Memorandum by the Confederation of Passenger
Transport UK (IT 39)
A NEW DEAL FOR TRANSPORT
The Government's White Paper on the Future
1. The Confederation of Passenger Transport
UK (CPT) welcomes the opportunity to comment on the Government's
White Paper on the Future of Transport. The Paper is an imaginative
and challenging document which aims not only to achieve integration
"within and between different types of transport" but
also integration with the environment, land use planning and other
related policies. Clearly such a document relies on further detailed
"daughter" documents to set out the way ahead.
2. Since this response, to the Select Committee,
is being produced in advance of the publication of the buses paper,
there are naturally some qualifications in the detail and tone
of our response. Nevertheless, if the daughter documents inherit
the features of the parent this will auger well for the future.
3. CPT welcomes the enhanced role envisaged
for buses through a system of Quality Partnerships. Evidence available
to date demonstrates that much can be achieved through a voluntary
system of co-operation between bus operators and local authorities.
Although the Government has set out its intentions to legislate
on aspects of Quality Partnerships it should not underestimate
the outputs which can be achieved when agreements are reached
on a voluntary basis. Indeed there are already strong incentives
for operators to invest in new vehicles.
4. A number of voluntary Quality Partnerships
exist around the country. All have been shown to have the potential
to deliver a marked improvement in the quality of bus services
offered to passengers. This in turn has resulted in an increase
in passenger numbers: the most notable and recent introduction
is in Manchester. It should be noted that Quality Partnerships
do not involve bus operators and local authorities alone; in some
cases they also involve train operators (e.g., through ticketing
and better interchange), the police and other enforcement authorities,
further increasing integration.
CPT notes the Government's intention to bring
forward legislation to put Quality Partnerships on a statutory
basis. However, we believe that the urgent introduction and development
of further partnerships is the key to delivering better bus services.
For this reason the industry is keen to work with local authorities
and other parties now, to bring about as many Quality Partnerships
as possible on a voluntary basis in advance of primary legislation.
Operators are demonstrating their willingness to invest, even
when local authorities cannot immediately find complementary funds.
Experience has shown that Quality Partnerships
differ in the elements involved depending on local circumstances.
For instance, a Quality Partnership covering rural services will
be different in a number of ways to one covering primarily urban
services. CPT agrees with the Government that local solutions
to local problems should be agreed at local level through the
Local Transport Plan.
For that reason, the legislation introduced
to put Quality Partnerships on a statutory footing must incorporate
a level of flexibility which would enable each Quality Partnership
to be tailored to meet local needs. The Office of Fair Trading
(OFT) has to show itself to be understanding and willing to allow
potentially anti-competitive arrangements when they are clearly
in the consumers' interest.
5. The paper proposes to give powers (subject
to Ministerial consent in each case) to local authorities to enter
into Quality Contracts where it is in the public interest to do
so. We believe that in the current co-operative climate the Minister
will not have cause to give this consent. Such a power is franchising
by another name and the industry is strongly opposed to such a
proposal. In our submission to Government, prior to the publication
of the White Paper, we demonstrated that franchising is a more
expensive system of providing bus services than the present method.
We further believe that franchising removes the incentive for
operators to improve the quality and quantity of services which
will ultimately result in a poorer service to the travelling public.
Independent research was carried out which confirmed our view
on this matter. Scarce resources should not be used in setting
up Quality Contracts when the case has not been made that they
improve customer satisfaction with public transport.
6. We welcome the Government's intention to
introduce a national minimum standard for concessionary fare schemes
for the elderly. This move recognises the expansion of the upper
age groups in our society and the importance of equity of treatment
for all. It is important that the funds required to improve the
schemes that fall below the benchmark are not robbed from other
public transport budgets. The industry believes that falling reimbursement
levels for some existing schemes are likely to lead to a challenge
if they continue.
7. The industry recognises the importance of
good public transport information for passengers. Whilst much
has been achieved in some parts of the country, the perception
by the public is poor. At present there are around 170 bus information
"hot lines" around the country:
100 are operated by bus operators
64 are operated by local authorities and PTEs
a small number are jointly operated.
This pattern has emerged as a direct result
of the local nature of bus services and generally meets the requirements
of existing passengers.
Nevertheless, the industry recognises that potential
new users are seldom knowledgeable on bus information and strangers
visiting a town for the first time may not immediately know where
to seek information. For these reasons the industry, in co-operation
with local authorities and ATOC (Association of Train Operating
Companies) are working on the introduction of a national enquiry
service. The aim is to ensure existing systems are accessible
by a national telephone number and the internet, working in harmony
with the National Rail Enquiry Service. It is planned to meet
Government targets of the system to be up and running by the end
of the year 2000.
8. The rebate is a crucial part of keeping fares
affordable to the passenger. The Government has promised consultation
on targeting the rebate on rural services and more environmentally
friendly vehicles. We foresee several possible consequences, not
all of which are desirable, but we look forward to this consultation.
9. Consultation is promised on the proposal
to being domestic drivers' hours regulations into line with European
long distance drivers' hours. This proposal will require very
careful consideration, since the cost of this would be significant.
CPT recognises that the juxtaposition of two sets of rules can
be complex, but there is no evidence that current UK domestic
rules are unsafe. In any case, most drivers use one set or the
other, and this problem is more apparent than real. Alignment
would lead to a prohibitive increase in the cost of providing
bus services, both commercial and tendered. Inevitably such costs
will be passed on to the passengers which will in turn deter them
from using public transport. CPT is concerned that there are insufficient
potential new bus drivers in the labour market to fill the gap
caused by rising demand and artificially reduced working hours.
It has long been recognised throughout Europe
that domestic drivers' hours should be a matter for local determination
and agreement. Clear distinction is made between the bus industry
and heavy goods vehicle (HGV) operations. The bus industry believes
that we should not be taken down this road simply because a problem
is perceived to exist in the HGV industry. In any event changes
should not be made in isolation from the proposed EU initiative
on Working Time in transport.
10. For some time the European Commission has
sought to obtain agreement between the social partners on the
regulation of working time in transport. Discussion have so far
failed to produce any firm agreements in the Joint Committee which
deals with the matter. It now appears that a proposed directive
on the matter will be produced by the Commission. As stated in
the previous paragraph, it would be wrong to act on one aspect,
working time, without taking into account proposed changes for
11. Guidance on good practice for through ticketing
and travel cards will be produced. Already there are some excellent
schemes which point the way to a future development, many at the
initiative of but operators. For example, a bus passenger in a
remote town in Oxfordshire can purchase a ticket on the bus which
can incorporate a train journey and London Travelcard facility.
An informal partnership of local authorities, train operators,
bus operators, etc., have paid for the development of the technology
to make this possible, CPT is taking this initiative forward at
national level to secure greater integration of ticketing.
12. CPT believes that co-operation between bus
and rail operators in the interest of passengers must be possible
without falling foul of competition law. Already the OFT is aware
of the thrust of Government policy in this area. During discussions
on the Manchester Quality Partnership, there was helpful advice
on those aspects of the partnership which were potentially anti-competitive
but nevertheless in the interest of the passengers.
13. Policies on access to buses by the disabled
are progressing. Bus operators already observe the spirit of the
legislation in their policies, procedures and new vehicle orders.
Already the vast majority of new buses are of low floor design.
For example, all bus services provided by the major operator in
the centre of Salisbury are all wheelchair accessible.
14. The ability of local authorities to charge
for road use and workplace parking and to use the funds to improve
public transport will be key to the success of achieving an integrated
public transport system. However, it must be recognised that a
reliable public transport service must be in place before the
introduction of charges. This means early action on bus priorities
and the development of good Quality Partnerships. In keeping with
the Government's intention of devolving power to local decision
makers, early action at local level by local providers and planners
15. One of the responsibilities of the new Greater
London Authority (GLA) will be a direct responsibility for transport
in the capital. CPT welcomes this important move and advocates
that the GLA should also assume responsibility for all the roads
in London. This will result in more coherent planning of road
public transport, especially where bus priorities are involved.
It is important that the transfer of the Traffic Commissioner's
licensing functions to Transport For London should recognise the
capital's national and regional function and not be accompanied
by unreasonably narrow criteria for services.
16. We were disappointed to read that "funding
for new major light rail schemes will not be a priority".
Whilst we recognise the reasoning behind this view, we believe
that there are circumstances where light rail provides the best
solution to moving large numbers of people in a confined area.
Although we welcome the encouragement to develop public-private
partnerships to take forward such schemes, we would hope that
the present view on public finance could be modified in special
17. The industry welcomes proposals to strengthen
the role of the Traffic Commissioners. For a number of years we
have supported moves in this direction, particularly in the use
of high entry standards to improve the quality of operations.
18. All the research from numerous sources,
shows effective traffic management is essential to deliver the
reliable service that bus passengers require. No amount of investment
in new vehicles will compensate for unreliability. Systems of
priority on the roads, at pinch points and at traffic lights,
are the minimum contribution that local authorities must make.
19. The need for fundamental change to the local
transport planning system will challenge the most committed of
planners. It is clear to us that the new five year plans (drawn
up in consultation with users and operators) will be pivotal to
the achievement of the Government's aspirations. We note that
plans are to be developed by Regional Planning Conferences (RPCs)
who will work in close liaison with the Government Office for
a region in partnership with Regional Development Agencies (RDA).
RDAs will in turn have powers to ensure that regional transport
plans help achieve sustainable economic development. It is not
entirely clear how the above groups will relate to each other.
We note with interest the proposals for Local
Transport Partnership Groups, Rural Transport Partnership Groups
and the Commission for Integrated Transport. Their plans must
cover all forms of transport, bus Quality Partnerships, air quality,
traffic congestion, road safety, and green commuter plans. We
believe that substantial further thought needs to be given to
the inter-relationship between all these bodies.
It may well be that the best approach to this
necessary but complex structure starts as a "bottom up"
system. Otherwise it will be confusing for the partners. There
is a clear opportunity to expand PPG 11 and PPG 13 to reflect
these new policies.
20. CPT represents the providers of bus, coach
and light rail transport. We will be pleased to expand on any
of the items raised in this submission.