Consultation on Scotland's Transport Strategy July Response from First

Transcription

1 Consultation on Scotland's Transport Strategy July Response from First CONSULTATION QUESTION 1. Are: facilitate economic growth; promote accessibility; promote choice and raise awareness of the need for change; promote modal shift; promote new technologies and cleaner fuels; manage demand; reduce the need for travel; and promote road safety the right goals for transport in Scotland? The selection of goals is rightly a political decision. However these goals are all entirely compatible with our objectives as a responsible public transport operator CONSULTATION QUESTION 2. Do consultees consider that the aim, vision and objectives need to be amended, for example to reflect Scottish Ministers' expectation to see Health Improvement at the heart of Scottish Executive policy? There is absolutely no conflict between a sustainable transport policy and health improvement policies. Health improvement through, for example, more walking and cycling fits very well with improved utilisation of public transport. CONSULTATION QUESTION 3. Are there areas of work in relation to local/regional transport that would merit the national dissemination of best practice examples? If so, what are they and who would be best placed to lead this? Real improvements are achieved through effective partnership working between local authorities and public transport operators working as equal partners. We would expect the RTPs to playa key role in leading dissemination of best practice. First believes that there are numerous examples of best practice, some examples: - Four way Quality Partnerships in North East. Aberdeen Park & Ride services. Glasgow Streamline Project Bus Route Development Grant Projects Aberdeen, Edinburgh and Borders Cycle facilities on First ScotRaii - secure parking and Class 322 cycle provision Edinburgh Park station Addition of commuter rail services to Inverness CONSULTATION QUESTION 4. What issues must this NTS address, to ensure that the Strategic Projects Review (SPR), which will follow it is as effective as possible? For example, should the NTS identify key transport corridors, or key types of Investment, which are most effective at growing the economy, to inform the SPR? If so, which ones? The NTS can set a framework so that there is no bias for or against Strategic Projects. Projects should not be considered in isolation, but take account of the total impact on the transport system. A balanced view needs to be taken of the need for big strategic projects (e.g. new or improved roads or railways) compared to smaller scale investment (e.g. local investment in bus priority or additional capacity on existing rail routes). The key to this is the robust and diligent application of STAG. In this way the Strategy will 1

2 Consultation on Scotland's Transport Strategy July Response from First ensure that strategic projects are considered in the context of the competing needs for investment in the existing network. Across the country, investment to maintain and improve reliability is an over-arching priority, without this the effectiveness of investment to improve capacity and journey times will be compromised. The NTS can also consider the role projects can play in achieving some of the Executive's higher-level objectives. For example electrification of rail, with increased use of renewable or nuclear power generation could have a big impact on CO 2 emissions. It would also contribute to reduced journey times and hence economic growth. Our experience is that, if action is not taken soon, peak capacity will become an issue on several key rail commuter routes, particularly Ayrshire and Fife. This must be a constraint to economic growth, especially as problems of urban congestion can only be expected to increase. The main inter-urban Express routes (Edinburgh - Glasgow & Edinburgh-Glasgow to Perth, Dundee, Inverness, Aberdeen) are very important for business travel. In this case shorter journey times are a key issue. In terms of bus operation, we believe it is essential that key, urban bus corridor improvements be targeted, with the prime objectives of speeding up journey times, improving infrastructure and key interchange nodes. We would further suggest that, the use of Punctuality Improvement Partnerships at a local level, could be used to identify network pinch-points and be a means through which strategic bus corridor improvements could be developed. CONSULTATION QUESTION 5. Do we have the balance of investment right between spending on new and existing infrastructure and other non-infrastructure activities and between different modes of transport? If not, how should it change over time? To an extent, the answer to this question depends on a sound analysis and understanding of future needs, and clarity of objectives. Only then can priorities be decided sensibly. However we can make a number of comments: There has been, and is planned, considerable investment in new rail infrastructure. The NTS must also take account of the need for investment in the existing network. For example, there are places where the network is running short of capacity, or where journey times or other aspects of service quality need to be more competitive. Such investment is likely to have a strong business case as demand exists and the impact of such constraints is apparent. In most urban areas, and in many rural areas, bus offers the most flexible choice, and represents good value. Speeding up of bus running times is a priority, as reliability is the prime passeng'er requirement, and is essential if new passengers are to be attracted out of cars. The balance between the different priorities will of course affect how investment is targeted. If the desire is to minimise social exclusion and focus on the least well off in society, there is a good argument for increasing tendered bus network budgets and giving fare assistance to groups other than those currently eligible for concessionary travel. If the priority leans towards economic growth there are good arguments for increased investment in the inter-urban and commuter rail networks. Whatever the priorities are, investment must be supported by a robust business case and STAG appraisal. 2

3 CONSULTATION QUESTION 6. To what extent should transport spending be targeted specifically at areas with significant potential for regeneration? How should transport spending be balanced between regeneration areas and other key areas, such as rural Scotland? This again is, rightly, a political question and as such it would not be appropriate for us to comment directly. However we observe that support of bus schemes can make a difference very quickly, often leading to services that become commercially viable CONSULTATION QUESTION 7. What further steps need to be taken in Scotland to facilitate the development of international connectivity both by air and by sea? Any support given to port facilities will only be effective if it is accompanied by investment to ensure there is adequate rail capacity to support increased freight traffic. Otherwise there is a risk that capacity and reliability of passenger rail services could be adversely affected. Sea crossings need good interchange facilities CONSULTATION QUESTION 8. Do consultees consider that there are issues relating to cross-border connectivity by rail and road, and within devolved competence, that the Strategy should consider? The question of where cross-border rail services terminate should be considered. Through trains beyond Glasgow and Edinburgh can "import" significant disruption from south of the Border (and vice-versa). The Strategy should consider if a more effective overall service could be achieved by focusing on connections at Glasgow Central, Edinburgh and Carlisle, and dispensing with through running. With station enhancements to improve interchange and good quality, frequent connecting services the performance gains could outweigh any interchange penalties. The operation of overnight train services is a fully devolved matter. The continuation of these services is frequently under question. The current sleeper fleet will be life expired during the next 10 years. Any strategy should analyse the long-term future of these services and what form they should take, if they are to continue (for example a long term move to a "couchette" style or to a fully en suite cabin style). They will, because of the space on a train each passenger requires, continue to require relatively high subsidy. It is only right therefore that the value and future of these services is assessed and is explicitly stated in the National Transport Strategy. The extension of the Bus Services Operators Grant (BSOG) to long distance coach services should be considered. This could help ensure a more level playing field, particularly against low cost airlines, and help to reduce CO 2 emissions. CONSULTATION QUESTION 9. What view do consultees take on whether there is a need for a faster Scotland to London rail service, to provide an alternative to flying in the long term? The dependence of the Scottish economy on domestic flights within the UK will be a significant restraint if oil costs continue to rise. Therefore the development of a more fuel 3

4 efficient manner of enabling the business community, particularly those in financial services, to travel to London seems essent.ial to ensure the long term prosperity of Scotland. Rail is already competing on "centre to centre" times - relatively small improvements in journey time could have a significant impact. In addition finding ways to make the "on train" time more productive for business travellers could also have a big impact for relatively small cost. We also note that, while not "quick", the sleepers can provide a service that is effective in terms of time utilisation for many CONSULTATION QUESTION 10. How do we ensure that all local authorities spend their Grant Aided Expenditure allocation for local roads on local roads? Do consultees think anything more needs to be done to ensure appropriate management, maintenance and operation of the Trunk Road Network? We believe that there is a great deal more that can be achieved here, for example: Funding could be hypothecated rather than through the GAE. By so doing, the money would be spent as central Government intended, with a resultant improvement in the road network. There are areas of best practice and Transport Scotland could be tasked with conducting a full audit of the LAs as infrastructure providers covering areas such as: o Maintenance of local roads. o Traffic management and road works. o Provision of bus priorities. o Journey times on key routes. We would also suggest that, as long as funding is by GAE, any part of the allocation not used for the purpose awarded should be reclaimed and redistributed to those LAs who have used their full allocation, so that they can bid for additional required improvements. We are also of the view that there is a need to audit the effectiveness of the utilities' roadworks improvements brought about by the Transport (Scotland) Act CONSULTATION QUESTION 11. What are the issues relating to the management and maintenance of the road and rail networks over the long term that the Strategy should address? We feel that the management and maintenance of the road network is currently not joined up. Trunk road maintenance is contracted out, and there appears to be no linkage between trunk and local road works. Consequently, operators often fail to receive adequate advance notice of roadworks, or the combined effect of different works leads to significant congestion problems. If we are to achieve modal shift, buses need to achieve running times and deliver reliable services. Society is changing and there are increasing calls for extending the operating hours of the passenger railway. We support this, but there must be an awareness of the vital importance of overnight maintenance to the railway. A balance must be struck here, we must not be over-protective of maintenance time, but on the other hand there needs to 4

5 be realism over the genuine needs for maintenance. The operators, Network Rail and funders need to be flexible here, there must be a realistic compromise. In addition, new investment should allow for flexibility and ease of maintenance as these pressures will only increase. Maintaining the quality and reliability of the infrastructure is probably the most important long-term issue affecting the quality and reliability of rail services. We must seek greater cost-effectiveness and productivity - but we must ensure asset quality is not allowed to depreciate through lack of funding. If this happens, reliability will decline and it will take a long time to reverse this situation. CONSULTATION QUESTION 12. What should the NTS say about freight, bearing in mind that a freight strategy is under development? In particular, what should the NTS say about meeting the different needs of freight and passengers on the road and rail network, and how to balance these competing demands? There is insufficient capacity on the rail network to meet the competing demands to provide more freight and passenger growth. We believe there are too many small freight trains making inefficient use of scarce paths. The emphasis for freight must be on longer trains so that the available freight paths are used to maxi mise the load carried. The focus of investment should be on infrastructure or rolling stock to allow longer, faster and heavier trains to make better use the capacity without adversely affecting the reliability of passenger services. Our recent experience is that if increases in freight traffic are hastily introduced this has a significant adverse affect on passenger services. On the other hand, we have subsequently seen how good planning can enable freight and passenger services to co-exist. With proper planning and investment in place, First would support incentives to minimise use of road for trunk haulage of freight through increased use of rail. Road haulage of freight can be detrimental if buses are delayed behind slower HGVs, this does not help encourage modal shift. There have been calls for HGVs to be allowed to use bus lanes, this would be a significant concern for us. CONSULTATION QUESTION 13. What, if anything, should the NTS be saying about skills, bearing in mind the leading role that the Sector Skills Councils have in reducing skills gaps and shortages in the public and private sectors and the role Transport Scotland has in promulgating good practice across the industry? Is it right to integrate skills issues into the NTS? Recruitment, training and retention of staff are a most important issue for the transport industry. It is right to include skills and training in the Strategy as absence of skilled staff is a material risk to delivery of the strategy. The economy is changing and there are high levels of employment in many areas. This is becoming acute in some areas (notably Edinburgh), where a highly developed service and administrative economy is making recruitment and retention increasingly difficult. The rail industry faces particular problems - demographic analysis predicts high levels of retirement over the next 20 years and a shortage of young people coming through to fill these roles. 5

6 Consultation on Scotland's Transport Strategy July Response from First The Scottish Executive and Scottish Enterprise need to work closely with Go Skills. Support for, and investment in, training should prove to be particularly cost-effective in delivering the objectives of the Strategy. Linkage with wider policies is also important. For example the need for a supply of workers for key industries such as transport should be considered in immigration policy. CONSULTATION QUESTION 14. Bearing in mind that investment in new transport infrastructure is not covered in the NTS, as it will be addressed in the forthcoming Strategic Projects Review, what specific steps, if any, does the NTS need to set out to support tourism? The transport industry has shown the ability to develop products to support the needs of tourism. The NTS needs to ensure there is provision of improved information to tourists about services and products. All tourism related businesses should be encouraged to promote Traveline Scotland. The full integration of VisitScotland.com and TravelineScotiand.org is an excellent example of partnership working. The NTS should recognise that tourist demands raise particular problems for all operators. Highly seasonal flows are difficult to accommodate - if capacity is provided this will be under-utilised the rest of the year. This is a particular issue for rail, where capacity utilisation is already high and there is only limited flexibility. When planning bus services there may be opportunities where local networks can serve tourism needs as well as those of residents. This may help to sustain commercially what would otherwise be marginal services. CONSULTATION QUESTION 15. What are the key barriers to developing effective Demand Responsive Transport and how should they be overcome? For example, legislative, regulatory or operational barriers? The National Transport strategy needs to take a step back and reassess the need for DRT on current genuine transport requirements. A significant percentage of the Scottish bus park is now accessible. The DRT perception of the Scottish bus fleet is 20 years old. We welcome DRT where it is used as originally intended, Le. to transport those who cannot make use of public transport. We are, however, concerned if heavily subsidised DRT services are allowed to abstract patronage from commercial networks. We welcome all measures to break down barriers and include social services and NHS transport in the pool of transport to be evaluated and utilised by each area. We support the best use of all available transport to minimise social exclusion in the most effective, economic and efficient way. We feel it is important that BSOG for DRT should only be awarded if the overall BSOG budget is increased. Any reallocation of the existing budget to include DRT would be very detrimental to existing services. 6

7 CONSULTATION QUESTION 16. Where are there examples of particularly good practice in demand responsive transport? This is not an area in which we operate, and hence we are unable to comment as we do not have any particular experience of this area. CONSULTATION QUESTION 17. Is accessibility planning something that should be considered for local or regional transport strategies in Scotland? If so, should it be compulsory, or (as at present), one of a suite of possible approaches? We fully support the use of accessibility planning to ensure that new developments are located in close proximity to good existing public transport links to places of work, education, health care and leisure, with this forming part of both local and regional transport strategies. We are also supportive of the use of accessibility planning to audit current revenue support expenditure to ensure that it is properly targeted to maximise benefit to local residents, thereby improving social inclusion. However, unless revenue support funding is to be increased, many improvements in public transport links will result in reductions in services elsewhere, or alternatively the transfer of funding from other budgets, such as health and education. We would, therefore, favour the use of accessibility planning as one of a suite of possible approaches, rather than being compulsory, unless there is to be a review of the provision of revenue funding such that there is increased funding to support accessibility initiatives. For rail this should happen at a regional level, as the impact on the rail system cannot be assessed at a local level. CONSULTATION QUESTION 18. How can we improve the accessibility of public transport to disabled people? For example, how far should concessions be extended for disabled people? Our experience with rail travel is that the key issues for disabled people are personal safety, availability of specific travel information, integrated transporvtimetables (to avoid convoluted journeys and/or lengthy waiting times) and ease of travel (in terms of both ease of access and provision of assistance). Of these, obviously ease of access has a significant influence. We do not see concessionary travel as being a key driver as regards accessibility though there is a need to better promote the numerous concessionary schemes that currently exist. Bus eligibility criteria have recently been debated and agreed by stakeholders, prior to the introduction of the National Concessionary Travel Scheme for the elderly and disabled. First would seek a period of stability and would not want to see this debate reopened at this time. In most locations where we operate in Scotland, we have continued to invest in accessible vehicles, with many of the local authorities investing in bus boarders. 7

8 However, if regular access to the modified bus stops is not enforced, and our buses cannot draw up parallel to the kerb, passengers with disabilities will not be able to make best use of these facilities or have confidence in using public transport, with all of the aforementioned investment being wasted. We, therefore, believe that improved enforcement of these facilities is vital. There may be a need for local authorities to have duty to enforce these measures. We also feel that training of bus drivers on how best to deal with these often-difficult situations is crucial and financial support for this must be made. The Strategy must face up to some difficult issues. Improved access for disabled people does have an impact on other aspects of the service (such as capacity and punctuality). These issues must be dealt with openly so that solutions can be found that respect the needs of all users. Inadequate funding and a "head in the sand" approach will result in a "lose-lose" situation. CONSULTATION QUESTION 19. How do we make sure that transport operators and drivers follow best practice in dealing with older people, with disabled people and other groups who may have difficulties with transport? For example, should it be a condition of funding that such best practice is demonstrated? Responsible operators are already striving to meet (and improve) best practice. First, in common with many of the other responsible operators, are: Signed up, and fully committed to meeting SVQ targets, which include customer care modules. Working hard to meet requirements (often set out in local authority contracts) with regard to driver training and skills. There is a need for assistance with communication links, primarily helping to raise staff awareness on the wide and often varying types of disability and how best to provide the necessary assistance. There is also a need for improved coordination between bus operators and local authorities. There are examples where shortcomings with the infrastructure make it difficult for bus drivers to take the best course of action. In addition, there are examples where design of disabled access schemes can be improved. For example the Thistle Card allows passengers to demonstrate they have special needs, but does not make clear what those needs are. Linkage of funding to best practice would be impractical and impose costs and rigidities. Who is to say what best practice is? How would this be measured? CONSULTATION QUESTION 20. What more could be done through transport means to tackle social exclusion in rural areas? First supports the measures (discussed in paragraphs 59 and 60), which could lead to the integration of all resources in an area, including accessible health trusts transport. An audit of all transport available to each authority - whether health, education, social work or public transport would ensure this was used most effectively. Where this lead to 8

9 savings, these could be reinvested in enabling a better penetration of the geographical area. We believe DRT is most cost-effective where it is primarily used as a feeder to bus services CONSULTATION QUESTION 21. What do we need to consider in reflecting on the future of the lifeline air and ferry network? Major benefits could be gained from greater emphasis being placed on air and ferry service integration with buses, as well as better interchanges for transfer between modes. Closer partnership working, especially with airports, could increase the bus service network.. Good connections between rail and sea are of great importance in Scotland. These can pose particular problems for rail operations - ferries are affected by sea conditions but rail services must adhere to timetables else greater disruption results. As it stands, rail operators are penalised financially for holding connections with ferries. The Executive should consider removing this disincentive. CONSULTATION QUESTION 22. What more should be done to ensure that there are connections from outlying estates to towns and cities? Many of today's problems are a result of planning decisions taken in the past (even the recent past) where transport operators have not been consulted over large scale development planning. To prevent this continuing, we suggest: Get the transport operators involved before planning permission is given so that services are in place from day one. Good habits need to begin on day one - it is far more difficult to change transport habits retrospectively. Services may need support until they are commercially viable. Make a transport plan a condition of planning. With existing estates there may be barriers preventing the development of good transport links: Where necessary, educate the local population to respect and use the services properly. This would reduce vandalism and fear of assault, especially on evening services. Where there is vandalism and a real (or perceived) fear of assault, the installation of CCTV both on bus or train and in the waiting environment acts as a deterrent and increases the feeling of security. In some cases "pump-priming" may be needed to build patronage up until such time as services can be sustained commercially. 9

10 CONSULTATION QUESTION 23. Are there are any specific areas or events in Scotland where transport particularly well or particularly poorly supports access to cultural opportunities? Are there any specific societal groups disproportionately disadvantaged in accessing cultural activities because of transport issues? The transport industry is good at responding to the needs of major events across Scotland, such as T in the Park, Radio 1's Big Weekend and major golf tournaments. However, major events close roads, and it is often exceedingly difficult for bus operators to get people to and from said events. Road closures for such events very often result in increased traffic congestion, making it very difficult for operators to deliver reliable services and causing inconvenience to passengers. As such, careful thought needs to be given to when and where such events are held. As a transport operator we frequently find that events are scheduled without a full appreciation of the constraints we face, or with not enough time to allow us to develop plans fully. This is a particular problem for rail, where lead times are longer than for bus, and event organisers can fail to understand the constraints. We endeavour to provide additional support to improve accessibility to cultural events in terms of strengthened trains and late night services. This is done where it is both commercially viable and practical. CONSULTATION QUESTION 24. Should travel plans be required of all "larger" employers? If so, how should we define "larger" and should Travel Plans be required of all public bodies such as local authorities and Health Boards to show public sector leadership on this issue? It could be argued that the requirement to produce travel plans is yet another burden on business. However, on balance, it is simply good corporate spcial responsibility for large employers to plan how workers can actually get to work and we support this idea. They should be required in all new developments. Careful consideration is needed over existing employers in locations already well served by public transport. Compulsion may be a burden with little real benefit. It would send the wrong message if public bodies were exempt from such a requirement and indeed they should be expected to show leadership here. CONSULTATION QUESTION 25. What should the relative roles of the Executive, regional transport partnerships and local authorities be in increasing the uptake and how might it be ensured that travel plans required of developers under the planning system are systematically enforced? It would seem to fall naturally to the RTPs to show leadership here and to support local authorities through sharing best practice etc. 10

11 CONSULTATION QUESTION 26. Should we be investing in "smart measures" to promote modal shift? If so, what degree of investment is required; what measures are most effective; and what should be the role of the Scottish Executive (for example, promotion of the concept, sharing best practice, running a scheme or funding others to run a scheme)? Most "smart measures" are aimed at changing public attitudes, and as such need to work at level above that of the operators. As such the Scottish Executive needs to take a lead here, including: Running national campaigns. Coordinating with operators (so services are there for those who wish to change their behaviour). As the main facilitator of a scheme, or assisting others, Le. RTPs, LAs etc We believe that it is vital that investment is directed to encourage and promote modal shift. However, without fully understanding the nature and scale of such initiatives, it is extremely difficult for First to comment on the degree of investment required. An example of an effective scheme is The Glasgow Streamline initiative. This provides travellers with "smart" messages comparing journey times for car and public transport, via websites, mobile phones and roadside VMS signs (park here and use the bus to get into City Centre more quickly, etc) based on real time information on bus services and traffic conditions. CONSULTATION QUESTION 27. Is there a need for a single national travel awareness "brand" that the Executive, RTPs and local authorities could all use? If so, what should it be? We feel this has been tried previously with minimal success and resulted in funds and focus being diverted away from doing something more useful and productive. Rather than create a new brand, it could be provided for by an existing one. There are already a number of travel schemes and information services in existence, some of which have low awareness and understanding, and it would be important that any brand achieved greater awareness and clarity of purpose. CONSULTATION QUESTION 28. We want to promote walking and cycling as healthy, sustainable ways to travel - what more should be done in this regard? We believe one of the best ways to promote walking and cycling is to support their integration with public transport. The provision of information so people can make integrated journeys is obviously important and is addressed under several other questions in "this consultation. Cycling works best as a means of feeding into public transport, for example as a means to access rail stations. This requires investment, such as secure parking facilities. Cycle routes to public transport may also need investment, provided there is a case under STAG. There may be safety issues with increased cycling, and better segregation of 11

12 some cycle routes may need to be provided. The Scottish Executive should also consider issues such as training and safety awareness for cyclists. The carriage of cycles on trains needs careful consideration. Many trains are now full in the peaks and extra capacity is scarce and expensive. The carriage of cycles on modern trains is not easy and can impose costs such as reduction in seating capacity and delays. If the Executive is serious about promoting cycling this issue cannot be ignored, hard decisions will need to be made. We would support any measures that promote awareness of how walking to the station or bus stop can form part of a healthy lifestyle. CONSULTATION QUESTION 29. How can the NTS maximise its contribution to improving the health of the nation? The NTS must encourage greater walking and cycling all of which can either directly or indirectly help improve the health of the nation. This is best achieved through integration with public transport. The NTS should promote the positive message that, for many, walking to and from the bus stop or train station to their boarding and destination point, may equate to the recommended 15-minutes walking each day to keep the heart healthy. Walking to a bus stop will benefit children's health (and also reduce car journeys significantly). There is a clear need to revisit the current provision of, and entitlement to school transport, with the Yellow School Bus model being given consideration. Staggering school times would allow much more efficient and cost-effective utilisation of school buses. Measures to reduce violence and anti-social behaviour on public transport will have a significant impact. Firstly, it will encourage more use of public transport, which will lead to more walking to and from bus stops and stations. Furthermore, it will reduce stress levels amongst staff working in public transport, which will benefit their health. CONSULTATION QUESTION 30. How do we make buses more attractive for people to use, and therefore allow them to make the choice to take the bus rather than using their car? How do we ensure that the quality of the travelling experience is made a priority by bus operators? It is vital that the NTS contains policies and measures that will see the speed of bus journeys improved. Both our existing and new passengers want service reliability; therefore, the industry needs help in ensuring that people who choose to use the bus are given greater priority. Good running speeds can be achieved by the provision of enforced bus priorities, as well as effective traffic management measures that combat traffic congestion. It is, therefore, vital that the NTS fully addresses these critical requirements. First continue to make considerable investment in its bus fleet across Scotland, increasing the availability of easy access, low-floor vehicles. However, the full benefits of these vehicles are not being delivered consistently, due to the access to bus 12

13 stops/boarding points being blocked. The NTS must ensure that, additional designated bus bays are introduced and that access is assured by regular enforcement. First, in common with most other operators, is continually working, very often in partnership, with local authorities, on improving the design, provision and availability of travel information. We fully support the integration of services, but would draw attention to the existing barriers to achieving more in this area, in the form of legislation contained within the Competition Act. We also support through ticketing - where it is recognised that added value entails a premium. First supports new technology where there is a sustainable business case, for example SMS text messaging and smartcard. We believe that there is a need for more Park and Ride sites being introduced, as part of an integrated parking strategy also addressing charging and regulation. We feel it is essential to see Punctuality Improvement Partnerships developed, which will be key to assisting with service planning and the delivery of reliable services. CONSULTATION QUESTION 31. Is there a need for change in how the bus industry operates, or are the current arrangements working? If so, what should this change be? First would contend that the regulatory framework is not an issue. No matter what the regulatory framework is, if the bus offers no benefit over the car, it will not succeed in attracting the car user. Whether the bus network is regulated, or the bus is owned by the government will not change that. If the bus is caught in the same traffic jam as the car, it will offer no benefit to the car user, whereas the car still offers the benefit over the bus of availability at the time the user wants it and of door-to-door travel. The bus must be able to offer a unique advantage to the car user. Paragraph 100 specifically mentions inter-operator integration and the question asks if benefits are to be had from the London model. There is an undoubted tension between competition on the one hand and aspirations for integration across operators on the other. While the London model achieves integration, in certain respects (primarily ticketing), this comes at a considerable cost to the public purse. In any event, much in the way of integration is already achieved under the present arrangements in Scotland. Individual operators, operating in a commercial market, are motivated already to ensure their own routes and timetables are, as far as possible, integrated and that fares and ticketing products are integrated. In various locations across Scotland, multi-operator tickets are now available (Zonecard, OneTicket). The impending introduction of on-bus, smart card enabled ticket machines, on the Scottish Bus Fleet, will clearly offer up new opportunities for integrated travel, subject to such schemes being commercially viable. 13

14 The key element that is often commented on as missing is route and timetable integration. This is missing primarily because of competition legislation, which prevents operators from achieving what the travelling public and many others aspire too, Le. improved service and timetable integration. Clearly, the situation outlined above has nothing to do with deregulation. It is a clear issue of competition legislation and the role of the OFT in public transport. We would suggest that, as the competition legislation is the cause of the present situation, it is this legislation that needs to be changed, not the regulatory framework, which we believe is capable of delivering what people want. The amount of effective partnership working between public and private sectors varies around Scotland depending upon the individuals involved and the priorities of individual local authorities. The NTS must set real goals and objectives in place in order to further develop partnership working, through both the newly formed RTPs and local authorities. First would seek to have LAs audited as infrastructure providers, and where there is clear evidence of LAs failing to move bus up their agenda, swift Government action should follow to address such situations. CONSULTATION QUESTION 32. How do we make rail more attractive for people, and therefore allow them to make the choice to take the train rather than use their car? We consider safety to be our utmost priority but beyond this the fundamentals of an attractive rail service will always be performance, journey times, capacity, cleanliness, the provision of information and the ability to access the service. Working with Network Rail we have seen good improvements in performance. We are continually seeking to improve this. We wish to see performance at a level where its importance in influencing travel decisions diminishes. This is achievable and we believe other issues are likely to become more significant over the period of this Strategy: Peak capacity is becoming a constraint. Our experience in Fife is that additional capacity in the form of new air conditioned class 170 units was delivered around the start of the franchise and appears to have encouraged modal shift. Scotland has seen good investment in additional rail infrastructure and several major schemes are now under development. This is welcome, but further new schemes should not be at the expense of the investment that is now needed to increase capacity on existing routes. Rail is well suited to serving longer distance inter-city journeys. Journey times are an issue and the Executive should consider measures to improve journey times especially on the Aberdeen & Inverness to Edinburgh & Glasgow corridors, as well as Edinburgh to Glasgow. Here again, difficult choices will have to be made. There are calls for new stations or increased stops on long distance routes. This will reduce the attractiveness of rail for journeys between the major towns and cities. The key here is effective coordination and integration of bus and rail. The way to increase modal share of rail (and bus) is for each to concentrate on its strengths. 14

15 It is likely that the perception of bus by many train users is very out of date, and this is partly responsible for many of the calls for additional rail stations. Furthermore, there are car users who will use rail but are reluctant to make connecting bus journeys. Paradoxically, the way to increase rail's modal share may be to make buses more attractive and/or update the perception of bus. There is spare capacity between the peaks. Increasingly this will be less attractive if car parks are full. We support measures to encourage other means of accessing stations (bus, walking etc). Such measures are important. However the reality is that many people still want to drive to the station. In terms of the Scottish Executive's wider goals, it is better that the car is used just to drive to the station rather than for the entire journey. Hence investment in parking spaces and secure parking is important. Personal security (or the perception of personal security) is an issue especially if we are to see more use of evening services. Better policing, staffing levels and increased investment in CCTV, help-points, lighting etc all have a role to play. The most important factor is use of the service by the law-abiding majority; this naturally leads to reduced crime and anti-social behaviour. The linkage with wider policy on law and order is important - the transport system only reflects what is happening in our society. Fares are a key issue also. In the short-term there are capacity constraints and fares have a key role to play in determining efficient utilisation of capacity. In the longer term, capacity is variable and ultimately it is for the Executive to decide the balance of funding between the taxpayer and the fare-payer. Any such decisions must take account of the impact fare levels have on capacity utilisation. Secure, clean, graffiti free stations, with appropriate waiting & ticket buying facilities are important also. Continuing investment in CCTV, CIS, lighting, waiting etc should not be neglected. CONSULTATION QUESTION 33. What else should be done at a national level to support improvements in travel information? How do we capitalise on the potential opportunities created by new technologies - such as 3G mobile phones - to improve the provision of travel information? We would encourage all those local authorities, which have not yet done so, to develop Information Strategies, involving meaningful consultation with operators. RTPs and local authorities should be encouraged to harness the many benefits that can be delivered via new technology, Le. SMS text messaging, real time information, plus electronic access to Traveline etc. Most travel information in Scotland is now "underpinned" by two databases. a) The NaPTAN (National Public Transport Access Points) data base captures details of all bus stops, rail stations, ferry terminals, underground stations, tram stops, airport terminals and bus stopping places where a physical pole is not in place. Without NaPT AN most of the present information systems and none of the emerging systems will work. NaPTAN is compiled by Local Authorities on a voluntary basis and this should be upgraded to a statutory duty to ensure that the system remains robust and competing pressures do not affect its maintenance. 15

16 b) The actual service timetables for bus, rail, ferry, underground, tram and air services are compiled for the whole of Scotland in the Traveline Scotland data base using information supplied by Local Authorities and some operators. The ability to get information on an all Scotland basis is very important, more so as passengers travel needs and journeys are not restricted by Local Authority boundaries. Again, this information is presently supplied on a voluntary basis and although, in most cases, the voluntary arrangements work well, they cannot be fully robust unless provided by means of a statutory duty. We believe that Traveline Scotland should continue to develop its SMS mobile phone texting to provide coverage throughout Scotland and expand this service to provide information to mobiles via WAP technology and provide and extend its Internet Journey Planning Service to mobile phone delivery. First, along with most of the main bus operators in Scotland, make a significant contribution to the running cost of Traveline Scotland (our National Information System). However, a small number do not although they continue to enjoy the benefits of having their information made available through Traveline Scotland. The charging mechanism to operators is fair and was developed in consultation with Local Authorities. To ensure equity and fairness and a secure future for Traveline Scotland, Local Authorities or Transport Scotland should have a duty to recover contributions from those operators who are not contributing on a voluntary basis. CONSULTATION QUESTION 34. Do you consider that we need to change the cost of public transport so, what changes should be brought in? fares and, if Within the current rail franchise we work to provide the best quality service that meets our customers needs including performance and value for money. We set our fares at such a level that allows us to meet these needs within the context of our Franchise Agreement's financial objectives. Growth of 7% in journeys since the start of the franchise indicates that we have been successful in striking this balance. Over the longer term any debate on rail fares needs to take account not only of the balance between fare-payer and taxpayer, but also the ability to deliver given capacity and infrastructure constraints. In terms of influencing modal shift, we believe that convenience is more important than cost to car drivers. Hence reduced bus fares would not have a major influence. The real issue here is not the cost of public transport fares - but the real lack of understanding on the true costs of motoring. The NTS must encourage the provision of measures to ensure these are understood and that these costs are actually borne by drivers. Research undertaken across the bus industry shows that reliability of service - rather than cost - is the determining factor as to whether or not people will even consider modal shift, thus it is imperative that the NTS ensures measures are introduced to help operators with this significant challenge. 16

17 Consultation on Scotland's Transport Strategy July Response from First CONSULTATION QUESTION 35. If you support lower fares, would such reductions need to be funded by tax revenue, or are there schemes, which consultees consider could pay for themselves through modal shift (i.e. because more people would be travelling, albeit paying somewhat lower fares)? There is evidence that targeted pricing initiatives and sales promotional activity increase passenger volumes, albeit at a reduced yield. Our objective with this type of activity is designed to increase volumes, we have no evidence on how this increase in volumes is broken down between true modal shift and generation of new trips. We note that the overall objectives of this Strategy are both to achieve modal shift and to reduce the need for travel. Thus some research funding would be desirable, to better understand how such schemes can focus on achieving true modal shift. For example, there is limited evidence to show that schemes such as Edinburgh City Council's 'Greenways' initiative have been successful in encouraging modal shift from road to rail. The impact on rail business was predominantly experienced in the peak commuter market due to the priority given to bus lanes in Edinburgh and the resultant increase in car journey times. CONSULTATION QUESTION 36. How can we promote integrated ticketing between different operators? Clearly, there needs to be a sustainable business case to support the introduction of integrated ticketing. In addition, whilst there has been a degree of flexibility allowed by the Competition Commission, legal barriers still exist, which prevents further progress in this area. The Scottish Executive needs to take the lead in reducing these barriers to integration. Smartcards could be the catalyst to further progress, once the Scottish bus fleet is equipped with smartcard machines, trough ticketing becomes technically much easier to achieve. The key issue from a rail perspective is that bus operators do not have the ability to issue integrated rail/bus tickets. Therefore it is not possible to purchase an integrated ticket where the journey starts by bus. In addition there is an opportunity to improve on bus signage for integrated schemes to make it easier for passengers to identify, which bus operators their ticket is valid for travel on. CONSULTATION QUESTION 37. How do we promote additional modal shift from road freight to rail and waterborne freight? The underlying issues for freight are the same as for the passenger railway - reliability, capacity, interchange and accessibility. The main potential for growth will be in increasing the length of trains to make better use. of additional capacity, this will need to be supported by some investment to enable freight and passenger services to co-exist e.g. extending passing loops. There are, across the railway a number of bottlenecks that constrain freight. Relatively small scale investment projects may unlock useable extra capacity. 17

18 Consultation on Scotland's Transport Strategy July Response from First CONSULTATION QUESTION 38. How do we ensure that people are safe, and feel safe, on public transport, at stations and bus stops, and while travelling by foot, bike or car? For example, what needs to be done to tackle anti-social behaviour on public transport and on our roads? The perception - especially of non-users - is worse than the reality. First, in common with the industry, is very anxious to avoid giving the false impression that travelling by public transport is unsafe. Instances of anti-social behaviour are generally highly localised. We feel a sustained PR campaign is required to ensure that incorrect impressions are corrected. This must be accompanied by firm action to deal with problem locations. Successful prosecutions are of key importance. This can be improved. For example, across our bus operating areas we have made a financial contribution to the funding of police liaison officers, who have acted as a deterrent and helped to improve the quality of crime reporting, which, in tum enables prosecutions. Another example is the use of DNA swab kits. However we are firmly of the view that there is a clear need for more action to be seen to be taken by the Prosecution Service. Again these issues link to wider policy initiatives. For example: Instances recorded by both the rail and bus industry very often show direct correlation with excessive alcohol consumption and/or drug abuse. We would suggests research be undertaken to establish if there is linkage in problem areas to the number of Anti-Social Behaviour Orders (ASBOs) issued, and whether all available action is being taken by relevant authorities against instances of anti-social behaviour. These are difficult problems but public transport will only reflect what is happening in society as a whole. Wider policy measures dealing with alcohol and drug abuse and anti-social behaviour will also benefit the public transport system. Nevertheless, there are things that public transport can do: CCTV has proven to be effective where widely installed, for example in Dundee, giving both passengers and operating staff added security. Against this background we note that monies allocated to RTP's cannot be used to further extend CCTV coverage across the Scottish bus fleet and feel that this is a decision, which should be reconsidered. RTPs need flexibility to allocate funds to whatever schemes would be most cost-effective in their areas. Anti-social behaviour is also deterred by having well presented trains and stations. Our concerted effort to eradicate graffiti from trains and stations in Strathclyde is testament to this. The previous presence of graffiti only seemed to encourage yet more, and also sends the wrong message about who "owns" the railway. On the rail system, we believe that our increased efforts to collect fares have increased personal safety and security. Potential offenders can be discouraged by the need to buy a ticket. We continue to work closely with the police, and support more focused and intelligence led operations. However, the deterrence effect of uniformed police officers on trains and stations should not be underestimated. 18

19 Apart from violence and anti-social behaviour, the other key personal safety risk is traffic. Additional segregated walkways, and designated cycle lanes, may provide additional confidence and safety to those choosing to walk or cycle. CONSULTATION QUESTION 39. Within a UK market, what, if anything, should Scotland specifically the uptake of biofuels? do to promote We support the development of biofuels. First, in common with most large operators, is constantly upgrading its fleet to reduce emissions. A substantial proportion of our Scottish bus fleet now has Euro 3 engines, with Euro 4 being specified in 2007 deliveries. Simultaneously, and in common with the large operators, we are investing in research and development, especially with regard to alternative sources of fuel. However it must be recognised that biofuels are more costly than traditional diesel. The Scottish bus industry is highly competitive and no one operator can take the lead here. Government must take the lead to ensure a level playing field. In addition, increased costs will have some impact on patronage unless some support is given CONSULTATION QUESTION 40. Where are the commercial opportunities for biofuels in Scotland? What, if anything, is the role for the public sector in supporting commercial blofuels developments? Are there downsides of an increased bio-fu.el market in Scotland? The downside of bio-fuels is that they are more expensive than fossil fuels, and also less efficient (I.e. fuel consumption is higher). CONSULTATION QUESTION 41. Within the context of a UK regulatory framework, what more, if anything, should be done to make motor vehicles in Scotland cleaner to run? As noted above, we are supporting the introduction of cleaner engines. We also note that a key issue for reducing bus emissions is actually enabling buses to keep moving and not be forced to idle in congestion. CONSULTATION QUESTION 42. Where are the potential gains in terms of new transport technology in Scotland? How do we capture the potential economic benefits of developing them In Scotland? What, if anything, is the role for the public sector in supporting the development of such new technologies? There could be significant gains from new rail technologies such as Maglev - clearly there are very high capital costs here, which will need partnership between public and private sectors. We are willing to harness new technology, where there is a clear business case for doing so. Alternatively, where the case for these new technologies depends on wider benefits there may be a need for support. 19

20 Consultation on Scotland's Transport Strategy July Response from First CONSULTATION QUESTION 43. What needs to be done to ensure that parking policy - on-street parking, bus and rail park and ride and so on - is more effective in managing demand and promoting modal shift? We feel that all-local authorities must be committed to introducing parking restraint and actively participate in partnership development of effective Park and Ride sites. It is imperative that main urban areas have park & ride within their portfolio of alternative travel options. Local authorities must be obliged to enforce parking restrictions, not simply have TROs in place. Local authorities should also be,obliged to prioritise their enforcement in such a way that an infringement which impedes a bus route, or bus stop, is dealt with as a higher priority, than those which do not, such as overstaying in a designated parking bay. The penalties should also reflect this. Car parking restraint should apply to all areas. There are many large residential estates where it is impossible to get even a small bus running a route on account of thoughtless parking by car owners Experience shows it is very difficult to persuade people out of their cars. If the Executive wants to achieve significant modal shift then measures such as workplace parking levies could also have a significant impact. Even then, motorists are relatively insensitive to cost. Given the seemingly inexorable rise in car travel, tougher measures such as reduced availability of City Centre parking may be necessary, - this would need to be accompanied by quality Park and Ride schemes. CONSULTATION QUESTION 44. How might park and ride schemes best be developed to further encourage modal shift and reduce congestion? How should enhancements be funded and what should pricing policies be? As previously stated, rail frequently provides very attractive "park and ride" opportunities. This is often frustrated because car parks are simply not large enough, and the car park is full even before the end of the morning peak. Stations such as Kirkcaldy illustrate this. In other places, measures such as differential pricing of parking during the off-peak could be effective, but as parking charges are regulated we are not free to vary these charges. Consideration should be given to the development of a national Park and Ride policywith public and private sector jointly selecting the first Top Ten sites I gaps - based on travel to work principles. As noted above, modal shift is hard to achieve - for this to succeed there may be to be measures to reduce the attractiveness of "in-town" car parking, such as reduced spaces and lor increased prices. It is also vital that, as additional Park & Ride services are introduced, supporting traffic management measures must be introduced, which allow shorter journey times to be achieved for those using Park & Ride, when compared to similar car journeys. 20