1    Friends of the Far North Line (FoFNL) was formed in 1994 to support the railway line from Inverness to Wick and Thurso, and now has almost 200 members. FoFNL supports the Scottish Government's policy of encouraging travellers to use public transport rather than private cars, so as to reduce traffic on overcrowded roads, to help conserve fuel resources, and to reduce the amount of pollution. We represent the views and aspirations of users (both passengers and freight consigners) of the Far North Line (FNL) and other lines out of Inverness, to service providers, government (local and national), Transport Scotland and other stakeholders.

2    We are grateful for the opportunity to comment on this Document. With the preliminary planning for CP6 well under way, with the HLOS and SOFA documents expected in the next several months it is appropriate to focus on more local aspects of transport provision. We will confine ourselves to railway matters except where there are general points to be made.

3    In 3.4.5 statistics for passenger growth are given. We endorse the comment that some small stations show widely different totals from year to year - some up, some down - and recommend that no weight is placed on changes where the annual footfall is below a certain number. This is because very low figures are unreliable and prone to under-reporting. It is notable that passenger increases are much lower on the more distant parts of the FNL - ie. those beyond reasonable commuting distance to Inverness. We believe that this is solely due to the egregious increase in journey times in the last 15 years. We will return to this point.

4    5.8 addresses the issues affecting tourism, specifically (in 5.8.1) saying that "[visitors expect that] the quality of public transport will be at least as good as is available elsewhere". This is not altogether clear. Does it mean as good as it is on inter-city trains? Or that trains should be as good as private cars? The demands of visitors, as distinct from local users, are likely to include better provision for the safe stowage of luggage, preferably within sight; better provision for bikes; better window alignment so that the view may be enjoyed from all seats. ScotRail passes some of these tests, but fails, and fails badly, on others. The refurbishment of Inverness-based Class 158 DMUs around 10 years ago brought seats into alignment with windows, and we are glad that the current refurbishment programme appears to be extending this to all Class 158s. However the franchisee has been caught between two irreconcilable demands: that a second wheelchair space be provided, and that the Inverness refurbishment of providing 4 bike spaces be maintained. The disability requirements are enshrined in law, so necessarily trump the requirements of cyclists, to the severe disadvantage of the latter. The solution surely is to satisfy both demands by removing a number of seats - no more than 4 to 6. The occasions when a 158 is full and standing cannot be very many; are the occasions when a third or fourth bike is turned away (a family of sought-after tourists) counted? Indeed, are the occasions when a second wheel-chair is loaded counted?

5    FoFNL welcomes the franchise commitment to provide a "tourist train" and we look forward to the full implementation with on-board staff to provide a full tourist experience.

6    5.9.5 is disingenuous in stating that average journey times between Inverness and Wick had increased by 6 minutes between 2007-08 and 2015-16. While this is true what is not stated is that journey times on that route had greatly increased between 2000 and 2007-08. The average increase in end-to-end journey times on the FNL since 2000 is a shocking 32 minutes. On any other railway route in Great Britain this would be wholly unacceptable, and would merit vigorous questioning of the industry by Ministers. It is tolerated here because Caithness and Sutherland passengers are a captive market, relatively few in number. Scottish Ministers, through Transport Scotland, not unreasonably direct funding where the greatest numbers will benefit. However those parts of the transport network with fewer users must not always be denied funding. Minor roads carry far fewer vehicles than Motorways, but still require occasional improvement beyond routine maintenance. So it is with the railway.

7    5.9.7 suggests that frequencies have a negative impact. We refute this in the case of the FNL. End-to-end frequencies have increased in recent years, thanks in part to pressure exerted by FoFNL, and the weekday (including Saturday) timetable is now as good as the infrastructure can support. We believe that a second Sunday service, leaving Wick in the morning and returning shortly after arrival at Inverness, would be well-used. The Invernet services have also increased in recent years and are now catering for a good flow of commuters from Easter Ross and the Inner Moray Firth area.

8    5.10.3 mentions the lack of pre-06:00 access to the HML as an impediment to bringing freight into Inverness. We ask what would be needed to eliminate this lack: main railway lines seem to be open during the night elsewhere. Is it a matter of staffing, or is the signalling infrastructure itself causing the restriction?

9    5.10.4 glosses over the major problem which will be posed in the next 20 years by the need to extract timber from remote parts of the Highlands. The issue is well known to HITRANS, as are the solutions being investigated: we think this ought to be set out in the Document. Rail has an important part to play as many of the roads, being laid on peat, cannot carry the likely number of lorries without sustaining severe damage. One of these, the A9 in Caithness, is a Trunk Road carrying all the traffic south from the county. It will be unable to cope with the timber lorries at the volume and frequency envisaged. There will need to be significant investment, running to tens of millions of pounds, either on the railway or on the roads. HITRANS must give guidance as to where, and how, the money should be allocated. Roads or the railway?

10    7 (on p.32) has a pretty map of "Lifeline Transport" which shows railway lines. What a pity that the text accompanying it fails to mention rail alongside "road, ferry or air".

11    We endorse the remarks made in 7.5. It would be good if some force were added to the concerns of "some stakeholders" in 7.5.3. The heading is, after all, "Lifeline" and the point about lifelines is that they are relied upon, sometimes in emergencies. It is not good enough that the lifeline road - the A9 - and the lifeline railways - the FNL and the HML - can be closed other than in the most unforeseen circumstances. Failure to maintain embankments, to prevent flooding or to monitor trees, is deplorable anywhere, but intolerable on a lifeline route. This lifeline-ness is the only occasion when routes with lower passenger numbers can truly trump the needs of routes in more populous areas. If a line between Edinburgh and Glasgow is disrupted - as is currently happening with the closure of Glasgow Queen Street High Level - there are three other routes. Lifelines are not like that, and investment should be made to ensure that interruptions and long delays are a thing of the past. This applies with equal force to road and rail.

12    8.3, in commenting on the age of transport assets, ignores the age of rolling stock. The 40-year-old Class 43 which will be refurbished to provide the Inter-City ScotRail fleet from 2019 will push up the average age of Scottish rolling stock by a noticeable amount. FoFNL looks forward to their introduction and expects them to be popular with passengers and to deliver an improved passenger experience, not least in comfort and on-board facilities. The ex-BR Class 15X fleet which will continue to provide services on the FNL (and other routes within the HITRANS area) are not suitable for 4-hour journeys, for which they were never designed. Even if a magic wand were cast over any likely refurbishments they would not provide a pleasing passenger experience, especially when compared with a car. FoFNL believes that these two situations - a politically embarrassing increase in the average age of Scotland's trains, and the Class 158s - can be solved at a stroke. The new Northern franchise in England will be ordering new-build DMUs - a thing which the industry believed would never happen again - and it would make good commercial sense for all franchisees in GB to consider whether bolting some more DMUs onto this order might not be a wise investment. The door to more DMUs seems to be open at present, having been firmly shut as recently as last year; it will not remain open for ever. Naturally different franchises would have different operational requirements for a new-build DMU, but the basic engineering would not alter. Interior fitments can be tailor-made to cater for specific needs. HITRANS should lend its weight to this kind of thinking, not least by having a new section 8.3.4 about rolling stock.

13    As this is a "refresh" exercise it would be instructive to compare what was set out in earlier documents of this kind with the outcomes which have been achieved. It is 17 years since the then Scottish Executive "supported the development of [RTPs]". What has happened in these 17 years, what were the aspirations, what has been achieved, what still needs to be done?