Laan om Lothian Buses welemes the ppartunty to comment on the corsultatlon document in ration to the above Bil Lotion Buss ple ‘Bus Regulation (Sota) Bi: constation 1 Summary 1.1 Lothian Buses fly endorses the core objective stated Inthe paper but doesnot bleve that the propose Bl would achov that core objective, 12 Tg peer sw teat cay and acral wht ny sng 1 13 fas to acknowledge thatthe presant regulatory repime fs capable of delivering very high quay sores at very litle cost to the pubic purse 14 The proposal that local authories should have the power to intervene in a market vthout any dty to. demonstate that that lewenton is actualy needed fundamentaly wiorg and potetaly very damaging 15 The paper commends the London meds without recognising is substan costs and shortcomings 16 Ih ywongy mplis that fanchising of a. number of routes can somehow be achieved Avot addtional subsidy rom the pubic: purse 17 The paper gostes over powers that local autores akeady have f they dont wie thar, that of ea does nt rake the case for greater regulatory powers. 18 The seareiy/abeance of lve Statutory Quality Parinerships or Qualy Contracts is not 8 vali ncbeatr that the present system Is fing as these ae enablng mechanisms, not tends i thesoles 2. There objctne zn the sated aim ofthe proposals 21 The cor objethe of bus seve provision 212 In considering potential changes to the regulatory epime governg the provson of bus Servces il important to Keep the focus on the objective succtly set out i the ‘Sroductory words atthe very start of the consultation paper '+ ‘Good pubic ransprt~ effective, lable, safe and affordable ~ sa haimark of 0 ‘modem, forwarceabng society 213 Lothian Buses wholly endorses ths statement. nour view, the sight regulatory framework fone which best ser, of would best sore, ths objectne. However, We th nol elev the care far making charges tothe present arangements made inthe ‘onstaton poper Nex do we believe the proposals would in fact lead to bene for2a 2 221 222 au 32 passengers. Indeed, we ae seouty concerned that 35 they stand the proposals cny 3 eri. rsk of uitended consequences whlch would ip fact be davimertal fr passengers there se things that ae not ight with bus sence provson In sme part of Scotian there f aso great deol which snot broken. Theres 9 grove dangetof 3 fix being applied to what ft broken and of that fo actualy breaKing what it at preset broken. ‘Accurate analis of aha, anything, fs wrong & needed, followed by appropiate and ‘proportionate sealmant of any probien once has been accurately defined with 2 obust evidential base, The consultation paper seems to us to propose a soluton before ‘aly defining the problem I's sealang to adress, which i contrary 10 the way public poley and funding deesions are curely made. k's no ight to stat with solution nd work backwards. The Impied ink between ay present problems andthe sructue ‘of local bus operations does nt stand upto scr. The paper does not consider whet ¥ any dsadvoniages xe ental in the proposed solution There Is areal risk of making ‘necdotal bases poley rater than eidental based polcy in this cas, “The stated aim of proposals We are concerned thatthe sated aim ofthe proposal, ie +My. proposal aims to give transport ouhortios greater contol of bus senices In thei area by erabing cuthontes fo vequate how they are delivered 1s an attempt to implement 2 longstanding, if awed, pokey poston, rater than = felition to 9 leary dafned problem, We are concemed that this the aim of the ‘roporas respective of any evidence thatthe stated object of delivering ‘good pube {apo ~ elective, reliable, safe and afrdable fs not curently being met, ond any fevdence that Local Authorly Involvement in this way would improve sences for the publ We believe there strong evidence to demonstrate thatthe presnt regime i n fact Producing vey g00d outcomes for consumers na Way that cost lfectve 10 the pubic purse. Deregulation s works Before considering mechanisms fr improving on what curently exists, fet us frst focus ion the dested outcome quoted earlier: + Good puble tanspert whch 6 effect, reoble and afordabie. [A recent arte inthe Herald (side Track, 8 August 2013), refering specially to the ‘resent canstaton pape, contaned the folowing 1+ "In Londen, buses were privatised but not derequloted, alowing Transport for Landon to contol fores ond serices fr buses i the capt! ~ though only thanks to1a £3bn annual subsidy rom the UK government. Perhops «better example les ‘oto to home ‘eur emphasis. Lethion Buses operates tho logest publely owned bus" company in Brain running 70 routes in Edinburgh, Fast lothion ond33 34 35 36 37 Storionds second chy (ade Taek The Hera, 8 August 2013) ‘his arte points vey erly towards what relly needed, which Isto focus on what is scaly wring wll Edinburgh and to understand the features that meke f wok Boing s0 does not lad t or support eonlsion that rereglaton In any form Is whet rnooded to delver goo bus seve In the iodution ta the consuttion paper, Mr Gray quotes that ver 400 mon bus Journey ate mage Scodand each yarn that case, well over 2 quater of them are {nade on Lothian Buses. is our contenon that In fact passengers sing the serves ‘rovided by Lothen 2uses af well ered. For them, dergulaton is. ging them 2 good Serve. Far from derigratng the stele which & ceary capable of working, the paper ‘ua to focus onthe specie areas where tangs are Beleved not to be working ‘While Lothian Buses belies many of those who promote ether rerepuation or “adoption of the London model do recognise that la fort 2 good bus sevice already tong provded in Edinburgh, what consistent fas to be acknowledged is that thsi being achioved Inthe deregulated rgultory regime. Quragument i that ths succes is @ Tesul of the. deragusted regulatory regime, not despite K- The preset, deregulated rege actualy is working and serving the key objecives sought by bus uses. Kis tho hy costaflecive fo the public pase, much more costeflectve than woul be 2 System whare Local Auhotles take eater contol tS not deregulation that ‘husng fafure in certain pors of the county, and much good woud be at sk if 3 ‘emedy were to be applied where tf not needed. t's utl Yo understand what actualy ‘Sworing well and, eral, Yo recopnse the fundamental component in the regime ‘wich ie making happan: deregulation, ln cing ways in wich bus series could be made better, statis from Tronspert Scslnd’s Bus and Coach Transport Statics are quoted (eara82)- We agree with the {spratons but we balove fs highy relent to the debate to recogise that al of ‘hoc ted have aleady bean echived by Lothian Buses: 1+ The percentage of buses in Scotland fited wth CCTV has more than doubled benween 20058 and 2010-2011 (28% f0 58%) although thi i stl lower than the 2010/1 GB fous of 69%, AtLothian Buses the gue 100% + 54% of buses nae fited with Automatic Vehicle Location devices In 201011 = up ion ot 007 ht si thon eG os GH Aen Bt ty awe 1+ 77% of buses in Scotlond in 20102011 had te smartcord readers compared to 3586 in GB (otih Londen. At Lothlan Buses (and inthe rest of Scotand) he figure if 100% fora bets on registered servcas + over 80% of buses in Sealand n 20101! were accessible or had @ fw floor ~ an Incraoe of 57% over the 5 year period. At Lothian Buses the figure 100% ‘As Lothian Buses operates in the deregulated market is sltevdent that what Lothian Buses has achved hn aleady meeing the asians set out in Transport Scollend’s st has beer achiewed ander darepuston. is que maleadng,thoofore, to suggest that38 39 210 a aul 412 ana 44 the solution to whatever the paper seeks to achieve les in doing away with @ regime which patently capable of dlvering success “he paper acknowledges that there evidence to suppor a igh satisfaction ate wih puble tanport serves, quoting that 76% of adults ore vary or fly satisfied wth Doble traepon. Lothian Buses’ onn cstomer research rom 201 (he most recent year for whieh data i valle) shows the following stsfaction vel: Over satsfactin: 68% Driver bahavout an atetede: 98% Punctuality: 93% Relabity: 96% Vale for money: 8956, Accessiblity: 91% [At the 1k of repeating the same message, thse levels of satsfaction have been fchioved under 9 deegulated rege, I vemahs unclear how a reputed regime shoud be expected to achive better outcomes for passenger. ‘The cave agunst deregulation ot made ‘Why quoted examples do not make the case ‘he paper offers 2 umber of reasons why the test of market fare should be relaxed, Ik quotes First's rationalization of series In East Lothian and Midlothian, Wis indeed = fac that Fist cared’ out raonalsation ih these areas. However, isnot demonstrated fatal nthe paper how ths resulted in datiment to users but Instead leaves the impression that detiment ose, 35 | To justly the pope's proposals. We would Challenge the papers autho to provide evidence to suppor thelr impbcaton that passenger detiment cetted from Frsts sence changes In fot, where the series Fist canceled sere operated under contract to the lca! buthoriy, thore sences were replaced In thal eniely by new conacis awarded to ‘ther operators wo now offer services of at last 95 hgh quay as tha previouhy ‘ered by Fst. Whue the servces which were withdrawn were operated commercial in amos al caves commetcl services continue to be provided by other operators, eowies ofa ost gh a quay as tose that were whdrawn, and in some anes at Tower fares hs wrong therefore to ofler hs example as 3 jstiicaion for making fancamentl changes toa regulatory regime wich & Infact working well if there is a concer that F an operator decdes to withdraw ffom exising contractual larangements ths. imposes an administrative burden on focal authors, the epparent favouring. of the “London model of network tendering does nething to reduce ths Indeed, in London there hae been conaderable experience of incumbent contractors Teoveg the market, The re of that happening & ot reduced at al by adopting the London modal Ro better In tht regard se indeed may be Wewed as worse, 25 842 42) 422 425 426 change of contractor on a packaged group of routes may well be more onerous to “admiter than changes 2 te leel ofan nial rote “This "worst-case scenario 8 led nthe troduction tothe consultation paper, does not therefore demanstat why the current system should change. Funding of oes making senices ‘The paper states tht Moray Counel has decided to stop funding local bus services. fale fo sate tht th counel nonetheless has the powes to support local buss “he fact thatthe counel has chosen rot to is simpy a cate of a decison tf make in determining hs spending rors. I the implication i that fnchiing Slow the Counc te secure bus services at 20 cost fo the publ purse, thf ‘emorstrated to be 2 vad presumption. al “This example of whet fat taken pace in Moray serves to highlight what wo understand to be one of the cate cbjectnes ofthe current proposal, namely, to find ways other than the entng tendered senaces mechonism [a which bus servees whose operating oats ae nol covered by revene Kom Taes paid by passengers wsing that serve cen nates be proved In Edinburgh, not al but serves which the public or Councls might believe desiable tre provided ether by the dominant publelyowned operator 0% by other (minor) ‘operators LB sets cut opeate commercaly and to delver a dhidend to #3 foal uthorky shareholders, t would therefore not seek to operate, without subs, services which have no charce ofa least breaking even. Were it 10 do s0. or were # to be ‘blged to. do 20 bj beng tequted to operate bunles of sencs, ome profitmakng Snd others lossimabing, the rete LB coud make to as shareholders would be hit Note: Once po tothe shareholder, the (8 reurrs become public expenditure. That Enables the Counc! 10 male democratic decions on how to! spend those returns 0 ‘acura ts gfend oucomes ard best valve) The some arguments apply, to an even greater extent, to other commercial companies in ainburgh or eevhere i Soalad, where the return to shareholder requrement may Be even more imperiant In other words, F Lis want {0 see sevces proved which ‘Would run at 2 fos, thee & no escaping the inevtaby that LAS would have, to stan ach sens ety, ney rough receded whe a hey ‘med the compares, LUniess one assumes that LAs could operate services, themselves, very much, more efcenty than cent operators (and, Yor exemple, LB is arguably 2 very efficent Speratr ejoying spies advantages of Scale Sone scope for increased efiencles & Surely smal) there Re of no scope for gam without exta cos. No pate owned ‘operator wil tender for 3 fonchse, sence er bunele of sarvces unless he can secure hntacts at 2 price whch allows fen to make profts ~ indeed thi is the way that Tendered senses werk at presemt, wth such serves akeady beng subject to the type (of often strong competion whi mis poft margins sbout as far as Weseems possble tops. ‘The answer to present pubc transport provision problems, therefore is not sructural Change Ge. rerepustion of bus companies, of Iranchisng arangements which would428 4210 42m 421 4213 bundle potently profitable and potently lssimaking services togethey. After the ital buding rowed fenching would tend to reduce competion and or increase pices. would ao rece fexilly, wih new services or ncreosed frequency unlhely {o be provided dung the pered ofthe fanchse ‘So long asthe real cbjecive that mare loss making services should operate than are peroted at present, the nescapable argver Is hat more money mast be found to fund thse senvies. [At present there & ra. more money avalable for transport or, fr that matter, for local futhory services general. Any new costs eg. the administration of franchising, end the prouson of entra strides to secure new, addltona or more frequent servEes © at renings and weekends, would have to be found by reducing expenditure elsewhere. ‘The key question for polcy mates sheulé therfore be rom where shoud the maney [At the local authority lve, the chances of resources being swiched to transport fom fer sence, eg, housng or education of soc services, seem extemal fmfod, SO the fal back ‘val almost slwaye be ~ find the resource you requte fiom esewhere ‘thin your transport bust “This then brings inthe concept of opportunity cost, and making sure that monies used ‘or transport er indeed other heads, used to best advantage. If pocy makers atrbute Suficontpronty to mproving bus serves, it 6 up t0 them to say fom where the ‘acon resources eaqared wil be foun. The key question ~ if we thnk of spending, $2y, £10 millon on Bus Substles — 8 what otherwse could we be doing with the ‘money? And woud that atermatie spene create an maintain 3 eater pubic benef bed meet statutory des on best valuo? OF, pul enter way, instead of spending £10 milon on other sanspor (or ether servic) ores, whot could we achive by Spending £10 ion on bus subst, and woud that sch of resurces produce fester public good 35a whole? [An example: the Borders Ralway costs £200 millon to build and needs £2milion ‘soy pov year to mest running csi, what alternate (eg. transpo) projec could behave been Gevered forthe same rmaney and woud the atenatie use or uses Selver greater publ: bent? STAG etc appr 3 too! which can or might help 0 Sraner some, but by no mean al of sueh opportunity cost questions. Rf also worth otng thot STAG appr atleast tars with te se oF problem ~ not the soon LB suggests that the key sue for policins, therefore, at both focal and rational fv Is rotto intevene n the present stucture of bus sence provision 0 long, a8 we troll Srgse othe prevent ucure i afacton and efiend. We abo argue above That change could hve serious negate implications. The way ahead must be to make the case for bus ivesiment tne widest sense) beng incessed relate to other ‘ental and los! gorernment spending pois, {tthe objective at the heat ofthe curent propa Is to operate mor loss making services tore resources are reeded not new structure ontost 72 73 ‘The paper states in par. 19 that ‘autores hand over cash 10 operators to sun Unproablesences but wih ile sayin how they are ur. Tis wrong: autores ‘enter into contacts vith @ supplier of 2 serie and pay for that ‘sere, exactly the ‘Same way es they precure numerous other Hinds of serves for ratepayers. They no more ‘Nandowe cash bus opeatrs than they do to contactors carving cut road reps providing school meas. Far fom having litle say in how those services are run ti the Suthorles themselves who specty contractual in as much deta as they choose how ‘hse services are run. Decisons taken by local authesiies in relaton to those coracts wl be subject to th usual ube scrutiny processes including best value au Regitralons and cancellations The paper quotes in para. 7B that 413 bus services in Scotland were cancelled in 20I0ht ond 542 Ip 201172, creating the Impesson that Scolands Yachg accelerating {oss of bus services. This however fls to menton that im 2010, 457 new saves \weee tegsteed, with 747 new senices regbtered in ZONV/I2 (tases deived rom ‘Notes dr Proceedhgs). To the exten that these statis tel us anything, is very rnisleacng to ote feductions but to ignore increases. fat, thse statics tel us Ile of relevance since the reguations for regering bus services cause certain kinds of charges to servees to be made by canceling 2 regataton and creation of a new one, father than by vaning an existing reisvaion, and a saree operated under contact, ‘local authority” passes fom ove operator to another, the repstaton has 10 be ancoled and reloed by a new ore.In cher words, canceling a reqstaton Goes nt ‘mean that a service has been withdrawn and W5 mislesdng to create the impression that t does, Quality Contacts ‘Te paper evidently sees the absence of any Qualty Contacts as inleatve that the rogene 6 flawed, 25 Qualy Contacts are on end i thomsales. Thoy aro not. They fre a meane to an er, that and being fo cater for passengers rises were the pray ‘mechani, the mari, has faued. There ie beoktety nothing wong wh that pnt 4nd absolutely nothing wrong vith the princple that the orus should. lle ona focal Suthorty to prove the need to Inervene. We beleve thet i any local auoiy was {gonuinly so concarced about passenger” needs could and would Indeed use the ‘echanism curently walable to noduce 8 Quality Contac. ‘We belive that many who se changes to the regulatory regime as being desable ao consider Edinburgh a enjoyng amongst tbe best hab curently esis bus service ‘rovsion in Scotland. As what Is boing achieved in Edinburgh ls being achieved without ther 3 Statutory Qualy Partnership or 2 Qualty Contact we see fle argument for ‘Sing tha te abserce ‘of Qually Convats of tse evdence thatthe present regime 15 ating: cleary good cutcomes are entirely achievable without the existence Of 3 ‘Quality Conta ‘The Qualty Contacts 2 statutory mechanism introduced by the Scoish Patlament 9 address fours" nthe market. 1S fit to see how one can deduce thatthe lack of use ofa alu’ mechanism means thatthe overl system i fang. At worst, only Indeates that those authors expenencing atures’ are not ubssing. the exing ‘eed mechan,81 au 812 ans Why the proposed saions would not work the London Model ‘The are quoted atthe start of section 3 of ths submission cites Eerburgh asa better ‘example than London. Wo spree: et us not fll into the trap of being mesmerised by how things are done in London. ‘Much of London's bus sence provision & good, but mast of what is good about In fact being davered hy Sealand under the present region reyime, at vetaly no cost, {o the pubic puse, Some of London's bur sence provson s net good. whereas the prezant regulatory rege f delving beter outcomes n Scotland ‘The recent series of television documentaries charting London’ buses (The, Route Masters, #BCZ) wat dsiucive in lustatng the excellent work which is done in Proving the capt’ bus sonices but ako tstated 2 tay shortcoming of the Tendon regulatory regen, which I ts inbaty to respond. qucy to passengers’ needs In'one pat of the docomentay passengers were shown beng forced to enduce lengthy ‘wats for a bus on a dal bast because buses on that particular route were consétenty Filo copoty Instead of proving the required eddtanal buses to cater for the unmet passenger demand, herby sohing the problema TIL offal was shown at 2 pubic freeing stempting t2 defend Ties inabity or unvilingness to increase the level of fervice, The operate was presumably meetings contractual oblgatins 20 had no incentive 1 provide more buses. & rogme under which bus servces af provided under Contact iflextblef& no. good for passengers in such a situation 10 have to wait intl the naxt tender round for solulon to'9 problem vith thelr bus sence to be Implemented, On the other hard, 2 rege which response 10 changes in the market 1 capable of reacting qucy to such needs: opectors are going 10 generate more revenue by running move buses they wil do so. A bureaucrat wo has no such icetive es While the level of subsidy in London quoted inthe Herald arte is misleading, a this sum appear to. ince S0S0y for ral serves, the message is nevertheless entely Teleont ae bus servee prouson in London comes ata masse cost fo the public puse. this simply eng to sy thatthe London model iene Which ought to be tho template fora remedy i Scofand without acknowledging the colossal subst which underpins ‘The level of subsdy for bus operatons quoted. in Transport for Londoa's 2012/3 accounts 377m, equating 1218p per passenger. [nfact, we suspect ths is the mount decty pad © operating convactrs and may not ich substi TL central Services dec etroutble to buses, whase equlalent costs ae in Scoland bome by ‘porate Thi ate of suse in Sellnd woul be simply unaffordable but without Ie Tar fem clear bow the London mods! woulda fact be capable of delivering the tlesied outcome in Scolland. Nor Rat al clear tha such model sctualy would ‘dtver those outcomes mote effectively than the preset regustryvepme ‘5 contrat the lvl of pute funding suppeting bus services in Ednbwh amounts to (0057p per tolalpatenge, compared on 9 Iker ike bass (je. excudng Bus Service ‘Operators Grant and fussing fr concessionary travel In both cases) vith T6p per tot Dsrenger in Lander, ke, 0.04% ofthe level of London substi. Given the widespread [eknowsdgement of sateaction with bus sence provson in Edinburgh there i snplya6 aur 82 aaa 822 ro case for subst the London model. Wile this makes the case principally for no ‘change’ in Edinburgh Simo arguments apply to al other pats of Scotand. In fact, some serses, the regulatory regime which is deverng good outcomes for Passengers in Echburgh is precsely the opposte of that which pps. London: theres in London us operation was privatised but Senice provision temas replated, in Edinburgh operon remans In pub hands, whe service proviton was deregulated Ih Lothian’ Buses yew, making bis senice prension responsive to the market has Wwotked, combined th publ ‘ovnership. but commer operaton. Removing Tesponsieness to the market woud nour vw act severely against the interests of pastengors and woud indo a great deal of excalence, not only in Edinburgh but in rays rl Sd we pty ome carpe we erg Ye Meh iy services. 1k seems Mogeat to propose mechaisms based on a model which not akesdy elverng sucess in Scoland eather than to bull on ane which Is akeady proven It Scotland, Rether than acvacate the use of the London model or mechanisms deved fa when rat model len to eon, woul be mate conser vi recogntion ofthe siccexses achieved in Ednburgh to seck to extend tht proven mo to the rest of Scotian Instead of any mechensms based on what happens in London, we would suggest thet Hf 3 Loe Authory balers tat company owned by K could be more effective In nesting flstomers needs than caro operators, that auth should have te legal power, at ‘scretlon, fo extablay (or acquis) a bus operating company so long as is run at arms length from the owning authory, and operates within the dergulted, compettve market, ts lsthe cae with Loan Base In greater Ednburgh. Bundled franchises ln oppareiy beevng shat proftsble routes should crosssubsidso unprofable ones UTogodess of the fact the ant achived without subsidy In London) the paper fais to ofler any station for why effect the subsiy forthe unprofitable routes shoul come ely from Bus wsers (hose paying fares to tevel on the prfable routes) rather than ffom the ponuace et large tMough taxation. Why should, for example, the fare payers ho travel fom Orumchapel tothe entre of Glasgow be the ones who provide the subsky for the bus fom Mingave to the West End or those traveling fom Muihoute to Leth pay forthe substy to provide the bus from Raveston to Blckhal? Sure is more eqitabe thatthe coune? tax payers of Mingave or thse in Ravebion Ihake some contibuton tothe susiy thr ervess need? Though the present stem for securing tondered services. they do. ‘Athough not expres sated inthe paper, there & an implcaton that combining both proftable routes ont anproitale ones ito a single anchse package wil somehow Feed to contac tnder which the prftabie elsment ll poy for the profitable Slemert. Quite apat tom the inequity implicit n such a premise, pointed Ut above, there Is no evidence whatever that ths would fact be the outcome. In fac, gen the masse ‘subsidy wich supports buses in London there ts yery song edence {0 Supoor the vw thal even ina market as danse as London, franchising requires huge financial support fom tho pubic pus,923 ery 233 on 'fanchng cat be achleved on basis neural tothe public purse ina market as dens as {Tendon what sister for thinking could be In Scotland? in ou aw ranching woud not be efrdabl In S:olnd. Removal ofthe markt fare test We adnowiedge that the proposals ental giving dictionary powers to local Butorties, rather tan universal charge 10 the present system. What is envsaged is @ Bower to imervene more ready than i possBle at present, arguing that the provent EQurement to esatish that the market Des fled % fo0 onerous ~ in essence, tht it ‘Should be sata for local auteras to interven. ‘This, however, is te single most dangerous part of the. proposal, Removing the Dolgaton on aloe authory to demonstate market fabure before exercing the Proposed new regutory pomers in effect would he care Banche dicreton to Frervone without hivng cles evcerce to show that passenger’ needs are not being Ime Ths could lee} to the eesttction of something which meets consumers’ needs ‘utely to elver a leng held poy ides, This cannot be rit hk may be that there should now be wide discussion on, and proper testing of, whet TFaiet falure' mom, and the coal! potentaly make iterertion less dieu where the need for such ntenenton can be ful psted. However, i our view tht, even fw, f'¢ Local Auborty belies that thee & Uuly 2 need to intervene, could and Should make the eft to use exsng powers ‘ncamains fundamental however, hat in order to protect passengers Interests t's iperative thot any aby ta tervene ssubjectto an cbjective test demonstrating mark flr Local autores andthe Trae Commistoner ‘The paper one-siey suggest tata the defclencis in bus sence provision i at the {ca bus opersion. Nowhere does racogise tat functions which aleady st within the contol of lace autores form a key. component of the delvety of geod bus Services, fang to recognise that takes no proposal to adress. uneven SF those functions across Scotlands focal authortes and instead ervisages that creating Larger sticks. wth which to. -ht operators wil alone beng about the dested on is Nowhere there any proposed measure to ensure that focal auhortes play ther por. sead, suggests that local authority control wil somehow of tse Free about provement, We belove this is wreng. ‘he paper clos » numberof aross in which improvements would be beneficial quoted from the government socal research survey Understanding why some peaple do nt Use buses (para. Wnluded amongst those ace: + Inproved ight, sheter: ond information, nctuding occurate ‘Real Time’ informatio, et bus stops + Aeton to try 0 inprve the speed and rlabiny of buses, incudng beterMonger bus anes)93 9 95 96 ro 102 tsewhere, the paper quotes evidence from Bus Users UK to the UK Potloment’s ‘Tanspont Select “Cormite (albeit without saying if any equivalent evidence has been ered to Holracd hr elation to vanspor in Scotand), save. 1+ goverment & serious about getting more people on 10 public transport then pig mre sare oes elbity fs sarc fo be 0 Nae roy ln sting why the current system shoul change t quotes (a. 2) from the Scottish Household Suey song thet + ‘of the people who said t would be pose to trove to work by publ transport but dn (43%, [.] 54% (aid wos] Because would take to fang” [AL these aspirations (which Lothian Buses endorses) le outside the capably of bus ‘peat to deiver > they le wii the are of responsi of local autores wich SEie have the pover to provide better nastrucure, chiding bus pony messes. She proposals completly Ipnre this fact and instead focus on operator, without any Tecogniton thal whe some lal authors’ commitment to pubic transport Is beyond ‘question, others do next to nothing to support improvements in bus service provi, Nowhere does the paper prapose oblgatons on local authorities 10 deliver on these Ineesures and sancons on those which fal to do. so. Given that lcs! authority Commitment fo such messes I variable, not credible to presume that focal Suthorites are in some way Deter equpped to delver the desred outcomes for passengers than cpaators. The proposal that the Tie Commisioner should have powers to ley franca penalies on operators who withdraw fom fanchsed services seams clumsy. i 3 Eontocior provding refs collection servces to 2 councl withdraws frm @ contac tary penalty for dong s0 would be expected to be bull info the contac, would not Fal fo 9 separate refure colection regulate to leey any penaly. No explanation is Offered as to wht the propose regime shoul apply to bus Service provision. there is ‘eod to recover cst Wom an operator which whdraws fom contact the pace for feng etna f'n the oso he cant oo weigh se ein reauerate enter, Concaton Propossls which one cou say wah confidence would deliver benefits to the consumer would be wekome, That cannot be said of these proposals as they stand. There may, ‘Rawaver, bs mera examining two potential changes fo preset arrongements 1+ ing 9 Local Auborty the power to establish its con publey ovmed bus ‘Sperating company, provided hat any sech company must operate commercaly the dereplte, compettve markt. + Seting out a corr definition of the test which Local Authocias must apply to sabish marta. ftre before” 9 Quolty Cortectcan be intoduced, while Fecogrisng the imperative of retaining an obligato To do so before intervening A changes are to be proposed & eset that they are based on a clea extablshed, ‘evidence base of delcleney nthe present avangortents sod its equaly essential thatwatt proposed can confidently be expected to rest in improvement and secure best Naluc. The present paper nather denies clearly any defeieney nor Is there any ‘rence to Say that te proposals contained in wl fad to eres (othe consume Indeed, theres very stong.reasan to belive that ab curently raed they coud ‘ctaly land to sets consomer detinent.