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Subject Titledd.mm.yy

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The Association of Transport Coordinating Officers was formed in 1974 to bringtogether local authority officers whose work involved what were then newcounty council responsibilities for passenger transport.

Promoting partnership and engagement, ATCO members include staff directlyconcerned with strategic policy development and implementation for securingof passenger transport services for a wide range of public authorities.

These include shire counties and unitary councils in England, Wales and Scotland,Passenger Transport Executives, London Regional Transport, the Isle of Man, theStates of Jersey and Northern Ireland.

Through exchanging information and views the Association helps to develop andpromote good practice, and to formulate policies and standards and promotetransport initiatives aimed at achieving better passenger transport services forall.

Members give advice to the Local Government Association and the Convention ofScottish Local Authorities. The Association cooperates closely with CSS, theCommunity Transport Association and the Passenger Transport Executive Group.

ATCO Members are responsible for the involvement of their Authorities in;

the provision and promotion (but not in general the operation) of busservices

rail and passenger ferry issues securing or providing education and / or social services transport services developing and implementing policies under which passenger transport

services are secured or promoted.

Your Ref:Our Ref:Date: 11 October 2013

ATCO Scotland response to the consultation on theBus Regulation (Scotland) Bill (Iain Gray MSP)

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ATCO Members have responsibility for:

Bus services, including assessment of the registered network and letting,monitoring and supervision of contracts for essential bus services that arenot provided commercially

Administering concessionary fares schemes The provision of infrastructure including road / rail interchanges and busterminals and facilities

The promotion and provision of information about local transport services,including development and implementation of the Bus InformationStrategy.

Promoting rail services - some of which, especially in Metropolitan areas,are supported by their Authorities.

Coordinating and procuring local bus services, schools and social servicestransport.

Developing transport initiatives including community transport, dial a

ride, demand responsive and other innovative services. Developing and implementing passenger transport policy, including BusStrategies and the passenger transport elements of the Local TransportPlan and Accessibility Strategies.

ATCO (Scotland) represents the 32 unitary authorities and the Regional TransportPartnerships (including SPT). It should be noted that this response is based onprofessional officer discussions and does not necessarily represent the views oftheir employing organisations. Please also note that not all of the aboveorganisations took park in the discussions.

Chris CoxChair, ATCO Scotland

e. [email protected]. 01324 504723w. www.atco.org.uk

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Do you support the general aim of the proposed Bill? Please indicateyes/no/undecided and explain the reasons for your response.

ATCO (Scotland) agrees with the aim of improving bus services but is undecidedabout the proposed bill. ATCO (Scotland) would need to see details of the

proposed legislation before forming a definitive opinion. ATCO (Scotland) wouldwelcome involvement at all stages of drafting a bill and any subsequentconsultations.

ATCO (Scotland) comprises local authorities from urban areas where the vastmajority of bus services are commercial to rural areas where the vast majorityof bus services are subsidised. In these rural areas, local authorities effectivelyalready have nearly full control of the bus network and franchising may bringrelatively few benefits. In urban areas, authorities may see more of the benefitsof franchising.

Currently local authorities and Regional Transport Partnerships (including SPT)have no influence over commercial bus services operating in their areas in termsof service frequency, routes, fares and vehicle standards.

In recent years there have been an increasing amount of commercial de-registrations and increased tender prices which has led to an overall contractionin the bus network. This has been exacerbated by the reduction in both centraland local government funding.

What would be the main practical advantages of the legislation proposed?What would be the disadvantages?

Franchising profitable and non-profitable routes

Advantages Local Authorities and Regional Transport Partnerships (including SPT)

would have full control over the bus network, including servicefrequencies, routes, vehicles and fares.

Any resulting increase in standards would be welcomed by bus passengers. Franchising should bring stability to the bus network, increasing passenger

confidence. Would allow introduction network ticketing, similar to the Oyster Card

in franchise areas without current difficulties involved in setting up multi-operator ticketing arrangements.

A large single operator network with network ticketing, complementaryservices, high quality vehicles and cheap fares is capable of significantlyincreasing modal shift.

Disadvantages Few bus operators in Scotland (or indeed the UK) who are large enough to

be able to operate any whole Council area franchises, significantlyreducing competition.

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Disadvantages (continued) Any increase in standards would require a significant increase in funding. Possible lack of expertise in whole-network design at local authority

level, requiring additional staff. Requirement to monitor all services in franchise area, not just tendered

routes, requiring additional compliance staff. Due to local political pressures, some areas with high frequencies maysuffer a reduction in service to provide resources to increase frequencieselsewhere that are requested by elected representatives who may havelimited knowledge of bus operations. This can have a significant impacton commercial services and could adversely affect the financial viabilityof the franchise.

Currently, there is competition for local bus service contracts in most localauthority areas. Franchising would mean that there could be no potentialtendered (or commercial) opportunities for unsuccessful operators whichwould impact on the viability of their businesses. This could lead to higherprices caused by a lack of competition when the franchise is renewed.

Possible long and costly legal cases could be brought against LocalAuthorities by bus operators.

Minimum Level of Service

Advantages Opportunity to provide higher levels of service to communities which are

currently unserved or served infrequently.

Disadvantages Highly likely to result in increased costs. Areas with a current level of service above the minimum level could have services

reduced in order to provide a minimum level of service elsewhere.

Financial Penalties

Advantages Currently, local authorities are limited in what action can be taken against an

operator of a subsidised service for poor performance. Increased powers toimpose financial penalties could deter operators from not meeting the expectedstandards.

Disadvantages Any risk of large financial penalties might result in increased costs if operators

build the risk into their prices. Risk of legal challenges if any penalties are levied.

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In addition, improvements in services would need to be matched withimprovements in infrastructure to make public transport more appealing,including improved bus shelters, real time information, bus lanes and bus prioritymeasures.

In terms of local authority staffing, specialist network design and scheduling staff

may need to be employed along with a team of contract compliance staff tomonitor the network. The franchising process may limit the viability of the non-successful operators,

which would reduce competition when the franchise was renewed thereforepotentially increasing costs.

Operators who own bus stations or other passenger facilities may close theirbusiness if not successfully gaining the franchise. This may result in the loss ofthese facilities which would require significant expenditure for local authoritiesto purchase or replace.

Is the proposed Bill likely to have any substantial positive or negative implications for

equality? If it is likely to have a substantial negative implication, how might this beminimised or avoided?

If the Bill delivered improved bus services it would have a positive impact onequality. However, if due to funding issues, service levels in some areas werelower, it would have a negative impact on equality.

The measures proposed could have positive implications for social inclusion. Amore equitable distribution of bus services is likely to help social inclusion bybenefiting groups of people who tend to be highly dependent on public transport.

Do you have any other comment or suggestion that is relevant to the need for or detailof this Bill?

Any franchise is likely to be operated by one of the larger national orinternational groups due to the level of resources required. It is essential thatsmaller operators are protected to maximise competition and minimise potentialcost increases. Allowing consortiums of smaller operators to bid for franchises(with suitable safeguards in the legislation) may alleviate this problem.

The Bill needs to be backed with funding to ensure that the desired improvementin quality can be delivered, in terms of service level, vehicles, fares andinfrastructure.

Local authorities would need to be given sufficient powers to monitor and takeappropriate action (including financial penalties) where standards are not beingmet.

The franchise period would need to be of sufficient length to make itcommercially viable for operators to invest in vehicles, local authorities to investin any required infrastructure and to attract operators from outside the area.

There would need to be a legal requirement for existing commercial operatorsto provide local authorities with passenger information/data prior to preparationof any franchise/contract.

Local authorities would need agreement from their neighbours regarding cross-boundary services.

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There would need to be guaranteed stability in funding for the Scotland-WideFree Bus Travel Scheme and Bus Service Operators Grant (BSOG) to ensure theviability of franchises for the contracted period.

Franchise funding might need to be ring-fenced to ensure that local authoritiesare able to afford the franchise for its duration.

In order to maximise competition, the franchising of local authority areas shouldbe staggered.

Documents

77 ATCO