Action for Public Transport (NSW)

Dear Mr Cox,

Introduction

As the issues facing the private ferry operators differ in many respects from those facing Sydney Ferries Corporation (SFC), we have made a separate response to the CVA submission.

Executive Summary

• We commend the CVA for being the only agency to make its submission to either the bus or the ferry review on time.
• While the amount of the proposed fare increase (2.99%) is acceptable, the evidence to support it is weak.
• The data provided by CVA in support of its claim for a fare increase is extremely limited in scope and we would ask that IPART not make any determination on the basis of this data alone. Full details of additional information required are given below, but basic data missing includes any mention of revenue, patronage statistics, separation of charter and passenger work, changes in services and legislative compliance.
• Some of these absences were noted by IPART in its determination following the 2004 fares review.
• A study should be conducted to see if there would be operational efficiencies, administrative improvements and benefits for customers if all the passenger services on Sydney Harbour and the Parramatta River were amalgamated.

Problems of Private Passenger Ferry Operators

CVA members face a number of problems:

• complying with the new Commercial Vessels Act
• rising fuel costs
• the age of the vessels
• the style of service lacks a contemporary edge
• expensive modern technology is slipping out of their reach.
• lack of ability to invest to take up opportunities.
• administrative support is required to offer a more sophisticated ticketing system.

To update their fleets and pay higher fuel costs will be a big challenge for some CVA members.

List of Members

A list of CVA members and a brief description of their activities would have been useful.

Services Provided

A summary of current services should have been provided, as well as changes over the past twelve months and details of any proposed changes.

Scheduled vs Tourist Services

It would be useful to know the mix of commuter and tourist passengers on scheduled services. The proportion of income derived from scheduled services and charter/cruise work should have been provided.

Fares and Tickets

A table of current fares charged on all services should have been provided. Details should also have been given of any discount or multi-ride tickets. There should be some discussion of standardisation of fares with Sydney Ferries, similar to the standard bus fares now applying across Sydney. Are CVA members ready to accept Tcard when it is introduced?

Patronage

Some patronage statistics would have been useful to show the importance of the work that private ferries perform. There was no mention of whether patronage is rising or falling. What will be the effects on patronage of a fare rise?

Vessels

It would have been useful to know details of measures taken or required to comply with the new Commercial Vessels Act. Full compliance will be expensive. What is the cost of these measures, and how will they be financed? Details of any planned vessel purchases should have been given. Calculations should have been provided for the average age of the vessels, and the maximum age.

Crews

Evidence should have been provided of ongoing staff training. The CVA submission mentions possible increased crew numbers being proposed by NSW Maritime. Some analysis should have been provided of the effects of this change.

Costs

Details of any variations in insurance premiums should have been shown. There is no evidence of any attempts at economy in costs. While evidence has been provided for an increase in unit costs, there is no evidence of any changes in relative costs per kilometre, per hour, per employee, per dollar revenue or indeed, if any such metrics exist. The submission mentions says that labour, fuel, insurance and interest comprise 65% of the costs, and that the other 35% will be increased at the same rate as these four. The other 35% comprises repairs and maintenance, depreciation, licensing fees, berthing and mooring fees advertising, motor vehicle expenses and other, which is 9.2%. This does not seem to us to be a satisfactory method of calculating or estimating cost increases, if in fact there are any increases in these areas. There is no mention of how costs have changed since last year.

Income and Revenue

The submission does not mention either of these words. Is revenue wholly linked to fare rises, or is there some attempt to increase patronage?

Customer Service

Detail of CVA members' commitment to a high level of customer service should have been given.

Amalgamation of Passenger Ferry Services

Scheduled passenger services on Sydney Harbour and the Parramatta River are now provided by only two operators - Sydney Ferries Corporation and Matilda Cruises. Note that this refers only to scheduled services, and not to charter and cruise operations.

There may be operational efficiencies, administrative benefits and improvements for customers if these services were amalgamated. This need not necessarily mean a take-over of one by the other (or of both by a third). It could be achieved by some sort of contracting arrangement as has been arranged by the Ministry of Transport for bus operations. Years ago, a couple of peak hour runs to Darling Street by the government ferry operator were in fact provided by a private ferry under contract.

We recommend that a study be undertaken to examine this proposal.

Please contact me on 9248-1235 if you have any further queries.

Yours faithfully,
Graeme Taylor
Assistant Secretary
Action for Public Transport (NSW)