Uncorrected Evidence lco4

Written evidence from SWWITCH (SB LCO 4)

The South West Wales Integrated Transport Consortium (SWWITCH) supports the principle of conferring the legislative competence in the areas under consideration to the National Assembly.

SWWITCH does however, have concerns about the subsequent application and the impact on costs and capacity to the public and private sector. SWWITCH is keen that the application of the LCO is worked through with Local Authorities in Wales to ensure consistency and the realisation of intentions behind the Order.

1.0	BACKGROUND
1.1	The South West Wales Integrated Transport Consortium (SWWITCH) was formed in 1988 and comprises the four south west Wales authorities: · Carmarthenshire County Council · Neath Port Talbot County Borough Council · Pembrokeshire County Council · City and County of Swansea SWWITCH is formally established as a Joint Committee of the four local authorities and meets quarterly.
1.2	The SWWITCH remit includes all forms of transport and wider access issues including land use planning integration, sustainable transport and behavioural change.
1.3	SWWITCH is one of four transport consortia in Wales supported by the Welsh Assembly Government and working closely with the Assembly on the planning and delivery of improved access to residents, visitors and businesses in and beyond Wales.
2.0	INTRODUCTION
2.1	SWWITCH is pleased to respond to the invitation from the Welsh Affairs Committee to provide a written submission on the Committee's pre-legislative scrutiny of the proposed Legislative Competence Order on Transport. SWWITCH has already responded to the National assembly for Wales' legislative committee and a copy of that response is attached as Appendix A.
2.2	The SWWITCH response does not attempt to provide comment or responses to all the specific issues raised by the Welsh Affairs Committee, but rather to focus on the issues which are within the SWWITCH Local authorities' area of responsibility and expertise.
3.0	SWWITCH COMMENTS ON THE PROPOSED LCO ON TRANSPORT
3.1	SWWITCH supports the general principle that the legislative competence in the areas indentified in Matter 10.2 of the proposed order be conferred on the National Assembly. This would be in the spirit and scope of the devolution settlement.
3.2	There are certainly strong demands from parents and representative groups for action following a high profile fatality some years ago on a bus carrying school children. The demand for the concessionary fares element of the proposed order is directly related to the needs of the Welsh Assembly Government and how they manage the concessionary fares system.
3.3	In terms of cross border issues, changes which improve safety standards of vehicles used for learner travel in Wales which are not implemented in England may well lead to extra capacity/cost requirements on local providers of transport and may raise parental expectations in an area where students attend schools on both sides of the border.
3.4	SWWITCH believes the purpose and scope of the LCO are properly defined and supports the Order in principle. However, it wishes to offer comments on the practical application as detailed in Appendix A in paragraphs 1 & 2.
3.5	As referred to in 3.3 above where changes to vehicle standards are required in Wales, for use on learner travel contracts, which are over and above those required in England, private operators may have to provide additional vehicles with associated capital, staffing and maintenance costs.
3.6	The proposed LCO would not necessitate the abolition of any Welsh institution, but the concessionary fare element may require the establishment of an independent appeals mechanism.

January 2010

APPENDIX A - Submission to the National Assembly for Wales' Legislation Committee

The South West Wales Integrated Transport Consortium (SWWITCH) is pleased to respond to the request for evidence to the Legislation Committee.

SWWITCH supports the general principle that legislative competence in the areas identified in Matter 10.2 be conferred on the National Assembly.

SWWITCH also supports the terms of the Order in principle but wishes to offer the following comments in relation to the concessionary fares scheme and learner transport covering questions 3 and 4 of the consultation document.

1. Concessionary Fares:

1.1. Local authorities currently administer the All Wales Concessionary fares scheme devised by the Welsh Assembly Government which determines the methodology and rate to be applied for the reimbursement of operators. Local Authorities have worked closely with Welsh Assembly Government Officials to develop and amend the existing scheme.

1.2. In terms of the powers, the fundamental determinant of cost is the level of patronage of local bus services by concessionary pass holders and whilst the changes to the reimbursement formula will control cost in the short term, cost will continue to increase in the long term as the population ages and people live longer.

1.3. The concessionary fares scheme supports social, economic and environmental objectives and aspirations which are consistent with the SWWITCH Regional Transport Plan. The Concessionary Fares scheme is intrinsically linked to other support mechanisms for local bus services such as Local Transport Services Grant and Bus Services Operator Grant. All are critical to the support of socially necessary services for communities, particularly in rural areas, where in south west Wales up to 80 % of the local bus network is subsidised. It is therefore essential that future work on the development of a more specific measure should take a more holistic account of :

• The strategic role of the concessionary fares scheme in safeguarding the long term sustainability of local public transport networks.

• The social , environmental and economic implications for any changes to the scheme.

1.4. SWWITCH wishes to emphasise the importance of partnership with local authorities and operators in the development of the specific Measure in relation to concessionary fares and that any proposals are thoroughly evaluated and resourced before a Measure is passed.

2. Learner Transport.

2.1. The proposals to introduce an Order covering the description of vehicles to be used on contracted transport will support aspirations on improving the safety of school transport contracted vehicles and are generally supported. The better the transport experience at a young age the easier it will be to persuade people to use more sustainable forms of transport in the future.

2.2 However there is a concern that the proposals will raise the expectations of the public as there will be no powers over the type of vehicles used on scheduled public transport services that a large number of school children use each day to access education and training. It may also limit opportunities for the integration of services and networks, particularly in urban areas, due to the different vehicle descriptions specified for each particular service area. This could result in pressure for more capacity. It is a complex service area with significant financial and capacity implications.

2.3 SWWITCH would again wish to emphasise the importance of partnership with local authorities and operators in the development of the specific Measure in relation to Learner Transport and that any proposals are thoroughly evaluated and resourced before a Measure is passed.