Cleaner Air for Scotland strategy: independent review

Conclusions and recommendations from the independent review of the Cleaner Air for Scotland strategy.

7. Transport


7.1 The Transport Working Group[68] identified and ranked key areas and this priority is largely followed here but is represented fully in their report[69]. Context and evidence which supports the recommendations can also be found in Annex 7. Several issues identified are interlinked not only in this transport section but with the environment, health, placemaking and governance issues identified. Given the position which is set out here, there was consensus that nothing less than transformational change is necessary.

7.2 As was set out in CAFS, transport contributes just over one-sixth of Scotland’s total PM10 and over one third of the total emissions of NOx. The majority of these emissions are caused by road transport[70] and road transport emissions are the largest source of kerbside concentrations and poor urban air quality. Road transport sector emissions have risen slightly in recent years and the sector’s emissions overall continue to grow.

7.3 With respect to air quality – behaviour change is “not a nice to have” or just an aspect that should be “encouraged”, and we cannot just wait for the ‘technology fix’. Energy consumption and emissions from transport are influenced not only by technical efficiency, mode choice and the carbon/pollutant content of energy but also by lifestyle choices and socio-cultural factors. The most likely pathway to success will involve both changes to our travel demand patterns and appropriate technological improvement. Policies to change travel demand patterns can be implemented sooner, and will impact more significantly, to achieve emissions reductions. The most significant impact of lifestyle change on the transport-energy system is due to reductions in the overall demand for transport energy, particularly for fossil fuels.[71]

7.4 The science on air quality is developing. Health and general emissions aspects have already been addressed earlier in this report. This highlights the cross-cutting nature of air pollution as not only an environmental and transport concern, but also as an issue which directly impacts upon public health. The next steps for the CAFS approach in relation to transport should consider and prioritise measures which stimulate and support public health improvements, particularly in relation to behaviour change and increasing the uptake of public and active travel.


7.5 A review of transport data capture, relevance and gaps is needed now. It is important that interventions are based on the best possible transport data on current movement and mode choice. In particular, data derived from phone company records – as used by Google and Apple to give information on road congestion – can be acquired. This may be addressed by Transport Scotland in the National Transport Strategy (NTS) and would be one component of having a stronger, more up to date and deployable resource for monitoring and assessing current and future needs. It also allows a better fit with police and SEPA systems that will enhance environmental data and safety issues. Bus companies would also be able to review these data in partnership and match it with their knowledge of their own networks.

7.6 CAFS introduced the National Modelling Framework (NMF). The NMF provides the basis for a national approach to both local and regional air quality modelling. This modelling requires robust transport and environmental data. The delivery of the local NMF for the four proposed LEZs was only made possible by undertaking detailed traffic data collections. Good quality data is essential for making key decisions. Annual traffic data should be collected nationally for use at national, regional and local levels and coordinated with environmental data.

7.7 Data sharing with the National Health Service (NHS) should also be improved, including through the nascent Public Health Scotland.

Recommendation – Data

T1. A robust commitment is needed on data and research support for transport planning. Consideration should be given to specific investment in transport supply and demand research. Additionally, both current pollutant and impact data capture should be reviewed and a commitment is required for continuous transport data provisionfrom the range of relevant locations across Scotland, building on the findings identified in SEPA and partners’ NMF work.[72].

Modal/Hierarchy Shift

National Transport Strategy

7.8 In the course of the next few months we understand that there will be a revised NTS, in turn followed by the Strategic Transport Projects Review (STPR). It is to be hoped these will reflect the revised priority ascribed to tackling the climate crisis as well as the challenges identified here of reducing transport sector air pollutants in addition to enhancing public service provision generally and encouraging necessary modal shifts.

Walking and cycling

7.9 The current funding level for active travel is insufficient to meet the need for transformative change, especially for related infrastructure programmes and the associated behaviour change support work given the paucity of funding over many decades. Doubling the funding level again (since the 2017 doubling announcement from £40 million to £80 million) would signal the seriousness of the task and the need to upskill and expand the human resources also needed. Short-term, stop-start sustainable transport programmes must be replaced with permanent programmes. In addition, the 50% local authority match funding requirement for the bulk of the active travel budget must be reconsidered. It is important to give incentives to local authorities to invest their own resources in active travel but in a situation where their transport capital budgets are often sufficient to pay for only one or two new pedestrian crossings a year, they may be genuinely unable to 50% match the central government resources available for active travel.

7.10 There are a number of areas which are highlighted where funding shortfall means that local authorities currently do not pursue interventions which could contribute to improving local air quality and broader health co-benefits (e.g. loss of car parking funds). The promotion and modal shift towards active travel provides wider economic benefits too. In Denmark, for example, for every km travelled by bicycle instead of by car society gains c.1€ in terms of health benefits, with 1.1 million fewer sick days. As an example of health savings, the Odense National Cycling City project resulted in 248 million € in saved health cost.[73]

7.11 More broadly in terms of promoting every day cycling and walking, there needs to be a hierarchy in providing funding for promoting modal shift through development of appropriate infrastructure. An example is councils applying for Scottish Government funding to build long-distance segregated cycle paths. These long distance paths do not necessarily change travel behaviour for everyday trips, but are more focused to leisure rides. The latter are not unimportant but we must first encourage routine active travel.

7.12 Additionally, the notion of hierarchy should be applied to transport and mobility at a policy as well as a personal level. Connected with the issues arising around engagement and behaviour change, it is something we need to encourage: to ensure the dominant “car first” choice selection is rejected. Disadvantaged individuals with no or less choice and those already with satisfactory active or public options are already eased into that cleaner point in the hierarchy, but a more prominent policy stance and communication strategy around cleaner, healthier mode selection should become the norm.

Buses as a core service and a demand management tool

7.13 There will be air quality improvement and concurrent benefits for users and non-users if buses can run cleanly, quickly and reliably. The case for relatively inexpensive measures, such as bus lanes, signal priority and preferential access to city centre streets, is likely to be strong where there is an air quality problem. Consistent and strong enforcement is essential. Controls on older, more polluting cars and taxis should be more acceptable if there is a good bus service along the required axis. Scotland operated a Bus Route Development Grant scheme over a number of years in the early 2000s, distributing several £Ms. A similar scheme that operated in England increased bus use on marginal bus services by more than 30% over two years, on average. There was a consensus, therefore, that there is not only a need to promote cleaner vehicles, but also to reduce the number of private cars on the roads in general. However, we note that buses need to be cleaner (Euro VI Diesel), and, as of now, it is more cost effective to provide cleaner buses than the longer term task of changing current private car fleets along many urban transport corridors.

Current bus replacement actions

7.14 Discussions with both public and private providers led to a clear picture of significant investment and improvement underway, albeit that progress is constrained by limited investment funds and capacity[74]. The industry is also already acutely aware of criticism of its pace of renewal but stresses the progress being made and planned. Technology and cost options have been considered carefully, including the work of the Low Carbon Vehicle Partnership (LCVP) and UK Government Department for Transport (DfT) projects, such as for Southampton. Specific Clean Air Zones (CAZs) such as Leeds, which appear to be working well, have been studied as exemplars and aids to learning for Scotland. For retrofit, the challenges and lessons from the Bus Emissions Abatement and Retrofit Programme (BEAR) 1 and 2 should be learned and reflected in a more effective BEAR 3. There are also short to medium term risks of displacement (as with taxis, etc.) of older, dirtier vehicles moving to already disadvantaged areas and users as fleets are upgraded, potentially worsening air quality in these areas. Nonetheless, the fleet changes already seen are bringing new and retrofitted, cleaner buses (as with taxis) onto a number of routes in our major cities and the consequent benefits can also be expected in the future. EURO VI engines in the bus fleet represent a reduction of c 80% in unit NOx and a halving of PM output over EURO V engines, continuing the step down in emissions per unit by buses over the last decade since EURO V was introduced.

LEZ workplace parking charges

7.15 Workplace Parking Levies are being considered at Stage 2 of the Transport (Scotland) Bill. In its first three years of operation Nottingham’s Workplace Parking Levy (WPL) has raised £25.3m which is being invested back into transport improvements in the city – namely the expansion of Nottingham’s tram network, the redevelopment of Nottingham Station and funding the city’s Link Bus Network which serves key employment site, hospitals, and Park and Ride services. Following the successful approach applied in Nottingham, results indicate that the introduction of the WPL as measured by the number of levies on Work Place Parking (WPP) has a statistically significant impact on traffic congestion in Nottingham[75] and thus likely lowering air pollution levels. Whilst potentially politically sensitive, with an appropriate narrative, these approaches can clearly deliver benefits. A coherent strategic package would be required.

Park and Ride provision

7.16 Increasing Park and Ride provision alongside LEZs with charges for all (or for more polluting) cars is almost certainly the most cost-effective way to support people who have no viable alternative to car travel for the main part of their journey but cannot afford to upgrade their car in order to drive without charge into a charged zone. Park and Ride provision is more effective if it is complemented by relentless attention to minimising the effect of congestion on the bus routes that serve it. This means making sure that bus lanes and bus stops are not blocked by cars and vans, for example. Such provision should also provide appropriate charging for electric/hybrid vehicles of appropriate type and scale.


7.17 The international evidence base suggests a size reduction of the vehicles (and likewise capacity) used for last mile deliveries in urban areas as a more sustainable and efficient alternative for freight operations.[76] However, given the potential for knock on effects of increased congestion resulting from greater numbers of smaller vehicles, if a larger vehicle can be used without adverse impact, this should not be prevented in the right setting. Consolidation in this fashion reduces costs, lowers energy use and minimises use of the transport system. Electric vehicles (EVs) are likely to become the main alternative for lighter commercial vehicles, however the cost of procuring these vehicles is prohibitively more expensive than their diesel counterparts currently (though this should change in time). As well as investment in supportive infrastructure for an electric fleet, the capacity of the grid needs to be assessed in each area and upgraded where required.

7.18 There is a lack of information available on LGVs. This is important as freight transfer into urban areas is a major issue and LGV use has been increasing so fast. The Transport Working Group, whilst recognising the importance of the issue, was unable to diagnose specific solutions and hence we make no specific recommendations. Further research, and discussions with the freight and retail industries are required. Discussions with the Freight Transport Association (FTA) and some freight and distribution experts led to a view that the LGV segment, partly as much of this sector is dominated by small to medium enterprises (SMEs) in Scotland, would be slow to take up electric or hybrid vehicles – the view that the battery would be a large part of the load and appropriate vehicles were not yet on the market at affordable prices, unless legislatively driven or strong incentives were offered. Nonetheless for distribution, urban and motorway/city edge-located consolidation centres are becoming a normal part of logistics thinking. If large or more polluting vehicles are excluded from city LEZs, how goods move into and around cities will be an issue of increasing importance.

Scrappage and mode shift support

7.19 Scrappage of older and more polluting vehicles does not have to mean replacement with new motor vehicles. The Transport Working Group noted the particularly important role that e-bikes could have in attracting people to active travel and international evidence for the increasing take-up of e-bikes.[77] Behaviour change programmes would be helped by significant incentives including season commuter season tickets and funding for other aspects of sustainable travel.

Trunk Roads

7.20 Additions to the existing Trunk Road and Motorway network should be significantly de-prioritised and ideally end within the next five or so years – other than for safety, maintenance and flow improvement reasons, and taking appropriate account of rural and remote needs. This is so that there is no further demand incentive offered, especially in urban areas, through the supply and expansion of these networks. Arguably, expansion at best does nothing to encourage behaviour change in supporting reduced emissions, and at worst increases emissions through actual and perceived continued infrastructure support, based on current travel behaviour.[78] [79] Given that analysis of the National Travel Survey shows that daily time spent travelling has remained constant over time, and vehicle km travelled have increased eight fold since 1952, it is safe to conclude that investments in new road infrastructure encourage people to travel further, and faster, by car, rather than cutting the amount of time that they spend travelling[80]. This response to new road capacity is unhelpful from an air quality point of view.

Recommendations – Modal/hierarchy shift

T2. The implementation of a second NTS should lead to a permanent preference for more sustainable transport modes and infrastructure investments. Serious consideration needs to be given to reductions in trunk and motorway route expansion and priority given to electric and low emissions infrastructure and services for rail, bus and goods segments. A focus on reducing vehicle numbers, supporting electric and low emission vehicles and tackling congestion issues caused by private vehicles is necessary. There should also be further and coherent, expanded support for cycle and pedestrian/active modes.

T3. Encourage the introduction of a workplace parking levy in LEZ areas. Consider use of funds generated for improvements in sustainable transport provision.

T4. Develop and communicate a Transport and Mobility Hierarchy applied to public policy and individual behaviour.

T5. Economic stimulus for scrappage of the most polluting vehicles with behaviour change focus including options for e-bikes, public transport season ticket contributions and other incentives which reduce car ownership.

T6. Consider appropriate incentives for cycle, electric cargo and other “last mile” vehicle delivery approaches and appropriate supportive infrastructure.

T7. Greatly increase bus-based Park and Ride provision alongside LEZs with chargers for electric/plug-in hybrid vehicles and appropriate fiscal charging for more polluting vehicles.

Placemaking and Planning

7.21 The Local NMF model, implemented and delivered by SEPA has proven to be beneficial in developing the evidence for the four cities (Aberdeen, Dundee, Edinburgh and Glasgow) required to implement LEZs. This level of support has had a positive impact on the development of LEZs and on the delivery of Glasgow’s LEZ, although it is rather early to make outcome rather than intent and process observations at this point. This approach should be expanded to include the Regional NMF – based on the Dutch Air Quality Cooperation Programme [81]. This appears to be a very sound regime.

7.22 There needs to be a spatial and general land use planning framework which is robust, clear and which ensures that, among other things that “local actions” would not be allowed where they go against nationally sought-after outcomes such as improving local air quality and achieving decarbonisation.

7.23 As there is a major programme of housing development and redevelopment of derelict sites, etc., there should be a major focus on ensuring that new developments are designed to reduce emissions through good design which includes connecting up with existing bus and rail services and other sustainable options as the first choice for local travel, as a de minimis. “Planning by design” is critical from the start in terms of delivering a new development. Car ownership and use needs to become seen as not the best first choice and car use trends must be countered, with polluting and inefficient car journeys made less attractive (including through social marketing). This could include “filtered permeability” to ensure the most direct and pleasant routes are afforded to those travelling actively or walking to public transport stops.

7.24 Supplementary Guidance on air quality is currently simply guidance. In view of the need to improve air quality it was the view of the Transport Working Group that it should be made mandatory. This can help the Scottish Government to impose changes where local authorities lack ambition in relation to air pollution mitigation.

Recommendations – Placemaking and Planning

T8. Spatial planning and transport planning need to work together to be effective in ensuring local decision-making does not undermine national objectives for air quality.

T9. Make Supplementary Planning Guidance on Air Quality mandatory.

Public Engagement and Citizen Science

7.25 With heightened attention already during the first half of 2019 at least to climate change and LEZs there is an opportunity to engage further in 2019/20 with the public on issues that have direct impacts at the household and community level. Scottish Government, Transport Scotland and local authorities, with SEPA and HPS et al. could be seen to act in concert to lead clean air initiatives. For example, the issue of actual exposures and what they mean could be communicated. This could relate to bus and car in-vehicle air quality and old versus new vehicles. It could address experience at pavement level and healthier modes, segregated route options and the benefits of cleaner vehicles etc. A sustained engagement with the public over years is likely to be needed to explain and discuss the reasons for, and the urgency of real change in travel behaviour.

7.26 Whilst some might find it challenging, a plain speaking, direct and factual TV/web video campaign highlighting the impact of vehicle emissions on children, cyclists, bus passengers, pedestrians and outdoor space users at street level pre-LEZ etc. could be impactful in encouraging behaviour change. Urging walking to school would also have multiple benefits, for those readily able to do so. Economic and other pro-environmental choice stimuli could go alongside improved travel (e.g. lower bus fares, employer benefits for non-car users within defined areas where there are travel choices) which are economically advantageous and socially normative, as well as visible positive changes such as priority bus routes, and segregated cycle routes on roads with speed limits above 20mph.

7.27 Citizen science could become an element of CAFS 2. Citizen science and public engagement campaigns are potentially very valuable in fostering understanding and allowing citizens to make informed choices and change behaviours in relation to transport and improving air quality and health. Many campaigns are currently underway which seek to achieve behaviour change at a variety of levels and also achieve multiple benefits across different policy areas. Individual local authorities, SEPA, Living Streets and Cycling Scotland as well as Health charities are all involved in education and awareness-raising campaigns around improving air quality, carbon emissions, active travel and health, travel choices and planning, anti-idling, and pedestrianisation outside schools which seek to educate pupils and their families on the wider environmental and societal benefits of making better transport-use decisions. These campaigns should be continued and broadened to ensure the maximum coverage of Scotland’s population can be achieved and also extended into new policy areas where additional benefits can be gained.

7.28 Local authorities, with a few exceptions, largely don’t appear to have the resources to prioritise air pollution and communication actions. There is a need for Scottish Government support, co-ordination and funding to assist local authorities with actions, including city/town centre street closures to raise awareness of the benefits for air quality, pedestrian space and business. Edinburgh’s ‘Open Streets’ initiative, which began on May 5th 2019 and similar events in Glasgow should provide a template for this kind of activity. Smaller local authorities do not have the funding available to establish regular Sunday street closures. Overall, there is a need to directly engage with the public on car ownership but leadership from Scottish Government is needed (see below).

Recommendation – Public engagement and citizen science

T10. The revised CAFS should have a commitment to a nationally funded and coordinated programme of citizen science and community engagement developed to improve the understanding of air pollution and how citizens can make informed decisions to reduce their impacts on the environment and improve their health.


7.29 Overall, managing demand is seen to be politically difficult and it is demand which largely is increasing emissions through both motorised traffic volumes and congestion. It is not however, enough to ask local politicians to act. There needs to be an informed and engaged public and clear national leadership. Then funding needs to follow logically on for increased and sustained growth in sustainable transport in order to address part of the root cause of road traffic-generated air pollution. The review therefore urges Scottish Government to give clear messages and practical advantages to the sustainable travel modes and balance effort visibly accordingly in order to deliver agreed air policy (and climate) objectives. The co-ordination of departmental effort in Scottish as well as local government needs to flow from this. Recommendations regarding integration of strategies and governance can be found in the General Recommendations section above.

Equity and Social Inequalities

7.30 There were concerns among the Transport Working Group to ensure that measures implemented do not have unintended consequences which exacerbate inequalities. Yet it remains that the poorest income groups, often with no or limited access to cars, are over-represented such as through residential location and/or occupational exposure (e.g. taxi drivers) to air pollution, yet the smallest proportional contributors to it. This may be an issue for scrutiny by the Just Transition Commission.

7.31 The proposal that not only should spending be increased on active travel and buses, but spending should be reduced on new trunk road infrastructure, which also has relevance to the placemaking work in this review highlights further challenges. It is clear from cities that have effected modal shift away from the car that they have not only improved alternatives but also made it more difficult to drive. This is also suggested later in Rachel Howell’s observations in the Engagement section (See Annex 9).


7.32 It is also clear that creating cities of short distances and medium densities is key to significantly reducing car use. New (trunk) road investment, by reducing the time cost of driving, does exactly the opposite, and encourages people to travel further, by car – so while the areas they live in may not be polluted, they will be more car reliant for trips into the polluted areas of cities and add to overall local and global pollutant emissions. It also changes patterns of accessibility and encourages more dispersed low density development patterns at longer distances from town and city centres, thus creating a built environment that is less conducive to active travel and bus use. Emerging policy and particularly the new NTS needs to reflect this analysis.

Best Practice

7.33 A range of learning examples was identified by the Transport Working Group and are represented also in EU/EEA[82] research reports and these deserve consideration and replication where appropriate. Several inform the group’s recommendations. They are presented at Annex 7.


7.34 The Transport Working Group and this review have made a number of recommendations to address the growing transport challenges, opportunities and significant emissions from transport we face. It is clear that LEZ implementation, combined with appropriate strategies for AQMAs (those already included and new ones) are a vital part of the necessary strategy for delivering cleaner air. As transport emissions are the largest component of pollution loadings in urban areas, reducing the number of vehicles is central to progress, as is both the promotion of active and sustainable options and the ultimate inclusion of all polluting vehicles in LEZs. It will also therefore be essential over the next four years that we understand what a successful LEZ[83] needs to look like and implement accordingly. This will be a matter not just of implementing best practice, but of ensuring LEZs with formats appropriate to their local issues and priorities are framed in a coherent overall Scottish framework and that appropriate interventions are applied to tackle the challenges involved.

7.35 It is also clear that the needs of urban and rural Scotland differ and the provision of infrastructure and services in highland, island and more remote communities must be tackled alongside the needs of urban areas. Signals of actual investment will be interpreted and new roads and services in some areas may be the best cost-effective way of providing appropriate mobility but in others may simply facilitate further car traffic and congestion and thereby exacerbate air pollution issues in the short-medium term. Greatly increasing public awareness and understanding as well as tackling a range of constraints will be central to achieving adequate progress. In the context of the declared climate emergency, the role of the new National Transport Strategy will be critical to leading radical improvements in mobility, in air quality and in influencing the balances of benefits, costs and hazards discussed.



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