Memorandum from Sustainable Transport
for the East of England Region, (STEER) (Bus 27)
THE BUS INDUSTRY
1. STEER is a coalition of campaigning groups
in the English Eastern Region representing environmental and sustainable
transport advocates. It has particular concerns with the way in
which the lightly regulated bus industry outside of London has
developed in recent years and welcomes the opportunity in response
to the Press Notice No 50/2001-02 published on 8th March 2002
to submit a memorandum for consideration by the Transport Sub
A BRIEF HISTORY
2. The history of bus operation in Britain
is largely one of long periods of inaction punctuated by quite
dramatic changes to the regulatory or ownership structure of the
industry. Thus since the Road Traffic Act 1930 and setting up
the Traffic Commissioners as a licensing body replacing the powers
of local authorities, we have had the setting up of the London
Passenger Transport Board in 1933, starting the separation of
the capital's bus network from that of the rest of the country,
the nationalisation of about half of the territorial bus companies
largely as a result of the Railways Act 1947, the sell out to
the state of the remainder of the major companies as a result
of the Transport Act 1968 (forming the National Bus Company) as
well as the absorption of most of the large conurbation municipal
operators into the new passenger transport authorities. Matters
then remained quiet until some overdue deregulatory measures trimming
the scope of the 1930 legislation were enacted in 1980/1 but which
retained the powers of the Traffic Commissioners over local bus
services. The effects of this had hardly time to settle when the
"big bang" of the deregulatory and privatising measures
of the Transport Act 1985 took place, selling off the National
Bus Company and pte bus operations, turning the remaining municipal
operators into companies with the aim of their privatisation.
3. The effect of the 1985 Act was to introduce
a period of instability in bus services with many instances of
wasteful "head to head" competition in urban areas,
frequent changes in services and many small independent operators
deciding to sell out where their businesses had a market value.
New bus orders fell significantly and the small van chassis based
"midibus" of typically 16-24 seats was seen as a panacea
in many areas. A decade after the 1985 Act sees ownership of the
bus industry dominated by about six large groups, it being purely
a matter of history where towns and cities now see a significant
degree of monopoly operation (eg Bristol, Carlisle, Exeter, Norwich,
Swansea) or where competition occurred and has now stabilised
(eg Hull, Leicester, Oxford, Plymouth). In other places, successful
ousting of the weaker operator has led to near monopolies of services
by the surviving operator (eg Brighton, Lancaster, Lincoln, Reading).
The changes made by the Transport Act 2000 are in reality a "light
touch" and have not yet had a fundamental effect on the industry.
4. The major changes wrought by the 1985
Act occurred at the same time as the use of buses was falling
nationally by as much as three to five per cent annually. This
loss of custom has now levelled out with growth being encountered
in some areas. This is in contrast to a steady upward climb for
some years of the usage of buses in heavily regulated London.
5. Looking at bus operation across the country,
there is a varied picture. On the positive side there are a significant
number of operators providing a high standard of service with
well trained staff driving new low floor accessible buses, working
with local authorities to provide decent waiting conditions, good
quality information and bus priorities. Although many operations
of the large groups fall into this category (eg the Brighton and
Hove network of Go Ahead, the Cambridge Citi operation of Stagecoach),
it is notable that many such "patches of excellence"
occur where the privatised company has remained locally independent
(eg Trent and Barton Buses of Nottingham, Truronian in Cornwall,
East Yorkshire Motor Services of Hull).
6. The regional Traffic Commissioners deal
with the registration of services, licensing of vehicles and operators,
but are not equipped to deal with the day to day issues of operation,
particularly passenger complaints. The bulk of their work relates
to the quality control of road haulage operators and vehicles.
7. There are factors within the control
of bus operators which regrettably can be seen in many instances
around the country and which act as a deterrent to bus travel.
Such factors include:
Poor information provision (both
at bus stops and enquiry facilities)
Inadequate service control management
needed when disruption occurs.
Poor marketing of services (especially
prepaid and multi tickets)
High fares and lack of transfer or
through fares to other services.
Lack of proper training for driving
Frequent and poorly advertised changes
Poorly cleaned and scruffily presented
8. There are also factors which lie largely
outside of operators' control which affect all bus operators to
varying degrees. These include:
Delays to services caused by traffic
Delays caused by parked vehicles
(especially on suburban roads).
Lack of proper waiting facilities
(eg well lit and maintained waiting shelters, also hardstanding
and footway access to rural shops).
New housing developments not taking
proper account of bus users' needs.
Traffic calming measures not taking
the needs of buses into account (eg use of road humps instead
of speed "cushions").
Low ambient quality bus stations
in many towns (often ill maintained or poorly located underneath
car parks or other buildings).
Driver recruitment problemsbecause
of the demanding nature of the job, poor comparative pay levels/expensive
living costs (esp. in SE England).
Lack of co-ordination between operators
(caused largely, but not solely, by the Competition Act 1998).
Vandalism and disruptive behaviour
both on and off the bus.
Poor social perception of bus services.
Lack of a national voice for the
provincial bus passengerother than the excellent voluntary
National Federation of Bus Users. (Why do London bus passengers
alone need statutory consumer representation?)
As can be seen from the foregoing factors, the
bus industry is beset by a range of issues which clearly need
to be addressed on a national basis if this mode is to play its
full part in reducing reliance on the car and meeting current
THE UK BUS
1 OF SUB
9. Fuel tax rebate is the general subsidy
to the operation of local bus services. Its effect is not controllable
from the policy viewpoint but it can probably be argued that it
has enabled a greater mileage of marginal services to be provided
than otherwise would be the case.
10. General subsidies by local authorities
and passenger transport authorities for operators were one of
the targets of the 1985 Act reforms. In its place have come operating
contracts which are tendered for on a competitive basis. In the
early days of the deregulated regime this led to operators submitting
unrealistically low tenders (and leading to giving of notice on
the tender or in a few cases the financial failure of the operator).
In areas where operators are few on the ground, local authorities
have more recently experienced a rapid rise in the cost of securing
11. The Rural Fund Bus Grant initiative
by the Treasury has had beneficial effects in financing bus services
in sparser rural areas or strengthening frequencies on existing
rural routes. However a downside has been the effect of operators
giving notice on marginal commercial rural routes so that they
can tender for them on a subsidised basis. The funding for this
latter purpose has then to be met from the local authorities'
existing public transport support budgets.
12. Bus Challenge initiatives have generally
had a positive impact by inducing operators and local authorities
to consider innovative ideas for new services (eg variable route
rural services with a limited degree of demand responsiveness).
There is a need for experimentation and innovation with the supporting
publicity and information provision. In urban areas it has meant
the provision of services meeting particular needs such as late
services on Friday and Saturday nights, geared to the needs of
13. Bus Quality Partnerships (BQP's) are
a form of "compact" between operators and local authorities.
Whilst there has been some good work in achieving a high standard
of provision (eg the "Superoute 66" services between
Ipswich Rail Station and Martlesham Heath which now operates on
a 24 hour basis) the impact is disappointingly scattered in national
terms. There is no ability in a BQP for an operator providing
a service on an all week basis to be protected from competition
during the profitable main day period. Similarly in such a situation
(or for other reasons) there is nothing to protect the local authority
which has invested in improved infrastructure, then having to
allocate finance for the contract subsidy of a route in the evenings
or on Sundays because the operator has decided that service provision
at such times is no longer commercial. The local authority cannot
determine frequencies in a BQP which is a fundamental element
of the provision of a bus service.
14. Bus Quality Contracts (BQCs) require
the prior authorisation of the DTLR and enable the local authority
to plan the total provision of services in an area or corridor
including the setting of fares. There is an onus on the local
authority to demonstrate why a BQC is warranted. In reality this
is a means of regulation within a defined geographical area.
15. Whilst it would seem that BQP's lean
towards the operator in maintaining the low level of regulation
whilst BQC's give a high degree of regulatory control to the local
authority, it must be questioned whether the existence of these
two forms of relationship are a means of avoiding the issue of
the right degree of regulation of the industry on a national basis.
It is important in any regulated system that whilst there should
be certainty in provision of a service from the customer's standpoint,
the operator should retain sufficient freedom to have the incentive
to develop services within the parameters of a service specification.
This matter is further discussed below in the section on the regulation
of the industry (paragraphs 19-23).
16. Bus priorities take a number of forms;
reserved or shared priority lanes on key sections of roads, traffic
signal detection, bus only accesses through commercial centres
or linked residential areas, bus only permitted turning movements
at busy junctions and "No Stopping Except Buses" orders
at bus stops.
17. All these measures are of assistance
to the operation of buses on increasingly congested roads by enabling
the provision of a more reliable and attractive service. There
is considerable variation in the enthusiasm for and level of provision
of priorities around the country, but the much greater depth that
policy development, implementation and monitoring is given by
the annually reviewed Local Transport Plan process has encouraged
some of the more "backward" local authorities to consider
bus priorities more positively as part of their approach to public
18. Enforcement of priorities is obviously
important in order that their full benefit can be felt by bus
users. However besides the obvious measures of enforcement using
police, cameras, traffic wardens, etc, there is a need for a more
informative approach to the public. As an instance, it should
not be difficult to publicise the numbers of people travelling
along a road at peak times in a priority bus lane and in the general
traffic flow so that accusations of "underused bus lanes"
are countered. Similarly, the thick yellow line denoting a "No
Stopping Except Buses" order is not easily recognised by
many other vehicle drivers; either specific publicity, or the
use of another colour for the road marking, for example red, may
be effective in this case.
19. A brief history of the regulation of
the industry was set out in paragraph 2. We are now in the aftermath
of the deregulating effect of legislation which has now been in
force for some 16 years. London's bus services are governed by
a bureaucratic system of regulation in which the operator has
very limited ability for manoeuvre. Also the system of re-tendering
with operators likely to gain or lose a considerable amount of
work can lead to other problems such as an unstable workforce.
However, it can be said that the London system works in terms
of passenger usage and probably in terms of public satisfaction.
Hertfordshire County Council published its Bus Strategy document
earlier this year and it records the fact that the expectations
of the large part of the population that lives close to the Greater
London boundary of the county are significantly higher than elsewhere
in the county for reason of what is perceived as a better bus
service enjoyed by London residents living nearby.
20. Integration of bus and rail services
is also threatened by the lack of regulation of bus services.
Because of the risk in providing outdated and hence misleading
information, First Great Eastern Railway in its timetable booklet
no longer shows bus links to towns not served by railin
an area where the principal bus operators belong to the same owning
group as the train operator! There has been a difficulty in maintaining
a ColchesterStansted Airport coach link which formed part
of the regional rail network at one stage. The ability to revise
or withdraw bus services at 56 days' notice makes forward planning
21. The way forward may lie in some form
of regional bus regulation transferring the present service registration
and monitoring functions of the Traffic Commissioners to the new
body. This would leave the Commissioners with the administration
of the qualitative elements of operators and vehicles on a similar
basis to its control of road haulage. The regional regulator would
have a relationship to the county/unitary/PTA public transport
support function. Such a body would be well placed to monitor
the efforts of local authorities in matters of shelter, information
provision and bus priorities as well as acting as final resort
of public complaints of poor service. Railbus service integration
should become more attainable with such a body to oversee matters.
22. Any re-regulation on a general basis
is likely to require primary legislation. There is also the question
of transition to a new regime which could be treated by freezing
service patterns as occurred with the introduction of the deregulation
following the 1985 Act. For political reasons a gradual approach
may be preferable. DTLR already carries out a quarterly exercise
in gauging satisfaction levels with bus services. It would be
a useful exercise to extend this survey to include non bus users
and to ascertain which aspects of bus operation cause most concern
to users as well as what improvements would be necessary to induce
non users to consider catching the bus. The introduction of some
trial areas of re-regulated services in several districts where
bus usage has declined significantly could be a useful step in
gauging the impact of a more regulated regime as long as the trials
were allowed to run a sufficient length of timeat least
two and possibly three yearsin order to generate any additional
23. If these actions point towards a more
general re-regulation of the industry the following aspects should
interests of existing operators in
the short term (eg a transition regime possibly on a route by
route basis as the network is reviewed by the regulator).
a requirement for bus operators to
liaise and co-operate with each other (and with rail, ferry operators
etc,) with removal of any hindrance from competition regulations.
need to standardise dates of service
revisions to, say, three times annually, including with the twice
annual national rail timetable change.
total agreed service provision in
a corridor to be provided by an operator (or jointly by operators)
on a cross-subsidising commercial basis or the whole route put
out to tender.
fares would be subject to local authority
decision, whereby either an agreed scale (subsidised if necessary)
applied or the operator left to commercial freedom as long as
it participated in area travel card and through booking schemes.
service parameters to be framed in
such a way that operators have an ability to optimise the economic
deployment of their resources as well as having the freedom to
operate a better service than that specified (ie similar to the
Passenger Service Requirement imposed on train operating companies).
ability for new entrants to participate
in service provision.
where not seen to be predatory on
the existing network, new speculative commercial services should
be permitted by the regulator on the same basis as existing services.
requirements on information provision
by local authorities and operators.
requirement on English district and
all unitary authorities to make proper provision for bus shelter
provision, cleaning and maintenance (using private contractors
where advantageous), as well as access to bus stops by provision
of hardstanding and footways over the whole of their area.
there will probably need to be an
ability for operators to appeal against decisions of the regulator,
(another function for the Transport Tribunal?).
24. As bus services can potentially cater
for a higher proportion of the total population than the car,
based on the ability to drive and afford car ownership etc, it
must follow that the bus can be an effective instrument in reducing
social exclusion. However, this also depends on factors such as
geographical penetration of the network, fare levels and response
to demand for services at particular times of day (eg very early
morning or evening times).
25. With the focus on accessibility in the
late 1980's and early 1990's for people with ambulant disabilities
and the subsequent DIPTAC regulations, the industry has responded
with new very low floor stepless bus designs which also assist
the encumbered passenger (eg the parent with a pushchair, two
children and a load of shopping). Even progressive express coach
operators are purchasing low floor access vehicles (eg Stagecoach's
Oxford Tube) rather than the traditional coach types with a mountain
of steps facing less agile passengers. The government has responded
by requiring all local service buses to be fully accessible by
2016, but it is to be hoped that this target will be achieved
well before that date.
26. There are other inclusion benefits from
an effective network of bus services by linking areas of different
ethnic patterns or income levels, buses encourage an informal
level of social contact. Buses must be able to provide access
to shops, jobs, education facilities and other essentials such
as hospitals. Planning principles, which have been thoroughly
revised since the 1990's, emphasise the need for encouraging non-car
access. If followed consistently by local authorities, the bus
should be enabled to provide reasonable access to a full range
of activities. Ideally in urban areas bus services should be of
such a quality and coverage so that no-one feels "trapped"
in their locality.
27. One final point worthy of mention is
that many bus operators in their quest to make services more attractive
to a wide range of customers, have tended to simplify networks
so that basic services are provided on a good frequency. This
has meant that some minor variations serving areas or roads on
an occasional basis have been withdrawn. This is a clear case
of having to meet the needs of a majority, but there may well
be a case for the local authority subsidising a low frequency
(eg three or four journeys daily) service meeting the needs of
marginal areas, thus supplementing the trunk route network.
28. Despite the reduction over the last
40 years of its share of all journeys, in distance terms the bus
is still the second most important travel mode after the car.
The bus can be universally available where a suitable road network
exists and thus is a very flexible mode of transport. It can supplement
fixed services such as rail, ferries and trams, adding to the
attractiveness of those modes. Most larger towns and cities operate
bus based park and ride schemes adding to the flexibility of using
the car in urban and rural areas (as well as introducing people
to the experience of riding in modern buses). Trams or light rail
schemes are being introduced in several cities with very impressive
results in term of ridership growth in most cases. However, this
is an expensive investment being justified where there are major
corridor flows of people and hence will be justifiable in only
a small proportion of our towns and cities. If the bus can be
enabled to perform its function effectively by means of priorities,
good information and stable, logically organised networks, then
the government's aim of increasing its share of total travel demand
can be realised.