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Towards a transport strategy for Scotland: consultation on rail priorities



A sustainable, effective and efficient transport system is crucial to the economic health of Scotland and its people. As Transport Minister, I want to ensure that Scotland's devolved Government plays its part in delivering such a system. Rail devolution increases our opportunity to make our transport system work for Scotland, with Scottish Ministers taking a central role in the decisions to be made going forward for rail in Scotland.

The devolved government is currently developing a Transport Strategy for Scotland covering the coming decade. The voluntary Regional Transport Partnerships are also beginning to consider what a Transport Strategy for their region would contain. This consultation will feed into this wider debate on transport, by focussing on one particular aspect of the overall picture - considering what role rail should contribute towards the total transport system.

We want to build on the momentum we have already created on railways, with more seats on more trains already reducing overcrowding, tighter quality standards in the Scotrail franchise, and work progressing well on building new railways. Devolution of rail powers to Scottish Ministers provides more opportunity to shape Scotland's railway to meet the needs of the people and businesses of Scotland. We want to develop a coherent rail strategy for Scotland, which reflects what rail is good at for both passengers and freight, and how it can best meet the needs of Scotland.

We want your input to this debate, and I look forward to hearing your views.

Tavish Scott signature

Tavish Scott MSP
Minister for Transport


Why are we consulting?

Rail devolution gives Scottish Ministers an opportunity to ensure that the rail network and services in Scotland are the best they can be for the people and businesses of Scotland. We want to make the most of the increased responsibilities, the new financial controls and the new relationships between the rail industry in Scotland and the Scottish Executive.

Ministers want to set appropriate strategic priorities for rail that can be delivered through Network Rail, First Scotrail and others. We want to establish what role rail best can contribute to the overall National Transport Strategy, and how we can build on the substantial investment we are already making in rail through the current franchise and major infrastructure projects.

Sections A to C consider the context for this consultation - its purpose, what rail devolution means for Scotland and how this consultation will feed into the overall National Transport Strategy. Section D considers the evidence on the most appropriate role for rail, and Section E considers what this means for setting strategic priorities. The specific areas where we would like your views are set out within Section E, paragraphs 18, 20, 22 and 24.

What are we consulting on?

We would welcome your views on what the strategic priorities for Scotland's rail should be. In summary, we would like your views on the following areas:

  • How may railways contribute most to the economy and society of Scotland?
  • What do existing and potential customers want from the railways? Are there ways in which we could encourage more people to use the train instead of the car?
  • To ensure appropriate services for commuters, long-distance passengers and freight, do we need to make choices on parts of the rail network about which type of service should take precedence?
  • Are there specific changes you would like to see to the rail network or services?


1. The purpose of this paper is to ask stakeholders what the strategic priorities for rail in Scotland should be. The aim is to help Ministers to set appropriate strategic priorities for rail that can be delivered through Network Rail, First Scotrail and others, and that are focussed on where rail can contribute most to the economy and society of Scotland. Your responses to this consultation will inform both the Freight Strategy and the National Transport Strategy, as well as inform specific decisions about rail.

2. The questions on strategic priorities are set in the context of rail devolution. Scottish Ministers will in future both specify and fund the outputs to be delivered by Network Rail within Scotland and by the Scottish franchise, which includes some services south of the border, such as the sleeper. In addition, Ministers will advise the Department for Transport on the outcomes that they would wish to see from cross border passenger services and will advise the Office for Rail Regulation on the outcomes desired from freight services, both within Scotland and cross border.

3. This consultation should also be seen against the background of the significant investment already being made in the railway. The current Scotrail franchise that began just under a year ago is designed to improve the quality of passenger services, and the investment in additional trains is already reducing overcrowding. The major infrastructure projects are progressing well: with trains due to be running on the line between Larkhall and Milngavie by the end of the year; with construction now started on the Stirling-Alloa-Kincardine line; with work on improving accessibility and enhancing capacity at Waverley station due to start next year; and work proceeding on links to Edinburgh and Glasgow airports, on a line linking Airdrie and Bathgate, a link between Edinburgh and the Borders and on tram links within Edinburgh.

4. Ministers set out their overall aim and overarching objectives for transport in the Transport White Paper in 2004 1. The overall aim is to promote economic growth, social inclusion, health and protection of our environment through a safe, integrated, effective and efficient transport system. The top priority in the Partnership Agreement 2 is to promote the economic growth of Scotland, and transport has a key role in this. The Partnership Agreement also makes clear that economic growth, and the transport system supporting it, must be sustainable, and in particular that we must minimise the impact on our environment by greater use of public transport. By the end of 2006, Scottish Executive funding on public transport will reach £1 billion per year, of which 70% will be targeted at public transport. The National Planning Framework 3 has emphasised the need for transport planning to be integrated with plans for economic development. Also, the Cities Review 4 proposed that there was a need for fast, effective connections between cities to assist their economic well-being, particularly for Inverness, Dundee and Aberdeen. This paper considers what rail is good at, and seeks your views on what role rail should have in contributing towards these overall aims. We also wish to know your views on the extent to which priorities should vary for different parts of Scotland.


5. Rail devolution brings new responsibilities to Scottish Ministers, transfers the finances related to these duties to the Executive, and changes the relationships within the rail industry in Scotland . These new responsibilities bring with them an opportunity to improve how the rail system works to the benefit of Scotland as a whole. In addition, the creation of the Regional Transport Partnerships, and their development of regional transport strategies, will feed in a strong regional dimension to rail devolution.

6. By 1 April 2006, Scottish Ministers will have responsibility for the majority of rail functions within Scotland. From October 2005 the Executive will be directly managing the First ScotRail franchise, and from April 2006, the Executive will have assumed the new role of funder of rail infrastructure within Scotland. Going forward, we will specify (via the Office of Rail Regulation) those network outputs that Network Rail will be tasked with delivering in Scotland. In return, Network Rail will identify, monitor and report separately for Scotland on how it is performing in delivering the agreed outputs in Scotland. This will provide greater transparency and accountability over the costs of, and outputs from, the rail network within Scotland.

7. Bringing together responsibilities for train services and for the physical rail network within Scotland creates a simpler industry set up in Scotland. In Scotland there is already positive partnership working between the key rail bodies and funders, which these additional changes will support by promoting clearer relationships, greater co-ordination and greater efficiency. These new relationships, following the introduction of the Railways Act 2005, are illustrated in Figure 1.

Figure 1: Principal Scottish Rail Industry Relationships

Figure 1: Principal Scottish Rail Industry Relationships


8. The findings from this consultation will inform the National Transport Strategy, which is expected to be published in draft form towards the end of the year and finalised by summer 2006. The National Transport Strategy will set out the long-term framework for Scottish transport, with around a 20 year horizon. Work on developing a freight strategy will also be undertaken in parallel to this work on rail and will also feed into the overall National Transport Strategy. The final form of both the National Transport Strategy and the rail strategy is yet to be decided, but at this stage we envisage that the rail strategy will form an integral part of the National Transport Strategy publication rather than be a separate, related publication.

9. This consultation will also help Ministers to set appropriate strategic priorities for rail that can be expressed in terms of outputs for investment that Network Rail and First Scotrail can then deliver. A Scottish Planning Assessment is being prepared by ARUP, to inform us of where the demand will be for rail services over the next 10 to 20 years, where the current network will fall short of supplying this, and proposals to meet the gap 5. Network Rail are also producing a Route Utilisation Strategy, which will produce options for making better use of the routes within Scotland over a shorter time scale, up to 10 years. The results of this consultation will help Network Rail and ourselves as funder to choose between which options have the best strategic fit, and are most likely to provide the most benefits to rail customers.

10. Following decisions on the strategic priorities for transport, there will be important funding decisions to be made about how much of those priorities are affordable and within what timescales. For the Executive as a whole, there will be the normal round of spending reviews, for transport specifically there will be a Strategic Projects Review, considering potential investments for all modes of transport, and for rail the Office of Rail Regulation will assess the costs of delivering specified outputs.

11. The three phases to this work - evidence gathering (including this consultation), strategy development, and funding decisions - are illustrated in Figure 2.

Figure 2: Three phase process for informing future rail decisions: evidence gathering, strategy development and funding decisions

Figure 2: Three phase process for informing future rail decisions: evidence gathering, strategy development and funding decisions


12. Rail has an important contribution to make towards achieving a safe, integrated, effective and efficient transport system for Scotland. This section considers what rail is best suited for: it considers what we might want of our rail network in future, the constraints on what rail can offer and what rail is good at and what it is less good at. It draws on the range of detailed studies on rail have been undertaken in recent years, such as the Scottish Strategic Rail Study 6, the airport rail links study 7 and the Central Scotland Transport Corridor Studies 8, and the work that is currently underway on the Scottish Planning Assessment which builds on this previous work.

13. The Scottish Planning Assessment is indicating that there will continue to be pressures for further growth in both passenger and freight use of rail over the next 20 years, due to a combination of economic growth, changing patterns of household composition, employment and movement of goods, airport growth, and in response to anticipated continued congestion on parts of the road network. This will put increased strain on the existing network, and particularly where services are busiest and the network is already working close to capacity. The major infrastructure projects already underway will relieve some of this strain, but not all.

14. There are two major constraints on the rail system that limit the role that rail can contribute. Firstly, we must always seek best value for public expenditure. In relation to rail that means we must make the right choices, taking into account the environmental, social and economic benefits. Secondly, rail's contribution is constrained by the physical nature of the rail network, which is fixed and relatively inflexible. Any one piece of track can only have one train service using it at a time. We cannot run a fast inter-city service, a commuter service stopping at local stations and a freight train transporting goods on the same track at the same moment, so we are faced with choices about which service should take precedence. Also, where the numbers of trains using the track grows, it becomes more challenging to maintain the performance of the existing services, as any delay that arises from one train will be much more likely to have knock-on effects on other services.

15. Public transport can provide particular environmental advantages over car use in many circumstances. For example, some work done for the Strategic Rail Authority 9, indicated that average carbon dioxide emissions per passenger kilometre for rail and bus were similar and were around two thirds of those for car passengers per kilometre. The same report suggests that freight transported by rail produces around one-eighth of the carbon dioxide emissions per tonne kilometre compared to Heavy Goods Vehicles. We should, however, note that these are average figures, and that empty trains will produce more emissions than the average per passenger, and full cars will produce less than the average emissions per passenger. The work being done on the National Transport Strategy will consider in more detail the relative environmental impacts of different modes of transport.

16. It follows that the emerging findings from the Scottish Planning Assessment are that rail's strengths lie where it can transport high volume flows of either passengers or freight, but its strengths may be compromised where it is attempting to fulfil multiple roles in excess of the capacity of one stretch of track, or where it is not integrated with other modes of transport that can more effectively meet the needs of dispersed and remote communities. Where there are high volume flows, rail can contribute to economic growth through the efficient movement of goods and people, whilst also providing environmental benefits, such as through the reduction of congestion on the roads. Examples include serving areas of high residential and employment density, serving major inter-urban markets, high density commuter flows, long distance freight journeys and providing links to major airports. Conversely, rail can be less competitive at providing other types of services, such as serving low density residential or employment areas; carrying small volumes of freight or freight with large modal transhipment costs; and trying to fulfil multiple roles ( e.g. fast inter-urban journeys and servicing local stations) if the rail network has insufficient capacity / capability to meet both objectives.


17. With the expected continued growth in demand for rail and the funding and physical constraints of the rail network, there is a need to make choices about what services rail can most effectively provide for Scotland. We believe it would be helpful to set out some clear strategic priorities that can guide future investment in train services, rolling stock and the rail network. We are particularly keen to know if you consider that the priorities should vary between different regions of Scotland, and the reasons for this.

The focus for future investment in the railway

18. Currently we are investing substantially in both train services, through the high quality franchise that we have put in place until 2009, and in the rail infrastructure itself, through the major projects that are enhancing the network, such as the links between Stirling and Alloa, Airdrie and Bathgate and the centres of Glasgow and Edinburgh and their respective airports. Investment may either be aimed at securing and maintaining the existing benefits of the network, for example, to regain previous performance levels or accommodate change to container heights. Alternatively, it may be aimed at unlocking the potential of the network to deliver new benefits, for example, new rail routes or increased capacity on existing routes. Much of the current investment falls into the latter category, and there may be an argument for the next investment phase being more focussed on the former category, and aiming to consolidate the benefits of the investment to date, rather than seeking further additional benefits. There also may be opportunities to consider whether the current benefits provided by the network, could be delivered in different ways that could be more efficient or effective.

Question 1:

a) Following the delivery of the current major projects, should we change the focus of investment in the railways to concentrate on securing the benefits from the existing network, or are there further new benefits that rail could achieve?

b) Would you like to see current rail resources used in different ways? Please be specific.

Top Priority for Customers

19. We consulted on the strategic priorities for Scotland's passenger railway in 2000 10, in order to guide the specification of the current franchise. The clear response from passengers was that their top priority for what they wanted from rail services was reliability and punctuality. Other improvements people wished to see were reduced overcrowding on services, more frequent trains especially those serving urban areas and on key inter-urban corridors, measures to better co-ordinate and integrate different forms of transport, improved safety and personal security for passengers, improved accessibility for all and in particular disabled people, exploration of new and innovative services, improved intercity and cross-country links through reduced journey times, and improved journey planning information systems.

20. Affordability of accessing transport is clearly also an important issue for many groups of customers, and may influence their choice of mode. Currently the rail network is funded through a combination of public expenditure (raised through taxation), passenger fares, investment from the freight industry and from private investment. Responsibility for determining that balance has now largely been devolved to Scottish Ministers. To take one example, changes to fares in future would have implications for either the level of services provided or for the level of train company financial support required from the Executive. Some fares are regulated, and changes in the level of these are set through franchise agreements; others are not regulated, and are for the franchisee to decide. There are numerous different types and levels of fares across the various types and times of services around the country, and there may be an argument for a simplification of the existing fares structure in future. Also, where there is a capacity problem on some services, for example, on peak-time commuter services, differential fares for earlier or later services, may be a very effective way of spreading the load across a greater period without the need of additional services. Differential fares may also encourage use of relatively underused services by particular segments of the market, such as business, commuter, leisure or tourist customers.

Question 2:

a) Are there measures that could be taken to attract new customers to rail, and to encourage more people to use the train instead of the car?

b) Is reliability and punctuality of services still the top priority for passengers? If not, what do you consider is the top priority?

c) What is the top priority for freight customers? Are reliability of access to the network and the timeliness of services also the top priority for freight customers?

d) For cross border passenger services, should the priority be a quick journey to the final destination ( e.g. London, Birmingham, and Manchester) or the ability to stop at intermediate stations?

e) If reliability and punctuality of services is the top priority for customers, should we generally only allow changes to the network that provide a net benefit to customers in terms of better reliability and punctuality?

f) Are there opportunities for a different, and more appropriate, approach to fares setting in particular areas of Scotland or for particular rail routes, or for particular types of passenger?

Choices for Use of the Network

21. As set out earlier Ministers have set out their overall aim for transport as to promote economic growth, social inclusion, health and protection of our environment through a safe, integrated, effective and efficient transport system, whilst the Partnership Agreement puts growing the economy as the top priority. The evidence from the Scottish Planning Assessment is indicating that there are particular challenges to optimising the effective use of a mixed railway, fulfilling multiple roles. Where the network is congested or running close to capacity, trade offs will usually have to be made. For example, we may need to decide whether a quick inter-city service should take precedence over a commuter service or a freight service.

22. How should these competing rail services be prioritised? One option would be to give precedence on any particular route to the type of service that will have greatest impact on the Scottish economy as a whole. This could be measured by comparing the existing and forecast future demand for that type of service, and the associated passenger kilometres or volume of freight, and might be varied according to the time of day and the season. For example, intercity services might generally have priority on the longer routes, such as from the Central Belt to Inverness, Aberdeen or Dundee, but commuter services would have priority in the peak hours into Edinburgh and Glasgow, freight might have priority between peaks and in the evening, and tourist services might be given priority on some routes during the summer period.

Question 3:

a) How should we prioritise services on different routes, where the fixed network is close to capacity and choices have to be made?

b) Should the general presumption for Scotland as a whole be to prioritise according to current and anticipated demand for the service, i.e. what will give the maximum benefit to the economy?

c) Do you have specific regional priorities that might differ from this? For example, are there particular routes or services in your region where you believe the predominant role should be to meet social inclusion or environmental objectives, rather than to grow the economy?

d) Do you consider that the priorities for specific routes should vary at different times of the day or during different seasons?

e) Would the increase in passenger kilometres and the volume of freight being carried be an appropriate proxy measure for the benefit to the economy, or are there better measures?

f) How should we compare the benefits from passenger and freight services?

Changes you would like to see to the rail network

23. Your responses to this consultation will be used by Ministers in deciding on the strategic priorities that they wish to guide future investment in the rail system. In parallel the Scottish Planning Assessment and the Route Utilisation Study are considering a range of specific options for changes that have been proposed, e.g. by Regional Transport Partnerships. If you have further specific changes you wish us to ensure are also considered, whether that is a timetable or service change, a change to a station or a change to part of the network infrastructure, this is an opportunity to let us know.

24. Any options for future changes will be assessed against the emerging strategic priorities and how affordable they are. If it was decided that additional investment in rail was affordable and appropriate in future, there would be a need to decide where it should be directed. One option would be to focus future additional investment on the areas of the network where rail is playing to its strengths, i.e. where services are or have the potential to transport high densities of people or high volumes of freight. In other areas, where the role of rail may be to support the tourism market or to provide links to more remote areas, as an alternative to the car, there may be a case for maintaining current services, but not investing further.

Question 4:

a) Do you have specific changes you would like to see to the railway? Please be clear what the change would achieve in terms of the overall objectives of promoting economic growth, social inclusion, health and protection of our environment.

b) Are there specific changes in your area that could improve integration of rail services with other forms of transport?

c) Should any additional future investment in the rail network be focussed on the routes that provide the maximum benefit to the economy, where there is the highest use or potential use by people or freight?


25. The findings from this consultation will be used to guide the strategic priorities for rail within the National Transport Strategy which is being developed over the coming months. A draft of that Strategy will be published towards the end of the year. We also expect these findings to help guide Network Rail in prioritising their own work on the Route Utilisation Strategy for Scotland, which they are developing over the next 6 to 9 months. In parallel, ARUP will be completing Part 2 of the Scottish Planning Assessment in November, providing updates of the likely demand for rail over the next 20 years and pointing to issues that will need to be addressed if the network is to meet this demand. Together these pieces of work will allow the Executive to finalise the strategic framework for the rail network, express this in terms of outputs that Network Rail should deliver in the future, and that the Office of Rail Regulation can cost.

26. In summary, we would welcome your views on:

  • How may railways contribute most to the economy and society of Scotland?
  • What do existing and potential customers want from the railways? Are there ways in which we could encourage more people to use the train instead of the car?
  • To ensure appropriate services for commuters, long-distance passengers and freight, do we need to make choices on parts of the rail network about which type of service should take precedence?
  • Are there specific changes you would like to see to the rail network or services?

27. The specific question on which we would like your views are set out in paragraphs 17-24. You can let us have your views in the following ways:

28. By post to:

Rail Strategy for Scotland
Transport Division 3:1
2-F North
Victoria Quay

29. By email to: railstrategy@scotland.gov.uk

30. Please complete and return the Respondent Information Form accompanying this paper also reproduced at Annex B.

31. The closing date for the consultation period is 28th December 2005

32. You can also view this document on the Scottish Executive website www.scotland.gov.uk

33. If you have any queries, would like extra copies of this document, or require copies of this document in alternative formats, please contact Denise Manzor on 0131 244 0855.

Annex i


Source: Scottish Executive (2005) Scottish Transport Statistics No. 24

This annex presents some background statistical information about the use of the rail network.

  • In 2003, people in Scotland took an average of 13.1 rail passenger journeys per year. For Great Britain as a whole the figure is 17.5 journeys. According to the National Travel Survey, nearly 5% of the average distance travelled in a year is by rail, with the average trip being around 30 miles.
  • The Scottish Household Survey found 3% of people travelled to work by rail, and 1% of children went to school by rail.
  • The total number of First ScotRail rail passenger journeys originating in Scotland was 68.7 million in 2004-05. This is 10% more journeys than the previous year, and 40% more than 10 years earlier. Two thirds of the rail passenger journeys were on services supported by the Strathclyde Passenger Transport Executive, and one-third were elsewhere in Scotland.
  • In 2003, there were 5 million rail passenger journeys between Scotland and other parts of the UK. Over the previous ten years, equivalent air passenger journeys have more than doubled, whilst rail passenger journeys had only risen by 17%.
  • Total passenger revenue from journeys originating in Scotland for 2003-04 was £207.7 million, and for cross-border passenger journeys originating outwith Scotland was £63.6 million.
  • There were 336 passenger stations in 2004-05. Thirty three stations in Scotland recorded more than half a million passenger journeys in the national rail ticketing system, which does not include the number of journeys made using zonecards.
  • In 2004-05, 83.1% of ScotRail trains, 77.8% of Virgin Cross Country, 77.5% of GNER and 72.1% of Virgin West Coast trains arrived 'on time', where this is defined as arriving at their final destination under 5 minutes late for regional operators' services and under ten minutes for long-distance operators' services. These punctuality statistics refer to all trains run by each operator, not just the Scottish services.
  • In 2004-05, 93% of ScotRail trains arrived on time or under ten minutes late, 2.1% arrived 20 or more minutes late, and 1.1% were cancelled.
  • The volume of rail freight traffic lifted in Scotland was 8.3 million tonnes in the latest year available, 2003-04. This accounts for 3.8% of the total volume of freight lifted by all modes, but 6.6% of the tonne-kilometres, due to rail freight tending to travel longer distances. In the same year, 1.56 million tonnes was delivered by rail to Scotland from elsewhere.
  • Of all the freight lifted in Scotland, half was delivered elsewhere within the UK, and 5% outwith the UK. Coal and other minerals accounted for three-quarters of the freight lifted in 2003-04. Freight within Scotland had an average length of haul of 153 kilometres, compared to 395 km to other parts of the UK, and 716 km for traffic destined for outwith the UK.
  • There are 2,729 kilometres of railway in Scotland, of which 23% is electrified.
  • In 2004 there were 49 train accidents. The number of deaths as a result of railway accidents, trespassers and suicides decreased from 27 in 2003 to 19 in 2004, of which 14 were suicides, 4 were trespassers and 1 was a level crossing user.

Annex ii


In addition to making this consultation document publicly available via the Executive website, we are circulating it to the following:

  • Scottish Local Authorities
  • Regional Transport Partnerships
  • Clerk of the Local Government and Transport Committee at the Scottish Parliament and the Departmental Committee Liaison Officer ( DCLO).
  • Rail Industry
  • Transport academics in colleges and universities
  • Trade Unions
  • Scottish MEPs
  • Transport Lobby Groups
  • Voluntary sector
  • Community/umbrella groups
  • Business sector
  • Disability Rights Commission
  • Equal Opportunities Commission
  • The Commission for Racial Equality
  • Other Government Departments
  • Relevant professional bodies
  • A range of individuals

A full list is available on request. If you think of anyone else or any other organisation who should receive a copy, please let us know.

Annex iii



Annex iv


Consultation is an essential and important aspect of Scottish Executive working methods. Given the wide-ranging areas of work of the Scottish Executive, there are many varied types of consultation. However, in general, Scottish Executive consultation exercises aim to provide opportunities for all those who wish to express their opinions on a proposed area of work to do so in ways which will inform and enhance that work.

The Scottish Executive encourages consultation that is thorough, effective and appropriate to the issue under consideration and the nature of the target audience. Consultation exercises take account of a wide range of factors, and no two exercises are likely to be the same.

Typically Scottish Executive consultations involve a written paper inviting answers to specific questions or more general views about the material presented. Written papers are distributed to organisations and individuals with an interest in the issue, and they are also placed on the Scottish Executive web site enabling a wider audience to access the paper and submit their responses 11. Consultation exercises may also involve seeking views in a number of different ways, such as through public meetings, focus groups or questionnaire exercises. Copies of all the written responses received to a consultation exercise (except those where the individual or organisation requested confidentiality) are placed in the Scottish Executive library at Saughton House, Edinburgh (K Spur, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD, telephone 0131 244 4565).

All Scottish Executive consultation papers and related publications (eg, analysis of response reports) can be accessed at: Scottish Executive consultations ( http://www.scotland.gov.uk/consultations )

The views and suggestions detailed in consultation responses are analysed and used as part of the decision making process, along with a range of other available information and evidence. Depending on the nature of the consultation exercise the responses received may:

  • indicate the need for policy development or review
  • inform the development of a particular policy
  • help decisions to be made between alternative policy proposals
  • be used to finalise legislation before it is implemented

Final decisions on the issues under consideration will also take account of a range of other factors, including other available information and research evidence.

While details of particular circumstances described in a response to a consultation exercise may usefully inform the policy process, consultation exercises cannot address individual concerns and comments, which should be directed to the relevant public body.