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Bus Regulation (Scotland) Bill CPT Scotland Response

The Confederation of Passenger Transport Scotland (CPT) is the trade association that
represents the bus, coach and light rail industries. Our members run over 90% of the
registered local bus service mileage in Scotland. CPT is grateful of the opportunity to respond
to the Bus Regulation (Scotland) Bill consultation document.
The introduction to the Bus Regulation (Scotland) Bill consultation document contains
aspirations which CPT supports:
Good public transport effective, reliable, safe and affordable is a hallmark of a
modern, forward-looking society.
Better bus transport can alleviate transport poverty, making a positive economic
impact on communities and addressing mobility problems for those in areas with poor
public transport links.
However, CPT cannot support the consultations wider proposals for increased regulation of
local bus services as we believe this would be detrimental to passengers and taxpayers.
The case for further bus regulation, as outlined in the consultation, is built upon a
questionable interpretation of the status quo which erroneously apportions blame for any
weaknesses of the current system solely onto bus operators.
The document fails to acknowledge high levels of passenger satisfaction or to reflect the
impact of the recession, local authority budget constraints, cuts in public sector funding and
rising costs.
Introducing a franchising model will not address the reasons why bus patronage levels have
declined slightly over the last five years. The consultation appears to advocate forcing local
bus operators to surrender their businesses in favour of a costly, regulated system devoid of
the innovation and efficiency synonymous with the commercial market.
The prospect of giving local transport authorities the power to bundle profitable and nonprofitable routes and franchise them as a package raises several concerns:

Does the consultation advocate a system whereby one authority franchises routes
within its boundaries but neighbouring authorities are happy to retain the commercial
bus market? What about services that cross through transport authority boundaries?
What compensation will the existing operators of local services receive for
confiscation of their commercial business?
What protection is there for the incumbent operators and their staff?
Will the staff of all local bus companies effectively stripped of their businesses then
TUPE over to the local authority?
Will they receive the same terms & conditions and pensions as were previously
provided by the bus operator?

There are huge implications for existing bus companies as well as seemingly prohibitively
large costs and obligations for any transport authority.
The consultation also advocates giving transport authorities the ability to set a minimum level
of service within the franchise, agreed with the operator and to use local authority fleets to
provide socially useful services where there are gaps in provision. It should be noted that
Transport Authorities are already able to use local authority fleets to plug service gaps and
are free to agree service levels within Statutory Quality Partnerships. There is no need for
further regulation to accomplish this.
Franchising
CPT believes that the consultations proposals fail to address the real threats of moving from
a commercial bus market to a franchising model.

Who will decide what routes are profitable and non-profitable and bundle them
together?
Will these profitable routes still be profitable if they are revised to include the
minimum levels of service the consultation alludes to? (For example, a busy urban
service will lose its profitability if it is expected to run more frequently off peak.)
Who is responsible for trialling and growing potential new routes?
What happens if a route becomes less or more profitable due to external factors such
as a new shopping centre opening or a factory closure?

There are huge costs associated with the design and administration of a bus network. No
transport authority in Scotland is currently equipped to take on this role. In fact, few have even
voiced a desire to.
Franchising was recently considered within the potential remedies proposed by the
Competition Commission in its Local Bus Service Market Investigation. The Commission
rejected the concept of franchising in its findings, stating that,
We decided not to recommend the introduction of franchising either instead of or
alongside our other measures. We concluded that, compared with the possible
introduction of franchising, our remedy package directly addresses the AECs
[Adverse Effects of Competition], is at least as effective in addressing the associated
customer detriment and is less costly and therefore provides a more proportionate
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solution.
The Competition Commission noted there are a number of material practical challenges and
risks associated with introducing effective area-wide franchising.

Competition Commission, Investigation into Local Bus Service Market


http://webarchive.nationalarchives.gov.uk/+/http://www.competitioncommission.org.uk/inquiries/ref2010/localbus/pdf/00_sections_1_15.pdf

Local transport authorities do not have sufficient skills and capabilities in areas such as
network design and monitoring. Transport authorities may also have insufficient knowledge of
the local bus market and commercial performance of routes to properly specify franchised
services, potentially leading to a worsening of local services.
While dismissing franchising, the Commissions remedy package includes a recommendation
that Transport Authorities consider partnership working. Furthermore, partnerships with the
following characteristics are likely to have the greatest potential for beneficial consequences
on competition:
a) partnerships which have the effect of improving the quality of information provided to
passengers, thereby increasing passenger demand for bus services and making
passengers more responsive to changes in operators offerings;
b) partnerships which are accessible to new and/or expanding operators and have the
effect of growing bus patronage and thereby improving the attractiveness of a local
bus market for new and/or expanding operators; and
c) partnerships which provide an environment which promotes sustained competition,
for example by encouraging service stability throughout the year.
The debate on regulation should concentrate more upon enabling the type of partnership
working between operators and transport authorities as outlined and recommended by the
Competition Commission. Re-engaging on the issue of franchising so quickly after it has been
considered and rejected by the Competition Commission is an unnecessary distraction.
Gavin Booth, Senior Officer for Scotland, Bus Users Scotland, widely echoes CPTs call for a
focus on effective partnership working;
Bus Users Scotland considers that effective partnership with willing participants is
preferable to an enforced, contracted and regulated arrangement. We will naturally
support any measures that give genuine improvements in service for the public.
However there are examples of excellence in bus services in Scotland, not least in
Edinburgh, which have improved on the service that was there in the previous
regulated regime, prior to 1986. There is little evidence to suggest that a regulated
regime would in itself improve bus services in Scotland unless large amounts of
public subsidy were to accompany such a move. Such funding is always vulnerable to
requirements to reduce public funding, so in fact a commercial approach can create
greater long-term stability of bus services.

Removing the Need to Prove Market Failure.


The consultation advocates removing the need for Transport Authorities to have to prove
market failure before operators can be compelled to enter into either Statutory Quality
Contracts, or franchising, stating it is unclear what constitutes market failure having never
been proven.
This is misleading as no transport authority has attempted to prove market failure rather than
no attempt to prove market failure has been successful.

Why has no transport authority ever felt the need to attempt to introduce a Statutory Quality
Contract? If there was a real desire for regulatory change surely this would have been
preceded by transport authorities attempting to gain further control?
Removal of this key test would seriously impair the protection it provides to operators where
there is no market failure, and would allow any local authority to seek to confiscate a
reputable operators commercial business without good reason.
Bus Service Mileage Cuts In Scotland
The consultation cites service reductions in one region of Scotland as evidence of potential
market failure across the country. While there has been a decline in commercial bus mileage
over the past five years in Scotland, this is widely mirroring the trend across Great Britain.
Cuts in commercial mileage are also far smaller than cuts to subsidised services made by
transport authorities over the same time period.
Moray Councils decision not to fund any subsidised bus routes in 2013/14 is highlighted
within the consultation as an example of the failures of the current commercial market when in
reality it is purely a reflection of the current economic constraints being faced by both the
public and private sector.
If a local authority suffering from the effects of the recession, a reduced budget from central
government and rising costs then opts not to run any tendered services this is not a reflection
on the performance of local operators, nor is it reason enough to call for a review of public
transport regulation.
The extent to which the bus market is regulated will have no bearing on whether Moray
Council, or any other council, chooses other priorities rather than funding subsidised services
The London Example
London is often heralded by proponents of reregulation as the system that Scotland should
aspire to but little is mentioned about the costs of both introducing and then operating such a
system.
In 2009/10 London consumed 42% of public spending on buses for 15% of the UKs
population. Spend per capita in London was 103.43 in 2009/10. SPTs current subsidy per
head of population for its network is 5.32.
The lower level of journeys per head, even in Scotlands urban centres, would mean that
transport authorities would need to fund additional support costs above those currently
supplied in London. It should also be noted that London is alone in operating a congestion
charging scheme that both discourages car use and can help fund public transport
alternatives.
Additionally, London was never deregulated in the manner of the rest of the UK. The historical
transport policy context - as well as Scotlands geography and demographics - means that the
London system is not a tenable alternative.

Tendered Services
The consultation erroneously states that At present, authorities hand over cash to operators
to run unprofitable services with little say in how they are run.
Local Authorities can choose to put tenders out to the market seeking bids from operators to
undertake specific routes. In most, if not all instances, the tendering authority will set out the
service pattern, frequency of service and fares to be charged.
In many cases the winning bidder is selected on the lowest cost bid. If a local authority wishes
to exert even more influence on the nature of a service then it can enter into a Statutory
Quality Partnership (SQP).
Transport Authorities have scope under current legislation to specify many aspects of
tendered services but, in the current economic climate, quality is often regarded as secondary
to price. This is not a flaw in the regulation but a consequence of the economic downturn and
perhaps an issue with local authorities undervaluing the importance of supporting public
transport.
SQPs
The consultation refers to the Scottish Household Survey findings that perceived issues
regarding journey times and reliability are two major reasons why people who could travel to
work by bus choose not to do so. These are two aspects of bus travel that would not markedly
improve under a franchising system. One proven method to improve journey times and
reliability is the introduction of bus priority measures commonly included within an SQP.
An SQP compels both the transport authority and the operators involved to invest in
improving local bus services. The operator may agree to frequencies, vehicle standards and
other facets within its control. In return the transport authority may offer to introduce
infrastructure improvements and priority measures.
The consultation proposals appear to demand the level of commitments from operators
commonly found in an SQP while removing the need for a transport authority to make similar
commitments to improving the elements of public transport which are under its control. How
such an arrangement hopes to lessen journey times, improve reliability and make public
transport more appealing is unclear.
Using a franchising system to increase frequencies will not encourage modal shift if the extra
buses are then caught up in congestion, leading to longer journey times, increased emissions
and high fuel costs.
The consultation would be better served by concentrating on what can be done to improve the
reliability, punctuality and general quality of bus services rather than focussing on who
controls routes and frequencies.
Although it is too early to draw strong conclusions from the current Scottish SQPs, lessons
can be learned form partnerships in other areas of the UK.

Oxford is widely seen as a successful example of a partnership between the County Council
and the two main bus operators which also maintains competition between the bus operators.
Stagecoach and the Oxford Bus Company entered a Voluntary Partnership Agreement which
allowed timetables and ticketing to be coordinated. A SmartZone multi-operator smartcard
scheme was also introduced, allowing passengers to travel on any local bus in the Oxford
area. In addition, bus services were rationalised, in cooperation with Oxfordshire County
Council, in order to reduce congestion and pollution in the historic city centre streets.
Passenger numbers increased from 36.3m in 2010-11 to 39.3m in 2011-12 a rise of over
8%. In addition, the city centre environment has improved. The success in Oxford shows that
a partnership approach can deliver a key improvement for passengers without an expensive
bus contracting approach.
Stagecoach and First have also entered a successful Voluntary Partnership Agreement in
Sheffield in which local bus operators, the City Council and the local transport authority work
together to plan fares and the network. The scheme, which was launched in October 2012,
has delivered a simpler bus network, more services on many routes, more low-floor buses
and a new range of tickets. Since its launch, there has been an increase in the number of
people using buses in Sheffield. In the past three months, overall bus patronage in the city
has risen by 5.3% while there has been an increase of 14% in fare-paying passengers. Fares
have decreased by an average of 3.4% while both punctuality and reliability have improved
with reliability at almost 99%
This is against a background of decreasing bus passenger numbers across the rest of South
Yorkshire.
A recent Partnership Plus deal between National Express Coventry and transport authority
Centro will see 80m of investment and bring a raft of improvements for passengers over the
next two years.
The Partnership Plus deal will see 65m of investment in the bus network by National
Express and 16m by Centro. Coventry city centre and the wider region will get new
infrastructure, shelters and passenger information as part of the deal. The partnership will
also deliver 300 new buses, including 15 hybrids; 10 new gold bus corridors with new buses,
real time information and increased bus priority; 350 new bus shelters; a Swift smartcard
system; expansion of the on-bus cleaning scheme and more talking buses with AV next stop
equipment.
These three examples have not required any additional legislation than is currently available
to local authorities in Scotland. It has taken commitment from all parties rather than further
regulation to deliver these improvements
Current Regulation of the Industry
CPT believes that the consultation document fails to accurately reflect the role of VOSA and
the extent of bus monitoring in Scotland. The role of VOSA monitors has shifted from a focus
on on-street monitoring of bus services to a more holistic approach focused on visiting
operators and ensuring they have the systems and practices in place to operate in a proper
manner.

The task of on-street monitoring has not been discarded. SPT wardens will continue to
monitor services in Strathclyde while Bus Users UK, through Bus Users Scotland (BUS), has
been appointed to monitor service compliance throughout the rest of Scotland.
CPT agrees that the powers of the Traffic Commissioner should be strengthened. In
particular, CPT would like to see the Traffic Commissioner be able to call transport authorities
to account for their part in any reliability or punctuality failures. Unlike rail, the bus has no
control on the track it runs on. Transport Authorities have a role to play in coordinating
roadworks and facilitating bus services through congestion. If there is a lack of information or
assistance then all parties should be held to account.
It is worth noting that the terms deregulation and reregulation are not entirely accurate
descriptions for bus policy. The current commercial market is often referred to as deregulated.
However, bus operation is heavily regulated, with all operators monitored by VOSA - and now
Bus Users Scotland - and answerable to the Traffic Commissioner.
Defining Market Failure
The consultation quotes an SPT report on regulation, stating;
while there are some examples of what might be taken to indicate market failure such as inadequate frequencies, inadequate quality and lack of network stability - it
is also the case that these might still not be enough to undertake a QC [Quality
Contract]
This is taken to mean that the reason there are no Quality Contracts is that it is too onerous a
task to prove market failure. However, the same SPT document also concludes that;
The risk allocation implicit in moving to a Franchising regime has been identified at
high level
This report has not attempted to quantify the costs and the benefits to SPT of a
franchise or quality contract approach. Some quantification of the costs and benefits
would be desirable in order to inform any policy decision.
The qualitative assessment that we have undertaken suggests that there would be a
high resource and funding requirement as well as a significant timescale associated
with bus franchising.
Any proposal to introduce franchising must also consider the possible reaction of the
bus operators in the industry. The experience of West Yorkshire PTE, Transport for
Greater Manchester and Nexus suggests quite clearly that before embarking upon a
quality contract approach, there is merit in developing a partnership approach to
ascertain whether it is capable of achieving a significant proportion of the benefits that
are expected from a Quality Contract, in a shorter timescale and at less cost and risk
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transfer to the public sector.

AECOM, Preliminary Review for Quality Contracts/ Bus Franchising in SPT Area March 2012
http://www.spt.co.uk/documents/sp230312_agenda10.pdf

It appears more sensible and fiscally prudent to pursue a partnership approach and improve
bus matters within the existing regulatory framework before considering the introduction of a
Quality Contract.
SQPs are a balanced solution that provide meaningful benefit to all of the partners, thus
generating the necessary stimulus and incentive for partners to commit time, effort and
investment in the local public transport network thereby creating an environment which brings
real improvements to passengers and generates further modal shift.
The suggestion that bus companies have little incentive to agree to enter into a voluntary
agreement is demonstrably wrong. The stability and certainty that comes from knowing what
is expected from operators and what operators can expect from the transport authority can
enable bus companies to invest in improving services, safe in the knowledge that the
transport authority is committed to improving the infrastructure these services operate on.
Decline in public subsidy
The consultation is correct in highlighting recent changes to bus funding as a real challenge to
the bus industry.
Changes to the Bus Service Operators Grant have seen the budget for the scheme cut from
an initially agreed 66.5m in 2012/13 to 50m in 2013/14.
A review of the National Concessionary Travel Scheme conducted earlier this year saw a cut
in the rate of reimbursement for operators from 67% to 60% from April 2013.
In 2011-12 there were 440 million local bus journeys in Scotland as opposed to 87 million
journeys on the Scottish rail network.
The governments spending priorities do not reflect this modal split in public transport use. In
2013/14 the Scottish Government will spend 248.6million on supporting concessionary bus
travel and BSOG. It will invest 755.9million in rail services in Scotland.
The 17% of total passenger journeys made by train receive over 75% of the government
support for public transport.
Against this challenging background the bus industry has still managed to attain positive
levels of public satisfaction.
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The latest Scottish Transport Statistics state that;

73% of passengers feel that buses are on time


79% of passengers feel that buses are frequent
74% of passengers feel that buses run they need them.
85% of people feel that journey times are reasonable
Scottish bus fares are consistently and increasingly below the UK average.
Most people agree that it is easy to change from buses and trains to other forms of
transport (82% for trains and 75% for buses) and to find out route and timetable
information (91% for trains and 84% for buses)

Scottish Transport Statistics, No.31, 2012 Edition http://www.transportscotland.gov.uk/files/j251205.pdf

Scotlands bus passengers are generally very satisfied with Scotlands bus services. There is
certainly no room for complacency and the bus industry is committed to improving these
statistics further. However, they do not reflect the picture of widespread dissatisfaction as
suggested within the consultation document.
More accessible services
CPT accepts that it remains challenging to run a commercial bus service that fully meets the
needs of the local population in largely rural areas. However, this does not mean that the
commercial market has failed and regulation is required.
Local authorities have the power to tender services that are not commercially viable for
operators to run. Tendered services as well as Community Transport and Demand
Responsive Transport are important contributors to filling the gaps in the market where
demand is insufficiently high to allow an operator to run a commercial service. In deep rural
areas there are few if any profitable services to bundle with unprofitable services.
A partnership approach is once more the most effective in terms of cost and bureaucracy.
The likely cost of franchising for regular bus services in remote rural areas would prove
entirely prohibitive.
The consultation highlights the fact that 542 registered services were cancelled in Scotland
last year as evidence of a contracting bus network across Scotland. However, the
consultation document neglects to mention that over the same period 718 new service
applications were accepted. The true picture is one of an evolving network of services,
adapting to changing demand.
It should also be noted that the majority of service changes were instigated because of
changes to subsidised routes. These were not commercial decisions by operators but led by
local authorities that wished to alter or cut the services they support.
Service Improvements
CPT notes that the consultation document references the Scottish Government Social
Research survey Understanding Why Some People Do Not Use Buses, listing some of the
suggested improvements contained within that could be made to bus services.
The improvements that non-bus users would like include improved lighting, shelters and
information and improved speed and reliability. These are steps that bus companies cannot
achieve alone infrastructure improvement and priority measures require support and
investment from transport authorities.
The research survey is cited within the consultation document as evidence of dissatisfaction
in the current bus market but when taken in context it actually supports the view that
cooperation and joint investment is required to deliver its suggested improvements as
opposed to regulatory change.

The consultation document quotes outdated Bus and Coach Statistics that fail to properly
reflect the excellent work of Scottish bus operators to improve their fleets. The more recent
statistics show;

63% of buses in Scotland are fitted with CCTV, an 80% increase over the last 5
years.
76% of buses in Scotland are fitted with Automatic Vehicle Location devices. (Higher
than the GB figure and a 245% increase over the last 5 years.)
89% of buses in Scotland have ITSO smartcard-readers. (The GB figure is 60%.)
84% of buses in Scotland are low-floor.
Operating costs per passenger journey in Scotland exceeded those for GB (outwith
London) for the third consecutive year and displayed a 21 per cent increase over the
past 5 years, largely because fuel forms a larger part of costs in Scotland due to
longer routes between population centres, and fuel costs have risen faster than
inflation.
Over the past 5 years, bus fares (excluding inflation) have risen by around 6 per cent
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in Scotland , this compares with a rise of around 10 per cent for GB as a whole

Despite costs being markedly higher for bus operators in Scotland, fares continue to be lower
than the UK average.
Community Transport
The consultation rightly highlights the importance of Community Transport. It is an important
part of the transport mix, particularly in rural areas where demand is insufficient to warrant a
commercial registered bus service.
While the consultation is right to consider Community Transport as a vital cog in local public
transport, it is wrong to assume that the sector would welcome proposals to change the
current regulatory framework.
The consultations proposals are not the legislative changes that the community transport
sector needs. Many of its concerns can be addressed by the sector being given proper
consideration within the planning of the local transport mix. Local authorities should be
incentivised, or compelled, to provide adequate funding for the services it requires. Steps to
remedy this are currently being considered by the Infrastructure and Capital Investment
Committee following a recent inquiry into the matter
Environmental impact
The consultation correctly highlights the environmental benefit of encouraging and growing
public transport use. Research carried out by Greener Journeys states:

Each double decker bus can take 75 cars o the road, reducing congestion and

improving air quality


If drivers switched just one car journey a month to bus or coach, it would mean one
billion fewer car journeys and a saving of 2million tonnes of CO2.

Transport Scotland, Bus & Coach Statistics 2011-12


http://www.transportscotland.gov.uk/files/BusCoach2011_12.pdf

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The best used bus services in urban centres may be reducing carbon emissions from
road transport by as much as 75%.

Bus companies are also investing heavily, with the help of the Green Bus Fund, on greener
vehicles using technologies such as hybrid engines, biofuels and gas to make substantial
carbon savings.
The consultation document states that it aims to empower transport authorities to consider
the environmental concerns of their areas. Existing SQPs in Scotland already enable this by
allowing transport authorities to specify the standard of vehicle permitted to use certain bus
corridors and priority infrastructure. Transport Authorities can also designate Low Emission
Zones to set environmental standards for vehicles within areas with poorer air quality.
No additional legislation over bus companies is required to empower transport authorities to
encourage modal shift to public transport or to make policy decisions which benefit the
environment. Instead, more needs to be done to tackle the culture within local government
which thus far fails to recognise the environmental benefits of public transport and of
supporting the bus.
Conclusion
Many of the aims of the current consultation document appear achievable within current
legislation. Additionally, several of the areas of bus operations which the consultation
identifies as requiring improvement are already being taken forward by CPT Scotland, its
members, the Scottish Government and other transport stakeholders.
CPT Scotland participates in the Bus Stakeholders Group which is currently reviewing the
processes for bus service registration. This should bring increased bus network stability and
allow local bus operators and transport authorities to work together to provide a more
comprehensive and integrated public transport network. The group also plans to review
Statutory Quality Partnerships and Statutory Quality Contracts in an effort to ensure current
legislation and guidance is working as intended and to address any impediments to further
SQPs being formed.
The Scottish Government has also introduced the Bus Investment Fund. This fund aims to
address the issue of the lack of ring-fencing for public transport budgets. Currently the
Scottish Government supplies in excess of 58m within the local authority block grants for
public transport yet it is apparent that a great deal of this money is redirected into other policy
priorities. The 3m Bus Investment Fund is small by comparison; however it does allow
transport authorities and local bus operator to apply for capital funding for infrastructure and
priority projects.
The first round of the Bus investment Fund has been hugely oversubscribed which suggests
that there is scope for partnership projects and willingness from both the public and private
sectors the main barrier being a lack of available funding. Local authorities must accept they
have a role to play in enabling better bus services and assign proportionate funding to this
goal.

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CPT accepts that local authority budgets are being squeezed and that there are several policy
sectors competing with transport for the allocation of limited funds. However, public transport
support can enable local authorities to achieve a range of policy objectives in areas such as
social inclusion, economic development, health and the environment.
The recent Public Transport Executive Group (PTEG) report The Case for the Urban Bus
acknowledged that public support for urban bus services generates multiple benefits including
supporting local economies, reducing road congestion and benefitting the disadvantaged and that it provides exceptional value for money in terms of the return on public investment
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and support.
It should be noted that bus users make 1.4 billion shopping trips per year across the UK and
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spend an estimated 27 billion on retail goods.
Bus routes that are more consistent and have quicker journey times can help the economy to
grow. More people access Britains high streets by bus than by any other mode of transport.
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40% of trips to the high street are made by bus, while only 30% are made by car.
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Congestion in urban areas costs UK plc at least 11 billion a year. Buses are a more efficient
use of road space than cars and, when combined with priority measures such as bus lanes,
can reduce travel delays and improve journey times for their passengers.
Buses are also key to reducing CO2 emissions from road transport. Just 5% of domestic
transport CO2 emissions come from buses, compared to nearly 67% from passenger cars and
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taxis.
CPT believes that, rather than assuming that further regulation is the panacea, we need to
foster a constructive discussion around improving bus services and properly address the
widespread culture of undervaluing the bus.
Professor John Hibbs of the Institute of Economic Affairs echoes CPTs views on the
perception of public transport within local government;
What has been sadly lacking ever since 1985 has been a positive attitude on the part
of highway authorities. To provide services buses need their own track, like trains.
This has to be shared with cars and goods vehicles, but cars are singularly inefficient
users of road space and in the absence of road pricing it should be the responsibility
of local government to deal with the problem.
Buses, however, do not rank high in public status, and motorists, who are voters and
ratepayers, resent the introduction of bus lanes and other kinds of priority. A
professional gap seems to have grown between urban planners and bus operators
reflecting perhaps a distrust of commercial management. After the Transport Act
2000 the quality partnerships were designed to overcome this, but there now seems

PTEG, The Case for the Urban Bus http://www.pteg.net/NR/rdonlyres/5F26BBD3-C4A4-4052-A453D5BFE5E0F0B8/0/ptegCaseforbusreportFINAL.pdf


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Institute for Transport Studies (2012), Buses and Economic Growth
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Greener Journeys (2012), Bus Policy: a five-point plan for growth
8
Cabinet Office Strategy Unit (2009), An analysis of urban transport
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Department for Transport (2013), Energy and Environment Statistics, Table ENV0202

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to be a real possibility that franchising would simply make things worse, by throwing
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the baby out with the bath water.
To help spur the debate, CPT Scotland has commissioned an independent report from the
TAS Partnership entitled The Economics of Bus Operation in Scotland.
The report is a snapshot of the industry in Scotland which concludes that the Scottish
Governments policy objectives for public transport should be based upon reducing the
generalised cost of public transport use - generalised cost being the total cost in time and
money of a journey from door to door.
In other words, enable bus operators to improve punctuality, reliability, information, ticketing
and the myriad of other factors that encourage bus use. Take the steps that bus operators
cannot to introduce bus priority measures and improve infrastructure. Look to do so through a
partnership agreement that commits all parties to playing their part.
If this consultation on bus regulation is spurred by a genuine wish to improve bus services it
should abandon its uncosted and inappropriate call for a system of franchising and instead
focus on advocating support for bus services through national schemes and local authority
spending decisions
It can be demonstrated that public sector support and quality partnerships not only improve
public transport but deliver measurable economic, social and health benefits to the local area.
The public sector doesnt need to control buses; it needs to enable bus services. Refining the
relationship between the public sector and commercial operators and enforcing the fact that
working together is beneficial to all parties is the best way in which we can deliver real
improvements to bus services across Scotland.

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Prof. John Hibbs, The Dangers of Bus Re-regulation, 2005

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