Memorandum submitted by FirstGroup plc
(ST 4)
AN INTRODUCTION
TO FIRST
First, the UK's largest surface public transport
operator, is the second largest operator of yellow school buses
in North America carrying a million children there every day in
16,500 vehicles.
Four years ago we started working with the then
DETR and Department for Education in an attempt to get their agreement
to run American built, dedicated school buses on a range of pilot
yellow school bus initiatives with local authorities across the
UK. We found there were endless constraints introduced. It took
a ministerial initiative to break through the logjam.
We now run seven pilot yellow school bus services
in the UK at Runnymede, Hebden Bridge, Aberdeen, Wrexham, Bristol,
Windsor and Maidenhead, and Wokingham. These are all small initiatives
which are all successful in their own right but are not large
enough to allow us to measure widespread behavioural change.
We believe that good home to school transport
has the potential to deliver educational benefits and, in the
longer term, public transport benefits. For example, teachers
at schools with dedicated school bus services have reported decreased
truancy (eg Henbury School in Bristol has reported improved attendance
of 57% from those children who use the yellow school bus) and
increased educational attainment as students arrive at school
with a "ready to work" frame of mind. We also believe
that the longer students are encouraged to use public transport—through
good service and reasonable fares—the better chance of continuing
the practice into adulthood.
CURRENT ISSUES
IN HOME
TO SCHOOL
TRANSPORT
Home to school transport is one of the most
neglected forms of transport in the UK. Some of the legislation
dates back to 1944 and, until now, the Government's policy initiatives
have focussed on good practice in a diffuse range of worthy but
largely impact-free solutions.
As a result development of school bus services
has been neglected. Traditionally school buses and coaches are
old, there are widespread instances of bad behaviour and vandalism,
services are fragmented and contracts traditionally awarded to
the lowest price bidder as a poor interpretation of best value
provider.
Many parents and children will avoid making
use of these services if they can. This might help explain why
just 7% of UK children under 12 travel to school by bus compared
with 54% in the United States where services are of a much higher
standard.
Nearly 20% of traffic on our roads at the morning
peak is on the school run with research for the Department for
Transport last year showing that the numbers of children travelling
to school by car over the past 20 years has nearly doubled (from
16% to 27%).
Better home to school transport would reduce
that traffic according to the DfT study which showed that 65%
of parents would prefer not to drive their children to school
but believe they have no reasonable alternative. Some 32% of parents
said they would not use their car at the morning peak if they
did not have to drive their children to school.
If improved school transport was on offer 76%
of parents who drive their children to school, said they would
switch—a figure echoed by pupils' responses.
IMPROVING HOME
TO SCHOOL
TRANSPORT—THE
YELLOW SCHOOL
BUS CONCEPT
— Yellow school buses are single floor
vehicles so the driver is able to see the students. Many problems
on school buses occur traditionally on the top deck of double
deckers where children are unsupervised;
— Yellow school buses have the same
driver every day who knows the names of the students;
— Drivers are, wherever possible, recruited
from the school community, such as parents, janitorial staff,
admin assistants, etc. In the US, many of our school bus drivers
are mothers with children at the same school who, apart from having
the same holiday requirements, understand the needs of both the
children and the schools and colleges;
— Drivers are highly trained, including
safety, security and child behaviour for the age group they are
carrying;
— The service operates as near door
to door as possible;
— There is a partnership between parent,
school and operator;
— The driver is in contact with his/her
operations room;
— The vehicle meets high safety standards;
and
— Drivers do not collect fares on board
and focus exclusively on driving and their passengers.
RESPONSE TO
CONSULTATION QUESTIONS
Q1. Do you agree that the existing school
transport legislation, which assumes that it is reasonable for
pupils to walk three miles to school (two miles for under 8s),
accompanied if necessary by their parents, is outdated, and contributes
to increasing levels of car use?
A1. First would agree that existing school
transport legislation is outdated. Increasingly parents do not
accept that three miles (or two miles for under 8s) is a reasonable
distance for their children to walk or cycle to school and consequently
take their children to school by car in larger numbers. Parental
choice has also created more complicated home to school journeys.
However, there are other important factors unrelated
to school transport legislation that contribute to increasing
levels of car use. Roads are busier and, in overall terms, both
walking and cycling have decreased. For example, when the Education
Act 1944 was passed many homes did not have one car, never mind
two or three. Increasing car ownership and travel patterns that
have changed beyond recognition means there are now more people,
with more cars, using them more often to go to more places.
Q2. Do you agree that any new school
travel schemes should be based on an assessment of the travel
needs of all pupils in a local travel scheme area (from nursery
to age 16)?
A2. Offering new school travel schemes to
all pupils has the greatest potential to meet the Government's
social inclusion objectives and to cut car use on home to school
journeys. An area-based assessment will make local authorities,
schools, parents and children confront the options available for
home to school transport. Local authorities should seek solutions
for all pupils on an area basis to take advantage of the operational
efficiencies, flexibilities and cost savings that this will offer.
If means testing is introduced then it should
be simple to understand and should not be expensive to administer.
A careful balance needs to be made between the administration
cost of extensive means testing and the ability to offer a widely
available and cheaper scheme with lower administration costs.
A sensible approach to fares must be taken if the aim of reducing
congestion and car use is to be achieved as moving away from free
entitlement carries a risk of the opposite occurring.
Q3. Do you agree that in drawing up school
travel schemes LEAs should have the widest possible discretion
to make appropriate travel arrangements?
A3. Giving LEAs the "widest possible
discretion" is always important but will be more effective
within a broad, national framework. The Draft Bill will allow
a range of new schemes as cycling and mileage allowances, concessionary
fares, community transport and car sharing schemes to come forward.
While these are all worthy options, First's
wide experience in North America and the UK, is that if we want
to achieve real impact, to deliver behavioural change, to reduce
congestion, to improve safety and to offer the broader educational
benefits that we have highlighted earlier, then only the school
bus can deliver.
It would be a lost opportunity if LEAs bring
forward labour intensive solutions at the expense of school bus
schemes. The day to day experience in North America demonstrates
that the widespread use of school buses are the most effective
tool in achieving the Government's objectives.
We would urge that the pilots are introduced
on a citywide scale if they are to successfully demonstrate the
real potential of dedicated school buses.
Of secondary concern is that giving LEAs the
"widest possible discretion" could lead to over-specification
denying the market the opportunity to provide cost and operational
benefits. Similarly, tenders could also be tightly drawn criteria
for certain types of vehicle or even specification of features
within vehicles, which could introduce barriers to entry and infringe
competition legislation.
Q4. Are the proposed scheme objectives
(see page 4, paras 7 and 8) drawn widely enough?
A4. Raising the quality of school transport
should be explicitly stated as one of the priorities of the proposed
schemes. Also trialling "modern technology in fare collection"
could distort priorities lead to the introduction of smartcards,
which could swallow up money that could be better spent on providing
services. The only exception would be where school transport could
be an "add on" to an existing smartcard scheme for libraries,
school meals, etc.
Q5. Do you accept the principle that
affordable fares could be charged if this secured more comprehensive
and higher quality school transport provision?
A5. In First's experience, there is price
resistance to charges over £1 a day per child and there is
huge administrative burden involved in collecting fares which,
for safety reasons, should not be collected from boarding students.
Fare levels should be set to encourage take-up rather than to
limit it. Indeed, widening free provision to school bus services
would have the biggest impact in terms of reducing congestion
and cutting car use, increasing the independence of students with
a safe, sustainable alternative to the parental car and offering
the possibility of educational benefits, such as reducing truancy
and improving behaviour.
A town or city-wide yellow school bus scheme
with low fares or even free school transport for all pupils living
over one mile from school would allow the potential impact of
dedicated school buses on school run traffic to be tested to the
full.
If fares are charged then vehicle quality should
improve to retain users. Again this may require LEAs to place
greater emphasis on high quality provision.
Q6. Are the proposals relating to charging
fair, in that they protect children from low income families who
attend their nearest suitable school from paying fares? Should
the legislation or individual scheme authorities do more to protect
vulnerable groups?
A6. First does not have a view.
Q7. Should there be protection for children
who have been unable to gain a place at a school within walking
distance from home, where they are sent to a school that their
parents did not choose some distance away?
A7. First does not have a view.
Q8. Should any compulsory school age
pupils educated full time at FE colleges or otherwise outside
school be treated in the same way as pupils of compulsory school
age registered at school, or are their needs best met through
a locally tailored package of support?
A8. First does not have a view.
Q9. Are the proposals for the core minimum
provision (ie for children of compulsory school age who live beyond
walking distance from the nearest suitable school at which places
were available) fair?
A9. First does not have a view.
Q10. Should schemes also make provision
(possibly on a fare paying basis) for transport to denominational
schools or Welsh medium schools, even when they are not the nearest,
provided the distances pupils travel and the cost of provision
are reasonable?
A10. First does not have a view.
Q11. Does the prospectus do enough to
ensure that there is good integration between school travel schemes
and post-16 transport policy statements?
A11. First does not have a view.
Q12. Are the proposed scheme start dates
(September 2006 or 2007), end date of pilot period (2010) and
evaluation timetable (2011) reasonable?
A12. The proposed dates are reasonable in
the sense that they can be achieved but the timetable could be
more ambitious. An evaluation of First's yellow school bus schemes
by Steer Davies Gleave for the Department for Transport has shown
that high quality, dedicated school bus services can deliver very
real benefits quickly. We believe the pilot school travel schemes
should be expedited to bring forward widespread implementation
as soon as possible not in seven years time.
Q13. Do the proposed changes to transport
legislation address the concerns of LEAs wishing to run local
travel schemes?
A13. First does not have a view.
Q14. Are any further legislative changes
needed to give LEAs the freedom they need to run innovative local
travel schemes?
A14. If LEAs were to offer longer contracts,
then costs could potentially reduce, as investment in new vehicles
would be more secure. We understand the Department for Transport
will shortly be publishing proposals in this area.
Q15. Does the draft prospectus provide
sufficiently clear and appropriate guidance for LEAs putting together
applications to become scheme authorities? Are the evaluation
criteria clear and appropriate?
A15. A wider cost benefit analysis including
savings in the cost of hiring vehicles for extra-curricular activities
(school trips or swimming lessons etc.) and the more difficult
to quantify benefits of a reduction in the number of accidents,
less pollution, a reduction in the amount of parents time spent
on the school run, a reduction in truancy etc. could be used should
be used to demonstrate overall cost neutrality rather than a simply
looking at school transport budgets.
Paragraph 34 of the Draft Bill and Prospectus
requires successful LEAs to produce annual reports, which will
then be drawn together in an independent evaluation. There is
a danger of comparing apples with pears in the evaluation. To
avoid any confusion, the DfES should issue a pro-forma that would
need to be completed for these reports. The pro-formas could then
be issued as part of the Application packs, giving LEAs an indication
of the reporting what will be required.
Q16. Please comment on the application
form (is it clear, is the content right, is it easy to complete,
is the application timetable achievable and matched to other related
dates (eg local transport plan applications, schools admissions
round))?
A16. First does not have a view.
Q17. What more could government do to
encourage better integration in local transport scheme areas between
all types of publicly funded transport, to achieve better value
for the more than £2 billion which is spent annually in England
and Wales on publicly funded transport?
A17. The Government could do more by supporting
properly staggered start times. The 10-15 minutes discussed in
the draft Bill will go some way towards achieving better value
but more staggered school times are the key to achieving a step
change in the quality of school bus services without increasing
costs dramatically. Using a bus on two or three home to school
journeys increases the marginal costs of operators (eg increased
fuel costs and drivers' hours) without increasing overheads (eg
the number of buses or size of depot).
Q18. Is it necessary for the Secretary
of State and the National Assembly to have the power to direct
LEAs to revoke or amend aspects of their travel schemes, once
approved?
A18. First does not have a view.
Q19. Are you content for this Bill to
provide both for pilot schemes, and for the local travel scheme
approach to be rolled out to more LEAs on a permanent basis, without
further primary legislation, if it is a success?
A19. The Bill needs to address how success
is judged. The success of the pilot schemes should be judged on
reducing congestion, shifting home to school journeys to more
sustainable transport modes, improving the quality of school bus
provision, reducing the number of accidents and the number of
children killed or seriously injured on journeys to and from school.
Success should not be reducing the school transport budget.
Overall, success needs to be tightly defined
because the draft Bill could reduce the number of car trips, but
overall private car mileage could increase (with much fewer short
trips, but an increase in long trips with the removal of free
entitlement).
Q20. Any further comments?
A20. Paragraph 33 of the Draft Bill and
Prospectus states that "All fare income must be invested
in improved services". This should explicitly state "All
fare income should be ringfenced for improved school transport
services".
April 2004
| 
