Dear OSR,

Transport Scotland and Sustrans Walking & Cycling Index

For a few years constituents have raised concerns with me about Sustrans Walking and Cycling Index (formerly known as Bike Life). In Scotland, the city reports and aggregated report for the whole of Scotland seem to be partly or fully funded by Transport Scotland.

A constituent has written to me saying they have raised some of their own concerns about the Index directly with the OSR. The constituent has provided positive feedback about the promptness and helpfulness of OSR’s response and is reassured that the OSR is informally looking into the Walking and Cycling Index.

However, the issues are so significant that I feel it necessary to add further concerns and follow up directly with OSR.

There are multiple concerns and as examples, three of the themes that keep coming up are:

1. 1. Data presentation: For example, the use of text and graphic design to present comparable stats for levels of walking and cycling in a manner that creates the impression that levels of cycling are proportionately greater than they are, which can misinform funding priorities.
   2. Omission of balancing data: For example, modelling is used to quantify the health benefits of cycling with preventing serious long-term health conditions, and early deaths, and then quantifying the saving to the NHS. However, this is not balanced by official data of actual injuries and fatalities from cycling and then modelling the related cost to the NHS. To pick one example, government figures show 255 people were killed or seriously injured while cycling due to “poor or defective road surface” between 2017 and 2022,  and this has happened recently in Lothians constituency. It also doesn’t consider the health implications of family and professional carers finding it harder to visit vulnerable people due to new traffic restrictions. By not including this balancing data, it misinforms policy makers and elected representatives on how best to allocate budgets to maximise health benefits and minimise negative impacts. In Edinburgh for example, spend on new cycle lanes has dwarfed spend on surface maintenance, and in the foreword to the Edinburgh Index, the Transport and Environment Convener uses the report as a platform to justify more of the same approach.
   3. Selective use of questions and case studies: This has the impact of creating misleading narrative about impacts for disabled people. Active travel is important for some people living with disabilities and more needs to be done with improving accessibility of pavements and crossings etc. However in Scotland, Sustrans is in an unusually strong position with the ability to control funding to councils for active travel schemes. Sustrans has been central to allocating funds for schemes that even if they sometimes make life easier in some locations for some disabled people, they often do this in a way that reduces car access and parking to a point that has serious negative impacts for others, including carers. This research does not include questions that allow disabled people to voice their experiences on these negative impacts, and it appears that as with all other case studies, case studies featuring disabled people generally reinforce Sustrans preferred narrative around active travel. A constituent has shared examples of active travel campaign groups being invited to submit case studies and participate in photos shoots for the report and Sustrans staff or prominent activists being featured.

The data from these reports is used in papers and consultations in a way that embeds the statistics within policy making and decisions to allocate nine-figure budgets in Scotland. Various organisations in the disability sector have raised concerns about projects funded by these budgets, including at COP 26 in Scotland where the issues of “ecoableism” were covered in relation to some active travel schemes having negative impacts on disabled people.

Sustrans is a registered lobbyist with the Scottish Parliament, and records show that over 100 lobbying events have been recorded over the last 6 years, therefore it seems inappropriate that Transport Scotland would be funding such high profile research through a lobby group.

I have also just learned from a constituent that Sustrans is included in legislation as a provider of Official Statistics to the Scottish Government which magnifies concern.

The Code of Practice for Statistics sets the standards that producers of Official Statistics should give confidence that published government statistics have public value, are high quality, and are produced by people and organisations that are trustworthy.

Therefore, I would be grateful to have further information on:

1. What action the OSR is taking with Transport Scotland and Sustrans around the Walking and Cycling Index 2023 which was launched a couple of months ago and will be regularly used as a reference by policy makers for the next two years?
2. What action will be taken for the next wave of research in 2025 for publication in 2026?
3. What the OSR’s position is on registered active lobby groups also being providers of Official Statistics and whether this aligns with the Code of Practice aim that organisations producing Official Statistics are viewed as trustworthy?
4. Is this situation of a lobby group also being a provider of Official Statistics unique to Scotland?

I would welcome your response.

Kind regards,

Jeremy R Balfour MSP