Memorandum submitted by The Public Transport
Consortium (ST 8)
1. LOCAL AUTHORITY
RESPONSIBILITIES
1.1 The Public Transport Consortium is a
Special Interest Group of the Local Government Association for
local authorities outside the metropolitan areas with a particular
interest in public transport. The majority of County Councils
in England are in membership, together with a number of unitary
Councils in both England and Wales. All members have responsibility
for the provision of both socially necessary local bus services
and home to school transport.
1.2 These duties come together in the provision
of school transport. This is a two-fold responsibility—as
LEAs they are required to provide statutorily free school transport
for those children living beyond prescribed walking distances
or whose routes between home and school are hazardous. As Transport
Co-ordinating Authorities they must consider and fulfil as deemed
appropriate the public transport needs of those who do not qualify
for free transport to school. In many authorities the Transport
Co-ordination Unit undertakes both these two functions.
1.3 The situation is significantly different
in metropolitan areas, where the average home to school distances
are much lower, and local bus networks are more intense. Also
particular circumstances apply in some shire areas because of
historic situations or quirks in the nature of local bus networks
(eg the Isle of Wight).
2. PREVAILING
VIEW OF
AUTHORITIES
2.1 Given that the legislative requirements
around school transport date back to the Education Act 1944 while
matters of local bus operation are largely governed by the Transport
Act 1985, there is long standing experience of the difficulties
which surround school transport provision.
2.2 The Consortium therefore welcomes the
considerable progress that has been made recently by the Department
for Education and Skills (DfES) and the Department for Transport
(DfT) in addressing the Travel to School issue, and is encouraged
by the publication of the Draft Bill and Prospectus.
2.3 Broadly, Member Authorities consider
that there are four main areas to be addressed in modernising
the approach to travel to school, and these are discussed in turn.
Congestion, sustainability and health
2.4 A considerable proportion of children
today are taken to school by car, and as a result volumes of cars
setting-down and picking up children at schools are the cause
of congestion and, in many cases, hazards in the vicinity of the
school gate. Furthermore, it is self evident that the "school
run" is a significant cause of general peak period congestion
in towns, suburbs and villages throughout the country, witnessed
by the significantly lower volumes of peak period traffic during
school holidays. This is working against wishes to introduce greater
sustainability into local travel, and it is recognised that children
carried by car are missing the health benefits of cycling or walking
(at least to bus pick-up points) on their way to school.
School bus costs
2.5 LEAs spend substantial sums on the procurement
of statutory free school transport. This is largely in the form
of contract bus services, though passes are also purchased for
use on commercial and supported local bus services. Furthermore,
supported local bus services are extensively provided for the
journey to school for fare paying pupils. (A typical county may
allocate about half of its total expenditure on local bus support
to services that are essentially for the journey to school).
2.6 The costs to local authorities of contracted
bus services for school and local bus services are generally rising
at rates considerably in excess of the rate of inflation. Nationally
the average rate of increase is 12% (school bus) and 15% (local
bus), though in some areas average increases can be as much as
40% year on year.
2.7 This is placing excessive pressures
on local authority budgets, and, while free school transport levels
must be maintained, supported local bus networks are as a result
contracting.
School bus quality and safety
2.8 With some exceptions, school transport
is provided by fleets of older vehicles. Typically a three or
five year contract for school transport will be operated by a
vehicle towards the end of its life, idle or available for maintenance
between school peaks, and less prone to high costs of repair in
the event of vandalism.
2.9 Even so, many bus operators are unenthusiastic
about school transport operation, which is reflected in the level
of bids for these contracts.
2.10 Quality standards of school buses can
therefore be low, though even the oldest buses must meet rigorous
licensing and inspection procedures. Older, poorer quality buses
are less popular with schools, parents and pupils, whilst newer
buses are regarded as more reliable, safer and environmentally
friendlier. They are more likely to prompt better behaviour from
travelling pupils, and engender a better image of the bus for
new generations of potential public transport users.
2.11 In some cases, local authorities have
taken positive steps to introduce better standards of quality
for school buses. This can be achieved by specifying maximum bus
age in contracts or by specifying, or purchasing and operating,
purpose built school buses (commonly the US style "Yellow
Bus"). However, a new bus can typically cost £120,000,
whilst a 20 year old bus may be available at around 5% of this
cost, so that the cost of improving bus quality is high, especially
when considered in the context of the financial pressures described
in paragraphs 2.5-2.7 above.
Equity
2.12 The present rules for the provision
of free transport to school are anachronistic and grossly inequitable.
In a typical County perhaps 15-20% of the total school population
is eligible for free transport, while others using public transport
pay the commercial fare. Hence, the child living 3.01 miles from
school get entirely free transport, whilst the pupil living 2.99
miles from the school gate must pay perhaps £2.50—£3.00
per day in bus fares. It is unrealistic to expect today's children
to walk up to six miles per day for the combined journey to and
from school.
2.13 For many years, it has been suggested
that the present statutory requirements for free school transport
be replaced by a modest flat bus fare (say £2.00 per day)
for all children whatever the distance to school, subject to adequate
provision to address hardship and the problems facing parents
with large families.
3. TAKING FORWARD
THE GOVERNMENT'S
PROPOSALS
3.1 The Consortium welcomes the proposals
in the Draft Bill to allow experimental action to improve school
transport in pilot areas. It is clear, however, that the range
of opportunities is large and the players (Government, Local Authorities,
Schools and Operators) must therefore be aware of this to understand
the scale of activity, organisational change and initial funding
that is required to ensure that the major benefits of the proposed
action might be achieved.
3.2 Although the proposals implicit in the
Bill seem to provide the opportunity for change to address the
problems set out in section 2 (above), they do pose a major change
to established patterns of behaviour, among schools, parents and
operators. The opposition to some of them amongst those with a
sectional interest may be considerable. Consequently it will be
important to develop the right political momentum, recognising
the benefits of a holistic approach to change. It is essential
for the generation of this political commitment that there is
early delivery of a substantial package of tangible and marketable
benefits in advance of, or alongside, the potentially unpopular
measures. Without this approach there is little chance that all
the players will be willing to proceed.
3.3 It also needs to be understood that
the use of any proposals merely as a cost cutting exercise for
the local authority is likely to stand almost no chance of proceeding.
Lessons from recent transport innovation (congestion charging
in London, speed cameras) show that change is only accepted when
the benefits are recycled for perceived related purposes.
4. FINANCIAL
IMPLICATIONS OF
PILOT WORK
4.1 A clear overall advantage of the proposed
new approach is the potential for significant financial gain,
which might be delivered to some of the key players:
— There is clearly scope to make significant
savings (probably between 10 and 20% of the current mainstream
school transport budget) from interactive staggering of school
hours, so that buses can be used for double journeys in the morning
and afternoon by serving two schools consecutively.
— A modest flat charge to those currently
receiving free transport would generate very worthwhile sums.
One member county calculates that a charge of only £1 per
day would generate some £2.7 million additional revenue.
This would be enough to pay for another 100 fare-paying school
buses—a 25% increase in the total of buses running at peak.
4.2 In addition, it appears that the Government
takes the view that a key source of finance to fund initiatives
will arise from better co-ordination of the transport within a
local authority's area of activity. Whilst savings can undoubtedly
be made in this way, experience from Cheshire, where a co-ordinated
approach has been progressively introduced over the last 20 years,
shows that that the organisational task of achieving this is complex.
It is also in the nature of such consolidations that each party
(eg a participating social services department) would want to
capture its own savings from the deal. Hence, over the proposed
timescale of a pilot initiative, progress towards integration,
whilst worthwhile in best value terms, is unlikely to deliver
major savings to the school travel scheme.
4.3 Thus, overall, considerable financial
benefits could be unlocked by a scheme. However the scale and
inter-relation of activity implied by this initiative, particularly
in the context of larger authorities, suggests that pump-priming
funding will be essential to gain local authority participation.
This is dealt with in section 8.
5. OPPORTUNITIES
PRESENTED BY
EXTRA FINANCE
5.1 The funds released by the action suggested
in 4.1 (above) could be used to provide a significant improvement
in the quality (2.8-2.11 above) and quantity of buses provided
for school transport. The opportunity thus becomes available to
initiate an on-going virtuous spiral whereby the image of the
bus, the attitude of the school and behaviour improvements can
all contribute to more effective use of the bus to offer a more
attractive option to greater numbers of pupils and parents. Furthermore,
insofar as the additional funds mean that it will no longer be
necessary to rely on the very poorest quality part of the market,
there should be an inherent increase in safety.
5.2 There is a need to recognise that the
funds released would provide a huge stimulus to the bus industry,
albeit for an activity which experience has shown is not necessarily
popular with big bus companies (2.9 above). Representations from
operators suggest that they need more stability and security of
operation to encourage them to invest in new vehicles and depot
modernisation and extensions. Fundamental to this is the willingness
of local authorities to commit to longer term contracts, given
that buses must be written off over a period of 12 to 15 years.
As some contracts would be of a local bus nature to permit individual
charging, it is essential that the pilot legislation brings relaxation
to the Transport Act (1985) tendering rules.
6. ENGAGING THE
SCHOOLS
6.1 The largest saving will depend on the
willingness of schools to stagger hours (4.1 above). Various consultants
have already demonstrated this potential in a number of areas
(eg Essex), but delivery has been frustrated by the reluctance
of schools to stagger.
6.2 The incentivisation of schools to shift
times is therefore crucial, but this runs contrary to the general
trend for greater autonomy to schools with less control by the
LEA. In this particular context, however, there is much to be
gained from a degree of direction. At the very least therefore
the Bill and Prospectus should be amended to give clear guidance
to schools on the value of co-operation in staggering of hours.
Consideration might be given to the allocation of a positive role
for transport to an individual on each school governing body.
There is certainly need for greater clarity on the responsibilities
of schools with respect to pupils on their way to and from school.
Recently sought counsel's opinion suggests that schools do have
certain responsibilities for transport events outside the school
gates.
6.3 In practice it will probably be necessary
to show schools that there are direct benefits to accrue to them
from action to initiate better use of school buses. It is possible
that with an effective partnership approach some more co-operative
schools will take the view that the promise of better quality
buses alone will be enough to persuade a school to shift hours.
However it must be recognised that bus users will still be minority
stakeholders in the schools' decisions. At the end of the day
it may be necessary to ensure that a significant part of the financial
benefits from time shifts be given to schools (to spend as they
will) if the desired better bus utilisation is to be achieved.
There is already a view in some quarters that school transport
is competing too heavily for other precious education resources,
and some share in the benefits for schools would help assuage
this.
7. CHARGING
7.1 It is necessary to return to this issue,
as it is one that is potentially controversial enough to jeopardise
the overall package of measures. As far as charging is concerned,
it will be necessary to have the benefits, in terms of better
quality buses or lower fares for those who presently pay, understood
and on the way to delivery before charging becomes acceptable.
Firstly, however, it is important to recognise that there will
be no compulsion on individual authorities to introduce charges,
and that some of the beneficial changes discussed in this paper
can be achieved without addressing the equity issue (2.12/2.13
above) through charging those currently eligible for free transport.
7.2 However the present inequity is a sufficient
issue for most members of the Consortium that it is considered
an important issue which should not be allowed to fall for reasons
of short term political expediency. This is all the more so when
it is recognised that research has shown that over 80% of households
in a typical shire county receiving free school transport have
incomes of over £30k, whilst for 50% it is more than £45k.
7.3 A modest charge of, say, £1 or
£2 per day should not be seen as an unreasonable amount.
At least one member authority has, in recent years introduced,
without difficulty, a daily charge in excess of £1 for over
16 year old pupils who previously had free transport, and similarly
a £2.50 a day charge to out of zone ineligible pupils. The
Bill requires that progress towards charging starts with extensive
consultation. It is perhaps valid to point out that those being
adversely affected are more likely to be vociferous than those
intended beneficiaries, who are harder to identify, and may not
yet have realised that they would indeed benefit.
7.4 An option would be to use the income
generated by introducing a modest charge to ameliorate the amount
paid by those who currently pay the commercial bus fare. The fare
cap at £1 or £2 per day could apply to all pupils. This
will require the setting up of a concessionary fare scheme, or
a multi-operator negotiated scheme. The former allows the operators
to dictate the level of recompense from authorities while the
latter may fall foul of Office of Fair Trading regulations and
sanctions on collusion. The pilot legislation should create the
freedom to devise, in partnership with bus operators, an effective
and fair concession fare scheme for this purpose without reference
to the OFT.
8. PHASED IMPLEMENTATION
8.1 The scale of the opportunity for major
benefits from the piloting of these proposed measures is equalled
by the scale of the effort to ensure effective implementation,
particularly as, to be effective, this should be integrated with
increasing effort on School Travel Plans and Safer Routes to School.
8.2 It will be difficult for a large county
to bring in a scheme comprehensively in one go. The work in rolling
out the extra transport provision to use the funds from staggering
of hours and/or charging will be enormous, even if the extra vehicles
were immediately available. For this reason, if charging is to
be accompanied by quality improvement, it may only be practical
to introduce charging on a phased area by area basis. The authority
will have to deal with the inequity of a partial charging regime,
as well as interface and selection criteria issues.
8.3 Furthermore, a charging regime is unlikely
to be introduced all at once, but, as has been past practice,
to each new cohort of scholars. Thus the income stream would take
five years to build up, whilst the additional bus transport has
largely to be provided all at once. (You cannot put half a bus
on because only the first year pupils are eligible). This demonstrates
a clear need for pump priming funding referred to 4.3 (above)—because
without this, the political acceptability referred to in 3.2 is
unlikely to be achieved, as the disaffected will outnumber the
beneficiaries.
8.4 Even with the best technical team and
the latest technology, the preparatory work will be at the best
speculative by the time the bid goes in, especially if it is on
a county scale. The potential for saving might have been identified
by then, but is unlikely to be clear enough to eliminate a significant
level of risk. Some flexibility on the financial assumptions must
be entertained and expected, otherwise there is the danger that
only very small scale bids for relatively limited and unadventurous
projects might emerge.
8.5 The pilot bid will have to be submitted
in parallel with the second five year LTP submission. This will
require close co-ordination by those submitting bids, since the
two interact, and there would be a different scenario if a bid
failed. If properly constructed, the existence of a pilot area
could help meet LTP objectives. Equally, a successful LTP programme
will help provide the means to carry out pilot area schemes, especially
in capital funding of safe walking routes, new buses etc which
will be part of the measures needed to encourage participation
by partners and stakeholders. It will be very important for the
DfES and the DfT to co-ordinate activity on these two major activities.
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