APPENDIX 4
Memorandum submitted by the North West
Public Transport Users Forum
Has deregulation worked? Are services better,
more frequent, meeting passenger need? Are bus services sufficiently
co-ordinated with other forms of public transport; are buses clean,
safe, efficient? If not, can deregulation be made to work? How?
In the densely populated city areas, there have
been many examples of an increased service level and also improvements
in the standards of the vehicles operating these services. Unfortunately,
these increased services have been confined to routes and times
which are easy to operate and only serve the needs of passengers
requiring simple end to end journeys. Even these improvements
have only met passengers' needs when the operational needs of
the operators have been met. This has given rise to very few early
morning and late night buses, plus many services ceasing to operate
after about 1800.
In fact, since 1986 there has been a 30% reduction
in bus patronage together with a 30% increase in bus mileage and
a 30% increase, in real terms, in bus fares. Whilst increased
mileage can partly be accounted for by the substitution of more
frequent, but also more unreliable, services provided by smaller
buses it is mainly the result of excessive wasteful competition.
Government subsidy to bus services is now greater, in real terms,
than it was in 1986. Operatives wages have also fallen in real
terms, and there is now a national PCV driver shortage which often
translate to unreliable services. Overall, it has to be said,
deregulation has not been a success.
Co-ordination with other modes of public transport
is extremely difficult, if not impossible, due to:
— Deregulated bus services being brought
within the scope of competition law which makes any agreements
constraining operator's rights to compete (such as common fares
and timetables) "anti competitive" and thus illegal.
Even in areas where the same operating group provides the bus
and rail services these are rarely co-ordinated.
— Deregulated commercial registered
local bus services operate within networks of bus services which
include tendered services regulated by local transport authorities.
These authorities can only specify fares or timetables on their
supported services and have no influence over how the commercial
operators might make (or not) "connections" or provide
(or not) through or interavailable ticketing.
— Taxis and other small passenger carrying
vehicles are licenced by local authorities and, with a few little
used legislative exemptions, denied the opportunity of providing
services at separate fares at times when, or in areas where, demand
is low.
— The perception that bus operators
do not see co-ordination being required either with other forms
of public transport or other bus services.
There has been significant investment in the
last five years in new buses by the large operating groups now
that they are effectively an oligopoly with local monopolies.
Most modern buses are clean, safe, efficient and provide a good
standard of service. In contrast, there are still many older vehicles
being used which are not suitable for the purpose. These are not
only operated by the smaller local companies, but also by some
of the large national groups.
Full deregulation does not work. Some form of
intervention is always necessary to provide a fully integrated
network to fulfil the requirements of the population.
Transport is a public services as much as education
and health, and will always require subsidy, especially in rural
areas. Deregulation has not addressed this but might be helped
to do so in some cases if quality partnerships could be put on
a statutory basis which included co-ordination of fares and timetables.
This would however not address the problems
which exist over complete networks. There is recent evidence that
the big five oligopolies are resorting to tactically deregistering
services to force local transport authorities to put these out
to tender in the hopes of securing a subsidy to reinstate service
which were probably previously commercial. However, escalating
labour, fuel and insurance costs may also account for some deregistrations.
In summary there must be a minimum network specification
for an area, within which the commercial services will play their
part. These commercial operations will be supplemented by socially
necessary services, subsidised by the public purse. These secondary
services should be co-ordinated by a properly funded transport
body such as a PTE or Regional Transport Board. It should not
be left to the smaller authorities such as the Shire Counties
or Unitary Authorities which are unable to see the full network
implications of their actions within their small sphere of responsibility.
Is statutory regulation compromising the provision
of high quality bus services?
By definition there is no statutory regulation
where there is deregulation. Perhaps the question refers to other
statutes such as the Competition Act 1998 and the legislation
relating to taxis and private hire cars?
A major function of any regulated system would
have to be the specification of minimum standards for all aspects
of the services provided and these standards must be set at an
attainable high standard which are enforced.
Are priority measures having a beneficial effect?
What is best practice?
In a few cases, yes. Current provision is patchy
and inconsistent, with new schemes becoming more reliant on unproved,
unreliable and expensive technology. This is unnecessary, as there
are tried and trusted methods which can still be used safely with
confidence.
Local Transport Authorities, including Passenger
Transport Executives, are not Highway Authorities, and operators
complain, often with reason, that whilst they deliver their commitments
to quality partnerships, such as new low floor accessible vehicles
driven by drivers trained in customer care, bus lanes and other
bus priority schemes are too often incomplete and poorly, if at
all, enforced.
Best practice is where a holistic approach is
taken to include real time passenger information, bus shelters
with boarding platforms and continuous bus lanes or busways. Runcorn
Busway, pre 1986, was an exemplar, but must now be open to any
operator deciding to register a local service along it. One failing
with the Runcorn system was the poor maintenance regime which
led to poor road surfaces and severe vandalism problems with the
infrastructure.
Guided bus lanes have a limited local impact
and give a poor return for the high costs involved in their provision—the
special roadways and guidance equipment on buses. Ordinary bus
lanes, properly enforced, are superior in both cost and efficiency
and this is exemplified by the "Red Routes" in London.
Is financing and funding for local community services
sufficient and targeted in the right way?
Too much emphasis has been placed on "innovation"
and the provision of short-term funding. There is a great need
for planned investment and ongoing sufficient revenue support.
Too much money has been wasted by local authorities and other
bodies purely on the bidding process for the various funds, with
no guarantee of any return for this investment of time and money.
Funding is complex and irrational. Bus Service
Operator Grant is based on fuel consumption and thus roughly paid
on a per mile basis. Operators are re-imbursed for accepting concessionary
fares on a "revenue foregone" basis, but the new Senior
Citizen and Disabled Passenger free travel is funded on a demographic
basis which takes no account of the level of existing bus services
and their current use (or not) by concessionnaires. Rural Bus
Grant is based on rural populations and Rural Bus Challenge and
the Countryside Agency's Rural Transport Partnership funds are
now discontinued with the money passed via Defra to Regional Development
Agencies. These appear to have no countrywide policies as to how
(if at all) they intend to spend this money.
In no case is funding related to patronage.
Rural and community services will never be a
commercial proposition and will always need support. This needs
to be reflected in the way these services are funded, plus a constant
review of how they are meeting the needs of the passengers.
Concessionary fares—what are the problems
with the current approach? Does the Government's proposal to introduce
free local bus travel across the UK for disabled people and the
over 60's from 2008 stand up to scrutiny? Should there be a nationwide
version of London's Freedom Pass—giving free or discounted
travel on all forms of public transport?
The current scheme is a mess—some Counties
have co-ordinated very good county-wide schemes complete with
cross-boundary provision, whereas others have left it to the Districts
which have provided less than useful passes which only allow free
travel within that district and no cross-boundary provision. The
introduction of the UK free travel passes in 2008 should remove
these problems and stop the "us and them" feelings of
many people in the latter category. There must be close observation
of the Welsh and Scottish schemes and lessons must be learned
if there are any major problems revealed. Experience in Scotland
suggests that the extra cost of Countrywide travel will not be
as great as feared.
As noted above, the reimbursements based on
population are unfair and skewed towards rural areas where bus
mileage is low. However in these areas the concession is meaningless
to rural dwellers who have no accessible bus services.
Ideally free travel should be multi modal if
that were affordable. Certain areas already have schemes providing
free or reduced travel on other forms of transport, but these
are very local in nature, ranging from PTE areas such as Greater
Manchester providing free travel on buses, trams and trains to
Parish Councils subsidising the provision of Senior Citizens Railcards.
A national version of the Freedom Pass would remove the final
"us and them" anomalies mentioned above and give a standard
approach to the avoidance of social exclusion by transport provision.
Why are there no Quality Contracts?
The statutory procedures for instigating these
are seen by local transport authorities as highly constraining.
The time scale from making an order to inception is too long and
whilst it was intended to allow for established operators to relocate
if unable to participate in the contract, it also allows them
to hold authorities to ransom by tendering excessive prices and
if not successful withdrawing in the interim thus leaving a bus
service deficit.
The rule which requires that QCs should only
be introduced where the local transport authority can show they
are the only practical way to deliver their bus strategies is
also enormously unhelpful.
Authorities also fear that the net cost of service
subsidies and premiums over a network will exceed their existing
costs. The Passenger Transport Executives' support of QCs is noted,
and the result of the mock tendering exercise for a virtual QC
in South Yorkshire Passenger Transport Executive will be interesting,
especially as it is reported to have tempted some large non UK
operators familiar with such "franchises" in their own
countries.
Are the powers of the Traffic Commissioners relevant;
are they adequately deploying the powers and resources that they
currently have? Do they have enough support from Government and
local authorities?
They are relevant but the Traffic Commissioners
(TCs) are woefully under resourced. This has reduced their ability
to act in many cases. The awareness of the Traffic Commissioners
by anyone outside the industry is virtually nil and they make
no effort to make themselves known. Their publications and website
are full of legal jargon and are not meant to be easily understood
by the general public. Interaction with passengers or their representatives
is poor at best and non-existent in some areas.
They cannot be proactive in holding operators
to account for unreliability and unpunctuality, and instead rely
on passenger complaints to trigger calling operators to public
hearings. However, unlike in Scotland and (soon) in Wales. there
are no multi modal transport users' consultative committees in
England (outside London) to which bus passengers can complain.
Most passengers are also unaware of the non
statutory Bus Appeals Body operated by BUUK and the CPT. Where
the TCs are effective is in enforcing the safety component of
quality licencing via the PSV Operator Licences they issue and
the safety checks made on their behalf by VOSA
The Government needs to push their existence
into the public domain and provide sufficient funds for them to
be readily accessible. The TCs should be more pro-active in helping
local authorities to oversee local bus operations.
Is London a sound model for the rest of the UK?
London is not so different to many Passenger
Transport Executives or other large conurbations as is often claimed,
and it would be reasonable to expect that these could generate
additional bus patronage given the same franchising powers and
funding as London, especially if the Passenger Transport Executive
or Authority were also the Highway Authority.
What is the future for the bus? Should metropolitan
areas outside London be able to develop their own form of regulated
competition? Would this boost passenger numbers? If not, what
would? Does the bus have a future? In addressing rural railways,
the Secretary of State has said that we "cannot be in the
business of carting fresh air around the country"; is the
same true for buses?
Without drastic government action bus patronage
will continue to decline. Government targets may well continue
to be met in the short-term, but only with the contribution made
by the growth in bus patronage in London.
Conurbations should be able to regulate the
provision of bus (and rail) services within, to and through their
areas. The metropolitan areas should be allowed to operate as
above, which combined with the provision of integrated ticketing
systems will lead to an increase in passenger numbers.
In rural areas there is a desperate need for
core revenue funding for a minimum level network of accessible
bus services, although there should also be consideration of feeding
this with unconventional and demand responsive services, such
as those provided by small passenger carrying vehicles, community
minibuses and taxis.
It is true that sudden injections of funding,
such as Rural Bus Grant, or concessionary fares reimbursements,
can result in unjustifiable support being given to "innovative"
services which end up "carrying fresh air". However,
new services do take time to be noticed, understood and used and
should not be arbitrarily withdrawn before they "bed in".
The use of DfT accessibility planning software should prevent
too many unsuitable services being tried initially and transport
provision should be tailored to the requirements of the area.
It would be ridiculous to send a double-deck bus to serve small
villages with just a handful of passengers, just as it would be
to send an 18 seater mini-bus to serve a large town on market
day!
19 May 2006
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