APPENDIX 21
Memorandum submitted by CEPOG
1. SUMMARY
1.1 CEPOG is the West Midlands Local Authorities'
Chief Engineers & Planning Officers Group, responsible for
advising the West Midlands Joint Planning and Transportation Sub-Committee
on strategic transportation and planning issues.
1.2 In particular, CEPOG is responsible
for the LTP2, its programmes, targets and delivery. Since buses
are at the heart of our LTP2 strategy, we welcome this opportunity
to share our experience and views on the importance of delivering
quality bus services that can and must contribute to our overall
transport strategy. Bus services contribute to both tackling congestion
and improving accessibility, particularly for socially-excluded
groups. The ability of deregulated services to contribute to both
these policy areas will be critical to the overall success of
our LTP2, the successful regeneration of the Metropolitan Area
and maintaining its contribution to the national economy.
1.3 This submission focuses on the key ways
that buses can successfully contribute to our transport strategy.
Issues linked to detailed operational matters will be covered
in the submission by Centro, the West Midlands Metropolitan Area's
PTE.
1.4 The West Midlands Metropolitan Area
has the highest level of bus use outside London, both in absolute
numbers (315 million passenger trips per annum in 2004-05) and
in terms of trips per head of population. Buses account for 90%
of public transport journeys in our Area and bus services are
vital for a significant proportion of our population who do not
have access to a car or who cannot drive.
1.5 Whilst not directly responsible for
the co-ordination of local bus services, the seven Metropolitan
Councils fund these activities through their support for the Passenger
Transport Authority and Executive (Centro). The value-for-money
of this support and its effectiveness and contribution towards
LTP2 targets is extremely important. Our 2005-11 Bus Strategy,
which accompanies the LTP2, provides a detailed framework for
improving bus services in our Area.
2. ARE DEREGULATED
BUS SERVICES
HELPING DELIVER
LTP2 OBJECTIVES?
Deregulation, Competition, Co-ordination and Integration
2.1 The 1985 Transport Act was designed
to increase competition in the bus market through deregulation
and privatisation. Whilst the break-up and sell-off of National
Bus Company operators, which some saw as state-owned monopolies,
initially created smaller individual companies with greater potential
to compete with each other, business mergers and takeovers have
given us a virtual private-sector monopoly with one company, Travel
West Midlands, accounting for approximately 81% of bus operations
in our Area. Thus the delivery of bus-related LTP2 targets is
strongly influenced by the business decisions of this company.
2.2 There have been benefits arising from
the 1985 Transport Act; low-floor buses, better frequencies and,
in some places, more customer-orientated routes. However, it is
a mixed picture. Some of the increased frequencies are due to
on-road competition for passengers. This can lead to an excessive
number of buses in key locations with individual competing timetables
that do very little for customers. This increases congestion,
or at least the perception of congestion, in key locations at
popular times. It also equates to poor use of overall resources.
2.3 Although in many places there are higher
service frequencies, actual delivery in accordance with registered
timetables is poor. Punctuality in 2004-05, as reported in our
LTP2, was below 60% within the Traffic Commissioner's "window"
of no more than one minute early and five minutes late. Our LTP2
target, in line with Government expectations, is to see operators
achieve punctuality levels of 83% by 2010-11 and 90% by 2012-13.
This will be extremely challenging.
2.4 There are opportunities for better integration
between buses and our Midland Metro and local rail network. It
is pertinent to note that National Express Group own Central Trains,
which provide all the stopping services within our Area, the Midland
Metro, which operates through the Black Country between Birmingham
and Wolverhampton, and Travel West Midlands, the dominant provider
of local bus services (with approximately 80% of the local bus
market). If integration could work under the current deregulated
system, it should have happened in the West Midlands Metropolitan
Area, but the system is not "joined-up".
2.5 The way services are currently delivered
acts against integration. There is not co-ordination of services
providing the quality, frequency and value-for-money that would
persuade motorists to leave their cars at home for many journeys.
This mitigates against attempts to tackle congestion and it adversely
affects our achievement of social inclusion objectives as multi-mode
public transport journeys are more difficult than they would be
with better integration. This has an impact on local businesses
in some parts of our Area where people without access to a car
either cannot take job opportunities or are not reliable time-keepers
because of difficult bus journeys. This is an adverse factor in
the regeneration of our Area and its contribution to national
productivity.
Service Standards
2.6 The current deregulated situation does
not appear directly to compromise the provision of high quality
local bus services where operators choose to provide them. However,
the regulations for entry into the local bus service market appear
to be too low and monitoring of standards is poor. This allows
low quality services to operate in direct competition with better
quality operators. The size and captive nature (through low car
ownership levels) of much of the Metropolitan Area's bus market
is such that competition has not necessarily led to higher standards.
It is not uncommon to find buses that are dirty inside. Altogether,
there is not a perception of local bus services being a quality
alternative to travel by car. Unfortunately, there is a perception
of services being operated for the benefit of the private companies
rather than to meet customer needs.
2.7 Perceptions of personal security and
actual crime at or close to bus stops or in bus stations are a
Local Indicator Target in our LTP2. Centro have set up a Safer
Travel Police Support Unit with Community Support Officers who
give a uniformed presence on parts of the bus network in order
to increase passenger confidence that bus travel is safe. This
is supported by ad-hoc high-profile initiatives involving Police
Officers and "sniffer" dogs alongside Community Support
Officers, working in partnership with operators' revenue protection
staff.
2.8 Actual crime has declined in recent
years with a 17% drop between 2003-04 and 2004-05. However, this
was accompanied by a 4½% increase in people's lack of satisfaction
with security. This perception, of course, affects actual bus
patronage.
2.9 Some off-peak services can become the
subject of a cycle of decline. Services carrying limited numbers
of passengers, including early morning and later evening services,
are particularly vulnerable to frequency reductions to maximise
vehicle loadings and improve their commercial viability. This
often means that the service is less attractive to users who then
choose to use other modes or not travel at all. If patronage continues
to fall, such off-peak services are likely to be withdrawn and
only retained if Centro can afford to support them. With increasingly
widening trading, working and leisure hours, this situation is
incompatible with our accessibility objectives, particularly access
to jobs outside normal working hours.
Delivery of LTP2 Targets
2.10 Our view of whether or not deregulation
has worked is based on today's context of buses being at the heart
of our transport strategy. The role of Centro since deregulation
has been to react to market failures, principally by seeking to
secure socially necessary services not provided by the privatised
bus companies. Today, we must focus on meeting our bus-related
targets in our joint LTP2. Delivering better accessibility in
a deregulated environment, especially for those who do not have
access to a car, is likely to require increased revenue expenditure
on socially necessary services.
2.11 We aim to reverse the decline in bus
patronage from its 2003-04 baseline, 325 million trips per annum,
by 9% to 355 million by 2010-11. This is an extremely ambitious
and aspirational target in today's deregulated situation. We have
a strategy but the risks to achievement are great with many of
the key factors being outside our control. Above-inflation fares
increases, especially when the real cost of motoring is falling,
leads to passenger losses. Failure to provide quality services
that are punctual, reliable and clean will deter existing and
new passengers, as recognised by Government—"the public
need to see clear evidence of reliable and efficient services
in their neighbourhood".1
2.12 Neither Centro, nor the Metropolitan
Councils, have the means to influence these important LTP2 targets,
except at the margins. This is regrettable since failure to meet
them can adversely affect assessment of our Annual Progress (Delivery)
Reports with significant consequent financial penalties.
2.13 Very simply, poor bus service delivery
is outside our control but it adversely affects the finances with
which we seek to deliver improvement across all modes, including
buses, in pursuance of our LTP2 objectives and targets.
2.14 Issues such as bus service routes,
frequencies, reliability and hours of operation, co-ordination
of services with each other and other modes for interchange purposes,
integration of ticketing and fares and quality and cleanliness
of vehicles are key factors influencing people's choices about
bus use. Making deregulation work, without the ability of the
local authorities to have a strong influence on all these aspects
of service provision requires voluntary action by the operators
to enter into partnerships. However, we are not convinced that
the longer-term strategic view set out in our LTP2 sits happily
with the more immediate business concerns of the bus companies.
2.15 The former Secretary of State stated
that "decisions on road, rail, bus and tram need to be looked
at together by the same people, so that they can make sensible
choices and decide on their priorties".2 We agree with this
on the basis that it includes all aspects of quality bus service
delivery.
3. RESOURCES
3.1 The current revenue resources generally
provide for a "safety net" to secure socially necessary
services, as per the provisions of the 1985 Transport Act. In
the current deregulated environment, increased resources are needed
to secure supported services, alongside commercially-provided
services, linked with bus-related LTP2 targets, including those
relating to reducing congestion and improving accessibility. Such
resources would also need to be adequate to secure quality rather
than "safety net" services.
3.2 If the provision of additional services
was done without working in partnership with the relevant operator(s),
there would be difficulties if public-sector supported services
were seen to be undermining the viability of commercially-provided
services. It would be extremely difficult, probably impossible,
to achieve. The obvious solution is to work in partnership with
the relevant operator(s), but the current legislative framework
specifically excludes fares and frequencies from such partnerships
and we believe these factors to be vital in the delivery of our
LTP2 patronage target, as well as being important in terms of
accessibility.
3.3 The other option is greater public control
or statutory influence over operational issues, including fares,
frequencies and quality standards. Allowing Centro greater control
over bus operations would mean that delivery of quality services
would be within a framework that would be accountable to the local
authorities that are accountable for LTP2 targets rather than
shareholders and the stock market.
4. THE ROLE
OF THE
TRAFFIC COMMISSIONER
4.1 We are concerned that the Traffic Commissioner
does not have adequate resources to "police" local bus
service operations. Operators are answerable to him for non-compliance
with the details of their registered services and yet there is
only one Compliance Officer for the whole West Midlands region.
It is not difficult to understand why the public believe that
operators are able to be a law unto themselves with regard to
how they deliver their timetabled services. Such poor public perception
damages the image of buses as an alternative to travel by car.
5. BUS PRIORITY
MEASURES AND
BUS STOP
INFRASTRUCTURE
5.1 Bus priority measures are often key
factors in delivering the enhanced bus services that will contribute
towards LTP2 targets. However, it can be difficult for Ward Councillors
to support strategic needs that may have detrimental local impacts
especially when there is no certainty that the outcome will be
beneficial for significant numbers of local people. This situation
is not helped by the fact that service frequencies and fares can
change at anytime and are important factors in improving patronage.
5.2 Similar considerations arise with regard
to public investment in quality bus stop infrastructure. Commercially-provided
services can be withdrawn or altered with little or no consultation,
even after close partnership working. Not only does this mean
abortive investment by the Authorities, but also it reinforces
the poor public perception of the provision of local bus services.
5.3 We are concerned about the delay introducing
camera enforcement of bus lane violations, exacerbated now by
the type-approval process.
6. CONCESSIONARY
FARES
6.1 Residents of our Area aged over 65 and
those with specific disabilities already had free travel on bus,
Midland Metro and rail services. This was extended to people aged
over 60 in 2005, in advance of the Government's deadline, although
it has not been possible to extend this to before 09:30 due to
capacity and funding constraints.
6.2 We welcome the Government's proposal
to introduce free travel anywhere in the UK. In the local context,
it will allow our residents access to surrounding (rural) areas,
both for recreation and family visits, thereby enhancing their
quality of life. More cross-boundary journeys by bus will also
make a minor contribution towards reducing congestion within our
Area.
6.3 There is a strong case for having concessionary
fares for other groups of people, including job seekers, younger
people and scholars. This would help reduce the school journey
by car and, during immediate post-school or college years, provide
affordable accessibility to jobs as well as establishing an understanding
of how local bus services work. This could build on successful
TravelWise initiatives, such as Workwise, piloted in the West
Midlands Metropolitan Area.
7. THE FUTURE
OF THE
BUS IN
THE WEST
MIDLANDS
7.1 We must be optimistic about the future
of local bus services in the West Midlands Metropolitan Area because
they are central to our strategy to tackle congestion. Local rail
and tram services are vital, but it is only bus-based services
that can penetrate all parts of our Area, thereby providing people
with the ability to leave their cars at home either for whole
journeys or for journeys to interchange facilities.
7.2 Buses are also critical for delivering
improved accessibility across our Area, which includes a significant
rural area between Solihull and Coventry, but especially in the
deprived parts of the Metropolitan Area, where household car availability
is extremely low (up to 60% non-car availability).
7.3 The London model is one way of providing
local bus services that people will use within a framework of
public accountability. Patronage growth in London has been phenomenal
in recent years, although support for buses is approximately three
times greater in London than in PTE areas3. Similar powers and
funding would help achieve the quality bus services in our Area
that are needed to meet our patronage targets and other objectives.
7.4 As recognised by the former Secretary
of State for Transport, "passengers need to have confidence
in what the bus will offer. This means the adequacy of the whole
network—routes, frequency, fares, as well as the day-to-day
service of the bus company".
7.5 We also want to see more people using
buses as part of our contribution to the health agenda. Just the
walk to and from bus stops is healthier than always sitting in
a car.
8. CONCLUSION
8.1 Ministerial statements about the Transport
Innovation Fund have acknowledged the need to improve public transport
and that rail, light rail, buses and Park & Ride must work
together. In most cases, buses are expected to provide the alternative
to the car. There has been a clearly stated link between tackling
congestion through demand management measures and better bus services,
and reliable services, noting that the TIF "will have a positive
impact on how buses are run"4.
8.2 Delivery of our LTP2 depends heavily
on there being better bus services, better focussed on people's
needs within an overall strategic framework. Buses are central
to our congestion and accessibility strategies but most aspects
of service delivery are market-driven and the bus operators are
not responsible for achievement of LTP2 targets although they
control most of the inputs. Some business decisions act directly
against patronage targets, for example it is recognised that putting
up fares leads to some patronage loss. Private-sector business
decision-making is often seen as having shorter time horizons
than LTPs that plan for five-year periods and beyond.
8.3 Many elements of customer service are
outside the control of the Authorities and need to be tackled
in partnership with public transport operators. These include
cleanliness, customer care, enforcement of no-smoking regulations,
security and the image and attractiveness of public transport.
However, partnerships cannot include frequencies and fares and
some form of "regulated competition" is needed in order
to co-ordinate these vital elements with delivery of LTP2 objectives
and targets.
8.4 Competition needs to be harnessed to
drive up quality standards in a way that will provide people with
what they need and want and will use. We recognise that people
will only be prepared to get out of their cars if there is an
affordable, reliable, high quality alternative. The future of
travel in the West Midlands Metropolitan Area is too important
to be left within the control of individual private companies
whose first responsibility lies to their shareholders whilst competing
with each other.
8.5 We are serious in our intent to tackle
congestion and are pleased to have been one of the areas chosen
to pilot TIF work. We share the former Secretary of State's belief
that "for road pricing to work we have got to have reliable
public transport—including reliable bus services that people
can depend upon".2 However, we are concerned that local bus
service delivery in our Area is not yet adequate to deliver the
step-change in quality that will be needed to give people a feasible
alternative to travel by car. We believe that current partnership
arrangements are not adequately proven as the basis for sustainable
long-term improvement of local bus services.
REFERENCES
1 Quotation from speech by Karen Buck to
ATCO, 29 November 2005
2 Quotations from speech by Alistair Darling
to the CPT, 26 January 2006
3 Figures from Transport Statistics, Great
Britain, 2005
4 Extracts from speeches by Alistair Darling
to the CBI, 28 November 2005, and to the CPT, 26 January 2006,
by Karen Buck to ATCO, 29 November 2005, and by Derek Twigg to
the LGA, 14 December 2005.
23 May 2006
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