INTRODUCTION

  1. The Confederation of Passenger Transport UK (CPT) welcomes the opportunity to comment on the Government's White Paper on the Future of Transport. The Paper is an imaginative and challenging document which aims not only to achieve integration "within and between different types of transport" but also integration with the environment, land use planning and other related policies. Clearly such a document relies on further detailed "daughter" documents to set out the way ahead.

  2. Since this response, to the Select Committee, is being produced in advance of the publication of the buses paper, there are naturally some qualifications in the detail and tone of our response. Nevertheless, if the daughter documents inherit the features of the parent this will auger well for the future.

BUSES

  3. CPT welcomes the enhanced role envisaged for buses through a system of Quality Partnerships. Evidence available to date demonstrates that much can be achieved through a voluntary system of co-operation between bus operators and local authorities. Although the Government has set out its intentions to legislate on aspects of Quality Partnerships it should not underestimate the outputs which can be achieved when agreements are reached on a voluntary basis. Indeed there are already strong incentives for operators to invest in new vehicles.

QUALITY PARTNERSHIPS—STATUTORY BASIS

  4. A number of voluntary Quality Partnerships exist around the country. All have been shown to have the potential to deliver a marked improvement in the quality of bus services offered to passengers. This in turn has resulted in an increase in passenger numbers: the most notable and recent introduction is in Manchester. It should be noted that Quality Partnerships do not involve bus operators and local authorities alone; in some cases they also involve train operators (e.g., through ticketing and better interchange), the police and other enforcement authorities, further increasing integration.

  CPT notes the Government's intention to bring forward legislation to put Quality Partnerships on a statutory basis. However, we believe that the urgent introduction and development of further partnerships is the key to delivering better bus services. For this reason the industry is keen to work with local authorities and other parties now, to bring about as many Quality Partnerships as possible on a voluntary basis in advance of primary legislation. Operators are demonstrating their willingness to invest, even when local authorities cannot immediately find complementary funds.

  Experience has shown that Quality Partnerships differ in the elements involved depending on local circumstances. For instance, a Quality Partnership covering rural services will be different in a number of ways to one covering primarily urban services. CPT agrees with the Government that local solutions to local problems should be agreed at local level through the Local Transport Plan.

  For that reason, the legislation introduced to put Quality Partnerships on a statutory footing must incorporate a level of flexibility which would enable each Quality Partnership to be tailored to meet local needs. The Office of Fair Trading (OFT) has to show itself to be understanding and willing to allow potentially anti-competitive arrangements when they are clearly in the consumers' interest.

QUALITY CONTRACTS

  5. The paper proposes to give powers (subject to Ministerial consent in each case) to local authorities to enter into Quality Contracts where it is in the public interest to do so. We believe that in the current co-operative climate the Minister will not have cause to give this consent. Such a power is franchising by another name and the industry is strongly opposed to such a proposal. In our submission to Government, prior to the publication of the White Paper, we demonstrated that franchising is a more expensive system of providing bus services than the present method. We further believe that franchising removes the incentive for operators to improve the quality and quantity of services which will ultimately result in a poorer service to the travelling public. Independent research was carried out which confirmed our view on this matter. Scarce resources should not be used in setting up Quality Contracts when the case has not been made that they improve customer satisfaction with public transport.

CONCESSIONARY FARES

  6. We welcome the Government's intention to introduce a national minimum standard for concessionary fare schemes for the elderly. This move recognises the expansion of the upper age groups in our society and the importance of equity of treatment for all. It is important that the funds required to improve the schemes that fall below the benchmark are not robbed from other public transport budgets. The industry believes that falling reimbursement levels for some existing schemes are likely to lead to a challenge if they continue.

PUBLIC TRANSPORT INFORMATION

  7. The industry recognises the importance of good public transport information for passengers. Whilst much has been achieved in some parts of the country, the perception by the public is poor. At present there are around 170 bus information "hot lines" around the country:

100 are operated by bus operators

64 are operated by local authorities and PTEs

a small number are jointly operated.

  This pattern has emerged as a direct result of the local nature of bus services and generally meets the requirements of existing passengers.

  Nevertheless, the industry recognises that potential new users are seldom knowledgeable on bus information and strangers visiting a town for the first time may not immediately know where to seek information. For these reasons the industry, in co-operation with local authorities and ATOC (Association of Train Operating Companies) are working on the introduction of a national enquiry service. The aim is to ensure existing systems are accessible by a national telephone number and the internet, working in harmony with the National Rail Enquiry Service. It is planned to meet Government targets of the system to be up and running by the end of the year 2000.

FUEL DUTY REBATE

  8. The rebate is a crucial part of keeping fares affordable to the passenger. The Government has promised consultation on targeting the rebate on rural services and more environmentally friendly vehicles. We foresee several possible consequences, not all of which are desirable, but we look forward to this consultation.

DRIVERS' HOURS

  9. Consultation is promised on the proposal to being domestic drivers' hours regulations into line with European long distance drivers' hours. This proposal will require very careful consideration, since the cost of this would be significant. CPT recognises that the juxtaposition of two sets of rules can be complex, but there is no evidence that current UK domestic rules are unsafe. In any case, most drivers use one set or the other, and this problem is more apparent than real. Alignment would lead to a prohibitive increase in the cost of providing bus services, both commercial and tendered. Inevitably such costs will be passed on to the passengers which will in turn deter them from using public transport. CPT is concerned that there are insufficient potential new bus drivers in the labour market to fill the gap caused by rising demand and artificially reduced working hours.

  It has long been recognised throughout Europe that domestic drivers' hours should be a matter for local determination and agreement. Clear distinction is made between the bus industry and heavy goods vehicle (HGV) operations. The bus industry believes that we should not be taken down this road simply because a problem is perceived to exist in the HGV industry. In any event changes should not be made in isolation from the proposed EU initiative on Working Time in transport.

WORKING TIME

  10. For some time the European Commission has sought to obtain agreement between the social partners on the regulation of working time in transport. Discussion have so far failed to produce any firm agreements in the Joint Committee which deals with the matter. It now appears that a proposed directive on the matter will be produced by the Commission. As stated in the previous paragraph, it would be wrong to act on one aspect, working time, without taking into account proposed changes for driving time.

TICKETING

  11. Guidance on good practice for through ticketing and travel cards will be produced. Already there are some excellent schemes which point the way to a future development, many at the initiative of but operators. For example, a bus passenger in a remote town in Oxfordshire can purchase a ticket on the bus which can incorporate a train journey and London Travelcard facility. An informal partnership of local authorities, train operators, bus operators, etc., have paid for the development of the technology to make this possible, CPT is taking this initiative forward at national level to secure greater integration of ticketing.

GUIDANCE ON COMPETITION BILL

  12. CPT believes that co-operation between bus and rail operators in the interest of passengers must be possible without falling foul of competition law. Already the OFT is aware of the thrust of Government policy in this area. During discussions on the Manchester Quality Partnership, there was helpful advice on those aspects of the partnership which were potentially anti-competitive but nevertheless in the interest of the passengers.

DISABLED ACCESS

  13. Policies on access to buses by the disabled are progressing. Bus operators already observe the spirit of the legislation in their policies, procedures and new vehicle orders. Already the vast majority of new buses are of low floor design. For example, all bus services provided by the major operator in the centre of Salisbury are all wheelchair accessible.

ROAD USER CHARGES AND CHARGES FOR WORKPLACE PARKING

  14. The ability of local authorities to charge for road use and workplace parking and to use the funds to improve public transport will be key to the success of achieving an integrated public transport system. However, it must be recognised that a reliable public transport service must be in place before the introduction of charges. This means early action on bus priorities and the development of good Quality Partnerships. In keeping with the Government's intention of devolving power to local decision makers, early action at local level by local providers and planners is essential.

TRANSPORT IN LONDON

  15. One of the responsibilities of the new Greater London Authority (GLA) will be a direct responsibility for transport in the capital. CPT welcomes this important move and advocates that the GLA should also assume responsibility for all the roads in London. This will result in more coherent planning of road public transport, especially where bus priorities are involved. It is important that the transfer of the Traffic Commissioner's licensing functions to Transport For London should recognise the capital's national and regional function and not be accompanied by unreasonably narrow criteria for services.

LIGHT RAIL

  16. We were disappointed to read that "funding for new major light rail schemes will not be a priority". Whilst we recognise the reasoning behind this view, we believe that there are circumstances where light rail provides the best solution to moving large numbers of people in a confined area. Although we welcome the encouragement to develop public-private partnerships to take forward such schemes, we would hope that the present view on public finance could be modified in special circumstances.

TRAFFIC COMMISSIONERS

  17. The industry welcomes proposals to strengthen the role of the Traffic Commissioners. For a number of years we have supported moves in this direction, particularly in the use of high entry standards to improve the quality of operations.

TRAFFIC MANAGEMENT

  18. All the research from numerous sources, shows effective traffic management is essential to deliver the reliable service that bus passengers require. No amount of investment in new vehicles will compensate for unreliability. Systems of priority on the roads, at pinch points and at traffic lights, are the minimum contribution that local authorities must make.

PLANNING

  19. The need for fundamental change to the local transport planning system will challenge the most committed of planners. It is clear to us that the new five year plans (drawn up in consultation with users and operators) will be pivotal to the achievement of the Government's aspirations. We note that plans are to be developed by Regional Planning Conferences (RPCs) who will work in close liaison with the Government Office for a region in partnership with Regional Development Agencies (RDA). RDAs will in turn have powers to ensure that regional transport plans help achieve sustainable economic development. It is not entirely clear how the above groups will relate to each other.

  We note with interest the proposals for Local Transport Partnership Groups, Rural Transport Partnership Groups and the Commission for Integrated Transport. Their plans must cover all forms of transport, bus Quality Partnerships, air quality, traffic congestion, road safety, and green commuter plans. We believe that substantial further thought needs to be given to the inter-relationship between all these bodies.

  It may well be that the best approach to this necessary but complex structure starts as a "bottom up" system. Otherwise it will be confusing for the partners. There is a clear opportunity to expand PPG 11 and PPG 13 to reflect these new policies.

GENERAL

  20. CPT represents the providers of bus, coach and light rail transport. We will be pleased to expand on any of the items raised in this submission.