SECTION 1—FIRSTGROUP

  FirstGroup is one of the leading UK based international passenger transport groups employing nearly 30,000 people. The Group is the largest bus operator in the UK and one of the largest train operators. In addition, the Group has a majority stake in Bristol International Airport and operates buses in Hong Kong.

SECTION 2—SUMMARY

  FirstGroup welcomes the publication of the Government's White Paper on Integrated Transport.

  It provides tangible proposals for improvements in public transport and the integration of road, rail and air. FirstGroup argues strongly that the private sector operators are best placed to help the Government deliver its promises on public transport. Delivering those promises is in the interest of both operators and of the Government.

  The Group looks forward to the publication of the daughter document on buses which we hope will add further detail to specific proposals to take the Government's vision forward.

  In particular:

—  We welcome the proposals to develop Local Quality Partnerships—we are already involved in more than 20 such schemes—we look forward to more. We see these as key to enable the bus to lead the transport revolution for the 21st century.

—  FirstGroup is keen to play its part—already this year we are buying over 900 new buses at a cost of £85 million specified to a modern design that we believe fulfils many of the objectives that John Prescott said he wanted. In Manchester we will shortly be introducing a new generation of low floor articulated buses—the first of this kind in the UK.

—  We also welcome the proposals for sensible restraint of cars in urban areas and believe it is crucial to the success of these initiatives that the funds raised will be ploughed back into priorities for local transport.

—  We look forward to working with local authorities to develop their Local Transport Plans.

—  We welcome the Government's commitment for a minimum half fare concessionary scheme for pensioners, but we would like to have further clarification as to how the scheme will be funded and confirmation that money will not be taken from other transport related local authority budgets.

—  We are pleased to see that the Government wishes to develop a national integrated transport information service by 2000. We will play our part in developing this vital part of the service which we need to provide to our customers. We look forward to being involved with other operators and the Government in discussions and proposals to achieve this aspiration.

—  We welcome the further commitment to the Strategic Rail Authority in particular to enable better co-ordination of all parts of the rail network.

—  We hope that legislation can be introduced as quickly as possible to achieve these goals but believe that many of the changes can be achieved within the current framework given goodwill by all concerned.

SECTION 3—BUSES

Quality Partnerships

  FirstGroup welcomes the proposals for improving public transport and in particular the endorsement of public/private partnership to deliver better bus services. The Group has been at the forefront in developing Quality Partnerships and believes that the further development of these schemes is the key to providing improvements in bus services very quickly.

  We believe that it is now possible to move forward very rapidly to develop Quality Partnerships on a voluntary basis across the country. It should be possible for the private sector to work with local authorities to put Quality Partnerships on a firm footing without the need to wait for further primary legislation.

  The Group does not believe that it is necessary to develop more formalised Quality Contracts that would in effect be franchise arrangements. We believe that franchising will prove to be an inflexible and bureaucratic system which will reduce the incentive for operators to improve the quality and quantity of services, to the detriment of the travelling public. We believe that the threat of Quality Contracts could undermine our ability to work with local authorities and to generate new investment through Quality Partnerships.

  If the Industry does not have the longer term security of being able to work with local authorities on a voluntary basis it will undermine its investment strategy and discourage long term capital planning in both vehicles and infrastructure. A 1 per cent or 2 per cent modal shift in traffic from cars to buses could result in up to 50 per cent increase in bus passengers over three years. Such a shift will only be sustained if sufficient investment is made to encourage and cope with the extra passengers. If it is felt that Quality Contracts are needed we believe that the circumstances in which they would be used should be very specifically explained, as it is in the White Paper for Scotland. Quality Contracts should only be available as a last resort after a Quality Partnership has irretrievably failed.

  In order to prove the viability of the voluntary Quality Partnership route we believe that a number of pilot schemes should be promoted as soon as possible. This would enhance their credibility for delivering public transport growth and demonstrate the ability of the industry to move forward quickly without the need for primary legislation. FirstGroup has already taken the lead in developing Quality Partnerships with over twenty schemes signed with local authorities across the country. In addition FirstGroup is now talking to a number of local authorities on ways in which we can take the Quality Partnership concept forward to the next stage.

  To this end the Group has put forward its Twin Track proposals under which we would fund up to 50 per cent of the cost of any new Quality Partnerships initiatives. We have indicated that we would be prepared to commit up to £50 million to get such schemes up and running. We are very keen to work with local authorities to promote these initiatives and in order to move the process forward quickly the Group will consider funding in excess of 50 per cent of the costs of such schemes in the first year, provided guarantees of local authority contributions in future years could be made. Specifically, we have made offers of funding in excess of £6 million for projects in Leeds and Manchester.

  FirstGroup acknowledges that private sector operators have a responsibility to facilitate the construction of bus infrastructure particularly if government and local authorities are also prepared to make that investment. In Twin Track we have devised a mechanism that will enable us to make an even greater contribution to Quality Partnerships and we would welcome the opportunity to take this idea further with the Government and to see schemes implemented prior to any new legislation.

Rural Bus Services

  We welcome the Government's announcement of additional spending on rural bus services. We believe that it is important that the most effective use is made of this funding. In particular we believe that consideration should be given to developing corridors where an attractive service frequency can be provided at a realistic cost with other modes of transport such as cycles, post and community buses and cars feeding into connectional nodes where services such as heated waiting rooms and retailing facilities can also be provided. We do believe that it is unrealistic to envisage the provision of services in excess of the "subsistence level" of more than four return journeys per day in isolated parts of the country. In many cases best value for money could be achieved by extending existing services rather than tendering for new services which themselves threaten the commercial viability of existing routes. Private operators should be involved in any further discussions with local authorities on how improvements to the provision of rural bus services can be achieved.

Enforcement

  We strongly endorse the Government's proposals to examine ways of improving enforcement of bus priority lanes. Whilst the priority lane is often the most cost effective way of improving the reliability of urban bus services, it is also the most open to abuse. Not only does this inconvenience all of the passengers on the bus but also encourages frustration and "road rage" from law abiding car users who witness infringements.

Bus design

FirstGroup has already developed a high specification design for all its new buses which incorporates low floor access, double glazing, better climate control and extra leg room as well as engines which comply with the new Euro 2 emission standards. We believe that our design goes a long way to achieving the aims set out in the White Paper. We believe that we are at the forefront in bus design and we look forward to taking a lead in future developments.

Drivers' hours

  The Group does not believe that it is necessary to introduce EU regulations which govern drivers hours. There is no indication that the current UK legislation endangers passenger safety. In addition, we do not believe that there is confusion between UK and EU regulations, as the vast majority of urban bus operators are covered by UK legislation alone. Any restriction on drivers hours would increase costs, bring uncertainty to the provision of more marginal bus services and potentially create a shortage of drivers at a time when the industry is expanding.

Tax Incentives

  The Group welcomes the Government's commitment to increase the duty differential between ordinary diesel and ultra low sulphur diesel (USLD) FirstGroup is rapidly moving to a position where all of its bus fleet will use ULSD. Together with the use of catalytic converters this will be as effective in terms of air quality as natural gas, which has proved to be a more expensive and less viable alternative. The Group also welcomes the proposal to provide incentives for public travel through the tax system, We would welcome the opportunity to take part in the discussion to formulate such proposals.

London

  The Group welcomes the proposals for the new Greater London Authority (GLA) to have responsibility for transport within London. We believe that it is important that the GLA takes a lead in producing policies to integrate bus, train and road transport within the capital.

SECTION 4-RAIL

  The Group supports the establishment of the Strategic Rail Authority and believes that this will be helpful in providing a better method of ensuring the effective development of the railway system for both passengers and freight. In some cases the privatised rail network has had a painful birth. FirstGroup does not set out to make excuses for the recent run of poor performance expect to say that it should be remembered that investment in the last years of British Rail was extremely poor—particularly in the infrastructure. While we believe that there is reason to think that the performance of many TOCs is improving, it should not be forgotten that only the private sector is likely to fund the necessary investment in the future and that a secure regularity situation will facilitate this.

  The Group wholly supports the Government's desire to improve passenger rail services and welcomes the opportunity to develop a framework for renegotiating franchises. In certain circumstances improvement in rail services can only be achieved by further investment in new infrastructure and rolling stock which will require the longer term perspective given by the security of franchise extension.

  We welcome the proposals to review the regime for setting Railtrack access charges and we are encouraged by the creation of the Infrastructure Investment Fund and the Rail Passenger Partnership. We hope to paly an active part in the development of new infrastructure investment proposals as part of our longer term rail investment strategy.

SECTION 5-MAKING IT HAPPEN

Structures

  We welcome the proposal to establish a Commission for Integrated Transport and for the development of local transport plans. However we believe that clarification is required as to how co-ordination will be achieved between local authorities, PTA/Es, Regional Development Authorities, regional planning conference and the Commission for Integrated Transport. It is important that the new planning structures facilitate initiatives and development rather than forming a bureaucratic barrier to progress. We look forward to working closely with local authorities and other planning bodies in the preparation of local transport plans and Regional Planning Guidance.

Funding

  The Group welcomes the White Paper's commitment to local public/private partnerships to finance major transport schemes. We also support the proposals to introduce legislation to enable local authorities to charge road users so as to reduce local congestion. We recognise, however, that improvements to local transport services must come first, before it is reasonable to expect car users to transfer to alternative means of transport. It is for that reason that we believe that it is fundamentally important to put in place improvements to transport services as soon as possible. If this proves to be a temporary problem in terms of funding in the early years, we are prepared, as we have outlined above in our Twin Track proposals, to provide front end capital investment to kick start some of these programmes.

SECTION 5—OTHER ISSUES

  We welcome the White Paper's endorsement of the Confederation of Passenger Transport initiative to establish an Independent Bus Appeals Body. We support the White Paper proposals for a wider role for the Traffic Commissioners. We would like to be included in the consultation process as to how the role should be widened.

  The Group believes that the White Paper strikes the right balance in relation to Light Rail. We believe that it is important to pursue cost efficient proposals and that Light Rail will therefore have only a limited role in certain specific areas.

  We support the development of a National Transport Information System. However we believe that it is important that the system retains the flexibility to change and develop services as required.

  The Group is already actively developing bus and rail integration and welcomes the White Paper's encouragement to pursue this. We believe, however, that the Government will need to resolve the issue of the potential impact of the Competition Bill in a clear and unambiguous way to ensure that co-ordination and co-operation between operators is not deterred.

SECTION 6—CONCLUSION

  In conclusion, FirstGroup is already well advanced in developing Public/Private Partnerships. We therefore believe that we are very well placed to work closely with the Government and local authorities to help them achieve the ideals outlined in the White Paper. We would suggest that three cities are used to show the impact of the immediate implementation of our proposals—Leeds, Manchester and Sheffield. Leeds and Manchester have already agreed and submitted their plans and we have put together a plan for matched funding of certain projects over the next three years. FirstGroup is therefore ready and willing to play its part in the development of an integrated transport strategy for the next century.

September 1998