18.The provisions on partnerships and franchising in the Bus Services Bill provide LTAs with a number of options for running bus services in their local area. We heard a wide range of views on the merits and disadvantages of each of these options. Our principal concern in assessing this evidence was whether the proposals would improve the passenger experience and encourage greater use of buses. In doing so, we build on the work done by our predecessor Committee, particularly in relation to its reports Competition in the local bus market and Passenger transport in isolated communities.
19.We received evidence suggesting that current partnership structures were often an effective framework for bus services because they gave the LTA opportunities to develop a more joined up and coherent approach to bus services while allowing the operator to invest and react to customer demand flexibly. For instance, both National Express and the West Midlands Combined Authority gave the West Midlands Bus Alliance as an example of a successful partnership, which had allowed improvements such as integrated timetabling and joint ticketing products to be agreed. FirstGroup told us that a successful partnership in Bristol had provided for new ticketing schemes, simplified and cheaper fares and encouraging passenger growth.
20.Much of the evidence we received welcomed the new forms of partnership proposed in the Bus Services Bill, as they would allow greater co-operation between operators and LTAs than was previously possible, thereby providing a more integrated network for customers. The Urban Transport Group told us that the QPS had proved useful to a wide range of LTAs and welcomed the AQP as an approach that built on these experiences. The EPS provisions were seen by many as providing even greater opportunities. Cornwall Council has said that partnerships are its preferred approach, with franchising powers to be kept in reserve. Nigel Blackler OBE elaborated on this, describing how Cornwall Council had worked effectively with local operators in agreeing a bus strategy:
The operators’ commitment, which we have seen since the deal was signed, in terms of new vehicles coming into Cornwall for the first time and working on ticketing initiatives and real-time information, shows a very positive response from the industry. We are greatly encouraged. If we continue in that way, we believe that enhanced partnerships may well be the best solution for Cornwall.
21.Similarly, Giles Fearnley of the Confederation of Passenger Transport and Managing Director of FirstBus told us “what really excite us in the Bill are the enhanced partnership opportunities. There is so much more that can be done working with local authorities and the enhanced partnership framework.”
22.There have long been concerns about the effectiveness of competition in the bus services industry. Some witnesses suggested that the new partnership structures could undermine proper competition by favouring incumbents. Across the country as a whole, more than two thirds of bus services are accounted for by FirstGroup, Stagecoach, Arriva, Go-Ahead and National Express (sometimes referred to as the “Big Five”). A 2011 Competition Commission investigation into the bus services market found a lack of competition and that one or two operators dominated in many local areas. A subsequent inquiry by our predecessor Committee highlighted the problem of large incumbent operators failing to provide sufficiently good service. In this inquiry, we heard that lack of competition continued to be an issue, for instance with Transport for Greater Manchester submitting evidence suggesting a lack of head to head competition in Greater Manchester. We note, however, that this evidence was challenged by Stagecoach and other bus operators.
23.Some operators outside of the “Big Five” told us that partnerships risked concentrating power in the hands of dominant, and particularly incumbent, operators. Under partnerships, operators must meet certain requirements, which in the case of an EPS in particular, have the potential to be relatively extensive. In addition, an EPS can only be implemented where “sufficient” operators do not object. The Government has yet to set out how the voting mechanism determining this will work in practice.
24.We were told by Dai Powell of HCT that partnerships could undermine competition by raising the barriers to new entry. Respondents also expressed concern that the EPS voting mechanism could provide the dominant operator with an effective veto over an entire scheme. This echoes the Competition and Markets Authority (CMA)’s recommendation that the voting mechanism should ensure that the views of smaller operators are sufficiently taken into account. The Government has accepted the CMA’s recommendations and recognises that the voting mechanism will need to reflect the local market. However, we also consider that a large number of operators with a very small market share should not be in the position to veto a scheme endorsed by few operators with a large majority of the market share.
25.However, while maintaining competition is important, we also note concerns that competition requirements may effectively undermine franchising or partnership proposals. West Midlands Combined Authority stressed the need for clear guidance on how competition law would apply to an EPS, telling us that it would not pursue a scheme where there was any doubt over competition compliance. Similarly, some members of the House of Lords expressed concerns that the CMA would be able to open lengthy and expensive competition investigations into finalised schemes even where it had already been consulted on the development of the scheme.
26.Advanced Quality Partnerships and Enhanced Partnership Schemes have the potential for delivering greater benefits by allowing local transport authorities and operators to work together more intensively. However, there is a risk that Enhanced Partnership Schemes could entrench the position of dominant operators. We welcome the Government’s commitment to take into account the specific aspects of the local bus market in developing the Enhanced Partnership Scheme voting mechanism. The Government should publish further detail regarding the voting mechanism as soon as possible to allow the House of Commons to scrutinise the possible impact of Enhanced Partnership Schemes on competition.
27.The evidence we received in relation to franchising broadly fell into two categories. Some respondents said that franchising created few benefits and significant risks, and proposals to introduce franchising should therefore be subject to greater regulatory control. Others suggested that franchising could produce significant benefits, and that the Bill should therefore be amended to allow LTAs other than mayoral combined authorities to franchise without requiring further consent.
28.We heard from witnesses who suggested that franchising was unnecessary. Some said the objectives LTAs seek to achieve through franchising can be—and are being—achieved through partnerships. In oral evidence, Mr Fearnley of the Confederation of Passenger Transport told us:
We seriously question what franchising can offer that serious partnership between authorities and operators cannot deliver. To look at an example, last November in Sheffield a revised new partnership was implemented between operators, the Passenger Transport Executive and the City Council. It has created a network that, in the combined authority’s words, is close to what they would have prescribed under a franchise.
29.This view was disputed by other witnesses, who suggested that partnerships could never deliver full network and fares integration. Network integration allows passengers to make a journey across the network easily, and involves, for instance, integration between bus timetables and those of other transport modes and simple ticketing. We heard evidence of dominant operators frustrating LTA partnership proposals designed to create a more integrated customer experience; Kent County Council, for instance, told us that the two largest operators in its area refused to participate in its multi-operator smart card because they preferred to use only their own cards. Moreover, competition law limits the extent to which even willing operators can co-operate, as demonstrated by the CMA’s recommendation that partnership schemes should not restrain operators from making their own decisions on fares. As Andy Gibbons of Nottingham City Council told us: “On integrated ticketing, uniformity, simplification and one simple smart system would only be solved through the franchising side”.
30.The introduction of franchising moves competition from in the market (operators competing on the roads for passengers) to for the market (operators competing to operate a particular service). David Williams of KPMG told us that:
London works because it gets part of its value from the attractiveness of the market. It gets good competition for contracts. It is a big market.
It is possible that there would be minimal interest in smaller markets that are unable to generate the same interest in their contracts as London. In addition, small and medium sized operators who may struggle to meet franchising requirements could also be excluded from the market.
31.We note that the Department has already accepted a number of recommendations from the CMA designed to ensure that LTAs fully consider the competition implications of their proposals. Abellio and Dr Jon Lamonte from Transport for Greater Manchester told us franchising mechanisms could drive up standards and encourage innovation. It is also possible that franchising may be a means through which the longstanding concerns about competition in the bus services market (discussed in paragraph 22 above) are addressed. Barriers to entering the commercial market and a dwindling number of subsidised services mean many smaller and medium sized operators are currently struggling.
32.The Bill requires LTAs putting forward franchising proposals to consider small and medium sized operators; we received evidence suggesting that such operators could be accommodated through breaking franchises up into a series of small contracts or creating opportunities for operators to work together. We note that head to head competition does not necessarily guarantee greater diversity of operators than competition for contracts under the current system. Transport for Greater Manchester told us, for instance, that small operators account for 36% of their current financially supported market, compared to less than 8% of the commercial network.
33.We heard from witnesses who suggested that risks associated with the LTA assuming responsibility for planning and managing a bus network were such that the Bill needed greater checks and balances. In particular, this was the lesson that some operators drew from the Tyne and Wear Quality Contract Scheme (QCS) proposal. A QCS allows LTAs to introducing a franchising style system, but only if they can satisfy an independent board that the proposal meets a five part public interest test. In November 2015 the QCS proposal in Tyne and Wear was found to not meet the public interest test. Martin Dean of Go-Ahead told us that this process:
[ … ] showed that the need for independent scrutiny, as I mentioned before, served the customer and the council tax payer well because it exposed a scheme that was just not workable. Franchising needs to be independently scrutinised. It needs the ability of professional organisations and interested bodies such as bus operators to scrutinise the proposals and then to advocate our position in front of an independent panel.
34.However, we received evidence suggesting that the real lesson to be drawn from Tyne and Wear was that the QCS process was too time consuming and expensive and effectively prevented LTAs from making use of this power at all. It is worth noting that both we and our predecessor Committee expressed concerns about the complexity of the process before the experience of Tyne and Wear. In its evidence, Merseytravel emphasised the Bill should avoid replicating these unworkable arrangements. Significant checks and balances also already exist in the Bill; any LTA that wishes to franchise must, for instance, undertake an assessment of the proposed scheme (including comparing it to other courses of action), obtain a report from an auditor of the assessment and consult widely with affected parties.
35.The Bill, as originally introduced, distinguishes between mayoral combined authorities, who are automatically entitled to introduce a franchising scheme, and other LTAs, who must undertake a two stage process requiring regulations for the category of LTA and the consent of the Secretary of State. The criteria that the Secretary of State would use in deciding whether or not to grant consent are described in outline in a policy statement published on 12 October 2016. The Department’s rationale for this distinction was that only mayoral combined authorities have the clear, centralised decision making and required powers and governance arrangements for transport across a relatively wide area to warrant automatic franchising rights. The House of Lords amended the Bill so that all LTAs can immediately commence a franchising assessment, without the requirement for regulations or the consent of the Secretary of State.
36.A number of respondents pointed out that the two step process in the original Bill risked closing off the potential benefits of franchising to rural areas, which are already bearing the brunt of local authority reductions to subsidised bus services, by requiring a potentially long and cumbersome process. KPMG concluded that franchising is likely to be particularly viable in some areas, for instance where buses are integral to the overall transport network, trip patterns are complex and the LTA is relatively large. It is true that metropolitan areas may be more likely to have these attributes. However, we were also struck by the evidence given by Dai Powell, chief executive of HCT Group, about his experiences of franchising in Jersey:
We operate a franchise in Jersey that we have operated for three years. The population is only 100,000 people. We took it over from another company three years ago. We have saved the States—the local authority there—over £1 million by doing it. We have increased passenger numbers by 30% in three years and given back a profit share to the States so that they can put in pro-bus measures [ … ]. You can do that in a rural area. It is not expensive to do.
37.We also received evidence querying the rationale for the distinction. The Government insists that it is giving mayoral combined authorities automatic access to franchising powers because they have clear, centralised decision-making for transport. Essex County Council and Cornwall Council told us that they already had similar accountability structures through elected councillors acting as executive Cabinet members. However, as noted above, certain conditions are likely to be necessary for a franchising scheme to be successful, and not all LTAs who are mayoral combined authorities can be assumed to have these attributes. For instance, the draft criteria which the Secretary of State would use to give consent would require LTAs to demonstrate that franchising could be put into practice effectively across the geography of the area, which could present difficulties, for example where highway powers remain with constituent councils.
38.Lord Ahmad of Wimbledon, Parliamentary Under Secretary of State for Transport, suggested that the requirement for regulations for each category of LTA other than mayoral combined authorities to franchise would enhance scrutiny by allowing Parliament to debate the broadening of access to franchising powers. In our view, the House of Lords and House of Commons should be able to debate which categories of LTA should be allowed to franchise during the Bill’s passage through Parliament, rather than delaying the discussion through the mechanism of secondary legislation.
39.Moreover, the policy statement outlining the criteria which the Secretary of State would use in deciding whether to exercise his power of consent was not published until 12 October 2016. At that point the Bill had reached Report Stage in the House of Lords. It is described as “initial draft guidance” which is “intended to outline some of the potential content” of the guidance which will be produced alongside the Bill. As noted by the Lords Delegated Powers and Regulatory Reform Committee, it is difficult to assess whether it is appropriate to delegate to the Secretary of State a power of consent for non-mayoral combined authorities when the criteria for that consent are not known.
40.Franchising has the potential to deliver benefits that cannot be achieved by partnerships. While there are some risks associated with franchising, these are mitigated by existing safeguards in the Bill. In our view, it is primarily for the local transport authority to decide whether or not franchising is appropriate for any particular area and we agree with the majority in the Lords that the process set out in the Bill as introduced is unnecessarily cumbersome.
41.We accept that there may be a case in principle for reinstating the secondary requirement for the Secretary of State’s consent before any individual authority other than a mayoral combined authority can franchise. However, this has been difficult to assess, in part because the draft guidance was not available for our witnesses to consider when they gave evidence to us. If the Government wishes to reinstate the consent requirement, it must produce more detailed guidance on how the Secretary of State will exercise these powers. A key consideration for the Secretary of State would be the extent to which the proposals for franchising ensure small and medium sized operators are not prevented from entering the market. The detailed guidance must be produced in good time for the Commons Public Bill Committee stage.
42.Franchising is at the heart of this Bill. The Committee is concerned that key elements relating to this provision are still not available for scrutiny while other parts are only available in draft. This is not the first time this has happened and it is unacceptable. The Government should commit to publishing all relevant draft secondary legislation and guidance when a Bill is introduced into Parliament.
43.Under franchising schemes, operators can only provide bus services where contracted to do so by the LTA, or unless the LTA agrees otherwise. We heard from operators who described the move from a deregulated market to a franchising system as “confiscation” or “expropriation” because it meant that they would no longer be free to offer bus services as they chose. For instance, the Wellgrade Group told us that the Bill would undermine the substantial goodwill and investment it had built up in its business over many years. We also note that in the Tyne and Wear QCS process, the Board found that there could be a case for compensation.
44.We appreciate that franchising represents a significant disruption for established operators. However, franchising does not prevent operators from providing bus services at all; it simply requires operators to compete for the market rather than directly for passengers, or to obtain consent from the LTA to run a service not covered by a franchising scheme. There is no case for compensation where a dominant operator loses market share to a challenger in head to head competition or the funding for a supported bus service is cut by the LTA. On the same basis, we do not consider there to be a case for compensation if an operator is unable to win a contract under franchise from the LTA. Moreover, introducing a requirement for compensation would act as a significant disincentive for an LTA to franchise, even where this is in the best interests of the local community.
45.We accept that the question of whether incumbent operators would suffer a loss from franchising is a complex one. However, franchising does not mean operators already providing bus services in the market cannot compete; it simply means that they must compete for the market rather than for passengers as they do at present. There is no case for compensation for operators in areas where the local transport authority decides to introduce franchising.
46.As discussed above in paragraph 7, funding for bus services has been under pressure in recent years. The Government has made it clear that no additional funding for LTAs will be available under the provisions contained in the Bill. Witnesses from Urban Transport Group and Transport for Greater Manchester suggested that there was no reason why franchising or partnerships necessarily needed to cost LTAs more money in the long term if these approaches facilitated growth on the network and generated additional revenue. Nigel Blackler of Cornwall Council echoed this in relation to the rural context, arguing for the need to:
[ … ] bring some of our funding into the bus system in Cornwall, as we have done on rail, to bring it up to a comparable standard and bring the two together. We believe that if we can do that, we can significantly increase the number of passengers using public transport in Cornwall; and if we can do that, we will get more money back through the fare box and more of the network will become financially sustainable going forward.
47.Lord Ahmad has committed to devolve BSOG where franchising is implemented, so that it is paid on a non-ring fenced basis directly to the LTA rather than to the operator. The rationale for this approach is that by pooling subsidies in a franchised system, they can be used more effectively. However, the detail of how BSOG will be dealt with at a devolved level is still unclear. When the Permanent Secretary, Philip Rutnam, recently appeared before us in relation to the Departmental Annual Report and Accounts he reaffirmed the approach of giving “local authorities as much freedom as possible in how to use the funding. It is the whole philosophy of devolution, removing ring-fencing around grants and trying to provide significant continued funding for local transport.” Andy Gibbons of Nottingham City Council told us that BSOG should also be devolved where there is an EPS.
48.In our view, the logic of this approach applies not just to franchising schemes but also to partnership approaches which give an enhanced role to the LTA in developing and managing integrated networks.
49.Franchising and partnership schemes have the potential, where successful, to partially address the funding pressures currently facing bus services by increasing full fare passenger numbers. We welcome the Government’s commitment to devolve BSOG where franchising is implemented. We recommend that the Government also commits to devolving BSOG to those authorities who implement an Enhanced Partnership Scheme or Advanced Quality Partnership.
50.At present, there is no legal requirement for bus companies to consult with affected parties where they propose to alter or withdraw bus services; consequently consultation is patchy at best. We received examples of operators stopping services integral to the local community with short notice and making frequent changes to routes and timetables. Equally, we were told of local authorities failing to consult when withdrawing subsidies for supported services.
51.In our view, it is unacceptable not to involve parties affected by proposed changes to bus services in the relevant decision making process. We are therefore encouraged by the provisions of the Bill which require LTAs to consult with a wide range of groups, including operators and organisations representative of users of local services in developing an AQP, EPS, franchising scheme or Advanced Ticketing Scheme. We also welcome the Government’s amendment in the Lords to include Transport Focus as a statutory consultee in relation to franchise and partnership schemes.
52.Franchising schemes can have a significant impact on factors which affect the working conditions of employees, including in relation to where and when they work, what standards they are expected to meet, and the environment in which they carry out their duties. It is therefore appropriate that LTAs consult with affected employees when introducing these proposals. However, it is also possible that partnership schemes could also have a significant impact on employees by changing the nature of the service. A Government amendment included consultations with appropriate representatives of affected employees as a requirement for franchising proposals. In a Government defeat, an amendment extending the same consultation right to employees affected by a proposed AQP was also passed in the Lords. This leaves an anomaly insofar as LTAs only need to consult with their employees where introducing franchising or an AQP, but not an EPS.
53.We also note the debate in the House of Lords around the possibility of allowing communities to designate certain bus routes as assets of community value. If accepted, such a provision would give the community at least six months’ notice of closure. The Government objected to this provision on the basis that it would require an operator to continue to operate a service considered financially unsustainable for six months. In addition, Lord Ahmad noted the support already provided by Government to community transport. In particular, the Total Transport pilot project seeks to assist local authorities integrate transport services currently commissioned by different central and local government agencies and provided by different operators. The aim of this approach is to allow existing resources to be allocated and co-ordinated more efficiently. While we welcome these initiatives, our predecessor noted that it is unrealistic for Government and local authorities to expect voluntary community transport projects to compensate for decreased bus services.
54.It is right that those affected by proposed changes to bus services have an opportunity to contribute to the decision making process. We welcome the Bill’s emphasis on consultation with bus users and employee representatives. We recommend that the Bill be strengthened by agreeing an amendment requiring LTAs proposing Enhanced Partnership Schemes to consult with the appropriate representatives of any affected employees. This would bring the provisions around employee representation for Enhanced Partnership Schemes in line with those for franchising and Advanced Quality Partnerships. We also support the proposal to allow communities to designate bus routes as community assets.
55.As highlighted by our predecessor Committee, passenger transport services are essential to allow isolated communities to fully participate in society. In the context of continuing cuts to local authority budgets, the Bus Services Bill can only be part of the solution in protecting local transport services in isolated communities. The Government must explain how its devolution agenda will help to support local communities to maintain often critical bus services that nevertheless require ongoing financial support.
56.The prohibition on LTAs from setting up new bus operators is one of the more controversial aspects of the Bill. The Government’s rationale for the prohibition is that the same LTA that is specifying services (as would be the case under a franchising system) should not also own an operator which can then bid for those services. Such a scheme is also likely to attract significant scrutiny from the Competition and Markets Authority, which may make it unviable in any case. Some of the operators who submitted evidence echoed these competition concerns; in addition, Go-Ahead told us that LTAs did not have the skills and experience to run bus companies.
57.However, the vast majority of evidence we received in relation to the prohibition on new municipal operators, including almost 2,000 emails from members of the public, supported its removal from the Bill. A number of respondents pointed to the particularly good performance of existing municipal bus operators such as those in Reading, Nottingham and Edinburgh. We also heard that municipal bus operators tended to be more accountable to local communities and passengers than those run by the private sector. Others argued that the clause ran counter to the direction of the rest of the Bill in allowing LTAs to determine what model was most appropriate to their particular area. Cornwall Council also told us that the recent failure of a number of bus operators made it necessary for the LTA to be able to operate a bus service as a last resort, lest some communities be left with no services at all. This is particularly a risk in some rural areas where bus services are less commercial and there are fewer public transport alternatives.
58.The prohibition drafted in the Bill as introduced into the House of Lords applies to all LTAs. This is the case even though the potential conflict of interest only arises under franchising, and only a small minority of LTAs are likely to introduce franchising. In addition, mandating an arm’s length relationship between the operator and the LTA should do much to manage the real or perceived risk of unfair competition.
59.There are some circumstances, for instance where no private operator is willing and able to operate socially necessary services, where it would be appropriate for a local authority or group of authorities to set up their own operator. We accept that there is the risk of a conflict of interest where the authority has decided to implement franchising and that such a conflict could seriously delay or perhaps even prevent a franchising scheme from coming to fruition. However, the current prohibition on all new municipal operators in the Bill is a disproportionate response. We encourage local transport authorities to assess the benefits of partnerships and franchising before they consider setting up a municipally owned operator. The Government should produce guidance setting out the measures it expects local authorities to put in place to ensure that an arm’s length relationship is maintained.
23 Transport Committee, Third Report of Session 2012–13, , HC 10; Transport Committee, Fourth Report of Session 2014–15, , HC288
24 See for instance, Transport Focus (); Wellglade Limited ()
25 National Express Bus (); West Midlands Combined Authority ()
26 FirstGroup plc ()
27 Urban Transport Group ()
28 Cornwall Council, [Accessed 1 November 2016]
29 [Nigel Blackler]
30 [Giles Fearnley]
31 DfT, , 23 September 2014
32 Competition Commission, , December 2011
33 Transport Committee, Third Report of Session 2012–13, , HC 10
34 Transport for Greater Manchester ()
35 Stagecoach UK Bus ()
36 See for instance, RATP Dev UK (); Tower Transit Group ()
37 [Dai Powell]; see also HCT Group ()
38 See for instance, Bath & North East Somerset Council (); Dr John Disney ()
39 Competition and Markets Authority, , 29 July 2016
40 DfT, , May 2016, p27; , 12 October 2016
41 West Midlands Combined Authority ()
43 See for instance, Stagecoach UK Bus (); The Association of Local Bus Company Managers (ALBUM) (); [Martin Dean]
44 See for instance, Community Transport Association (); Essex County Council (); Trades Union Congress ()
45 [Giles Fearnley]; see also [Robert Montgomery]
46 North Ryedale Public Transport Group ()
47 Kent County Council (); see also Urban Transport Group ()
48 , 29 June 2016
49 [Andy Gibbons]
50 [David Williams]
51 See for instance, Bus Users UK (); Wellglade Limited ()
52 , 29 June 2016
53 Abellio (); [Dr Jon Lamonte]
54 [David Williams]; [Dr Disney]; [Nigel Blackler]
55 HCT Group (); Cornwall Council ()
56 Transport for Greater Manchester (); Transport for Greater Manchester ()
57 FirstGroup plc (); [Robert Montgomery]
58 QCS is abolished in England by this Bill, but will continue to exist in Wales
59 QCS Board, , November 2015
60 [Martin Dean]
61 See for instance, Tower Transit Group (); Tyne and Wear Public Transport Users Group (); Unite the Union ()
62 Transport Committee, Third Report of Session 2012–13, , HC10, para. 68; Transport Committee, Fourth Report of Session 2014–15, , HC 288, para. 20
63 Merseytravel ()
64 DfT, , 12 October 2016
65 DfT, ,16 June 2016
67 See for instance, Campaign for Better Transport (); Community Transport Association (); TravelWatch NorthWest ()
68 KPMG, , January 2016, p.11
69 [Dai Powell]
70 DfT, , 16 June 2016
71 See for instance, Essex County Council (); Cornwall Council ()
72 DfT, Bus , 12 October 2016
74 DfT, Bus , 12 October 2016, para. 1
75 Delegated Powers and Regulatory Reform Committee, First Report of Session 2016–17, ., HL Paper 13, para. 9
76 See for instance, The Association of Local Bus Company Managers (ALBUM) (); East Yorkshire Motor Services Limited (); The Chartered Institute of Logistics and Transport ()
77 Wellglade Limited ()
78 QCS Board, , November 2015
80 [Frank Rogers]; [Dr Jon Lamonte]
81 [Nigel Blackler]
82 , 4 July 2016;
83 Merseytravel ()
84 [Philip Rutnam]
85 [Andy Gibbons]
86 See for instance, Dr John Disney (); Community Transport Association (); Cllr John Bull (); Cllr Michael Base ()
87 [Claire Walters]
89 RMT (); Trades Union Congress (); Unite the Union ()
94 DfT, , 14 January 2016
95 Transport Committee, Fourth Report of Session 2014–15, , HC288, para. 37
97 The Association of Local Bus Company Managers ALBUM (); The Go-Ahead Group plc ()
98 See for instance, We Own It (); East Midlands Later Life Forum ()
99 See for instance, Unite the Union (); Bus Users UK (); Finn Smith ()
100 [Claire Walters]
101 HCT Group (); Kent County Council (); Merseytravel ()
102 Cornwall Council ()
22 November 2016