APPENDIX 29
Memorandum submitted by the Chartered
Institute of Logistics and Transport in the UK
INTRODUCTION
1. The Chartered Institute of Logistics
and Transport in the UK—CILT(UK)—is the UK's premier
institute for professionals working in all aspects of transport
and logistics including transport planning, operation and administration.
Its 20,000 members include bus company proprietors, managers and
other staff together with central and local government officers
working in transport policy, planning and on highways management.
The Institute is uniquely placed therefore to comment objectively
on the issues raised by the Committee's Inquiry.
2. The bus industry must play a leading
role if the Government's objectives for reducing road congestion,
improving air quality and reducing greenhouse gases are to be
achieved. CILT(UK)'s perception—bluntly stated—is
that failure to achieve a sufficient contribution from buses will
be more to do with a lack of consistency and continuity between
the different strands of central Government policies emanating
from the Treasury, the Department for Transport, Trade and Industry,
the Department for Communities and Local Government, the Department
for Environment, Food and Rural Affairs, the Department for Education
and Skills and the various Executive Agencies responsible for
transport and highways, than with any shortcomings of those working
locally to deliver services. CILT(UK) repeats its contention[22]
that unless stable conditions are created for the bus industry
to succeed in delivering both satisfactory commercial performance
and the policy goals set in Local Transport Plans, inter alia
attracting substantial patronage from trips currently made by
car, the targets set by the Government cannot be met.
3. In this evidence we briefly address the
questions posed by the Committee, who will be aware that the CILT(UK)
and its predecessor, the Chartered Institute of Transport, have
consistently advocated the need for less confrontation and polarisation
in delivering transport policy. The CIT was the original proponent
of the concept of Quality Partnerships[23]
and CILT(UK) remains convinced that, although the complex statutory
environment created by successive Governments is not ideal, the
only practical way forward is for all players to work together
and reach consensus. In 2002 we said, "That will undeniably
require some vigorous debates, but time is not on the side of
British transport and substantial changes to the legislative framework
are not a short-term option". That remains our view and our
arguments focus on creating the conditions in which co-operation
is encouraged, backed where necessary by sanctions for failure
to deliver for both public authorities and commercial operators,
and improving the way in which external financial support is delivered
for the benefit of bus industry customers.
(a) Has deregulation worked?
4. Although it would be convenient to give
a supposedly definitive one word answer to the question, unfortunately
the world is not so simple! The Committee will no doubt receive
a number of memoranda of evidence presenting statistical analyses
based on figures in Transport Statistics Great Britain and other
official publications presenting a spectrum of conclusions from
the negative that deregulation is an abject failure as patronage
outside London has continued to fall, to the positive that privatisation
has produced increased investment, improvements in efficiency
and reductions in subsidy. We simply comment first that the impacts
of deregulation and privatisation, implemented by the Transport
Act 1985, are different and second that the bus industry is essentially
local and that the data does not allow performance at local level
to be examined.
5. In fact, the performance of bus services
outside London is extremely variable. Where there is vigorous
company management of services, responding to local needs and
marketing the advantages of bus travel, where authorities (including
the police) are prepared to encourage bus use by giving buses
priority in the use of road space appropriate to their role as
a mass carrier, and use their responsibilities and influence over
enforcement of traffic regulations and parking to discourage use
of cars for trips better made by public transport, there are significant
successes. Brighton, Cambridge, Edinburgh, Nottingham, Oxford
are often quoted but there are many others, some not so conveniently
described by association with a large city. Conversely, where
company management is lacklustre, passively accepting the inevitability
of decline, and authority policies are not supportive, or in some
cases programmes have failed to be delivered, performance, has
been poor. We will not name and shame (the list is as long as
the successes!) but no doubt others will point to examples of
the sorts of failures we mean.
(b) Is London a sound model for the
rest of the UK?
6. There will be several suggestions to
your Committee that London provides a model that is suitable for
replication elsewhere. Indeed franchising is the most commonly
used tool in reforming relationships between bus operators and
transport authorities elsewhere in the world. However, it must
be recognised that conditions in London are different in several
respects:
— the density of development and traffic
levels together with the availability of frequent public transport
were encouraging lower levels of car use and in some cases ownership,
even before introduction of:
— the Central London Congestion Charging
zone which has considerably improved the reliability and speed
of bus services although blackspots still exist;
— the level of public investment in
bus services to support congestion charging and provide alternatives
to relieve overcrowded underground services;
— the fact that the GLA is a genuine
Strategic Transportation Authority taking an holistic view of
all public transport and strategic highway services; and
— London has never been deregulated.
We believe that success in London owes a great
deal to the vision and determination of the political and professional
leadership of the GLA, Transport for London and contracted bus
operators and should not be simply attributed to the absence of
deregulation or even the level of investment and support for buses.
As elsewhere in the UK, more local examination of the communities
that comprise the GLA area will reveal examples of poor performance
as well as good. Some argue that more freedom for the contracted
operators to plan services, particularly in outer London, would
result in better matching of resources to need rather than standards.
7. CILT(UK) believes that the reasons for
success in London are similar to the reasons for success elsewhere,
namely vision, leadership and sound management. The key lessons
from London that should be transferable are the importance of
treating transport holistically and being able to raise funds
locally. There is a need for the major metropolitan areas at least
to have strategic transport authorities. Although the Passenger
Transport Authorities and their Metropolitan District Councils
have worked well together in producing joint Local Transport Plans
covering their conurbations and councils in unitary authorities
and counties have similarly worked together across administrative
boundaries, this does not have the same clarity and focus, nor
ultimately the ability of a single decision making body to resolve
conflicts and provide leadership.
(c) Co-ordination, integration and
service quality
8. The Committee refers to co-ordination
of bus services with other forms of public transport. Co-ordination
between different bus operators is equally important, although
this is made more difficult by the narrow interpretation by the
Office of Fair Trading (OFT) of a market for bus services as opposed
to the wider market for local travel in which private cars dominate.
For the bus industry to play its full part in the integrated transport
policy to which we believe the Government still subscribes it
must be capable of offering services which cater both for those
with no realistic alternative way of travelling (including those
without personal access to cars, young people, etc)—the
traditional (and dwindling) "captive" market—and
for those who can be persuaded to choose bus travel for reasons
which might include convenience, value for money or successful
marketing. Because of the OFT's views and the differing attitudes
of the large groups that dominate both bus and rail industries,
the extent of formal co-ordination is very variable. Offsetting
this are the efforts of many local authorities to promote public
transport in their areas as a whole, supported by Government backed
initiatives such as the national telephone information service,
traveline, and the Transport Direct internet portal. Journey Solutions,
a joint initiative of the Confederation of Passenger Transport
(CPT) and Association of Train Operating Companies (ATOC) is progressively
rolling out PlusBus tickets giving local bus add-ons to rail travel.
9. Service Quality is addressed in the question
by reference to "clean, safe, efficient" the latter
presumably including reliability, timekeeping and availability
(extent of route network and frequency of service). CILT(UK) believes
that, catalysed by the activities of the Disabled Persons' Transport
Advisory Committee (DPTAC), the UK bus industry has an enviable
record of introducing new, low floor accessible buses so that
Britain is a leader in the availability of accessible services.
This benefits many other groups, especially parents with buggies
and those with luggage, in addition to disabled people. Many of
the better examples of bus services around the UK benefit now
either from cleaners or drivers sweeping out litter between journeys
at termini: however, it must be said that better standards of
behaviour in respect of littering and treatment of assets used
by the public are required to assist operators tackle the problems
of cleanliness.
10. The bus industry and local authorities
have both been proactive in the use of CCTV for passenger security
and this has led to rapid apprehension of culprits committing
acts of violence and damage on buses. Statistics show the most
vulnerable part of a public transport journey is generally the
walk to or from the point of boarding or alighting the vehicle
and this is a general problem in society not confined to public
transport.
11. Many operators have increased service
frequencies by concentrating resources on core networks of routes.
These are supported by good publicity provided by the operator
or the authority or jointly. Market research and monitoring shows
that such services are appreciated by the public and generally
show patronage growth. There remains the problem of fringe areas
where services cannot be provided viably and in some cases it
must be said that the political instinct to restore a bus service
leads to considerable waste of resource. In such areas, alternative
solutions such as DRT (Demand Responsive Transport) or variants
such as taxibus may be more cost effective and can draw on other
suppliers and resources that may be locally available.
(d) Can deregulation be made to work
and if so, how?
12. In the Institute for Logistics and Transport's
evidence in 2002 it was suggested:
"A more radical approach would be to move
to a more open system of network support, whereby in each authority
area a `conference' of the authority and all the operators within
its area would jointly determine the overall requirement for bus
services, following which operators would each assess the level
of support necessary, including concessionary travel, to maintain
the parts of the overall network provided by them. Negotiation
between the authority and the operators would finalise service
and support levels".
13. This approach is in effect the Passenger
Transport Area concept of the 1968 Transport Act fast forwarded
to the deregulated world. The 1968 Act provided for a multiplicity
of stakeholders as well as elected representatives in the Passenger
Transport Authorities but this was removed too early by local
government reform in the 1970s and 1980s. The Bus Strategies required
under the Local Transport Plan system introduced by this Government
in the Transport Act 2000 offer a vehicle for developing this
approach. Ideally it would be accompanied by reforms to the payment
of Bus Service Operator Grant, Concessionary Travel Reimbursement
and service subsidies to make a consolidated support payment available
through the authorities for each operator's part of the network.
This is not the same as Quality Contracts or the Quality Networks
concept advocated by the Association of Transport Co-ordinating
Officers (ATCO).
14. This "Network Development Conference"
approach would harness the commercial skills of the operators
to achieve the economic and social objectives of the authorities
with the best possible networks and service levels for the total
resources available. It would maximise the effectiveness of the
combined resources of the commercial network and public support
payments. This is not too dissimilar to a number of European countries
where support is paid for networks of services rather than individual
routes, expecting that concessions for children, older people
etc carried on regular services will be part of the general fares
structure. In Great Britain, excepting Greater London, tendering
is on a route-by-route basis and opportunities to plan jointly
the commercial and publicly supported services do not arise. Potential
network synergies are lost. In the UK, changes would be required
not only to tendering and concessionary travel regulations but
also to the role of the Competition Act 1998 in relation to the
UK bus industry.
15. A working party of the CILT(UK)'s Local
Transport Forum is starting a programme of work to examine how
this concept might be developed.
(e) Is statutory regulation compromising
the provision of high quality bus services?
The powers of the Traffic Commissioners
16. The dead hand of the Competition Act
1998 as interpreted by the Director General of Fair Trading has
led to the termination—to the bemusement of the public affected—of
sensible voluntary integration such as joint timetables and inter-available
ticketing schemes. There is a strong case for treating the bus
industry as a utility and creating a Bus Regulator to judge public
interest and promote the achievement of the Government's integrated
transport policies.
17. CILT(UK) believes that modernisation
of the Traffic Commissioners' role should continue and that consideration
should be given to extending it to judging public interest in
a "Bus Regulator" role and to policing local authority
delivery of programmes to assist buses in Local Transport Plans
and Quality Partnerships.
(f) Are priority measures having a
beneficial effect?
18. Buses share their "track"
with general road traffic. Whilst this enables services to run
close to where peoples' journeys start and finish, buses are caught
up in traffic congestion, unless bus priorities are provided.
Statistics recently considered in a CILT(UK) Forum suggested that
up at least 10% more buses may be required to operate services
to the Traffic Commissioners standards because of this and it
is proposed to do further work on this. Bus priorities are beneficial
but a number of practical problems reduce their impact.
19. Provision of bus priorities requires
political will from the local highway authorities. This may not
be forthcoming since bus priority measures are often interpreted
as being "anti-car" rather than better use of road space.
Similarly, all too often the police see buses only as another
commercial road user and not as an effective instrument for reducing
congestion.
20. Four particular problems are often quoted
as reducing the effectiveness of bus lanes:
— Inconsistent periods of operation
confuse car drivers and lead to lane abuse.
— Inconsistent surface treatment: separate
colours—green, red, black—are now commonly used but
there is no standardisation—eg red for all day lanes, green
for daytime only, etc. For example, conventions differ in London
and Edinburgh!
— Enforcement—the police can
give bus-lane enforcement little priority, which leads to widespread
abuse at all times. Limited waiting/loading times are frequently
ignored by frontagers onto bus-only lanes. The police work to
priorities and plans set by the Home Office and suffer their own
lack of resources. Many bus operators fit CCTV cameras to their
vehicles for internal security and external recording of traffic
incidents. Subject to appropriate codes of practice, the recordings
should be available for enforcement purposes. Whilst detection
of bus lane infringements by the operators themselves is obviously
helpful, only the police can deal with moving traffic offences.
As the benefits of bus lanes can be quickly eroded by infringement,
highways authorities and the police should build police enforcement
into the costing of proposed schemes as part of the ongoing revenue
costs.
— Maintenance—the ride quality
of modern vehicles is dramatically reduced by the poor maintenance
not only of surfaces in bus lanes but also the inner lanes of
roads generally.
(g) Are local community services sufficiently
funded and targeted?
21. By "local community services"
we assume the Committee refers to initiatives using other than
conventional bus services. These can range from voluntary sector
community transport schemes which often depend on local authority
or charitable funding, through innovative use of other resources
such as NHS, social services and schools transport vehicles to
subsidised services such as those supported by the Government's
Urban and Rural Challenge initiatives. CILT(UK) believes such
services can play a valuable role and that the conference approach
advocated above can identify the areas of lower demand in which
they are most likely to be required.
22. If funding of the challenge type is
provided the downstream consequences of success must be recognised.
For example, rural bus services that proved successful and comfortably
met the relevant local authority's criteria for subsidy were cut
back or discontinued when the authority had no headroom in its
subsidy budget when challenge funding expired. Expectations have
been raised and on normal criteria the new services should have
continued. Exit strategies and sustainability must be important
considerations when using such forms of funding.
23. For both rural and urban challenges
a number of common characteristics emerge:
— interchange between services and
modes;
— use of new technology, particularly
vehicle tracking and communications, which will also facilitate
better fleet management, real time passenger information and other
worthwhile developments capable of wide application;
— convergence (particularly in rural
areas) of transport, health and parcel carriage requirements;
— demand responsive operation (eg DRT,
dial-a-bus, "Wigglybus" etc) and or funds from other
agencies with complementary functions to supplement transport
funding, for example community health practices and the Countryside
Agency);
— need for strong promotion and marketing;
— recognition of the traveller as an
individual and adapting services to his/her needs; and
— the advent of travel plans or some
types of higher quality service introduced with challenge funding
can create problems of abstraction of passengers from commercial
service, for example when "direct" works buses are introduced.
(h) Concessionary travel
24. A Byzantine set of regulations govern
UK concessionary travel schemes and require that operators should
be "neither better nor worse off" as a result of carrying
concessionary passengers. The comparison is with passengers carried
at the full standard fare, but as concessionary travellers account
for around 40% of total UK bus patronage, supported by public
funding of almost £500 million, effectively many commercial
services are underpinned by public support payments. We propose
above that these should be rolled up into a single funding pot.
25. Concessionary travel is expensive to
administer: authorities and operators devote much effort and resource
to calculating concessionary travel reimbursement. There is scope
for simplification by revising the regulations to allow the costs
of concessionary travel schemes to be a matter for commercial
negotiation between authorities and operators in their areas reflecting
the fact that these are contractual payments to carry specific
groups of passengers at reduced fares.
26. CILT(UK) notes the national initiatives
for free bus travel in Scotland and Wales, for free local bus
travel in England from 1 April 2006 and free national travel in
England from 1 April 2008. Although concessionary travel schemes
may not be the most economically efficient way of helping elderly
and disabled people, the impact on bus industry finance is significant
and will assist the introduction of better ticketing methods to
monitor the costs of this "free" travel.
(i) Quality Contracts
27. As noted in the Introduction, one of
the Institute's predecessors—the Chartered Institute of
Transport—developed the concept of Bus Quality Partnerships.
In the Transport Act 2000 provision was made to give such partnerships
statutory protection but this has been little used.
28. The major weaknesses of Bus Quality
Partnerships as presently operated are:
— they are not binding on participants.
Instances of authorities and operators defaulting on their initial
commitments have been reported; and
— they are not able to include hours
of operation of services or fares levels. In some cases, informal
concordats have been reached on these issues.
29. Bus Quality Contracts have been seen
as an opportunity to extend a quasi-franchising system, similar
to that introduced with some success in London, to other parts
of the UK. However, a number of problems can be identified with
this approach, including:
— few councils and PTEs now have staff
skilled in the detailed processes of bus service planning necessary
to formulate the service specifications that will be the basis
of the contracts. In London the way in which privatisation was
carried out ensured that appropriate skills were retained in TfL;
— when operators are contractors operating
someone else's service specification with no opportunity for change
in response to customer needs, tensions arise and job satisfaction
suffers for managers who take no substantial role in market development;
and
— the tortuous approval procedures
laid down in the Transport Act 2000, which introduce further bureaucratic
burdens for both authorities and operators.
30. Clear examples of the need for more
effective partnership can be seen especially in many small to
medium sized towns and their rural hinterlands, where the mismatch
between commercial and subsidised service requirements leads to
networks that do not make best use of the available resources.
CILT(UK) still believes that partnerships to jointly determine
the total bus network in each authority area offer the way forward,
using conferences of authorities and operators as suggested above.
SUMMARY AND
THE FUTURE
31. CILT(UK) recommend that in the reforms
of regional and local government in England being considered by
the Government priority should be given to creating strategic
transport authorities responsible for both roads and public transport
and with appropriate revenue raising powers including road user
charging.
32. CILT(UK) draws attention to the references
in this brief discussion to two particular factors that are essential
for good bus services:
(i) Quality of management in companies and
local authorities, together with political vision and leadership.
(ii) Partnership between those responsible
for the bus services themselves and those responsible for managing
the highways and associated services such as enforcement of traffic
regulations and parking.
33. Strong management skills resulting from
good education, training and professional development, appreciation
of wider policy issues and effective partnership between the various
disciplines involved are key to delivering good bus services.
This applies whatever the regulatory framework.
34. Partnership rather than quality contracting
is seen as a way forward, with the proposal of the Network Development
Conference offering a model for debate. CILT(UK) believes primary
legislation and radical changes are not required. Using the wide
range of powers to make regulations it should be possible to use
existing legislation to move towards the Conference proposal.
35. Support to the bus industry should be
rationalised so that a single "pot" replaces current
separate arrangements for service subsidies, concessionary travel
and Bus Service Operator Grant.
36. The Competition Act 1998 sits uneasily
with the objectives of integrated transport policy. One way that
this could be resolved is by the creation of a bus regulatory
authority, as is the case for the railways and other privatised
utilities, perhaps through a modernised and expanded role for
the Traffic Commissioners.
25 May 2006
22 Evidence to the Transport Sub-Committee of the Transport,
Local Government and the Regions Committee by the (then) Institute
of Logistics and Transport, April 2002. Back
23
"Bus Routes to Success", Chartered Institute of Transport,
1991. Back
| 
