Response To Public Transport Users' Committee Consultation

Friends of the Far North Line (FoFNL) was formed in 1994 to support the railway line from Inverness to Wick and Thurso, and now has 190 members. FoFNL supports the Scottish Executive's policy to encourage travellers to use public transport rather than private cars, so as to reduce traffic on overcrowded roads and help conserve fuel resources and reduce the amount of pollution. We represent the views and aspirations of users of the Far North Line, and other lines out of Inverness, to service providers, government (local and national), and other stakeholders.

We understand the Scottish Executive's desire to set up a Public Transport Users' Committee (PTUC), and why it is being done now. Since the winding-up of the Rail Passengers Committee for Scotland (RPCS) in July 2005 there has been only the GB-wide newly-constituted Rail Passengers Council (now called PassengerFocus (PF)) to capture and articulate the views of rail passengers in Scotland. With far fewer people and resources it is hard to see how PF can carry out its remit as quickly and thoroughly as the old Committee was able to do. Nevertheless we wish them well, and to play our part in constructing a Scottish body to complement its GB activity. At the same time as the RPCS was wound up the Caledonian MacBrayne Users Committee (the same people, acting on ferry matters under a different name) ceased to exist. This had not been foreseen and the Scottish Executive moved swiftly in spring 2005 to establish a replacement body. A Consultation Document (CD) was issued and various models for ferry representation were suggested. With hindsight we believe this was unfortunate, as the ferry model, being part of the proposed PTUC, is now largely set in stone, and has to be accommodated within any new structure for other transport modes. Had it been possible to design a pan-modal PTUC with nothing already established a better delivery of the desired representative outcomes is likely to have been achieved.

We are doubtful about how successful a new single body is likely to be in its task of representing passenger interests across four widely differing modes of public transport. For example, a bus passenger in rural Aberdeenshire is likely to face different problems from those faced by a rail commuter from the suburbs into Glasgow. A ferry passenger from Dunoon to Gourock will face different problems from those of an airline passenger from Wick to Inverness, or indeed between Orkney islands. The range of passenger concerns which the PTUC will require to capture, refine, and articulate to service providers will be enormous, and it is hard to see how one body can structure itself to do this thoroughly and in a manner likely to persuade the travelling public that their concerns are indeed being understood and dealt with.

Before responding to the questions posed in the CD we wish to set out how we think a successful Scottish PTUC should look. It is very different from the model set out in the CD, and for reasons that we will set out.

First, what is the purpose of the PTUC? Surely at root it is, as we have said above, to capture, refine and articulate the legitimate concerns of the travelling public. If it to be of value it must be regarded by those to whom it addresses itself (service providers, government at local, regional and national level, bodies like Transport Scotland and others) as talking sensibly from an evidence-based standpoint. It must be able to demonstrate that what it says is not merely the thinking of a small group of well-intentioned people, but genuinely representative of a wide range of passengers using the service in question. It must therefore be structured in such a way as to enable it to capture these views in a robust and demonstrable manner. As indicated above, this will be different for rural bus-users and urban rail passengers. Form must follow function. For this reason, as we shall state below, we prefer the Scottish Executive's Option 1 model. But we have severe reservations about the bodies lying underneath it - what the CD calls the mode-specific sub-committees (msscs). It is these bodies which will actually carry out the gathering and refining of passenger concerns, passing up to PTUC the task of articulating. Some of the msscs are, or are likely to be, well set up to do this (or, as in the case of rail, to have recent still-accessible experience of how to do this). Others are not so set up - the Bus User Complaints Tribunal, for example, having a very narrow remit (complaints only) and comprising only 3 people for the whole of Scotland. The Air Transport Users Council is a UK-wide body; the (rail) PassengerFocus is a GB-wide body. The proposed structure attempts to cobble together four (at least) disparate entities, some of which already exist, into a coherent whole. We believe it is bound to fail in its primary purpose.

Our preferred model will involve sacrificing some of the work already carried out, which is regrettable, but it will have the continuing advantage that the PTUC which will emerge will be fit for purpose, because it was designed holistically to acknowledge the difference in passenger concerns between modes, but to accept that, arising from these, there is nevertheless a strong common thread. That is why our preference for Option 1 (a much-modified Option 1, however) is so strong.

In what follows we make no further mention of the Mobility Access Committee for Scotland (MACS). As the CD makes clear in para.28 MACS is a Statutory Body which exists "to advise Scottish Ministers on the transport needs of disabled people ...". We do not believe it has a specific role to play in the day-to-day work of PTUC, but that its views should be sought by PTUC at all relevant times. Its advice to PTUC should be given in the same way as its advice is given to Scottish Ministers. It should not be a part of PTUC as thereby its independence would be compromised. Many passenger concerns are matters where the interests of disabled people are in conflict with those of non-disabled people (eg. the provision of wheel-chair space on trains which takes up the space for around 6 seats).

The salient characteristics of the four modes must be reflected in the mssc designed for that mode. For rail, where the concerns are much the same across Scotland (trains running to time are essential everywhere; information is essential everywhere, and so on) a relatively small group of people will suffice. Our view is that 8 to 10 (of whom 2 would be full-time and the rest working perhaps 5 days per month) would suffice. They should represent as wide a range of travellers as practical, and it is essential that a good geographical spread be achieved. They should be complemented (as appears to be the plan with PF) by a carefully selected cadre of local volunteers who will feed in information about specifically local problems. These volunteers would be unpaid, and would not have a time commitment, but would be expected to respond quickly to a request for input of whatever kind.

The ferry model would be similar. The proposed two-tier (to be three-tier when PTUC is established) is unnecessarily cumbersome, and reflects, we believe, self-interest among those now doing the job. There are far too many people involved. A sleeker model, still capturing passenger concerns, could be designed using the rail model of the previous paragraph. 10 people would suffice. Again it is essential that different island communities are represented, and here we would specify that one member from each of the following islands (or island groups) should always be on the mssc: Shetland, Orkney, Lewis/Harris, the Uists/Benbecula/Barra, Islay/Jura, Coll/Tiree/Colonsay, Mull, Arran, Bute/Cumbrae, Dunoon. If ferry complaint appeals are to be handled it may be necessary to employ a third full-time staff member (the 2 already in place for rail being able to handle routine ferry-related matters. Rail complaints are handled centrally by PF in Warrington).

The air model can be very simple. 2 or 3 members will be sufficient, with a geographical spread allowing inter-island services in Shetland/Orkney, mainland routes within and furth of Scotland, and island to mainland routes all to be covered.

The most intractable mode is bus travel, because it is so varied. A model that addresses the needs of a long-distance coach passenger between Inverness and Glasgow, as well as those of rural bus users will be hard to design. This is because of the fragmented nature of service provision, with most rural services being provided by small operators in a specific location, and because the industry is unregulated. Nevertheless a panel of around 10 people should be capable of capturing most of the problems, provided (as with rail) they are supported by a network of volunteer observers throughout Scotland. 1 or 2 more full-time staff will be required, as the volume of correspondence with many service providers will be considerable.

Drawing these together, we see a series of 4 msscs with a total of around 30 to 32 members (5 days a month) and 5 full-time salaried staff. The rail and bus bodies will have a formalised network of volunteers feeding information as required. Over these bodies will be the PTUC itself. Since it will not be involved in gathering information, and only in the sifting and presentation of it, it need not be large. Ideally each of the msscs should be represented on it (by the Convener) and, in order to bring an independent view, it should have 2 non-mode-specific members, one of whom should be an academic transport consultant, and an independent Convener. The Members of PTUC (but not of the msscs, except the Conveners by virtue of their membership of PTUC) should be paid, with the 4 mssc Conveners and the Convener of PTUC being amply rewarded for their time commitment, likely to be 2 days a week. The non-mode-specific Members should also be paid, but since their time commitment will be less this should be at a lower (say half) rate.

This bears little resemblance to the model set out in the CD, and we acknowledge that this is a substantial drawback. But the cost of getting it right is an initial cost, readily quantifiable at the outset; the persisting cost of operating a flawed model is continuing and impossible to quantify. Furthermore it fails to address satisfactorily the original requirement of PTUC: to deliver to the Scottish Executive and service providers a concise appraisal of passenger requirements across four public transport modes.

We now turn to the Questions posed in the CD.

Q1    As discussed at length above, Option 1 (modified) is our preference.

Q2    Answered in detail above.

Q3    We agree that PTUC should not deal with individual complaints. PF will deal with unresolved complaints from rail passengers, but there must be a mechanism for dealing with unresolved complaints from ferry, air and bus passengers. In the absence of anyone else this must surely fall within PTUC's remit. Otherwise we agree with most of the remit as set out in para.44. We have a concern about the inclusion of "cycling and walking interests". If this means articulating concerns about adequate provision for cycles on eg. buses or trains, we accept that this is a legitimate matter for PTUC. But cycling and walking are, of themselves, not uses of public transport. The concerns of cyclists as road users and of pedestrians should not fall within PTUC's remit. The inclusion of "undertaking research" will have a resource implication. The staffing numbers suggested above do not include any allowance for carrying out research. If research is to be an activity then either 2 more full-time staff will be required or sufficient funding must be made available to PTUC for it to commission research from outside. The latter is likely to be more expensive.

Q4    FoFNL maintained a good working relationship with RPCS, and does so with PF. We would expect to continue this with PTUC and with its msscs as relevant. It is likely that FoFNL members will wish to be considered for volunteer observer status in the rail mssc.

Q5    As detailed above, PTUC itself should comprise the Conveners of the four msscs and three others, at least one of whom should be a transport consultant. These seven people must be able to think and act strategically, and the four Conveners will be expected to bring mode-specific knowledge of their mode. It is surely essential that all members of the msscs should have knowledge of their own mode, and this is more important than a strategic capacity.

Q6    A member of PTUC must be, and be seen to be, able to speak on behalf of passengers. They must be independent of service or infrastructure providers (a fatal flaw, in our view, with the proposed Shipping Service Advisory Committees (SSACs) for ferry matters where the Local Authorities are often pier owners, sometimes run the services, and seem likely to dominate SSACs). A member must therefore be able to demonstrate clarity of thought, the ability to weigh and prioritise arguments, the ability to present policy and advice to stakeholders, often at a very senior level. Members of the msscs need not have all these skills, but must have the skills necessary to gather the information about their mode, and to marshal and present it (through their Convener) to PTUC. Since meeting individual passengers (eg. at station "presences") is a vital part of this, the ability to interact with total strangers is essential.