Max Calms
lain Gray MSP
Scottish Parliament:
Edinburgh
EH99 ISP
10 October 2013
Dear Mr Gray,
| write with reference to the consultation for your proposed Bus Regulation (Scotland) Bill. | am a
private individual, resident in North Lanarkshire and use a large amount of buses per week.
| will firstly, give answer to the questions which you encourage respondents to answer before giving
further detalls of my views on the bill
Q) Do you support the general aim of the porpased bil?
A) | do not support the general aim of the proposed bill as | believe that the re-regulation of bus
services would only lead to @ worse service for passengers. This is because that when a service
becomes regulated, there is simply no commercial incentive for the operator to provide a service
for the passenger or be innovative, the only incentive is to keep costs down in order to win the
contract to operate the services.
Q) What would be the main practical advantages of the legislation proposed? What would be the
disadvantages?
| cannot foresee any advantages of the legislation that is being proposed. The disadvantages of the
proposed legislation is that in the end, the passenger would suffer as the service would not be
provided for the benefit of them, it would be provided on a minimum costs basis. This would more-
than-lkely result in @ return to the dear old dark days of the Scottish Bus Group when patronage
was absolutely miniscule as the services were not being provided with the customer in mind meaning
that they had absolutely no faith in the bus service. There would also be a significant financial
disadvantage to tax payers in the fact that they would now be subsidising every bus service in
Scotland regardless of whether it required subsidy or not,
) In wht ways do you envisage regulation being used to improve bus services?
I cannot envisage regulation being used to improve bus services in any way, it will simply lead to a
worse service for passengers.
Q) How can community transport be utifsed to serve local communities ond particulary low passenger
volume routes?
Effective local working groups should be set-up in order to manage community transport and
provide a service to those less able or where there is not enough patronage for a commercial orsupported bus service. The extension of the national concessionary travel scheme to Include
community transport routes could also lead to benefits for this type of operation,
Q Do you agree that the Traffic Commissioner should be able to impose greater financial penakies on
operators who a) fil to meet the terms of the franchise or b) walk away from the fronchise altogether?
As | do not agree with the general aim of the bill, | also do not agree that the Traffic Commissioner
should be given the power to impose greater financial penalties,
Q What is your assessment of the ikely financial implications of the proposed bill to you or your
organisation? What other significant financial implications are likely to rise?
‘The financial implications of the bill are likely to be enormous to the tax payer as the state would be
paying for all of the bus services in Scotland, even those that do not have any need to be subsidised.
Passengers would also more-thar-likely have to subsidise this cost somewhat through fares
Q) Is the propased bill likely to hove any substantial positive or negative implications for equality? If s likely
to have a substantial negative implication, how may this be minimised or avoided?
As [am responding as a private individual and not an organisation, | cannot comment on this
question.
Do you have any other comment or suggestion that is relevant to the need for or detll ofthis bil?
Twould further like to highlight that do not agree with this bill as it would remove all commercial
incentive from bus operators to operate services for their passengers, the only incentive would be
to keep costs down in order to win the contract. This would result in a worse service for
passengers as the service would not be provided to suit them.
‘Whilst there is advantages of the London tendering network, I would like to highlight the fact that
this system is of extremely high cost to the public purse and that there are several disadvantages of
‘operators not being able to operate the service commercially, as subject to passenger demand, This
‘was highlighted in a recent BBC2 documentary in which a particular bus route, namely the 436 was
suffering from lack of capacity at peak times often leaving passengers stranded and waiting over 60-
minutes to get a seat on a bus. The result of this was that Transport for London were simply
‘unwilling to pay any additional cost to the tendered operator to provide additional buses and the
tendered operator was unwilling to do so on a commercial basis. Had the operator been willing to
‘operate these extra journeys on a commercial basis, it would have been extremely difficult for them
to register a commercial service in the tendered London bus service environment.
‘Commercial bus services are effective as operators are given the commercial incentive to improve
services in order to drive up profits. When that commercial incentive is not there, there is simply no
incentive for the operator to provide a beneficial and innovative service to passengers,
| would like to thank-you for taking the time to read over my views on the proposed bill and I hope
that you will give them serious consideration,
Yours Sincerely,
Max Caivny