From Workhorse to Thoroughbred -- Comments

This is the reply by Transport 2000 Cambs & W Suffolk to the recently issued ``daughter document'' on buses to the Government's Transport White Paper, with title ``From Workhorse to Thoroughbred''.

Simon Norton, Coordinator, Transport 2000 Cambs & W Suffolk, 1 May 1999. The author can be contacted by email -- or, from 1 July, at 6 Hertford St, Cambridge CB4 3AG, fax 01223 337920.

Part 1 -- Introduction

Transport 2000 is the national environmental transport campaign which we represent in Cambridgeshire, including Peterborough, and jointly with the Ipswich & Suffolk branch in the western extremity of Suffolk. Please note that these comments are not intended to represent the views of Transport 2000 nationally; nor, where we quote examples from outside our area, those of the relevant Transport 2000 branch.

General: We whole heartedly support the aims of the paper. We believe that there is lots of potential to develop the bus network to play a much greater role in the transport system. We also support most of the specific measures proposed by the Government -- in particular, it may be assumed that we support any section of the paper on which no comment is given.

However, we are rather sceptical as to whether the measures proposed are strong enough to deal with the scale of the problem. This mirrors the concern of the Environment, Transport & Regional Affairs Committee of the House of Commons as expressed in its recent report on the Integrated Transport White Paper itself. Many of our comments are echoed in this report.

Our two main concerns are that the fragmentation of responsibility resulting from the 1985 Transport Act is not fully dealt with; and that the need for adequate revenue support finance needs to be underlined.

We have two proposals to deal with the former. One, which will not be discussed further, is to replace the current fragmented network of county and unitary authorities with a new network of Passenger Transport Authorities. This would complement the existing metropolitan authorities and would at last give us a chance of integrated rural networks. Such PTA's, whether metropolitan or otherwise, should have a duty to provide facilities for cross-boundary as well as internal transport needs.

The other is our proposal for ``Quality Corridors'' which is expounded in our response to 6.10.

We now list our comments on each section in turn (if any). Part 2 deals with the Executive Summary; Part 4 deals with paragraphs where comments were specifically invited; Part 3 with the rest. We conclude with two Appendices; Appendix 1 gives five examples which illustrate our Quality Corridor approach, while Appendix 2 gives our guidelines for reforming the driving hours regulations (see comment on 12.9).

Part 2 -- Comments on Executive Summary

1. A new framework for local authority influence over buses. We believe that it is important to give local authorities more powers over timetabling -- otherwise it will be impossible to secure integrated timetables with good connections between services. This is the prime motivation behind our Quality Corridors proposal. Furthermore, we believe that local authorities should be given some guidance as to how to use their new (and existing) powers, covering in particular bus information (see 4 below), ticketing (see 5 below, also comments on 5.9 and 9.6), school buses (see comment on 3.28), Quality Corridors (see comment on 6.10), positioning workings (see comment on 11.3), and cross-boundary coordination (see (c) of comment on 3.19).

2. Statutory backing for Quality Partnerships. We support this proposal.

3. An end to the deregulation ``free for all''. Again, we support this, but we believe that the proposals do not deal with all the flaws of the deregulated system -- hence our Quality Corridors approach.

4. Better bus information. As local authorities are already the most effective providers and distributors of information in most areas, we think that the prime need is to issue guidance with a view to bringing all local authorities up to the standards of the best. Passengers should also have a right to redress when given inaccurate information.

5. More joint ticketing. We fully agree with the need for powers for local authorities to force compliance with ticketing agreements -- and, again, there should be guidance on how to use these powers.

6. Minimum standards for concessionary fares. Passes should be valid throughout the country -- see our comment on 3.23.

7. Service frequency enhancements. We support whole heartedly the proposal to give local authorities clear powers to enhance a commercial service even though the extra services may be considered to be in competition. See also the second paragraph of our response to 5.9.

8. Options of bus ``Quality Contracts'' for area-wide networks. We believe that while this is the correct ultimate goal, it would be better to start with Quality Contracts for smaller groups of services, as per our Quality Corridors proposal.

Part 3 -- Miscellaneous Comments

1.14. We are concerned at the impression given here that the Government believes that allowing operators to determine service patterns and timetables for commercial services is adequate as the ``default'' system. We believe that almost every area, at least outside the cities, is likely to contain routes which under this approach won't link up properly. Hence our preference for a flexible Quality Corridors approach. In place of requiring local authorities to seek ministerial consent for such schemes, which we consider cumbersome, we suggest that operators and other parties should be entitled to apply to quash such schemes if they are operating against the public interest.

1.16. We are worried that the Government has given no indication about funding for newly introduced rural services when the current scheme runs out in 2001. There is certainly no prospect that revenue from parking taxes or road user charges will be available in most areas by then. It is also unrealistic to expect most such services to become commercial by then -- especially in the absence of incentives for motorists to switch to public transport (such as the above mentioned parking tax). To bridge the gap until all local authorities are able to introduce parking taxes, some options are as follows:

(a) Extend the existing scheme beyond 2001 as long as necessary -- perhaps on a rolling basis so that local authorities will always know that finance will be available for the next three years.

(b) Amend the Local Transport Plan financing system so that revenue support, as well as capital spending, is eligible. If this took effect from the start of the ``definitive'' Local Transport Plans (as opposed to the ``provisional'' ones being produced this year), this would be just right to take over from the end of the current schemes.

(c) Counter the culture of abstinence in local government spending which was introduced by the last government, so that local authorities are encouraged to raise more money through Council Tax for better services, suject to the ``best value'' policy expounded in 1.17.

These are not the only options -- what's important is that something is done to tackle this problem.

2.13. We certainly support more bus priority schemes, but are concerned that many local authorities are overemphasising their role in making buses more attractive to motorists -- even in rural areas where they are of little relevance.

2.14. We see light rail primarily as an alternative to conventional rail for local services, enabling better penetration of town centres and other important traffic generators by using the flexibility of street running. We do not see the development of bus and rail (both conventional and light) as alternatives -- both are urgently needed.

3 (general). We believe Local Transport Plans should provide a much firmer framework for the development of public transport. We have already suggested (comment on 1.16, (b)) that revenue support should be eligible for funding under the LTP system; this would also help to counter an over-emphasis on capital spending that has been harmful in the past. We believe LTP's should include minimum standards -- especially frequencies -- for all services, so people can take decisions about where to live and work in full confidence that the local authority is committed to maintaining the services they need (including access to shops and leisure facilities as well as work). Such minimum standards would not be 100% binding -- this would tie the hands of local authorities too much -- but they should represent a commitment that people could normally rely on.

3.23. It is suggested that the minimum standards will only guarantee half fare travel within one's own area. We believe the elderly should be encouraged to get out and about, while minimising the use of their cars (if they have them) -- in other words, that passes should be valid throughout the country.

3.28. The guidance to local authorities should include the opening up of more rural school buses to the general public. This applies especially to the longer routes which serve secondary schools and further education colleges. In some cases there may be scope for developing ``school interchanges'' whereby the various buses serving a school, after dropping off pupils in the morning, would fan out to a variety of towns, and correspondingly in reverse in the afternoon; and that all these buses should connect with one another so people from throughout the catchment area of the school could easily make day trips to any of these towns.

3.31. We believe that as part of the National Curriculum schoolchildren should be taught how to use the public transport system.

9 (general). In addition to improving ticketing, there should be a policy of encouraging lower fares (on both bus and rail) to make the use of public transport more competitive for those who have already laid out a considerable sum for the use of their own car. (This would also make it more affordable for people without cars.) For individuals, let alone for groups, fares are often so high as to discourage the use of public transport where a car (and free or cheap parking) is available.

In the longer term, revenue from parking taxes or road user charges would form an appropriate source for fare subsidies -- we don't believe that it is appropriate to hypothecate the revenue from these sources for capital spending.

11.7. At present there is an anomaly whereby demand responsive services are not eligible for fuel rebate in respect of discretionary mileage. This may have contributed to the withdrawal of the service mentioned in Example 2 (see Appendix). We suggest that fuel tax rebate should be provided for the mileage actually driven.

11.10. We have previously stated our support for the general principles of bus priorities while expressing our concern that some local authorities are putting too much faith in them as a universal panacea. However we would now like to make a different point.

In many towns the main hold-up points for buses are at the intersections of key radial and orbital routes. Buses overwhelmingly tend to use the radial routes. Consequently a strategy of giving radial traffic priority over orbital traffic would have the side-effect of speeding up buses. It would also increase the accessibility of central as opposed to peripheral developments, and thus act as a brake on the tendency to urban sprawl which has done so much to foster car dependence. We therefore call for some pilot studies on whether such a policy can work in the terms considered here. Of course it would be necessary to introduce restrictions to prevent people from passing through the centre as an alternative to using one of the orbital roads.

11.16. We think picking up and setting down passengers, especially those intending to catch a bus from the relevant stop, could well be allowed.

12.1. We are concerned that as general coach demand has risen, provision of services on many cross-country routes not suited to the rail network has fallen. Quality Corridors provides a mechanism to deal with this, but only if local authorities are given a statutory duty to consider cross-boundary travel (see (c) of comment on 3.19).

12.5. We have no objection to the proposals as long as there is no intention to require coach passengers to wear seat belts. Passengers may need to move around the coach, e.g., to visit the toilet (if there is one) or to ask the driver to let them off. The safety record of coaches is better than that of cars, so we don't feel there is an overwhelming case on safety grounds to compel the wearing of seat belts.

12.6. We are concerned that coaches should not be subject to restrictions which reduce their competitiveness with cars. This is one reason for suggesting that cars should be subject to the same speed limit as coaches -- which would counter the argument on safety grounds against allowing coaches to use the off-side lane. At present, this lane can be described as a ``car priority'' area and therefore goes against the Government message that other modes should have priority.

12.9. We are very concerned that the introduction of EU rules on a universal basis will sharply increase the cost of bus operation.

Longer routes achieved a de facto exemption from EU regulations by being registered in sections, an arrangement that lasted right up to 1998 without complaint from the EU or anyone else, until it was ruled that Arriva's Newcastle-Carlisle route was legally ``express'' even though it observed all stops en route.

Arriva's reaction has been to split up routes such as Stansted Airport-Lakeside (see Example 5), with consequent inconvenience to through passengers, precisely to avoid such cost increases. Similarly, Essex CC, though maintaining a through supported service between Saffron Walden and Colchester (see Example 4), stopped advertising it as such -- which may have led to a fall in passengers which has now led to a decision to discontinue the service after summer 1999. (We understand that during the summer the status quo will be restored by advertising the service as a single route.)

If the EU regulations are made universal there will be no incentive for operators or councils to split up routes in this way -- which would be a good thing. But local authorities may find themselves faced with a whole host of de-registrations by operators and increased tender prices. Unless the Government can guarantee that this won't happen we strongly oppose the proposal.

Indeed, we go further and believe that the EU, who have adopted the policy of a ``citizens' network'' for public transport, should be asked to review the regulations. Why are the same regulations considered appropriate for daytime buses on rural roads, which have an excellent safety record, as for long distance lorries on motorways? For some ideas see Appendix 2.

However, we support the application of the Working Time Directive to public transport -- an obligation to work long hours is not only unfair on employees but may act as a deterrent to staff recruitment.

12.10. We would like to make two points. First, my personal experience of the M4 Heathrow spur bus lane leads me to doubt its efficacy -- buses coming off the M4 can't get into the lane to use it. Secondly, we strongly support the development of new interchanges between coaches, local buses and rail: see Examples 2 and 3 for some ideas to this effect.

Cycles on buses. This is a topic not covered in the paper. We believe that there should be a special effort to make provision for carrying non-folding bicycles, without detriment to other passengers, on ``strategic'' routes that provide long distance links on corridors not served by rail.

Part 4 -- Invited Comments

3.19. We are concerned that some local authorities have not made best use of the funding. Problems include:

(a) Some local authorities have used the funding to replace revenue support for previously existing services. While the rules do not allow local authorities to directly replace existing funding, there is nothing to stop them from offsetting support for the service improvements with reductions in support elsewhere, or failure to replace withdrawn commercial services. We believe that only spending over and above what would be required to maintain the previously existing network should be eligible for funding; in other words, if local authorities withdraw support from existing services, or fail to support replacements for withdrawn commercial services, they would be obliged to use the money to support improvements elsewhere before they received Government funding.

(b) Some local authorities have not given the new services a fair trial. For example, Lincolnshire withdrew support for no less than 97 services from the beginning of the 1999-2000 financial year, most (but not all) of which had been introduced in November 1998 under the Government scheme. 39 of the services cater for journeys to work -- yet building up patrinage for this type of service depends on people getting new jobs or homes and certainly takes over 5 months. And many of these routes would have potential to attract tourist and leisure use -- but not in the winter.

(c) Many local authorities seem to be concentrating on services within their own area and neglecting cross-boundary travel needs. Sometimes different local authorities are supporting separate services within the same corridor when a joint approach would offer better facilities to passengers at lower cost. We believe that the remit of local authorities should include a duty to cooperate with their neighbours to provide cross-boundary facilities where appropriate.

(d) While some local authorities have used the funding to support much more comprehensive inter-urban networks, the improvements introduced by others have been much more haphazard.

(e) Some local authorities have been influenced by concerns of whether funding for the new services will still be available after 2001. The Government should make an announcement as soon as possible that such funding will be continued -- some options are given in our comment on 1.16.

4.11. We believe that the Government has got the details of the scheme to provide statutory backing to Quality Partnerships about right.

5.9. We believe that when a service enhancement is introduced, if the new operator is different from the incumbent, then the two should be obliged to enter into a ticket interavailability agreement, which should cover not only return and season tickets but also ``network'' type tickets such as day anywhere ``rangers''. That's the only way to avoid confusion.

Furthermore, the considerations in this section apply equally when the prime object of the enhancement is not to provide more buses but to serve alternative intermediate points. It is vital that local authorities should not be induced to put such stringent conditions on the use of such services as to make them unviable. (See Example 1 for a case in point.)

6.10. We believe that the proposals for Quality Contracts represent the likely ultimate fate for the public transport regulatory system in most areas. However, we believe it would not be appropriate to go into such a system on a ``big bang'' approach. Our alternative is a step by step ``Quality Corridor'' approach which would work as follows:

(a) A Quality Corridor would cover a group of routes as determined by the local authority or authorities concerned.

(b) Before implementing a Quality Corridor, local authorities would be obliged to consult with existing commercial operators and bus users.

(c) Existing commercial operators would have a right to participate in the network to the extent of their previous operations, subject to their submitting a reasonable price.

(d) Local authorities would have a right to determine routes and timetables, so as to plan connections, ensure that services sharing a section of route were well spaced, and to ensure that communities off the main route received their fair share of the service.

(e) Commercial operators would not be precluded from running additional services on the corridor, but their right to do so would be subject to regulation. If they did introduce such extra services and these proved successful, they might be incorporated into the next update of the Quality Corridor agreement.

(f) Local authorities would not require ministerial agreement to implement a Quality Corridor agreement, but disaffected operators, users and other interested parties would have the right to apply to quash such an agreement if evidence could be produced that it was not operating in the public interest.

Appendix 1 shows some cases where we believe the Quality Corridor approach would be appropriate.

7.6. We believe that three changeover dates per year is most likely to be appropriate. Note that there is nothing wrong with allowing operators to make their changes at any time, provided they had been announced sufficiently far in advance to be included in the timetable information published at the previous changeover date. It would be highly desirable if passengers were given several weeks notice of new timetables before a changeover date -- and, if there was adverse public reaction, a dispensation could be granted to change the timetable before it came into effect.

Whatever happens there should be a definite commitment to ensure that information obtainable by passengers prior to a changeover date is valid without question until the next changeover date, subject to exceptional circumstances such as infrastructure work (not only on road, but also on rail and water where connectional facilities are involved).

However, there would be no harm in permitting operators to introduce extra services over and above what was in the published timetable.

7.7. We see no reason for separate consideration of this point which seems to be covered by 7.6.

7.10. Again, we see no reason for maintaining the five minute rule -- though there should be a dispensation to allow timetable changes with the aim of improving reliability. I can't work out whether the first proposal in 7.9 is intended to require the registration of changes which advance journeys or those which retard them; in general the latter are likely to be less harmful as people won't miss the bus that way (though they may miss an onward connection).

8.7 and 8.11. We support the proposals as stated.

8.15. We also support this proposal, but believe that it is at least as important for operators to give adequate publicity to the fare system, e.g., details of what reduced fares offers exist, and the exact extent of their validity. Without such publicity people may shrink from using buses because they believe they are dearer than they in fact are, and passengers may pay more than necessary through ignorance of the best option. (Note: these comments also apply to rail.)

9.6. We prefer the second option. However our proposed Quality Corridor system would also provide a mechanism for enforcing ticketing integration.

We believe that local authorities should normally ensure that ticketing arrangements for any supported service were integrated with those of the main commercial operator within the area, including interavailability of ``day out'' type tickets.

10.9. We would support changes along the lines suggested.

10.11. We believe the best mechanism to secure passenger representation is to extend to buses the remit of the Rail Users Consultative Committees. This would presumably necessitate an increase in their number. We also believe that the Local Transport Plan, if sufficiently detailed, could provide a mechanism for consultation; and we would like to see a statutory duty for local authorities to consult users before introducing supported services on other than a short term basis.

11.3. We believe the tendering system is completely inappropriate where the desired objectives can be best secured by modifying an existing commercial service, rather than introducing a new one. We therefore believe that all limits on ``de minimis'' contracts introduced for this purpose should be abolished. The original intent behind the restrictions was presumably to prevent local authorities from entering into ``sweetheart deals'' with favoured operators, but such abuse would surely be better dealt with in other ways. And surely, after years of financial restraint, local authorities are now sufficiently imbued with the ``best value'' philosophy to be trusted to make their own judgements as to whether tendering or de minimis contracts are more cost-effective.

Incidentally we believe that in determining tenders local authorities should take into account the scope for using positioning workings to provide extra services. At present all too often such journeys are made out of service even when they would provide useful facilities. An example if the service from Woodbridge to Orford in Suffolk, where timetable changes through the Rural Bus Grant increased the service to 6 days a week but led to the loss of the access journeys for visitors.

Appendix 1 -- Examples

Example 1: Peterborough-Stamford via Barnack. Delaine has traditionally run the service on this route via Marholm. However, a few years ago it switched to running alternate journeys via Helpston, which is also served by another (less frequent) service. The crunch came when it switched to running the whole route (which is hourly) via Helpston.

Peterborough City Council procured a 2 hourly tendered service between Peterborough and Stamford via Marholm and Ufford. However, as a result of pressure from Delaine, they have disallowed its use for any journey for which the Delaine route can be used, including end to end.

But the Delaine service is not necessarily suitable for such a journey. Take for example the case of someone coming into Peterborough from Stilton. The Delaine bus is scheduled to leave just as the other bus is scheduled to arrive, from the opposite end of the bus station. By contrast people using the new route have an easy 8 minutes to make the interchange, and the buses use adjacent bays.

The intermediate villages not on the Delaine route are large enough to deserve a regular service, but not to support such a service by themselves. As a result of this, Peterborough City Council has recently revised the tendered network, leading to a large reduction in the number of buses for Marholm and Ufford. We believe the former service should be restored with the restrictions removed.

Our proposals for this particular case are to procure a half hourly (or better) service between Peterborough and Stamford, which would include the Delaine route, the supported service via Marholm and Ufford, and other services between the towns, both commercial and supported. A Quality Corridor would provide a suitable mechanism for achieving this.

Example 2: A14 corridor. This is an example of a ``strategic link'' which might well be appropriate for being overseen by the planned Strategic Rail Authority.

The A14 is a heavily used road linking Felixstowe with Rugby. The section east of Cambridge is paralleled by a railway, but there is nothing to the west of Cambridge. The section between Cambridge and Huntingdon is subject to acute congestion at peak periods. The corridor, in conjunction with connecting rail services, offers potentially the fastest route for journeys between East Anglia and the Midlands: for example, Cambridge to Birmingham would take about 2 hours 15 minutes city centre to city centre, as opposed to 2 hours 45 minutes by existing National Express coach (which only runs by this route 1-2 times per day) or 3 hours 5 minutes by train.

There are many other opportunities for rail connections: Cambridge to Ipswich, Stansted Airport and London; Huntingdon to Peterborough and the North; Kettering to the East Midlands and Sheffield; and Rugby to the North-West; we therefore believe it would be essential to integrate this service with the rail network with regard to both timetabling and ticketing. Hence our suggestion of the Strategic Rail Authority as a suitable overseer.

The Highways Agency could also play a role in recognition of the contribution such a service could make to reducing traffic problems on the A14. It could provide bus stops on the A14 together with safe access from nearby villages, and a coachway interchange (see comment on 12.10) near the M1/M6/A14 junction, which would need access to/from the M1 South to work properly.

Our proposed Quality Corridor service would initially run hourly from Haverhill to Rugby via Cambridge, Huntingdon, Thrapston and Kettering. Between Haverhill and Cambridge it would replace a recent service enhancement supported by Cambs CC and operated by Stagecoach Cambus. Between Cambridge and Huntingdon it would replace an existing commercial 2 hourly limited stop service operated by Stagecoach United Counties. (There is also a high frequency service by a longer route through St Ives run by two other operators.) West of Huntingdon it would offer new local and inter-urban facilities replacing two services, one express (but not rail linked) and one demand responsive, both withdrawn in 1998.

Example 3: Granta Valley. In January 1999 Stagecoach Cambus introduced changes on the Granta Valley corridor linking Cambridge, Sawston and Saffron Walden. This led to improvements for some journeys while making others far less convenient. There has been significant local discontent at the loss of the former direct route to Addenbrookes Hospital; the replacement facility involves a change of bus. Also lost has been a through service between Whittlesford and Saffron Walden; this is used by fewer people but there is no satisfactory replacement facility even with a change of bus. The timetable connects with a newly introduced Essex CC link from Saffron Walden to Thaxted and Stansted Airport in one direction only.

If the operator is unwilling to change its times to facilitate the above mentioned connections, the Quality Corridor system would provide an appropriate mechanism to achieve this. There are also options to improve the road infrastructure, such as a coachway interchange (see 12.10) near Duxford, which would help to stimulate an enhancement of the service which the Quality Corridor system would provide a mechanism to implement.

Example 4. Stour and Colne Valleys. Separate operators provide commercial daytime services between Cambridge and Haverhill (enhanced by a supported service, see Example 2); Haverhill and Sudbury; Haverhill, Halstead and Braintree; Sudbury and Ipswich; Bury St Edmunds, Sudbury and Colchester; and Halstead and Colchester. Some of these routes also have evening and Sunday services, mostly supported by the relevant local authority. However the central section has no evening service, and Essex CC plans to discontinue support for the only through Sunday service (which links Saffron Walden and Colchester).

We believe the provision of through services between Cambridge and Colchester or Ipswich via Haverhill would open up significant potential to attract new custom for journeys such as Cambridge-Sudbury and Haverhill-Ipswich. This in turn could help to support regular evening and Sunday services.

To achieve this would require the bringing together of six operators (only two of which belong to the same group) and three local authorities. How better to do this than a Quality Corridor?

Example 5. London eastern orbital corridor. This links Stansted and Gatwick airports. In between lie the major shopping centres of Lakeside and the recently opened Bluewater. The corridor also presents opportunities for connections with radial rail routes at Harlow Town, Brentwood, Greenhithe, Swanley and Oxted stations, as well as Gatwick itself.

The route parallels the intensively trafficked M25 corridor on which removal of traffic is surely a high priority. Yet such removal depends on providing attractive through services along the corridor making interchange with relevant radial routes.

The main existing operator in the area is Arriva. Far from being interested in developing such a service, they recently split their Stansted Airport to Lakeside service into three portions (see comment on 12.9). Other operators include First Eastern National, Ensign Bus and Gatwick Flyer -- the last a non-registered operator which provides a door to door link from E/SE London, S Essex and N Kent to Gatwick.

The route passes through seven local authority areas, and makes useful connections with five rail franchises. The operators of the two shopping centres and the British Airports Authority also have an interest in providing effective non car-based access to their premises. The situation cries out for a Quality Corridor partnership between all these organisations.

Appendix 2 -- Driving Hours

This is a proposal to replace the existing EU driving hours regulations for buses and commercial vehicles with a more flexible approach. This would be tighter for some vehicles (especially long distance lorries) and looser for others (especially buses on local roads).

We believe that the regulations should apply to a wider variety of journey. Ideally all driving should be covered, but if this is considered impractical, then at least all non-private motoring should be included, such as business travel in company cars. Note that if all driving was covered, there should be an increase in permitted hours to avoid hardship to bus and lorry drivers who need to use cars to get to work.

We believe that an increase in permitted driving hours for buses would be as likely to increase as to reduce safety, by making it more viable to provide an attractive alternative for the private motorist. We suggest that the allowed limits on driving hours should vary as follows:

1. By class of vehicle. There should be greater restrictions on heavy lorries than on lighter vehicles including buses. In addition, the regime for buses should be loosened to make it easier to provide an adequate service.

2. By class of road. Vehicles using motorways should be subject to tougher restrictions than vehicles using other roads (though not so much tougher as to encourage heavy lorries to avoid the motorways). As far as buses are concerned, this would affect services with long non-stop runs (say over 15 miles or 24 kilometres, in conformity with the present definition), but it would not discourage operators from using short stretches of motorway to speed up their local services.

3. By time of journey. In the interests of safety there should be more stringent restrictions on schedules which do not allow drivers sleeping hours in conformity with their body rhythms. This would apply to all relevant classes of vehicle, but buses would generally come off relatively lightly as there are few services during the dead of night.

In addition, we recommend that drivers should be given a dispensation enabling them to complete their journeys if faced with unexpected traffic hold-ups. In the case of buses this dispensation would also be used to allow a reduction in break times in the interests of reliability of service, lack of which is one of the most potent factors discouraging public transport use.

There would, of course, have to be safeguards preventing the abuse of this dispensation. For buses, one might stipulate that it could only be applied to a given timetabled journey for a small minority of occasions -- so that if it was habitually affected by hold-ups operators would be forced to make allowances for them in their schedules.

It would be more difficult to devise a dispensation system for lorries (unless their schedules are similarly regular). In any case, there should be no dispensation given to lorries which were only en route to an overnight stop, rather than a loading/unloading point.

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