consultation-questions-islands-connectivity-plan-strategic-approach-paper-and-vessels-and-ports-plan-word draft response

Argyll and Bute Council · 25 April 2024
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Page 1

Public Consultation for Islands Connectivity Plan
– Strategic Approach Paper and Vessels and
Ports Plan
Transport Scotland
Public Consultation for Islands Connectivity Plan
- Strategic Approach Paper and Vessels and Ports Plan
Consultation Identifier Questions
Q1. Are you completing this on behalf of yourself or an organisation?
☐ Individual
☒ Organisation
Q2. If an organisation, please list below. 
Q3. What statement best describes your living situation?
☐ I live on the mainland the majority of the time
☐ I live on a Scottish island or peninsula the majority of the time
Q4. If you live on a Scottish island or peninsula, please comment
below which one. 
Q5. What age category are you in?
☐ Under 16s
☐ 16 to 18
☐ 19 to 21
☐ 22 to 34
☐ 35 to 44
☐ 45 to 54
☐ 55 to 59
☐ 60 and over
Local Authority – Argyll and Bute Council
N/A

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– Strategic Approach Paper and Vessels and
Ports Plan
Transport Scotland
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Q6. Are your day-to-day activities limited because of a health
problem or disability which has lasted, or is expected to last, at least
12 months?  
☐ Yes, limited a lot  
☐ Yes, limited a little  
☐ No  
Q7. What do you mainly use the ferry services for?
☐ For Business   
☐ For Employment/Education   
☐ For Personal/Leisure   
☐ All of the above  
Q8. How frequently do you use the ferry services? 
☐ Never
☐ Occasionally
☐ Weekly
☐ Monthly
☐ Seasonally (Summer period)
Main Consultation Questions 
Themes, Vision and Priorities 
Transport Scotland has gathered feedback from previous workshops and
consultations to identify priorities for the future of Island transport connectivity: ferry
networks,, supported by the integration with other transport services. This
information has contributed to the development of themes, which are the focus for
the Islands Connectivity Plan.
The following key themes emerged:    
• Community voice and transparency  
• Reliability and resilience  
• Accessibility   
• Timetables, unplanned and essential travel  
• Integration of services 
• Capacity and demand  
• Freight 
• Vessels and ports

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Transport Scotland
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• Low carbon and environmental impact  
• Ferry fares  
• Local authority services 
Q9. Do you think these key themes capture the main aspects of
transport connectivity for island and peninsula communities?
☐ Yes
☒ No 
Please explain your answer.
Argyll and Bute Council’s official response to the consultation document is based
on the following key principles:
• Lifeline services are so critically important and expensive to retain
sustainably it is inappropriate for Argyll and Bute Council to have the
responsibility for the provision of any ferry services which operate to
islands which are located within the Argyll and Bute geographical area.
It is the preferred position of the Council not to operate any ferry services. 
• Future ferry services that are to be delivered must be promoted on the
basis that they are affordable, reliable, and sustainable and offer a high
quality service that integrates with other transport links. These services
must be flexible and the services must be able to respond to future
demand and not only current demand e.g. changes in economy related
to renewable energy and tourism etc and also meet the demands of
changing demographics and socio-economic profile. 
• Delivery of future ferry services across Scotland should be based around
the ambition of sustainable economic development and reflect the
government’s objectives of promoting solidarity, cohesion and
sustainability as promoted within the Scottish Government’s own
National Strategy for Economic Transformation. 
• We welcome any potential to enhance local ferry and air services which
currently provide lifeline connections to our island and peninsular
communities. We would also note that whilst capital funding could help
establish demand responsive transport services it will require revenue
funding to make these services viable to operate. We would again stress
that the majority of road and public transport infrastructure serving our
rural, island and peripheral areas is owned and operated by local
authorities and as such, by excluding local infrastructure and revenue
funding from the previous STPR2, it is difficult to see how the proposed
intervention will significantly improve rural accessibility over the lifetime
of this plan.

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• Argyll and Bute Council, Orkney Council, Shetland Council, Comhairle
nan Eilean Siar and Transport Scotland all have responsibility for
financially subsidising PSO air service routes and airports; with each
organisation carrying out its own individual procurement for the air
services it has responsibility for. This lack of a joined up approach limits
opportunity in terms of procurement savings, advertising, potential to
stimulate competition and offer linkages not currently being met to
ensure no islands are left behind. Argyll and Bute Council therefore
would welcome  an update on the Scottish Government’s committment
to undertake a Scottish Air Services Review. 
• The Council wish to unite with island community council’s that
recognition is given to air services across Scotland and the significantly
important role the play in supporting fragile island communities as an
integration with ferry services for island transport connectivity. We would
also expect, similar to the commitment for the Scottish Ferry Services
Review through the Islands Connectivity Plan, for a funding plan and
programme for vessel deployment and services, that there will be a
commitment following the aviation review to allocate a funding
programme to improve integrated island transport connectivity. 
• Transport Scotland have confirmed that their subsidised PSO air
services from Glasgow to Barra and Tiree already face capacity issues,
especially during the summer, and that stopping these services in Oban
‘is not viable within existing capacity levels and our aircraft are fully
utilised on the existing Glasgow to Campbeltown Tiree and Barra
services. Any additional services would require additional aircraft
capacity. If that was to be purchased by Transport Scotland it would cost
£7M circa per aircraft’.  As these routes are at capacity this demonstrates
the significant demand that exists to develop and support further new air
routes. This is a further reason why there needs to be a national Scottish
Air Services Review, similar to the Scottish Ferries Review and likewise
with the Scottish Ferries Review when additional ferries are procured,
additional aircraft should also be procured when capacity constraints are
identified on the national air service network. This would be at a
competitive capital price when comparing investment of new aircraft to
the investment required for a new ferry. 
• Funding, Fares and Subsidy – funding of transport infrastructure and
services is a key barrier. Without adequate funding, we will see a
continued contraction of rural public transport services.

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• Investment must be prioritised to ensure that essential core services are
provided to all communities. Life line services should be funded with
clear identification of future needs. It is imperative that services are
future proofed to allow the full economic potential to be realised over
time. 
• .Investment must be prioritised to ensure that essential core services are
provided to all communities. Life line services should be funded with
clear identification of future needs. It is imperative that services are
future proofed to allow the full economic potential to be realised over
time. 
Based on feedback and discussions with key stakeholders and drawing on Scotland’s
National Transport Strategy 2 and the National Islands Plan, we have developed a
draft vision and associated priorities for ferry services, supported by other transport
services.
Draft Vision
Scotland’s ferry services, supported by other transport services, will be safe, reliable,
affordable and inclusive for residents, businesses and visitors enabling transport
connectivity, sustainability and growth of island and peninsula communities and
populations.  
Draft Priorities
Priority 1: Reliable and Resilient
Reliable and resilient ferry services that meet the needs of communities and
businesses and support the transition to a well-being economy which is fair, green
and growing.
Priority 2: Accessible
Ferry services that are accessible and provide easy to use and affordable transport
connectivity for all users.  
Priority 3: Integrated
Ferry services that enable sustainable and active travel choices which support our
health and well-being and make our Island and other ferry dependent communities
great places to live, work and visit.

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Priority 4: Low Carbon
Ferry services that take actions to reduce the negative environmental impact of their
operations and help to achieve Scotland's net-zero targets.
Q10. Do you believe the draft vision captures the aspirations of island
and peninsula communities for their future ferry services?
☐ Yes
☒ No
Please explain your answer.
The historical evolution of ferries has resulted in some ferries being subsidised and
provided by local authorities. Argyll and Bute Council have subsidised ferry services
to Jura, Luing, Lismore and Easdale for a significant number of years. This has a
significant impact on the Council's finance and ultimately affects the other services
the Council can deliver across Argyll and Bute within budget. This is especially
significant during the current climate of economic difficulties where services are
subject to reduction. Lifeline services are so critically important and expensive to retain
sustainably it is inappropriate for Argyll and Bute Council to have the responsibility for
the provision of any ferry services.
The Scottish Government is best placed to provide a consistent delivery to ferry
provision. This approach would allow an over arching service standard and offer
economies of scale.
Scotland’s National Strategy for Economic Transformation sets out the significance of
transport to rural areas highlighting policies to expand the rail network and improve
accessibility of ferries and airports. As such, it is vital that the Scottish Government
continue to invest in our key transport arteries that are so important to the future
success of the region. The Council will continue to work in partnership with the Scottish
Government, Transport Scotland, HITRANS, SPT and public transport operators to
lobby for increased investment in our transport services so that these meet the diverse
requirements of our local communities and businesses whilst also bringing vital
tourism revenue to the local economy.
There are also regular ferry user groups and frequent consultation with island
communities and also other bodies such as Regional Transport Partnerships such as
Hitrans, SPT, COSLA, COHI and the Highlands and the Islands Regional Economic
Partnership. More weight however needs to be given to the information gathered and
opinions communicated through these groups to Government.

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Q11. Do you think the 4 draft priorities reflect what island and
peninsula communities see for their future ferry services?
☐ Yes
☒ No
Please explain your answer.
Argyll and Bute is characterised by numerous peninsulas separated by deep sea lochs
and includes 25 inhabited islands. It is important to retain flexibility to provide and
sustain access and economic stability because of the essential and lifeline nature of
ferry services.
The future economic needs of these remote communities should be identified to
ensure that any increase in fares, to accumulate more funding from users, does not
impact adversely on the economy. These types of economies are already fragile as
they are susceptible to the impact that uncontrollable factors can have on the seasonal
industries the majority rely on e.g. weather plays an important role in tourism, farming
and fishing and can make or break a season.
There is a need for a consistent range of data on performance to be collected and
communicated clearly to customers on a regular basis to identify island priorities. This
communication needs to be transparent and easily understood. Customer satisfaction
on individual routes should be a key metric and displayed on individual routes. Clear
performance targets need to be established and where these are not reached, or a
downward trend is recorded, actions need to be identified on how this will be improved
or reversed linked to a clear timetable. This would then clearly identify island priorities.
Community Voice and Transparency
We acknowledge the importance of empowering community voice and transparency
in communications. The current methods of engagement that are used by operators
to inform communities are through email and webpage updates, with further
communications shared through relevant Ferry Committees and Transport Forums.
Local authorities and Scottish Government/Transport Scotland use engagement
methods such as through project reference groups, stakeholder groups and
webpage updates.

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However, we have heard from communities that more can be done to take account
of their views when it comes to decisions on ferry services and that there is a lack of
clarity on how decisions are made.
Q12. Are there other ways of engaging with communities and
stakeholders that would benefit decision making on ferry services,
including vessels and ports projects?
☐ Yes
☒ No
Please explain your answer.
There are already ferry user groups and the opinions expressed in these groups need
to be taken into account. Each ferry route has different user needs and pressures.
Lifeline ferry services /networks must be reliable, high quality, affordable, flexible and
futureproofed in order to meet the needs of our communities and enable growth in key
local sectors (tourism, food and drink, agriculture, aquaculture, forestry and renewable
energy). An uplift in economic activity is vital to reverse the trend of declining
populations in some of our rural and island communities and improved transport and
connectivity is essential for these communities to thrive. It is also essential that there
is investment in local ferry and port infrastructure to ensure this is futureproofed to
accommodate increased patronage generated by the predicted growth in tourism,
local industries such as food and drink including aquaculture and whisky and general
vehicle traffic due to initiatives such as RET.
More could be done to raise awareness of the Ferries Community Board across
communities and that its primary purpose is be the voice of the communities and
provide the community view to CalMAC. It should be better highlighted to ensure
greater involvement of the communities for example, served by the Clyde and
Hebrides Ferry Services over the duration of the new contract.
Communities should have a greater say in the development of timetables, it is
important to involve a wide range of island representatives involved that have a
number of different requirements and ambitions for their community. The business
community for example, young people, and people in need of regular medical
treatment off the island. There is also a need to recognise local strategic priorities.
Argyll and Bute Council for example have a priority to increase our economically active
population and develop our local economy. This is just as important for our islands as
it is for our mainland communities. Improved transport connectivity is a top priority of
our local people confirmed recently through CPP consultations and it is therefore

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considered essential for a successful community and economy. Timetables need to
reflect this ambition.
It also has to be recognised by Government and residents alike that crew hours need
to take account of rest regulations and are consequently an important factor restricting
the expansion/flexibility of timetables, where a single extra sailing can result in a
requirement for a whole additional crew to be employed which would not be cost
effective. There is already synergy between local authorities and Regional Transport
Partnerships as Local Authorities are members of Regional Transport Partnerships
and Regional Transport Partnerships are answerable to Local Authorities. Argyll and
Bute Council however feel that the responsibility of ferry service provision is of national
importance. Scottish Government is therefore best placed to manage these services
and ensure future ferry services meet community needs and are affordable,
sustainable and flexible to respond to future demands. Delivery of future ferry services
across Scotland should be based around the ambition of sustainable economic
development and reflect the government's objectives of promoting solidarity, cohesion
and sustainability as promoted within the Scotland’s National Strategy for Economic
Transformation.
Accessibility
We propose introducing an Accessibility Standard that would be in addition to the
legal requirements and could act as guidance for all ferry services. This is to ensure
that our ferry services, vessels and ports are easy to use for all, while recognising
that people have different needs and capabilities.
The Standard could include standards such as inclusive and disability training to be
carried out frequently and an accessibility review carried out periodically on ferry
services, ports and vessels.
Q13. Do you think an Accessibility Standard is a good idea?
☐ Yes
☒ No
Please explain your answer.
Argyll and Bute has a high percentage of older residents and this is increasing.
Mobility is therefore an important issue for our communities and also for our many
visitors. Accessibility is therefore a key issue and should be regularly monitored to see
when improvements need to be made.

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Facilities to allow access for those with limited mobility will therefore be a priority but
in addition to improved access for foot passengers the movement of luggage should
also be considered. Consideration for example, should be given to providing separate
luggage transfer facilities, equivalent to the service provided to air passengers, on the
larger vessels.
It is also worth noting that estimated the Purple Pound nationally equates to £249
billion per year. Argyll and Bute Council would also welcome efforts to improve
accessibility and be known as a fantastic accessible destination for older people.
Provision where appropriate of some form of left luggage facility which would aid those
passengers that are waiting onward travel connections.
Although improvements to vessel/shore infrastructure goes some way in improving
access standards adequate crew/staff training ensures that most access issues can
be addressed as and when they occur.
Q14. What do you think should be included in this standard?
Please explain your answer.
The value of smaller passenger ferries and workboats to improve our areas
accessibility needs to be recognised. That said, small boat operators will find it too
expensive, or impractical, to comply fully with one size fits all regulations.
Consequently, there is a need of greater understanding here through better
engagement with communities to better understand the constraints as well as the
requirements of the local community to sustain or improve marine accessibility.
Access standards and requirements should be included within the tender process
however they should not be so prescriptive as to create an unacceptable financial
barrier for an economical affordable bid to be made.
The design of new ferries and harbour/ shore infrastructure should take full account of
the DPTAC guidance, for example the provision of handrails, ramps and assistance
telephones. Consideration where possible should also be given to their use in smaller
ferries and ports.
The need for regular, recognised disability awareness training is viewed as a relatively
cheap and quick solution in helping to reduce many of the barriers faced. Good
customer care and assistance by staff is often viewed as the key factor when deciding
if ferry travel is possible, practicable or comfortable.

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Port and ship operators need to plan their communication and information
dissemination to take full recognition of PRMs. Audio, visual or other disabilities need
to be considered, especially when considering passenger safety.
Disabled Persons Assistance policies should be developed by all ferry and port
operators as a matter of best practice.
A policy for those passengers which may require additional assistance which fall
outside the general categorisation of PRM, for example people travelling with small
children, or heavy / awkward luggage or baggage should be encouraged.
An accessibility indicator system would be beneficial but would need clear definition
of its rating system. Indicators would require to inform on the 'level' of accessibility
rather than in terms of 'accessible' or 'not accessible'.
Reliability and Resilience
Community feedback highlighted that the reliability and resilience of ferry services
needs to be seen as a priority due to the impact on communities, businesses and
visitors when ferry services are disrupted.
Q15. Do you agree or disagree that the first priority of the Islands
Connectivity Plan should be to improve reliability and increase
resilience of ferry services?
☐ Agree
☒ Disagree
Please explain your answer.
Argyll and Bute given is the second largest geographic area of any Scottish Local
Authority but with less than 2% of the total population of Scotland. The area is also
characterised by its diverse geography with 23 inhabited islands and long peninsulas
and as such, lifeline ferry networks are essential to support a sustainable, well
connected economy.
Reliability and resilience of lifeline ferry services is critical as communities are often
completely reliant on these to access key services, education and employment
opportunities. Data on trip use for education/employment/NHS usage etc should also
be recorded to better understand customer needs. At time of booking there should be
a request for purpose of your journey, some may not want to provide this information,
(potential to also force an answer before proceeding to next stage of booking), but at
least this would give some idea of use/needs of the ferry service.

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Our island communities and many peninsula communities depend on these services.
They are critical lifeline routes. In terms of performance measures the satisfaction of
these communities with the service needs to be a measured together with feedback
from users of the ferry service.
It is also critical to individuals, particularly commuters, and local businesses that
performance measures are relevant to their experience, informative for the operator
and the Government, and ultimately lead to year on year improvement and reliability
over the life cycle of any contract awarded.
Timetable, Essential and Urgent Travel
We are aware that as ferry travel has become more popular, some services have
become more difficult to accommodate short-notice spaces for essential vehicle
travel by island residents and key workers.
Q16. Do you have any suggestions as to how the booking process
could release vehicle space on services when island travel with a
vehicle is essential?
Please explain your answer.
The needs of local residents is paramount. Also the visitor economy is very important
for the future sustainability of island communities and it is important to remember the
visitor season to our islands can be short and is in competition with a global industry.
Tourists & visitors to our islands are often dependent on using vehicles. Many would
find it difficult to use the active / public transport methods to limit demand for vehicle
space particularly given their requirement for luggage and limited public transport
options.
Keeping more tourist traffic in standby lanes until the last minute to ensure space was
available for local / urgent use could result in considerable uncertainty, reduced
bookings and a reduction in revenue for island businesses. This would generate
corresponding complaints from disappointed visitors and businesses unable to secure
income.
The situation would be better handled by increasing ferry capacity through additional
sailings. It is also worth noting that island communities have considerable concern
over the use of larger vessels sailing less frequently given the capacity of the
destination i.e. the island road network.

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Integration of Services 
Journeys on our ferry networks are often only part of a longer journey between the
traveller’s ultimate origin and destination. The end-to-end journey can combine the
use of several transport modes which can include public transport and/or active
travel (walking, wheeling, and cycling) or a private vehicle. An integrated transport
network that allows easier transition between the ferry and public transport or active
travel is a key enabler to encourage the use of our ferry networks without the need
for a private vehicle. This has benefits to the user such as making the transport
system more accessible, making better use of capacity on ferries and contributing to
net zero.   
Q17. What would encourage you to use public transport or active
travel as part of your overall journey when using the ferry services?
The current economic and challenging fiscal climate has placed considerable pressure
on Local Authority budgets and this is making it increasingly difficult to invest in
sustainable transport infrastructure projects. In Argyll and Bute this issue is
compounded by the fragile condition of large parts of the local road network which is
so vital to the region. As such, Argyll and Bute Council rely heavily on grant funding
such as Cycling Walking Safer Streets (CWSS) and Sustrans Community Links
funding to deliver active travel infrastructure projects in the region. Investment in
proper active travel infrastructure is required to make this a feasible option and this
needs to be designed to suit local circumstances and available budgets. Currently,
grant funding conditions set by third party funders can however make projects unviable
to deliver. There needs to be adequate public and active travel options on either side
of the ferry journey.  A number of our islands are large in size with a dispersed
population that requires the use of the private car to reach final destinations.  
Many of our communities have very limited public transport options and this is reducing
due to revenue constraints.  This applies on both sides of the ferry journey from the
mainland and islands. There could be other implications in taking this approach.  For
example, reaching Rothesay by the main ferry by public transport is a relatively easy
option provided it is timed with the leaving times of the ferry. Public transport on the
island is limited so this automatically restricts visitors to one part of the community or
having to go to considerable expense to say hire a car or use a taxi service. On Bute
what happens when the main ferry goes off line and people have no alternative but to
use Colintrive?  How will they get there by public transport?  More importantly how will
they return their original destination from Colintrive by public transport?
HITRANS have been taking forward a study regarding options to provide an improved
transport hub in Oban town centre focussing around the railway station and ferry

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marshalling area. The Council welcome this study and are encouraged by the work
undertaken to date however, we would also be keen to investigate the feasibility of
taking forward a park and ride facility as a possible alternative to  ease congestion in
Oban Town Centre.
Argyll and Bute has a wide range of public transport services including lifeline ferry
and air links, local and regional bus services, rail, trunk and public roads. We would
agree that the connectivity between all of these elements of the transport network is
vital to the region’s economy.
Local authority budget cuts – pressure strained transport budget.  96% of public
transport bus services in Argyll are subsidised by the Council. Opportunity for more
funding to be directed towards local authorities to support rural bus services which
are commercially unviable. At present the £500m committed by the Scottish
Government to improve bus services by targeting areas of congestion and bus
priority measures will predominantly benefit urban areas and do very little to address
the lack of public transport connectivity in many rural areas.  This is exacerbated by
the lack of rail connectivity in the majority of Argyll and Bute.
Free travel on ferries for under 22 years is welcomed however it should be
recognised that free travel is absolutely limited in a rural environment, and
dependent on the ferry service timetable available/bus timetable, – e.g. bus service
every 4 hours not even considering ferry connections. In Argyll and Bute 96% of the
bus services are funded/subsidised by the local authority. 
It should be a condition of the contract that the operator provides timeous notification
of its timetable fares etc for inclusion in the national journey planner. The Ferry User
Groups established could be taken forward as a vehicle for realising true integration.
These have worked well in allowing the local authority to integrate subsidised public
bus services to the ferry timetables. Rail have been reluctant to use the vehicle that
the established  Ferry User Groups offer and this should be rectified if true meaningful
public transport service integration is to be realised.
Island ferry services timetables should be integrated with island air services timetable.
Air services across rural Scotland are all continually being operated in small pockets
in isolation from each other. Argyll and Bute Council, Orkney Council, Shetland
Council, Comhairle nan Eilean Siar and Transport Scotland all have responsibility for
financially subsidising Public Service Obligation (PSO) air service routes and also
airports and each organisation carries out its own individual procurement for the air
services it has responsibility for. There is not a joined up approach – that could offer
many savings in procurement, advertising, training etc. Bundling the air services
together will offer better opportunities to stimulate competition and offer linkages not
currently being met and ensure no islands are left behind. For example ABC operate
and subsidise a PSO air service from Oban to Coll, Colonsay and Tiree. Transport
Scotland operate and subsidise a PSO from Glasgow to Tiree yet these services are
procured in isolation from one another with no joined up approach.

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Air services from Oban to the central belt and international airports of Glasgow or
Edinburgh would complement and mirror the air services supported to the south of
Argyll by Scottish Government from Campbeltown to Glasgow (another subsidised
Transport Scotland PSO route). Oban airport can easily accommodate the Scottish
Governments newly purchased Twin Otter aircraft that are utilised on the Scottish
Governments routes from Barra/Tiree connecting to Glasgow. The Tiree and Barra
flights all fly over Oban at present without connecting and this is seen as a missed
opportunity. As highlighted within the 2013 HITRANS economic air route development
report, new air services operating out of Oban airport offer the greatest economic
return for the west coast of Scotland – making it the perfect choice to act a s a regional
west coast hub airport. 
Capacity and Demand 
We have heard that the space for vehicles on busy ferry routes fills up quickly at
popular times, especially in summer. This makes it difficult for residents of those
islands, and visiting key workers, to travel with a vehicle at short notice.  
 
We propose to address ferry capacity issues by:  
• Using refreshed community needs assessments to identify different options
for service frequencies and vessel size 
• Collaborate with operators and communities to identify ways of using existing
and planned capacity better 
• Identify the key “pinch points” on the Clyde and Hebrides Ferry Service and
Northern Isles Ferry Service networks and consider options for additional
vehicle capacity where this is practical, beneficial, and affordable.     
Q18. Do you agree or disagree with this approach to dealing with
ferry capacity due to increased demand?  
☐ Agree
☒ Disagree 
Please explain your answer. 
Communication on a regular basis between the ferry operator and users of the ferry is
essential.  There needs to a requirement for regular dialogue informed by regular
transport capacity studies linked to estimates of future demand from industry and
residents.  The capacity of the current ferry fleet has been severely compromised due
to the age of the fleet and a lack of capacity to deal adequately with the impacts of
mechanical failure or other events. This impacts negatively not just on island residents

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but also the ability to attract people to the place in the future.  In addition the
importance of the visitor economy cannot be under estimated for our island
communities.  Without visitors many island services or businesses would not be
sustainable and a lack of capacity in the ferry network last summer for example, hit
hospitality businesses very hard when ferries were not available or diverted to cover
other routes.
Freight
The Scottish Parliament’s Net Zero Emission Transport (NZET) Committee
recommended reconsideration of wider policy on the provision of freight capacity on
our ferry routes; and the point at which profitable businesses should no longer be
reliant on public subsidy of their freight costs.
  
Q19. In what way do you think the costs of island freight transport
could be shared differently between users and public funding?
Being able to plan ahead over extended periods of time. Dedicated overnight freight
services as described previously is one idea. Or dedicated freight sailings at off peak
times for example, within the existing timetables could also be a consideration.
Incentives could be introduced to encourage operator innovation in service provision.
For example operators could be allowed to operate at their own cost, services
out with the specified contract timetable should they feel it is profitable to do so.
Consideration could be given to a maximum fare scale to allow tenders to use their
experience and innovation to 'pitch' fares/offers in order to create the maximum
revenue and thus reduce the level of subsidy.
The principle of freight user pays for investment funding whilst giving greater
transparency would inevitably result in significant increases for users and potentially
affect viability. The national government should meet a substantial part of the costs
whilst revenue generated through freight fares can off set some of the costs. 
Vessels and Ports 
To renew the vessel and port assets, required for the long-term sustainability of our
current networks, prioritising where to invest is required due to budget constraints in
the current financial environment. We are proposing that the following factors are
taken into consideration when making decisions on prioritisation: 
• The sustainability of ferry services by maintaining and increasing
reliability and resilience.

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• Ferry routes and services providing the primary transport connection
for people, goods and services required for the sustainability of each
community. 
• Those communities identified as at greater risk of depopulation and
economic decline.      
Q20. Do you agree or disagree that these are the right factors to
consider when making decisions on prioritisation?
☐ Agree
☒ Disagree 
Please explain your answer.
There are no trunk roads or rail services on any of Argyll’s 22 inhabited islands and a
number of our local island communities are accessed by lifeline ferry and air services
via local authority port and airport infrastructure. As with Transport Scotland, local
authorities require increased funding to futureproof and improve our transport assets
so that these can be a driver for national priorities such as inclusive economic growth,
decarbonisation and improved health and wellbeing. As it stands, many of Argyll and
Bute’s most fragile rural communities have been largely excluded from future transport
investment via STPR2 and this has the potential to exacerbate issues such as
depopulation, social isolation and rural fuel poverty. 
We are supportive of these factors however, it must include local authority ports,
harbours and ferry services or there is a risk that certain island communities will be
excluded. Argyll and Bute Council currently operate 4 ferry services to the islands of
Jura, Luing, Lismore and Easdale and we also own a number of ports which form part
of the CHFS ferry network. It is therefore vital that our infrastructure is considered as
part of future long term plans and investment programmes.
Q21. Currently the factors above are not ranked. Do you think they
should be?
☐ Yes
☒ No 
Please explain your answer. 
The Scottish Government have recently published “A Scotland for the Future – The
Opportunities and Challenges of Scotland’s Changing Population.” This document
recognises the significant challenge of depopulation in many rural communities and
an ageing and declining population represents one of the biggest challenges facing
many communities in Argyll and Bute. The Governments Strategy sets out four
‘building blocks’ which will serve as distinct work streams for the Population

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Programme and these include a “A More Balanced Population.” With rural
communities and those in the West experiencing population decline, while many in the
East experience increased population growth, we must ensure our population is more
balanced and distributed across Scotland so that all our communities can flourish. 
STPR2 could and should have provided a vehicle to address this building block given
the importance and necessity of adequate transport infrastructure to rural areas
however, at present there is a risk that the decision to de-scope local authority
transport services and infrastructure will exacerbate issues such as rural depopulation. 
It is again noted that many of our rural island and peninsular communities are entirely
reliant on Local Authority roads and public transport services for connectivity and these
communities will be largely excluded from investment via STPR2. In summary, Argyll
and Bute Council do not support Transport Scotland’s position with respect to local
infrastructure being considered out of scope of STPR2 and believe that this will
undermine local authority’s ability to support the delivery of the vison and objectives
of NTS2/STPR2. 
Low Carbon and Environmental Impact 
A Strategic Environmental Assessment will be carried out on the of the Islands
Connectivity Plan.  This process aims to ensure environmental and sustainability
aspects of the Plan are captured and considered in the development of policies and
plans detailed in the draft Islands Connectivity Plan.
Q22. What environmental issues do you believe should be captured in
the Strategic Environmental Assessment in relation to this plan?
Please explain your answer.
It will be difficult to achieve climate change objectives by reducing vessels speeds to
slow down on Carbon emissions as this is in direct conflict with users of the service
whose majority wish as fast a journey sailing as possible.
However consideration of how to best optimise the ferry services to transfer road
freight to sea will offer a reduction in road haulage miles and reduce the carbon
footprint. Untapped markets by identification of ferry routes that would optimise the
freight market would also bring added revenue and reduce the level of subsidy.
It simply requires investment in new ferries that are more efficient to operate and less
prone to mechanical breakdown and are also able to deal with increased weather
impacts.  The use of clean fuel technology needs to be employed asap whether that
is through electric motors or use of green hydrogen. Simply reducing vessel speeds
to lower emissions would lead to a poorer service and fossil fuels would still be used. 
Making maximum use of ferry capacity would also increase efficiency and perhaps the
use of flexible fares here could help with this.

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The Scottish Government committed in the Climate Change Plan to 30% of the ferry
fleet, owned by Scottish Government, to be low emission by 2032. The Scottish
Government is committed to looking at how they can use hybrid and low carbon energy
resources for the fleet, which is currently taking place through the small vessels
replacement programme.
Q23. Do you have any other suggestions in how ferry services can
contribute to the reduction of carbon emissions?
Please share your views.
There could in the future be innovative propulsion choices such as fuel cell
technology/diesel electric propulsion. 
Reduced carbon footprint can only be achieved where there is adequate public and
active travel options on either side of the ferry journey.  A number of our islands are
large in size with a dispersed population that requires the use of the private car to
reach final destinations.  
That said, passenger ferries are very popular with residents and visitors.  For example,
the Tayvallich to Jura Ferry and these connections should be encouraged and
supported wherever possible to provide credible alternatives to using vehicles. 
There could also be opportunities for regional boat builders if smaller, electric vessels
were commissioned by C MAL to open up accessibility in our coastal communities.
Consideration should be given as to how to best optimise the ferry services to transfer
road freight to sea will offer a reduction in road haulage miles and reduce the carbon
footprint. Untapped markets by identification of ferry routes that would optimise the
freight market would also bring added revenue and reduce the level of subsidy. 
Ferry Fares 
The Road Equivalent Tariff (RET) system of fares is in place across the Clyde and
Hebrides Ferry Service (CHFS) network for passengers, cars, coaches and small
(under 6 metres long) commercial vehicles. A different fares structure remains in
place for the Northern Isles. 
A key aim of RET was to allow ferry users to pay a fixed element plus a rate per mile
travelled, which is linked to the cost of the equivalent journey length by road in a
private vehicle. RET also resolved many previous issues of complexity in the fares
offering and fare-inconsistency across routes, within the CHFS network.

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The 3 key principles of RET are:
• Simplicity and Transparency - the basis for fares must have an
established rationale and simple for a user to understand.
• Comparability and Consistency - the basis for fares should be the
same for each community.
• Public Sector Affordability versus Community Sustainability - fare-
setting needs to balance the different requirements of public sector
affordability with sustaining communities.
Q24. Do you agree or disagree with retaining the current RET
principles set out above, as the basis of a ferry fares structure?
☐ Agree
☒ Disagree
Please explain your answer.
It needs to be recognised that each community has different needs and as a
consequence of this there cannot be a one size fits all policy. With specific regard to
Bute for example there is significant impact on residents and supply chains at peak
tourism times. For example, ambulance patient transfers delayed, mainland hospital
appointments missed, parts for local garages delayed. That said many local
businesses on Bute (and other Islands) depend on local visitors to remain viable so
there needs to be a balance struck to ensure the needs of all ferry users are fully taken
into account.
Whilst the concept in principle for fixed links is welcome, the suggestion that a fixed
link could be progressed to Mull is a distraction for the Craignure shore side project
(replacement pier and associated shore side infrastructure). There needs to be clarity
provided around the possibility of this fixed link location being progressed or not.
Confirmation either way and timescales should a fixed link be a likely will be a
consideration for the business case for the Craignure Pier development. A fixed link
to Mull, whilst bringing opportunities would also have the potential to increase
vehicular traffic on the existing ‘fragile’ road network as well as having the potential
to being detrimental to SGs policy of reducing car KMs by 20% by 2030.
Another example concerns the island of Mull where there is a commuting issue for
people working in Lorn on a daily basis. High ticketing prices at peak times therefore
on that route is likely to negatively impact on local residents to a greater extent rather
than visitors. ABC would welcome further details on the proposed STPR2
consideration of a fixed link to the island of Mull and where this link is proposed. We
have not to date seen mention of this proposal in any previous documentation. Fixed
links were only previously mentioned in relation to the Clyde and Hebridean Ferry
Services contract and not specifically to the island of Mull. Given the detrimental

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impact on island infrastructure that has resulted from the introduction of RET we would
have thought a fixed link would only compound this – again another example of why
there needs to be consideration of local authority infrastructure and a joined up
approach. We understand that a business case on this intervention is proposed and
we assume this will also identify what likely impacts such a transport intervention
would have on the local economy of Oban. The lack of clarity on the proposal is
causing uncertainty in terms of future ferry and port investment. ABC would request
an urgent meeting with TS to discuss this issue particularly in light of the islands
connectivity plan and recent announcements.
Significant consideration should be given to the provision of fixed links to islands
where it is cost effective. Whole life costings of the ferry service should be compared 
with a fixed link solution. Argyll and Bute Council have carried out a STAG
assessment on provision of a fixed link to Lismore,  Luing and Easdale where a fixed
link to these islands offers a solution to the provision of a ferry service. 
The issue of peninsula communities should also be addressed as although
connected to the mainland these communities can still suffer from isolation. Argyll
and Bute is characterised by numerous peninsulas separated by deep sea lochs.
We feel that a designation is needed for peninsula access along the same lines as
islands that conveys the  lifeline nature of ferry services to these areas in supporting
and sustaining social and economic well-being.
On Islay there are specific business needs that need to be taken account of that
impacts on the accessibility of the service for residents and also visitors. 
It is also worth noting that Argyll and Bute is characterised by numerous peninsulas
separated by deep sea lochs and includes 23 inhabited islands. It is important to retain
flexibility to provide and sustain access and economic stability because of the essential
and lifeline nature of ferry services. 
Introducing different levels of fares such as “islander fares” on Clyde and Hebrides
Ferry Service routes, could increase overall fare revenue and keep services more
affordable for islanders.  It could also allow use of different fare types to tackle
overcrowding of vehicle-deck capacity, on busier sailings through the year.
Q25. Do you agree or disagree with the option to create different
levels of fares for different types of users, e.g. islander and non-island
residents.
☐ Yes
☒ No 
Please explain your answer.

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The changing of ticketing prioritisation linked to measures such as peak demand fares
etc. may be a way to manage demand but there is a need to look at all potential
negative impacts of this approach.  For example, will dearer ticketing during
commuting times deter local residents accessing work opportunities?  Will it be used
as an excuse not to accept bookings at weekends where most demand for visitors are
due to change overs in self-catering? Will additional costs deter visitors to our islands
particularly where our islands are in close competition with mainland coastal
communities? Will it be balanced by significantly lower fares targeted at particular user
groups?
Levels of charges are by no means the only impediment to or stimulus of local
economic activity. Frequency and passage times have a significant bearing on traffic
generation, capacity and operating costs. Hours of operation also have a bearing on
quality of access. In contrast to Cowal where services run till late evening provided by
Western Ferries,  Bute , Gigha etc although relatively close to the mainland are cut off
from any physical communication with the outside world from early evening onwards
this is a serious economic and social constraint. Whilst considering additional
specifications to tender documents a review of existing specifications should also be
carefully considered.
There needs to be careful consideration of the islands and peninsulas needs and
ambitions for their communities when considering fare structures e.g. changes in
economy related to renewable energy and tourism etc and also meet the demands of
changing demographics and socio-economic profile. Ferry services need to be whole
life costed and flexible to unlock long term sustainable economic development and
achieve the government’s objectives of promoting solidarity, cohesion and
sustainability.
  
Q26. Which of these groups do you believe should be eligible for
islander fares?
☐ Permanent residents
☐ Second homeowners
☐ People who work, but do not live, on islands 
☐ Island residents who are currently students and living at mainland addresses
during term-time 
☐ Service providers 
☐ Nominated friends & family
☐ None

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Q27. Do you agree or disagree with a fares structure that both
encourages passengers to travel without a private vehicle and
incentivises travel at quieter periods? 
☐ Agree
☒ Disagree 
Please explain your answer. If other, please add further information. 
Argyll and Bute is characterised by numerous peninsulas separated by deep sea lochs
and includes 25 inhabited islands. It is important to retain flexibility to provide and
sustain access and economic stability because of the essential and lifeline nature of
ferry services.
The future economic needs of these remote communities should be identified to
ensure that any increase in fares, to accumulate more funding from users, does not
impact adversely on the economy. These types of economies are already fragile as
they are susceptible to the impact that uncontrollable factors can have on the seasonal
industries the majority rely on e.g. weather plays an important role in tourism, farming
and fishing and can make or break a season.
Tourists & visitors to our islands are usually dependent on using vehicles. 
Consequently, many would find it difficult to use the active / public transport methods
to limit demand for vehicle space particularly given their requirement for luggage and
limited public transport options. 
As already stated above, the current economic and challenging fiscal climate has
placed considerable pressure on Local Authority budgets and this is making it
increasingly difficult to invest in sustainable transport infrastructure projects. In Argyll
and Bute this issue is compounded by the fragile condition of large parts of the local
road network which is so vital to the region. As such, Argyll and Bute Council rely
heavily on grant funding such as Cycling Walking Safer Streets (CWSS) and Sustrans
Community Links funding to deliver active travel infrastructure projects in the region.
Investment in proper active travel infrastructure is required to make this a feasible
option and this needs to be designed to suit local circumstances and available
budgets. Currently, grant funding conditions set by third party funders can however
make projects unviable to deliver. There needs to be adequate public and active travel
options on either side of the ferry journey.  A number of our islands are large in size
with a dispersed population that requires the use of the private car to reach final
destinations