Bus Regulation Bill Response

Bus Regulation Bill Response Aberdeen & Grampian Chamber of Commerce

RESPONSE FROM ABERDEEN & GRAMPIAN CHAMBER OF COMMERCE
Proposed Bus Regulation (Scotland) Bill

Introduction
Aberdeen & Grampian Chamber of Commerce (AGCC) is North-east Scotland's
leading private sector, member-focused, business organisation. The Chamber
represents more than 1,200 businesses with 90,000 employees.
The consultation published is an area a number of our members are interested in
generally. Research previously conducted by AGCC has shown that the transport
connections in this region, which people rely on to get to and from work, are a barrier
to growth.
The Chamber has a transport steering group and most of the main transport providers
in this region are members. These members were consulted in relation to this
consultation. This response summarises their views in relation to the proposed Bill.

AGCC member comments
Competition
Members were very concerned about the implications this Bill would have on
competition in the public transport market.
Over the past year, local operators have invested significantly in new buses and
announced new services, which were based on the market demands of this region.
They fear that any interference in the market through regulation would not incentivise
them to further invest in new buses and services.
Members highlighted that the consultation offers no evidence that the proposals
would not negatively affect competition. As such, we would expect evidence to be
produced which demonstrates that competition in the bus market will not be stopped
by the implementation of this Bill.
Any proposals that are brought forward must also retain some degree of operator
flexibility to invest in the aspects of their own business, as they see fit.
Costs
Our members have highlighted that over the past few years there has been
decreasing levels of public sector investment in bus services at the same time the
sector has faced rising costs. According to Stagecoach, during 2012 costs for bus
operators rose by 4.7%, and there was also a real terms decrease in public support
through the Bus Service Operators Grant and Concessionary Travel Scheme. This
difficult financial environment has had a direct influence on operators ability to run
certain services.
In instances where a service has become commercially unviable, the Local Authority
has

Bus Regulation Bill Response
Bus Regulation Bill Response Aberdeen & Grampian Chamber of Commerce


Has powers to plug the gap in provision if it deems the service be important. However,
action on the Local Authorities part is currently limited due to the current financial
pressures on them to protect existing levels of public services.
Again, members considered there to be no evidence in the consultation document that
the proposed changes to the operating environment would result in benefits to the
passenger. Without additional funding, budget constraints could mean that Local
Authorities could not meet the expectations of passengers in relation to service
provision.
In addition, the introduction of franchising would also have significant cost implication
for Local Authorities. A running of a franchise system would incur significant
administration costs for Local Authorities as they would need to increase monitoring
and reporting of operators and their services.
Without significant funding, we are sceptical about how a franchising system could
work in practice. Operators highlight that without public subsidy, the public would likely
be forced to pay for the administration of the system through higher fares.
Investment in infrastructure
We note the comment in the consultation document you believe the proposed Bill will
result encourage more people to travel by bus. Our members support the ambition that
more people should travel by bus, however, public transport operators in this region
argue that traffic congestion is the most discouraging factor in encouraging people to
travel by bus.
Transport providers have stated that a Bill regulating bus transport cannot be the sole
solution to address declining passenger numbers and there also requires significant
investment in infrastructure. This is particularly important for the Aberdeen area, where
bus operators eagerly await the delivery of the Aberdeen Western Peripheral Route in
order to establish more efficient services which meet the needs of passengers.
We understand that the issue of infrastructure funding is not the consideration of this
consultation, but members have been very clear that they do not believe that the main
aims of the Bill are achievable without significant investment in the countrys
infrastructure.

Improving the proposals
AGCC believe that any legislative change should be assessed against four main
principles:
1. Is the proposal simple?
2. Is the proposal transparent?
3. Will the proposal support economic growth?
4. Will the change be equitable for businesses?
On that basis and having consulted with our members we do not believe that the bill
would not benefit our members based on the principles outlined above. In our view, the




Bus Regulation Bill Response
Bus Regulation Bill Response Aberdeen & Grampian Chamber of Commerce

following actions should be taken:

Should you wish to discuss the impact of your Bill further, please do not hesitate to
contact the Chambers policy team.
































James Bream
Research & Policy Director
James.bream@agcc.co.uk
01224 343904

Rachel Elliott
Policy Executive
Rachel.elliott@agcc.co.uk
01224 343925


1. Evidence should be provided to demonstrate that competition will not be
discouraged if the Bill is implemented.
2. Lobby for further funding to Local Authorities to deliver improvements in bus
services.
3. Address infrastructure barriers which are preventing people from accessing
good public transport services.

Aberdeen & Grampian Chamber of
Commerce
The Hub
Exploration Drive
Aberdeen Energy Park
Aberdeen
AB23 8GC

www.agcc.co.uk