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Originally published on 19 May 2025.
This is our response to Transport Scotland’s consultation on the Just Transition draft plan for transport in Scotland.
While the draft outcomes broadly reflect what the Just Transition Plan for Transport should be aiming to achieve, they would benefit from greater detail and more specific, measurable targets.
It would also be helpful if the final Just Transition Plan for Transport could clearly indicate which of the action priorities outlined in the different parts of the plan link to which outcomes.
While there are projects referenced in the draft plan that will help support the successful roll out of Scotland’s public EV charging networks – such as the EVIF funding scheme – we do not think that the proposed outcomes and indicators will adequately track the success of Scotland’s public EV charging networks. Ensuring these networks are comprehensive, accessible and affordable for everyone is essential to enabling those who are reliant on a private vehicle to transition to electric alternatives.
The grouping of outcomes into fours may lead some readers to question whether the process was guided more by structure than by a comprehensive identification of all the essential outcomes for Scotland’s transport just transition. Clarifying the rationale behind this grouping in the final plan could help reinforce confidence in the robustness of the process.
The plan should include reducing speed limits as a priority action. In recent years, 20mph speed limits have become widespread across many areas of Scotland. This is a welcome development and there is evidence from Edinburgh that it has resulted in a reduction in both traffic speeds and collisions. Furthermore, a reduction in average speeds is likely to reduce the severity of injuries when collisions do occur.
However, for the average cyclist who is unable to comfortably maintain speeds close to 20mph and cycles well below the speed limit, motorised vehicle users can vary greatly in the understanding they show to cyclists slowing them down. This lack of understanding can contribute to an unwelcoming road environment. For nervous and less confident cyclists to be willing to cycle on these roads, 20mph speed limits would need to be more strongly enforced as a minimum.
A bolder approach would be to reduce speed limits to comfortable cycling speeds. This could be trialled in the busiest, central parts of selected Scottish towns and cities to begin with, then rolled out more widely if it showed positive results.
This will likely apply equally or more greatly to disabled people riding adapted cycles.
The plan should include encouraging safe ebike use as a priority action. The Scottish Government has previously provided funding through Energy Saving Trust for the purchase of ebikes and ecargo bikes. This technology can be transformative for getting less fit, less confident cyclists out on Scotland’s roads. It can serve to ‘flatten’ streets and enable non-athletic cyclists to keep apace of other motorised road users.
Unfortunately, there has at the same time been a proliferation of illegal non-speed limited ebikes which has led to growing public concern in some areas. Those riding these bikes at high speeds in areas shared with pedestrians – or non-ebike riders – can be seen as a danger to other users of these spaces, even where no incidents occur.
There is a potential risk that certain behaviours associated with the use of this technology could lead to public frustration, not only with the technology itself but with cyclists more broadly. To help maintain public support for cycling and ensure safety for all road users it might be worthwhile considering proportionate and well-designed enforcement measures for repeat offences. However, any such approach should be carefully implemented to avoid discouraging responsible and considerate cycling.
The plan should include the development of cycle routes that are clearly separated from roads used by larger motor vehicles as a priority action. While the plan references infrastructure for active travel, it would be helpful if it explicitly stated that this will be included. A dual approach combining separate cycle routes and reduced speed limits where separate cycle routes aren’t possible could be very effective. It may also help to build broader public and political support for active travel initiatives.
In addition, in areas where space constraints may initially appear to preclude the introduction of cycling infrastructure, consideration should be given to reconfiguring street layouts, such as introducing one-way streets to create room for dedicated cycle lanes. This would promote cycling while also helping to discourage unnecessary car use.
No, there is nothing else that we would like to see in the draft plan for people who are more likely to face challenges accessing affordable, convenient and safe travel. Our answer to question 4 above covers the gaps that we have identified.
As a first step, targeting the highest emitters while ensuring protections for low-income groups could be a sensible approach. The transport-related carbon footprints of higher earners are often disproportionately large compared to the rest of the population, especially those on low incomes or living in poverty.
Targeting some of the worst polluting behaviours could help to accelerate progress on reducing transport emissions. These include:
A flat tax per tonne of carbon is unlikely to be effective on its own. Unless set at a prohibitively high level – which could disproportionately impact lower-income groups – the wealthiest individuals could easily absorb this tax without changing their behaviour. A more effective approach could involve a progressive tax structure where the cost per tonne increases with each additional tonne emitted (eg first tonne costing £10, second £100, third £1000).
This would quickly make the most carbon intensive forms of private travel financially unattractive, even for high earners. The revenue generated could then be reinvested to support sustainable sectors of the economy while also incentivising “high carbon travellers” to consider more sustainable options.
There may be public concern that carbon taxes represent an overreach into personal choices. To help build support, such measures could be applied to a limited to a small number of high-emission activities. These might include private jet use, frequent commercial flying beyond a set threshold and private boat travel.
It could also be sensible to apply carbon pricing to the ownership of vehicles above a certain size or when more than a certain number are owned. Such a targeted approach would focus on the most carbon-intensive behaviours whilst having a minimal impact on the vast majority of the population.
A well designed progressive carbon tax targeting the most emissions-intensive activities could deliver rapid and meaningful reductions in emissions, and could help reshape societal norms, reducing the social acceptability of high emission lifestyles.
Our response here applies to non-transport workers, specifically oil and gas workers, although it could also apply to other sectors.
The first bullet point in the summary of future priorities highlights the need for workers and businesses to prepare for the transition. For many of these workers and businesses, the pace and scale of the changes involved may go beyond what they can realistically manage on their own. The third bullet point talks about exploring options to support workers and businesses facing the greatest challenges from the transition as well as improving signposting to green jobs information.
While this is encouraging, it would be helpful for the final plan to include more detail on the form that this support will take (for example, training programmes, financial support, etc). Scotland’s oil and gas sector provides well-paying jobs for a significant number of people, and transitioning this workforce into greener industries will require sustained strategic effort. This includes not only reskilling and retraining, but also ensuring that alternative opportunities are genuinely accessible, attractive and aligned with workers’ existing skills and aspirations.
Options provided:
A united stance across public, private and third sector groups – along with support from as many individuals as possible – will be essential in championing these initiatives. As these issues gain more attention nationally, this collective stance can help address concerns, build understanding and encourage wider support.
A coordinated, large-scale approach is unlikely to be driven by individuals alone. While individuals have an important role to play, they would likely require external support to help them to make an impact. This would most feasibly come from the public sector, or a publicly funded third sector organisation. There are clear opportunities to build this kind of coordination through shared forums – such as the HDV skills and diversity workshops recently delivered by Energy Saving Trust – which also offer valuable opportunities for shared learning .
Fleet rationalisation and active travel
The approach doesn’t mention how fleet rationalisation or active travel can help Scottish businesses meet net zero targets – nor any support that will be allocated for this.
Fleet rationalisation describes the process of downsizing fleets by identifying and removing non-essential vehicles, or vehicles that can be categorised as such through a manageable change in operations. Active travel solutions can complement fleet rationalisation efforts, as can encouraging the use of public transport in place of fleet vehicles where feasible. Some organisations have also successfully incorporated the use of car clubs into their operations to minimise fleet size and associated financial and carbon costs.
These can be effective mechanisms to reduce emissions and costs, but many organisations will need support to implement them. In most cases, this will be in the form of impartial, tailored advice – a key benefit of these approaches is that they’re relatively low cost. In fact, they are almost certainly lower cost than the alternative of continuing to own and operate superfluous vehicles.
Businesses with employees without off-street parking
It can be over five times as expensive to run an electric vehicle on the public charging network than on a domestic tariff. Several factors contribute to this difference, including higher VAT rates on public charging; the availability of very low cost overnight domestic tariffs; and the overheads associated with operating a public network that don’t apply to home charging. As a result, businesses whose staff don’t have access to off street parking may face higher costs. Furthermore, such businesses may have to contend with resistance to using these vehicles from staff finding public charging less convenient than using conventional fuelling infrastructure.
Businesses will likely meet these challenges in different ways. Some may choose to restructure fleet operations so more vehicles are based at their depots and run off charging infrastructure there. Introducing the infrastructure for this will come at significant cost. Furthermore, it may put pressure on their existing parking capacity. Staff who are used to keeping vehicles at home may be unhappy about the inconvenience of having to travel to these depots – potentially at their own expense – rather than having the car at home.
The draft plan doesn’t include any information on meeting the challenges this imposes. The most effective mitigation measures would be financial support and access to expert guidance on acquiring and operating the necessary charging infrastructure – as well as helping staff to adapt to new operational systems. This guidance could take the form of bespoke advice tailored to each organisation. In addition, an expert steering group could be established to develop and share best practice approaches for meeting these challenges.
Based on their titles, the indicators all seem appropriate – we have suggested some additions below. However, it would be helpful to have a clearer understanding of how each of these indicators will be measured and tracked. The final plan should also specify what success/failure looks like for each.
Outcome 1: Could include tracking the number of jobs over time to demonstrate new jobs being created. It would also be valuable to capture data on jobs created vs jobs lost as the sector transitions.
Outcome 2: It would be helpful to have a system for tracking the specific measures organisations are introducing to improve gender and age representation and equality of pay.
Outcome 3: This outcome and its indicators mention LGVs, HGVs, buses and coaches, but doesn’t mention zero emission cars.
Outcome 5: This outcome could also include mobility as a service penetration as an indicator.
Outcome 6: It would be useful to include a clear definition of what is meant by ‘basic services’ within the plan or the indicators for this outcome. This clarity is essential to ensure that the services provided are sufficient to support a good quality of life.
Outcome 7: It would be helpful to track how costs of bus services on the islands compare with those on the mainland.
Outcome 9: It would be valuable to also track perceptions of transport safety. If these are negative, people will be less likely to make use of services available, even if they are very safe.
Outcome 10: It would be useful to see a definition of what ‘accessible transport’ means in the plan or this outcome’s indicators.
Outcome 12: It is worth noting that active travel health benefits will be difficult to capture.
increases in cycling and footfall in areas where traffic calming or reduction measures have been introduced should be tracked. It would also be beneficial to track how confident and safe people feel about adopting active transport modes – particularly cycling. Any actions taken to improve these figures should also be recorded.
Statistics on bike theft should also be tracked.
Outcome 13: It would be useful to track instances of where new transport infrastructure includes nature restoration components as added value. Details of these restoration works should include whether they have taken place at the site of works, or in an area remote from the site. It should also note how the nature restoration has offset the impact of the site works – if this has been the reason for including restoration works.
Outcome 14: It is important to consider how air pollutants from transport sources can be measured separately from other sources. Along with mortality figures, it’s important to track prevalence of health conditions for which air pollution is known to contribute to morbidity.
Outcome 15: In some areas of Scotland achieving this outcome will require substantial upgrades to existing infrastructure. It will be important to identify these locations. One effective approach could be to identify areas already experiencing frequent transport delays or requiring ongoing maintenance to roads and related infrastructure. Once these areas have been identified a clear plan should be developed setting out how and when these infrastructure upgrades will be delivered. Progress with delivery should be tracked, and this should serve as an additional indicator for measuring success against this outcome.
Outcome 16: Robust reporting structures must be in place to ensure the accuracy of carbon accounting – particularly when monitoring emissions originating from abroad.
It would be helpful to track how the price of public charging differs from the price of home charging for EV drivers.
It would also be helpful to monitor the level of charging infrastructure in areas relative to the demand full vehicle electrification would create (noting that this will be higher per vehicle in areas with low levels of off-street parking available).
Neither of these directly align with any of the stated outcomes as none of them specifically address electric cars.
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Last updated: 18 July 2025
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