The overall aims would seem largely acceptable as far as they go.

Point A:

Certainly some good-quality reliable research into what works well, what passenger attitudes are and what it would take to convert non-users into users is essential. The last-named is an essential piece of the jigsaw, though will need sophisticated research techniques. Many car users blame paucity of public transport as their reason for choosing to use the car, even where there is an adequate public transport alternative.

Research materials need to be drawn up with a thorough understanding of the needs of bus passengers, where often the most effective solutions are the simplest ones which can be overlooked if research is conducted at too sophisticated a level.

Neither must research be allowed to be skewed by vociferous specialist interest groups, whose needs may be met at the expense of the needs of the greater ‘silent majority’ of bus users.

Point B:

We welcome the inclusion of passengers in the process of making key decisions.

Point C:

‘Make suggestions about the future direction of bus provision’ sounds a little half-hearted; we would hope the body would have ‘significant influence in the decision making process concerning the future direction of bus provision’.

Overall we are concerned by the suggestion that the body should ‘operate primarily at the national rather than a regional or local level’.

Rail services connect different regional centres and most of their issues can be dealt with, and have an influence at, national level. Bus services are essentially highly local in nature and localised solutions are essential. Any national focus can work in only the very broadest terms to influence bus policy, and a concept which works well in one location is not always transferable to another locality, even one which may seem superficially similar in demographic or geographic terms.

Issues such as fares are decided at local level and are affected by numerous local factors in addition to the more national trends in fuel costs, insurance costs etc. Even staff costs will vary in different locations; the last attempt to produce a national wage scale for bus drivers under National Bus Company in the 1970s resulted in cost bases rocketing unnecessarily in some locations while other locations with plentiful other local work opportunities and high wage rates had chronic driver shortages.

While there may be scope for some national targets, eg minimum distance of dwellings from a bus route, minimum frequencies and/or hours of operation for populations above a certain number etc — and even these may be inappropriate or impractical to achieve in every location — for the most part each locality will require bespoke local solutions. We welcome the fact, incidentally, that the Local Transport Bill appears to recognise this by offering a number of approaches rather than a single, all-embracing structure for the industry.

2) Do you feel that the body should cover any items not included in the suggested remit in paragraph 15?

Do you think that there are any items covered in paragraph 15 above that shouldn’t be included?

A.

We consider that ‘representing the interests of existing and potential passengers in England through the use of evidence and influence’ is too narrow a remit and that there should be a single representative body which includes dealing with passenger complaints. The Bus Appeals Body is an effective medium, which needs strengthening and enhancing.

Passengers are already confused by a multiplicity of operators, the role of the local authority/PTE/PTA, how the Traffic Commissioner fits into it all and the role of the Bus Appeals Body; they need a simple and well-recognised focus for their complaints, suggestions and all other aspects of bus passenger representation. We feel that having a body dealing simply with national concerns will be far too remote from the individual user and will be considered irrelevant to most of them. A bus passenger representation body needs to relate to passengers (and indeed non-users) where they are, and needs to be the focal point for their complaints along with any other issue affecting them: though we recognise that the first port of call should be the bus operator itself. A statutory body will be better resourced than the Bus Appeals Body, as currently constituted and funded, to deal with complaints and other issues effectively.

We would also like to see a bus passenger representation body, to some extent at least, promoting best practice in the bus industry. Rail has a growing market place and, overall, quite a good public perception, at least in comparison with other modes such as bus. Indeed its greatest issue is lack of capacity. The overall trend of bus use by fare-paying passengers outside London is still one of decline, albeit with a growing number of bright spots which buck that trend. Perception of bus services amongst non-users is typically poor, yet passenger satisfaction surveys are often positive. The body will need to guard against adding to the perception that bus services are poor, and there are times when accentuating the positive aspects is important, to dispel myths that bus travel will unfailingly produce a bad experience and is for ‘losers’, when this is patently not the case. This must not be a case of whitewashing, but a focus that creates further bad publicity for the industry will create a self-fulfilling prophecy, resulting in accelerated decline and prompting further service cuts.

One of the body’s remits might be the collation and dissemination of best practice in bus service provision, the scope of which would include bus service delivery by the operators, good information systems, best practice by local authorities to provide, maintain and enforce effective priority systems, engagement by all parties with local business and the community, good partnership between bus operators and other stakeholders, local authorities/PTEs in particular. BUS USERS UK already produces a guide to best practice in bus service provision.

B.

Naturally we would agree with the premise that the body should engage with and complement the work of existing representative bodies, as well as with passengers and operators. The local, grass roots view will be essential for feeding into any nationally-based research programme. BUS USERS UK deals with passengers ‘on the ground’ and in particular its surgeries programme encounters thousands of ‘ordinary’ passengers in a unique way. These are set up in such a way that ordinary bus users come and have their say, rather than just those with a particular axe to grind, and the agenda is always set by the individual passenger, so there are no preconceptions. Feeding in of issues arising from surgeries and from the complaints process will be a vital part of any research.

Our greatest concern about the work we undertake is that it is grossly under resourced and any solution that involves BUS USERS UK feeding in core information into a nationally-focussed research-based body should be funded by a proportion of the available resource being directed to BUS USERS UK to enable it to function on a properly England-wide basis.

It should be noted that BUS USERS UK is funded partly by the industry only in the absence of other funding measures. While previous Government policy towards BUS USERS UK has been that it should be funded by the industry, the organisation has always been aware that this can create a perception that it is not impartial, and certainly has not gone down the industry-funding road from choice, but as a necessary evil.

Indeed BUS USERS UK’s shortage of resource stems in part at least from its desire to minimise its dependency on funding from the industry.

C.

‘Giving advice and making representations to local, regional and central government regarding the bus industry;’ ought also to include bus operators and enforcement agencies, such as VOSA and the Traffic Commissioners.

D.

We acknowledge the value of research that feeds into the process from passenger level. This has not been properly addressed in the past. Bus passengers tend to be less vocal and less articulate at making their views known than other transport users and capturing their views is vital to any research process. We have on occasions dealt with individuals whose employment prospects have been threatened by unreliable bus services, though these are people whose views are not currently heard. For socially-excluded people with limited opportunity for employment and no choice of means of transport, such issues are of much greater personal consequence than the length of time rail commuters have to stand going into Waterloo each day, and the same is true for rural communities, for which bus services can be a significant yet fragile lifeline.

As always though it does need to be remembered that a national approach may not be universally applicable to the local situation.

E.

We would accept that this point (producing an annual report) is entirely appropriate.

Other issues

Regarding the issue brought up in point 16: we would fully have expected the Bus Passenger Champion to include a complaints remit. BUS USERS UK has shown many times over, both through its own work and that through the Bus Appeals Body, that a body is needed to take on complaints that have been badly handled by bus operators. There is evidence that some of the larger companies are handling complaints more effectively than they were 18 months ago, but it is still patchy and the way some complaints are handled beggars belief. We are also convinced, from the patchiness of receipt of complaints, that passengers are not universally aware of what avenues are open to them and that not all bus operators are doing their best to advise passengers of these avenues.

If there is be a single bus passenger champion, then it ought to champion the needs of individual passengers at grass roots level rather than exist solely at a much higher level, which will be seen as irrelevant by individual users and add to their feeling that they are disenfranchised. Moreover, given the local nature of bus service provision, a body simply producing national solutions will be of limited value.

Whilst BUS USERS UK is happy to continue its role, in conjunction with the Bus Appeals Body, it would be more effective doing so as a properly funded and truly national body as part of the overall national bus passenger champion. Bus passengers should have access to a ‘one-stop shop’, at least from the point where a bus operator has failed to give a satisfactory response to a complainant. We would like to see a standardised route for complaining with a very simple message on each bus, repeated on the upper deck of double-deckers or rear section of articulated buses, telling passengers (a) the name of the bus operator, (b) the address, phone no and e-mail address to which to complain and (c) the address, phone no and e-mail address of the ‘body’ for use when they are still dissatisfied. Transport for London uses notices to similar effect which include the registration number of the bus, which could be useful information for the passenger when pursuing a complaint. We would also like to see the practice whereby some local authorities post details of Bus Appeals Body/BUS USERS UK in timetables/on bus stops extended to cover all areas for the body.

Regarding point 17, a statutory complaints body would not take away the local accountability: BUS USERS UK and the Bus Appeals Body has always stepped in only after the operator has had the chance to deal with the matter. It is entirely appropriate that such an approach should be maintained, with operators having the first opportunity to deal with the matter themselves. But companies will often stand behind their own unilateral policies (a favourite one, for example, is that the company will only reimburse a taxi fare if it has failed to run the final service of the day) and users need a dispassionate third party to take such matters further and prove that such policies are actually quite meaningless.

Were the body to have a ‘signposting role’ (point 19), which directed more passengers to BUS USERS UK and Bus Appeals Body, both organisations would need an increase in resource to be able to respond to the increased demand for their services. Both are committed to giving a good service to bus passengers and both would welcome the ability to resource a much more effective Englandwide role.

Preferred options

Option 1 – Working with Existing Bus Passenger Bodies

BUS USERS UK has functioned well as a body representing bus users for more than 20 years. It is run by people who use buses regularly and have a good understanding of the issues that face bus users in both urban and rural situations outside London; bus use in London has several key differences from bus use elsewhere and an understanding of how bus services work and how people use bus services outside London is essential.

BUS USERS UK has a history of campaigning on a national basis for overall issues which affect bus users, such as the adverse effects of traffic congestion on bus services and the need for improved and properly-enforced bus priorities.

It has developed a wider knowledge of issues that affect bus passengers through working with them to resolve complaints, and in its unique bus users’ surgeries programme, which takes buses into shopping centres to enable ordinary people going about their daily business to meet the people responsible for their bus services (operators and local authorities) with no formalised agenda so that people are completely free to express their own particular concerns. Information fed back in this way is often very specific to the locality, but there are growing trends across the country which would feed into a national research programme: these are issues such as:

• poor frequencies in the evenings and on Sundays which often lead to social exclusion

• poor frequencies or non-existent services in rural areas

• an increasing intolerance of mobile phones and music on buses

• services being driven too fast or with insufficient care for passenger comfort

Although BUS USERS UK and its associated Bus Appeals Body currently have no statutory powers, for the most part operators are used to respecting and abiding by their adjudication in passengers’ complaint cases, and BUS USERS UK has a good track record of bringing alienated passengers back ‘on side’. BUS USERS UK has taken care to understand the issues affecting bus operators so the industry knows it will not make unreasonable or impractical demands of it (for instance when a passenger demands an increased service to meet their own particular need when that need is quite clearly unique to that individual or to a small group of individuals) and as such respects the organisation when it has a legitimate case against an operator.

Regarding point 25, BUS USERS UK does indeed have a regional focus, though it believes a national focus comprises a consensus of regional issues. BUS USERS UK certainly does not seek only to represent particular regions, but wants to build a truly national organisation with full-time professional representation in every region of England (outside London, where London Travelwatch has a statutory role). Passenger Focus has a similar structure, though aligned to Train Operating Companies. The bus industry is much less homogenous, with different groups mingled in a patchwork fashion across the country and a meaningful proportion of bus services provided by non-group companies, and thus a regional approach is much more appropriate for bus passenger representation.

BUS USERS UK has been thwarted from developing further than it has by a lack of resource. A proportion of its income comes from membership, and this is supplemented by direct grants from the Big Five bus companies. Its total annual income for England has been less than £100,000, and its achievement on such a small resource has been considerable.

For some time BUS USERS UK has recognised its need to work on a much larger scale, and is confident that it can deliver better value for money working on that larger scale. Were BUS USERS UK to be properly resourced and with funding that ensures its independence, it would have a much more robust future and would be in a position to represent all bus users everywhere in England.

In Wales BUS USERS UK is already funded by Welsh Assembly Government. It thus enjoys a much higher profile in Wales than it does in England. It has been able both to represent the individual user more effectively and contribute to the overall debate on transport in Wales in a way it has been hampered in doing in England by lack of adequate resource. BUS USERS UK in Scotland also receives funding from Scottish Government, though at present on a smaller scale than Wales and linked to specific projects.

Given the different funding regimes BUS USERS UK’s Welsh operation already functions in an almost entirely autonomous way, with its own offices, bank account and is currently setting up its own Community Interest Company, although it shares certain head office functions with the main organisation, particularly in terms of membership facilities and activities.

The Scottish activities, funded at a lower level, are not yet as fully-developed as those in Wales, but Scottish operations are also largely separate from England. As BUS USERS UK does not cover London, given the existence of London Travelwatch, it is effectively set up already to cover England excluding London, so there would be no geographic anomalies were BUS USERS UK to become the statutory body.

BUS USERS UK’s experience of working at grass roots level with users of provincial bus services throughout Britain is probably unparalleled. What BUS USERS UK does not have is experience in robust research on a national basis, though its local work can form an essential ingredient in such research. While it would be possible for BUS USERS UK to create such a resource, it does recognise that Passenger Focus is one body which already has experience and expertise in this area and infrastructure in place to undertake it, and BUS USERS UK would see great benefit in working with Passenger Focus to provide an appropriate research function, rather than reinvent the wheel. However we do believe bus and rail users have different requirements, and are concerned that rail can easily overshadow bus, so in any such solution BUS USERS UK would need to retain its autonomy.

Option 2 – A new standalone Statutory Bus Passenger Champion Body

A new standalone Statutory Bus Passenger Champion Body would need to learn and understand the needs of bus passengers and the ways of the bus industry from scratch and develop its own systems. BUS USERS UK has the benefit of more than 20 years’ experience of dealing effectively with passengers and other stakeholders, and already has good, robust systems in place, with plans in place to develop these further. While BUS USERS UK as the passenger champion would need to develop research systems almost from scratch, it sees the benefit of working with Passenger Focus and tapping into its expertise in a formal partnership rather than trying to reinvent the wheel.

Option 3A – Conferring additional functions on Passenger Focus

Again Passenger Focus would need to reinvent the wheel to work on buses; a partnership of Passenger Focus concentrating on what it does well and of a strengthened BUS USERS UK/Bus Appeals Body, able to work equally effectively throughout provincial England, concentrating on what it does well could create an excellent synergy which would ensure bus passengers were well-represented at local level and that an evidence-based research programme would feed genuine bus users interests into the policy-forming process. Retaining the autonomy of BUS USERS UK in such a structure would ensure that bus passenger views were not swamped by rail issues.

Option 3B – The creation of a new multi-modal Public Transport Users’ Committee

As already mentioned, the vast majority of bus passenger journeys are standalone, and the synergy between bus and rail (and/or other modes) is less than is often perceived. That’s not to say there is no scope for improved integration between modes, but the needs of bus passengers and of rail passengers are very different. Experience shows that with their more articulate ridership, rail issues tend to dominate most multi-modal forums (and the media) despite the fact that many more bus journeys are undertaken than rail. Given the fact that much of the rail network is focussed on London, and there is a large amount of Anglo-Scottish and Anglo-Welsh rail traffic, contiguity of a bus body representing England outside London and a GB-wide rail network could present difficulties and will certainly lead to confusion.