Memorandum from Simon Norton (TPT 11)
I am writing to submit evidence into the House
of Commons Transport Committee inquiry into ticketing arrangements.
I am coordinator of Transport 2000's local group covering Cambridgeshire,
but this evidence is being submitted purely in a personal capacity.
This evidence partly overlaps the evidence I
gave to the inquiry on fare levels, reflecting the substantial
overlap between the two issues. However I have tried to restrict
the evidence I am giving to the issues described in the terms
of reference for the inquiry.
INTRODUCTION
1. I welcome the opportunity to submit evidence
before this inquiry. In general I support the Government's stated
aims to develop integrated ticketing. I believe, however, that
progress towards these aims has been very limited, and I herewith
offer ideas for remedying this.
2. There are several reasons for developing
integrated ticketing:
2.1 To avoid penalising passengers
who need to change en route. This is because fare levels tend
to be tapered, so (say) a two mile bus journey from one's home
to the local station plus a 50 mile train journey would cost significantly
more than a 52 mile journey by a single mode.
2.2 To reduce overall time spent in
ticket queues at stations and on buses by enabling a single transaction
to cover several legs of a journey.
2.3 To minimise the inconvenience to
passengers whose routes have been split up or who are making return
journeys where each leg involves a different operator.
2.4 To encourage leisure travel in
the countryside, which can make a significant contribution to
keeping rural public transport going and which typically involves
many changes of vehicle en route.
3. However, the practical use of such integrated
ticketing as has emerged has been severely restricted for the
following reasons:
3.1 Commercial bus operators are actually
discouraged from arranging integrated ticketing because of fears,
often justified, that they will be seen by the Office of Fair
Trading as being contrary to the interests of competition.
3.2 While some local authorities have
developed integrated tickets covering both supported and commercial
bus services in their areas, they are few and far between. Furthermore
it is even rarer that they have developed mutual acceptance agreements
with their neighbours.
3.3 Publicity about the exact validity
of specific integrated tickets is often not available, leaving
passengers to just hope that individual bus drivers or train conductors
will accept their tickets.
3.4 Quite often bus drivers and rail
ticket offices do not know how to issue certain types of ticket.
3.5 Rarely do rail ticket machines
offer bus add-on options.
4. Here are some examples from my own experience
which illustrate the above.
4.1 Shirerider—a Sunday ticket
combining train travel with unlimited bus travel in Shropshire,
Worcestershire and Herefordshire. I've asked for such a ticket
five times, and not once have I been given the correct ticket
without delay.
4.2 Stagecoach Explorer (issued by
Stagecoach in Bedford)—formerly interavailable with Explorers
issued by Arriva Shires and Essex, Arriva Fox, and Huntingdon
and District, now no longer so.
4.3 Sunday Rover—formerly interavailable
between Sunday buses in the whole of the East of England region
plus some adjacent counties. Since then, however, many companies
have dropped out but no publicity has been issued giving definitive
information about which ones still participate—indeed I
don't even know whether the facility still exists. Last time I
tried to use it I had difficulty getting the driver to issue one,
and several other bus drivers refused to accept it, costing me
more than I'd paid for the ticket to start with. I never got a
refund.
4.4 Chiltern Railways Off-Peak Saver
from Hertford East to Kidderminster—ticket office did eventually
find out how to issue one, but it took so long that I nearly missed
the train after the one I had been aiming for.
4.5 Rail/bus ticket from Finsbury Park
via Biggleswade to Potton—ticket office denied knowledge
of this one and my request for a refund is at the time of writing
still pending.
5. The above explains my answers to the
first two questions in the terms of reference. I now proceed to
answer all those where I wish to offer evidence. I use the same
numbering as in the terms of reference, eg my answer to the question
numbered 2 is in paragraph 5.2.
5.1 Is ticketing sufficiently integrated
across different modes of transport and between different geographical
areas? No
5.2 Does the Government have an adequate
strategy for developing the integration of ticketing systems?
No
5.3-5 (on smartcards). I have no evidence
to offer on these questions.
5.6 Is the legal framework within which
ticket inspectors function appropriate? See answer to 8 below.
5.7 What appeal mechanisms exist for
passengers, and are they adequate? Passengers have London Travelwatch,
Passenger Focus and the Bus Appeals Body. I have no evidence to
offer on whether they are adequate.
5.8 Are the rights of passengers and
the powers of ticket inspectors well balanced? No, passengers
need a right not to be penalised when they have difficulty getting
the ticket they want or inadvertently breach the conditions of
that ticket. The former can apply when
5.8.1 The ticket machine at the relevant
station cannot issue the ticket they want (eg when they already
have a ticket for part of the journey and need an excess ticket
to cover the rest). It might also be the case that passengers
are unable to get the ticket they need because it isn't obvious
how to do so (I have no idea whether the machines at Cambridge
station will issue Anglia Plus tickets, for example).
5.8.2 The only ticket issuing facilities
are separated from their platform by a level crossing which will
close when the train they are after is approaching. (This applied
in the case a few years ago when a couple of girls were run over
by a train at Elsenham station.)
5.8.3 The ticket queue is unexpectedly long.
5.8.4 The bus that brings them to the station
is running late or makes a very tight connection with the relevant
train.
5.9 Do operators of public transport
take adequate measures to protect fares revenue? It should be
a commercial decision for them whether the deployment of more
revenue protection officers is worthwhile. I do not believe that
they should be expected to take extreme measures to ensure 100%
compliance at the possible expense of inconvenience to passengers.
5.10 Is the Government's concessionary
fares strategy, including the proposed scheme for concessionary
bus travel, adequate? The present scheme in England is inadequate
because support is only automatically given for travel within
one's home district, which may not cover all one's essential travel
needs. The scheme that will come into force in 2008 will be much
better. However I would like to draw attention to one possible
problem. Is there a danger that cash strapped local authorities,
especially in unitary areas, might cut local bus services in order
to save on the subsidies they will be providing to concessionary
pass holders? This should be considered before the Government
makes any decisions on local government reorganisation or finance.
The significance of unitary status is that it means that the same
tier of government will be supporting concessionary pass holders
as will be deciding on service levels for supported bus services.
5.11 Are concessionary fares schemes
sufficiently integrated across different modes of transport and
different geographical areas? I believe that concessionary pass
holders living in areas that are very dependent on rail transport
should be entitled to free travel on their local lines, but otherwise
I accept that it may not be desirable to provide unlimited free
travel on trains. The scheme coming into force in 2008 will provide
integration across the whole of England outside London; I do not
know what provision, if any, will be made for integration between
London, the rest of England, Wales, Scotland and Northern Ireland.
6. Let me conclude by making the following
recommendations.
6.1 New legislation should be introduced
to make it clear that bus operators do have a right to make interavailability
agreements provided that these do not exclude any third operator
that may provide services which might be covered.
6.2 Local transport authorities should
have a duty to extend the validity of bus operators' integrated
tickets to supported services running in the same general area.
The same should apply to return tickets where at least one leg
is by supported service.
6.3 Local transport authorities should
have a duty to include in their timetable publcity full and up
to date details of all integrated ticketing schemes covering all
or part of their area. Passengers would be able to carry such
details with them which would help to avoid disputes with bus
drivers and train ticket offices and conductors. (Note: at present
there is not even a duty to provide timetable publicity—I
believe there should be, but this is presumably beyond the remit
of this inquiry.)
6.4 Rail operators should have a duty
to develop integrated ticketing, including interavailability agreements
with bus operators who run on parallel routes outside train operating
hours or during hours when cheaper tickets are not accepted on
trains.
6.5 Rail operators should be given
assistance with adapting ticket machines to issue all relevant
tickets, as well as with providing for any relevant smartcards.
Furthermore, in stations that straddle level crossings, such ticket
machines should be available at both sides of the station.
6.6 Penalty fares should not be imposed
where the conditions of (e) are not satisfied. Furthermore they
should not apply to people who have legitimate reason to access
station platforms for purposes other than catching trains.
March 2007
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