This is my evidence to the Westminster parliament's consideration of Bus Services (No2) Bill. TLDR: floating bus stops should only be considered as a last resort, not a standard feature. 

I’m writing in connection with the Bus Services (No. 2) Bill and in particular on the proposals to introduce guidance on the accessibility of bus stopping places. I am an independent consultant specialising in travel and mobility of disabled people www.nfpplanning.com. I am also the Convener of the Living Streets Edinburgh Group, although I am writing in a personal capacity. 

The ‘floating bus stop’ design where a bus passenger needs to cross a cycleway when boarding a bus is fundamentally problematic for many people, especially older and disabled people. Passengers boarding - and especially alighting from - a bus value the sense that they have reached a safe, pedestrian space where they do not face the prospect of conflict with a vehicle of any sort, which is a risk inherent in the concept.

Organisations representing blind people have been particularly vocal in opposing them and the reasons are well explained in this research by UCL for the Guide Dogs for the Blind Association: https://www.guidedogs.org.uk/how-you-can-help/campaigning/our-current-campaigns/streets-ahead/. However, many other people - who cannot move quickly, are deaf or have cognitive impairments (such as dementia) - are likely to face similar anxiety using this design. All design guidance from Cycling by Design to LTN1/20 acknowledges this potential conflict between disabled pedestrians and cyclists. 

On the other hand, many cycling advocates emphasise the benefits of the floating bus stop for the safety and convenience of cyclists. There are undoubtedly benefits to cyclists in removing the need to either wait behind, or overtake, a stationary bus at a bus stop. However, these benefits must be weighed against the disadvantages to bus passengers, especially those who are older and/or disabled.

The balance to be struck between the interests of bus passengers on the one hand and cyclists on the other must, in my view, be heavily weighted towards the bus passenger. The importance of floating bus stops to cycling appears to me exaggerated to the point of absurdity by some campaigners. For example, it has been asserted that if these bus stops were to be banned “it would end cycling as a form of transport” bit.ly/4nvqHLT. Most cycling doesn’t even take place in a segregated cycle lane but on the carriageway. We know that side road junctions pose a significant risk to cyclists even with a segregated cycle lane, but I am not aware of evidence which shows that overtaking a bus is an especially hazardous manoeuvre.

The case for installing floating bus stops can be made where there are especially hazardous conditions for cyclists - for example, where a segregated cycle lane is on a fast, busy road (e.g. a dual carriageway with a speed limits of 40mph). There, the risk to a cyclist overtaking a stationary bus is clearly much greater than it would be in a single carriageway street with a 20mph limit: which is where floating bus stops are typically (and unfortunately) installed as a matter of course in Edinburgh.

For these reasons, I would therefore encourage the Committee to legislate to discourage the use of floating bus stops, unless there are especially compelling reasons why they are needed in particular circumstances.

David Hunter
Not for Profit Planning
July 2025

Motability has been in the news a lot with the scheme under attack from right wing press such as Richard Littlejohn and Tom Harwood, much of it in effect aimed really not so much about Motability itself but at the wider disability benefits system. In turn, this has generated defences of the scheme, suggesting "nothing to see here".
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However, the scheme which has grown massively in recent years absolutely does need fresh scrutiny - not only from the perspective of its value for money to taxpayers, but equally for its fairness to disabled people. Motability first came seriously under the spotlight in 2018 when the National Audit Office reviewed the scheme following reports of grossly-excessive executive pay, the accumulation of inflated reserves and opaque governance. This review resulted in a number of modernising changes for example refreshing the Trustees of Motability Foundation which had become an old boys’ club. 

However, the business model of Motability Operations (the monopoly commercial arm of the scheme which is owned by financial institutions), remains unchanged: buying new cars at discounted, VAT-exempt prices; leasing them to customers over three years: and then re-selling them on the secondhand car market.  And year after year - until last year) it  continued to rack up surpluses of the hundreds of millions of pounds.

Year ending      pre-tax profit (loss) *       Donations to MF*
2021                556                                             170
2022                923                                              200
2023                 604                                             250
2024                (416)                                               -
* £ million

In addition to acquiring ever-increasing reserves, Motability Operations also made big donations to the Motability Foundation - again, in the hundreds of millions of pounds. The Foundation. which is supposed to control the scheme. has consequently become one of the richest charities in the UK, with assets now reaching over £2 billion. These have doubled since the NAO report.

All these surpluses - whether reserves from Motability Operations or donations to Motability Foundation - derive directly from disabled customers who pay more for leases than is needed to cover the scheme’s costs. However, they also derive from government subsidy in the form of the big tax exemptions (VAT and Insurance Premium Tax) which enable Motability to offer leases below commercial market rates. As the scheme has expanded, and as more expensive, often electric, cars are promoted through the scheme, the revenues foregone by the Treasury through these tax exemptions have also ballooned. The NAO estimated the value of these tax concessions at up to £888 million in 2017; the current value will be in the £billions.

Which brings us to the latest twist in Motability’s story. Last year, for the first time in recent memory, Motability made a heavy loss, in contrast with the recent record of multimillion pound surpluses. This loss appears to be largely because of falling resale prices of secondhand cars. (Most of the value of Motability Operations’ assets are in the form of the vehicles it owns). In recent years, Motability Operations has heavily promoted Electric Vehicles, with Chairman Sir Stephen O’Brien stating Motability Operations’ goal in its 2024 annual report as how “we navigate the UK’s transition to electric.”

The UK car industry is struggling to meet government targets for EV sales, and Motability’s mission seems to have shifted. Its chief focus seems now to be not meeting the mobility needs disabled people, but rather supporting the UK car industry during challenging market conditions associated with the EV revolution. When the NAO investigated Motability in 2018, Motability accounted for 1 in 10 of all new car sales in the UK. Astonishingly, in a few short years, this has risen to 1 in 5. With further instability on the horizon through tariffs, Motability’s role in the motor industry will only grow in importance.

Motability Operations warns that the £416 million loss announced in its 2024 Annual Report will lead to higher lease prices - i.e. it will be disabled people who bear the cost. When Motability makes money, the surplus goes to reserves or to the Motability Foundation; when it loses money, customers are charged more. Either way, disabled people pay. If the Government wants to subsidise the UK car industry, let it do so, But why should disabled people be expected to?

Why does this three-metre stretch of Edinburgh’s Viewforth have no pavement? Because of a failure of our planning system - or perhaps more accurately, a failure in the culture of our planning system.

The location marks a former vehicle entrance to the old Boroughmuir High School, which has been developed by Cala Homes into prestigious flats. Despite the extensive issues involved in achieving the necessary consents, the Planning Department made no effort whatsoever to require the developer to turn the redundant road entrance into a proper footway. This means the pavement is interrupted by two dropped kerbs - one extremely steep and probably unusable by many wheelchair users - and with unnecessary and misleading tactile paving. Adding to the absurdity, the failure to amend traffic orders to extend the yellow lines across the former entrance means that there’s now a free parking space for anyone who wishes to use it.

The new smooth tarmac pavement with kerbs removed.

These facts frequently lead to claims that reducing car traffic will disproportionately benefit disabled people. The argument is that anything that reduces car traffic is going to disproportionately affect non-disabled people (who drive more); and potentially improve disabled people’s mobility (who drive less). To take one example, the Equality Impact Assessment for Scotland’s ‘Route Map to Achieving a 20% Reduction in Car Traffic’ (3) assesses the policy’s impact on disabled people as “Positive”: “Reducing the number of private vehicle journeys on the road will help free up road space and reduce journey times for those with disabilities who do need to travel by car.”

This logic is misplaced for two reasons. Firstly, disabled people who drive are often far more dependent on their cars than non-disabled people. Just in Scotland, more than 200,000 people have a Blue Badge and there are thought to be some 70,000 Motability customers. Alternative modes - public transport and ‘active travel’ - are often not an option, not only because of physical accessibility but for the impact on time, pain management, anxiety, toilet needs and a whole host of other considerations. Door-to-door is a vital consideration for many disabled people, not only for cars but also taxis (which are used approximately twice as much by disabled people as by non-disabled) and community transport. This point is, to be fair, largely recognised by policy makers (including the Transport Scotland 20% reduction team cited above). Witness for example exemptions for Blue Badge holders to a range of restrictions from parking controls to accessing Low Emission Zones.

The second reason why measures to reduce car travel can adversely impact disabled people is that disabled people are often reliant on cars, not to drive them, but as a passenger, and perhaps even more importantly, to assist formal or informal carers. Many disabled people rely on family visits as well as for lifts, and on services coming to their front door. These kind of support networks aren’t helped in any way by Blue Badges and such like, and these impacts seem to me to be often overlooked. 

We need to take account of this broader context especially when considering measures like Low Traffic Neighbourhoods which physically restrict cars. Such measures don’t affect all car users equally and far from benefiting disabled people, can have serious unintended negative impacts on disabled people’s mobility and wellbeing. We must surely look to reduce the amount of unnecessary car travel for all kinds of reasons (health, environment, economy) but understanding the potential impacts on disabled people of measures to achieve this at the outset is vital if they are to be fair, and to command the widest possible public support.

(1)https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/972438/transport-disability-and-accessibility-statistics-england-2019-to-2020.pdf

(2)https://www.transport.gov.scot/publication/disability-and-transport-findings-from-the-scottish-household-survey/

(3)https://www.transport.gov.scot/publication/draft-equality-impact-assessment-a-route-map-to-achieve-a-20-per-cent-reduction-in-car-kilometres-by-2030/

The Scottish Government is currently consulting on a new national ‘Cycling Framework’ (open until December 19 2022) https://consult.gov.scot/transport-scotland/cycling-framework/  While this contains many sensible proposals, it also contains one astonishing omission and a bizarre question.
The omission is in the section titled ‘training and education’. Five ‘actions’ are proposed to train cyclists…but the safety and attractiveness of cycling is not going to be revolutionised by changing the behaviour of cyclists, but of drivers. The proposed framework says nothing whatsoever about how to curb inconsiderate and aggressive driving behaviour. Without this (accompanied by effective enforcement action) many people who would like to cycle will keep off their bikes, and those that do cycle will continue to face danger routinely.

The framework’s bizarre question is number 23. This asks if you agree that: “In order to ensure maximum value for money and impact, active travel funding in the short term should be prioritised for those local authorities with the greatest capacity to deliver, with capacity building support offered to those with the least.”

*Every* local authority has capacity to deliver active travel.  If ‘active travel’ really means walking and wheeling every bit as much as cycling, there can be no justification for this suggestion. Throughout Scotland, pavements are inadequate - cluttered, inaccessible, narrow - and sometimes completely absent. It is hard or impossible to cross many roads safely. 

Every local authority needs to be equipped to tackle the active travel priorities that it chooses. For example, simple ways to improve the accessibility of walking and wheeling are set out in 'Small Changes can make a Big Difference' which I wrote for the Mobility and Access Committee for Scotland (MACS) last year: https://bit.ly/3zrT4AG. I doubt if many councils will be queuing to take up the offer of ‘capacity building’ to help them make those choices!

Transport Scotland is currently consulting on what kind of streets, if any, might be eligible for exemption from the ban on pavement parking set out in the 2019 Transport (Scotland) Act bit.ly/3FL6wTT. The two categories suggested are 

a) "the footway is of sufficient width to enable 1.5 metres (down to an absolute minimum of 1.2 metres over a short distance to take account of street furniture) to be available for the passage of non-vehicular traffic (including pedestrians, wheelchair users and mobility scooters) when a vehicle is parked on the footway,"

or:

b) "the carriageway associated with a footway is of sufficient restricted width or access that it would be rendered unpassable by emergency vehicles when one or more vehicles are parked on the carriageway, but would be possible to access if vehicles were permitted to park on the footway."
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Neither category works. In the first case, how wide does a pavement have to be in order to be wide enough for a vehicle to park on it? How wide is this hypothetical “vehicle”? Is it an HGV, or a motorbike? Is it parked sideways or end-on? The supposed ‘minimum widths’ of 1.5 metres or 1.2 at an absolute minimum (a nonsense in itself to have both a minimum, and also an ‘absolute minimum!) that must be left for pedestrians will not be respected. The intention presumably is to allow exemption for streets which have very wide pavements, where parking may have been long accepted in local communities and there is still sufficient space for pedestrians; but the criteria would nonetheless legitimise vehicles obstructing the pavement.  

The second scenario, the ‘fire engine’ exemption, has even less merit. There's not even the slightest intent to protect pedestrian space (1.5m, 1.2m or whatever).  If a street, or even one side of it is exempted, pavement parking will become even more normalised than at present. Parking attendants (if they exist in the area at all) won’t even visit exempted streets.

Nevertheless, I can see that there will be public demands to exempt certain streets from the ban. Especially from rural areas, where parking on pavements and verges may long have been the norm, and where many in the local community feel that this ‘works’. The images for Strathyre, Stirlingshire and Pathhead, Midlothian, illustrated below, are the kind of villages where I can anticipate demands for exemption on this grounds. There will indeed no doubt be some disabled people who themselves park on pavements and support exemption - and others who don't share the view that 'it works'.

So, should regulations permit such streets to be exempted? No. I can see no criteria for exemption which won’t have the (unintended?) consequence of allowing antisocial and perhaps hazardous parking to continue - or indeed worsen - leaving councils powerless to act. 

Presumably, anyone parking on a footway in a street that has a legal exemption from the pavement parking ban will be immune from ticketing under a decriminalised parking regime, no matter how badly they park, even if they block the entire pavement. It could be argued that this is police matter as obstruction offences will remain potentially liable to action from Police Scotland. However, experience shows that in practice, the police will not enforce obstruction of the pavement - as for example, the residents of Clockmill Lane Edinburgh (below) have found. This won’t change once the ban has come into effect: exempted streets will be a free-for-all for antisocial parking, and there will be nothing that anyone affected (especially disabled people) or the local council can do about it. This is an even worse position than the present.

But wouldn’t allowing no exemptions criminalise ‘common sense’ pavement parking in communities ‘where it works’? Not in practice, no. In the real world, we all know that enforcement won’t be universal; resources will be focussed on problem areas. Many councils have no Decriminalised Parking Enforcement (DPE) and even urban councils which do have parking wardens deploy them in targeted areas. So there will be no incentive for councils to target communities where pavement parking isn’t seen as a problem; but the potential for enforcement action must remain an option if it becomes one.

Over the past couple of years, I’ve spent a lot of time (too much, some might say!) looking at all types pavement clutter, and what we can do to reduce it. (See for example this video I produced for Living Streets Edinburgh and its impact on disabled people especially: bit.ly/39ER0M7). While there’s increasing awareness of the problems caused by ‘A-boards’, bins and pole-mounted signs, I’ve only recently begun to think about one type of rarely-mentioned clutter - directional traffic signs. These signs abound on busy pavements, invariably on double poles. They take up a lot of footway space, are ugly and also convey a general sense that the street belongs to traffic rather than people. But surely they are essential for the efficient circulation of traffic?

I think not. Most signs were erected years, or more likely decades, ago. Certainly well before sat nav and smart phones allowed drivers to navigate ditgitally rather than visual instruction. If as I understand it at least half of drivers now navigate entirely by GPS (1), doesn’t it follow that these signs are much less useful now than when they were installed? So maybe we can remove half of them at a stroke without inconvenience to drivers?

However, what is *on* these signs deserves a closer look. Many massive signs convey very simple information which is either not needed, or could be communicated much more simply. A favourite of mine is the brown “City Centre Attractions” tourist signs like this one on Queensferry Road. Pretty much every visitor to Edinburgh knows that most of its ‘attractions’ are in the city centre, so why the need for these giant two-pole signs? (Edinburgh’s excellent Street Design Guidance, by the way has a presumption against double poles - unfortunately, like much else in the SDG, all too often ignored by the council itself). In Spain or France, these would be replaced by a more modest but equally effective ‘Centro Ciudad’ or ‘Centre Ville’.

(1) https://www.saga.co.uk/magazine/motoring/cars/accessories/how-do-sat-navs-work

More widely, on closer scrutiny I’d say that many, perhaps most, directional traffic signs can be simplified or done away with entirely. Take some following examples:

A common sign is the one which basically says ‘straight on’. While there is probably a need for the no left/right turn signs close to the junction, how can these two adjacent signs this size be justified on a busy Hanover Street, right in the centre of a UNESCO world heritage site no less?

On the Western Approach Road, the main traffic route into the city from the west, there is this sign. Among the questions this raises are "how come the ‘city centre attractions’ are in the opposite direction to the city centre?" Wouldn’t a simple sign indicating ‘north’ and ‘south’ be more useful…?

While I appreciate that repeater signs may avoid drivers switching lanes inappropriately, surely they should be a last resort. Certainly, the amount of space taken up on the first sign for parking information is surely unwarranted - drivers increasingly get this information online too, just as with directional information (Semple Street).

However, there seems to be no routine process which councils use to review the need for traffic signs (or indeed any other signs). Perhaps the solution is, re-affirming the principle that “walking and wheeling are top of the movement hierarchy”, to conduct an audit of every sign in the city to see how many we can remove, rationalise or reduce.  Meanwhile, next time you pass a traffic sign, it is worth stopping a moment to think what it actually says, and ask yourself “does this need to be here at all?”

This blog describes a scene I watched recently where a taxi driver picked up an elderly passenger. Although a small incident in itself, I think it illustrates a fundamental problem in reconciling active travel infrastructure with good access for disabled people, which deserves much wider discussion and deeper thought.

Right now, the City of Edinburgh Council is consulting about the future of its temporary ‘Spaces for People’ schemes. As in many places, a range of measures have been installed to aid social distancing and encourage active travel; typically pop up cycle lanes, widened footways and roads closed to motor traffic. There seems little doubt that public opinion is polarised, with many people and businesses seeing them as half-baked measures frustrating everyday movement (especially by car) and others seeing them as an essential step towards a more sustainable future. 

There is also little doubt that some schemes are a cause of deep concern for many disabled people. A ‘poll’ carried out by Disability Equality Scotland last September (bit.ly/3pcIoS2) found that 71% of respondents said that their life had been made more difficult by Spaces for People (compared to only 10% who said it had made life easier). 

I was walking along Morningside Road in December last year when a taxi pulled up almost beside me. It stopped just at the entrance to a segregated pop-up cycle lane, blocking it entirely so I paused to see why he did this. The taxi driver left his cab and began looking for his passenger. After perhaps a minute, he walked on and turned the corner into Church Hill Place, returning a few minutes later accompanying a very frail lady using a walking frame, I would guess in her late 80s or 90s. They made their way slowly to the taxi and the driver helped her in, before then driving off. 

This scene was unsatisfactory for everyone involved: the passenger had to walk a significant distance despite her very obvious mobility difficulty; the cycle way was blocked and unusable for the time the taxi was stopped; the taxi driver spent longer on the job than he would no doubt have liked.

In terms of the process, TAP had secured some funding from the Scottish Borders Council and wanted to find some support to help their members look critically at the pedestrian environment and find ways that it could be made better for disabled people. We agreed to arrange a series of street access audits in September and October, before the winter weather set in; however, this also was when new restrictions on gathering and physical distancing came in. As a result, I thought that we would need to postpone the project. 

However, the Chair of the Panel proposed a creative solution - that we would do audits, not in small groups but in pairs, and then I had the job to collate and assemble our findings. So I carried out three audits in Peebles (essentially north, central and south) with the TAP chair, while other members of TAP ‘buddied together’ on walks in pairs to carry out their own surveys in the town. In all, we conducted seven ‘mini-audits’ between us and these were collected into three reports (plus a summary). 

Inevitably, this method meant that some of the richness of on-site discussions about different views was lost. Everyone has a unique perspective and different people pick up on different things during an audit, and I only got to meet two of the TAP members. However, it was possible in this way to bring together a wide range of different inputs while complying with Covid-19 guidance, and producing resources which will hopefully result in tangible improvements to the town’s accessibility.

The findings of this work are for TAP to take forward as they see fit. But I was struck by some observations about pedestrian mobility in the town which I think are of broader significance. 

Firstly, on my initial visit, I was quite surprised to find that the High Street had only a single pedestrian crossing (a pelican).  As a result, people are constantly walking in and through traffic to cross the High Street. If a vibrant street like this is to work at its best, it must be easier to cross it safely!

The broad High Street itself is (less surprisingly) packed with cars. Relatively high levels of car use and dependency are always a factor in rural market towns, and Peebles has an additional fundamental problem in that the A72 runs straight through the town centre. However, there must be options to reduce the dominance of traffic through the town - most obviously the introduction (along with other towns in the Scottish Borders) of experimental introduction of a 20mph limit must surely make sense on a permanent basis?

Finally, away from the town centre, the engineering of residential areas illustrates the massive legacy of streets hostile to walking which so many towns suffer from. In the south of the town especially, the post-war housing estates have massive ‘bell-mouth’ splays at almost all junctions, encouraging vehicles to move fast and increasing the distance for pedestrians to cross. In the older northern part of the town, many pavements are barely a metre wide, often adjacent to significant traffic levels. Although most pavement surfaces are in relatively fair condition, dropped kerbs and (even more so) tactile paving is scarce. In these circumstances, it was therefore not surprising to learn (and observe) that many wheelchair users and buggy pushers use the road rather than the pavements. A sight which is a fairly damning verdict on the pedestrian environment…

Overall, this is not an environment which encourages everyday walking and wheeling and will take years and a lot of money to fix, and of course, not just in Peebles. At a national level, new plans and priorities for infrastructure investment are being made, through the work of the National Infrastructure Commission and soon, the Strategic Transport Projects Review. Will this result in real investment in better neighbourhood pavements, road crossings and such like? This may not generate the same headlines as duelling trunk roads or launching new ‘active travel freeways’, but might be the best value investment of all, for the benefits to health, local economies, inclusion and the environment.  We need to make a start!

The year 2020 marks 25 years since the passing of the first Disability Discrimination Act (DDA). Shamefully, transport was entirely exempted from Part III of the Act, which outlawed discrimination against disabled people in accessing goods, facilities and services. The Department of Transport fought tooth and nail against including a general right of access to transport in the 1995 Bill (education was also initially excluded). The government saw the proposed DDA as a more business-friendly alternative to a rights-based approach to tackling disability discrimination through a Civil Rights (Disabled Persons) Bill, such as proposed by Harry Barnes MP - and as supported by the disability rights movement.  Explaining the exclusion of transport (and education) from the Bill, Disability Minister William Hague said in March 1995 “we have had the good sense to allow that matters such as education and transport deserve to be treated in a different way.” (1)  

The government maintained this stance throughout the passage of the Bill.  In the House of Lords, on 22 May 1995, Lord Mackay of Ardbrecknish (Minister of State, Department of Social Security) said “We have…made it clear that we believe that progress towards accessible public transport is best achieved by targeted action rather than by any kind of blanket legislation. Different modes of transport inevitably require different access solutions. A simple application of Part III to transport vehicles is not therefore appropriate." (2)

The government also initially rejected the more specific case for requiring minimum access standards for public transport vehicles. Defending this, William Hague had said in January 1995 “It is obvious nonsense to suggest that excluding transport vehicles from the Bill denies disabled people access to transport. The Government's record on initiatives in that area is second to none.” (3)

However, during the passage of the Bill, the Government was forced to accept what became Part V of the 1995 Act covering public transport, including powers to make access regulations about vehicles, carriage of passengers in taxis, etc. This resulted, among other things, in the Passenger Service Vehicle Accessibility Regulations (PSVAR) being introduced in the year 2000. 
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There have undoubtedly been significant improvements in public transport access in the past 25 years (look at how low floor buses have transformed much local travel) but many problems remain.  Although the second (2005) DDA put right the exemption of transport services generally from the ‘Part III provisions', the exclusion of transport in the 1995 Act cost disabled people a decade of improvements in access to transport; the consequences of which we still live with today.