Memorandum by the South East Forum for
Sustainability (Bus 30)
THE BUS INDUSTRY
1. My name is Nigel Rose. I represent the
South East Forum for Sustainability—Transport Group-Thames
Valley on the Thames Valley Multi-Modal Study Steering Group.
SEFS itself represents the interests of a number of environmental
groups (including Transport 2000, CPRE, FoE, RSPB, Railfuture,
Wildlife Trusts etc) at a regional level. I am also an Independent
elected member of Wokingham Unitary District Council and have
been involved in matters relating to transport at a local level
for some 20 years.
2. It goes without saying that the bus should
form a key part of the transport network at a local level. However,
failure to integrate with rail and metro services and a general
neglect to consider the passenger's total needs have led to a
steady decline in patronage outside London and one or two specific
towns.
3. If modal shift is to be achieved then
the bus has to be an attractive alternative to the private car
in terms of the total journey experience. This will require:
— priority use of road space by properly
joined up and enforced bus lanes, priority at and through traffic
lights, etc so that actual road speeds can be competitive;
— new housing developments designed
to be bus friendly (particularly for school buses) by using looped
layouts and bus gates etc;
— real time information systems at
bus stops and via mobile phones, internet etc (this can be particularly
important in areas where services are less frequent and the (potential)
passenger does not know whether the bus went early, is late or
is not running at all on that occasion);
— changes in revenue support for school
buses and the scrapping of the current two mile and three mile
rules which decide whether pupils are entitled to transport—these
distances are completely outdated and encourage the school run;
— more revenue support for services
in the evening and at weekends—we no longer have a nine
to five economy and leisure (window) shopping journeys are as
significant a generator of congestion as work journeys—even
nine to five workers have to stay late and will not use the bus
if there is a risk they cannot get home;
— ticketing systems should provide
discounts for regular use over a half year, but need to move away
from the season ticket approach that assumes five journeys in
a week—working at home and away from a regular base remove
the benefits—smart cards or similar could provide the solution.
4. There are effective examples of bus priority
measures in the greater Reading area where Park & Ride buses
utilise the hard shoulder of the A3290 "motorway" and
then have priority at traffic lights when joining the A4, bypassing
queuing cars; bus lanes in both directions on the eastern approaches
to the town centre; traffic light priority on the A329 corridor
and at a major crossroads in Twyford. However, the total effectiveness
is reduced by abuse of the bus lanes by non-authorised users and
parking, particularly by "white vans". Speedy action
is needed to provide the necessary enforcement legislation, currently
restricted to London.
5. There is one piece of legislation which
currently goes totally against an integrated joined up network
of routes and the achievement of government transport policy—the
competition policy operated by the DTI and the Office of Fair
Trading. The situation is obviously proving frustrating to the
DTLR as much as it is locally, judging by recent correspondence.
6. The Transport Act 1985 deregulated the
bus industry, outside London, with the laudable aim of developing
new, innovative services. However, the very strict interpretation
of the rules on competition between operators is now working against
best service to passengers and is having the opposite effect to
government transport policy, by driving frustrated passengers
back into cars.
7. All the surveys done locally by Councils
and others indicate a desire for integration of services and co-operation
between operators to deliver through-ticketing and comprehensive
"joined-up", preferably clock-face, timetables. However,
based on best legal advice, the operators cannot contemplate considering
this approach. The Transport Act 2000 (135 to 138) provides for
local authorities to make a ticketing scheme, but again legal
advice means that operators refuse to take part because it is
viewed to be illegal under competition legislation.
8. There are many examples around the country
where co-operation between operators would be in the best interests
of passengers—for example First Group and Stagecoach would
like, I understand, to provide a Greater Manchester Travel Card,
providing the opportunity for cross-city journeys, lost when GMPTE
services were privatised. This has been blocked by the OFT.
9. On the other hand, London Transport,
with its Travelcards developed to give through ticketing between
suburban trains, buses and tubes, was specifically excluded from
the legislation and is able to provide an integrated system—something
of much benefit to residents across the south-east when travelling
to London, but not available to them locally.
10. The problem was brought to a head in
Wokingham Unitary District last autumn. Until November, all services
on one of the main local corridors across the area from Reading
out to Twyford were operated by Reading Transport. Residents of
villages could take any one of several RT services to Reading.
Between them there was a roughly half-hour frequency, even though
some individual services only ran two hourly. They could make
savings of 30p to 50p with return tickets and, in the case of
the villages within the Reading designated "urban area",
residents could also use the Reading "Busabout" £2
ticket for the day enabling, for example, pensioners to make through
journeys across Reading, at no extra cost, to a hospital to visit
relations, despite changing buses in the town centre.
11. Reading Transport withdrew one of their
longer routes for legitimate commercial reasons, but this formed
a major component of the overall frequency of services. Fortunately,
Arriva stepped in to take over from their High Wycombe base, which
has kept the overall service frequencies about the same—BUT
they will not accept Reading return and "Busabout" tickets
because of their legal concerns. They cannot issue the latter
so residents wanting to go to the hospital across town cannot
take the Arriva bus without a major cost penalty of £1 or
potentially a two hour wait in Reading for the "right"
bus back home. Similarly, Reading Buses cannot accept Arriva returns.
Passengers have to buy single tickets to ensure flexibility. They
are returning to their cars out of frustration, unless, having
no car, they have no option but to wait or pay.
12. The operators would like to co-operate
but dare not. A little local indiscretion could lead to a fine
of 10 per cent of total group turnover. For companies like Arriva
or Stagecoach, who run trains and buses across the country, the
numbers could be huge—millions of pounds. Competition regulation
is making public transport less competitive with its real competition—the
private car—and frustrating government transport policy.
13. The OFT also appear to think that it
is better for two operators to each run an hourly service within
five minutes of each other rather than be sensible and deliver
an overall frequency of 30 minutes. This may give theoretical
competition on fares, but the only competitor that wins is the
private car!
14. The DTLR have reminded us of the Order
made in 2001 exempting multi-operator ticketing schemes from having
to be notified individually to the OFT. However, DTLR have acknowledged
that "bus operators and local authorities have expressed
considerable concern about the terms of the ticketing scheme block
exemption. Bus operators are bound to take the Competition Act
very seriously and, mindful of the sanctions, are understandably
extremely wary of breaching any of its provisions. It is clearly
unsatisfactory that operators should either feel compelled to
abandon existing worthwhile initiatives, or be deterred from developing
new ones" (letter from DTLR to Wokingham District Council—February
2002).
15. In the same letter, in relation to "joined-up"
timetables, DTLR said ".....the Director General of Fair
Trading takes the view that an agreement between bus operators
to operate at agreed minutes past the hour amounts to a market
sharing agreement. As such it is prohibited under the terms of
the Competition Act 1998. Clearly there are obvious potential
advantages to passengers in this kind of agreement and the OFT
have suggested that it may be possible for an agreement to benefit
from an individual exemption". The OFT are not therefore
including this in the so-called block exemption.
16. I hope that the Sub-Committee will recognise
from the above that, if headway is to be made to deliver modal
shift and remove some of the problems for those without cars,
then public transport has to be joined-up in all its aspects—train
to bus and bus to bus. I urge the Sub-Committee to demand immediate
action from the DTI and OFT to remove the damaging impacts of
the Competition Act and the Treasury to release more revenue funding
to support bus services and community transport and provide a
comprehensive network of truly sustainable transport alternatives
to the private car. This is necessary to fulfil the objectives
set out in the Transport White Paper and the Transport Act 2000.
The alternative will be grid-lock for those with cars and more
social exclusion for those without.
N D Rose
12 April 2002
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