Cleaner Air for Scotland 2: consultation

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.

8. Transport

132. The overarching objectives of the Scottish Government’s transport policy are:

A Scotland that is connected by a sustainable, inclusive, safe and accessible transport system, helping deliver a healthier, fairer and more prosperous Scotland for communities, businesses and visitors. A sustainable travel hierarchy that promotes both a reduction in the need to travel, a modal shift to minimise transport emissions and effectively manage demand to reduce the number of road-based vehicle movements. 

National Transport Strategy

133. The National Transport Strategy (NTS2)[85] sets out an ambitious and compelling vision for Scotland’s transport system for the next 20 years to protect our climate and improve lives.  The transport sector’s role in improving air quality is captured within the NTS2 ‘Take Climate Action’ priority, given that ‘our current transport system is a significant contributor to poor air quality’.  The NTS2 ‘Reduces Inequalities’ priority is also relevant in that everyone in Scotland will share in the benefits of a modern and accessible transport system that provides fair access, is easy to use and is affordable; these are vital if modal shift (and thus emissions reduction) is to be realised via the Sustainable Travel Hierarchy.  The NTS2 states that: ‘we will design our transport system so that walking, cycling and public and shared transport take precedence ahead of private car use’, utilising the Sustainable Travel Hierarchy and the Sustainable Investment Hierarchy. 

134. In applying a sustainable travel hierarchy, we must: 

  • manage demand and decrease absolute traffic levels by reducing vehicle journeys (particularly single occupancy private cars), rather than simply switching from the internal combustion engines (ICE) to ultra low or zero emission vehicles, as these do nothing to ease congestion;
  • reduce the need to travel, particularly drawing lessons from the COVID-19 emergency around flexible/home working;
  • enable a modal shift from private cars to mass transit at a faster pace than occurred in the 2010s; 
  • reduce exhaust and non-exhaust emissions from all vehicles; and  
  • ensure that technological and engineering solutions will make a difference in the real world.

135. The Sustainable Investment Hierarchy is embedded within the Strategic Transport Projects Review[86] which emphasises a reduction in the need to travel unsustainably, making the most of our existing transport strategic system and supporting strategic investments in sustainable, smart and cleaner transport options, in accordance with Just Transition principles[87].

Low Emission Zones

136. Part 2 of the Transport (Scotland) Act 2019 confers new powers on local authorities in relation to the creation, and civil enforcement, of Low Emission Zones (LEZs).  This supports the Scottish Government’s commitment to LEZs[88] into Glasgow, Edinburgh, Dundee and Aberdeen. LEZs set an environmental limit on certain road spaces and restrict entry to the most polluting vehicles with the aim of improving air quality in Scotland’s city centres.  Vehicles that do not meet the emission standards set for a LEZ will not be able to drive within the zone and a penalty charge will be payable by the vehicle’s registered keeper, unless the vehicle is either out of scope of the LEZ or is exempt.


We will:

  • Introduce LEZs into Scotland’s four largest cities.
  • Provide financial support to businesses and individuals most affected by the implementation of LEZs through schemes such as the LEZ Support Fund[89] and Scottish Bus Emissions Abatement Retrofit (BEAR) Fund[90].

Avoiding travel  

137. The greenest mile is the mile not travelled. There is a role for employers to minimise emissions from staff commuting by promoting flexible, mobile and adaptive working (e.g. homeworking, flexible office spaces).  Transport Scotland has commissioned new research to build the evidence base on employers’ attitudes towards working from home and their intended approach to employee travel as we exit from lockdown. This will help inform our thinking on how to support employers to encourage sustained home working as businesses recover from the pandemic.  The Fair Work Framework[91] and Acas homeworking guidance offers tangible advice on how to incorporate homeworking into corporate carbon management planning[92]


We will:

  • Encourage all Scottish employers to apply the Acas homeworking principles (where practically possible) within their Carbon Management Plans.
  • Ensure that public bodies will be exemplars in adopting this way of working, and should incorporate travel from employee commute as part of their corporate carbon footprint and will report these emissions via their public bodies duties reporting. 

Active travel

138. The Active Travel Framework[93] 2019 sets out the key policies for improving the uptake of walking and cycling in Scotland.  It builds on the Active Travel Vision that by 2030 Scotland’s communities are shaped around people, with walking or cycling the most popular choice for shorter everyday journeys.  The NTS2 states that Scotland’s transport system will be designed with sufficient walking and cycling options.  As well as the clear benefits for air quality and climate change, this shift to active modes will also have major benefits for improving health through greater levels of physical activity.

139. The National Walking Strategy (NWS)[94] and the Cycling Action Plan for Scotland (CAPS)[95] set out clear ambitions for increasing the proportion of short journeys completed by walking or cycling.  The Scottish Government has invested significant resources in improving walking and cycling infrastructure. In 2018 it doubled the funding for active travel from £40 million to £80 million, and has increased this to over £500 million in 2020-21.  This funding supports various active travel schemes such as Places for Everyone[96] and Smarter Places, Smarter Choices[97].  In 2020, we delivered the ‘Spaces for People’ fund in response to the Covid-19 emergency, providing over £38 million of funding and guidance to local authorities to quickly design and deliver the temporary walking and cycling infrastructure that was needed to allow people to physically distance.


We will:

  • Provide funding for permanent cycling and walking infrastructure and behavioural change programmes, in line with the NTS Sustainable Travel Hierarchy and the Sustainable Investment Hierarchy. 
  • Work with local authorities and delivery partners to consider opportunities for making the temporary infrastructure permanent through the Places for Everyone programme.
  • Consider the impact of match funding criteria on the uptake of active travel funding for infrastructure and behavioural change programmes.
  • Work collaboratively with partners to deliver our Active Travel vision of enabling walking, cycling and wheeling to be the most popular mode of travel for short, everyday journeys in our towns and cities. 


140. Bus services are arguably the single most important mode for reducing transport related air pollution due to their central role in  reducing congestion, improving journey time reliability, and as a key component of future Mobility as a Service (MaaS) solutions. 

141. 75% of all public transport trips are taken by bus[98] but bus patronage has been dropping over a number of years and this must be reversed; bus must be positioned as one of the key tools in addressing air pollution from transport.  Given that a single bus can take up to 75 private cars off our roads, the case for investment in bus priority infrastructure is strong.  In 2019, the Scottish Government committed to investing over £500 million in such infrastructure - via the Bus Partnership Fund - to support local authorities, whilst also rolling out infrastructure for the trunk road network to prioritise high occupancy vehicles.

142. The Scottish Government also provides substantial financial support via the Bus Service Operators Grant[99] and concessionary fares, which now incorporates additional incentives for bus operators to adopt low emission vehicles.  Procurement of next generation buses could be realised through a range of mechanisms including grant funding to operators to purchase zero emission buses using the rapid Scottish Ultra-Low Emission Bus Scheme funding model.  The Scottish Bus Emissions Abatement Retrofit[100] programme also provides funding to licensed bus and coach operators, local authorities and community transport operators to retrofit existing mid-life buses to the Euro VI diesel standard (and thus make them LEZ-compliant).

143. A new bus service improvement partnership model underpinned by the Transport (Scotland) Act 2019 may help support the leveraging of measures that support air quality improvements, via conditions associated with vehicles and services.


We will:

  • Manage the Bus Partnership Fund to support local authorities to establish bus priority infrastructure and adapt the trunk road network to prioritise high occupancy vehicles. 
  • Support fleet renewal toward the purchase of new ultra-low and zero emission buses in tandem with preparing/retrofitting the applicable existing mid-life bus and coach fleet for LEZ compliance. 

Taxi and private hire

144. The taxi and private hire licensing regime is set within the Civic Government (Scotland) Act 1982, with supporting non-statutory best practice guidance from 2012[101].  The setting of taxi and private licensing conditions - including the setting of vehicle age limits and/or emission standards - in tandem with the collation and hosting of data is the responsibility of local authority licencing teams. 

145. Compliance with LEZ emission standards is seeing taxi operators either upgrade to a zero emission taxi (supported by a Scottish Government interest free loan) or retrofit existing Euro 4 or 5 diesel taxis with new engines that are dual fuel and run predominantly on Liquefied Petroleum Gas to the Euro 6 standard (with help available from the Scottish Government LEZ Support Fund). 


We will:

  • Update the Scottish Government ‘Taxi and Private Hire Car Licensing: Best Practice for Licensing Authorities (2012)’ guidance with a focus on environmental considerations and air pollution mitigation, including the role of emission abatement retrofitting.
  • Ensure that taxi operations are incorporated into the drafting of ‘LEZ Guidance’, with cross reference to the ‘Taxi and Private Hire Car Licensing’ guidance.
  • Explore the merits of a national taxi and private hire licencing database in terms of supporting the LEZ enforcement regime.  


146. The Rail Safety and Standards Board Air Quality Strategic Framework 2020[102] vision for the rail industry is: 'a rail network with a minimal impact on local air quality.'  Collectively, the RSSB, train operating companies and Network Rail can improve air quality by actions that encompass modelling, retrofitting, idling, monitoring and collaboration.  There is a natural fit between CAFS 2 and the RSSB framework to support delivery of tangible emission reduction from the rail industry in Scotland.

147. Localised problematic concentrations of air pollutants in large stations has seen Network Rail taken action to prevent unauthorised vehicles accessing the interior of prominent Scottish stations such as Glasgow Central and Edinburgh Waverley.  The RSSB recommendations around monitoring and mitigation offer a natural starting point to reduce air pollution in large stations.  

148. In July 2020 the Rail Decarbonisation Action Plan was published which sets out the plan to deliver against the Programme for Government commitment to decarbonise domestic passenger services in Scotland by 2035.  This will be mainly delivered through a rolling programme of electrification, however, there will be some individual routes where the objective will be delivered through the use of alternative traction technology (hydrogen or battery).  The resultant removal of diesel passenger services will minimise air pollution from trains. 

149. There has also been investment in active travel provision through increased train and station cycle spaces, helping further encourage modal shift out-with the rail portion of journeys, in tandem with the rollout of integrated ticketing[103]


We will:

  • Ensure that the RSSB Air Quality Strategic Framework recommendations are supported and delivered where practicable in Scotland. 

Low carbon economy 

150. The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 must act as a catalyst to link climate change and air quality policies wherever practicable, particularly given the suite of annual and interim emission reduction targets for the economy sector.   

151. Significant progress has already been made in Scotland on zero emission vehicles.  The Scottish Government has committed to expand the already comprehensive Charge Place Scotland network of over 1250 public electric vehicle chargers across all parts of the country until 2022.  This core network complements the growing provision of public charging provided by the private sector and builds increased consumer confidence in using electric vehicles.

152. The Scottish Government is working closely with public bodies and local authorities to improve low carbon infrastructure, promote behavioural change, and increase public access to low carbon technologies. Examples include:

  • The Switched on Towns and Cities programme[104] enables local authorities to deliver infrastructure that supports EV uptake, with the aim to create at least 20 electric towns and cities across Scotland by 2025 to facilitate a step change in the uptake of plug-in electric vehicles. 
  • The Low Carbon Travel and Transport Challenge Fund supports public and third sectors to deliver low carbon transport and active travel hubs.
  • The Switched on Fleets initiative supports local authorities and public bodies’ transition of their vehicle fleets to zero emission alternatives, this includes electric and Hydrogen Fuel Cell vehicles. 
  • Supporting households in the transition to zero emission transport through interest-free Electric Vehicle Loan in tandem with funding towards the cost of installing domestic charge points for electric vehicles.


We will:

  • Deliver strategic expansion of the ChargePlace Scotland network.
  • Work across the public sector to accelerate the decarbonisation of vehicle fleets.
  • Support a step change in the update of zero emission vehicles by supporting 20 Switched on Towns and projects by 2025[105].


153. The use of Biofuels as a transport fuel can help to achieve objectives on air quality and greenhouse gases. Fuels such as Biomethane, BioLPG, Biobutanol, Bioethanol and others are commonly used in transport fleets outside of Scotland. These fuels represent an alternative to diesel, and burn inherently cleaner, producing significantly less NOx and particulates at the tailpipe. Biofuels can be attractive to operators of commercial vehicles and can be more cost effective to run. 

154. Second and Third generation biofuels in particular are able to reduce well-to-wheel CO2 emissions by up to 80% and can utilise by-products from waste agricultural and waste food stocks of which Scotland is well placed to capitalise. This will also improve self-sufficiency of fuel supply to Scotland. 


We will: 

  • Support the adoption of alternatively fuelled vehicles where these achieve the objectives of reduced emissions of air pollutants and greenhouse gases.
  • Enable dedicated infrastructure through collaboration with the biofuel supply chain to increase the availability of biofuel filling stations for the transport sector. 


155. The movement of goods and services around Scotland is a vital component of the economy.  Use of heavy goods vehicles to do this may still be the most appropriate mode in certain circumstances, particularly over longer distances, and should not be prevented in the right setting.  A mix of spatial planning and logistic technology – in tandem with the emergence of zero or ultra low emission powertrains as market-ready affordable solutions - could help to optimise emissions from the heaviest vehicles in our fleet in the years to come. 

156. The Scottish Parliament Environment, Climate Change & Land Reform Committee’s Air Quality Inquiry in 2018[106] recognised the need to identify opportunities for maximising the efficiency of urban freight movements.  One option could be the potential application of consolidation centres under the Local Government (Scotland) Act 1973 and the Local Government in Scotland Act 2003 that local authorities could use to create distribution hubs, at their discretion.  Opportunities for distribution or consolidation hubs must be identified at a local level and must be industry-led in order for them to be commercially viable. 

157. The public and private sectors must collaborate to identify effective pragmatic solutions that centre around the affordability of, and access to, zero and ultra low emission vehicles.  This approach will help to decarbonise the freight fleet and improve air quality at the same time.  We must also acknowledge that some freight operators may be tied into lease agreements that do not enable easy, quick alteration of their fleet profile within the timescales set by Government to mitigate air pollution. 

158. Zero emission light commercial vehicles, including e-cargo bikes, are emerging into the market and may offer more efficient and less harmful options for moving goods locally.  Transition to such light commercial vehicles will be dependent on availability, lead-in times and cost/affordability (which links into the support element noted above). For e-cargo bikes, there is a natural alignment with the design and construction of active travel infrastructure.  Important points to consider are engagement with industry and academia to examine options around, and barriers to, last mile and first mile deliveries, the potential impact of multiple smaller vehicles transporting goods on congestion; and the experiences of freight providers and retailers in coping with the surge in home deliveries during the COVID-19 emergency. 


We will:

  • Collaborate and engage with the freight industry and retailers to explore the options for, and the associated logistics of, ‘last/first mile’ delivery approaches.
  • Collaborate with the private sector to identify effective pragmatic solutions on the uptake of zero and ultra low emission vehicles.

Trunk road network and demand management

159. The NTS2 clearly states that ‘we will not build infrastructure to cater for forecast unconstrained increases in traffic volumes’ and acknowledges that not managing demand for car use is no longer an option.  This means that capacity expansion of the trunk road and motorway networks will be de-prioritised over the next 20 years.  Instead, the Scottish Government will focus on schemes encompassing safety, maintenance and network optimisation.  The NTS2 also states that managing demand will include better public transport and more and improved active travel options, alongside a role to encourage people not to make unnecessary journeys.


We will:

  • Work to revoke all Air Quality Management Areas, by meeting the required air quality objectives,  where trunk roads are the primary contributor to air pollutants.
  • Ensure that all trunk and local roads will comply with European air quality targets.
  • Explore how we can reallocate road space to cycling and pedestrians following learning from COVID-19 pop-up schemes.

Intelligent Transport Systems 

160. Intelligent Transport Systems (ITS) describe technology and communications used to improve efficiency and safety for transport users[107] and also encompass the growing field of connected and autonomous vehicles (CAVs).  Transport Scotland’s ‘Future ITS Strategy’ sets out our vision for the continued and evolving use of ITS solutions to support a safe and efficient trunk road network, with a specific focus on making traffic management decisions based on expected, modelled or measured pollution levels.  Transport Scotland’s ‘A CAV Roadmap for Scotland’ sets out a vision for how Scotland can be at the forefront of developments in the connected & autonomous vehicle industry and to put sustainable transport at the heart of decision making and ensure that transport plays a key role in delivering net zero emissions by 2045.

161. In relation to air quality, ITS solutions could: 

  • ease congestion and smooth traffic flow;
  • support low cost sensor deployment across a range of topics including local air pollution monitoring; 
  • support the design of traffic management technology deployment at potential pollution hotspots (including signalling; algorithms/strategies particularly at junctions with start:stop traffic flows); 
  • enabling localised pollution communication messaging to advise vehicle drivers around how their driving behaviours contribute to localised pollution;
  • make active travel routes as attractive as possible by prioritising urban cycling corridors through harmonised traffic junction light settings;
  • underpin the delivery of the LEZ back-office enforcement regime; and 
  • form a cornerstone in supporting the reallocation of road space and modal shift to public transport or active travel.

Workplace parking charges

162. Part 7 of the Transport (Scotland) Act 2019 focuses on a Workplace Parking Levy (WPL), providing local authorities with discretionary powers to implement a WPL scheme.  WPLs can help to reduce congestion[108] and tackle climate/air emissions by influencing travel behaviour in a way that disincentivises private car use and encourages use of public and sustainable transport.  However, it is a matter for employers on whether WPL scheme costs are passed onto employees.

163. For the purposes of improving air quality, local authorities that implement WPLs (and in doing so control the scheme design to determine geographical boundaries that might include, but should not be limited to, LEZs) should invest any proceeds from WPLs into more sustainable modes, to facilitate their local transport strategy.


We will: 

  • Take forward a policy consultation in advance of drafting WPL regulations, and thereafter, take forward the regulations required to support the WPL provisions in the Transport (Scotland) Act 2019 which require commencement and supporting regulations.  

Vehicle scrappage schemes

164. Vehicle replacement programmes worldwide have historically applied a scrappage scheme to incentivise the registered keeper to trade in a used car/van for a new (ultra-low or zero emission) car/van.  The Scottish Government introduced the LEZ Support Fund in 2019 as a form of vehicle replacement programme to help those who will have the most difficulty in making the transition to the introduction of a LEZ. Rather than a conventional scrappage scheme, it provides targeted mobility grant funding for households (who currently use a LEZ-non-compliant private car) and micro-businesses using non-compliant light commercial vehicles. This approach seeks to encourage lower emission mobility options such as, but not limited to, e-bikes, bikes, public transport season ticket contributions and other incentives which reduce car ownership.


We will:

  • Deliver a vehicle replacement programme in Scotland that is founded on the principle of emissions reduction.   

Vehicle speed and air pollution

165. Speed impacts on emissions are influenced by a range of factors including driver behaviour, congestion, fuel type and engine technology including after-treatment devices.  Emissions tend to plateau between 40 and 60mph compared to much lower or higher speeds.  

166. What is most important in terms of vehicle speed and emissions is the promotion of a smooth driving style that would see lower incidences of acceleration, deceleration, gear changing and braking in tandem with a reduction in ‘stop-go’ driving. 

Measures requiring further investigation and research

167. Not all transport policies are devolved. However, there are opportunities for the UK administrations to collaborate including understand how fiscal instruments such as fuel duty and vehicle excise duty could be altered to incorporate the costs to society from air pollution caused by transport. This might include examining how a charging/payment regime alternative to the existing fuel and road taxation based structure[109].  How transport scheme design and operation can support COVID-19 recovery plans is also important.

Question on Transport

17. Do you agree with the actions put forward in the transport chapter?

A) Yes

B) No

C) Neither agree nor disagree

Additional comments in support of your answer



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