36 Fife Council

8/10/2019 36 Fife Council

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Bus Regulation (Scotland) BillCONSULTATION RESPONSE

NAME Gary Moyes

Please indicate whethe !ou es"onding as an indi#idual $e$%e o& the"u%lic o on %ehal& o& an oganisation'

On behalf of an organisation

I& !ou ae es"onding on %ehal& o& an oganisation "lease gi#e details%elow

Na$e o& oganisation Fife Council

*ou Title Lead Officer (Network Planning & Inforation!

Addess "rans#ortation & $n%ironental er%icesFife Council'ankhead Central'ankhead ParkGlenrothes)* +G,

Tele"hone nu$%e -./01 00 00 00 e2t3 // // 45

E Mail addess gary3oyes6fife3go%3uk

Consultation $ethod 7##ro%ed by Fife Council8s $2ecuti%e Coittee (4- 7ugust 4-19!

+, -o !ou su""ot the geneal ai$ o& the "o"osed Bill' Please indicate.!es/no/undecided0 and e1"lain the easons &o !ou es"onse,

)es3

Paragra#h 1 states: My proposed Bill aims to give transport authorities greater control overbus services in their area by enabling authorities to regulate how they are delivered.7s ageneral ai: we would welcoe the ability to ha%e ore control o%er the bus ser%iceso#erating in our area3 ;e do su##ort ore control for Local 7uthorities and the "rafficCoissioner to ensure ser%ices are o#erated that suit counities8 needs3

"he 'ill entions the legislati%e setu# in London but sto#s short of recreating this in cotland3;e would therefore ask that further inforation is #ro%ided on how the #ro#osed franchisingdiffers fro the London franchising in order that we ha%e a clearer understanding of the#owers a Local 7uthority would ha%e and how they could be used effecti%ely3 ;e wouldwelcoe ore detail on the #ro#osals and would ask that further engageent with Local

7uthorities: through theAssociation of Transport Co-ordinating ffers !ATC"#takes #lace3
mailto:[email protected]:[email protected]


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2, 3hat would %e the $ain "actical ad#antages o& the legislation "o"osed' 3hat would%e the disad#antages'

Main Advantage"he ain ad%antage of the 'ill is the Minimum $evel of %ervice#ro#osal (&'ull (ay)%ervices".7s a eans of trying to address the figure is si#ly an e2a#le: as a fine balance has to be struckon what is %iable and what would lead a co#any to decide to withdraw daytie ser%icesbecause the e%ening ser%ice would cost too uch3

e%elo#ing the abo%e idea further: there could be national iniu standards of bus ser%ice#ro%ision established rather than the abo%e local iniu standard3 Dsing a %ariety of#o#ulation: de#ri%ation: accessibility and urbanArural indicators: iniu fre?uencies couldbe defined for e%ery #art of cotland3 $ach urban and rural area can already be Eoned using

accessibility software to take account of these indicators3 For e2a#le: anyone running a busser%ice within a city would ha%e to run defined iniu fre?uencies on daytie: e%eningsand undays: whether Glasgow: undee or In%erness3 If the routes ser%ed areas of ulti#lede#ri%ation: the fre?uencies would ha%e to be higher3 ural %illages would ha%e asafeguarded iniu ser%ice le%el to the nearest e#loyentAsho##ingAhealth facilities etc3"hus: legislation would enshrine that siilar areas across cotland ust ha%e the saeiniu ser%ice le%el3

$%en if no other #art of this 'ill is taken forward: we would urge that at least the abo%e#ro#osal is #rooted as an aendent to the "rans#ort (cotland! 7ct 4--13

Main (isadvantages

;e see two ain disad%antages with the #ro#osals funding and the o#tional nature ofthe3

'unding"he current legislati%e fraework has changed %ery little since the 15.0 "rans#ort 7ctderegulated bus ser%ice #ro%ision3 'us co#anies recei%e incoe fro fares: Local 7uthoritycontracts: 'us er%ice O#erators Grant and the Concessionary Fares chee3 If the 'illforces o#erators to run soe


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and the cottish Go%ernent will need work together for a better funding echanis if weare to achie%e the ty#e of bus network we all wish to see3

ptional *egulation"he 'ill #ro#osal is for


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over how all services (including commercial routes) are operated. Fife ouncilwould like to use such powers to de!ne routes and timeta"les for the "ene!t ofour residents. Whilst we have total control over our su"sidised routes, we cannotin#uence commercial routes or timeta"les. $n essence, commercial "us operatorsplan their own commercial network, in competition with other operators. LocalAuthorities are expected to %!ll the gaps& at unpro!ta"le times or in unpro!ta"le

areas. We would like powers to coordinate the entire network ' includingcommercial routes to ensure routes and times suit the needs of communities."his would be regulation3

5, How can community transport be better utilised to serve localcommunities and particularly lowpassenger volume routes?

Firstly, many community transport operators operate under a %ection *+& licence(see Transport Act 1!"), which for"ids operating local "us services. A lass *+ licence does permit operation of a %"us service& for residents of a speci!ccommunity "ut the general pu"lic cannot use the service. $t is, in e-ect, a %closed&service. emoval of this restriction may encourage some kind of "us provision inlow volume areas "ut we would "e concerned over the /uality and suita"ility ofvehicles, especially as we head towards the implementation of the #$%

Accessibility &egulations 2'''. 0any community transport vehicles in thiscategory are standard mini"uses, not suited for stepfree or wheelchair access. $f*+ legislation was amended to permit operation of local "us services, the 1ra2commissioner should have a role in ensuring vehicle, maintenance and premisesstandards are similar to those re/uired for %ection 33& licence holders. A 33licence does o-er the a"ility to operate registered local "us services.

1he di2culty for "oth *+ 4 33 licence holders is the %not for pro!t& clauseattached to "oth such licences. With a 33 licence, it is possi"le to tender forLocal Authority "us contracts "ut no pro!t is permitted. 1he operator musttherefore go through a complicated exercise to prove that they are not pro!tingfrom the contract, which can "e a disincentive to many. 1o encourage 33 licence

holders to "id for Local Authority contracts, legislation could "e changed to permitsome level of pro!t for the operator&s organisation.

$f the a"ove proposals are taken together, it may "e prefera"le to merge *+ 433 licence legislation to create one single licence type.

Fundaentally: though: it ust be reebered that 15 & 44 o#erators e2ist at #resent to#ro%ide ser%ices for s#ecific counity needs3 Few are interested in tendering for Local

7uthority contracts because it reduces their freedo to o#erate the counity ser%iceswhich they were set u# to o#erate3 If 15 & 44 o#erators are to be encouraged: throughlegislati%e changes: to run local bus ser%ices: it ay ha%e an ad%erse effect on thecounity ser%ices that they currently o#erate3 In addition: if they are now to be %iewed as#ro%iders of local bus ser%ices: they should not be e2e#t fro any franchisingAroute

bundlingAiniu le%el of ser%ice legislation #roduced as a result of this 'ill3

;here Local 7uthorities ha%e fleets o#erated under 15 legislation: these are usually used to#ro%ide ial=a=ideAing & ide ty#e ser%ices for those with #ersonal obility difficulties3 Ourabo%e suggestions relate to #ri%ate 15A44 o#erators but #erha#s the si#lest way to#ro%ide soe bus ser%ices at non=#rofitable ties would be to allow a Local 7uthority=onlye2e#tion to allow use of e2isting Council %ehicles for the secondary #ur#ose of #ro%idinglocal bus ser%ices3 "his could certainly reduce the costs of e%eningAunday #ro%ision3 "he%ehicles would still ha%e to be #urchased for their #riary #ur#ose but a legislation change


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would #erit their use on any


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together on, taking into account current levels of "us su"sidies paid "yAuthorities and the levels of su"sidy7reim"ursement paid "y the ;overnment forthe oncessionary 1ravel cheme and

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36 Fife Council