Memorandum of the Institute of Logistics
and Transport (Bus 38)
THE BUS INDUSTRY
INTRODUCTION
1. By way of preamble it is worth noting
the crucial role that the bus industry must play in order to achieve
the objectives for reducing road congestion, improving air quality
and reducing greenhouse gases that the Government has set in its
integrated transport policies, most recently the 10-Year Plan.
Put bluntly, unless the bus industry is able to attract substantial
patronage from trips currently made by car, the targets set by
the Government cannot be met, even if a renascent railway industry
achieves or exceeds the targets set for it.
2. The Institute is concerned that some
recent comments by Ministers, Bus Industry leaders and Local Government
Members and Officials have indicated a confrontational stance,
particularly in respect of the interpretation and use of provisions
in the Transport Act 2000 for Quality Contracts. As the original
proponents of the concept of Quality Partnerships ("Bus Routes
to Success", Chartered Institute of Transport, 1991) we remain
convinced that in the complex statutory environment created by
successive governments, the only practical way forward is for
all players to work together and reach consensus. That will undeniably
require some vigorous debates, but time is not on the side of
British transport and substantial changes to the legislative framework
are not a short-term option.
SUBSIDIES IN
THE UK BUS
INDUSTRY
3. UK governments have always tended to
regard the provision of public transport as a commercial activity.
Operating companies are expected to make profits. Subsidies are
considered to be a sign of inefficient operation. However, cross-subsidies
are an inherent factor in public passenger transport. Subsidies
could not normally be paid from public funds to bus operators
until the 1968 Transport Act which enabled them to be paid for
the provision of economically or socially necessary services.
The 1985 Transport Act arose from the then government's desire
for transparency in the costs of operation of bus services. Services
that could not be provided commercially were to be put out to
competitive tender.
4. Today around 83 per cent of bus mileage
is provided commercially, ie without subsidy, with the balance
being provided through the tendering system. This, however, does
not reveal the extent of other public funding made available to
the bus industry through fuel duty rebate, and to its passengers
through payments for concessionary travel. Local authorities also
directly fund a variety of ancillary functions, including in many
areas the publication of timetables and information and/or the
provision of infrastructure (bus stations, stops and shelters).
Overall it is estimated that some 25-30 per cent of expenditure
by or for the bus industry is supported from public funds.
5. For the bus industry to play its full
part in integrated transport policy it must be capable of offering
services which will cater both for those with no realistic alternative
way of travelling (including those without personal access to
cars, young people etc)—the traditional (and dwindling)
"captive" market—and for those who can be persuaded
to choose bus travel for reasons which might include convenience,
value for money or successful marketing. To serve these market
segments adequately requires services which are comprehensive
in terms of times of availability and hours of operation of an
appropriate range of routes, operated by vehicles with high standards
of amenity and comfort (including ease of access) at fares which
are seen as reasonable, particularly for those opting to use bus
in preference to other modes.
6. In much of the developed world, including
most of Continental Europe and many North American cities, it
has long been accepted that the costs of providing public transport
services that meet these criteria will exceed fare income. Subventions
from public funds are often in the range 30-50 per cent occasionally
greater. It is important to recognise that in many other countries
both public and political attitudes accept such levels of subsidy
on the basis of maintaining the general quality of life in the
urban environment. Public Transport is rarely subject to the dramatic
swings that have characterised British transport policy. Correspondingly
levels of investment have been more consistent than in the UK,
although, at least in major urban areas, recent operator investment
in new vehicles has been impressive.
7. It will be seen that public support levels
to the UK bus industry overlap the lower end of the range of support
observed in other developed countries. However, the common perception
of travellers is that UK public transport is significantly worse
than in many parts of Europe. All things being equal, this should
not be so and this suggests that there is a strong case for examining
how the support is applied.
8. A common European model is to pay support
for networks of services rather than individual routes, and to
expect that concessions for children, older people etc carried
on regular services will be part of the general fares structure.
In Great Britain, excepting Greater London, tendering is on a
route-by-route basis and opportunities to plan jointly the commercial
and publicly supported services do not arise. Therefore some network
synergies are lost.
9. UK concessionary travel schemes are governed
by a Byzantine set of regulations requiring that operators should
be "neither better nor worse off" as a result of carrying
concessionary passengers. The comparison is with passengers carried
at the full standard fare, but as concessionary travellers account
for around 40 per cent of total UK bus patronage, supported by
public funding of almost £500 million, effectively the foundations
of many commercial services are underpinned by public support
payments.
10. Concessionary travel is expensive to
administer: authorities and operators devote much effort and survey
resource to calculating concessionary travel reimbursement. There
is cope for simplification by revising the regulations to allow
the costs of concessionary travel schemes to be a matter for commercial
negotiation between authorities and operators in their areas reflecting
the fact that these are contractual payments to carry specific
groups of passengers at reduced fares.
11. A more radical approach would be to
move to a more open system of network support, whereby in each
authority area a "conference" of the authority and all
the operators within its area would jointly determine the overall
requirement for bus services, following which operators would
each assess the level of support necessary, including concessionary
travel to maintain the parts of the overall network provided by
them. Negotiation between the authority and the operators would
finalise service and support levels.
12. Bus strategies required under the Local
Transport Plan system offer an ideal vehicle for developing this
approach. Ideally an additional sum equivalent to the current
level of fuel duty rebate payments in the area would be available
through the authorities so that a single support payment could
be made for each operator's part of the network.
13. This "Network Development Conference"
approach should more effectively bring together the commercial
skills of the operators with the economic and social objectives
of the authorities to achieve the best possible networks and service
levels. Essentially it would maximise the effectiveness of the
combined resources of the commercial network and public support
payments. Such an approach is not too dissimilar to those in a
number of European countries. In the UK, changes may be required
not only to tendering and concessionary travel regulations but
also to the role of the Competition Act within the UK bus industry.
14. This discussion of subsidy was opened
by the comment that the British have usually regarded the provision
of bus services as a commercial ie profit making activity. Subsidies
have been seen as a sign of inefficiency. Integration has been
seen as a political objective, not an essential feature of public
transport networks that can provide reasonable alternatives to
the private car. This lack of clarity or vacillation by successive
governments has led to Britain having some of the poorest public
transport in Europe. The Government needs to decide what role
it sees for public transport and then draw up the appropriate
financial rules and structures. Five basic options might be suggested:
PUBLIC TRANSPORT ROLES, OBJECTIVES AND SUBSIDY
IMPLICATIONS
| Role | Objective
| Subsidy |
| Commercial | Profit | None
|
| Augmented Commercial | Profit with quantified subsidy to meet identified non-commercial needs.
| Limited |
| Transportation | To provide an effective alternative to the private car with subsidies to keep fares competitive with perceived car costs and thus "control" modal split.
| Focused |
| Regeneration | To complement economic, industrial and development policies through adequate provision of public transport in network and frequency terms.
| Focused |
| Social | Public transport provided as a social service offering mobility for all. Subsidies enable higher frequencies over a wider network to be provided at fares all can afford.
| General |
15. The 1998 White Paper and subsequent actions: The
Transport Act 2000, Local Transport Plans and the 10-Year Plan,
all identify a "transportation" or "regeneration"
role for public transport. Thus subsidies will have to be paid
wherever the cost of public transport networks cannot be fully
recovered from the fare box. This does not mean that bus operators
should not use all their skills both to contain cost and effectively
market their services. Nor does it mean that securing authorities
should be over-prescriptive. The density of networks and frequency
of services will vary according to the nature of the area.
16. In the time available to compile this memorandum
the Institute has not had time to investigate potential solutions
to some of the issues raised. However, a number of broad conclusion
on subsidies can be drawn:
(i) public transport needs to be treated as a network,
not a loose collection of free-standing routes, if it is to achieve
its maximum potential;
(ii) with 25-30 per cent of the bus industry's turnover
coming from public funds, comparison with European cities and
regions with only slightly higher levels of support suggests that
better results might be expected;
(iii) the various streams of public support and the regulations
governing them are Byzantine and unnecessarily complex. Consideration
should be given to providing all mainstream support for buses
(service subsidies, concessionary fares, fuel duty rebate) through
a single ring-fenced comprehensive "pot" allocated through
the Local Transport Plan process with the fuel duty related support
from central government included;
(iv) in determining the single support payments for each
operator, there should be negotiation and agreement between authorities
and operators to finalise the network and service levels.
THE RELATIVE
MERITS OF
BUS QUALITY
PARTNERSHIPS AND
BUS QUALITY
CONTRACTS
17. As noted in the Introduction, one of the Institute's
predecessors—the Chartered Institute of Transport—developed
the concept of Bus Quality Partnerships. These have been supported
and reinforced by the provisions in the Transport Act 2000 to
give such partnerships statutory protection.
18. The major weaknesses of Bus Quality Partnerships
as presently operated are:
— they are not binding on participants. Instances
of authorities and operators defaulting on their initial commitments
have been reported;
— they are not able to include hours of operation
of services or fares levels. In some cases, informal concordats
have been reached on these issues.
19. The advocates of Bus Quality Contracts see them as
an opportunity to extend a quasi-franchising system, similar to
that introduced with some success in London, to other parts of
the UK. However, a number of problems can be identified with this
approach, including:
— few councils and PTEs now have staff skilled in
the detailed processes of bus service planning necessary to formulate
the service specifications that will be the basis of the contracts.
In London the division of London Transport Buses ensured that
appropriate skills were available in each successor body;
— a major criticism of the London arrangements is
that the operators have the close relationships with the passengers
that should ensure that service provision and performance are
well matched to customer needs, not Transport for London who plan
the services in great detail and control the contracts. When operators
are cast in the role of contractors operating someone else's service
specification with no opportunity for change in response to customer
needs, tensions arise and job satisfaction suffers for managers
who can then take no substantial role in market development;
— the tortuous approval procedures laid down in
the Transport Act 2000, which introduce further bureaucratic burdens
for both authorities and operators.
20. Clear examples of the need for more effective partnership
can be seen especially in many small to medium sized towns and
their rural hinterlands, where the mismatch between commercial
and subsidised service requirements leads to networks that do
not make best use of the available resources.
21. The Institute still believes that partnerships to
jointly determine the total bus network in each authority area
offer the way forward, using conferences of authorities and operators
on the lines suggested in the discussion of subsidies above. By
combing the skills of authorities in identifying the social and
economic needs for services to meet their policies with those
of operators in planning, marketing and operating bus services
it should be possible to maximise both the effective use of resources
and passenger satisfaction.
THE RESULT
OF "BUS
CHALLENGE" INITIATIVES
22. At the current time, the Institute is aware of mixed
results from projects undertaken under the various Bus Challenge
initiatives, but the sample available is small. However, it is
appropriate to make a number of observations on the principles
of such funding and the types of scheme being supported.
23. Provided that they are additional to and not replacing
mainstream funding, "challenges" are a useful device
for encouraging innovation. However, it is important to recognise
the downstream consequences of success. For example, if a rural
bus service proves successful to the extent that it would comfortably
meet the relevant local authority's criteria for subsidy, yet
that authority has no headroom in its subsidy budget when challenge
funding expires, what happens? Expectations have been raised and
on normal criteria the new service should continue. Should another
subsidised service be sacrificed to allow this? The Government
should place more emphasis on exist strategies both in its calls
for bids and in assessing them.
24. For both and rural and urban challenges a number
of common service characteristics emerge:
— interchange between services and modes
— joint sponsorship, for example with community
health practices and the Countryside Agency
— demand responsive operation (eg dial-a-bus, "Wigglybus"
etc)
— need for strong promotion and marketing
— emphasis on personal travel needs as compared
to more traditional bus service planning
25. Some key issues arising from this are:
(i) recognition of the traveller as an individual and
adapting services to his/her needs;
(ii) convergence (particularly in rural areas) of transport,
health and parcel carriage requirements;
(iii) the availability in some instances of regeneration,
other specific funds or funds from other agencies with complementary
functions to supplement transport funding;
(iv) use of new technology, particularly vehicle tracking
and communications, which will also facilitate better fleet management,
real time passenger information and other worthwhile developments
capable of wide application;
(v) the advent of travel plans or some types of higher
quality service introduced with challenge funding can create problems
of abstraction of passengers from commercial service, for example
when "direct" works buses are introduced.
26. Care must be taken that disproportionate effort is
not applied to small-scale schemes that are not capable of replication
on a larger scale. Similarly, several authorities have decided
not to bid for later rounds of Challenges because of "bidding
fatigue" and the consequences of diverting scarce resources
from mainstream task to projects with uncertain outcomes, either
in attracting new support or in practical results.
27. All of these features suggest that there will be
value from the Challenge initiatives in:
— increasing focus on individual needs in bus service
planning;
— exposing opportunities to combine transport with
other functions and initiatives (eg with health service requirements
or tourist development);
— accelerating the use of appropriate new technology.
But they should not be overused and have clear exist strategies.
THE IMPORTANCE
OF BUS
PRIORITY MEASURES
AND THEIR
ENFORCEMENT
28. Bus priorities are essential if reliable and punctual
bus services are to be provided. The biggest disadvantage of the
bus is that it shares its "track" with general road
traffic. Whilst this enables it to provide accessible services
it causes buses to be caught up in traffic congestion, unless
bus priorities are provided. Although it is preferable that buses
should have exclusive use of such priorities to maximise their
benefits, in some instances the admission of carefully selected
additional classes of vehicle may be accepted. Thus, it is common
for cycles and taxis to be admitted to bus priority lanes, less
frequently motorcycles and Heavy Goods Vehicles are also admitted.
Where bus frequencies are low and road space permits, High Occupancy
Vehicle (HOV) Lanes may be adopted. In the UK, this has been done
only in Leeds where the lane is reserved for buses and other vehicles
carrying two or more people, leading to the lane being christened
a "two +" lane!
29. The provision of bus priorities requires political
will from the local highway authorities. This is frequently not
forthcoming since bus priority measures are generally seen as
being "anti-car" rather than as better use of road space.
Similarly, in respect of enforcement, all too often the police
see buses only as another commercial road user and not as an effective
instrument to reduce congestion.
30. Another factor in the success of bus priorities is
visibility to the motorist. The most obvious cases of this are
guided busways and contra-flow bus priority lanes, but there are
also substantial arguments in favour of long continuous stretches
of bus priority as may be found, for example, in the Red Routes
in London, the Greenways in Edinburgh, the guided busway corridor
schemes in Leeds and the Quality Bus Corridors in Dublin. Such
schemes are however the exception rather than the rule.
31. Many bus priority schemes are installed in a piecemeal
fashion and do not reflect any joined up thinking. Thus there
are instances where park and ride sites have been set up but there
are no bus lanes of any length to help the bus (and thus the park
and rider) to reach the city/town centre quickly without being
trapped in traffic queues. Similarly bus priority lanes and other
measures are often insufficiently lengthy or too infrequent to
make much difference. They consequently fail to entice the potential
traveller to prefer the bus over the car. If the bus is to be
promoted as a main mode of urban travel then users must be able
to see and experience the difference in using the bus rather than
a car.
32. Only guided busways are self-policing: all other
bus priorities require supervision to ensure that prohibited vehicles
do not use them. A mile-long bus-only lane can be rendered useless
if one lorry parks in it to make a delivery, or if a car park,
whilst the driver pops into a newsagents. The abuse of bus-only
lanes in Britain tends to be high because of insufficient enforcement
by the police. A very different situation exists in Dublin where
the Quality Bus Corridors are respected and well-policed by the
Garda.
33. The main impact of bus-only lanes is to improve service
reliability, unless they are part of a comprehensive route traffic
management exercise, such as the Red Routes in London, where cost
savings may be made because vehicle and staff productivity can
be improved. However, in non-comprehensive or insufficiently enforced
schemes it is frequently the case that benefits observed in the
short-term are eroded, often because of abuse of the facilities
by other road users.
34. Once bus-only lanes have reached a degree of maturity,
five particular problems arise:
(i) Inconsistent periods of operation cause confusion
to car drivers and lead to lane abuse, ie ignoring the restriction
when they should be observing it and ignoring the lane when they
can use it!
(ii) Inconsistent surface treatment, in that separate
colours—green, red, black—are now commonly used but
there is no standardisation—eg red for all day bus lanes,
green for daytime only etc. Note the different conventions in
London and Edinburgh for example!
(iii) Lack of enforcement—the police do not consider
bus-lane enforcement worthy of any priority, which leads to widespread
abuse at all times. Limited waiting/loading times are frequently
ignored by frontages onto bus-only lanes. It is of course recognised
that the police work to priorities and plans set by the Home Office
and suffer their own lack of resources.
(iv) Maintenance—where bus-only lanes are coloured,
eg Greenways in Edinburgh, the coloured top layer wears off and
this, combined with the works of the public utilities, means that
the viable message is reduced.
35. The key to successful bus priorities is enforcement.
Many bus operators are now fitting CCTV cameras to their vehicles
for internal security and external recording of traffic incidents.
It is believed that images from these and static cameras can only
be used for prosecution of bus lane offences in London, but they
do enable serious or persistent offenders to be identified and
referred to the enforcement authorities. The London arrangements
should be extended elsewhere in the UK, possibly accompanied by
decriminalisation to allow warden enforcement and reduce pressure
on police resources.
36. Whilst detection of bus lane infringements by the
operators themselves is obviously helpful, only the police can
deal with moving traffic offences. As the benefits of bus lanes
can be quickly eroded by infringement, there is a strong case
for suggesting that the highways authorities and the police should
build into the costing of proposed schemes provision to pay for
police enforcement as part of the ongoing revenue costs. In some
cases, operators have paid for a police presence, but usually
only for short periods.
37. There should now be sufficient evidence from the
large number of bus priority schemes for DTLR to develop guidance
on the costs and benefits of enforcement, so as to improve the
provision for enforcement both in the planning and the operation
of such schemes. This is now urgently required so the yet to be
implemented schemes in LTPs can be put in place with maximum effect—this
demonstrates the importance of clear and technically robust monitoring
programmes as part of these infrastructure projects.
38. The Sub-Committee's question directed attention to
enforcement. Before leaving the topic of bus priorities however,
the Institute consider attention must be drawn to a serious potential
conflict between policy objectives and assessment of major LTP
schemes using the NATA procedures. Because NATA, rightly, looks
at costs and benefits in the round there have been cases (for
example Leicester) where a comprehensive package of bus priorities
and real traffic restraint has failed to be accepted because of
the influence of high disbenefits to car traffic —in fact
because the prime objective of the package is being shown to be
achieved! Had the package been brought forward as a series of
smaller schemes, each under the major scheme threshold and so
within local authority discretion under Local Transport Plan procedures,
there would have been loss of visibility and impact compared to
the comprehensive approach but the package would eventually have
been completed. Such cases demonstrate that the Government needs
to review its approval procedures to ensure that its transport
objectives and targets as set out in the 10-Year Plan are not
frustrated by the perverse operation of standard assessment procedures
and resource allocation rules.
REGULATION OF
THE BUS
INDUSTRY
39. As noted in the preamble, and in common with the
Institute's views on the rail industry, now is not the time for
another piece of radical primary legislation. Experience elsewhere
in the world has shown that privatised and deregulated operations
can provide high quality integrated public transport systems if
there is a consistent approach to the application of subsidy and
co-ordination of operators' services.
40. In the discussion of subsidy we have suggested that
substantial revision of the regulations governing tendering and
concessionary travel, to allow support to be applied at a network
level rather than to a route or an individual passenger journey
would be beneficial and that the mechanism to deliver this in
practice can be developed through the Bus Strategies of Local
Transport Plans.
41. One area of major concern which time and space does
not permit us to explore adequately in this memorandum is the
dead hand of the Competition Act as interpreted by the Director
General of Fair Trading. Already the application of the provisions
of the Act has led to the termination—to the bemusement
of the public affected—of sensible voluntary integration
such as joint timetables and inter-available ticketing schemes.
There is now a strong case for treating the bus industry as a
utility and creating a Bus Regulator to judge public interest
and promote the achievement of the Government's integrated transport
policies.
THE CONTRIBUTION
OF BUS
SERVICES TO
REDUCING SOCIAL
EXCLUSION
42. Social exclusion is commonly associated with urban
problems, particularly in inner cities and on large peripheral
estates. However, it is not only urban areas that have social
exclusion problems, rural poverty is a less studied but nonetheless
acute problem. Even in non-deprived areas, pockets of social exclusion
exist. Crime tends to be prevalent in many deprived areas, with
vandalism and attacks on vehicles, including buses, becoming more
widespread. Choice is also limited where new housing areas require
the provision of a bus service, but it is not present at the inception
of the development, and introduced much later on.
43. It has long been recognised that the social groups
most likely to suffer social exclusion are also those most likely
to use bus services. They are also those least likely to be able
to afford to run a reliable car (leading to the phenomenon of
estate roads partially obstructed by immobile vehicles for most
of the day). Therefore a key failure of most current transport
policy as far as tackling social exclusion is concerned is that
choice is unlikely to be available for the people most affected.
Buses offer the best opportunities to use transport to tackle
social exclusion.
44. As has already been experienced with the introduction
of low floor buses to benefit disabled people which have also
brought significant benefit to others such as parents with buggies
(which can use the wheelchair spaces) and those with temporary
mobility impairment, measures to assist social inclusion will
usually also be of benefit to a wider population. The following
paragraphs demonstrate the issues for each aspect of bus services.
45. Networks: Support must be made available to ensure
that all communities have adequate links to a range of employment,
shopping and commercial centres, hospitals and clinics, social
and recreational facilities. Although instances of public transport
services being provided and supported financially as part of regeneration
initiatives have occurred, there is little recognition of the
need for long-term funding to sustain services as lifestyle changes
take place. It is little use funding training for a group of unemployed
people to take jobs in a relatively distant location if the pubic
transport service used to access those jobs is withdrawn at eight
weeks' notice (the period of notice required to vary a regulated
local bus service) because the operator considers it is not viable
or if there are no convenient services linking such clusters of
people to appropriate locations where their skills can be employed.
46. Service Frequency and Periods of Operation: In the
remoter deprived communities, the sense of isolation is often
enhanced by the early termination of services. This cuts down
the ability to socialise in the town or regional centre. In the
mornings and at weekends, relatively late starting services can
reduce the opportunity for shift-based and other employment requiring
an early start.
47. Fare Levels: Public transport fares have risen considerably
faster than the general cost of living index, at a time when motoring
costs have continued to fall. The paradoxical situation is created
that bus services, perceived as a low amenity form of transport,
are more expensive than high amenity motoring. For those unable
to purchase travelcards or season tickets the situation is exacerbated
in that no discounts are available. Although concessionary fares
alleviate the problem of travel costs for elderly, disabled and
children in education, there is no such assistance available for
low paid part-time workers, unemployed people, parents accompanying
families or other deserving cases. Furthermore, the policies of
some operators towards multi-operator travel schemes (for example
in West Yorkshire the all operator Metro Card price is drastically
undercut by single operator equivalents offered by the large groups)
and the attitude of the Competition Authorities towards the creation
of such schemes on a commercial basis, mean also that for some
on the margins of social exclusion the availability of suitable
tickets is becoming more restricted.
48. Patterns of Operation: Although not specifically
a problem of social exclusion, bus operators have tended to rely
on "mass transit" solutions to grow the market by concentrating
services at higher frequency on key routes. This frequently creates
the dichotomy that increasing bus use and modal transfer may be
achieved, but at the expense of giving up service on sections
of route which are valued most by those with limited mobility
and no alternatives. It then falls to local authorities to cover
the lost services through the tendering process. More flexible
patterns of operation with timed interchange and free transfer
between services or greater use of demand responsive options would
help considerably with solving the problems of isolation and restricted
travel opportunities that characterise social exclusion.
49. Support Policies: Whilst the remedies indicated,
of providing more extensive networks, with longer periods of operation
and cheaper travel, inevitably imply greater public support or
lower returns for the operator, there should be a virtuous relationship
in creating increased levels of bus travel, reduced need to own
a car and, in the longer term, increased revenue from greater
bus use. At subsidy levels measured in pence per passenger trip,
such support compares well with public support for both car travel
(which certainly does not cover its full costs in congested conditions)
and for rail, where support is often measured in pounds per trip
and the majority of passengers would not be regarded as socially
excluded.
SUMMARY
50. In this memorandum the Institute has discussed a
number of issues in response to the questions raised by the Sub-Committee.
Common threads emerge:
— Partnership rather than quality contracting is
seen as a way forward, with the proposal of the Network Development
Conference offering a model for debate;
— Primary legislation and radical changes are not
required. Using the wide range of powers to make regulations it
should be possible to use existing legislation to move towards
the Conference proposal;
— The Conference approach would allow full incorporation
of bus priority, social inclusion policies, joint ticketing, information
and infrastructure within the overall negotiation of support levels
for an area;
— Support to the bus industry should be rationalised
so that a single "pot" replaces current separate arrangements
for service subsidies, concessionary travel and fuel duty rebates;
— The Competition Act 1998 sits uneasily with the
objectives of integrated transport policy. This could be resolved
by the creation of a Bus Regulator, as is the case for other privatised
utilities.
April 2002
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