Memorandum submitted by the Association
of Transport Co-ordinating Officers (ATCO) (ST 19)
1. The Association of Transport Co-ordinating
Officers (ATCO) represents Local Authority Officers responsible
for the planning managing procuring and promoting of public transport
and School Transport, the co-ordination of passenger transport
in the public sector, and the development of sustainable alternatives.
2. ATCO welcomes the opportunity to comment
on the draft bill and the implications for local authority resources,
the co-ordination of school transport with other modes of travel
and the promotion of modal shift and healthy lifestyles for children.
3. ATCO particularly welcomes the recognition
that the school run is a major contributor to traffic congestion
and that the prime objective of the bill is to reduce the dependence
on the private car for the journey to school and promote alternative,
more sustainable, modes of travel.
4. ATCO welcomes the flexible approach to
provision to be allowed in trial areas. The distance based criteria
set in the current legislation is inequitable and divisive and
should be capable of amendment to reflect local circumstances.
Whilst the principle of a mileage-based formula is considered
too rigid the guarantee of free, appropriate, transport should
be retained for those pupils with particular difficulties in accessing
education.
5. Any new school travel scheme should consider
the needs of all pupils. However, providing what amounts to an
individual travel plan specific to each pupil must be properly
resourced and also be integrated with other transport provision.
6. The proposed objectives of the scheme
represent a step change in the method of providing school transport.
The prime concern that ATCO would raise is that the existing budgets
for school transport should be retained; and the introduction
of a scheme should not be seen as a method to reduce the overall
spending in this area. ATCO would welcome the legislation requiring
any savings made by more innovative provision to be re-invested
in greater development of the objectives of the scheme.
7. ATCO is of the opinion that major efficiency
gains can only be made by co-ordination of school opening and
closing hours as part of integrated approach to delivering school
transport within a scheme. This is something that the proposed
legislation fails to consider and given the voluntary nature of
the trial schemes it should be provided as a discretionary power
in the bill.
8. The principle that affordable fares could
be charged to all children is to be welcomed in principle; however,
it is important to ensure pupils travelling on commercial bus
services are treated equitably and not disadvantaged compared
to those on subsidised transport. The legislation should also
make clear what steps will be taken to protect low income and
other vulnerable groups. There is a need to link this with the
provision of concessionary bus travel for all children and students
up to 19 years. ATCO sees the advantage in a national standard
for this to ensure consistency between all LEAs.
9. The provision of transport for pupils
who cannot access the nearest school should be retained; an extension
of this to those pupils whose parents exercise the right to access
alternative schools through parental choice should not be allowed
due the additional resources involved.
10. ATCO recognises the simplification that
would result in providing post-16 education transport including
to FE colleges etc under similar eligibility criteria to other
pupils. Clarification is needed in respect of what constitutes
the nearest school/FE college in terms of courses with multiple
subject choices such as A-levels. Any increase to the statutory
level of provision will require funding to be provided.
11. The retention of a minimum level of
provision should be decided locally taking into account the geography
and demographics of school catchment areas.
12. The principle of providing transport
to denominational schools is something that ATCO recognises as
a follow on from the admissions policies set out in the Educations
Acts. Where transport is to be provided clear and transparent
criteria for eligibility should be set in the legislation and
the right of parents to seek a faith based approach to schooling
be subject to a high standard of proof of faith involvement. In
respect of Welsh medium education the legislation should continue
to require transport to the nearest Welsh language provision to
be made with this clearly defined, as the difference between full
Welsh language schools and mixed language schools offering a Welsh
language stream is considerable in terms of culture and the distance
to be travelled. ATCO believes that this provision should be to
the nearest Welsh language education, irrespective of school status.
13. As noted in paragraph 10 the key matter
in the area of post-16 education is the need to clarify basic
eligibility. This will become more important given the focus on
improving participation rates in the post-16 education sector.
14. ATCO considers that the start dates
for trial schemes to be realistic, subject to adequate resources
being available to manage the change. The matter of resources
is critical given the length of time the existing system for education
transport has been in being with local authority officers familiar
with the current requirements. New requirements and more flexible
approaches will invariably need additional personnel.
15. The proposed changes will allow local
authorities an appropriate degree of flexibility to run local
travel schemes. The focus should be on encouraging schemes that
integrate with other transport services and with other initiatives
such as safer routes to school and road safety education for pupils.
16. The principles of an innovative travel
scheme will need to draw on the ability to co-ordinate the travel
of several schools to ensure that economies of scale can be generated
to finance new initiatives. The major handicap is the inability
of LEAs to control school opening and closing times to allow more
effective use of current transport resources. Whilst ATCO believes
that it is essential for this to be addressed as part of the bill.
17. The guidance for LEAs seeking pilot
scheme is clear in terms of the information needed. However, the
guidance fails to recognise the resource issues that affect local
authorities seeking pilot scheme status and the current trend
for non-LEA officers to be the procurers of school transport.
ATCO is not recommending that the role of the LEA in school transport
be diminished given the statutory obligations that fall on LEAs
to ensure attendance at school but the bill should acknowledge
the role of non-LEA staff ie transport co-ordination officers
in the provision of school transport.
18. The application form for pilot scheme
status is clear. The matching of the timescales to other transport
and education related targets are considered by ATCO to be fundamental
to the success of any schemes proposed. In particular the submission
of the next 5-year Local Transport Plan in July 2005 should be
seen as a key date given this document's role in setting medium
term transport strategies. The emphasis in the new LTPs on accessibility
to essential services including education should be a key driver
in shaping new school transport strategies.
19. The aim of obtaining best value from
the £2 billion spent on school transport annually can best
be achieved by setting flexible and meaningful local targets that
reflect each LEA's circumstances. Many local transport authorities
have integrated transport units in place and achieve cost effective
provision of school transport within existing constraints. The
key to greater efficiency lies in staggering school hours to enable
better use to be made of existing transport resources. ATCO sees
fundamental benefits in linking the issues surrounding school
travel to the LTP process and the targets for accessibility to
be introduced in the new round of LTP submissions which would
ensure that LEAs and local transport authorities act with a common
purpose.
20. The power for Ministers or the National
Assembly Government of Wales to intervene should not be continued.
The Education Acts place a duty on local authorities to ensure
attendance at school that should be enshrined into this bill.
Sanction would then be for individual parents to pursue against
the LEA against the background of local circumstances, something
that the bill is designed to promote as the key determinant of
school travel provision.
21. ATCO considers that, subject to the satisfactory
working of the pilot schemes being established, the bill should
enable other LEAs to implement change at their discretion in line
with their own local circumstances without the need for further
primary legislation.
22. Minor changes to transport legislation
proposed in the pilot areas will also be applied generally through
a Regulatory Reform Order. The opportunity should be taken to
make the provision of bus services for school children as attractive
as possible to bus operators and LAs. Specifically Bus Service
Operators (Fuel Duty Rebate) Grant should be paid on all services
where children pay a separate fare to school and the three children
to a double seat concession should be revoked in order to promote
more comfort and reduce behaviour problems.
April 2004
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