Bus Services Bill [HL]

Written evidence submitted by Worcestershire County Council Transportation Services Unit (BSB 27)


Over the period between April 2012 and March 2016, annual bus patronage in Worcestershire has reduced by 3 million passenger journeys, a fall of 20%. The estimated impact of this reduction has been to create an additional 4,300 new or extended car journeys per day. There are a number of factors that have contributed to this reduction

· Decreasing revenues from public sources for bus operators with reductions in subsidies (£4 million p.a.), concessionary reimbursements (£1 million p.a.) and Bus Services Operators Grant (20%). There has also been a fall in revenue from provision of Home to School Transport that has had less impact on the main providers of Local Bus Services.

· Reduced competition as a result of operators withdrawing from the market either through selling operations or ceasing operations in response to the adverse financial environment for bus operators. This has impacted the Wyre Forest District and to a lesser extent Redditch

· De-registration of commercial bus services particularly in rural areas again in response to the adverse financial environment. Many rural routes now operate on a 'service of last resort' frequency.

· Poor service reliability in part due to the use of older vehicles, potentially linked with declining maintenance standards and attempts to reduce costs through more 'efficient' vehicle use resulting in reduced 'catch up' time in vehicle diagrams.

· High costs of operating in some urban areas resulting from increasing levels of traffic congestion.

Our analysis is that the problems facing the industry in Worcestershire are largely financial resulting from the poor profitability of operating in the County.

There are initiatives that have been progressed to offset the negative factors and to make bus services more appealing to the public.

· Integration of Home to School trips into Local Bus Services

· Introduction of a multi-operator ticketing scheme (Connecta)

· Introduction of Real Time Information Services along key corridors

· Introduction of scheduled Community Transport Services in rural areas to replace de-registered local bus services

· Collaboration with Transport for West Midlands in extending its' SWIFT Smartcard into Worcestershire

· Consulting with bus operators on the Local Transport Plan (LTP4) to address concerns about traffic congestion.

The remainder of this document sets out the views of Worcestershire County Council on the proposals detailed in the draft legislation.

Partnerships and Franchising 

Worcestershire County Council welcomes the development of existing Partnership options and the availability of options that do not involve the commitment to continuous investment in infrastructure improvements. At this stage it is felt that the Enhanced Partnership may be the most appropriate option to address the current decline in bus patronage in the County although the Council would wish to evaluate the option for a voluntary scheme in the knowledge that the EP option will require significant in-house resources to assess options, devise and develop the EP plan and scheme.

The Council does not see Franchising as a viable option in a rural area, there being two key areas of commercial risk, firstly through taking responsibility for the revenue risk for all bus services across the County given the current state of the bus market in Worcestershire and secondly the risks associated with tender prices given the limited local operator bus across a geographically dispersed area, effectively leaving the County open to single suppliers able to fulfill requirements at a local level. There are also concerns that an aggrieved operator that currently operates commercial services but is not successful in tendering through the franchise process may seek redress for loss of income.

We can understand the proposal around a ban on Local Authorities setting up bus companies but we would not wish to see Local Authorities completely prevented from operating local bus services. From time to time Worcestershire County Council has had to step in as an operator of last resort when services were de-registered or where companies have ceased operations to stabilise the service with the aim of tendering a later date when the service parameters have been established.


The Council welcomes the concept of linking ticketing into Partnership agreements as even with a statutory multi-operator ticketing scheme in place, there are operators who feel that it does not apply to them and need to be prodded into compliance. The Enhanced Partnership is an area that we would wish to explore as it appears to be more appropriate to the conditions that we experience.

The proposals to future proof ticketing schemes is also welcomed and an area where the Council. Tying ticketing schemes into partnerships and the registration process will be a welcome development.

We do have concerns about how a multi-modal ticketing scheme would operate based on conversations will a TOC when the current Connecta Scheme was established. The Rail Industry had a mindset that multi-modal meant a Plusbus product and there was a reluctance to consider bus operators selling a ticket that was valid for rail travel.

Open Data and Registration 


· The current process for registration of bus services and provision of information on bus services to the public is not for purpose and is expensive to operate. While Electronic Bus Service Registration has been around for quite a while, take up has not been high and it is important to understand some of the reasons behind that.

· There is no financial incentive to provide Electronic Bus Registration files to the Traffic Commissioner; as a result there are some quite large companies who have the capability to provide the data in electronic format that chose to submit paper registrations.

· Even where operators supply electronic files, very often they are not compatible with Travel Information systems due to issues in the way that file was compiled such as the order of bus stops, there is need for files to be sense checked before uploading to a central system hence there is still a role for the Transport Authority.

· Bus registrations would be managed more efficiently if devolved to the Transport Authority as proposed in the draft Bill, not only because of the link to travel information but the Transport Authority is much closer to the needs of the bus operators within its' area.

· Most small and many medium sized bus operators will find it difficult to justify investment in expensive computer based planning software capable of producing Electronic Bus Registrations. By allowing the Transport Authority to charge a processing fee over and above the registration fee, the Transport Authority could provide a managed service for smaller bus operators.

· The proposals to give Transport Authorities powers to access revenue and patronage data for services that have been de-registered is welcome. While patronage data has usually been forthcoming, revenue data has been a far more contentious issue yet is crucial in planning replacement services.

Central data hub 

· The current central data hub (TNDS) is fit for purpose for bus service information in so far as it provides raw information on bus service times. This system could be developed to provide timetables and to meet the aspiration to provide information on fares.

· The Council is aware from its' daily contact with our residents that the availability of timetables is important to the public especially future timetables at times when they need to plan ahead such as September when the schools return, Christmas and Easter, and the Third Party travel apps including that provided by Travel Line Information Limited (TIL) do not provide the required functionality.

· There have been a number of so called standard formats but there has been no standardisation on one format. There are various formats including ATCO-CIF and four TransXchange formats in use at this time. Data is received from various operators and Transport Authorities for consolidation into the central repository, The National Data Set (TNDS), this adds to cost and to the shortcomings of the existing system based on Traveline Regions

· The current Traveline structure has evolved over time from a system that was designed to support telephone call centres into an all embracing data service for bus services across a variety of platforms. In recent years there has been a great emphasis on reducing bus operator costs but little attention has been paid to requests to address the public sector costs associated with data supply and management. Traveline appears to be still wedded to a Regional structure, even where the formal regional structure has been wound up, understandable in some ways as a means of coping with the proliferation of data sources and formats referred to above. What we need as a Transport Authority is to be able to receive data from bus operators in a standard format and transfer our consolidated data in the same format to the central repository without the added costs and workload associated with going through a middle man such as a Traveline Region.

Fare Data 

· In summary we believe that the task of providing fare information related to an individual journey is highly complex and in the first instance it may be advisable to provide general information on fares and ticketing options such as the availability of travel cards in place in a particular area.

· The provision of information on zonal fares such as Day Fares may be achievable in the short term provided that the system has the logic to interpolate the geographical boundaries for each individual fare which is not always clear from information provided by bus operators.

· The ability to provide meaningful information on point to point stage fares will prove a challenge, this is important in a rural county where a simple day fare structure may not be appropriate for a journey especially for shorter journeys and for single trips.

· While bus stop information is available in the NaPTAN database, the relationship of fare stages to bus stops is not, and fare stages will be operator specific so that two operators serving the same stretch of road may operate different fare stages.

· The magnitude of the task is greater than has been achieved in existing systems for providing transport fare information and we know that there has been controversy over the quality of fare information provided from such systems. The number of bus stops and fare stages is an order of magnitude greater than for instance the number of railway stations and journeys may involve transferring to one or more operator with the added complication of multi-operator tickets. There is also the additional feature of the availability of off peak fares in some areas by individual operators.

· As this data is entered and stored on the ticket machines that are used to set the charge that a member of the public will pay, there may be an opportunity for a standard data export format to access the data that is already available on the ticket machines, most of which are already capable of exporting data in standard formats such as .csv files for the bus operators own use in back office systems.

· In line with the proposals in the Bill for development Advance Ticketing Schemes covering multi-modal travel, any system for providing fares information must be designed with the capability to eventually provide end to end fares information for a multi-modal journey covering local bus, rail and coach options.

Impact Assessments 

Maintenance of bus stop and locality datasets 

Maintenance of all datasets is essential not just bus stop and locality datasets but also including the integrity of service information, Transport Authorities are best placed to maintain them.

There is a wider issue regarding ownership of bus stops, shelters and street furniture that the DfT may wish to consider with a mish mash of involvement by District Councils, County Councils and bus operators. Partnership and Franchising arrangements must address this.

Accessibility information requirement 

We have 3 comments

· While there is a requirement for bus operators to provide information on whether accessible vehicles are used on a service, a requirement that is largely redundant given the timescales for enforcing the PSVAR Regulations for vehicles over 22 seats, there is no indication of whether the bus stops that the customer wishes to use is accessible. Many stops are not accessible to wheelchair users due to location. For example in rural areas buses may not be able to deploy ramps because of the non availability of kerbs or hardstanding.

· The availability of Next Stop announcements would be a welcome improvement for all customers, especially those unfamiliar with the area. We have concerns that there will be a wide variety of solutions and lack of standardization in on bus equipment that will result in similar problems to those experienced today with bus displays when buses are redeployed around an operator's network. A more simple solution based on Smartphone using GPS would provide a base level functionality without the need for expensive on bus equipment provided that the NaPTAN database is maintained.

· The use of On Bus Displays for advertising could bring in additional revenue but there would be a need for guidance or in the case of Partnerships and Franchises powers to ensure that advertising is appropriate. For example we are aware of examples of inappropriate advertising including a bus carrying an advertisement for a Lap Dancing Club being used on a route that served a school and a bus carrying a poster with a suggestive image of a nurse being used on a route that served a Hospital.

Open data & registration, ticketing co-operation, franchising & partnership improvements 

We have covered these issues in our main narrative, with our views on the subject. We support the principle of mandatory release of information and installation of AVL devices on all vehicles used on registered and Section 22 services. Despite the financial incentives offered through BSOG and in the case of Worcestershire, the offer of equipment from the County Council, some operators, mainly local operators, will not come to the table as they do not see the value of the technological developments.

March 2017


Prepared 16th March 2017