APPENDIX 28
Memorandum submitted by the Association
of Local Bus Undertaking Managers (Album)
The Association of Local Bus Undertaking Mangers
(Album) represents many small and medium sized bus operators throughout
the United Kingdom. Our members include Municipals such as Nottingham
Transport and Cardiff Bus and a large number of private businesses
such as Trent, Western Greyhound and East Yorkshire Motor Services.
Has deregulation worked? Are services better,
more frequent, meeting passenger need?
Bus usage is dependent on a wide range of factors.
The most important of these are:
— Bus service reliability—passenger
surveys invariably show this as passenger's key priority.
— The relative speed of buses and cars—the
priority allocation of road space and the introduction of major
bus lane schemes are vital.
— The availability of car parking and
it's pricing relative to bus fares.
— The quality and attractiveness of
bus services.
— The full costs of running a car in
relation to household incomes.
— The extent to which new development
is concentrated in urban centres, which buses can serve more easily,
rather than, dispersed towards the edge of towns and cities.
— The amount car users pay to use the
road (road pricing is potentially a key issue).
— The level of bus fares.
— The extent to which local bus services
provide a comprehensive network.
— The degree to which operators and
Local Authorities work together to achieve real benefits for the
passenger and put the interests of the passenger first.
— The ease of passing a car or motorcycle
driving test.
Many of these key issues are completely independent
of the regulatory framework for buses.
Evidence from Europe shows that where regulated
systems are in place there have been large falls in public transport
passenger ridership, eg, in Italy where passengers have declined
by 14% between 2002 and 2004.
Similarly in Northern Ireland bus patronage
fell by 3% between 2000 and 2005, under a regulated system.
Many bus networks operating in a deregulated
environment have shown double figure passenger growth eg Lancaster/Morecambe,
Bedford, Kidderminster, Oxford and Cwmbran.
There is no evidence that buses are less effective
in England than in any other European country. Commercial unsubsidised
passenger levels have generally held up well in all the English
PTE areas over the last five years. Where passenger levels have
fallen this can be largely attributed to changes in concessionary
fare policies and in some cases to demographic factors.
The Government's new free concessionary fares
scheme will however, undoubtedly encourage many more people to
travel by bus.
Are bus services sufficiently co-ordinated with
other forms of public transport?
Some people clearly benefit from the co-ordination
of bus services with other modes of public transport. It is, however,
important to recognise that bus to bus interchange is frequently
more important than interchange with other forms of transport
and, therefore, has to be prioritised. There are also often more
important overall passenger needs, eg that the bus fits in with
school or work finishing times rather than meeting a specific
time train.
Lengthy diversions into rail stations or interchange
points also often make the total service less attractive to bus
passengers by increasing journey times between their origin and
destination. Such diversions also often significantly increase
costs of operation making services less viable if usage of the
multi modal transport interchange point is not sufficient to cover
the extra costs involved.
Bus Operators do, however, work with other transport
providers and Local Authorities to co-ordinate services where
there is genuine passenger demand.
The Traveline project also shows bus operators
commitment to work with Local Authorities and other organisations
to provide co-ordinated information on all transport modes by
telephone or via the web.
Are buses clean, safe, efficient?
Buses are one of the safest forms of public
transport with Department for Transport data showing that between
1993 and 2002 there were only an average of 0.4 fatalities per
billion passenger bus kilometres. Equivalent figures for cars,
motorcycles and bicycles were 3,113 and 41 respectively. During
the same period there were only an average 13 serious injuries
per billion bus passenger kilometres, whilst the equivalent figures
for the car were 33; the motorcycle 1,393 and the bicycle 773.
Operators have invested millions of pounds in
the past few years to introduce low-floor fully accessible vehicles.
As a consequence of this investment the average age of the national
fleet now stands at 7.12 years.
Bus safety remains one of the industry's strongest
suits.
Buses are becoming increasingly environmentally
clean and data from the European Environment Agency shows that
buses produce around 20% of the emissions of cars based on an
analysis of grams per passenger kilometre. In addition Euro 3
engines produce 80% less carbon monoxide, around 75% less hydro
carbons and two thirds less nitrogen oxides than pre 1990 bus
engines.
If not, can deregulation be made to work? How?
Operators have heavily invested in providing
quality bus services and where Local Authorities have adopted
pro-active pro-bus strategies to support that investment, significant
passenger growth has been achieved.
Regulation cannot force investment and regulation
will not in itself produce service reliability improvements or
make buses more attractive in comparison to cars.
Deregulation has many success stories and in
the vast majority of cases the key common feature is that these
have been achieved where operators and Local Authorities concentrate
on a mutually shared common desire to grow bus ridership and work
in close harmony on a voluntary basis.
Is statutory regulation compromising the provision
of high quality bus service?
Competition regulations have limited the extent
to which operators have been able to co-ordinate timetables and
co-operate in other areas for the benefit of the customer. Legislative
changes have also significantly impacted on cost, particularly
in respect of employment legislation, health and safety legislation
and drivers hours rules. The vast majority of operators fully
appreciate the importance of quality to passengers, as well as
their growing expectations, and have, therefore, been incentivised
to try to minimise the impact of these cost increases on the quality
of the product they have on offer.
Are priority measures having a beneficial effect?
What is best practice?
Bus priorities are having a beneficial effect,
particularly where a comprehensive network of measures is introduced.
Many local authorities are reluctant to implement such priority
facilities due to public opposition. Brighton and London demonstrate
the benefits that such measures can bring to existing bus passengers
and in encouraging modal shift from the car. Many existing bus
lanes could be made more effective by increasing their period
of operation.
More extensive bus priority measures are required
in our cities and towns across the country. Dedicated bus lanes
are the key, but significant improvements in reliability can also
be achieved through GPS and traffic light priorities. There should
be greater funding incentives for local authorities that are prepared
to introduce such measures all day to reduce traffic congestion
and comparable financial funding penalties for those local authorities
that fail to take a long term view by not addressing these issues.
From an operational control perspective some
bus companies trying to introduce new bus to base radio communication
systems would also benefit from the Government making it easier
for operators to secure band three radio channels at an affordable
rate.
Significant numbers of car users will be attracted
to the bus if bus journey times are considerably speeded up relative
to the car.
Is financing and funding for local community services
sufficient and targeted in the right way?
More funding should be allocated to pump priming
bus service improvement projects that have a good business case
and a potential long term future. A separate bus kick start fund
should be retained either ring fenced within the Transport Improvement
Fund or outside it. Album is concerned that the new TIF monies
will largely be devoted to major road/light rail/infrastructure
projects rather than on service enhancements.
More funding should also be targeted to schemes
where operators are willing to match or partially match fund the
investment.
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?
The Government's new April 2006 English concessionary
fares scheme represents a considerable overall improvement on
the arrangements that were in place previously for the majority
of senior citizens. There has, however been considerable public
confusion, particularly in areas where very complex schemes have
been introduced by some Local Authorities in respect of cross
boundary fares.
The other major problem with the 2006 scheme
has been the allocation of the funding to individual local authorities,
which was not based on actual travel or anticipated take up. The
monies were also not ring fenced solely for use to fund concessionary
travel. As a result of this some Local Authorities have received
insufficient funding to cover the costs of the new scheme, whilst
others have received too much and have diverted some of these
funds to other purposes.
Important lessons must be learnt. The administration
of the proposed 2008 free English national scheme should either
be administered on a central basis or, at the very least, on a
regional basis in order to ensure that the funding available is
used for concessionary travel purposes.
It is also important that sufficient "additional
costs" funding is budgeted for, especially for operators
in major tourist centres such as York, Bath, Blackpool and Brighton,
as the new national free scheme will undoubtedly generate considerable
extra bus travel.
Free or discounted national travel on other
forms of public transport should only be considered if there are
sufficient funds available. The costs associated with implementing
such a scheme are likely to be considerable not only in terms
of fare forgone reimbursement, but also in terms of providing
the required additional capacity on rail.
Why are there no Quality Contracts?
There is clear evidence that bus patronage growth
and all legitimate public policy objectives can be secured without
resort to Quality Contracts. The successes in Cambridge, Lancaster,
Brighton and many other areas where operators and Local Authorities
concentrate on improving service quality for passengers and making
the bus more attractive, have shown that Quality Contracts are
unnecessary.
A "market testing" exercise by the
PTE group has suggested that Quality Contracts would require Local
Authorities to take new financial risks and substantial public
spending on depots, although satisfactory garage facilities already
exist.
Time limited Quality Contracts would not encourage
operator investment to the same degree as the current deregulated
environment. Contract renewal periods would also cause considerable
uncertainty and concern for both passengers and staff.
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 Traffic Commissioners powers in respect
of safety and service quality are not only relevant, but also
extremely important from an industry standards and a public confidence
perspective.
Overall the industry gets the scrutiny that
is required , but the Traffic Commissioners can only take action
when they have evidence of poor performance Additional investigative
resources are needed to ensure that the standards achieved by
the majority of reputable operators are also adhered to by a small
minority of other operators.
The Traffic Commissioners should also be given
powers to take action against Local Authorities which consistently
fail to address traffic congestion issues raised by operators
and which prevent them from achieving the Traffic Commissioners
punctuality targets. At the present time operators can be fined
and have restrictions put on their licences (including revocation)
for non compliance. Local Authorities have no such incentive to
take action to address Service reliability issues, which is intrinsically
unjust, as many of the factors which cause service unreliability
are in the control of the Local Authority and not the operator.
Is London a sound model for the rest of the UK?
London is not a sound model for the rest of
the country. The levels of financial subsidy involved are simply
not affordable elsewhere.
Having said that buses in London have been a
great success story and there are key pointers for the rest of
the country. These include:
— Limited and very expensive central
parking.
— Considerable expenditure on bus priorities,
enforcement and service reliability measures.
— Unified control of vital parts of
the highway network and road pricing policy.
— Strong political pro bus leadership
and support for congestion charging.
— Comprehensive local tax raising powers
for transport.
Local Authorities outside London could achieve
similar (but proportionate to spending) results, if they tackle
the road allocation issue, without any change to the regulatory
system.
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 passenger numbers will be boosted if there
is greater commitment to:
1. The introduction of more widespread bus
priority measures to improve punctuality and the speed of the
bus relative to the car, together with appropriate enforcement.
2. Ensuring that major traffic generators
are located in central urban areas or in parts of urban areas,
which are well served by public transport.
3. Restricting the free movement of cars
in central urban areas and making sure that the true environmental
cost of car usage is reflected in parking charges and road pricing.
4. Encouraging some Local Authorities and
operators to adopt the best industry practice of many of their
colleagues. Genuine constructive partnership working between operators
and Local Authorities is the common feature of the vast majority
of the UK's bus success stories.
All of the above will achieve far more than
a change in regulatory regime.
24 May 2006
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