APPENDIX 16
Memorandum submitted by Bus Users UK in
Wales
The Committee is asked to note that these comments
reflect the views of Bus Users UK in Wales whose activity is funded
exclusively by the Welsh Assembly Government. We believe that
the situation in Wales differs in key ways from that of England.
With the exception of Cardiff it has no significant urban conurbations
such as West Yorkshire, Greater Manchester or West Midlands. Much
of it is basically provincial, much of it very rural. It is a
readily identifiable region in its own right. We believe that
a common approach to the provision of public transport in Wales
will have significant benefits.
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?
It is true to say that many bus services in
Wales are better in terms of frequency, quality and meeting passenger
needs. We do not believe that this is a product of deregulation
but rather a product of significantly increased demand resulting
from the All-Wales concessionary fare scheme. However, the increase
in passenger journeys should be seen in the context of a decrease
in bus miles operated over a similar period. This suggests a concentration
by operators on core routes where passenger numbers can be maximised.
This in turn can be seen as the effect of the need to generate
profit and is especially true in areas where there is a dominance
of major plc subsidiaries. It is less true in the two major urban
areas where bus services are provided in the main by local authority
owned operators (Cardiff and Newport)and where the shareholder
is the local authority and the drive is as much for social reasons
as for shareholder profit. Even so there is a difference in focus
in these two areas which results from the differing political
agendas in the two authorities.
There is little in the way of proper integration
(ie buses and trains that meet at convenient locations and widely
available and easy to use inter-availability of ticketing) between
modes at an all-Wales level although there are examples to be
found such as PlusBus. Often this lack of integration is a result
of geographical/historic factors exacerbated by traffic congestion.
For example the location of the Swansea rail station on the eastern
edge of the town and 1 mile from the central bus station dictates
that buses from the west side of the city (which because of its
social mix produces the greatest number of rail passengers) do
not serve the rail station simply because the cross city operation
becomes unreliable. Another example is an area-wide ticket available
on bus and train and which can be purchased on buses and trains
but is only available on services operated by First group subsidiaries.
This reduces the potential use of what otherwise would be a very
attractive ticket. OFT is cited as being a further deterrent to
integration of tickets and services but it is also an understandable
desire to "protect" revenue and avoid the costs of any
revenue apportionment exercise. A clear indication of this is
the Network Rider ticket which has been available across south
east Wales for many years. It is a daily ticket which is bought
on any one of the buses of about five operators and available
for use on any of the participating operators' routes. The revenue
stays with the operator that sells the ticket. A weekly version
is also available but is not widely inter-available simply because
there is the potential for one operator to sell a fairly expensive
ticket and keep the revenue when the majority of journeys might
be made with other operators and for which they receive no payment.
This is a regular cause of complaint, is irksome for users and
a deterrent for potential users.
Buses are clean or dirty depending on the commitment
of the operator to invest in such and there are cases of appalling
standards of cleanliness as well as good standards. A "post
code lottery" tends to work. Similarly, whilst we have noted
individual operators working hard to deal with the effects of
anti-social behaviour we are surprised that there is little in
the way of collective working by operators on this problem. Indeed
it has been Bus Users UK in Wales that has facilitated an all-Wales
free travel scheme for uniformed police officers and which is
pursuing a regional or national approach to incident reporting.
We see this as both a cultural and a cost issue amongst operators.
We see that deregulation is a factor in limiting the provision
of more frequent and better bus services in areas and at times
where the market is not readily identified or where it might need
to be developed over a time.
The major problems that deregulation and associated
privatisation have caused lie in the failure of the principle
and the process to take account of the nature of business to become
dominant and pay insufficient attention to the quality of service
provision. In theory, competition should be a spur to provision
of better services but we see little evidence of this. Instead
it has created several unhelpful effects:
— The creation of monopoly by major
plc subsidiaries with an obvious focus on maximising profit at
the expense of social considerations.
— The ability for small, low cost,
poor quality operators to undermine networks or individual services
by "cherry picking".
— Conversely, the lack of competition
between larger operators on lucrative routes suggests a desire
to maintain the status quo since the damaging cost implications
of competition are well known.
— The constant tinkering with timetables
and routes in order to save costs more than seeking to meet demand.
This leads to network and service instability.
— The reduction in the number of bus
operators leading to difficulties in the tendering process for
local authorities.
It is stressed that Bus Users UK has no particular
issues with private enterprise other than when the focus is on
shareholder needs at the expense of users' needs.
Is statutory regulation compromising the provision
of high quality bus services?
Such regulation as exists through the office
of the Traffic Commissioner and through the various transport
acts has not always been helpful in raising quality standards.
Access to the industry is still seen as too easy and there are
examples in Wales where operators are not well managed and have
insufficient regard for the needs of users. There are examples
of drivers unable to speak English, having insufficient training
to know a route, who smoke at the wheel, buses that are dirty.
Difficulty in recruitment and retention of staff of a calibre
to meet passenger needs is well known and believed to be a factor
in raising service standards although, again there are examples
of good practice reducing this problem. It is interesting to note
that Cardiff Bus (Local Authority owned) is one of the very few
(possibly the only) bus operator in the UK to have secured Investors
in People accreditation.
We note the provision contained with the Transport
(Wales) Act 2006 that will enable the Welsh Assembly Government
to establish an effective and representative public transport
users committee. This is to be welcomed and will be useful in
identifying areas for improvement and assisting in better regulation
of bus services (and rail).
Are priority measures having a beneficial effect?
What is best practice?
Implementation of bus priority (and other traffic
restraint) measures continues to be a slow process and it is difficult
to cite examples of best practice. It is hoped that the quite
extensive bus lane network approaching completion in Swansea may
become an example of best practice in Wales. Such measures are,
however, not widespread. Elsewhere the consultation process to
implement has shown considerable public resistance to bus lanes
where they might lead to loss of private car parking space (eg
Cardiff). In the less urban areas of Wales, car use remains unbridled
with all the attendant problems inherent in that for the provision
of reliable bus services. Notable examples are Aberystwyth and
Welshpool but in essence they are only typical.
We believe that local authorities are not adequately
dealing with the provision of bus priority measures, that the
costs of delays caused by traffic congestion are borne by bus
users and that the problem lies at the heart of the difficulty
that operators having in providing reliable services. If this
matter is not dealt with at UK (or possibly at Wales) national
level then the issue of deregulation becomes entirely secondary.
Traffic congestion is the biggest single factor in preventing
buses being reliable.
Is financing and funding for local community services
sufficient and targeted in the right way?
It is not entirely clear what is meant here
but has been taken to mean bus services at a community level and
including "traditional community transport".
It is difficult to know accurately if funding
is sufficient and targeted. At our bus user surgeries we are often
swamped with complaints that certain areas have no public transport
and this especially in evenings and on Sundays, times when demand
is insufficient to be of interest to a commercial operator. This
suggests that there may be no funding to provide a service. And
yet we also frequently see services running with no passengers
or with very low numbers and that suggests a lack of "market
awareness" or lack of proper targeting of funds on the part
of funding bodies (normally local authorities).
We are aware too that community transport groups
often have under utilised resources and yet are reluctant or unwilling
to venture into a more commercial regime under which they might
provide cost effective, well targeted local services on a tendered
basis. These might be DRT schemes which provide links not only
to important locations but also to longer distance services on
the bus and rail network.
Outstanding examples of an entrepreneurial approach
with a social conscience have appeared in some of the London CT
organisations which are now securing funding for their social
activities through the operation of contracts for bus services
in London and recently in West Yorkshire.
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 60s 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?
Comment here applies only to the Welsh scheme
which has, as is well known, been successful and instrumental
in growing the market for bus travel. We have identified minor
problems with the reimbursement arrangements which are based on
local fares and where it has been insufficient for longer journeys.
Examples have been on some commercial services in South Wales
where, although passenger numbers have been high, revenue including
the reimbursement in respect of concessionary journeys has been
insufficient to sustain the service. We are of the view that the
formula used for reimbursement is nevertheless appropriate and
flexible enough to deal with such problems if local authorities
are willing to look at variations to the formula where such problems
arise.
We believe that there is a need to research
any links that might now exist between improvements in health
and wellbeing and the access to free travel. We believe such links
exist.
We would endorse any move towards a UK national
scheme that provides discounted or free travel on all modes although
accept the complications that might arise purely from the geographical
size of England compared to the relatively small and self contained
nature of Wales. The potential to aggravate peak time capacity
problems must be borne in mind and there may be places where there
need to be time restrictions. However, any scheme which includes
rail should take account that there is considerable potential
to abstract revenue from bus services which would have unwanted
effects on their long term viability. Free travel provides what
is, in effect, a market using public money. Therefore under the
current deregulated regime the market could precipitate a decline
in bus use. Issues of overcrowding on the rail network should
not be ignored.
Why are there no Quality Contracts?
It is unclear why this should be so. The belief
is that the process is seen as too long winded, particularly so
in Wales. Local Authority staff resources are known to be severely
stretched in many cases. Whilst the theory is probably felt to
be laudable it is likely that the generally held view is probably
that things are not so bad that we need to use scarce resources
developing Quality Contracts when the outcome may be unclear.
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?
The powers of the Commissioner are relevant
but felt to be insufficient. Supported by three monitoring officers
of which two are directly funded by the Welsh Assembly Government
the Commissioner has been successful in dealing with some of the
worst excesses of poor quality operators and Bus Users UK in Wales
enjoys a part in that process through regular liaison with the
Commissioner's office. It is clear however that, since two-thirds
of the compliement of monitoring officers are externally funded,
without this the Commissioner would have severely limited resources.
We believe that within the constraints of the legislation the
Commissioner provides a good service and makes good use of what
are felt to be insufficient resources. There are concerns about
the length of time that it can take to bring operators to heel.
Further, there are no mechanisms available which prevent a discredited
operator from starting a new business with the same poor quality
standards of management and operation that may have caused them
to become discredited in the first place. We have seen several
examples of this. There is no legislation under the jurisdiction
of the Commissioner or elsewhere that covers matters that are
of regular concern to users such as:
— the need to adequately warn users
of pending changes to services or fare increases;
— the need to properly justify fare
increases;
— the need to properly and effectively
provide timetables; and
— the need for a proper system that
reports on reliability and performance in a way that is helpful
to users and meaningful.
Matters of major concern to users such as buses
failing to turn up are only dealt with through the legislative
process after lengthy evidence gathering and a tortuous legal
process. We accept the need of an operator to defend its position
and understand that there are occasions when non-operation or
late operation may be beyond its control. However, we still see
too many occasions when such problems go unnoticed and that the
operator is fairly secure in the knowledge that it will not be
held to account.
Taking account of the fact that many problems
for bus operators (and therefore for users) result from traffic
congestion and lack of traffic restraint measures we believe that
the Commissioner should have a greater input into the various
processes which control these matters.
The powers are relevant. They are not wide ranging
enough and lack sufficient "teeth" to ensure operators
provide what users want and need but this is true only within
a deregulated regime. Under a more regulated regime such as a
franchise the regulation would flow from the contractual and organisational
arrangements and would be more direct, swifter and more appropriate,
eg penalties for non operation or dirty buses, more effective
promotion of services etc.
Is London a sound model for the rest of the UK?
Bus Users UK in Wales sees no reason (other
than the obvious legislative difficulties) why network or area
franchising arrangements cannot provide a better service, one
that is network wide and which can through contractual arrangements
ensure that service delivery in all aspects is to a high standard.
Competition between operators would be for the franchise and not
with each other. Common standards can be set and maintained. The
franchising authority would need to show entrepreneurial flare
and be able to react to market demand and satisfy social need.
It should be dynamic and not unnecessarily bureaucratic. Such
an arrangement should be able to combine the appropriate mix of
market understanding and social awareness. Nevertheless success
in London is as much a function of demand management, traffic
restraint and significant funding as it is a function of there
being a regulated regime. Ultimately, as far as integration and
network stability is concerned the London model of regulation
in itself is not a predicate of better bus services.
A very clear example of how the free market
has been unhelpful to bus users is the introduction of new high
floor coach type vehicles by First on local bus routes. The new
vehicles are fully DDA compliant but have replaced slightly older
low floor buses (also of course fully DDA complaint). The operator
is perfectly entitled to do this. It has been a cause of serious
complaint amongst people (who now have to board the bus by the
steps into the saloon) who may be elderly and slightly infirm
or who have buggies which now have to be folded and the child
carried under one arm.
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?
Bus Users UK in Wales fully endorses the principle
that "we cannot be in the business of carting fresh air around
the country" and this is equally true of buses. We are of
the view that a regulated environment such as a franchise in which
the worst excesses of the free market can be tamed, can boost
passenger numbers. This could be either on an all-Wales basis
or on a regional basis. Metropolitan areas should not be the exclusive
preserve of such a regime. Indeed it is often the more rural and
provincial parts of Wales that suffer the most from instability
of services, poor promotion of them by local authorities, poor
quality of service, lack of evening and Sunday services.
Does the bus have a future? It is necessary
here to have some sort of vision of what is meant by "the
bus". The vision of Bus Users UK in Wales is for the bus
to be the first choice of travel because it is easy to use, attractive
to travel on, offers value for money and is reliably available
for a majority of journeys.
If that vision is accepted then the answer is,
yes it has a future if effective measures are put in place to:
— Prevent land use that takes no account
of public transport provision and only generates further traffic
congestion.
— Ensure that long term funding is
in place to support public transport schemes that may take time
to become viable.
— Tame the excesses of the free market
as they impact on the provision of bus services.
If these measure are not put in place the answer
is no, there is no future.
23 May 2006
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