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3. Towards a Strategy for Tolled Bridges
3.1 Number of Written Responses Received
Number of Responses per Question

The twelve Tolling Strategy questions each elicited between 32 and 41 responses, with an average of 36.3 responses per question.
Questions concerned with tolling measures to reduce traffic and congestion on tolled bridges (questions 7 and 8) elicited the highest number of responses, with an average of 40.5 responses each.
Question 9, which is concerned with tolls reflecting the cost of wear and tear, elicited the second highest number of responses (39).
Questions 5 (multiple crossing discount vouchers) and 6 (common vehicle classification system) each elicited 36 response, and questions concerned with exemptions (questions 1 to 4) elicited an average of 35.3 responses each.
Questions concerned with procedures for changing tolls or charges (questions 10 to 12) elicited an average of 34.3 responses each.
3.2 Findings
3.2.1 Exemptions
Question 1:Do you think that the system for verifying Blue Badge exemptions should be changed?If so, can you suggest what these changes should be?
The number of responses received to question 1 by respondent type is as follows:
Question 1 | No. of Responses | % of comments received | "yes" to change | "no" to change |
|---|
Business Sector | 3 | 9% | 1 | |
|---|
Bridge Authority | 2 | 6% | 1 | |
|---|
Other Public Body | 1 | 3% | | |
|---|
Lobby group | 2 | 6% | 2 | |
|---|
Representative Organisation | 6 | 18% | 5 | |
|---|
Research Body | 1 | 3% | | 1 |
|---|
Local Authority | 9 | 27% | 6 | 1 |
|---|
Local Councillor | 1 | 3% | 1 | |
|---|
Individual | 6 | 18% | 3 | 2 |
|---|
Regional Transport Partnership | 1 | 3% | | |
|---|
Transport Provider | 1 | 3% | | |
|---|
Total | 33 | 100% | 19 | 4 |
|---|
Many respondents said that the need for and methods of verification are symptoms of a wider problem concerning Blue Badge Scheme administration and believed that such matters go beyond the scope of the Tolled Bridges Review.
Most respondents felt that the solution to Blue Badge verification problems lies in emerging technology, e.g. having Blue Badges with a readable barcode, rather than changes to current verification procedures by tolling operators, although some respondents anticipated problems with electronic tolling since Blue Badges are registered to individuals rather than vehicles.
Justification for tolling exemptions for Blue Badge holders was questioned by a small number of respondents who understand the Blue Badge scheme to have been designed to provide car-parking benefits, rather than exemptions from transportation costs, for qualifying travellers.
Not withstanding technological problems and solutions, the following changes to current arrangements were also suggested:
- Adopt a consistent system at all three tolled bridges
- Adopt the system developed for Edinburgh's Road User Charge Scheme
- Adopt the same audit procedure that is used for other exempt vehicles
- Stop verification checks at the tolled bridges and accept the risk of misuse
- Facilitate pre-registration by making vouchers more widely available
- Blue Badge exemptions should operate in the same way as concessionary travel
- Provide dedicated tollbooths
- Develop a central register of Blue Badge holders
MACS, the Scottish Ministers' statutory advisors on the incorporation of the interests of disabled people into Scottish transport policy, consider that Blue Badge exemption vouchers should be known as 'exemption vouchers' rather than 'disabled vouchers'.
Tackling the issue of Blue Badge verification is believed by many respondents to go beyond the scope of the Tolled Bridges Review but a number of short and longer term measures could assist in alleviating the problems outlined in the Consultation Paper. MACS suggest that the way in which Blue Badge exemptions are described requires consideration. Some respondents are not convinced about the justification for these exemptions.
Question 2: Do you consider that the exemptions for emergency service vehicles should remain limited to the Ambulance, Fire and Police Services, or should we consider extending this to cover other key services?
The number of responses received to question 2 by respondent type is as follows:
Question 2 | No. of Responses | % of comments received | "yes" to extension | "no" to extension |
|---|
Business Sector | 3 | 9% | 3 | |
|---|
Bridge Authority | 2 | 6% | 2 | |
|---|
Other Public Body | 2 | 6% | 1 | 1 |
|---|
Lobby group | 4 | 11% | 2 | 2 |
|---|
Representative Organisation | 4 | 11% | 2 | 2 |
|---|
Research Body | 1 | 3% | 1 | |
|---|
Local Authority | 9 | 26% | 8 | 1 |
|---|
Local Councillor | 1 | 3% | | 1 |
|---|
Individual | 8 | 23% | 6 | 2 |
|---|
Regional Transport Partnership | 1 | 3% | 1 | |
|---|
Total | 35 | 100% | 26 | 9 |
|---|
Three-quarters of quantitative responses to question 2 consider that exemptions should be extended to other key services.
The most frequent suggestion was to make tolling exemptions consistent with Road User Charging (Exemption from Charges) (Scotland) Regulations 2004 or to exempt Coastguard vehicles, consistent with these Regulations. Several respondents suggested exemptions for Doctors on call and slightly fewer suggested exemptions for Bomb Disposal Unit vehicles.
"… it makes perfect sense to extend this exemption to include HM Coastguard registered vehicles. HM Coastguard is already a recognised '999' service and particularly relevant to the bridges because of the proximity to busy commercial and leisure waters."
- Lobby Group
Other suggestions included: the Royal Military Police vehicles, vehicles used by volunteer drivers who provide a free patient transport service, and other non-emergency vehicles used by medical services such as health visitors and the blood transfusion service. One respondent also supported local discretionary powers, as has benefited the Princess Louise Scottish Hospital for Limbless Sailors and Soldiers.
Most responses were indicative of an association between tolling exemption and faster bridge crossing time. Some respondents, however, perceived difficulties for toll collectors with the necessary 'on-sight' recognition of non-blue light vehicles and in distinguishing 'emergency' trips by such vehicles from trips for other purposes.
There is general support for consistency with Road User Charging (Exemption from Charges) (Scotland) Regulations 2004, which would permit exemptions for Coastguard vehicles, and some lesser support for exemptions for non-emergency medical trips. Most responses suggest there is a natural relationship between tolling exemption and faster bridge crossing time, which may not necessarily be the case for vehicles without a blue light.
Question 3: Vehicles used by bridge authorities to respond to breakdowns on each bridge are exempt. Do you see a case for extending exemptions to the AA, RAC or other commercial breakdown services responding to breakdowns on the road network other than where this is the responsibility of the bridge authorities?
The number of responses received to question 3 by respondent type is as follows:
Question 3 | No. of Responses | % of comments received | "yes" to exemption | "no" to exemption |
|---|
Business Sector | 3 | 9% | 3 | |
|---|
Bridge Authority | 2 | 6% | | 2 |
|---|
Other Public Body | 1 | 3% | | 1 |
|---|
Lobby group | 4 | 12% | 2 | 2 |
|---|
Representative Organisation | 4 | 12% | | 3 |
|---|
Research Body | 1 | 3% | 1 | |
|---|
Local Authority | 9 | 27% | | 9 |
|---|
Local Councillor | 1 | 3% | | 1 |
|---|
Individual | 7 | 21% | 1 | 6 |
|---|
Regional Transport Partnership | 1 | 3% | | 1 |
|---|
Total | 33 | 100% | 7 | 25 |
|---|
Most respondents were not in favour of extending exemptions to commercial breakdown services responding to breakdowns on the road network. The reasons given for this opinion were mainly:
- Adequacy of the service provided by bridge support vehicles
- Commercial organisations recover their costs from customers
- Difficulties distinguishing recovery trips from trips for other purposes
"(we) see no reason to exempt commercial breakdown services from paying tolls as they recover their costs from the motorist. They will not attend to the breakdown any quicker if they are exempt from paying a toll. "
- Bridge Authority
Those in favour of exemptions for breakdown services gave the following main reasons:
- Consistency with actual/planned exemptions in UK congestion charging schemes
- Breakdown services assist in the relief of congestion on the road network and provide an emergency service for drivers to the benefit of all road users
- Breakdowns on the wider road network can cause delays on the bridges
" Rescue and recovery services make a vital contribution to road safety and congestion management in providing swift management of roadside incidents thus improving traffic flow for public transport, commercial vehicles and private cars and positively impacting on the economy in helping to deliver more reliable journey times."
- Business Sector
Some of those in favour of extending exemptions to commercial breakdown service providers further suggested that such an exemption should be limited to certified rescue and recovery operators. However the respondent who expressed no opinion was concerned only that any extension be fair to all commercial breakdown operators.
The predominant view is that tolling exemptions for commercial breakdown service providers is not justified in terms of direct benefits to traffic on the toll bridges and that the benefits experienced by road users more generally as a result of these services, although reflected in some UK congestion charging schemes, should not be reflected in a bridge tolling strategy.
Question 4: Should public transport vehiclesand multiple occupancy vehicles be considered for exemption from bridge tolls?
The number of responses received to question 4 by respondent type is as follows:
Question 4 | No. of Responses | % of comments received |
|---|
Business Sector | 4 | 10% |
|---|
Bridge Authority | 2 | 5% |
|---|
Other Public Body | 1 | 3% |
|---|
Lobby group | 6 | 15% |
|---|
Representative Organisation | 5 | 13% |
|---|
Research Body | 1 | 3% |
|---|
Local Authority | 9 | 23% |
|---|
Local Councillor | 2 | 5% |
|---|
Individual | 7 | 18% |
|---|
Regional Transport Partnership | 1 | 3% |
|---|
Transport Provider | 2 | 5% |
|---|
Total | 40 | 100% |
|---|
All 40 respondents answered or commented on exemptions for public transport vehicles and 37 respondents answered or commented on exemptions for multiple occupancy vehicles ( MOVs).
Exemptions for Public Transport Vehicles: Quantitative results were as follows:
| "yes" to exemption | "no" to exemption |
|---|
Business Sector | 4 | |
|---|
Bridge Authority | 2 | |
|---|
Other Public Body | 1 | |
|---|
Lobby group | 4 | 1 |
|---|
Representative Organisation | 4 | |
|---|
Research Body | 1 | |
|---|
Local Authority | 9 | |
|---|
Local Councillor | 1 | |
|---|
Individual | 6 | 1 |
|---|
Regional Transport Partnership | 1 | |
|---|
Transport Provider | 2 | |
|---|
Total | 35 | 2 |
|---|
Almost all respondents to this part of question 4 supported exemptions for public transport vehicles, consistent with exemptions under Road User Charging (Exemption from Charges) (Scotland) Regulations 2004.
" Ministers have already made a policy decision to exempt buses under road user charging regulations; the justification for this applies to the toll bridges as much as to urban charging schemes."
- Representative Organisation
A number of respondents said they supported exemptions for public transport vehicles as this would be wholly in line with attempts to encourage modal shift and sustainable travel, to assist traffic management and stabilisation, and to reduce congestion.
However, several respondents felt that a clear definition of 'public transport vehicle' is required, with various, mostly conflicting, suggestions for inclusions and exclusions being made, including: tour and private hire coaches, buses and minibuses, and taxis.
One individual supported exemptions for public transport vehicles only if savings are passed on to passengers.
Exemptions for Multiple Occupancy Vehicles: Quantitative results were as follows:
| "yes" to exemption | "no" to exemption |
|---|
Business Sector | 1 | |
|---|
Other Public Body | 1 | |
|---|
Lobby group | 2 | 1 |
|---|
Representative Organisation | | 2 |
|---|
Research Body | | 1 |
|---|
Local Authority | 3 | 2 |
|---|
Individual | 4 | |
|---|
Transport Provider | 1 | |
|---|
Total | 12 | 6 |
|---|
Most respondents to this part of question 4 were firmly in favour of a tolling regime that favours MOVs over single occupancy vehicles ( SOVs). While twelve of these respondents supported relief by exemption, others - including some of those unequivocally opposed to exemptions for MOVs - said that a discounted toll for MOVs would be more appropriate.
Several respondents in favour of a discount rather than an exemption for MOVs suggested that discounts should vary according to the time of day and should reflect the individual traffic management needs of each bridge. One respondent, however, felt that discounts would have to be significant to be effective in encouraging car sharing. Opinions on discounts are discussed further under question 5.
" Exempting MOVs could place an undue burden on SOVs - many of which will be business. It may be worth noting that many vehicles which are classified as SOVs on passing through the tolls may have been MOVs when travelling in the opposite direction."
- Business Sector
Six respondents were firmly against tolling regimes that favour MOVs. These, and other, respondents said that congestion management is outwith current tolling remits and that incentives to encourage MOVs should be part of a wider (local, regional or national) congestion charging strategy, not part of a tolling regime.
" The issue of Multi Occupancy Vehicles brings up the fundamental question - what is the purpose of the bridge toll? The purpose of the Tay Road Bridge toll is to cover the cost of maintaining the bridge, it is not congestion charging."
- Local Authority
Several respondents felt that a clear definition of 'multiple occupancy' is required. One respondent was concerned that verification procedures could result in delays at the tolling plaza, and others have concerns about the detection of occupancy under electronic tolling.
There is widespread support for exemptions for public service vehicles, in line with Road User Charging (Exemption from Charges) (Scotland) Regulations 2004. Most responses were in favour of tolling advantages for MOVs, although many respondents felt that a discount is more appropriate than an exemption, and some felt the level of discount should reflect the particular circumstances of each bridge. Other respondents, however, believe that measures that encourage MOVs should belong to a wider congestion management strategy and should not be reflected in bridge tolling tariffs. Some respondents say that clear definitions of 'public transport vehicle' and 'multiple occupancy vehicle' are required.
3.2.2 Discount Schemes
Question 5: Should tolled bridges offer multiple crossing discount vouchers ( MCDVs) to all bridge users, or particular classes of users such as buses or multiple occupancy vehicles? If so, why should this be?
The number of responses received to question 5 by respondent type is as follows:
Question 5 | No. of Responses | % of comments received |
|---|
Business Sector | 2 | 6% |
|---|
Bridge Authority | 2 | 6% |
|---|
Other Public Body | 1 | 3% |
|---|
Lobby group | 6 | 17% |
|---|
Representative Organisation | 5 | 14% |
|---|
Local Authority | 9 | 25% |
|---|
Local Councillor | 1 | 3% |
|---|
Individual | 7 | 19% |
|---|
Regional Transport Partnership | 1 | 3% |
|---|
Transport Provider | 2 | 6% |
|---|
Total | 36 | 100% |
|---|
Quantitative results were as follows:
Question 5 | MCDVs for all users | MCDVs for buses/ MOVs | "No" to MCDVs |
|---|
Business Sector | 2 | | |
|---|
Bridge Authority | | 1 | 1 |
|---|
Other Public Body | | 1 | |
|---|
Lobby group | 2 | 2 | 2 |
|---|
Representative Organisation | | 1 | 4 |
|---|
Local Authority | 1 | 1 | 5 |
|---|
Local Councillor | 1 | | |
|---|
Individual | 4 | 1 | 2 |
|---|
Regional Transport Partnership | | | 1 |
|---|
Transport Provider | | | 1 |
|---|
Total | 10 | 7 | 16 |
|---|
30% of the quantitative responses to question 5 were in favour of general availability of MCDVs for the benefit of all types of frequent bridge users.
" It is normal practice for high users of any commodity to benefit from a discount."
- Lobby Group
21% of the quantitative responses to question 5 were in favour of allowing MCDVs to MOVs only, or additionally to public transport vehicles if not fully exempt.
The remainder of the quantitative responses to question 5 did not support MCDVs for any class of bridge user, although most of these respondents said that public transport vehicles should be exempt. The main reason given for opposing MCDVs was a concern that MCDVs inappropriately reward certain types of crossing e.g. single occupancy vehicles travelling at peak periods. However there was little belief that the availability of these vouchers induce such crossings nor that their withdrawal would make much impact on levels of congestion.
Other Functions of Discounts: Most respondents who did not support discounts for multiple crossings were in favour of discounts to reward multiple-occupancy. There was also support for the use of discounts to reward efficient methods of toll payment, both now and under any electronic tolling system, with perceived benefits including reduced administration costs and faster passage through tolling plazas.
" In part, the principle of appearing to give discounted travel sends the wrong message. However, the use of vouchers actually permits bridge administrations to lower collection costs … enabling them to pass on the cost-savings to customers as a form of encouragement to them to adopt that means of payment."
- Individual response
One respondent suggested discounts could also be used as a tool to encourage 'greener' forms of transportation.
Most respondents believe public transport vehicles should be exempt rather than discounted. A significant number of respondents support multiple crossing discount vouchers for all bridge users but a larger proportion believe this sort of discount offers inappropriate rewards, though few respondents said it induces additional traffic. Many respondents would prefer to see discounts being used to encourage 'positive' behaviours such as multiple occupancy and efficient means of payment.
3.2.3 Classification of Vehicles
Question 6: What are your views on a common vehicle classification system for levying tolls at all Scotland's tolled bridges?
The number of responses received to question 6 by respondent type is as follows:
Question 6 | No. of Responses | % of comments received |
|---|
Business Sector | 3 | 8% |
|---|
Bridge Authority | 2 | 6% |
|---|
Other Public Body | 1 | 3% |
|---|
Lobby group | 6 | 17% |
|---|
Representative Organisation | 5 | 14% |
|---|
Local Authority | 9 | 25% |
|---|
Local Councillor | 1 | 3% |
|---|
Individual | 6 | 17% |
|---|
Regional Transport Partnership | 1 | 3% |
|---|
Transport Provider | 2 | 6% |
|---|
Total | 36 | 100% |
|---|
There were no objections to this suggestion and the majority of respondents were strongly in favour. A common vehicle classification system is seen by most respondents as an essential element of interoperability and accordingly many urged that classification be common not just across Scotland, but across the UK and Europe. A common system was also said to provide greater consistency for travellers, although some respondents noted that a common classification system need not translate into a common tolling tariff for Scotland. Two respondents suggested a common classification system would improve the analysis and comparison of traffic data.
Although well supported, the establishment of a common classification system and the detection of the relevant criteria at tolling plazas and under electronic tolling were, however, seen as potentially problematic.
Most respondents agree that a common vehicle classification system is sensible but ideally should also apply beyond Scotland. Difficulties in defining and detecting the relevant criteria are anticipated.
3.2.4 Reducing Traffic and Congestion on Tolled Bridges
Question 7: Should we encourage modal shift from single occupancy cars to public transport and multiple occupancy vehicles on all tolled bridges? If so, how might this be achieved?
The number of responses received to question 7 by respondent type is as follows:
Question 7 | No. of Responses | % of comments received | "yes" | "no" |
|---|
Business Sector | 3 | 7% | | |
|---|
Bridge Authority | 2 | 5% | 2 | |
|---|
Other Public Body | 2 | 5% | 1 | |
|---|
Lobby group | 6 | 15% | 4 | |
|---|
Representative Organisation | 5 | 12% | 2 | |
|---|
Research Body | 1 | 2% | 1 | |
|---|
Local Authority | 9 | 22% | 6 | |
|---|
Local Councillor | 2 | 5% | | |
|---|
Individual | 7 | 17% | 6 | |
|---|
Regional Transport Partnership | 2 | 5% | 1 | |
|---|
Transport Provider | 2 | 5% | 2 | |
|---|
Total | 41 | 100% | 25 | 0 |
|---|
Principle: Most respondents were generally in favour of encouraging modal shift on all tolled bridges. However a significant number felt that this should be considered on a bridge-by-bridge basis as levels of congestion, which was seen as the only justification for such a measure, vary. This was especially regarded as unjustified at Erskine Bridge.
A small number of respondents felt it would be inappropriate to encourage modal shift by means of tariffs at the tolled bridges as a matter of principle. For these respondents, modal shift aspirations are part of a much wider issue and should be considered in the context of National or Regional Road User Charging, rather than the narrower framework of bridge tolls.
" This question cannot be answered by reference to the bridges alone. In principle we agree with the points made but achieving these objectives are much more complex than indicated. Overall travel behaviour is more volatile and changeable than implied by a narrow representation of mode choice change within a single corridor … Sustainable changes will only be achieved if "push" and "pull" measures are planned to work together and likely impacts will be over networks and lifestyles rather than narrow corridors and modes."
- Representative Organisation
Method: The most effective means of encouraging modal shift on the tolled bridges was broadly agreed to be more frequent, capacious, reliable and attractively priced public transport alternatives, which are better tailored to the origins, destinations and shift patterns of bridge users and which offer seamless interchange facilities.
" Many users of the Forth Road Bridge are not travelling to central Edinburgh, but to surrounding areas such as West Lothian and Midlothian. For these users to be able to switch to public transport, a quality service must run to those areas."
- Lobby Group
A broad range of methods for encouraging modal shift were suggested, including:
- A tolling differential or discount for multiple occupancy vehicles
- A higher toll for single occupancy vehicles at peak periods
- A tolling differential by time of day
- Directional tolling to target peak flows
- Introduction or extension of priority lane(s) and/or dedicated tollbooth(s) for efficient road users
- Introduction or expansion of Park & Ride/Choose facilities
- Better real-time information about bridge delays with pointers to alternative modes of transportation
- A strong lead in promoting car-sharing and more flexible working patterns to minimise trips on congested routes during peak periods
Many respondents were concerned that penalties for single occupancy vehicles travelling at peak periods could have unfavourable consequences for non-tolled routes and would be unfair to the very many drivers who have no reasonable alternative to their current time and mode of journey.
" Don't just penalise the lone driver thinking they have an alternative ... My wife works shifts so cannot be guaranteed a straight timetable etc. Assuming her shift is when a bus and train is actually running, the bus/train is more expensive than the car and to go by train would mean 2 buses, then a train, then two buses at the other end, adding an extra 1_ hours to her daily journey. To go all the way by bus would add at least 2_ hours to her journey, and both (options) may also involve sitting about at either end as she may not get to town at exactly the time she is due to start. She drives against the flow of traffic so does not add to the congestion."
- Individual Response
Most respondents are in favour of tolls as a tool for encouraging modal shift, but some believe it should be part of a wider congestion management strategy. Better public transport alternatives are widely held to be key to success but many respondents urged against penalties for travellers who are unable to shift either their mode or time of travel because of inflexible or irregular work obligations.
Question 8: Do you think that raising tolls at peak times would result in less congestion at those times?
The number of responses received to question 8 by respondent type is as follows:
Question 8 | No. of Responses | % of comments received |
|---|
Business Sector | 4 | 10% |
|---|
Bridge Authority | 2 | 5% |
|---|
Other Public Body | 1 | 3% |
|---|
Lobby group | 6 | 15% |
|---|
Representative Organisation | 5 | 13% |
|---|
Research Body | 1 | 3% |
|---|
Local Authority | 9 | 23% |
|---|
Local Councillor | 2 | 5% |
|---|
Individual | 7 | 18% |
|---|
Regional Transport Partnership | 2 | 5% |
|---|
Transport Provider | 1 | 3% |
|---|
Total | 40 | 100% |
|---|
Qualitative results are not provided for question 8 as only a very small number of responses were wholly unqualified.
Around half of respondents felt this measure would have some degree of success, with several respondents persuaded by the impact of London's Congestion Charging Scheme. However, only a small number of respondents indicated unqualified support for such an initiative.
Other respondents to question 8 either rejected this option, did not express a view on the impact of increased tolls at peak times or qualified their view on the basis that such a measure would be unfair to the very many bridge users who have no or limited flexibility in their mode or time of travel because of the location of their place of work and/or inelastic or irregular shift patterns.
" Many drivers have little choice in the manner or timing of their crossings, often confined to travelling at peak time in order to conform with working hours or other time limited constraints. They may not have the option of transferring their journey to public transport for a variety of reasons - whether that is because public transport does not offer them access to their destination, takes longer than the car, is not available at the outset or is unsuitable to them or their need(s)."
- Lobby Group
There was therefore a strong view that this measure should only be considered in tandem with provision of the types of public transport improvements outlined in responses to question 7. Again, several respondents felt peak increases should be considered on a bridge-by-bridge basis as levels of congestion differ.
A number of respondents felt that a peak increase would have to be substantial to make a significant impact on congestion levels and concern was expressed that this could simply lead to spreading or moving of peak periods or displacement of congestion onto untolled routes.
One respondent suggested that the effectiveness of peak increases would be enhanced if coupled with a reduction or elimination of tolling charges during off-peak periods.
Most respondents are in favour of tolls as a tool for encouraging modal shift. Some preferred a 'carrot' approach to a 'stick', others think both approaches are necessary. Although around half of respondents believe increased tolls at peak periods would have some degree of success, such a measure received limited support. The lack of suitable public transport alternatives and the limited flexibility of many commuters were the main reasons for opposing this idea. Most said that better public transport alternatives are key to success.
3.2.5 Tolls Reflecting the Cost of Wear and Tear
Question 9: Should tolls reflect the impacts of different vehicle types on the need for maintenance, repair and strengthening programmes? If so, do you have suggestions for how this might be done?
The number of responses received to question 9 by respondent type is as follows:
Question 9 | No. of Responses | % of comments received | "yes" | "no" |
|---|
Business Sector | 4 | 10% | | 1 |
|---|
Bridge Authority | 2 | 5% | 2 | |
|---|
Other Public Body | 1 | 3% | 1 | |
|---|
Lobby group | 6 | 15% | 3 | |
|---|
Representative Organisation | 5 | 13% | 2 | |
|---|
Research Body | 1 | 3% | 1 | |
|---|
Local Authority | 9 | 23% | 6 | 1 |
|---|
Local Councillor | 1 | 3% | 1 | |
|---|
Individual | 7 | 18% | 5 | 1 |
|---|
Regional Transport Partnership | 1 | 3% | | |
|---|
Transport Provider | 2 | 5% | | |
|---|
Total | 39 | 100% | 21 | 3 |
|---|
Principle: The majority of quantitative responses to question 9 supported the principle of tolls reflecting the cost of wear and tear.
The qualitative responses included a significant number of respondents who were either firmly against this suggestion, or felt strongly that this issue should not be considered in isolation from others, such as the benefits that the haulage industry brings to the Scottish economy and the preference for a smaller number of heavy goods vehicles than a larger number of light goods vehicles in terms of traffic stabilisation and congestion. Others commented that as the number, proportion and impact of heavy vehicles varies from bridge to bridge a common approach or charge is not appropriate. Clear tolling objectives were therefore seen by many as key to an informed response to question 9.
" At one level it is logical for tolls to reflect the maintenance costs … However, closer consideration reveals that the types of vehicle which would incur the highest charges are those vehicles which for other reasons might warrant the opposite. Conversely the type of use which represents the least efficient use of a bridge in transport, economic and environmental terms (the regular single occupant vehicle) incurs the lowest charge."
- Local Authority response.
A few respondents commented that a toll set according to the principle suggested by question 9 must necessarily be arbitrary as a toll that accurately reflected cost of impact would be prohibitive to heavy vehicles. Displacement of traffic to uncharged roads was seen as a particular risk if tolls were to increase significantly for particular classes of vehicles.
One respondent further suggested that impact on bridge maintenance costs should instead be considered in the context of a National Road Pricing scheme and another felt that revenues are already collected in other ways for maintenance of the road network, with heavy vehicles paying a higher rate of Vehicle Excise Duty than other vehicles, and that costs associated with toll bridge maintenance should not be separately charged.
Several respondents discussed question 9 only in relation to public transport vehicles and repeated their views expressed in response to question 4 that public transport vehicles should be exempt from tolls as they are efficient users of road space.
Methods: Around one-quarter of respondents to question 9 commented on how tolls should reflect the impacts of different vehicle types on the need for maintenance, repair and strengthening programmes and made the following suggestions:
- Toll based on axle loading
- Toll based on number of axles and height of vehicle above its first axle
- A graduated toll based on gross carrying capacity
- The highest tolls should reflect the most damaging forms of suspension
Several respondents said that, ideally, the relevant criteria should be electronically detectable.
Respondents were almost equally divided on this issue. Those against higher tolls for heavier vehicles said it is necessary to consider a much wider range of issues when setting toll levels and believe that the interrelationship of these issues is complex. Some respondents are concerned that too large an increase could be counterproductive and could have other unfavourable consequences beyond the bridges themselves. Others commented that as the number and impact of heavy vehicles varies from bridge to bridge a common approach is not appropriate. . Several respondents said that, ideally, the relevant criteria should be electronically detectable.
3.2.6 Procedure for Changing Tolls or Charges
Question 10: Do you think the current process involving Public Local Inquiries ( PLIs) is appropriate for making changes to tolls or charges to meet the costs of managing, maintaining and operating a bridge?
The number of responses received to question 10 by respondent type is as follows:
Question 10 | No. of Responses | % of comments received | "yes" | "no" |
|---|
Business Sector | 2 | 6% | 1 | 1 |
|---|
Bridge Authority | 2 | 6% | | 2 |
|---|
Other Public Body | 1 | 3% | | |
|---|
Lobby group | 5 | 16% | 2 | 2 |
|---|
Representative Organisation | 4 | 13% | 1 | 3 |
|---|
Research Body | 1 | 3% | | 1 |
|---|
Local Authority | 9 | 28% | | 9 |
|---|
Local Councillor | 1 | 3% | | 1 |
|---|
Individual | 6 | 19% | 2 | 4 |
|---|
Regional Transport Partnership | 1 | 3% | | 1 |
|---|
Total | 32 | 100% | 6 | 24 |
|---|
80% of the quantitative responses to question 10 do not think that the current process involving PLIs is appropriate for making changes to tolls or charges to meet the costs of managing, maintaining and operating a bridge. These, and other, respondents are mainly concerned about the time and cost involved in dealing with even single objections.
" The current arrangements result in the iniquitous position where a single objector can delay the introduction of necessary toll increases at great expense to the public purse. A much quicker and more flexible approach is required so that tolls can be easily changed to meet changing circumstances but all still within a regulatory framework."
- Representative Organisation
Several respondents commented that there are many other charges for public services, such as parking charges, which can be varied without the need to conduct a PLI.
Around a third of respondents believe that changes to meet the cost of maintenance and repairs in particular should not be subject to the current PLI process and some suggested that increases for those purposes should be provided for in the Tolling Orders or should be determined by the Bridge Authorities, possibly with approval of the Scottish Ministers.
Around one-fifth of respondents support the current process. Those in favour said it provides a means of essential public consultation and accountability, although some suggested that this should be assured through an alternative, less complex but still independent, process. And although not in favour of the current PLI process, two respondents felt that PLIs are appropriate where public concern is significant.
Most respondents believe the PLI process to be an overly lengthy and unjustifiably expensive way of changing tolls or charges, although a small number think it is appropriate where public concern is significant. One in five respondents support the process as it provides a means of essential public consultation and accountability. However, some of these respondents said that they would be prepared to consider an alternative procedure which balances democracy and efficient decision-making.
Question 11: Do you consider that final approval by Scottish Ministers is an essential safeguard for toll/charge payers or do you think the final decision is a matter for the management authority for the bridge?
The number of responses received to question 11 by respondent type is as follows:
Question 11 | No. of Responses | % of comments received | SMs | BA |
|---|
Business Sector | 3 | 8% | 2 | |
|---|
Bridge Authority | 2 | 6% | 2 | |
|---|
Other Public Body | 1 | 3% | 1 | |
|---|
Lobby group | 6 | 17% | 5 | |
|---|
Representative Organisation | 5 | 14% | 5 | |
|---|
Research Body | 1 | 3% | | |
|---|
Local Authority | 9 | 25% | 7 | 1 |
|---|
Local Councillor | 1 | 3% | | 1 |
|---|
Individual | 6 | 17% | | 1 |
|---|
Regional Transport Partnership | 1 | 3% | 1 | |
|---|
Transport Provider | 1 | 3% | | |
|---|
Total | 36 | 100% | 23 | 3 |
|---|
The majority of quantitative responses to question 11 said that final approval should lie with the Scottish Ministers.
A small number of respondents said that final approval should lie with the Bridge Authorities but that appeals to the Scottish Ministers should be allowed. One respondent suggested that decisions should be made by the Bridge Authorities but should be ratified by the Scottish Ministers, and that Ministerial powers to refuse ratification should be restricted.
Other suggestions about who should have final approval of changes to tolls were:
- The Scottish Executive
- The Bridge Authorities in consultation with the Scottish Executive
- An independent body with less complex procedures than a PLI
- Public referendum
Most respondents believe that the Scottish Ministers should have final approval.
Question 12: Do you consider all tolls should be subject to increases linked to an inflation index?
The number of responses received to question 12 by respondent type is as follows:
Question 12 | No. of Responses | % of comments received | "yes" | "no" |
|---|
Business Sector | 3 | 9% | 1 | 2 |
|---|
Bridge Authority | 2 | 6% | 1 | 1 |
|---|
Other Public Body | 1 | 3% | 1 | |
|---|
Lobby group | 5 | 14% | 1 | 2 |
|---|
Representative Organisation | 5 | 14% | 3 | 1 |
|---|
Research Body | 1 | 3% | | 1 |
|---|
Local Authority | 9 | 26% | 3 | 2 |
|---|
Local Councillor | 1 | 3% | | 1 |
|---|
Individual | 6 | 17% | 2 | 3 |
|---|
Regional Transport Partnership | 1 | 3% | | |
|---|
Transport Provider | 1 | 3% | 1 | |
|---|
Total | 35 | 100% | 13 | 13 |
|---|
Despite quantitative results, most responses were either not in favour of this suggestion or had concerns about the practicalities of inflationary increases.
" Increases should relate to the cost of maintenance and repair programmes, (also in the case of FETA any transportation initiatives) and be subject to regular review (Annual/Biannual) and take account of several factors including traffic growth, inflation index and likely cost of future maintenance. Any increases must be practical in terms of coinage."
- Representative Organisation
Many respondents felt that the level of tolls should be linked to operational needs, which may not necessarily justify tolling increases, and/or policy objectives. The frequency of such changes was also a common cause of concern as were consequential coinage problems. However two respondents recognised that both these problems would be ameliorated by electronic tolling.
Most respondents either do not feel that tolls should be subject to increases linked to an inflation index or have concerns about the practicalities of such changes. Inflation is generally seen as just one of many factors that should be taken into account when periodically reviewing tolling prices.
3.3 Objections to Tolling
A significant number of respondents volunteered objections to the continuation of tolling at one or more of Scotland's three tolled bridges. Some of these respondents commented that questions 1 to 12 are relevant only if tolling is to continue and their responses comprised arguments, some very detailed, in support of ending tolls at one or more of the bridges. These comments have been summarised at Annex 5.5. Most of these respondents, however, commented on some or all of questions 1 to 12 in the event that tolling will continue, but asked that their fundamental objections to tolling at one or more of the three bridges be noted.
As mentioned in section 2.2, questions in the Consultation Paper have been asked on the presumption that tolling will continue at each of Scotland's three tolled bridges. This approach did not mean that a decision had already been taken to retain tolls - it has not. Although beyond the scope of the Phase Two Consultation exercise, the implications of discontinuing tolling at each of the three bridges is being considered as part of the second phase of the Tolled Bridges Review.
All of the original responses to the consultation, containing all of the detailed individual points made in relation to each question are available to, and will be considered by, those involved in preparing the report on Phase Two of the Tolled Bridges Review.
A significant number of respondents voiced objections to the continuation of tolling at one or more of Scotland's Tolled Bridges.
3.4 Other Comments Received
Free alternatives to tolled routes must be signed as the primary route, even where the tolled route is more direct. Several respondents anticipate that the requirement to sign alternative routes to the Erskine Bridge will cause significant problems for longer-distance traffic when the M74 extension is built.
A small number of respondents were concerned about the impact on tolling revenues available for maintenance costs should financial incentives such as exemptions for efficient road users be successful or toll increases prove prohibitive.
A small number of respondents suggested that payment of tolls through the purchase of crossing permits, similar to the operation of season tickets, should be considered as it is an efficient way of collecting tolling revenue.
One respondent expressed concern about the effect of a given vehicle qualifying for more than one discount e.g. for multiple occupancy and for travelling outside the peak period which could result from a more complex tolling strategy.
One respondent questioned the legal differences between exemptions and 100% discounts, particularly with regard to the continuation and variation of tolls.
Mandatory signage of free alternatives to the tolled Erskine Bridge route could present significant problems in completion of the M74 extension. The effect of various tolling options on tolling revenues is of concern to some respondents, particularly with respect to funding maintenance programmes. Season tickets for tolled bridges are considered by some respondents to be an efficient way to collect tolling revenue.
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