Submission from the Confederation of Passenger Transport Scotland, 8 February 2022
CPT Scotland facilitates a dynamic bus and coach industry to provide better journeys for all, creating greener communities and delivering economic growth. We do this by representing over 100 members in Scotland from across the industry be they large or small, bus or coach, operator or supplier. We campaign for a supportive policy environment, give our members practical advice and support to run their businesses safely, compliantly, and efficiently, and bring the industry together to share ideas and best practice. We’re ambitious to make things better for passengers, inclusive in seeking out different perspectives, and we’re always there when our members need us.
We are delighted to be giving evidence to the Committee on NPF 4 on Tuesday 8 February.
CPT has no specific expertise in planning but the planning framework is of critical importance to the bus and coach sectors, given the role that public transport plays inconnecting communities, providing accessible travel links, and opening up access to facilities, services, jobs and education.
Broadly speaking, CPT Scotland welcomes the content in NPF4.
It is worth highlighting that the Bus and Coach Sectors already contribute to all four of the 'place' models.
sustainable places: bus already provides a sustainable transport option given one full bus can replace up to 70 cars on the road. Operators are investing heavily on meeting Low Emission Zones targets and the sector as a whole is responsible for less the 5% of road transport emissions. The green credentials of bus will only increase as bus decarbonisation continues, with operators already investing over £100m in zero emission buses in the last two years.
liveable places: Bus already provides key sustainable transport links to services and facilities and will do so between 20-minute neighbourhoods. Increased bus use, alongside reduced car use, will reduce congestion on our streets, which would not only make bus travel quicker and more reliable, but it will also make our streets safer, reduce noise and air pollution, and make our communities better places to live.
productive places: Bus connects people to work and education. Many people already rely on buses to get to education and work. By expanding bus use and making it more attractive and affordable, more people will be able to access employment and training in a sustainable way.
distinctive places: Coach tourism creates access to our natural world and heritage and already plays a role in enhancing our natural and cultural heritage by increasing investment through tourism and creating new rural opportunities.
Access to a reliable and affordable mode of public transport allows people to have a choice on where they live, where they work and how they travel.
CPT Scotland broadly agrees with the linking of NPF4 with the Strategic Transport Projects Review (STPR) 2 and noting the priorities of the latest National Transport Strategy, specifically the sustainable transport hierarchy. If the Scottish Government is to meet its very ambitious targets regarding transport decarbonisation, and most importantly modal shift away from car, it is vital that all aspects of government policy are pushing in the same way.
NPF4 sets the framework for delivering the ambitions of STPR2. We believe buses will play a vital role in a number of these projects and it is important that NPF4 recognises the need to facilitate the access and use of buses within these plans. We are pleased to see public transport prioritisation in NPF4 and broadly welcome the contents of NPF4 that relate to Sustainable Travel, most specifically:
Action 25 of Action Areas which states-
our low-carbon future will depend on supporting modal shift and reducing car use, and that public transport, including the bus network, will play an important role in decarbonisation and developing innovative solutions and linkages to the rail system.
Policy 10 Sustainable Travel where key directives are being proposed including;
Not supporting planning applications at locations which would increase reliance on the private car or would involve walking or wheeling more than 400m to access public transport.
Expecting development proposals to demonstrate:
how the development will provide for and prioritise transport in line with the sustainable travel and investment hierarchies;
consideration of the need to integrate transport modes;
the need to as far as possible facilitate access by reliable public transport, ideally supporting the use of existing services or new services that do not require on-going public sector funding.
CPT wish to highlight that last point which is of concern to us. All bus passengers receive ongoing public sector funding either in form of concessions or support to keep routes open and fare prices down via different Central and Local Government grants/contracts. So if the goal is to increase access to buses through planning mechanisms, there must be an understanding that any bus route new or existing will receive on-going public sector funding as government support for bus passengers is delivered to almost all scheduled bus routes. Without this support, all bus operators would have to make difficult decisions regarding bus routes, frequency and fare rises. It is vitally important to note that this would be the same tough choice for both private and publicly owned operators.
It is also vital to point out that prior to approval for any significant proposals for new developments discussions are had between local bus operators and Local Authorities and/or with the local Bus Service Improvement Partnerships to make sure that operators will be able to extend/divert existing services or add a new service if required. There is no point in adding the bus stops and lanes (infrastructure) in design if operators will be unable to service those bus stops.
Finally, it is vitally important that the Scottish Government is able to enforce the new directives set out in this framework. Without the proper enforcement, this document will be a selection of broad ambitions rather than the rule for a just and green transition that we all wish to see.
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