I am writing to highlight the need for transparency and fairness in the ongoing CalMac ferry service consultation, specifically concerning the route changes that impact Campbeltown. As a resident of Kintyre, I’ve closely followed this matter, as have many others in our community. We have concerns about the process and question its fairness.
Firstly, I understand that CalMac faces challenges, such as an aging fleet and technical issues. However, decisions must be made carefully, with consideration for those affected. The consultation process must not only appear fair but genuinely be so.
The consultation can be found here. It was initially posted on X, formerly Twitter, on 28 August 2023.
The story from the beginning
My journey began with a letter to Duncan Mackison, the new CEO of David MacBrayne (which is the parent company of CalMac). Before writing to the First Minister who referred me to CalMac, I wrote to Mr Mackison outlining my concerns and suggested corrective actions on 30 August, 2023. I am yet to receive a response, which doesn’t really do much for confidence.
One of the issues that struck me with the public consultation was the initial absence of a privacy policy. This isn’t just about data privacy; it’s about compliance with UK GDPR regulations. This raises some critical questions: Why should anyone participate in a consultation that doesn’t respect our data rights? And the follow up question: Would this or could this have a detrimental effect on the numbers of people taking part, and therefore would this skew or at least call into question the results? And one further question: What else is wrong?
I see that since writing to them on 30 August they have added a privacy policy which is now visible, or at least was from 12 September when I last looked. That’s progress, however, this should have been in place from the start to maintain trust.
Another concern I raised was that the consultation process allows multiple responses from a single participant and lacks geo-locking. I was able to take part and create several answers, not only from the UK but from Russia and the United States by simply using a VPN. This calls into question the integrity of the data being given to the consultation. How do we know it’s not junk data? Where is the confidence that this consultation is transparent and accurate? How do we know only those meant to take part can take part? What data cleansing process will be used (if any) and where is the transparency around that?
Transport for Scotland had a much more secure survey system when they performed the recent ‘Rest and Be Thankful’ public consultation. Why was this not used in this case? This then raises another question; as this is transport related, it certainly seems to fall under Transport for Scotland remit, so why leave it up to CalMac?
Just for show?
Many people I’ve spoken to believe that a decision has already been made. They also question why Skye travellers are seemingly favoured with a ferry when there’s a perfectly adequate road route, which, ironically, is the same argument we hear all the time to deny Campbeltown a ferry! Where are the hard facts and figures from Transport Scotland that back up this proposed priority matrix? Should this data not be an integral part of the consultation so people can formulate an informed opinion for themselves and properly contribute to the consultation, rather than narrow the discussion to a preformulated decision?
This quote from the survey places the Campbeltown route first: “As Ardrossan-Campbeltown and Mallaig-Armadale have land links, these should be disrupted first if a vessel cascade is needed and where appropriate.”
The actual question later in the consultation is: “Do you support the proposal to disrupt Ardrossan-Campbeltown and Mallaig-Armadale first if a vessel cascade is needed (and vessel deployment can help)?”
Followed by: “Do you support the proposal to aim to minimise the impact on any single route to around 1 week, given this will increase the number of communities that will be affected by a single disruption?”
Those questions seem loaded. Looking back at the statement I made about the insecure nature of the consultation, if the results show many people in favour of cancelling the Campbeltown route, and not being in favour of alternating services, would that be based on actual tourism needs? Business needs? Social needs? Or simply boil down to a numbers game because a few million around the world and an army of bots outweighed the minority of 5000 in Kintyre?
And as a reminder to us all, the current situation is that the Campbeltown route has been cancelled all season and the Skye ferry has been running. Would the route prioritisation matrix simply mean, in real terms, that the situation we faced this year with no ferry will continue and that Skye will continue to be serviced? Where is the delineation? What would be the deciding factor? Do we really think Campbeltown will have a ferry service every other week? Where is the clarity on this ambiguous matter?
A look at the facts
The Isle of Skye does indeed have a bridge and if people took the A87 route from the tourist hotspot of Fort William, they’d be inconvenienced by 2hrs 20 minutes according to Google Maps. The condition of the A87 is very good as they’ve had a lot of recent resurfacing works, including the bridge itself. There are even cycle paths and pedestrian walkways.
If the Campbeltown ferry was off, they’d have the A83 to take, with the appalling road conditions, despite patchy remediations. The journey from Glasgow, our nearest conurbation, is also longer at 3hrs 30minutes. This is why people just don’t bother if they don’t have to. It’s too long and the road is less pleasant to drive. I have that on record from guests who have cancelled bookings when the ferry was cancelled.
My argument would be that given the better links to Skye, that service should be cancelled first(I’m very sorry Skye!), but notably missing from the public consultation is any context from Transport Scotland to help inform decision making. It’s all opinion based. What we need are independent socio-economic impact assessments that have proper and fair representation from all regions.
Fact vs opinion
I have seen a recent (2022) impact assessment that did not feature much in the way of representation from Kintyre, yet proudly displayed an entire page dedicated to Skye. Many of the other whisky regions had multiple representatives, some had teams of ten people from both tourism services and distilleries, whereas Kintyre had two representatives and was barely mentioned. You can see the report here.
I have also not seen any consideration of the figures that demonstrate on occasion when there is a good service to Campbeltown, that the ferry usage increases by 33% year on year due to consumer confidence. Those figures, mentioned to me by a local councillor, could very well indicate that our local economy is being throttled. Why are we working in the dark with no hard data, shouldn’t all this information form part of the public consultation too?
I did write and received this response from the Ferries Directorate, Transport for Scotland, “Due to the range of interested parties CalMac Ferries Ltd (CFL) decided to launch a public consultation, on the proposed changes to its Route Prioritisation Framework for its major vessel network, rather than through engagement via specific stakeholder groups.”
This means that the hard data being used to cement the proposal is being drawn from the public consultation that has questions around its data integrity and methods of data gathering.
What now?
I call for the current public consultation to be withdrawn and redesigned to be secure, to ensure data integrity, to have clear decision points, to allow people to make informed decisions and to allow a level playing field for all regions. This will require proper socio-economic impact reports and while I understand the need for planning, there is still time to put all of this in place in time for the new season next year.
The decision to alter the ferry route and the route prioritisation matrix isn’t just about logistics; it’s about the livelihood and well-being of our community. Each cancelled booking is a person spending less in our region, each cancelled booking is a person inconvenienced, a decision made to go elsewhere and a loss to Kintyre.
It’s time for CalMac, and more importantly Transport Scotland, to step forward and provide the information, the service, the transparency, and the accountability we deserve. We won’t be silenced, and we won’t stand by while our voices go unheard. Our community’s future and well-being depend on it.
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