The objective of this consultation was to seek the views of all interested parties to a number of potential changes to the bus registration process intended to encourage greater collaboration and partnership working between local transport authorities and bus operators in Scotland.
The consultation followed discussions in the Bus Stakeholders Group. It was launched by Transport Scotland on 1 August 2014 It closed on 7 November, the closing date having been extended from 24 October to allow for further contributions. This paper summarises the responses to that consultation and outlines how Transport Scotland intends to proceed in the light of them.
What did the consultation cover?
The key proposals upon which views were sought related to the following areas:
- Extending the period for notifying relevant authorities in advance of registration from 14 to 28 days.
- Strengthening the requirement on bus operators to consult rather than simply notify the relevant authorities of any proposed registration.
- Encouraging the relevant authorities where appropriate to draw concerns arising out of registrations to the attention of the Traffic Commissioner and/or Transport Scotland.
- Reducing the registration period from 56 to 42 days – either for all registrations or for those submitted electronically – in order to maintain the overall time taken for the whole process from initial notification to the start of the service at 70 days.
- Requiring bus operators to detail within registered hourly frequency bands any services that are registered as frequent services.
At present, if a bus operator wishes to operate a new bus route, or change or discontinue an existing route, they are obliged to notify the relevant authorities (any local authority and Strathclyde Partnership for Transport in whose areas the service stops or will stop) 14 days before submitting the application for registration with the Traffic Commissioner. With limited exceptions, the new services – or changes – can be implemented 56 days after registration.
The changes set out in the consultation seek to encourage and facilitate greater collaboration between bus operators and the relevant authorities in planning and implementing changes to bus services at the local level. It is anticipated that this could help reduce or mitigate problems before they arise, and contribute towards greater stability in the bus network.
Although not in themselves major changes to legislation, the proposals are designed to lead to greater behavioural changes on the part of local transport authorities and bus operators. In many parts of Scotland a collaborative approach has already been adopted in order to make the most of available resources. We want to see this become the norm, to the benefit of all parties, most importantly the travelling public.
Such an approach, maximising the tools at our disposal and amending provisions to improve partnership working, is necessary to achieve the best outcomes for transport users from the public funding that goes into supporting public transport services.
A total of 54 responses were received, as detailed at Annex A. Respondents could be divided into five distinct groups depending on their institutional affiliation and whenever possible we have tried to distinguish between any differences in responses between groups.
The responses came from bus operators (7), local authorities (21), Regional Transport Partnerships (7), other professional organisations and trade body associations (12) and individuals (8). These responses will help inform the development of policies we will be taking forward during 2015.
It is notable that 6 of the 8 individual responses were from people living in Law, Carluke, who may have become aware of the Consultation after seeing it advertised on the website for the Law Community Trust (which also submitted a response).
Where respondents have given permission for their response to be made public, these have been placed on the Transport Scotland website. We have checked all responses where agreement to publish has been given for any potentially defamatory material before logging them.
The consultation asked eight questions about the proposals. An in-depth analysis has been undertaken of the 54 responses and the summary findings for each question are contained in this document.
The overall response to the consultation indicated support for the aims of the proposals although there were notable differences in how to get there. Some respondents advocated statutory provision for almost all proposals while others considered that an approach set out in Guidance or a Code of Conduct might best achieve the aims sought.
The majority of respondents provided positive answers to all the consultation questions with the exception of questions seeking to reduce the registration period from 56 days to 42 days for registrations submitted electronically (Question 4b), where most respondents regardless of their institutional affiliation were against the proposal.
Transport Scotland would like to thank all of the stakeholders who responded to the consultation. The results of the consultation will help with the development of guidance and legislative changes that Transport Scotland will bring forward to improve the process of bus registration in Scotland. More details are provided below following the discussions of the responses to individual questions.