Consultation Digest (National) Issue 3, 8 January 2021: Scottish Government sets target to get people out of their cars.

Happy New Year to you all. I hope you all had a relaxing festive period. I’ve been well and truly thrown back into work this week reading and digesting the Scottish Government’s Climate Change Plan update. It feels like the policy equivalent of Christmas dinner. Unfortunately, there’s not time for a snooze in front of the TV – the Parliamentary Committee scrutinising the transport policy section needs comments by Tuesday 12 January.

Previous Climate Change Plans have been pretty woeful for action on transport and as a result we’ve seen emissions from the sector remain unchanged for decades. So it was quite a surprise and a turnaround for Government to include a target to cut car traffic by 20% by 2030. Scotland is the first nation in the UK to aim for this so should be celebrated, but we shouldn’t lose sight of the fact that Government hasn’t yet explained how this will be achieved. We know that greater investment in cycling is key to helping people out of their cars for short journeys so now is the time to make this point to MSPs and Government.  

Section 1: Current Consultations

(in date order for responses)

1.1: *NEW* Securing a green recovery on a path to net zero: climate change plan 2018–2032 – update

A few days after the December digest the Scottish Government published its Climate Change Plan update (CCPu).  Parliament will be scrutinising the CCPu with the Rural Economy and Connectivity Committee taking evidence on the transport section. Their call for evidence has a deadline of Tuesday 12 January so get your skates on if you want to provide your views.

Previous Climate Change Plans have not done nearly enough to present the strong ambitious policies needed to reduce emissions from transport and as a result transport emissions haven’t reduced in 30 years and transport is now the largest contributor to Scotland’s emissions by sector.

In the past Government hasn’t been willing to force people to change their driving habits so it is encouraging that the CCPu includes a headline target for a 20% cut in car kilometres by 2030. This is excellent to see, however, a setting a target on its own isn’t enough so the Government’s promised ‘route map’ to be published this year needs to be strong. We need to ask the RECC Committee to scrutinise Government’s plans.

There’s no extra money for cycling and walking beyond the existing £500m over 5 years commitment, which is disappointing because £100m per year is not enough if Government wants cycling to be a realistic solution for people to lower their carbon footprints.  

There is a new policy called Active Freeways described as ‘segregated active travel routes on main travel corridors connecting communities and major trip attractors’. There’s really not a lot detail on this in the CCPu so again in your response please urge the Committee to find out more about this emerging policy.

In general, the CCPu is moving Scotland in the right direction, the question is if it’s fast enough for the planet and does it do enough to encourage more cycling and meet the second aim of supporting a green recovery. Initial reaction from Cycling UK can be found here.

Closes 12 January 2021

1.2: Scottish Government – Cleaner Air for Scotland 2 – a draft new air quality strategy for Scotland

Consultation on a draft new air quality strategy for Scotland, taking into account the recommendations arising from the independent review of the Cleaner Air for Scotland strategy. Chapter 8 is all about transport actions so lots of opportunity to say what we need for active travel. It’s worth looking at and responding, even if you only answer this one question.

Closes 22 January 2021

1.3: Fourth National Planning Framework (NPF4): position statement

The Scottish Government has issued a position statement on the NPF4 and is seeking our opinions. The main NPF4 is still to come next year so this consultation is asking what we all think about the direction of travel. Achieving climate emission targets is a big theme in this document along with resilient, greener, better communities and places.

I had promised to analyse this consultation for this digest, however, time has run out so look out for thoughts on this in the February digest, due out on 12 February.

Closes 19 February 2021

1.4: *NEW* Law Commission (& Scottish Law Commission) – Automated Vehicles: A regulatory framework for automated vehicles

This 3rd consultation builds on two previous consultations on safety assurance, allocating legal responsibility, and licensing AVs for passenger services and public transport.

If you are worried that this consultation may be full of technical ‘legalese’ (I am), there is a summary paper. And keep in mind the principle that for automated vehicles to be safe they need to be able to not just see and recognise cyclists and pedestrians but predict their movements.

During this three-month consultation the Law Commission welcome views on key questions including, the legal meaning of “self-driving”, a GB safety assurance scheme for automated vehicles, the extent of criminal liability, and access to data w to enable the regulatory scheme for AVs to function.

Closes 18 March 2021

1.5: A82 improvements survey

The survey set up by Kate Forbes MSP is still open for your opinions on which sections of the A82 Glasgow to Inverness road are in most need of improvement in order to reduce traffic crashes and collisions. Read more here.

Section 2: Forthcoming Consultations

Nothing new here this month – still waiting on the below consultations.

2.1: Scottish Government – Permitted Development Rights (phase 2)

No news yet on Phase 2 of the consultation which will cover permitted development rights for e-bike charging points.

2.2: Strategic Transport Projects Review (STPR2)

No news either on any further Scottish Government’s STPR2 consultation. See here for more information and links to previous STPR2 documents.

Section 3: Consultation Feedback

3.1: National Transport Strategy (NTS2) – Delivery Plan – 2020 to 2022

You may have responded to the Scottish Government’s NTS2 consultation which was held about a year ago. The Scottish Government has released its first Delivery Plan for the NTS2 which provides a little more detail on what actions will be taken to meet the NTS2 outcomes. The Delivery Plan was published just after the Climate Change Plan update and includes the standout policy to cut car kilometres by 20% by 2030.

3.2: The Town and Country Planning (General Permitted Development and Use Classes) (Scotland) Amendment Order 2020

Scottish Government feedback on the consultation, outlined in Digest 72, Item 1.5 is as follows:

‘Thank you for responding to the consultation on the Scottish Government’s Programme for Reviewing and Extending Permitted Development Rights (PDR) in Scotland Phase 1 Proposals. 

I’m writing to confirm that today (18th December) we published the responses to the consultation, an analysis of those responses and that the above Order was laid in Parliament.

•             The analysis of the responses to the consultation on proposals for Phase 1 changes is available at:   

•             The responses have also been published and can be accessed at:  

Alongside the regulations we will shortly publish an explanation of the changes to PDR and how we have responded to the views expressed in the consultation. This will be available at: Work Packages | Transforming Planning. In addition, we propose to prepare a number of pieces of guidance and advice for planning authorities and applicants explaining the changes to PDR when it is proposed that they come into force in April 2021.

This represents the first Phase in our programme of reviewing and extending Permitted Development Rights and we will now proceed with Phase 2.