Action for Public Transport (NSW)

http://www.aptnsw.org.au/

P.O. Box K606,

Haymarket NSW 1240

actionforpublictransport@hotmail.com

20th September 2013

Mr James Cox
CEO, Independent Pricing and Regulatory Tribunal of NSW
Level 8, 1 Market Street
SYDNEY NSW 2000
PO Box Q290
QVB POST OFFICE NSW 1230
Telephone: 9290-8400
Fax: 9290-2061
ipart@ipart.nsw.gov.au

Dear Mr Cox,
Review of Stockton and Private Ferry Fares for 2014

Introduction

This initial submission from Action for Public Transport provides general commentary on IPART’s Review of Stockton and Private Ferry fares for 2014. In summary, we ask IPART to rethink its approach to private ferries.

The Need for Price Regulation of Private Ferries

IPART’s discussion paper notes the small scale of the private ferry industry, and questions the need for price regulation. Action for Public Transport believes that price regulation is about protecting consumers and should apply to all public transport services. Further, we also believe that fare structures across all modes of public and private transport in Sydney should be integrated to provide a simple and seamless transport network.

Financial Viability of Private Ferry Operators

Action for Public Transport has expressed concern in recent years about the continuing viability of the private ferry industry. While we are yet to see a submission from the Charter Vessel Association, we suspect there has been little improvement. We believe that the industry requires restructuring, and that operators should be paid a set fee for each service operated with all passenger revenue going directly to Transport for New South Wales. We also believe that existing subsidies paid to the industry should be publicly disclosed.

Ticketing

As we have suggested in previous years, there is a need to extend multi-modal ticketing offered on government public transport services and private buses to the private ferry industry. This includes the new Opal smartcard electronic ticketing system. Private ferries need to be part of this revolution, and if they are not included the downward trend in industry performance will continue.

Fares for 2014

We will await a submission from the private ferry industry before making comment on whether an increase in fares is justified.

Conclusion

The private ferry industry in New South Wales has been in decline for some years now. IPART should recognise the seriousness of this situation and support a wide ranging industry restructure.

Yours faithfully,

Graeme Taylor
Convenor
Action for Public Transport
Email: graeme.taylor5@bigpond.com