Action for Public Transport (NSW)

PO Box K606

Haymarket NSW 1240

http://www.aptnsw.org.au

22nd July 2007

James P. Cox
Chief Executive Officer
Independent Pricing and Regulatory Tribunal of New South Wales
Level 2, 44 Market St, Sydney NSW 2000
PO Box Q290, QVB Post Office NSW 1230
transport@ipart.nsw.gov.au

Dear Mr Cox,

Determination of CityRail and TravelPass Fares

Herewith is the submission from Action for Public Transport (APT) to your review of the fares proposed to be charged by CityRail from later this year.

But first, we have some concerns about the way the review has been started. It appears that the process was initiated by CityRail, and not by IPART. We also feel as if we have been side-lined. The first that APT heard of a review was when the reporters started ringing us on Saturday 23rd June. Normally, advertisements are placed in the newspapers first. The first advertisement we saw was on 6th July.

A. Executive Summary

  1. Action for Public Transport would rather spend its time discussing a new Fares Policy for all public transport in Sydney, instead of tinkering with a train fare system that remains basically unchanged since the first train ran in 1855.
  2. However, since we are duty-bound to respond, we reject all the proposed increases on the basis of lack of justification on CityRail s part, and likely hardship on the passengers' part.
  3. CityRail's submission is largely a "smoke and mirrors" job, quoting irrelevant or misleading figures, omitting other more relevant facts and figures, and glossing over the inadequacies of the current service.
  4. CityRail's claim that a fare increase is justified because of future improvements is, to be polite, ingenuous, and to be truthful, absurd.
  5. The Minister said that "not all taxpayers necessarily access the service". Fare payers and tax payers are not two mutually exclusive groups. All tax payers in New South Wales benefit from a subsidised metropolitan rail system.
  6. CityRail's statement that incomes have risen is irrelevant, especially in Sydney, where each day's newspaper brings reports of increases in food and energy costs, school fees, mortgage repayments, state taxes, council rates and stories of the hardships and even bankruptcies suffered by low income families in Sydney s outer suburbs.
  7. CityRail's statement that costs have risen may be correct, but CityRail needs to prove that it has been diligent in trying to contain costs.
  8. The proposal to increase fares by fixed amounts rather than by a percentage is legitimate, but it seems to have been done to avoid the embarrassment that the Ministry of Transport suffered when they tried to double-dip on roundings from the master fare scale for bus fares.
  9. The proposal to increase fares by fixed amounts rather than by a percentage unfairly penalises those shorter distance travellers with the cheapest tickets. A $2 increase on a Purple TravelPass ($55) is an increase of 3.6%, while a $2 increase on a Red TravelPass ($33) is 6.0% - nearly twice as much. There is a similar effect with the short and long distance single fares.
  10. The proposal to increase the price of the DayTripper ticket to $16.00 is fine if it is seen as a tourist ticket. However, as a general purpose all-day ticket for local residents it is far too expensive.
  11. The access fees (Gate Pass) at Green Square and Mascot stations should be scrapped to harmonise fares with those to other stations.
  12. CityRail's costs are higher than necessary because of its ultra-conservative reaction to safety issues.
  13. The review process may be flawed without the additional information that IPART requested CityRail to provide following last year s review.
  14. Any change in CityRail fares should be deferred until the results of the 2008 review of CityRail's regulatory framework are known.

B. Recent Reviews

The NSW Premier excluded CityRail from IPART fare reviews in late 2004 and late 2005. It was not thought appropriate to seek a fare increase while the service provided by CityRail was below standard. Those two reviews dealt only with bus and ferry fares.

A review of rail fares last year resulted in average increases of 2.9% in peak hour and single fares from July 2006. Off-peak return fares were increased by 25%. The price of TravelPass tickets with no rail content was not increased.

The end-of-year review of bus and ferry fares resulted in price increases from January 2007. The price of TravelPass tickets without rail content was increased, but those with rail content stayed the same.

C. A New Fares Policy

The pay-by-distance fares policy, used by nearly all of Sydney's public transport, dates back 152 years to the days of the first train.

We will never have a world class public transport system while the bureaucrats persist with an archaic distance-based fare schedule. Section fares might have suited late nineteenth century Sydney, when most travel was on the tram and train lines radiating from the city. One hundred and twenty years on, people s travel patterns are different. They go in all directions, and a zone fare system is essential to match the demand. Using the bus or train to get about should be as easy as using a car.

Sydney is the last city in Australia to wake up to the changing needs of passengers. Other cities have zone or time fares.

Sydney people have enjoyed a taste of zone fares in the form of the weekly all-modes TravelPass ticket for many years now. However, these tickets, though efficient and popular, have severe limitations. Firstly, they cannot be used on any of the private bus or ferry services. The passenger should not have to know who owns the bus - the one ticket should be valid on all of them. Secondly, TravelPass tickets are only sold as weeklies, quarterlies or yearlies. There is no daily one, except for the over-priced one-size-doesn't-fit-all DayTripper. Only the Pensioner Excursion Ticket (PET) is a true all-modes, all-owners, all-routes all-day ticket (but even this is not accepted on the boutique systems). For the full fare paying passenger, any more than a simple return trip between A and B requires a complicated series of tickets. Ordinary rail-only tickets allow no flexibility in travel patterns. For instance, a weekly train ticket from Stanmore to Hurstville does not allow the holder to go closer to the CBD than Redfern. A single or return train ticket between Chatswood and Wynyard does not allow the holder to break the journey at North Sydney. The zone or time tickets used in other cities allow a person to make these variable trips by public transport as easily as in their own car.

A complete overhaul of Sydney'public transport revenue policy is long overdue. Instead of charging passengers for distance travelled, a new policy is required which charges all the beneficiaries of transit use, that is, all city users. The policy needs to recognise the contributions that transit users make in solving Sydney's major challenges - peak oil, global warming, environmental issues and traffic congestion - and reward them for it.

APT hopes that IPART will champion radical changes in the fare policy during the broader review to be conducted next year. The Tribunal's letter to stakeholders dated 25th June 2007 says that this broader review will consider "the need for greater efficiency and reliability in the supply of services so as to reduce costs and improve quality, safety and reliability for the benefit of consumers and taxpayers". A change from a mono-mode distance-based system to a multi-mode zone based fare system would fill the bill on every one of these requirements, with the possible exception of safety.

D. Flimsy Promises

CityRail wants a fare increase to help pay for future improvements. We've heard that one before.

Many of these future improvements appear only on paper at election or budget time. The tangible end-product is often brutally docked, like the Chatswood to Parramatta railway, or continues to recede further into the future with each passing year. The Sydney Morning Herald on 22nd July 2007 detailed the sorry history of abandoned railway schemes in Sydney over nearly one hundred years.

More money is obviously needed to pay for extensive and long overdue infrastructure projects, but the government needs to find other ways of financing them than continually gouging commuters. The government cannot make up for years of starvation and theft by squeezing 20 cents out of a part-time worker's purse.

Consumers will pay C.O.D., Cash On Delivery, not P.O.P., Pay on Promise.

E. CityRail's Service Improvements

CityRail wants a fare increase because, it says, services have improved.

Beauty is in the eye of the beholder.

Immediately after the election on 24th March, it was reported that "The Premier, Morris Iemma, has made improving public transport his top priority in Labour's fourth term, pledging yesterday to change the culture within RailCorp to ensure it delivers better service for customers." (SMH 27th March 2007.) This is hardly a proud endorsement of the current status.

Regular users know both the planned and unplanned shortcomings of the rail system - sluggish trains, late running, miserly weekend services, crammed carriages, ticket selling queues, mechanical failures, communications breakdowns, etc. These have all been comprehensively documented in the media over recent weeks and months. The KPI numbers reported in the CityRail submission seem to bear little relation to passengers' daily experiences.

We understand that on-time running is monitored only at Central, only in peak hours and only for the peak direction. Passengers using trains outside of these areas could tell other stories about on-time running. CityRail must implement procedures to monitor all train services, even if only on a sample basis. This was recommended by IPART in its report of the 2006 review determination.

A fare rise cannot be justified on the grounds of service improvements.

F. Consumers have never had it so good!

When the fare rise proposal was announced, the Minister said on television something to the effect that consumers had had a pay rise and could afford higher fares. But that does not reflect reality.

Increases in food and petrol costs, mortgage repayments, state taxes, council rates and the hardships being met by low income families in Sydney s outer suburbs have made almost daily reading in the newspapers in June and July. See the headlines quoted in the Appendix.

A fare rise would cause hardship to many people.

G. Long Term CPI Increase

According to a table in CityRail's submission (page 18), the CPI has outstripped rail fares by about 6% since 2000 (or by 12% since 2003).

According to a table in IPART's 2006 Annual Report, train passengers now pay on average 19% more in real terms than they did in 1992/93. That is, rail fares have out-run the CPI by 19 percent.

CityRail has already had its cake.

H. Fixed Amount Increase

CityRail's proposed increases in single and weekly fares are shown in the following table. The fixed amount increases avoid the problem of rounding master fares up or down that comes with percentage increases, but the master scale still exists. However, the broad-brush increase brings a new problem. The tickets in the lower end of each band would suffer price increases of 8 10%, while those at the upper end would increase by only about 5%.
Distance Up to (km)* Adult Single 2006 Adult Single 2007 Increase Amount Increase Percent Weekly 2006 Weekly 2007 Increase Amount Increase Percent
5 2.40 2.60 0.20 8.3 19.00 21.00 2.00 10.5
10 2.80 3.00 0.20 7.1 23.00 25.00 2.00 8.7
15 3.20 3.40 0.20 6.3 26.00 28.00 2.00 7.7
20 3.60 3.80 0.20 5.6 29.00 31.00 2.00 6.9
30 4.00 4.20 0.20 5.0 32.00 34.00 2.00 6.3
35 4.40 4.60 0.20 4.5 34.00 36.00 2.00 5.9
40 4.40 4.80 0.40 9.1 35.00 37.00 2.00 5.7
45 5.20 5.60 0.40 7.7 38.00 40.00 2.l0 5.3
55 6.20 6.60 0.40 6.5 41.00 43.00 2.00 4.9
65 6.80 7.20 0.40 5.9 45.00 48.00 3.00 6.7
75 8.20 8.60 0.40 4.9 48.00 51.00 3.00 6.3
85 9.00 9.60 0.60 6.7 51.00 54.00 3.30 5.9
95 10.00 10.60 0.60 6.0 53.00 56.00 3.00 5.7
105 10.40 11.00 0.60 5.8 55.00 58.00 3.00 5.5
115 11.60 12.20 0.60 5.1 57.00 60.00 3.00 5.3
135 13.20 13.80 0.60 4.5 66.00 69.00 3.00 4.5
175 17.40 18.00 0.60 3.4 76.00 79.00 3.00 3.9
215 21.00 22.00 1.00 4.9 83.00 86.00 3.00 3.6
305 29.00 30.00 1.00 3.4 110.00 113.00 3.00 2.7
* These are not distances from Central, but distances from origin to destination station.

These new ticket prices must not be allowed to become the new master fares by default. The new master fare will be the current master fare plus 20 cents or 40 cents or whatever. For instance, the current master fare for 10 15 km is $3.09, which was rounded up to a ticket price of $3.20 in 2006. The proposed 20 c increase would make the ticket price $3.40 and the master fare would be $3.29. IPART must ensure that these master fares are not conveniently swept out with the rubbish. Weekly tickets, too, have master scales. See section 5.3 of IPART's 2006 determination.

I. TravelPass

CityRail's proposed increases in TravelPass prices are shown in the following table.
INCLUDING RAIL Current Price Proposed Price Increase Amount Increase Percent
Red> 33.00 35.00 2.00 6.0%
Green 41.00 43.00 2.00 4.9%
Yellow 45.00 47.00 2.00 4.4%
Pink 48.00 50.00 2.00 4.2%
Purple 55.00 57.00 2.00 3.5%
NOT INCLUDING RAIL * Current Price Proposed Price * Increase Amount * Increase Percent *
Blue 31.00 31.00 0.00 0.00
Orange 38.00 38.00 0.00 0.00
Pittwater 53.00 53.00 0.00 0.00
2 Zone 31.00 31.00 0.00 0.00
* The price of these tickets was increased following the Bus and Ferry Fare Review in January 2007, and there is no proposal to increase them now.

Again we see that the proposed indiscriminate fixed amount increase will cause discriminatory percentage increases of between 3.5% and 6.0%.

These multi-mode TravelPass tickets are a type of zone ticket, and for that reason, they are very popular. Instead of escalating the prices, CityRail should be encouraging use of the tickets by at least maintaining the current price.

A greater take-up of TravelPass tickets would also benefit Sydney Buses in its campaign to promote pre-paid tickets. CityRail management should think of the trains as part of an overall city transport system rather than as an isolated entity.

Recent practice has been to change the price of TravelPass tickets that have rail content at a different time from those without rail content. This is absurd. It's like a rainbow lottery sometimes your colour wins, sometimes it loses. If Sydney had any semblance of an integrated transport system, all fares changes would happen at the same time.

J. DayTripper Ticket

CityRail proposes to increase the price of DayTripper from $15.40 to $16.00 (4%). The DayTripper ticket allows travel on trains, STA buses and SFC ferries over most of the Sydney metropolitan area. It does not allow travel on the many privately owned buses or ferries.

As a ticket for a leisure "day out", it is good value, and is very simple and convenient for people who do not regularly use public transport. For example, a return off-peak train trip from Parramatta to Circular Quay costs $6.20 and a return ferry trip to Manly costs $12.80, a total of $19.00. And, of course, more bus, train or ferry trips can be taken on the same day using the same ticket.

However, as a general purpose ticket for someone wanting to do a number of tasks around the city or suburbs, such as shopping, medical, banking, etc, it is far too expensive. The ticket price covers the high cost of possible ferry travel, but not everybody needs to use a ferry on an ordinary day out.

The price should be reduced to something like $10 or $12. And if this is less than the cost of a return ferry to Manly or train from Penrith, so what! People who make these trips regularly would use some form of discounted ticket, and would not buy a DayTripper. A cheaper ticket would not cause the system to be overrun by hordes of liberated battlers waving DayTripper tickets.

K. Access Fees on Airport Line Stations

While the rail fares to the four privately-owned stations on the Airport Line are the same as the fares to any other station at an equivalent distance, the actual ticket price to the passenger is grossly inflated by the "station access fee" or Gate Pass.

The amount of the fee was once shown on either or both of the Airport Line web site or the CityRail web site. However, the scale of access fees has been removed or hidden, and the amount can only be found by calculating the difference between two fares.

For instance, the fares from Central to Tempe (6.84 km) are $2.80 single and $23.00 weekly. The fares from Central to Domestic (6.7 km) are $12.20 single and $36.50 weekly. The Gate Pass fees for Domestic are therefore $9.40 single and $13.50 weekly.

A scale of Gate Pass fees was obtained by personal enquiry at a station, but there is none in written form. Such a table would be useful for people who hold an ordinary rail ticket entitling them to travel through the four private stations, and who wish on the odd occasion to pass through the turnstiles at one of them. They would know how much extra they would have to pay. Such people could be holders of a periodical rail ticket, a TravelPass, a Pensioner Excursion Ticket or a DayTripper.

A sample scale of Gate Pass fees is:
Stations Single * Concession Single * Day Return (any time) * Weekly *
Green Square and Mascot 2.00 1.00 3.30 13.50
Domestic and International 9.40 7.20 12.90 13.50
* Note that these prices are not the cost of the tickets. They are the fees added to the ordinary rail fare.

The weekly Gate Pass fee for the two airport stations is kept low to be affordable for airport workers. The high single and return fee catches mainly travellers and visitors. The two non-airport stations, Green Square and Mascot, are used overwhelmingly by local residents and local workers.

We recommend that, to harmonise fares between these stations and all other non-airport stations, the Government itself should pay the access fee to the station owners. The government has done something similar to harmonise bus fares between privately-owned and government-owned buses.

L. Restoration of Next-Day Return Ticket

Some years ago, CityRail removed the "next day" availability of the return portion of a return rail ticket. We urge IPART and CityRail to consider restoring this benefit.

A single ticket between Central and Newcastle costs $17.40. An off-peak return costs $24.00. A person from one city wishing to spend a reasonable time in the other would have to stay overnight and have to pay two single fares, a total of $34.80. If the return portion of an off-peak return ticket could be used on the second day, it would only cost $24.00. Presumably, CityRail would consider that it had "lost" $10.80 on the deal. However, CityRail could, in fact, be $24.00 in front, because the traveller might make a trip over two days that he would not have made at all as a one-day trip.

M. The Part-Time Worker

An increasingly large number of people are now working less than a five-day week, and the current options for rail tickets are often unsuitable. For occasional train travellers, the single or return ticket is the most useful, if the most expensive. For full-time workers, a discounted weekly RailPass or multi-mode TravelPass is usually the best option. However, people who work only three or four days a week usually have to buy a return ticket every day. This is relatively expensive, and also time-wasting, both for the traveller and for the ticket clerk.

Bus and ferry passengers can use the discounted TravelPass tickets for a full week's travel, but they also have the benefit of the TravelTen and FerryTen tickets. These provide discounted rides even for part time workers who don t travel every day, and are valid until all ten trips are used. Rail passengers have no such ticket. CityRail should investigate how part-time workers can be catered for.

And before anyone says "Tcard" is the answer, it isn't. A stored value card would still charge the same expensive one-day fare.

N. Tcard

This is just a reminder that the Tcard, a stored-value smart card for use on all public transport and at other places as well, is still years behind schedule. Its imminent introduction has, in the past, often been used as a reason not to tamper with the core of the existing fares and ticketing system. However, that excuse has worn thin, and we can no longer wait for its "imminent" start before commencing reforms of the fare system.

The Tcard is only a method of collecting fares. It will not change the fares. The person who catches a bus to the station, then a train, or the person who catches a ferry to Circular Quay and then a bus uptown, will still have to pay two separate fares, with two separate flagfalls.

O. Higher Costs from Ultra-Conservative Attitude to Safety

CityRail says that cost increases justify a fare rise. Some costs have increased as a result of CityRail's own decision to run trains to a slower timetable.

Those costs can in turn be attributed to what we see as the Rail Safety Regulator's zero-tolerance or draconian policies, which have forced CityRail to eliminate risks for events which might happen only once every 500 years.

The Rail Regulator's risk management philosophy is far too conservative. This manifests itself in rail employees also being too conservative. For example, train drivers creeping into stations in order not to run past the end of the platform, in fear of heavy penalties, and track engineers not raising the speed limits for upgraded lines in fear of being blamed for incidents which MIGHT occur years into the future.

There is anecdotal evidence, especially on the Internet, that over-reactive directions from the Rail Safety Regulator and self-preservation safe-working policies in RailCorp have produced a railway which is excessively slow. This is based on the fallacious argument that a railway needs to be slow to be safe. Other comparable railways run at higher speeds with greater safety. In due course, we believe RailCorp will do also. It will require a change in focus at the political or management level. Until then, CityRail users should not be penalised with higher fares to pay for questionable management decisions.

And with apologies to Isaac Asimov - safety is the last refuge of the incompetent.

P. References to 2006 IPART Determination

In its determination following the June 2006 review of CityRail fares, IPART requested CityRail to undertake a number of tasks before the next review. These requests are detailed mainly in Part 7 (page 41-42) of IPART's determination, but there are other references elsewhere.

There is little evidence in CityRail's submission to the 2007 review that all or any of these tasks have been done. The Tribunal should ensure that CityRail provides this information. There is no point in agreeing on something at a review, then not following it through.

Some items requested by IPART in June 2006 were:

Q. Review of Regulatory Framework for CityRail Fares

The Minister and IPART have announced that a review will be conducted in 2008 to determine a new regulatory regime for CityRail fares. APT is not quite sure what this means. The Minister has asked the Tribunal to recommend a regulatory framework that will provide CityRail with incentives to provide efficient passenger rail services.

It is astounding to learn that CityRail needs "incentives" to do a job that has been its reason for existence for the past 150 years. We are also concerned that the review is confined to rail fares, and there will be no attempt to move towards a single type of fare for all public transport.

The Minister said: "In conducting this review, the Tribunal is to consider the matters listed under Section 13 of the Act, in particular the need for greater efficiency and reliability in the supply of services so as to reduce costs and improve quality, safety and reliability for the benefit of consumers and taxpayers." There is no mention of increasing patronage, although one would hope that improvements in quality, safety and reliability would result in increased patronage.

R. Conclusion

We will be happy to participate in the Public Hearing proposed to be held later this year.

If you have any queries please contact me by email at allanmiles@hotmail.com or by telephone on 9516-1906.

Yours faithfully,





Allan Miles
Secretary
Action for Public Transport (NSW)



APPENDIX - MEDIA REFERENCES

The following are some recent newspaper headlines on articles about CityRail's services and about the users' ability to pay increased fares. Even allowing for some editorial hyperbole, the articles cast some doubt on the statements that CityRail has made in its submission. The original clippings are available if required.

DT = Daily Telegraph, ST = Sunday Telegraph, SMH = Sydney Morning Herald, S-H = Sun-Herald

CITYRAIL SERVICE QUALITY

"Plan the weekend on buses: 19,320 train disruptions on way". Mx 14/03/07

"4000 stuck on the train trip from hell". DT 15/03/07

"Transport meltdown: 4000 trapped for three hours". SMH 15/03/07

"Night of chaos and garbled messages". SMH 16/03/07

"There's no excuse for rail chaos: former boss". SMH 16/03/07

"Yet another grinding halt". SMH 16/03/07

"Brought to a stop by one broken part: Shoddy CityRail planning exposed". DT 16/03/07

"Lucky delayed trains a stuff-up, not disaster". DT 16/03/07

"Late-running Tcard branded too complex". SMH 20/03/07

"World's worst trains: the secret report CityRail didn't want you to see". DT 21/03/07

"Tripping over the rail line: Reports trash reliability, safety". Mx 21/03/07

"Riding CityRail can be a heath hazard". DT 22/03/07

"Iemma promises transport overhaul". SMH 27/03/07

"Iemma to make rail chief pay the price". DT 27/03/07

"Power to the passengers: CityRail managers docked for complaints". DT 17/04/07

"CityRail's peak crisis; curse of missing Oscars". DT 17/04/07

"Lack of staff derails stations - union". SMH 22/05/07

"Delays score 7 out of 9: and storms set to hit trains again". Mx 19/06/07

"Thousands stranded on city's rail again". DT 19/06/07

"Ten minute wait in line just to buy a train ticket". SMH 25/06/07

"CityRail commuters are the butt of a sick joke". DT 06/0/07

"Another oh-no moment as trains suffer wind once more". SMH 06/07/07

"CITY FAIL: Stranded again by woeful train debacle". DT 06/07/07

"Trains: the answer is not blowin' in the wind". SMH 07/07/07

"Rail misery for 10 more years. Tunnel is only hope: Watkins". DT 07/07/07

"It's a Train Wreck: The Premier said never again but the rail culture is still a mess". SMH 12/07/07

"Windy excuses are blown away". DT 12/07/07

"Not the wind, just hot air". SMH 13/07/07

"RailCorp failed to resolve safety issue - union". SMH 13/07/07

"CityRail solution: Fix it or resign". DT 13/07/07

"No idea at all: how CityFail let you down". DT 13/07/07

"Rail Disgrace: Stranded wheelchair commuter told: We'll get back to you in a few days". DT 14/07/07

"Rail system is off track again". S-H 15/07/07

"Get back on track: Iemma's ultimatum to deputy and unions to fix trains". DT 16/07/07

"Breaking Point: train chaos on harbour bridge again". Mx 17/07/07

"Ghost trains: rail network that never was". SMH 21/07/07

"Waiting for phantom trains at ghostly stations". SMH 21/07/07

CUSTOMER'S CAPACITY TO PAY

"The big squeeze: Soaring housing costs are squeezing family budgets". SMH 28/06/07

"Surge in families forced to sell their homes". SMH 30/06/07

"Fees eat your tax cut: State pushes up price of 700 services, charges". DT 02/07/07

"Home price debt crisis". SMH 03/07/07

"Councils win approval to lift rates". DT 04/07/07

"Battlers' pay rise outpaced by inflation". SMH 06/07/07

"Mortgage belts tighten as prices keep climbing". SMH 11/07/07

"Mortgage stress to hit home at election". SMH 12/07/07

"Milk breaks $2 barrier: Wholesale price rise passed on to shoppers". DT 13/07/07

"Bankruptcy soars as city feasts on easy credit". SMH 14/07/07

"Power bills may triple amid price-gouging claims". ST 22/07/07