We agree to this in principle but would caution against increasing costs for disabled passengers who need to travel by car (adaptions to car, travelling with medical or mobility equipment etcetera). For many disabled people their car is their mobility aid.

Public transport from ferry terminals is currently unreliable. Timetabled services have no flexibility, leaving passengers stranded in the event of a delay. Disabled passengers need to plan journeys around their care needs and be fully confident that their needs can be met in the event of a delay or cancellation. Public transport is therefore a last resort.

Passenger assistance is inadequate. Disabled passengers travelling solo can struggle with boarding methods, particularly when the linkspan is out of use.