Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum from Sustainable Transport for the East of England Region, (STEER) (Bus 27)



  1.  STEER is a coalition of campaigning groups in the English Eastern Region representing environmental and sustainable transport advocates. It has particular concerns with the way in which the lightly regulated bus industry outside of London has developed in recent years and welcomes the opportunity in response to the Press Notice No 50/2001-02 published on 8th March 2002 to submit a memorandum for consideration by the Transport Sub Committee.


  2.  The history of bus operation in Britain is largely one of long periods of inaction punctuated by quite dramatic changes to the regulatory or ownership structure of the industry. Thus since the Road Traffic Act 1930 and setting up the Traffic Commissioners as a licensing body replacing the powers of local authorities, we have had the setting up of the London Passenger Transport Board in 1933, starting the separation of the capital's bus network from that of the rest of the country, the nationalisation of about half of the territorial bus companies largely as a result of the Railways Act 1947, the sell out to the state of the remainder of the major companies as a result of the Transport Act 1968 (forming the National Bus Company) as well as the absorption of most of the large conurbation municipal operators into the new passenger transport authorities. Matters then remained quiet until some overdue deregulatory measures trimming the scope of the 1930 legislation were enacted in 1980/1 but which retained the powers of the Traffic Commissioners over local bus services. The effects of this had hardly time to settle when the "big bang" of the deregulatory and privatising measures of the Transport Act 1985 took place, selling off the National Bus Company and pte bus operations, turning the remaining municipal operators into companies with the aim of their privatisation.

  3.  The effect of the 1985 Act was to introduce a period of instability in bus services with many instances of wasteful "head to head" competition in urban areas, frequent changes in services and many small independent operators deciding to sell out where their businesses had a market value. New bus orders fell significantly and the small van chassis based "midibus" of typically 16-24 seats was seen as a panacea in many areas. A decade after the 1985 Act sees ownership of the bus industry dominated by about six large groups, it being purely a matter of history where towns and cities now see a significant degree of monopoly operation (eg Bristol, Carlisle, Exeter, Norwich, Swansea) or where competition occurred and has now stabilised (eg Hull, Leicester, Oxford, Plymouth). In other places, successful ousting of the weaker operator has led to near monopolies of services by the surviving operator (eg Brighton, Lancaster, Lincoln, Reading). The changes made by the Transport Act 2000 are in reality a "light touch" and have not yet had a fundamental effect on the industry.

  4.  The major changes wrought by the 1985 Act occurred at the same time as the use of buses was falling nationally by as much as three to five per cent annually. This loss of custom has now levelled out with growth being encountered in some areas. This is in contrast to a steady upward climb for some years of the usage of buses in heavily regulated London.


  5.  Looking at bus operation across the country, there is a varied picture. On the positive side there are a significant number of operators providing a high standard of service with well trained staff driving new low floor accessible buses, working with local authorities to provide decent waiting conditions, good quality information and bus priorities. Although many operations of the large groups fall into this category (eg the Brighton and Hove network of Go Ahead, the Cambridge Citi operation of Stagecoach), it is notable that many such "patches of excellence" occur where the privatised company has remained locally independent (eg Trent and Barton Buses of Nottingham, Truronian in Cornwall, East Yorkshire Motor Services of Hull).

  6.  The regional Traffic Commissioners deal with the registration of services, licensing of vehicles and operators, but are not equipped to deal with the day to day issues of operation, particularly passenger complaints. The bulk of their work relates to the quality control of road haulage operators and vehicles.

  7.  There are factors within the control of bus operators which regrettably can be seen in many instances around the country and which act as a deterrent to bus travel. Such factors include:

    —  Poor information provision (both at bus stops and enquiry facilities)

    —  Inadequate service control management needed when disruption occurs.

    —  Poor marketing of services (especially prepaid and multi tickets)

    —  High fares and lack of transfer or through fares to other services.

    —  Lack of proper training for driving staff.

    —  Frequent and poorly advertised changes to services.

    —  Poorly cleaned and scruffily presented buses.

  8.  There are also factors which lie largely outside of operators' control which affect all bus operators to varying degrees. These include:

    —  Delays to services caused by traffic congestion.

    —  Delays caused by parked vehicles (especially on suburban roads).

    —  Lack of proper waiting facilities (eg well lit and maintained waiting shelters, also hardstanding and footway access to rural shops).

    —  New housing developments not taking proper account of bus users' needs.

    —  Traffic calming measures not taking the needs of buses into account (eg use of road humps instead of speed "cushions").

    —  Low ambient quality bus stations in many towns (often ill maintained or poorly located underneath car parks or other buildings).

    —  Driver recruitment problems—because of the demanding nature of the job, poor comparative pay levels/expensive living costs (esp. in SE England).

    —  Lack of co-ordination between operators (caused largely, but not solely, by the Competition Act 1998).

    —  Vandalism and disruptive behaviour both on and off the bus.

    —  Poor social perception of bus services.

    —  Lack of a national voice for the provincial bus passenger—other than the excellent voluntary National Federation of Bus Users. (Why do London bus passengers alone need statutory consumer representation?)

  As can be seen from the foregoing factors, the bus industry is beset by a range of issues which clearly need to be addressed on a national basis if this mode is to play its full part in reducing reliance on the car and meeting current social needs.


  9.  Fuel tax rebate is the general subsidy to the operation of local bus services. Its effect is not controllable from the policy viewpoint but it can probably be argued that it has enabled a greater mileage of marginal services to be provided than otherwise would be the case.

  10.  General subsidies by local authorities and passenger transport authorities for operators were one of the targets of the 1985 Act reforms. In its place have come operating contracts which are tendered for on a competitive basis. In the early days of the deregulated regime this led to operators submitting unrealistically low tenders (and leading to giving of notice on the tender or in a few cases the financial failure of the operator). In areas where operators are few on the ground, local authorities have more recently experienced a rapid rise in the cost of securing tendered services.

  11.  The Rural Fund Bus Grant initiative by the Treasury has had beneficial effects in financing bus services in sparser rural areas or strengthening frequencies on existing rural routes. However a downside has been the effect of operators giving notice on marginal commercial rural routes so that they can tender for them on a subsidised basis. The funding for this latter purpose has then to be met from the local authorities' existing public transport support budgets.

  12.  Bus Challenge initiatives have generally had a positive impact by inducing operators and local authorities to consider innovative ideas for new services (eg variable route rural services with a limited degree of demand responsiveness). There is a need for experimentation and innovation with the supporting publicity and information provision. In urban areas it has meant the provision of services meeting particular needs such as late services on Friday and Saturday nights, geared to the needs of young people.


  13.  Bus Quality Partnerships (BQP's) are a form of "compact" between operators and local authorities. Whilst there has been some good work in achieving a high standard of provision (eg the "Superoute 66" services between Ipswich Rail Station and Martlesham Heath which now operates on a 24 hour basis) the impact is disappointingly scattered in national terms. There is no ability in a BQP for an operator providing a service on an all week basis to be protected from competition during the profitable main day period. Similarly in such a situation (or for other reasons) there is nothing to protect the local authority which has invested in improved infrastructure, then having to allocate finance for the contract subsidy of a route in the evenings or on Sundays because the operator has decided that service provision at such times is no longer commercial. The local authority cannot determine frequencies in a BQP which is a fundamental element of the provision of a bus service.

  14.   Bus Quality Contracts (BQCs) require the prior authorisation of the DTLR and enable the local authority to plan the total provision of services in an area or corridor including the setting of fares. There is an onus on the local authority to demonstrate why a BQC is warranted. In reality this is a means of regulation within a defined geographical area.

  15.  Whilst it would seem that BQP's lean towards the operator in maintaining the low level of regulation whilst BQC's give a high degree of regulatory control to the local authority, it must be questioned whether the existence of these two forms of relationship are a means of avoiding the issue of the right degree of regulation of the industry on a national basis. It is important in any regulated system that whilst there should be certainty in provision of a service from the customer's standpoint, the operator should retain sufficient freedom to have the incentive to develop services within the parameters of a service specification. This matter is further discussed below in the section on the regulation of the industry (paragraphs 19-23).


  16.  Bus priorities take a number of forms; reserved or shared priority lanes on key sections of roads, traffic signal detection, bus only accesses through commercial centres or linked residential areas, bus only permitted turning movements at busy junctions and "No Stopping Except Buses" orders at bus stops.

  17.  All these measures are of assistance to the operation of buses on increasingly congested roads by enabling the provision of a more reliable and attractive service. There is considerable variation in the enthusiasm for and level of provision of priorities around the country, but the much greater depth that policy development, implementation and monitoring is given by the annually reviewed Local Transport Plan process has encouraged some of the more "backward" local authorities to consider bus priorities more positively as part of their approach to public transport development.

  18.  Enforcement of priorities is obviously important in order that their full benefit can be felt by bus users. However besides the obvious measures of enforcement using police, cameras, traffic wardens, etc, there is a need for a more informative approach to the public. As an instance, it should not be difficult to publicise the numbers of people travelling along a road at peak times in a priority bus lane and in the general traffic flow so that accusations of "underused bus lanes" are countered. Similarly, the thick yellow line denoting a "No Stopping Except Buses" order is not easily recognised by many other vehicle drivers; either specific publicity, or the use of another colour for the road marking, for example red, may be effective in this case.


  19.  A brief history of the regulation of the industry was set out in paragraph 2. We are now in the aftermath of the deregulating effect of legislation which has now been in force for some 16 years. London's bus services are governed by a bureaucratic system of regulation in which the operator has very limited ability for manoeuvre. Also the system of re-tendering with operators likely to gain or lose a considerable amount of work can lead to other problems such as an unstable workforce. However, it can be said that the London system works in terms of passenger usage and probably in terms of public satisfaction. Hertfordshire County Council published its Bus Strategy document earlier this year and it records the fact that the expectations of the large part of the population that lives close to the Greater London boundary of the county are significantly higher than elsewhere in the county for reason of what is perceived as a better bus service enjoyed by London residents living nearby.

  20.  Integration of bus and rail services is also threatened by the lack of regulation of bus services. Because of the risk in providing outdated and hence misleading information, First Great Eastern Railway in its timetable booklet no longer shows bus links to towns not served by rail—in an area where the principal bus operators belong to the same owning group as the train operator! There has been a difficulty in maintaining a Colchester—Stansted Airport coach link which formed part of the regional rail network at one stage. The ability to revise or withdraw bus services at 56 days' notice makes forward planning difficult.

  21.  The way forward may lie in some form of regional bus regulation transferring the present service registration and monitoring functions of the Traffic Commissioners to the new body. This would leave the Commissioners with the administration of the qualitative elements of operators and vehicles on a similar basis to its control of road haulage. The regional regulator would have a relationship to the county/unitary/PTA public transport support function. Such a body would be well placed to monitor the efforts of local authorities in matters of shelter, information provision and bus priorities as well as acting as final resort of public complaints of poor service. Rail—bus service integration should become more attainable with such a body to oversee matters.

  22.  Any re-regulation on a general basis is likely to require primary legislation. There is also the question of transition to a new regime which could be treated by freezing service patterns as occurred with the introduction of the deregulation following the 1985 Act. For political reasons a gradual approach may be preferable. DTLR already carries out a quarterly exercise in gauging satisfaction levels with bus services. It would be a useful exercise to extend this survey to include non bus users and to ascertain which aspects of bus operation cause most concern to users as well as what improvements would be necessary to induce non users to consider catching the bus. The introduction of some trial areas of re-regulated services in several districts where bus usage has declined significantly could be a useful step in gauging the impact of a more regulated regime as long as the trials were allowed to run a sufficient length of time—at least two and possibly three years—in order to generate any additional custom.

  23.  If these actions point towards a more general re-regulation of the industry the following aspects should be considered:

    —  interests of existing operators in the short term (eg a transition regime possibly on a route by route basis as the network is reviewed by the regulator).

    —  a requirement for bus operators to liaise and co-operate with each other (and with rail, ferry operators etc,) with removal of any hindrance from competition regulations.

    —  need to standardise dates of service revisions to, say, three times annually, including with the twice annual national rail timetable change.

    —  total agreed service provision in a corridor to be provided by an operator (or jointly by operators) on a cross-subsidising commercial basis or the whole route put out to tender.

    —  fares would be subject to local authority decision, whereby either an agreed scale (subsidised if necessary) applied or the operator left to commercial freedom as long as it participated in area travel card and through booking schemes.

    —  service parameters to be framed in such a way that operators have an ability to optimise the economic deployment of their resources as well as having the freedom to operate a better service than that specified (ie similar to the Passenger Service Requirement imposed on train operating companies).

    —  ability for new entrants to participate in service provision.

    —  where not seen to be predatory on the existing network, new speculative commercial services should be permitted by the regulator on the same basis as existing services.

    —  requirements on information provision by local authorities and operators.

    —  requirement on English district and all unitary authorities to make proper provision for bus shelter provision, cleaning and maintenance (using private contractors where advantageous), as well as access to bus stops by provision of hardstanding and footways over the whole of their area.

    —  there will probably need to be an ability for operators to appeal against decisions of the regulator,— (another function for the Transport Tribunal?).


  24.  As bus services can potentially cater for a higher proportion of the total population than the car, based on the ability to drive and afford car ownership etc, it must follow that the bus can be an effective instrument in reducing social exclusion. However, this also depends on factors such as geographical penetration of the network, fare levels and response to demand for services at particular times of day (eg very early morning or evening times).

  25.  With the focus on accessibility in the late 1980's and early 1990's for people with ambulant disabilities and the subsequent DIPTAC regulations, the industry has responded with new very low floor stepless bus designs which also assist the encumbered passenger (eg the parent with a pushchair, two children and a load of shopping). Even progressive express coach operators are purchasing low floor access vehicles (eg Stagecoach's Oxford Tube) rather than the traditional coach types with a mountain of steps facing less agile passengers. The government has responded by requiring all local service buses to be fully accessible by 2016, but it is to be hoped that this target will be achieved well before that date.

  26.  There are other inclusion benefits from an effective network of bus services by linking areas of different ethnic patterns or income levels, buses encourage an informal level of social contact. Buses must be able to provide access to shops, jobs, education facilities and other essentials such as hospitals. Planning principles, which have been thoroughly revised since the 1990's, emphasise the need for encouraging non-car access. If followed consistently by local authorities, the bus should be enabled to provide reasonable access to a full range of activities. Ideally in urban areas bus services should be of such a quality and coverage so that no-one feels "trapped" in their locality.

  27.  One final point worthy of mention is that many bus operators in their quest to make services more attractive to a wide range of customers, have tended to simplify networks so that basic services are provided on a good frequency. This has meant that some minor variations serving areas or roads on an occasional basis have been withdrawn. This is a clear case of having to meet the needs of a majority, but there may well be a case for the local authority subsidising a low frequency (eg three or four journeys daily) service meeting the needs of marginal areas, thus supplementing the trunk route network.


  28.  Despite the reduction over the last 40 years of its share of all journeys, in distance terms the bus is still the second most important travel mode after the car. The bus can be universally available where a suitable road network exists and thus is a very flexible mode of transport. It can supplement fixed services such as rail, ferries and trams, adding to the attractiveness of those modes. Most larger towns and cities operate bus based park and ride schemes adding to the flexibility of using the car in urban and rural areas (as well as introducing people to the experience of riding in modern buses). Trams or light rail schemes are being introduced in several cities with very impressive results in term of ridership growth in most cases. However, this is an expensive investment being justified where there are major corridor flows of people and hence will be justifiable in only a small proportion of our towns and cities. If the bus can be enabled to perform its function effectively by means of priorities, good information and stable, logically organised networks, then the government's aim of increasing its share of total travel demand can be realised.

April 2002

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