Action for Public Transport (NSW)

We thank you for the invitation to submit proposals to the Tribunal for consideration during the review of government fares for the remainder of the 2004-05 year.

Our submission is attached.

We have no objection to the submission being made available for public inspection. In fact, we request that you do so.

If you think it would be helpful, I would be happy to make a supporting presentation at the Tribunal’s public hearing on 3rd September.

Please contact me by phone on 9516 1906 or by email to allanmiles@hotmail.com if you have any queries.

Yours faithfully,



Allan Miles
Secretary
Action for Public Transport (NSW)

1. Introduction

As is our usual practice, Action for Public Transport is making two submissions to the Review – one before the government agencies have submitted theirs, and one afterwards. This is to inform the agencies of APT’s proposals, so that they can agree, disagree, compromise or comment on them in their own submissions, and make the Tribunal’s task easier.

This tactic has so far been spectacularly unsuccessful, as the various government agencies continue to move in their pre-destined paths, immovable as the stars in their courses. However, we live in hope.

We have made the main part of this first submission very brief, because most of the points we wish to make were made in 2003,…. and in 2002…. and in 2001. The figures may have changed, but the arguments are still the same. We will therefore just update the figures in this part of the submission and refer the reader to Appendix A or Appendix B for more details.

A description of APT and our general policies on fares and tickets is in Appendix A at paragraphs 2 and 3.

2. Executive Summary

The main points in our submission are:

(a) State Transit must sell more tickets off-bus to avoid wasting the time of the driver, the bus and the other passengers when tickets are purchased by boarding passengers.

(b) Increase the price of single cash tickets by 25% or more while keeping the price of TravelTen and TravelPass tickets stable.

(c) Retain TravelPasses and introduce a new Brown Zone for use by Inner-West residents.

(d) Retain the BusTripper ticket and improve its marketing and sales.

(e) Keep single ferry fares the same, and make only a small increase in FerryTen, TravelPass and Manly JetCat fares.

(f) Increase the price of the Pensioner Excursion Ticket from $1.10 to $1.50 while it still applies only to government transport, and sell the ticket off-bus.

(g) Don’t defer any changes with the excuse that the smart-card ticket system is coming soon. This has been the excuse for doing nothing for at least the past two years, and the smart cards are still coming “real soon now”.

(h) We recommend that CityRail should make a submission to the Review. Although it has been made clear that no increase in rail fares will be allowed, the normal review documentation would be beneficial to all parties.

3. Off-Bus Ticket Sales

State Transit must encourage more passengers to use pre-paid tickets rather than paying cash to the driver. Its efforts so far have not been good enough.

State Transit must declare:

1. the current level of cash-to-driver payments as a percentage of boardings;
2. the trend in this percentage over recent years;
3. whether this level and trend are acceptable, and why;
4. what is the maximum acceptable level of cash fares;
5. when this will be achieved;
6. how it will be achieved.

Over recent years, APT has many times suggested methods of reducing the proportion of cash fares. Refer Appendix A, paragraphs 8, 9, 23, 38 and Appendix B, paragraph 72. Unfortunately, none of the methods has been given even a tentative trial, let alone been implemented.

The suggested methods include, but are not confined to:

• steep increases in single fares
• minimal increases in TravelTen fares
• no increases in TravelPass fares
• new TravelSix ticket
• new TravelTwo ticket (without discount)
• trial of a no-cash bus
• ticket vending machines
• greater publicity for TravelTen multiple person use

The benefits (all of which are calculable in dollar terms) would include:

• less time wasted by the driver;
• less time wasted by the bus;
• less time wasted by the other passengers;
• less congestion in the city streets (bus dwell times at stops would be shorter);
• less cash handling and security costs;
• customer loyalty.

If State Transit remains averse to any action, then the Tribunal must set it some direction.

The introduction of the smart card system will NOT solve the cash fare problem.

The final Parry Report, December 2003, said at p 58: “Any future reform of ticket products ….. should also recognise that the collection of cash fares imposes additional costs that will be avoidable under a smart card ticket option”.

APT agrees that cash fares impose additional costs (which should be borne by the culprit). However, it is not true to say that they (the costs) will be avoidable under a smart card option. The option exists now to pre-purchase a range of tickets, but many people don’t bother, either by choice or circumstance. If they don’t buy a TravelTen now, they won’t buy a smart card, especially as the price of a smart card will include a non-fare deposit of $5 or more.

4. Cash Fares for Buses

The following table shows our suggested increases in on-bus cash fare prices. While 25% might seem a large increase for the first and most popular band, it is only 40 cents, and is nowhere near large enough to encourage a switch to pre-paid tickets (TravelTens, etc). An increase to $3.00 (88%) or to $4.00 (150%) might be.

It must be remembered that, according to the Premier’s instructions, “individual fare products may be adjusted to varying degrees but the changes must, in aggregate, be less than or equal to the overall adjustment determined by IPART”.

APT’s Proposals for Single Bus Fares:

Sections	2003	2004	Increase	% Increase
1-2	1.60	2.00	0.40	25%
3-5	2.70	3.20	0.50	18%
6-9	3.50	4.00	0.50	14%
10-15	4.00	4.50	0.50	13%
16+	4.80	5.00	0.20	4%

The following table shows the increase in single cash bus fares over the past eight years.

Sections	1995	2003	Increase Over Eight Years	Average Increase Per Year
1-2	1.20	1.60	33%	4%
3-5	2.50	2.70	8%	1%
6-9	2.50	3.50	40%	5%
10-15	3.30	4.00	21%	3%
16-21	4.00	4.80	20%	3%
22+	4.40	4.80	9%	1%

5. TravelTens

The current discount levels on TravelTen tickets must be retained or increased. This should be done by holding the price of TravelTens while increasing the price of single tickets.

The 10-15% discount claimed by State Transit, Dr Parry, Mr Unsworth, Mr Costa et al, to be reasonable is actually at the lower end of the acceptable scale. Discounts of 25% or more are common in other major cities.

APT’s suggested price increases for TravelTens are as follows. These apply the approximate CPI rise, and also round the prices out to even dollars.

Sections	2003	2004	Increase	% Increase
1-2 Blue	11.80	12.00	0.20	2%
3-5 Brown	19.70	20.00	0.30	2%
6-9 Red	24.50	25.00	0.50	2%
10-15 Green	33.20	34.00	0.80	2%
16+ Orange	41.80	42.00	0.20	1%

The average increase per year for TravelTens has been 50% more than the average increase per year for single bus fares. The following table shows the increase in TravelTen prices over the past eight years.

TravelTen Ticket	Price 1995	Price 2003	Increase Over Eight Years	Average Increase Per Year
1-2 (Blue)	8.00	11.80	48%	6%
3-5 (Brown)	16.00	19.70	23%	4%
6-9 (Red)	16.00	24.50	53%	7%
10-15 (Green)	24.00	33.20	38%	5%
16-21 (Orange)	32.00	41.80	31%	4%
22+ (Purple)	40.00	41.80	5%	1%

6. TravelTen Discount

This table shows the new discounts if our recommendations for single and TravelTen fares are applied.

Sections	2003	10 singles	TravelTen	2004
1-2 Blue	26%	20.00	12.00	40%
3-5 Brown	27%	32.00	20.00	38%
6-9 Red	30%	40.00	25.00	38%
10-15 Green	17%	45.00	34.00	24%
16+ Orange	13%	50.00	42.00	16%

7. Single Fare Premiums (or Penalties)

If the discounts above seem too high, look at it the other way round. Instead of considering the TravelTen as being offered at a discount, say that the TravelTen price is the standard fare and the price paid by single ticket users carries a premium or penalty.

Sections	TravelTen	÷ 10 (Standard Fare)	Single	Premium (or Penalty)
1-2 Blue	12.00	1.20	2.00	67%
3-5 Brown	20.00	2.00	3.20	60%
6-9 Red	25.00	2.50	4.00	60%
10-15 Green	34.00	3.40	4.50	32%
16+ Orange	42.00	4.20	5.00	19%

8. TravelPass Prices

We recommend that no increases at all apply to TravelPasses.

• as for TravelTens, little or no increase may encourage cash-fare bus users to switch to a pre-paid ticket;
• recent increases have been far too high (50% over seven years), and retention of the current price will go some way towards redressing that impost;
• the decision to freeze rail fares this year provides a unique opportunity to also freeze TravelPass prices;
• it would be inequitable to increase the price of the non-rail TravelPasses while holding steady the price of those with rail content.

9. TravelPass Discounts

There has been much discussion but little agreement about the value of the discount on a TravelPass, and we will not repeat it all here. See paragraph 71 in Appendix B, and also our submissions to the Parry and Unsworth Enquiries..

1. TravelPasses must stay.
2. TravelPasses provide both Integrated Ticketing and Integrated Fares.
3. The proposed smart card provides Integrated Ticketing but NOT Integrated Fares.

10. Aggregate Adjustments

The Premier has said that “individual fare products may be adjusted to varying degrees but the changes must, in aggregate, be less than or equal to the overall adjustment determined by IPART”. This supports APT’s proposals for TravelTen and TravelPass ticket prices to remain at approximately the current level while greatly increasing single trip fares. APT does not have the statistics to be able to accurately apportion the increases between cash and pre-paid fares so that the aggregate adjustment equals that determined by IPART, but we would like to see State Transit’s calculations on this matter.

11. New Brown TravelPass Zone

Introduce a new Brown TravelPass Zone as an alternative to (but not replacement for) the Red TravelPass Zone. It would cover the eastern suburbs and inner western suburbs as far as Strathfield and Campsie, but exclude North Shore and perhaps ferry travel. It would overlap the existing Red Zone, and both tickets would be the same price. Many inner-west residents live on the fringe of the Red Zone and rarely travel to the North Shore. They work, shop and play at Burwood and Campsie, but the Red Zone cuts out one stop before these centres. See paragraph 44 in Appendix A.

12. BusTripper Ticket

Retain the BusTripper ticket and improve its marketing and sales distribution to provide a readily available lower cost alternative for bus users who do not wish to pay for the rail content in a DayTripper ticket. See a history in paragraphs 25 and 52 of Appendix A. The current price is $10.90 (if you can find one) but it could probably be increased by about 5% to $11.50.

13. DayTripper Ticket

This is an extremely popular ticket at the current price of $15.00. A return ferry trip to Manly from Circular Quay would cost $11.60, so if a person has to pay more than $3.40 for a return trip from home to Circular Quay, they are in front. The price could probably be increased by 7% to $16.00.

14. Single Ferry Fares

Retain the current prices for single ferry fares. See table below.

Single fares are excessively high when compared with bus and train fares for the same distances. For instance, from Circular Quay, $5.80 will take a ferry passenger 11 km to Manly, a bus passenger 40 km to Palm Beach (or further, if the bus went that far), and a rail passenger 50 km to St Mary’s. We realise that such comparisons are very crude and ignore many factors. Nevertheless, the perception is that ferries are expensive.

Sydney Ferries’ finances are far from clear at the moment. Any attempt to justify fare increases should be deferred until the 2005-06 financial year.

Single Fares	Current 2003-04	Proposed 2004-05	Amount Increase	Percent Increase
Inner Harbour – Zone 1	$4.50	$4.50	Nil	Nil
Inner Harbour – Zone 2	$4.80	$4.80	Nil	Nil
Manly/Rydalmere	$5.80	$5.80	Nil	Nil
Manly JetCat	$7.50	$7.50	Nil	Nil
Parramatta RiverCat	$7.00	$7.00	Nil	Nil

Single ferry fares have increased by an average 8% per year over the past eight years.

Single Fares	July 1995	July 2003	Percent Increase 8 years	Average Increase Per year
Inner Harbour – Zone 1	$2.80	$4.50	61%	8%
Inner Harbour – Zone 2	$2.80	$4.80	71%	9%
Manly/Rydalmere	$3.60	$5.80	61%	8%
Manly JetCat	$4.80	$7.50	56%	7%
Parramatta RiverCat	$4.20	$7.00	67%	8%

15. FerryTen Fares

The Premier has said that “individual fare products may be adjusted to varying degrees but the changes must, in aggregate, be less than or equal to the overall adjustment determined by IPART”. This allows single fares and TravelPass ticket prices to remain at the current level while increasing FerryTen prices to obtain an aggregate rise within the allowed limits.

16. FerryTen Discounts

The current discounts of up to 36% should not be thought of as excessive. It is not the discount that is high. It is the excessively high base rate of the single fare that produces the large percentage discount.

The following table shows APT’s proposals for FerryTen discounts.

FerryTen Discounts On 10 Single Fares	Current 2003-04 Discount Amount	Current 2003-04 Discount Percent	Proposed 2004-05 Discount Amount	Proposed 2004-05 Discount Percent
Inner Harbour – Zone 1	$16.50	37%	$16.00	36%
Inner Harbour – Zone 2	$16.90	35%	$16.50	34%
Manly/Rydalmere	$15.10	26%	$14.00	25%
Manly JetCat	$12.50	17%	$11.50	15%
Parramatta RiverCat	$20.70	30%	$20.00	28%

17. Ferry Component of TravelPasses

Retain current prices for TravelPass tickets. Recent steep increases have resulted in TravelPass prices rising an average of 50% over seven years. The decision to freeze rail fares and our proposal to freeze single ferry fares provide a unique opportunity to also freeze TravelPass prices this year.

18. Newcastle All-Modes DayTripper

19. Pensioner Excursion Ticket - Price

Increase the price of the Pensioner Excursion Ticket from $1.10 to $1.50 while it still applies only to government transport. The PET has been the same price, except for the GST increase, for 16 years. This change can be done before the ticket is extended to include private buses.

Overheard conversations show that pensioners are concerned, even paranoid, about “the rise to $2.50 on 1st July”. We realise that the price of the PET is outside the control of the agencies and the Tribunal, but these parties can make recommendations to the Government. While an increase in the fare will have a zero effect on the agencies’ income, the 40 cents that the Government saves on the subsidy can be spent on other transport items.

20. Pensioner Excursion Ticket – Off-Bus Sales

State Transit and the Government must find a way to sell Pensioner Excursion Tickets (PET) off-bus. The problem is not so much with the actual time taken by the sale. It only happens once a day for each user and the transaction is usually quick. Eligible passengers know the price, they usually have the right money and card ready, and they don’t have to ask the driver any questions.

The problem arises with attempts to introduce a no-cash bus. Other passengers can buy their ticket off-bus (TravelTen or TravelPass) but Pensioners and Seniors can’t. It would defeat the purpose of a no-cash bus if the driver had to carry cash just for PET’s, and it would be inequitable to debar Pensioners and Seniors from a no-cash bus. A system could be organised with a little ingenuity, and a lot of motivation and willpower.

21. TransitWay Fares

22. Deferral to Smart Card System

We would not wish any of these suggestions to again be dismissed on the basis of the new smart card system being introduced “real soon now”. We are aware of the dates of the proposed trial programs, but there is still plenty of time to introduce these changes.

23. Consumer Price Index (CPI) Increase

We have no objections to fare increases (to quote the Premier) “up to the Consumer Price Index (CPI) subject to efficiency gains, and fare increases above the CPI to clearly demonstrate customer benefits through improvements in service quality linked to specific initiatives such as bus priority measures”.

According to the Australian Bureau of Statistics web site (www.abs.gov.au) the change in the Consumer Price Index (CPI) for Sydney from March 2003 to March 2004 (the latest available) was 2.0%, the same as the weighted average CPI of the eight capital cities.

The change for Sydney for the individual quarters was: June 2003 - 0.1%; September 2003 - 0.1%; December 2003 - 0.8%; March 2004 - 1.0%.

24. Consistent Fare Structure

We note the Premier’s wish to progress to a “consistent fare structure for the bus industry” and “that IPART consider the Government's preferred approach of moving to a single fare review, including moving to a single fare change applicable to all bus operators”. However, we are not convinced that this boils down to something as simple as a single fare for all equivalent distances throughout Sydney. Would such a single fare rise to meet the private bus level, fall to meet the STA level, or be somewhere in between?

There are many factors that might be cited to justify higher or lower fares (or, conversely, lower or higher subsidies) in different areas;

• the quality and cost of the bus
• the drivers’ conditions and awards
• population density in the area
• traffic conditions and the speed of travel
• frequency of buses
• hours of operation
• desire to encourage mode change, etc.

It might even be said that State Transit customers already pay an additional indirect price through the higher land or rental values in the inner suburbs.

25. Five Year Price Path

We note also the Premier’s wish that IPART’s determination should be based on a five-year price path.

We look forward to seeing the Tribunal’s proposed five-year price path for both buses and ferries, and how this will lead to a “consistent fare structure”.

26. CityRail Fares

APT has written to CityRail suggesting that a submission on rail fares be presented to the Tribunal. Although the government has said that an increase in rail fares will not be granted, and although the Tribunal may not “process” the submission, we believe that a submission would be beneficial for several reasons:

• It would enable CityRail to calculate and place on record a nominal fare rise that would have been sought. Any increase sought in a subsequent year could then be seen as the sum of two components.
• CityRail could summarise all its costs, revenues and arguments for the current year, and keep them separate from the figures for 2005-06.
• CityRail fares are entwined with State Transit and Sydney Ferries fares through various TravelPasses in Sydney and in Newcastle. A submission from CityRail might be of assistance to those agencies in preparing their submissions.
• CityRail fares are also entwined with the fares of the Transitway and some private bus companies, and again, some indication of CityRail’s thinking might be of assistance.
• A submission this year would prevent a gap from appearing in the annual records.
• A submission this year would assist CityRail in preparing its "five year price path" as required by the Premier.

27. Discounts – What is Reasonable?

This question has been debated many times, with opposing arguments being supported mainly by guesswork and gut feelings.

This year, APT would like to see the agencies make some attempt to identify the various factors involved in giving a discount for pre-purchased multi-ride tickets, and to calculate, no matter how roughly, the monetary effect of each. As an old accounting adage says “It’s better to be nearly right than exactly wrong”.

Some factors that come to mind are:

• the cost to the commuter of outlaying money in advance (a week, a month or a year);
• the benefit to the operator in banking or receiving this money in advance of its use;
• the savings to the operator in the cost of ticket selling staff and machines;
• the savings to the operator in the cost of cash handling, storage and security;
• the savings to the operator in the cost of paper, ink, etc used to print the tickets;
• the savings in driver and vehicle time. This would apply only to street vehicles such as buses and trams, and not to trains and ferries;
• any other costs or savings.

There might be different calculations depending on the type of ticket:

• TravelTens
• FerryTens
• TravelPasses
• Rail Weeklies
• Rail Periodicals
• DayTripper
• BusTripper.

The shorter working week for many people is also a factor in their choice of tickets. Many people only work three or four days a week now, and they may not be inclined to buy a weekly which usually only gives one free day.

There is also evidence that economically disadvantaged people cannot afford the advance outlay on a TravelTen, and so they pay the higher prices for daily fares. We request that consideration be given to issuing a ticket with a smaller number of trips (at perhaps a reduced discount) that may be more appealing to these users. See paragraph 9 in Appendix A.

We note that a single fare on the Sydney Monorail is $4.00, but holders of a MetroCard (a stored value card) pay only $2.50, a discount of 38%. On several “$2 Days” during the year, the card can be topped-up for only $2.00 a ride, a discount of 50%.

28. The Transport Task

The function of the various transport agencies is not simply to run a service, or to turn a profit or minimise a “loss”, but to be part of an integrated transport system and assist in easing the congestion on Sydney’s roads. Each authority must look beyond itself to the wider world.

29. Recognition of External Benefits

The agencies, in their submissions, must recognise, identify and evaluate the benefits that flow to the general community by having an efficient public transport system that will attract patronage. The Tribunal when considering the appropriate balance between user pays and government subsidies must take these benefits into account.

30. Terms of Reference

In the absence of any specific Terms of Reference for this review, the Tribunal should refer to the “factors to be considered” as detailed on its web site. See Appendix E.

31. Integrated Ticketing AND Integrated Fares

We wish to again dispel the notion that integrated tickets via the smart card will bring integrated fares.

In its 1996 report, IPART said: “Passengers who undertake multi-modal travel but do not have access to integrated ticketing include STA bus passenger paying cash fares or using TravelTens” IPART, March 1996, An Inquiry into Pricing of Public Passenger Transport Services, Fare Structures for Public Transport, Transport Interim Report No 4, p29

“Smart cards are not a substitute for ticket integration, but are a convenient way of buying tickets.” IPART, March 1996, An Inquiry into Pricing of Public Passenger Transport Services, Fare Structures for Public Transport, Transport Interim Report No 4, p33

In its 2002 submission, State Transit said: “The purpose of the Integrated Ticketing project is to introduce a smartcard ticketing system” “In a smart card system on our buses I would be looking at the smart-card fare being essentially what is now the TravelTen fare” IPART, 10/5/2002,Transcript, Public Hearing Into Public Transport,L40-42, p7

The 2003 Parry Enquiry said: “integrated ticketing [definition:] The use of a single stored value card to purchase travel (referred to as the ‘smart card’)”. Prof T Parry, December 2003, Ministerial Inquiry Into Sustainable Transport In New South Wales, Appendix C, glossary. Strangely, he thought it important to define this term even though it doesn’t appear in his text.

“The Inquiry believes STA needs to develop a simpler bus ticket regime, and one that is better attuned to the prospect of ‘smart cards’….[a] rationalised TravelTen discount is desirable” Prof T Parry, December 2003, Ministerial Inquiry Into Sustainable Transport In New South Wales, 6.3.1, p 59

As we have warned before, the technology must serve the system. The system must not be subverted to suit the technology.

32. Submissions to the Parry and Unsworth Reviews

APT made two submissions to the Parry Review (June and October 2003) and two submissions to the Unsworth Review (August and December 2003). Many of our views on fares and tickets are detailed there, and we refer the Tribunal to those documents.

33. Submissions to Previous IPART Reviews

APT has made submissions to the IPART Reviews each year for at least the past ten years. Our two submissions to the 2003 Review are included here as Attachments A and B.

Apart from the major items mentioned above, there are many other items that should be raised for consideration again. The following is a full list of paragraphs in Appendixes A and B, and those items for re-consideration are highlighted in bold type.

34. Late Submissions by the Agencies

35. Submissions by Other Government Agencies

36. The Second Submission

A. Introductory

1. First Submission

This is the first of two proposed submissions from Action for Public Transport. It is being sent before the submissions from the transport authorities are due in the hope that the authorities may read it and address some of the matters raised here before they finalise their own submissions. APT will make a second submission after we have read what the authorities have had to say in their papers.

2. Description of APT

Action for Public Transport (NSW) is variously described as a community-based watchdog group on transport issues, a public transport consumer group guarding passengers’ interests, and an environmental group advocating ecologically sustainable transport systems.

We are not a “front” for any union, business, political party, government agency or other lobby group. APT is funded solely by membership subscriptions and donations. We are affiliated with similar groups in Sydney and worldwide, and have been operating continuously since 1975.

We are concerned about, and opposed to, government transport policies that are driven by vested interests instead of the public interest, particularly the unsustainable use of private motor vehicles in urban areas.

3. APT’s General Policy on Fares and Fare Increases

Our general policy has been, and continues to be that:

1. fares charged should be high enough to reflect the quality of the service provided
2. fares charged should be low enough to attract people out of their cars
3. fares charged should be high enough to generate reasonable cost recovery
4. fares charged should be low enough to be affordable
5. fares charged should be equitable
6. fares charged should be subsidised by governments to recognise the social and environmental benefit of encouraging people to use public transport
7. the fare system should be simple enough for users to understand
8. the fare system should be comprehensive enough to cater for different user needs
9. the fare system should be easy enough for ticket sellers to comfortably manage
10. the fare system should be seamless across different operators and modes
11. multi-mode tickets for single journeys should not include multiple flag-falls
12. users should be encouraged to pre-purchase tickets in order to reduce delays and inefficiencies caused by cash fares
13. pre-purchased tickets should give discounts of at least 20%
14. effective measures should be taken to minimise fare evasion
15. accidental fare evasion should not automatically invoke harsh penalties
16. fare increases should generally not exceed the inflation rate while allowing for the correction of anomalies and the effects of rounding
17. operators should maintain separate tables of notional fares (as well as actual fares) so that increases are not applied to fares that were already rounded up last year

B. Follow-Up of Items from 2002 Determination

The following paragraphs (points 4 to 20) refer to items mentioned in the Tribunal’s determination for 2002/03, issued in June 2002. We would be interested to know the progress, if any, on each item since then.

4. CityRail - Forecast Data

In section 2.2 the Tribunal said, “Adequate forecast data will be required by the Tribunal wherever requested fare increases exceed the increase in the CPI.”

5. Sydney Buses - Performance Assessment Regime

In section 2.3 the Tribunal said that it “would like its fare determinations to be able to consider an effective performance assessment regime for public buses as implemented by Transport NSW”. This theme crops up many times in the determination.

6. Sydney Ferries - Cost Efficiency Review

In section 2.4 the Tribunal said “STA has engaged consultants to review Sydney Ferries’ cost efficiency, and the Tribunal awaits a final report on the finding of the review.”

7. Newcastle Services - Cost Recovery.

In section 2.5 the Tribunal notes that the Better Buses program “is forecast to result in a containment of costs in future years, enabling cost recovery levels to improve.”

8. Sydney Buses - Increasing Use of Single Ride Tickets

In section 3.1 the Tribunal notes that the STA “is concerned at the increase in market share of cash single ride tickets from 20 to 24 percent.”

9. Sydney Buses - TravelSix Tickets

In the 2001 Determination (para 3.1, page 13) the Tribunal said that the STA is considering introducing other ticket types such as a TravelSix. This was raised again in the 2002 determination at section 3.1.

For the City to Surf Run in August 2002 the STA pre-sold what were in effect TravelOne and TravelTwo tickets, both at no discount. The first provided a single ride between Bondi Beach and the city in either direction, and the second provided a return trip between Bondi Beach and Bondi Junction. . If they can do it once (or twice now, actually) then why not all the time.

10. CityRail – TravelTen Product

In section 3.1 the Tribunal noted that the SRA “is examining the feasibility of introducing a TravelTen type product for trips within the inner-city zone since stations in this zone do have automatic gates.”

11. STA and CityRail – Analysis of External Benefits

In section 3.2 the Tribunal recognised the complexity of assessing external benefits but said that it “supports increased analysis and assessment of these issues by both SRA and STA in the future.”

12. STA - Passenger Charter

In section 4.1.2 the Tribunal noted that the STA “is currently working with Transport NSW in a joint venture with other transport agencies on the development of a generic service charter.”

13. STA – Detailed Service Standards

In section 4.1.2 the Tribunal said that it “supports the publication of detailed service standards on a regular basis for public scrutiny. Such a publication should clearly outline the meaning of each statistic and the sampling methodology used to collect the information.”

14. CityRail – Monitoring by Rail Regulator

In section 4.2 the Tribunal noted that, “in the future CityRail’s performance will be monitored and audited by the Rail Regulator against a set of standards established by the Minister for Transport.”

15. CityRail – Customer Satisfaction

In section 4.2.1 the Tribunal noted that “SRA has not published results of customer satisfaction surveys over the past year.”

16. CityRail – Indicators for Assessment of Service Standards

In section 4.2.2 the Tribunal noted that while “on-time running is an important indicator of service standards….. it should not be the sole focus. It is sensible to have a range of indicators with which to assess performance.”

It should be noted that on-time running is measured only on limited occasions (peak hours Monday to Friday) and at limited locations (Central and some terminuses). Sample time checks should also be taken at other times of the day, on weekends, and at other locations.

17. State Transit – Service Standards

In section 4.3 the Tribunal noted that the operational statistics quoted in Table 4.1 “are aggregates and can mask problems in particular areas or for particular timeframes.”

Also, “On-time running is measured at the point where the bus leaves the depot to begin its route. It therefore may not reflect whether the bus arrives on-time at a particular point along the route.”

The Tribunal acknowledged that on-time running would be affected by general traffic flows, which STA cannot control. However, we still assert that that some on-route timing and destination timing should also be monitored, recorded and reported so that problems become known and remedial action can be taken, or at least considered.

It should be noted that waiting passengers find early running just as frustrating as late running. It is interesting to note that the Sydney Buses web site says

State Transit Automated Ticketing System (STATS) is not only a better ticket system, but also gathers accurate information on the use and performance of services. For example, ‘on time’ running will be monitored throughout journeys and at key points by the STATS system. We also work closely with the RTA to improve reliability and the introduction of more bus priority measures will help our reliability.

18. Sydney Buses – Audit Office Comments

In section 4.3.1 the Tribunal noted some conflict between what the STA and the Audit Office considered to be appropriate maintenance standards. Have these different interpretations been reconciled so that in future years both parties will be talking the same language?

19. State Transit – Performance Assessment Regime

In section 4.3.1 the Tribunal noted that “under the PAR it is likely that STA will be required to collect information (and report on a quarterly basis) on vehicle accessibility, heating and ventilation of buses, information and signage systems, vehicle emission performance and complaint handling mechanisms.”

Also “Transport NSW will be required to assess STA’s performance. … against a set of benchmarks.”

20. State Transit – Newcastle Services

In section 4.3.3 the Tribunal noted a “particularly poor” on-time running rate in Newcastle, and that “the forecast data also shows there is unlikely to be any significant improvement in on-time running in the coming period”.

C. Left-Overs From the 2001 Determination

21. State Transit - Network Reviews.

In the 2001 Determination (para 4.3.1, page 24) the Tribunal said that key service improvements proposed by STA in following years include undertaking a network review following customer consultation.

Since then, the East review has been completed, the North review is current, and we understand that the South and West review is scheduled for later this year.

Information that we have seen* regarding Better Buses East shows that 68 runs were added and 106 runs were cut from the three depots, leading to an overall loss of 38 runs each fortnight. This translated to a dollar saving of $153,000 per fortnight. One wonders what was the major determinant – cost savings or service improvements.
(* Form letter from Clover Moore, MP, to constituents dated 22.12.02.)

22. State Transit - Bus Priority Lanes

In the 2001 Determination (para 4.3.1, page 24) the Tribunal said that key service improvements proposed by STA in following years include establishing a relatively senior management position to deal on a day to day basis with the management of bus priority lanes with the RTA and police.

Is this being done?

23. State Transit - No-Cash Bus

In the 2001 Determination (para 4.3.1, page 24) the Tribunal said that key service improvements proposed by STA in following years include trialling a bus that does not accept cash fares to examine the extent of improvement in on-time running.

The issue here should not be on-time running, as stated by the STA, but faster scheduled running. Such a trial would provide daily visible proof to passengers that they can get a faster ride by using pre-paid tickets. A no-cash bus will not improve on-time running for buses that accept cash fares. Other remedies need to be sought for that.

When APT raised this again in 2002, the STA responded that there had, in fact, been an “accidental” trial during a few days when drivers did not collect fares.

We reject this as a trial. A trial is a planned, organised and advertised event extending over at least a month, with defined operating conditions, measuring methods, comparison methods, evaluation criteria and reporting timetable. We would still like to see such a trial begin.

24. Goods and Services Tax (GST)

When the GST was introduced it made motoring cheaper and public transport more expensive.

What have the authorities and the state government done towards having the GST on public transport removed?

What have the authorities and the state government done towards having the GST already collected on public transport returned to the state for the benefit of public transport?

25. State Transit - BusTripper Ticket

In the 2002 Determination (para 5.2.1 in footnote 41 on page 34) the Tribunal said that utilisation of the BusTripper is low, with the STA selling an average of 76 tickets per day. This is hardly surprising, since the STA does its best not to advertise or sell the ticket.

But first, some history. In December 2000, the authorities withdrew the BusTripper, DayPass and DayRover tickets, replacing them all with a single DayTripper ticket. This is a great ticket and has many advantages – it covers all forms of government transport, it is cheap, and it is sold on buses. The downside is that with the demise of the BusTripper ticket, people who could not or would not use a train during the day still have to pay the extra for train travel. APT complained to the minister at the time, and the BusTripper ticket was restored.

In March 2001, the authorities released a large foldout guide to tickets, but failed to mention the BusTripper in it. They “forgot”. The BusTripper was listed on the small leaflet issued by the STA following the July 2001 fare increases. The same leaflet issued in July 2002 omitted BusTripper, as did the large newspaper advertisements. When we complained, State Transit told us they had “limited space to convey messages in print”, and that “long and complicated tables of numbers attract little attention from most users”. We found this rather odd because the little 10 x 21 cm leaflet contained a table of 67 other “numbers”.

The BusTripper is not mentioned on any bus timetables. It has been restored to the STA’s web site and is mentioned on the DoT’s web site. However, these sources do not mention the difficulty in buying a ticket. The BusTripper is not advertised in buses. The ticket is not sold on buses or at the STA kiosks at Wynyard, QVB and Circular Quay (the Railway Square kiosk STILL doesn’t sell any tickets at all). It is only available at “selected” agents, and very few of those. Thankfully, however, the bus ticket machines still accept it.

Strangely, a large 24 page booklet issued by CityRail in October 2002 does mention the ticket. (It is an excellent publication in many ways.)

If the reason that the STA restricts the advertising and sales of the BusTripper ticket is to gain the additional revenue from the DayTripper ticket, then we would prefer that they be honest and say so. However, until then, we ask that the BusTripper be advertised and sold equally with the DayTripper ticket.

26. STA Medium Term Pricing Path

In its 2001 submission (Section 7, page 21) the STA described its Medium-Term Pricing Path, detailing the proposed fare increases over four years for bus operations in Sydney.

The proposed average fare increase for full-fare adults on Sydney Buses was 14.40 cents in 2001/02, 9.86 cents in 2002/03, 10.45 cents in 2003/04 and 1.29 cents in 2004/05, a total of 36 cents over four years. It is important to note that these are “cents” and not “percents”.

As the STA did not receive the fare increase it sought in 2001, we presume that the figures in this Pricing Path will have changed. We would like to know whether the goal is still 36 cents over four years, or some other figure, and what the proposed steps are towards that goal.

27. STA’s Cryptic Data

In our response to the STA’s 2001 submission, we said that some figures were presented in a cryptic manner, and it was difficult to find the data needed to make valid comments.

For instance, there were many references to proposed average increases of so many cents (not per cent) per trip. However, there was no average absolute price per trip (so that we could work out a percentage) or find the percentage increase (so that we could work out the base price).

It was also very difficult to find any simple statement about just how much capital funding State Transit needs from whatever sources to achieve what it wants to do.

We ask that State Transit makes the statistics more clear in its submissions.

D. NEW ITEMS

28. CPI Increase

We note from the newspapers on 23rd January that the CPI rose 3.0 % over the previous twelve months and is expected to rise 2.5 % during 2003.

29. Pensioner All-Day Excursion Ticket - Price

Once again, we raise the fact that the cost of the Pensioner Excursion Ticket has not risen (except for GST) for many years. The ticket price was increased from $1.00 to $1.10 in 2000 for GST. The previous increase from $0.60 to $1.00 was in 1988.

The ticket is far too cheap, and leads to unreasonable expectations and demands both from those who do and those who do not enjoy the facility.

The single age pension in 1988 was $120.05 per week. The single age pension in January 2003 is $214.70 per week (and will go up again in July 2003). This is an increase of $94.65 or 79% over 15 years, or 5.3 % per year.

We consider that a price increase to $1.50 or $1.60 would be reasonable, a view shared by many senior citizens. While this is a 50% increase now, it is less than 4% per year spread over the past 15 years. Even an increase to $2.00, while being perceived as an 82 % increase, would in fact be only 5.5% per year over 15 years.

The half fare concession on short single trips could mean that not every pensioner would have to pay $1.60 or $2.00 to go out.

We realise that this increase would be revenue neutral to the SRA and STA, as each additional cent raised by fares from a concession passenger is a cent not received by way of government reimbursement. However, if a promise could be given as to how the additional fare box money might be spent, perhaps the users might be more willing to pay it. We recognise that concession pricing is a matter for the NSW Government, but we suggest that the Tribunal recommend such action to the Government.

30. Pensioner All-Day Excursion Ticket – Area Coverage

The ticket covers only CityRail and STA transport. To be equitable, the availability of the ticket needs to be expanded to include private buses (and private ferries). If this is too generous, perhaps different priced tickets could be sold for different areas or zones.

In general debate, the terms Pensioner Excursion Ticket and pensioner concession ticket are often confused. The latter are half-fare tickets available, as far as we know, on all buses and ferries, trains, trams and monorails – just about everywhere, in fact, except the Manly jetcats.

In this debate, it is also often said that people who live in western Sydney cannot make use of the Pensioner Excursion Ticket. This is true, but only in relation to travel on private buses in that area. Once the person gets to the railway station, the ticket is available for travel all over the inner suburbs. It might similarly be said that a person who lives in the inner suburbs cannot use the ticket to go to Bonnyrigg or Castle Hill.

31. Integrated Ticketing Proposal

We are aware that such a scheme is being developed. However, we do not want any of our current requests delayed with the excuse that they will be included in the new arrangements. This is “never-never” land. We want action now.

32. Integrated Ticketing – Consultation

This group and other commuter organisations have very serious concerns about the lack of true consultation with the groups by the project owners and designers.

In the three or four years of the life of the project there have been only two or three meetings with commuter groups. Even then, the commuters were not treated as true stakeholders in the project, but were merely told what was going on or were invited to ask questions. We have had no proper input.

When we ask questions, such as “Will the system be able to provide this or that?” the answer is always, “Yes, it can do that,” but not “Yes, it will do that.”

We fear that the system is being provided for the benefit of the operators and the bank holding the prepayments, but not for the traveller.

We request the immediate, formal and continuous involvement of commuters in all aspects of the system development life cycle.

The Public Transport Users Association (PTUA) in Melbourne has a similar complaint. In the September 2002 journal they said, “The Minister has refused to appoint consumer and public interest representatives to the Ticketing Taskforce, which is made up entirely of DoI (Department of Infrastructure) bureaucrats and representatives from the private operators.” Also, “The PTUA is concerned that the Taskforce is operating as a closed shop, and its members neither know nor care what passenger want.”

33. Integrated Ticketing – but not Integrated Fares

It is true that a rider may need only one ticket to travel from Bonnyrigg to Bondi Beach by private bus, train and government bus, but we fear that the fares will not be integrated. The rider will probably have to pay the flagfall and the distance cost three times.

We request an assurance from the authorities that this will not happen.

We request an assurance from the Tribunal that you will prevent it from happening.

34. Integrated Ticketing – Loss of Discounts

We fear that the discounts provided by many or all multi-ride tickets will disappear if each ride is charged separately as mentioned in the previous paragraph. This could include TravelTens, weeklies and TravelPasses. Many people keep both a Blue and a Brown TravelTen in their pocket for different length journeys. It is difficult to see how both can be stored on a smart card and the correct one chosen by the machine.

We request an assurance from the authorities, especially State Transit, that the proposed smart card will still give discounts on TravelTen tickets, or, if not, that the current magnetic stripe tickets will still be freely available and acceptable.

We request an assurance from the Tribunal that you will prevent any loss of current facilities.

35. Our Proposals for Fares Generally

We propose that large increases be applied to cash bus fares this year, and minimum or zero increases to rail and multi-ride tickets. This is partly an attempt to reverse the trend towards cash fares on buses. It is also to redress the trend where those cash fares have increased by 25-36% over seven years, TravelTens by 41-47% and TravelPasses by 50-58%. These figures refer to the most popular two or three low order bands.

The authorities, and State Transit in particular, have long complained about the alleged “excessive discounts” given to TravelPass holders. They say that holders make many “trips” and the authorities calculate a value for each of these trips, then add the relevant fares to get a “value”. This ignores the fact that, to a TravelPass holder, three ”trips” on a bus, a train and another bus only make one “journey”. CityRail recognises this. A journey from Ashfield to Arncliffe with a change at Redfern is not charged as two trips, but as one, with one flagfall.

We do not have the sophisticated data collection and analysis methods of State Transit, but our rough estimate of the weighted average increase of our fare proposals is 1.0 %.

We would hope, however, that the large price increase in the single cash fares, combined with other initiatives, would reduce the number of people buying cash fares, and so reduce the weighted average in the long run.

36. STA – Off-Peak Bus and Ferry Fares

Unlike CityRail, State Transit does not have any discounted off-peak tickets for buses or ferries. (There used to be a discounted lunch-time ferry fare, but that has long since gone.) We would be interested to learn of any proposals for such fares.

37. STA – Our Proposals for Bus Fares

The following paragraphs give APT’s proposals for bus fares from July 2003. The general principles were:

• cash fares – large increases to try to steer people towards pre-paid tickets;
• TravelTens – very small increases, mainly to round out the prices;
• TravelPasses – no increases as they have risen too much over recent years.

38. STA Buses – Cash Fares

We do not have statistical evidence of the latest trend regarding the proportion of travellers who buy cash fares, but from observation it does not seem to have reduced. Amongst the worst, or the most noticeable groups of “offenders” are

1. tourists,
2. people going up and down George Street for lunch or drinks, and
3. young people going out for the night.

Apart from adjustments to fares, what other strategies does the STA have to halt the trend? Vending machine? Street ticket sellers? Advertising? Leaflets on buses? What is the defined acceptable percentage target for cash fares?

39. TravelTens and FerryTens – Multiple Boardings

TravelTens and FerryTens may legitimately be used by more than one person boarding the bus or ferry at the same time. The first person, after inserting the ticket in the machine, may pass it to a second person, and a third and so on.

However, this facility is not widely advertised. For instance, it is not mentioned on bus timetables, and it is not mentioned in the 24 page CityRail booklet quoted above. It is mentioned on State Transit’s web site.

If this aspect were more widely known, especially in relation to buses, groups of people might well be persuaded to use TravelTens instead of paying individual cash fares. It is cheaper and quicker.

40. Our Proposals for STA Bus – Cash Fares

The main feature of our proposal is a large increase in the most popular short distance fares, not so much to raise revenue, but to reduce the proportion of cash fares. Between July 1995 and July 2002, cash fares increased as follows: 1-2 sections – 25%, 3-5 sections – 4%, 6-9 sections – 36%, 10-15 sections – 18%, 16-21 sections – 17%, 22-27 sections – 7%.

41. Our Proposals for STA Bus – TravelTens

The increases here are low, ranging from zero to 2 percent, in an attempt to draw users away from single cash fares. Between July 1995 and July 2002, TravelTens increased as follows: Blue – 41%, Brown – 18%, Red – 47%, Green – 32%, Orange – 24%, Purple – 0%.

These increases are roughly twice the increase in the cash fare over the same period.

42. Our Proposals for STA – TravelPasses (Bus and Ferry Only)

No increases are proposed this year because users have borne heavy increases over the past years. Between July 1995 and July 2002, TravelPasses prices increased as follows: 2 Zone – 57%, Blue – 58%, Orange 46%, Pittwater – 37%.

43. Our Proposals for STA/CityRail – TravelPasses

No increases are proposed this year because users have borne heavy increases over the past years. Between July 1995 and July 2002, TravelPasses prices increased as follows: Red – 50%, Green – 46%, Yellow – 40%, Pink – 36%, Purple – 15%.

44. Our Proposal for New TravelPass Zone

The deletion in 2002 of the outer zone Brown TravelPass, and the addition a few years ago of the short distance Brown TravelTen ticket offers an opportunity to create a new Brown TravelPass zone in the inner suburbs. It also offers the opportunity to bring the order of the colours into alignment in both tickets. We realise that the tickets bear no relation to each other, but there is some memory of the sequence in the public mind.

The proposal is to create a new Brown TravelPass zone that would partially overlap the Red Zone. The Brown Zone would cover all bus and rail in the eastern suburbs, and in the western suburbs as far as Strathfield, Rhodes, Campsie, Bardwell Park and Rockdale. It would not cover anything north of the harbour, including ferries. The price would be the same as the Red TravelPass.

The Red TravelPass would stay unchanged in area and price.

In 2002, we requested an extension of the Red TravelPass from Croydon to Burwood and Strathfield and from Canterbury to Campsie, on the grounds that these were major retail and employment centres for inner-west residents. The authorities declined our request on the grounds of loss of revenue, which is understandable.

To protect the revenue, therefore, we propose that in return for adding on the Burwood, Concord and Campsie areas, the bus and rail authorities could delete the area north of the harbour in a new Brown TravelPass Zone.

No doubt, many refinements of this proposal could be offered and we would be happy to discuss them, but we would like genuine consideration to be given to the basic idea. We don’t want to know why it won’t work – we want to know how it can work.

45. Sydney Ferries – Efficient Costs

It is still too early to determine the final impact that the Sydney Waterways enquiry will have on Sydney Ferries’ “efficient costs”.

46. Our Proposals for Sydney Ferries – Single Fares

The current cash fares are expensive and do discourage casual use of the ferries. In some cases it’s only half the price to take the bus. A big increase may see both the patronage and the cash take fall. We understand that ferry patronage fell 4% last year. Sydney Ferries need to maximise revenue, and a cut in the fares may achieve this goal by increasing patronage. It is important to note that if the ferries charge very high fares and still lose money there will have to be an inquiry. Sydney Ferries vessels are all quite large and they need to be kept full to make money. It not worth running a ferry with just a few passengers no matter what fare they pay.

We therefore propose only a nominal increase in the cash fares. We recommend no increase in the Jetcat fare because of greatly reduced fuel costs. State Transit needs to develop a market for non-commuter travel to make full use of these vessels.

47. Our Proposals for Sydney Ferries – FerryTens

We propose no increase in order to increase the level of discount over single fares. State Transit should fit Green Machines to ferries for validation of multi-ride tickets.

48. STA - Intermediate Fares on Sydney Ferry Services

Some years ago, the STA charged reduced fares on intermediate ferry services that did not go to Circular Quay, such as Greenwich to Birchgrove, Cremorne Point to South Mosman, and Milsons Point to Balmain. These fares are no longer available and passengers are charged the full $4.30 for the short trips.

We request that these intermediate fares be re-instated at a price of approximately half the full fare to and from Circular Quay.

49. STA - “Better Ferries” Program

We understand that State Transit is planning a “Better Ferries” program, along the lines of Better Buses East, North etc. We would be interested to learn what State Transit’s brief will be for this program, that is, what it is setting out to achieve.

50. CityRail Fares - General

We have no proposals for general changes to CityRail’s fare structure or fare levels. An increase similar to last year’s of around 2.0% would be acceptable.

We think that CityRail should explain more clearly and perhaps more forcefully what happens when small increases are not passed on to short distance fares. There was a perception in some places last year that short distance riders had escaped a fare rise that other users had to suffer. It should be made plain that eventually, short distance users will bear a once-off 10% increase while longer distance riders will still have their annual one or two percent rises.

It should also be emphasised that the zero rise affects not only inner suburban people who travel to the city, but anyone who travels a short distance. Thus, instead of giving the example of “Burwood to City – no increase”, the press release could say “Parramatta to Blacktown – no increase”. Both journeys are about the same distance.

51. CityRail – Next Day Use of Off-Peak Return Tickets

Until about 10 to 15 years ago, the return portion of all return tickets (full fare or Off-Peak Return) was valid on the next day, or on the Monday after a Friday, or even a Tuesday after a long weekend. Now, return tickets are only valid until 4 a.m. the next morning.

We request that the former facility be restored on all return tickets for longer distance journeys, say over 100 kilometres (that is, 100 km one way, or 200 km return). This would enable people travelling between Sydney and such places as Wyong, Katoomba, Mittagong, Dapto and beyond to have a reasonable time at their destinations without having to rush to catch an afternoon or evening train.

52. New BusTripper Price

We recommend that the BusTripper ticket be retained and the price increased from $9.70 to $10.00, an increase of 3.1 %. We also recommend, as always, that the ticket be more widely advertised and more widely available for purchase.

53. New DayTripper Price

We recommend that the price of the DayTripper ticket be increased from $13.40 to $14.00, an increase of 4.5 %. At this price the ticket is still very good value, and very convenient (especially for avoiding the queues for Manly Ferry tickets at Circular Quay). On current fares, an off-peak return rail ticket from Petersham Quay is $3.00, or a return bus fare from Leichhardt is $5.20, and a return ferry trip to Manly is $10.80, so a day tripper with a DayTripper is in front already.

54. Students’ TravelPass

At present, students are not allowed to buy TravelPass tickets for periods longer than a week. We consider that student concession TravelPasses should be available in the same quarterly and yearly periods as for adult TravelPasses, or perhaps for periods aligned to university terms.

The School Term Pass for primary and high school students is available for periods of one, two, three or four terms.

55. Newcastle Fares – General

Our group is not close enough to the situation in Newcastle to offer any detailed suggestions regarding fares and tickets in that city.

56. Newcastle – DayTripper Ticket

One point that we would like to raise concerning Newcastle, however, is the provision of an all-modes all-day ticket. There used to be a Day Rover in Newcastle, but it was discontinued along with the Sydney one several years ago.

The current time-based fares include an all-day ticket for $7.60, which gives unlimited bus and ferry travel for 23 hours (yes 23) from the time of purchase (e.g. 6pm today to 5pm tomorrow). This is rather unusual. The base 1-hour fare is $2.50, so the 23-hour ticket is probably fairly priced, but it gets very little use. There is no equivalent to the Sydney DayTripper train-bus-ferry ticket. We recommend the introduction of such a ticket priced at around $8.00 or $9.00. The Sydney price of $13.40 would be too dear for the Newcastle market. It should be designed so that it can eventually be extended to cover the private buses.

57. Integrated Transport Information Service (ITIS)

In its 2001 submission (Section 3, page 7) the STA described its involvement in the continuing development of the ITIS system

We would be interested to know what further progress has been made in this area.

58. IPART and Private Bus Fares

If the Integrated Ticketing system ever gets going, what power will IPART have over the private bus (or ferry, tram or monorail) component of the tickets?

If IPART will have some power over the private component of an integrated ticket, will it be given the same power over the cost of an non-integrated private ticket?

E. CLOSING REMARKS

59. Lateness of STA and CityRail Submissions

In 2002 the submissions from both authorities were received four weeks after the due date. They are late every year, though never so late as that and we are at a loss to understand why. The need for the submissions could hardly have been a surprise, as they have been requested at this same time for about the past ten years. Even if there were no IPART enquiry, surely the authorities would need to go through a similar process in submitting requests for fare changes to their own department heads.

60. Submissions from Other Government Agencies

INTRODUCTION

This is the second of two submissions from Action for Public Transport on fares for government transport services. The first was sent before the closing date for submissions from the authorities in the hope that the authorities would address in their submissions some of the matters we raised. This second submission comments mainly on the proposals, or lack thereof, in CityRail’s and State Transit’s submissions.

The headings of the 60 items in our first submission are listed in Appendix A for reference, and the numbering in this submission continues from there.

SUMMARY OF SECOND SUBMISSION 2003

61. Summary of APT’s Submission

• We censure the CityRail and State Transit submissions for their lack of content and for their deferral of everything to somebody else and some other time.
• We reject the proposition that the discounts on the periodicals (especially the TravelPasses) are too generous and must be drastically reduced
• We criticise State Transit for its unwillingness to tackle the problem of the high proportion of bus passengers paying single cash fares
• We are disappointed that the authorities never discussed with us any of the proposals made in our first submission over three months ago
• We propose a few more minor initiatives not mentioned in our first submission.

COMMENTS ON CITYRAIL AND STA PROPOSALS (OR LACK THEREOF)

62. General Comments

The submissions by CityRail and State Transit are remarkable, more for what they don’t say than for what they do. They contain many platitudes but few plans, many shadows but little substance, much history but little hope, and many arguments but little conviction. The documents are characterised by timidity or inertia, paralysis or fear, and procrastination or misplaced optimism. The excuses for doing nothing are stated variously as – the Tribunal will decide the fares, the Integrated Ticketing system is coming “soon”, wait and see what the coming Funding Enquiry says – and probably unstated reasons such as - tread warily until Mr Costa has put his broom away.

Apart from saying what a good job they are doing (and we don’t dispute that), there is not one firm, detailed proposal in the whole of State Transit’s submission for Sydney Buses. The small table of proposed capital expenditure for the next four years on page 6 reveals very little. The Sydney Ferries submission is similar, although in one instance they have thrown caution to the winds and proposed a new “Upper Parramatta River” ticket. (The name could probably do with a make-over.) The submission for Newcastle buses and ferries is also “steady as she goes”. All three submissions talk about a “holding pattern”, a “modest rise to match CPI” and an increment “to respond to the increasing cost base”.

The CityRail proposal is similar to State Transit’s. No forecasts and no specific proposals for fares or tickets. A few innovations such as off-peak singles and Rail TravelTens are promised - but not just yet.

The one area in which both authorities seem to show some united spirit is in their wish to milk the captive, got-a-job, must-be-rich, adult periodical ticket holders. CityRail proposes to reduce discounts (RailSpeak for increase prices) on periodicals “in the metropolitan area” (page 26). State Transit proposes the same for TravelPasses, TravelTens and FerryTens, which tickets are also confined to the metropolitan area. Users of these tickets have been the front-line cannon fodder for fare increases over the past seven or eight years. In paragraphs 35-43 of our first submission, we recommended little or no increases in periodical tickets, small increases in single train and ferry fares, but large increases in single bus fares.

This proposal for increased single bus fares was one of several measures designed to reduce the proportion of cash fares paid to the driver, as well as relieving the constant burden of fare increases on multi-ride ticket holders

We are very disappointed that, after the authorities acknowledged receipt of our first proposals in January, we never heard from them again. Even in their own submissions they have failed to mention most of our proposals, neither supporting nor rejecting them, so we will now have to raise them with the Tribunal. If the authorities had explained, either in discussion or in their submissions, why such-and-such could or could not be done, we would have been happy to let the matter rest (at least, until next year).

This submission also raises some minor new matters, such as Business RailCards, Periodicals by Salary Deduction, and Rebates on lost periodicals.

63. Reducing Discount on Rail Periodicals

This proposal is mentioned several times in CityRail’s submission, but only once are the words “in the metropolitan area” added. This raises two questions:

1. The discounts on periodicals from beyond the suburban area to Central are much greater than those from within the suburban area to Central.
2. There would also be inequity if CityRail reduced the discount for short distance periodicals within the metropolitan area (Burwood to Central, Burwood to Granville) but did not reduce the discounts for equivalent short distances outside the metropolitan area (Lawson to Katoomba). These weeklies all cost $23.00.

CityRail needs to spell out more precisely the ramifications of “in the metropolitan area”.

Many people don’t work five days a week and make ten trips. A person who worked four days a week would obtain no savings at all if the discount were reduced to 20% or less.

64. “Burden on Taxpayers”

We have criticised CityRail before about using these emotive words. In one paragraph on page 6 they mention both the burden on taxpayers and the contribution from taxpayers. However, in the section on External Benefits, they mention the various beneficiaries of the rail system, and close by talking about “an investment by the community in CityRail”. Everybody is a taxpayer, and everybody benefits.

65. Factors Other Than Price

We agree that for many, or perhaps most people, price is not the most important factor in deciding whether or not to choose public transport. Both CityRail and State Transit have mentioned this in their submissions. The other factors in the decision are well known and need not be repeated here. However, given the current level of complaints about public transport (justified or not), it would seem unwise or insensitive to impose large fare increases now. The public is saying that they will pay for better services when they get better services.

66. Where Will the Money Come From?

Rejecting large fare increases now means that money for improvements cannot be expected from fares. If the customers want to see better trains, buses and ferries before they pay their money, then alternative sources of finance must be found to pay for the improvements. This will be considered by the Funding Enquiry that will commence soon. The money to improve the services could be in the form of a loan, to be repaid from higher fares when the improvements are implemented. It is to be hoped that the authorities have plans ready should large sums of money suddenly come their way.

67. Where Will the Money Go To?

Do the authorities possess costed project plans that would deliver specific benefits in specific areas in a specific time, if only they had the money? In other words, are they in a position, tomorrow, to ask the Government for a precise sum of money to spend on particular projects that will deliver measurable benefits in a defined time? This is in addition to the capital requirements already in their budgets, small because of the authorities’ limited horizons and expectations.

68. Rail TravelTens

CityRail says these cannot be introduced until the Integrated Ticketing system arrives. APT says that the tickets could be implemented in a limited way in a few months if CityRail put their mind to it. After all, the idea has been tossed around for several years now. Somebody must have had some ideas.

We agree that RailTens could not begin system-wide until every station has some sort of recording or validating device at the gate. However, the place where the ticket is sorely needed is just the place where every station does have barrier machines – the Central Business District. In the area bounded by North Sydney, Kings Cross and Redfern, every station has automatic barriers. Within this area, many people do not have periodical rail tickets, but need to travel around the city or across the bridge either for work or shopping or after-work entertainment.

The single fare from any one of the CBD stations to any other is either $2.20 or $2.60. To be workable, the City RailTen would have to be based on a common fare, and also offer a reasonable discount. If we said the common fare was $2.40, and gave a 20% discount, then ten tickets would cost $19.20 – say $20.00 rounded. This would still provide a 9 % discount off a $2.20 ticket, and also save the user time through not having to queue up to buy a ticket.

The CityRail barrier machines do not print anything on tickets as they are validated, unlike the Green Machines on buses that record each trip on TravelTens. CityRail would have to decide if this is a problem, and if so, find a way around it.

CityRail says (para 2.9.3) that they cannot even provide a RailTen for the CBD “due to the prohibitive cost and operational changes required”. We find this difficult to believe. The AirportLink company introduced “ten-for-nine” tickets in April 2003.

We strongly caution – repeat, strongly caution CityRail and State Transit not to wait until after the Integrated Ticketing system is installed before implementing ticket reforms. We have grave doubts as to whether anything like what is expected from that system will ever happen.

69. Car Parks

CityRail says (page 21) that they have “provided a new 39-space car park at Broadmeadow costing $545,000”. That works out at $14,000 per car. APT wonders whether that money could have been better spent on improving the bus services and interchange facilities at this or some other station which could benefit hundreds of people instead of just thirty-nine.

70. A Limit to the Funding?

State Transit says in its submission on Sydney Buses (page 4) “Government faces increasing demands for funds both within and outside the transport portfolio. Accordingly there is a limit to the funding that can be allocated to State Transit.” We say that, depending on how seriously the government sees the problem, there need be no limit to the funding that can be allocated. The government appears to have no hesitation in continuing to allocate billions of dollars to roads, which not only starves State Transit (and CityRail) of funds, but makes worse the problems that public transport is expected to solve.

71. TravelPass Discounts

State Transit says that TravelPass discounts range from 34% to 47%. We have no way of verifying these figures, and we doubt that State Transit has either, but we consider the assertion to be excessive. The discounts would vary from person to person.

Looking at both ends of the scale, the Purple TravelPass costs $52 and the Blue TravelPass costs $27.

An average Purple TravelPass user might make ten rail trips between St Marys and the City and ten 1-2 section bus trips. They would probably not use it at the weekend.

$6.00 x 10	= $60.00
$1.50 x 10	= $15.00
Total		= $75.00
TravelPass	= $52.00
Discount	= $23.00 = 31% on $75.00.

An average Blue TravelPass user might make ten 3-5 section trips and ten 1-2 section trips Monday to Friday and perhaps two more 3-5 section trips at the weekend.

$2.60 x 10	= $26.00 (weekday trips)
$1.50 x 10	= $15.00 (weekday trips)
$2.60 x 2	= $  5.20 (weekend trips)
Total		= $46.20
TravelPass	= $27.00
Discount	= $19.20 = 42% on $46.20.

These “generous” discounts might seem to validate the authorities’ case.

However, in both these cases the price of each separate trip has a flagfall component in it, making the total cost for calculating the discount seem higher. If we treat the two trips as a single journey, as would be the case if the person did not have to change vehicles, then the discounts might possibly be:

Purple TravelPass

$6.60 x 10	= $66.00 (ten trips St Mary’s to, say, Glebe, if there was a train to Glebe)
TravelPass	= $52.00
Discount	= $14.00 = 21% on $66.00

Blue TravelPass

$3.40 x 10	= $34.00 (representing ten 6-9 section bus trips)
$2.60 x 2 	= $  5.20 (two weekend trips of 3-5 sections)
Total		= $39.20
TravelPass	= $27.00
Discount	= $12.20 = 31% on $39.20

A comparable case is a person travelling by train from St Marys to Sydenham, and having to change at Redfern. The separate fares are - St Marys to Redfern $6.00 and Redfern to Sydenham $2.20, a total of $8.20. However, the fare from St Marys to Sydenham is only $6.00, not $8.20, as the passenger is considered to have made only one trip, not two. The discount on a $39.00 weekly would appear greater if calculated on the $8.20 two-trips basis instead of the $6.00 one-trip basis.

72. Cash Single Bus Tickets

Some quotes from page 9 of State Transit’s submission on Sydney Buses.

“Following a period where the cash single ride ticket market share increased somewhat, it would now appear to have stabilised at around 20%”. We are pleased to see that it is lower, however State Transit has not said how low it should go. Is 20% acceptable? We don’t know. Casual observation of people boarding buses would suggest that it isn’t acceptable. We recommend that State Transit nominate a target for cash fares each year, and then report on whether or not they have achieved it. Perhaps it should be a Customer-Related KPI (Key Performance Indicator).

“State Transit will continue to monitor the impact of annual fare determinations to ensure that the proportion of on-bus sales remains at a low level.” It is not only the annual fare determinations that have an impact on the proportion of on-bus sales. It is everything else that State Transit could do, but won’t.

“From an operational perspective, a number of incentives exist to minimise the proportion …. etc”. We know what the operational incentives are, but State Transit hasn’t told us what the strategies are. STA’s only lifeline seems to be the Integrated Ticketing system.

Far from requiring state-of-the-art computers to speed up bus boarding, our observer noted that most old-fashioned of devices, a queue conductor, assisting a large crowd of passengers to board the 500 series buses in Druitt Street on Monday evening 19th May 2003.

73. A Range of Innovative Fare System Policies

On page 9 again we read “The new ticketing system will also provide the opportunity to consider a range of innovative fare system policies that cannot be supported by existing technology.”

Not all enlightenment in the area of ticketing rests with State Transit. In APT’s submission to the concurrent private fares enquiry, we reported on our survey of about 30 of the main bus companies in the Hunter – Sydney – Illawarra region and compared the ticket types with those available from State Transit. We recognise that no single private company offers any more than three of these tickets. Many offer two, or one, and some offer none at all.

74. Affordability Comparison

On page 11, the comparison of fares for a 4 km trip by different modes is not quite fair.

The submission says a single bus fare to Lilyfield is $2.60, a TravelTen is $1.89, and a Light Rail fare is $3.60. This ignores the fact that a Light Rail weekly, allowing unlimited trips, costs only $19.00. The round-trip monorail fare of $4.00 is also mentioned, but the discounted fare of $2.50 (sometimes $2.00) using a multi-ride MetroCard is ignored.

75. Customer-Related KPIs – Comfort

We question whether “Comfort” is the appropriate heading under which the age of buses should be recorded. Some new buses, especially those smaller ones purchased by the private companies, are quite uncomfortable.

OTHER NEW ITEMS

76. Purchase of Season Tickets by Salary Deduction

CityRail used to staff a small office to assist large corporate and government employers to set up and maintain a program whereby employees could purchase yearly tickets by regular salary deductions. This was beneficial both to CityRail and the employees, and the cost of the “interest free loan” to employees was borne by the company.

To the best of our knowledge, this office was around for at least forty-five years but it has unfortunately been closed. We request that consideration be given to re-opening it, or establishing a similar office elsewhere to encourage and assist employees in the purchase of yearly rail and TravelPass tickets.

77. Sale of Bus TravelPasses at TVMs

CityRail Ticket Vending Machines sell TravelPasses that contain rail content – Red, Green, Yellow, Pink and Purple. They do not sell the Blue, Orange or Two Zone TravelPasses, although these can be purchased from ticket offices. Consideration should be given to making the full range of TravelPass tickets available through the machines.

78. CityRail Business RailCards

For a few years in the mid-1990s, CityRail had a ticket called Business RailCard. This ticket was purchased in a company name and could be used by anybody employed by that company.

The tickets came in three types:

• Gold, which covered all the CityRail area from Nowra to Newcastle, Goulburn and Lithgow. (Details of price not now available)
• Silver, which covered all the suburban area (Penrith, Campbelltown, Cronulla, Cowan, etc.) The cost of this ticket was $2,070 for twelve months.
• Blue, which was a point-to-point ticket between two nominated stations, and all points in between. They cost 25% more than individual non-transferable point-to-point periodical tickets. For instance, a yearly Blue Business RailCard between Burwood and Chatswood via the city cost $1,098.75, which was 25% more than the individual price of $879.

The tickets were still available in January 1998, but were withdrawn soon afterwards, presumably because they didn’t sell well, although one never knows what are the real reasons behind anything that CityRail does.

We recommend that CityRail reconsider the market, design, price and publicity for such a product.

79. Service Fee for Lost Periodical Tickets

Before computer tracked tickets were introduced, CityRail had a fee structure for the replacement of lost TravelPasses that involved a small service fee for printing, plus an additional 10% of the unexpired value of the original ticket. The presumed intent of the additional fee was to insure CityRail to some degree against the possibility of fraudulent re-use of the replaced ticket.

With the introduction of computerised ticketing, the means exist to disallow and capture, at the barrier, tickets that have been replaced. An analogy can be drawn with banking cards. APT recommends that a flat service charge only should apply to the replacement of lost or stolen TravelPasses and FlexiPasses.

80. TravelTen Tickets to be Marked “Transferable”

In Item 39 of our first submission, we mentioned that TravelTen and FerryTen tickets are transferable, and can be used by more than one person boarding at the same time, and commented that this facility is not widely advertised.

We omitted to mention that this transferability is not even stated on the ticket itself. All the tickets that are “not transferable” say so, but the one that is “transferable” doesn’t say so. We recommend (again!) that a statement to this effect be printed on the ticket.

81. Range of Concession Fares

We realise that concession fares are not the province of IPART, but we want to place on record here the complexity of the system.

The NSW Council of Social Services (NCOSS) has made a valiant attempt to list all the types of concessions (see the web site below). This covers seven pages and mentions seventeen different types of concession cards. And, of course, children under twelve, who don’t need a card, make an eighteenth group. Pity the poor bus drivers!

http://www.ncoss.org.au/hot/transport_concessions/transport_concessions_guide.pdf

82. I.T. and Communications Budget

We note with alarm that State Transit will reduce I.T. and communications expenditure from $5.6 m in 2003/04 to only $1.0 m in 2006/07, presumably because the ticketing system will be taken over by the Department of Transport. As mentioned elsewhere, we recommend caution about this new system rather than this unbounded optimism.

CONCLUSION

83. Public Hearing

I am writing in relation to IPART's forthcoming review processes with respect to passenger transport fares for 2004-2005, in the context of the Government's recently announced transport reforms.

In light of recent performance issues on the CityRail network, I direct under section 7(1) of the Independent Pricing and Regulatory Tribunal Act 1992 ('the Act') that the 2004-05 IPART fare review process for CityRail be deferred until further notice. However, fare reviews of other public transport modes should proceed.

Following the Ministerial Inquiry into Sustainable Transport, the NSW Government has committed to delivering parity in fare structures and consistent service levels across public and private bus and ferry transport operators.

I therefore request under section 13(l)(c) of the Act that, when making its investigations into passenger transport fares for all public transport modes, the Tribunal consider the following matters that arise from the Inquiry's recommendations:

• the making of a determination based on a five-year price path; providing that fare increases up to the Consumer Price Index (CPI) should be subject to efficiency gains; and
• providing for fare increases above the CPI to clearly demonstrate customer benefits through improvements in service quality linked to specific initiatives such as bus priority measures.

In respect of the Tribunal's section 9 investigations of privately owned public transport fares, I would ask that you also have regard to the above matters.

Bus Services:

In order to progress with a consistent fare structure for the bus industry and to implement reforms arising from the Unsworth Review of Bus Services, several changes to the existing arrangements, including legislation and the role of IPART, are being considered by the Government. The proposed legislative amendments will not commence in the first half of 2004.

When calling for public and industry submissions I request, pursuant to section 13(l)(c) of the Act, that IPART consider the Government's preferred approach of moving to a single fare review, including moving to a single fare change applicable to all bus operators.

I also request that IPART consider whether any State Transit fare increase for 2004-05 and later years should be applied on a "weighted average" basis aimed at better aligning Government and private operator fares. Such an approach would result in IPART determining an overall price change for bus fares. Individual fare products may be adjusted to varying degrees but the changes must, in aggregate, be less than or equal to the overall adjustment determined by IPART.

For non-commercial bus services, the Government is developing a new funding approach along the lines recommended by the Unsworth Review of Bus Services (see p.70 of the Final Report), but this may not be completed for 2004-05.

Therefore it may be appropriate that the process used for the 2003-04 review be used in 2004-05.

Ferry Services:

In respect of ferry services, under section 13(l)(c) of the Act, I also request that IPART consider adopting the same process outlined above (i.e. single fare increase figure for both private and public operators). As there are no relevant legislative changes planned in relation to ferries, I request that in all other respects IPART consider following existing processes for 2004-2005.

I have no objection to the contents of this letter being made publicly available, if you consider it appropriate.

If your officers wish to discuss these matters, they should contact Ms Zoe de Saram, Policy Manager, Economic Development Branch, at The Cabinet Office on (02) 9228 4930.

Yours sincerely,




Premier

ADVERTISEMENT FOR REVIEWS

The Tribunal is conducting a fare review for government bus and ferry services (ref: 03/327) and a concurrent fare review for private bus and ferry services (ref: 03/276).

The tribunal has requested submissions from State Transit Authority, Sydney Ferries Corporation, Bus and Coach Association and Charter Vessel Association by 23 July 2004. These will be available on the Tribunals's web site (http://www.ipart.nsw.gov.au) from 26 July 2004.

The Tribunal invites submissions from other stakeholders and interested parties. To allow full consideration of the pricing proposals and information submitted by the transport agencies, submissions from other stakeholders to both reviews will be required by 20 August 2004.

Submissions should be sent to the address below or in electronic format to ipart@ipart.nsw.gov.au clearly marked to refer to the review of government or private services.

A public hearing will be held on Friday, 3 September 2004 at the Tribunal's offices, with the Tribunal's report released in time for implementation by 31 October 2004.

Questions or enquiries regarding the Tribunal's reviews should be directed to Dr Dennis Mahoney, Program Manager Transport, on 02 9290 8494.

James P. Cox, Acting Chairman, 10 June 2004
IPART
Level 2, 44 Market Street, Sydney NSW 2000

PO Box Q290
QVB Post Office, NSW 1230

Section 15 of the Pricing and Regulatory Tribunal Act requires the Tribunal to have regard to twelve factors in making its determinations and recommendations. No guidance is given to the Tribunal in the Legislation concerning the relative importance of these various factors. The factors can be grouped as follows:

• Consumer protection
• prices, pricing policies and standards of service
• general price inflation
• social impact of decisions
• Economic efficiency
• greater efficiency in the supply of services
• effect of exercise of functions by some other body
• Financial stability
• rate of return on public sector assets
• impact of borrowing, capital and dividend requirements
• Environmental and other standards
• protection of environment by appropriate pricing policies
• considerations of demand management
• standards of quality, reliability and safety