Action for Public Transport (NSW)

P.O. Box K 606, Haymarket NSW 1240

www.aptnsw.org.au

8th October 2003

Dr Thomas Parry

Ministerial Inquiry into Public Passenger Transport

C/- Transport Co-ordination Authority

GPO Box 1620

Sydney NSW 2001

inquiry@transport.nsw.gov.au

9268 2825

 

 

Dear Dr Parry,

Ministerial Inquiry into Public Passenger Transport

Response to Interim Report

 

Thank you for this opportunity to comment on the Interim Report entitled "Ministerial inquiry into sustainable transport in New South Wales – Options for the future."

Our response is attached, as well as a copy on disk.

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

Yours faithfully

 

 

 

 

 

 

Allan Miles

Secretary

Action for Public Transport (NSW)

SUBMISSION BY ACTION FOR PUBLIC TRANSPORT – OCTOBER 2003

TABLE OF CONTENTS

INTRODUCTION AND SUMMARY

Introduction

Summary of This Submission

Format of This Submission

What is Action for Public Transport?

RESPONSES TO THE REPORT CHAPTERS

  1. Overview and Introduction
  2. Overview of public transport in New South Wales
  3. Challenges in delivering better services in the Greater Sydney Area
  4. Revenue needs for the government-operated public transport network
  5. Funding options
  6. Fair Fares: equity and efficiency
  7. Service quality regulation, incentives and fares
  8. Charging for road use
  9. Decision criteria for choosing transport projects
  10. Concessions and community transport
  11. Report Appendixes

 

OTHER COMMENTS

What’s Next?

ATTACHMENTS

ATTACHMENT A – List of "discount" mentions

ATTACHMENT B – All The Old Lines

 

 

INTRODUCTION AND SUMMARY

Introduction

This submission is in response to the issue in August 2003 of the Interim Report of the Parry Inquiry – the ministerial inquiry into sustainable transport in New South Wales. The report is entitled "Options for the Future". The closing date for responses was 10th October 2003.

This report can be seen at

http://www.transport.nsw.gov.au/ministerial-inquiry/parry-interim-report.pdf

Action for Public Transport is firmly of the view that the biggest problems of access to services and sustainable transport for the people of Sydney lie outside the terms of reference of this Inquiry.


Failed government planning policies, not funding, are the more serious threats to Sydney's transport system. Over at least the last two decades, government decisions have favoured enhancements of the roads network rather than public transport improvements. This has happened in spite of political rhetoric promising an increased proportion of government spending on public transport (1), academic research recommending a swing toward public transport investment (2), and even recurring public polling which has indicated increasing voter support for a switch to public transport funding instead of roads (3).


Sydney's population is expected to expand by one million people in the next 20 years (4). If the city is to retain its current world ranking then funding for not just the maintenance, but also the expansion of the public transport system, as well as roads, hospitals and schools, will simply have to be found. APT disagrees with the emphasis in the Interim Report recommending higher fares as a favoured source of this additional revenue. (See 6.1.4 – The Effect of Fares on Patronage, page 16 in this submission).


The Inquiry's findings may be useful for testing voter responses to various fundraising options and could help in planning election strategies, but they are no substitute for much better strategic planning of the Sydney region. The collapse of the present government's 1999 "Action for Transport 2010" transport plan within just four years of its publication, highlights the alarming failure of current strategic planning policies.


To quote the Director of the UWS Urban Studies Program in the Sydney Morning Herald of 16 Jan. 2003 - "Hubris, corruption and greed have left the nation's premier city in desperate need of a strategic plan for growth." "We have been well aware of our worsening car dependency (problems) for at least two decades, but are no nearer a solution. The road building lobby….has continued …..to prosecute its plans for the mass asphalting of the city for at least three decades. The road machine seems unstoppable, and unchallenged in its implicit claim to be the real planning agency for Sydney".

    (1) – Carr, R J, MP, NSW Opposition Leader, pre-election press release, 27 Feb. 1995

    (2) – Warren Centre, Sydney University, 2002, and Urban Frontiers Program, UWS, S M Herald, 16.Jan. 2003.

    (3) – Warren Centre, 2002, and NRMA / Nielsen, Nov.2002, reported in "Hub & Spoke" July 2003.

    (4) - Property Council, quoted in S M Herald, 12 Sept. 03.

Summary of This Submission

APT has no objection to the overall thrust and argument of the interim report, bearing in mind its limited focus mentioned above, and the fact that it is an Interim report, not making any firm recommendations. It is generally a valid presentation of the facts, the problems and the options.

We recognise the heavy weight of the project, and we commend the Minister for taking it onto his shoulders. We look forward to watching and perhaps helping the Minister take the first steps of what will be a long journey through difficult terrain. We trust that he has the strength and confidence to reach his goal.

Action for Public Transport is primarily a consumer advocacy group, looking after the interests of public transport users. We think we do that job reasonably well, but we do not claim to be experts in the funding and operation of large public transport systems. Our remarks therefore will tend to focus on what comes out at the delivery end of the process, rather than what goes in at the other end.

Some points of concern with the content of the Interim Report are:

  1. There are too many emotive words – taxpayer, loss, discounts, inequity, etc – and one-sided statements that seem to be trying to push a particular point of view, focussing the reader’s attention in one direction only. For instance, computer searches of the report shows about 20 instances where fares and tickets are referred to as discounted, but not one instance of them being referred to as pre-paid.
  2. Too much reliance is placed on STA and SRA calculation of discounts on periodical tickets. While we have no statistical data to refute these figures, common sense in many cases gives a hint that they may be incorrect, or at best, misleading.
  3. Although we understand that none of the options has been costed yet, we might have expected a rough estimate of implementation costs, running costs and projected revenue for each.
  4. In several places there are statements purporting to be fact, and unquestioned imperatives for the future, which are not soundly based on available evidence.
  5. Of all the 37 funding options, the easiest and most lucrative is to increase fares, and we fear that this will happen first without adequate consideration of all the others.
  6. The almost apologetic funding requests of CityRail and, to a lesser extent, State Transit, reveal very modest ambitions.

 

Format of This Submission

Our submission follows the chapter and paragraph headings of the Interim Report and responds to them in that order.

Under many of the sections we have made the note "No comments". This does not mean that we are not interested in the subject, but that we have no major objections, corrections or amplifications to make to the statements and proposals in the report. Yet.

 

 

What is Action for Public Transport?

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 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, and the unacceptable level of long-distance freight on our roads.

While APT nominally covers all public transport users, we tend to speak for the unorganised masses. The special interest users, (pensioners, other social security beneficiaries, school children, the disabled, inter-urban commuters, regional users, cyclists, etc) are better served by their own organisations. Our comments on these areas will therefore be limited.

 

RESPONSES TO THE REPORT CHAPTERS

Overview

The overview presents a generally accurate summary of the main problems with both the monetary and the operational aspects of the Sydney and New South Wales transport systems. The report is, however, frequently couched in emotional, exaggerated and biassed language. Exceptions are described so as to give the impression they are the general rule.

One example – "Some STA ferry services carry few passengers, are costly to operate and provide a service that can far more efficiently be met by alternative bus services." (page xiii). The import of the single word "some" at the beginning of the sentence is quickly lost in the gloom painted by the other 25 words in the sentence. The effect is to malign the whole ferry operation. Just how many ferry services carry few passengers? How few is "few"? How many are costly to operate? How costly are they? Does "cost" mean total expenses, or net "loss" after revenue? How many services can be more efficiently (let alone far more efficiently) met by bus services? Efficiently for whom – the passenger or the STA? What about all those additional buses on the road?

Another example – "a costly public ferry service that includes what is effectively a subsidised water taxi service for mainly middle to high income earners" (page xv). Words meant to offend. The report uses the word "includes", but doesn’t say what proportion of the ferry service is a subsidised water taxi for the rich. It is also "demonisation by postcode", as one writer to the newspaper put it.

This language is a classic example of Ross Gittins’ guide to spin doctoring detailed in the Sydney Morning Herald on 15th September 2003. Rule number one is "no matter how big and rich you are, find some poor people to hide behind". This is to be used when attacking government policy. The corollary, used by government, is to find some rich people to attack.

On page xi the report says, "What is clear is that the level of cost recovery needs to be increased." Such a proposition is by no means "clear". We presume that what is meant is "cost recovery from fares", but that still does not give any Euclidean proof of the statement. How is it "clear"? The cost recovery from fares for government buses and ferries is about 52 percent and for rail about 28 percent. Those figures are averages and there are better and worse cases within each mode. Which "needs to be increased" and which doesn’t?

On page xviii, under Fares and Ticketing, there is no mention of the need for or the ability of the smart card system to reduce the cost of multiple flag-falls when a passenger changes modes during a single journey.

On page xix, under Transport Levy, the report says, "Such levies would be difficult to justify without a corresponding reduction in fuel excise." APT would like the Inquiry to expand on the logic of this. In any case, the federal government has, under pressure from the motor lobby, already reduced fuel excise by 1.5 cents per litre, costing $4 billion over four years.

APT supports the suggestion on page xx that "the federal government should review taxation, expenditure, and other policies that are detrimental to the use of public transport." How does the Inquiry plan to advance this idea from locker-room strategy to success at the full time whistle?

Other specific comments appear in our detailed assessment of the report following. Opinions similar to our own have already been aired by others in newspaper articles and letters in the week following the release of the interim report, and there is no need to repeat them all here.

Summary of reform options

The summary in the report lists 37 options for reform. Many of them would take years of struggle through jungles of political, community, legislative, procedural, technical and operational obstructions before they could be implemented.

There is no evidence in the report that the set-up costs, the running costs and the revenue for any of the 37 options have even been guessed at.

Unfortunately for the public transport user, the quickest, least expensive and most lucrative option would be fare increases, which could be done with a signature and a quick computer program change tomorrow.

Public transport users will demand to see some preliminary cost and revenue figures for all the options, including a formula for sharing the pain, before we would accept large fare increases as the first (and perhaps only) point of attack. We don’t want to be like the first spaceship full of new settlers that was sent off to a new planet in the "Hitch-hikers Guide to the Galaxy" series. On arrival they waited for the other ships to come, only to realise too late that the authorities always intended to send just that one ship, and that they had been dudded.

 

1 Introduction

1.1 Terms of reference for this inquiry:

  1. The likely future needs of CityRail and STA Bus and Ferry operations, with regard to efficient operating and capital costs;
  2. Funding options to meet these revenue needs, as well as funding options for any future expansion of the public passenger transport system;
  3. Options for enhancing the optimum use of public passenger transport relative to other transport modes;
  4. Possible arrangements for incentive mechanisms which better link fares and service standards, including safety; and
  5. Options for better targeting the funding and delivery of transport services to meet the needs of different groups in the metropolitan and non-metropolitan communities, including rural community and health transport needs.

In APT’s first submission in June, we also listed the following nine "Terms of Omission", without which, we said, the Inquiry would be fundamentally flawed.

  1. Funding requirements and funding options for privately owned (but government licensed) public transport.
  2. The fundamental problem with the Roads and Traffic Authority (RTA) which plans, evaluates, approves and implements many of its own projects independently of other transport needs.
  3. Methods of evaluating transport projects to ensure that financial, social and environmental considerations are included for larger projects.
  4. Methods for prioritising transport proposals alongside road proposals so that those with the highest cost/benefit outcomes are funded first.
  5. The huge imbalance in funding between roads and public transport.
  6. The perception that public transport "runs at a loss" and needs to be fixed, whereas "roads" do not.
  7. A transport policy that is increasingly being driven by the infrastructure investment industry.
  8. The failures of the transport authorities to protect passenger interests in revenue-earning contracts, such as those for advertising and rentals.
  9. Federal taxation policies, especially the Fringe Benefits Tax (FBT) and Goods and Services Tax (GST), which both favour private car transport and penalise public transport.

Without going into details here, we are pleased to say that some of these were, in fact, considered and are mentioned in the Interim Report.

 

 

1.2 Report structure

We have no comments on this section.

 

 

2 Overview of public transport in New South Wales

2.1 Transport in the Greater Sydney Area

Section 2.1 says, "there was limited expansion of the rail network in the latter half of the 20th century". The Circular Quay loop, opened in 1956, is not mentioned. Also omitted are a couple of closures – Richmond to Kurrajong in 1952 and Campbelltown to Camden in 1962.

 

2.2 Transport in rural and regional New South Wales

We have no comments on this section.

 

2.3 The Commonwealth Government and public transport in New South Wales

The report mentions that the Commonwealth fuel excise goes to consolidated revenue, and comments on how little is returned to transport generally, and how much of that goes to roads. While we sympathise with those comments, we have to be realistic and remember that the fuel excise is just a tax, like the excise on alcohol and cigarettes, and the government can spend it how it wishes. Otherwise, we will get into the old argument of how the taxes on beer and tobacco should be spent.

The Auslink program brings new hope that funds for transport projects will be allocated on a priority basis, whether it is for road, rail, air or sea. This is not the place to discuss details. The Australian Financial Review dated 25th September 2003 contained a good coverage of it.

 

2.4 Rail services in New South Wales

On a somewhat pedantic point, Table 2.3 says that 42% of CityRail’s passengers on a weekday are "commuting". The category would be better termed "going to work", if that is what is meant. Many people going to work are not technically commuters. On the other hand, many students are "commuters", as they travel frequently and use pre-paid ticket at a commuted price.

 

2.5 Public bus and ferry services

Also perhaps a pedantic point, Table 2.6 says that 34% of STA’s passengers on a weekday are "commuting". The category would be better termed "going to work". Many people going to work are not technically commuters. On the other hand, many students are "commuters", as they travel frequently and use pre-paid ticket at a commuted price. We note that a similar table on page 175 correctly describes this category as "work".

Tables 2.7 and 2.8 show that STA bus and ferry users pay 52 percent of the costs by way of fares, while CityRail users pay only 28 percent (table 2.4). These figures should dampen somewhat the fires of passion stoked by the report writers against well-heeled bus and ferry users.

2.6 Private bus services

We have no comments on this section.

2.7 Other services

This section covers

NightRide buses, which replace suburban trains in Sydney from midnight to dawn, do not seem to be mentioned anywhere in the report.

3 Challenges in delivering better services in the Greater Sydney Area

One of the four challenges listed in the report is to "develop a skilled, flexible and customer-oriented management … etc." Many reports of government agencies (especially railways) in various states over recent years start with words like "we are changing from an operations based organisation to one that is customer focussed." We will believe it when we see it.

3.1 Challenges to improving services in rail

(Refer 3.1.5 – Sustainable CountryLink Services)

If country rail services are to be curtailed as a means of reducing costs, the replacement bus services should offer a level of comfort and amenity which is at least comparable with that of train travel. Current long distance bus services are not comparable. They are characterised by a minimum-cost syndrome. There are minimal terminal facilities, minimum personal spaces in terms of seat pitch, seat breadth and aisle space, cramped on-board toilets and nil on-board amenities except perhaps for drinking water. For some passengers, the bane of long distance bus travel is the compulsory "entertainment", which invariably takes the form of unceasing audio or video programming designed for and aimed at the lowest common denominator in passenger demographics.


3.2 The need for bus reform

The report does not acknowledge that road congestion and the lack of bus priority (a relatively recent phenomenon in Sydney) seriously degrade the attractiveness and efficiency of bus services.

3.3 Achieving efficiencies in ferry services

The unflattering comments about management of Sydney Ferries may have something to do with the level of maritime knowledge held by recent managers. We discuss this further under section 4.3.3 (Scope for efficiencies).

On the subject of the Manly JetCat, the report says, "demand for services on the Manly route can be met by (regular) ferry services alone." No doubt the JetCat passengers could fit on the regular ferries, but do they want to? Passenger demand does not equate entirely to capacity. In this case, some passengers demand speed as well, and will pay extra for it. We also understand that seasoned Manly commuters carry both Manly FerryTen and Manly JetCat tickets to use as the occasion arises. Comments here, and in section 4.3.3, about the Manly Ferry being able to carry all the Manly JetCat passengers are not really helpful to the debate.

This section adds, "Only a small proportion of the population directly benefits from these (ferry) services." Maybe, but a larger proportion benefits by not having those people on buses on Military Road or Parramatta Road or the Anzac Bridge. The Taronga Park Zoo is also a beneficiary (direct or indirect?) of the ferry services. What would happen to its patronage, and to traffic on the surrounding streets, if the ferry was withdrawn or restricted?

"There are lower cost transport alternatives available". It may be a lower cost alternative to put the ferry passengers in buses, but it is not an attractive alternative – either for the passengers or for the other people sharing the roads.

 

3.4 The potential for expansion of light rail

We have no comments on this section.

4 Revenue needs for the government-operated public transport network

4.1 Revenue needs for metropolitan rail

It is perhaps not helpful to use the word "revenue" to describe the money needed to cover both operational costs and capital requirements. Perhaps "funding" would be a better word. This is the word used in the next chapter – "Funding options".

We would have expected to see in the report a brief summary of CityRail’s capital projects, along with the estimated cost of each and a priority rating such as – in progress, next five years, next ten years, or in our dreams.

APT has a newspaper article headed "It’s crunch time for the railways". It goes on to say, "The State Rail Authority needs a colossal cash injection of $16 billion over the next 14 years to halt its financial haemorrhaging, according to a confidential report handed to the State Cabinet". That was December 1988, and the fourteen years are up.

It is disappointing to infer from the interim report that CityRail seems happy to bumble along for another fourteen years, contented with the scraps that fall from the master’s table. Afraid, unlike Oliver Twist, to say, "Please sir, I want some more."

Section 4.1.2 contains phrases revealing very modest ambitions – "network enhancements", "some improvements", "alleviate existing pressures", "operational and technological options", "no new major rail links" and "relatively static". In fact, the report specifically admits, "the forecast expenditure is essentially aimed at maintaining existing levels of service rather than expanding coverage or achieving significantly higher performance standards". People with ambition like this would never get a job at the RTA.

A new underground city rail corridor is called "the extreme". The RTA will do one for you before breakfast.

Under section 4.1.3 (page 46), it is suggested that "merging the SRA with the RIC offers some opportunity to reduce the ‘head office’ costs of operating the organisations separately". However, under section 4.3.3 (page 55) the report suggests that splitting Sydney Ferries from Sydney Buses would "improve the cost effectiveness". They can’t both be right.

4.2 Revenue needs for STA buses

Table 4.5, Performance against KPIs (page 49), equates comfort of buses with the age of buses. In our opinion, age and comfort are not directly related. Perhaps "age of buses" could be classified under maintainability or safety or reliability, but none of those are directly related either.

At section 4.2.3, Scope for efficiencies (page 52), the report asks in the margin, "Are all the new buses’ specifications necessary?" APT considers that the creature comforts of a public bus need to be comparable and competitive with those of a modern motor car offering door-to-door service if commuters are to be wooed onto public transport in the public interest.

In the same section, on page 53, much is said about restricting the use of pensioner tickets in the peak periods to reduce bus fleet size. In APT's view, much greater fleet time-savings could be gained simply by better policing of the existing transit and bus-only lanes. The report makes no mention of this.

APT is fairly sure that most of the elderly people who travel on the bus in the morning peak with Pensioner Excursion Tickets are not doing so for the fun of it, especially if the bus if full, as the report says. Many have to leave home early to get to medical appointments, to do work for voluntary organisations, to baby-sit their grandchildren or for long-distance social visits.

4.3 Revenue needs for Sydney Ferries

Especially 4.3.3 - Scope for efficiencies.

Cost Savings

Consultants have made a cost-efficiency study of Sydney Ferries in 2003. (See Ross Gittins’ "All the old lines" number 5 at Attachment B.) The changes suggested by the experts give a total saving of some $7,460,000 a year by our calculations. In the context of the $1,900,000,000 problem quoted at the beginning of the report, this amount is a drop in the harbour – 0.4 percent, to be precise. We presume that "modifications" to services means "reductions". The changes are probably not worth the consumer backlash. (Remember that Manly is a marginal electorate.)

Most of the savings are quoted as "per year" but one item of $4 million is just quoted as "medium to long term". Other anticipated savings are qualified by words like "up to" and "could". Some savings will be directly offset by new costs.

 

Separate Entity for Sydney Ferries

The proposal to unhitch Sydney Ferries from Sydney Buses and cast it adrift needs more careful thought.

Firstly, if the split is to "improve the cost effectiveness", then why, on page 46, is it suggested that a merger of two rail corporations would save money. Running the buses and ferries under the same management brings savings in administration costs.

Secondly, under the present combined STA management, there are very good timetable connections between buses and ferries. Such arrangements could well be scuppered if the entities are separated.

Thirdly, a high level of maritime expertise can be maintained within a joint structure. It is not necessary to split them for this reason.

4.4 Revenue needs for CountryLink

We have no comments on this section.

5 Funding options

5.1 Principal funding sources

We have no comments on this section.

 

5.2 Criteria for assessing funding options

We have no comments on this section.

 

5.3 User-pays funding options

It is often said that fares should be kept low so that poorer people can afford them. The price of groceries or taxis or rent is not kept low for everybody just so that the poorer people can afford them. These things are charged at market prices, and benefits are paid to poorer people to assist with buying them.

 

5.4 Beneficiary-pay funding sources

We have no comments on this section.

 

5.5 Private funding options

We have no comments on this section.

 

5.6 Public investment options

We have no comments on this section.

 

5.7 Summary of funding options

We have no comments on this section.

 

5.8 Observations

We have no comments on this section.

 

 

6 Fair fares: equity and efficiency

APT has no objection to some increase in cost recovery from the fare-box. However, a mixture of sedatives and truth serum needs to be injected into the debate before any rational discussion can follow. Facts in the report are, in places, highly selective and the language can be very excitable.

An Attack on Discounts

A computer search of the interim report shows that tickets and fares are described as "discounted" in about 20 instances, often accompanied by words such as "heavy, heavily, significant, unsustainably high, excessive, very large". However, the words "pre-paid, pre-purchased, off-bus", and the like are never mentioned once. See Attachment A.

The report suggests elsewhere that the government should receive discounts for bulk-buying bus services from operators for the SSTS (section 10.2.1, page 158), but thinks it unreasonable that the 40 percent of passengers who bulk-buy tickets from the government should receive any discount.

Definitions of Ticketing Systems

The definition of "integrated fares" in the introduction to this section is unsatisfactory. The report says that "integrated fares means applying the same fare structure across rail, buses and ferries", and that "integrated fares apply to multi-modal travel". Our definition of integrated fares is "the purchase of one ticket for one journey, with no penalty for changing vehicle or mode along the way". We have doubts whether the report’s definition means the same thing.

CityRail already has integrated fares for journeys wholly on its own system. A person making a single train trip from Ashfield to Tempe gets an integrated ticket and an integrated fare. There is no penalty by way of additional flag-fall for changing trains at Redfern, as there would be if the passenger bought separate tickets for the two legs of the trip (or had travelled by bus, changing at Broadway).

Single full-fare Ashfield to Redfern $2.80

Single full-fare Redfern to Tempe $2.80

Single full-fare Ashfield to Tempe $3.00

State Transit and private buses have extremely limited examples of penalty free transfers on single journey tickets.

The various Link tickets (Manly, Zoo, Bondi Beach, etc) are return tickets covering train, bus and ferry travel as appropriate. They are integrated tickets but not integrated fares. The price of the ticket is merely the sum of the individual modal tickets.

The report further muddles the definitions by saying, "simplified ticketing refers to the use of a single stored-value card to purchase travel – the so-called smart card". As Humpty Dumpty said to Alice in Through the Looking Glass, "When I use a word, it means just what I choose it to mean – neither more nor less". Well, "simplified ticketing" might mean what the report says and it might not. Simplified ticketing was around long before smart cards, and smart cards are no guarantee of simplified ticketing.

6.1 Requirements for public transport fare structures

Under 6.1.1 the role of taxis could have been mentioned. For a group of people it can be cheaper (and quicker) to take a taxi than to pay individual fares on public transport.

The final paragraph in section 6.1.2 says "the different combinations of revenue, and fare revenue in particular, means that different public transport users in different parts of the metropolitan system are being treated very differently when it comes to their contribution to cost recovery." (Note: the word "metropolitan" appears to be ill-used in this context.) While this may be often true, it is not always true. A majority of people, but not all, travel from their home to the CBD, a long or a short distance. However, short distance fares are the same everywhere on the system. The fare from Wyong to Gosford is $4.00 for 20 km, the same fare as for the 20 km from Pymble to Central. The distances from Wentworth Falls to Katoomba and from Bondi Junction to Central are both 7 km and the fare for both is $2.80. It is not where a person lives, but how far they travel that affects "how they are treated".

Secondly, we wonder if it really worries anybody that people "are being treated very differently". If the Ashfield to City commuter is getting a cheap trip, does he really care that the Gosford to City commuter might be getting a cheaper trip per kilometre?

In section 6.1.3, "pre-existing private investments in transport" might also include a yearly ticket as well as or instead of a car. The possibility of using a taxi also arises here if more than one person is travelling.

Under 6.1.4, The effect of fares on patronage, (page 87) the report says, "There is widespread agreement that the demand for public transport in Sydney is relatively insensitive to fare changes (‘price inelastic’)." However, APT believes that any fare rises are likely to hurt the poor most. While there may well be "inelasticity" in patronage in response to fare rises (fare rises do not automatically result in commensurate declines in patronage) the pattern for various demographics is likely to vary widely. Public transport patrons who have a choice in their mode of transport may revert to driving, using taxis, or some other alternative. Those in the lower socio-economic strata, who are more likely not to have choices in transport, may have no option but to pay the higher fares. Thus any fare rise may be seen as discriminatory toward this latter group.

6.2 Existing ticketing products and fare structures

On page 90 the report says that the different social profiles of ticket users "raises questions about the appropriateness of the single cash fare as the basis for setting other fares", yet single cash fares are used as the basis for calculating the alleged discounts on multi-ride tickets.

Our comments in this section will question the calculations of the alleged discounts offered by the multi-ride tickets, and also question whether or not they are excessive. We do not discuss the base level of fares on which the discounts are based. This is a separate exercise. We are merely forestalling a grab for higher fares based on the premise of excessively high discounts.

Some fairly detailed and wearisome calculations follow. However, they go to the crux of the report’s findings, so we trust that the reader, calculator in hand and hope in the heart, will see them through to the end.

TravelTens

Table 6.3 shows the discounts for bus TravelTens ranging from 13 to 30 percent off the single fare. We don’t dispute the size of the discount, only whether it is excessive or not.

FerryTens

The report does not show a table of ferry fares, so we have filled the gap:

Sydney Ferry Fares

Single

FerryTen

Discount

 
         

Inner Harbour Zone 1

$4.50

$28.50

37%

 

Inner Harbour Zone 2

$4.80

$31.10

35%

 

Manly and Rydalmere

$5.80

$42.90

26%

 

Manly JetCat

$7.50

$62.50

17%

 

Parramatta RiverCat

$7.00

$49.30

30%

 

 

The apparent large discounts of some of the FerryTens could be seen, not so much as a bonus to regular ferry travellers, but a result of high "tourist" prices charged for cash fares.

TravelPasses

Table 6.4 shows the alleged discounts on TravelPass tickets ranging from 32 to 46 percent. We have no idea how this "effective average discount from standard single fare" is calculated, and challenge STA and CityRail to produce supporting evidence. For TravelPasses, the size of the discount, the calculation of the average discount, and whether it is excessive are all in dispute. Remember the "questions about the appropriateness of the single cash fare as the basis for setting other fares" mentioned above.

TravelPasses without Rail Content

The no-train TravelPasses are:

Blue

Bus travel in Eastern Suburbs, Inner West and lower North Shore, and ferry travel in the inner harbour.

Orange

Bus travel everywhere except Pittwater, and ferry travel everywhere.

2-Zone

Bus travel in any two adjacent zones, but not including the CBD. No ferry travel.

Pittwater

Bus travel in any two adjacent zones, but not including the CBD. No ferry travel.

No TravelPass is valid on a Manly JetCat except when they replace regular ferries at night.

Blue TravelPass

This ticket, costing $29.00, is alleged to have an average discount of 43 percent from the "standard single fare". Let us say that a person makes a 2-section bus trip and a 4-section bus trip every morning and the same home again at night. At single cash fares, that would be $2.70 x 10 plus $1.60 x 10, a total of $43.00. At $29.00, a Blue TravelPass gives a 33 percent discount – far from the 43 percent alleged in the report. Even with an additional $2.70 x 2 trips on Saturday, that still only makes the total value $48.40 (at single fares), and the discount from a $29 ticket would still only be 40 percent.

However, if the TravelPass were not available, our commuter would surely use TravelTens rather than pay single fares to the bus driver twenty or more times a week. The costs then would be $11.80 plus $19.70, a total of $31.50, and a discount of only 9 percent – nothing like the alleged 43 percent.

Looking at the calculations in reverse – if the Blue TravelPass at $29 is discounted an average 43 percent as alleged, then the average person would have to use $50.90 worth of travel to achieve that 43 percent discount. ($50.90 minus $29.00 equals $21.90 discount, equals 43% of $50.90.) At single cash fares our average person would have to make nineteen $2.70 bus trips in a week to spend $50.90. ($2.70 x 19 = $51.30) That’s the equivalent of Leichhardt to Maroubra Junction and back five days a week except Friday, when he stays in town for a drink and gets a lift home. Or ten trips from Malabar to Railway Square ($35) then to Camperdown ($16) and back. That’s an awful lot of bum-numbing bus ride. And if that is the AVERAGE, then some people are doing more. They deserve a mention in the Guinness’s Book of Records. And some people must be travelling less, and receiving a smaller discount.

If we calculate $50.90 worth of travel at TravelTen rates (instead of cash fares as above) we get twenty 3-5 section trips ($39.40) plus ten 1-2 section trips ($11.80). At an average of 21 minutes per trip (Table B.1, page 175) that is nearly eight hours of bus travel a week. The most ardent bus-o-phile would have trouble fitting that in.

Including the ferries – a ferry from Neutral Bay to Circular Quay and a 2-section bus trip up George Street would cost $6.10 at full fares ($4.50 + $1.60). Ten times a week makes $61.00 – and a $29 TravelPass gives a discount of 52 percent. If the TravelPass were not available, a regular traveller would not queue up to pay cash four times a day (especially at Circular Quay at peak hour). Using TravelTens and FerryTens, a one-way trip is $4.03 ($2.85 + $1.18), or $40.30 a week. The $29 TravelPass then gives a $11.30 or 39 percent discount. Throw in a few extra bus trips and the discount would reach the alleged average 43 percent. However, this target is reached only by including the relatively expensive ferry fare. The vast majority of TravelPass users rarely go near a ferry.

Pittwater TravelPass

This ticket, costing $49.00, is alleged to have an average discount of 33 percent. It would only be bought by someone living in the Pittwater area who travels to work in North Sydney or the CBD. Ten single 16+ section bus tickets cost $48.00, so the TravelPass is actually at a premium, not a discount. Even allowing for a few additional trips at lunch time or the weekend totalling, say, $11.80, the total use at cash fare rates is $59.80, or a discount of only 22 percent.

Note that a person from Pittwater would be unlikely to use the Manly ferry for regular travel, as the express buses to the CBD and Railway Square are much quicker. Also, it is unlikely that our commuter would wish to take pleasure trips on the bus at the weekend, having already spent nearly two hours each day on the bus going to and from work.

However, if the TravelPass were not available, our commuter would use TravelTens rather than pay single fares ten or more times a week. The costs then would be $41.80 for ten trips on an Orange TravelTen plus say $8.66 for a few extra trips (four trips on a Blue TravelTen at $1.18 and two trips on a Brown TravelTen at $1.97), a total of $50.46, and a discount of only 9 percent – nothing like the alleged 33 percent.

Other No-Train TravelPasses

Similar calculations could be done for the Orange TravelPass (alleged discount 47 percent) and the 2-Zone TravelPass (alleged discount 34 percent). Note that rail travel is not available on the Blue, Orange and Pittwater TravelPasses, and neither rail nor ferry travel is available on the 2-Zone TravelPass.

TravelPasses with Rail Content

These provide such a wide range of travel options using rail, bus and ferry that it is difficult to work out what an "effective" discount is and what an "average" discount is, but we will try.

We understand that limited travel Workman’s Weeklies were introduced in Sydney in about 1910, and unrestricted Weeklies in 1925. The concept of discounted weekly fares should therefore by now have become entrenched in the everyday fares philosophy of CityRail.

We have only calculated the discounts for the smallest (Red) and the largest (Purple) zones. Calculations for the other zones will give similar results. The full range of zones is listed in the following table, together with the stations on the western line as an example.

Red

City Circle, Central, Redfern, Macdonaldtown, Newtown, Stanmore, Petersham, Lewisham, Summer Hill, Ashfield, Croydon

Green

Burwood, Strathfield, Homebush, Flemington, Olympic Park, Lidcombe

Yellow

Auburn, Clyde, Granville, Harris Park, Parramatta

Pink

Westmead, Wentworthville, Pendle Hill, Toongabbie, Seven Hills

Purple

Blacktown, Doonside, Rooty Hill, Mount Druitt, St Marys, Werrington, Kingswood, Penrith, Emu Plains

The Red TravelPass does not allow travel on the Manly or Parramatta ferries, but all the others do. No TravelPass allows travel on the Manly JetCat.

The Red TravelPass does not allow bus travel beyond (roughly) The Spit, Chatswood, Lane Cove, Croydon, Canterbury or Rockdale, but all the others do. Only the Pittwater, 2-Zone and Purple TravelPasses allow bus travel in the Pittwater area.

Red TravelPass

A Red TravelPass costs $32 and the alleged average discount is 33 percent. Let’s say that someone lives at Croydon and works at Maroubra Junction, and takes a train to Central and then a bus. This is close to an extreme case. Ten single train trips cost $28 and ten single bus trips cost $27, a total of $55. A $32 TravelPass gives a discount of $23 or 42 percent. However, our regular traveller would not buy cash fares twenty times a week, every week. If the TravelPass were not available, he would buy a Croydon to Central rail weekly for $22 and a bus TravelTen for $19.70, a total of $41.70. On this basis the $32 TravelPass gives a discount of $9.70 or 23 percent. Add in some extra train trips at the weekend and the discount would still struggle to reach the alleged 33 percent.

Purple TravelPass

A Purple TravelPass costs $54 and the alleged discount is 45 percent. It covers rail travel from Penrith, Campbelltown, Cronulla and Cowan as well as all STA bus and ferry travel. Single rail fares from Penrith to the City are $6.60, from Campbelltown $6.00 and from Cronulla or Cowan $5.20. Using the $6.00 fare as our average, and without any additional trips, the weekly cost would be $60, and the discount $6, or 10 percent. (Note that the fare from some of these stations to the City will also take our traveller to North Sydney or St Leonards.) If he required no other trips, he would have bought a rail weekly costing $40.

Add in ten bus trips at $1.60 ($16) and perhaps another short return train trip (say $5) and the total value at single fares becomes $81 ($60 + $16 + $5). The discount is now $27 or 50 percent. However, it is ridiculous to think that a person would buy five return train tickets and ten bus tickets for cash every week. Using a rail weekly ($40) and a bus TravelTen ($11.80) the total is $51.80 and the premium (not discount) on the TravelPass is $2.20. Our traveller would have to make a few more bus, train or ferry trips to even come out in front.

Note also that Penrith, Campbelltown, Cronulla and Cowan are at or near the outer extreme of the Purple TravelPass zone. The inner extremes of this zone are Asquith, Blacktown, Casula, Glenfield (for East Hills line) and Woolooware. A weekly rail ticket from these places to the City costs only $37 ($33 from Asquith), further reducing the alleged discount.

It is also ridiculous to say that, because the Purple TravelPass can be used on all the suburban lines, the holder could and would travel from Cronulla to Cowan and to Penrith. Only monks and dedicated rail fans perform self-flagellation these days.

TravelPass Zones

Perhaps, instead of looking at the prices of the TravelPasses, the zone and mode availability of each type could be reconsidered.

Rail Weeklies

The report refers in passing to the cheaper per kilometre cost of longer rail trips, and to the "heavily discounted weekly tickets". It is surprising that no reference is made to the sliding scale of discounts, resulting in big differences in the discounts between short and long distance weekly tickets.

The following table is a sample scale of weekly tickets:

Km

Single

x 10

Weekly

Discount %

         

5

2.20

22.00

18.00

18

20

3.60

36.00

28.00

22

35

4.40

44.00

33.00

29

65

6.60

66.00

44.00

33

105

10.20

102.00

54.00

47

195

21.00

210.00

82.00

61

305

28.00

280.00

108.00

61

There are many reasons, not the least of them political, for this huge discrepancy in discounts. One is that a commuter from Wyong is highly unlikely to return to Sydney over the weekend, while a commuter from Ashfield would probably use the ticket at least once over the weekend and perhaps one night during the week. Note again that "short distances" does not just mean 10 km radius from the CBD. It also means 10 km radius from Katoomba or Parramatta or Sutherland or Wollongong. The fare is the same.

The Level of Discount

Our apologies for all the above figures, but it was necessary to discover whether the alleged discounts quoted in the report are fact, fancy or something between. In our opinion the needle swings a little towards the fancy side of halfway, but without the evidence of statistical data, we cannot prove it. Can CityRail and State Transit prove conclusively otherwise? This is important, for on it hangs the Inquiry’s case for increasing the price (reducing the discount).

Readers can calculate the discounts for themselves using the fare tables on the web site: http://www.131500.com.au/tickets_and_fares.asp

One bus section is about 1.6 kilometres.

Remember that it is illogical, unfair, and, according to the report, perhaps even inappropriate, for the single cash fare to be used as the basis for other calculations (page 90).

 

Is the Discount Excessive?

In a word, No!

In cleaning out some old newspaper clippings recently, we found a picture of STA chief, John Brew, dated 16th December 1988. He was proudly reminding readers that he had recently introduced a multi-ride bus ticket with a 45 percent discount and how this had increased patronage and reduced cash handling costs. But that was then, and this is now.

Bulk-buying anything deserves a discount - as a reward for being a good customer, as an enticement to come back, and to recognise the savings to the vendor in handling only one sale. The government expects to receive a discount when it bulk-buys bus services from contractors (section 10.2.1, page 158, of the Interim Report). So why shouldn’t bulk-buyers of travel tickets receive a discount?

These days, many full-time workers don’t need to leave home until after 9 am, and could use off-peak return train tickets at a discount price. Buying a rail or TravelPass weekly might not save them any money, but they do it for the convenience. Would CityRail prefer that they make five or six purchases a week, or only one?

In the above examples, we have assumed that a person makes at least ten trips a week. Part-time workers might make only eight trips. In a normal week the periodical might give them no discount over single fares, but they will buy it for the convenience. If the discount was less that 20 percent they might not buy a weekly at all and use single or return tickets instead.

As mentioned earlier, the report uses "discount" or variations thereof in relation to tickets and fares about 20 times, but never once uses the word pre-paid, pre-purchased or any variations.

When travellers pay in advance for bulk tickets, the operator benefits in several ways:

  1. the operator has the use of the customer’s money for up to a year before the service is provided;
  2. the operator needs fewer staff or machines to handle only one sale a week, a quarter or a year, rather than every day;
  3. the operator has reduced cash handling costs and risks;
  4. the operator saves on the cost of stationery for printing the tickets;
  5. in the case of buses, the operator saves time, labour and fuel if people have already paid their fare before boarding;
  6. in the case of weeklies and other periodicals (but not TravelTens and FerryTens) the operator gets payment for a service not used if the ticket holder doesn’t travel on one or more days for any reason (sick, day off, strike, public holiday, working elsewhere, etc)
  7. the opportunity for fare evasion is lessened.

This is well known to everybody, not just transport experts, but none of it is mentioned in the report. We can only assume then that it is a deliberate case of hiding any facts that don’t fit the required verdict. (Ross Gittins’ rule 7 – "ignore facts that weaken your case".)

Over the years, APT has had many sparring matches with IPART over the definition of an acceptable discount.

For TravelTens and FerryTens we concede that around 20 percent is fair, because a user pays for each trip taken, rather than paying for an unlimited number of trips in a week. Note that the current discount for the Green TravelTens (17 percent) and Orange (13 percent) is less than twenty percent.

The apparent large discounts of some of the FerryTens could be seen, not so much as a bonus to regular ferry travellers, but a result of high "tourist" prices charged for cash fares.

For point-to-point rail weeklies, the current sliding scale of discounts from 18 to 33 percent for shorter distance trips (up to about 60 km) is also a fair trade-off and should not be altered.

Beyond that distance, however, we agree that the discounts on rail weeklies are excessive and could be trimmed back to about 35 or 40 percent. This change should be done gradually, meaning over a period of about five years.

The table on page 20 would then look like this:

Km

Single

x 10

Weekly

Discount %

         

5

2.20

22.00

18.00

18

20

3.60

36.00

28.00

22

35

4.40

44.00

33.00

29

65

6.60

66.00

44.00

33

105

10.20

102.00

66.30

35

195

21.00

210.00

126.00

40

305

28.00

280.00

168.00

40

For some of the extremely long distances, there are so few weeklies sold that such a large reduction in discount is probably not worth the backlash. We understand that about 34 people regularly commute from Maitland to Sydney, a distance of about 200 km each way.

For TravelPasses, the figures are far from clear. Because of the wide range of travel options available, it is very difficult to work out an effective discount, and we will not trawl through all the calculations again. To allow more scrutiny of the process, perhaps some simple average formula for each ticket could be agreed upon.

The price of the TravelPass should then be discounted by about 20 to 25 percent of the sum of those multi-trip fares.

 

Yearly Tickets

The discussions in the report and in our response have so far been concerned solely with discounts on weekly tickets. An additional discount applies to longer-term periodicals. A quarterly TravelPass costs 11 times a weekly (not 13 times) and a yearly TravelPass costs 40 times a weekly (not 48 or 52 times). A yearly rail ticket costs 41 times a weekly, and a sliding scale of discounts applies for rail tickets between 30 and 365 days. This "period" discount is the same no matter what the distance.

Central to

Wollongong

Calculation

 

Ashfield

Calculation

           

Weekly

$50

$50 x 1

 

$22

$22 x 1

30 days

$195

$50 x 3.9

 

$86

$22 x 3.9

90 days

$555

$50 x 11.1

 

$244

$22 x 11.1

180 days

$1,046

$50 x 20.9

 

$460

$22 x 20.9

365 days

$2,054

$50 x 41.1

 

$904

$22 x 41.1

The additional discount for a yearly ticket is then 11 or 12 weeks out of 52, or 21-23 percent. If we say that a person’s working year is only 48 weeks, then the discount is 7 or 8 weeks, or 13-15 percent.

A yearly rail ticket from Penrith to Central is $1,807 ($44 x 41.07). From Springwood, Lisarow, or Wollongong, a yearly to Central is $2,054.00 ($50 x 41.08). The cost of yearly TravelPasses varies from $1,160 (Blue and 2-Zone TravelPass) to $2,160 (Purple TravelPass).

By forgoing bank interest for a year the ticket holder loses an average of six months interest. At an annual interest rate of 4 percent, the purchaser would lose about 2 percent.

On these calculations the yearly ticket holder gains 13-15 percent in "weeks" and loses 2 percent in cash, a net additional gain over weekly tickets of 11-13 percent.

Is such an additional discount justified? Yes, it is. Most of the benefits to the operator from selling weekly tickets are multiplied many times by selling only one ticket a year.

 

6.3 Options for ticketing reform using smart cards

As we have said in many forums, consisting mainly of people with blind eyes and deaf ears, the smart card system is a technology in search of an application. The proposed system, as we understand it, seems to be mainly for the benefit of the computer companies, the transport operators and the bank holding the funds.

We say "as we understand it" because, despite repeated and long-standing requests, no formal, continuing, consultative process involving the final users (the fare paying passengers) exists within the system development process. Consequently, we don’t know how it will work. We suspect that the report writers are similarly in the dark - or at least working by soft and romantic candlelight. One of the opening sentences on page 92 says, "The inquiry understands that the integrated ticketing under design has the possibility of continuing to handle multiple ticket products." Does nobody know for sure?

An earlier sentence mentions "the elimination of cash fares". This will happen at about the same time as the elimination of politician’s perks. State Transit’s submissions to IPART over recent years say that about 25 percent of passengers pay fares to the driver, yet they are doing nothing about it. They don’t even say what an acceptable level of cash fares might be. An opportunity was available a few months ago to increase the price of cash fares relative to pre-paid fares, but the STA and IPART chose not to take it. In fact, they did the opposite. State Transit sells off-bus single and return tickets prior to the City to Surf race each August, at no discount, but refuses to sell them at other times.

While we know that smart card systems have been successfully installed elsewhere, and we don’t dismiss the possibility of it happening in Sydney, we consider that the current proposal, rather than being anything genuinely needed or wanted by the public, is more in the nature of a three-card trick.

Card One – users don’t get their discounts until they have used up their full-fare rides first;

Card Two – the discounts would be offered from the funds used for the initial purchase of the

smart card (page 92). In other words, we will be offered our own money back as a discount;

Card Three – users will be charged a fee for transferring funds from their bank to the smart card.

Fagin would have been proud.

The report also makes some other naïve statements or assumptions about the operation of smart cards. In discussing the removal of some inequities it says, probably correctly, that the expensive single trip fares are more commonly purchased by less well-off travellers (page 92). Our understanding is that the less well-off travellers don’t buy the cheaper multi-trip tickets because they can’t afford them. This is not as silly as it sounds. These cheaper tickets have to be bought in bulk, and the budgets or planning ability of such people does not stretch to buying ten tickets at once, cheap though they may be. If they can’t afford a TravelTen now, they won’t be able to afford the purchase price of a smart card plus the first deposit of funds.

Sydney already has, without the benefit of smart cards, tickets which "allow for multimodal journeys across government and privately operated services on one integrated ticket, without multiple ticket purchases payments" (page 93). They are called TravelPasses (for government only services) and BusPlus tickets, which cover certain rail and private bus journeys. Before that we had Brown MetroPass tickets. And the concept is far from new. In the 1930’s, combined tickets were available for trips on the government trams and the then privately owned Sydney Harbour ferries. When the Eastern Suburbs Railway was opened in 1979, combined single bus and rail tickets were available.

APT is not necessarily opposed to a smart card system. We just don’t think the current proposal has been properly thought out, and there has been no true consultation with the fare payers. There are options for all sorts of things in a smart card system. Most of those mentioned in the report seem to be to the consumer’s disadvantage. Where are the bonuses, rewards or incentives – half-price days (like at the movies), happy hours, lucky "door" prizes, cheap "top-up" days?

The Sydney Monorail occasionally has cheap "top-up" days, where subscribers to the Loyalty Programs can add rides to their stored value card for $2 instead of the normal $2.50. The next such "$2 Day" is 22nd October. These specials are not advertised to the public, but are notified to individual subscribers. The letter accompanying this offer says, "We are always looking to develop further relationships to provide members with discounts ……". The normal $2.50 stored value fare is a 38 percent discount from the $4 cash fare. A $2 fare is a 50 percent discount. And you don’t have to wait until any full-fare rides are used up first. Obviously they haven’t read the Excessive Discounts Manual.

 

6.4 Options for improved fare integration

The various options for fare reform, the advantages and the problems are generally well stated in the report (6.4.1), and there is no point in going through them all here. Examples could be quoted of cities all over the world that have one type or another or a combination. Each seems to suit the local circumstances well.

Also, the issues involved in fare integration appear to have been well canvassed (6.4.2), and further discussion is best left to the future.

 

 

6.5 Observations

This section in the report is a summary of the preceding paragraphs. We have made extensive comments under the individual section headings.

 

7 Service quality regulation, incentives and fares

 

7.1 Current arrangements for regulating quality

We have no comments on this section.

 

7.2 Service quality measurement: the role of KPIs

We have no comments on this section.

 

7.3 Linking fares and quality of service

The mention of RTA in 7.3.1 should be STA.

In section 7.3.3, the report suggests that the current four State Transit bus divisions in Sydney (North, East, North & West and South & West) could be restructured as independent business units, and that these units could compete against each other and against private operators for all contract areas.


While we recognise that competition, and the threat of losing the contract, is one way of ensuring that operators deliver the required service, we have some concerns about whether this is appropriate within State Transit. What would be the practical consequences if, for instance, if the East Division won the contract for the North Division area? Would East "buy out" North? Would East sub-let the contract to North? Would North be forced to accept the contract but at East's price?


Another concern with this re-structure is that we have seen it all before. State Transit seems to be on an eternal cycle of big-bang and big-collapse phases. Management is devolved to regions, then areas, then individual depots then it is clawed back again in stages to head office. Too much freedom given to areas and depots results in different types of services being offered to consumers, and this can become confusing. We have no objection to internal competition between units, and initiatives from one unit being spread to the other units, but the public should only see one homogenous system.

7.4 Observations

We have no comments on this section.

8 Charging for road use

We commend the Inquiry for addressing the complex and sensitive subject of road-use pricing. However, we disagree with the Inquiry's conclusion that road pricing as a means of funding public transport is only practicable in the long term and not before higher quality public transport services are available as alternatives to driving.


We do not accept that better public transport alternatives need to be provided before road pricing commences. Any new road pricing regime will need to be implemented gradually, for reasons of economic stability, quite apart from the politics. The design and implementation of such regimes could commence immediately.


8.1 Achieving the efficient use and provision of roads

We have no comments on this section.

 

8.2 Problems with the current practice

We have no comments on this section.

 

8.3 Bearing the costs of NSW roads

We have no comments on this section.

 

8.4 The need for road use reform

We have no comments on this section.

 

8.5 Tolling on selected arterial roads

We have no comments on this section.

 

8.6 Where to from here?

We have no comments on this section.

 

8.7 Charging for road use in the Greater Sydney Area

We have no comments on this section.

 

8.8 Options for road pricing

In section 8.8.1, table 8.6 says, "Cordon charges are likely to be regressive". Refer Ross Gittins’ standard argument number three – "always claim the tax change is regressive. Most people don’t really know what regressive means – so few will challenge you to prove it."

 

8.9 Observations

We have no comments on this section.

 

9 Decision criteria for choosing transport projects

9.1 Possible future investments in transport infrastructure

We have no comments on this section.

 

9.2 From broad policy objectives to projects, not vice versa

Transport planning in Sydney over the past decade or two has been more than "a piecemeal approach, or primarily a list of transport infrastructure projects" as described in the report. It has been a planned pecuniary plundering of the public purse by private profiteers. It can be likened to Hans Christian Andersen’s tale of the Kings’ New Clothes, where the con men pretended to show the king a roll of beautiful material. To a wise man, they said, it was the most glorious cloth in creation, but to a fool it was invisible. And the king and his court, not wishing to appear fools, went ahead and bought the tunnel, and the bridge and the freeway.

 

9.3 Appraisal approaches in New South Wales and elsewhere

We have no comments on this section.

 

9.4 What is required to avoid limitations of the past approach?

We have no comments on this section.

 

9.5 The consequences of a non-integrated approach

We have no comments on this section.

 

9.6 Observations

We have no comments on this section.

 

10 Concessions and community transport

10.1 Overview of concessions and community transport services

We have no comments on this section.

 

10.2 The need to better target funding


The Interim Report's justification for increasing the $1.10 pensioner excursion fare is too simplistic. See further discussion under 10.2.2 below.

 

10.2.1 A more effective School Student Transport Scheme (SSTS)

The reference to discounts on page 158 is interesting. In discussing school services, the report says, "In addition, the government should expect to pay lower than standard fares for the SSTS. A purchaser who buys a large proportion of a business’s services would normally receive some discount on the standard price in recognition of the benefits the business receives from this source of revenue. Contracts with service providers should reflect all the benefits they receive from the government’s SSTS payments."

In other words, it’s OK for the government to receive discounts for bulk-buying, but not to give discounts to passengers who bulk-buy tickets. According to the report, periodical tickets account for 40 percent of all train trips (page 172), and 42 percent of all bus trips (page 176).

On page 159 the report suggests introducing an application fee of $30 a year. Why is it called an application fee, instead of a travel fee? Why only $30 a year?

The report also fails to mention that students living within the specified radius of their school already pay $40 per term (not per year) for a School Term Pass. There is no reason why students living outside the zone should not at least match that cost while travelling inside the zone. It seems somewhat topsy-turvy that the students living closest have to pay, while those living furthest away pay nothing.

10.2.2 Equitable provision of pensioner excursion tickets (PET).

This section suggests making the PET unavailable for morning peak hour journeys between 7 am and 9 am. Presumably, for simplicity, this would apply in both directions, although there is generally more room on contra-peak flow vehicles. We mentioned earlier, under section 4.2.3, that some senior citizens need to travel during these hours for various reasons, and banning the PET will not remove them from the bus or train. What sort of ticket will these people buy for their journey home?

At an IPART public hearing some years ago, CityRail officials were forced to concede, after some prodding and back-of-the-envelope calculations from a Tribunal member, that there were, on average, only two pensioners per carriage in the morning peak. Are these figures still true? We repeat, senior citizens don’t tackle peak hour buses and trains without good reason.

The Report argues for the spreading of the Pensioner Excursion Ticket to the private bus users in outer suburbs. However, it does not acknowledge that the elderly residents of suburbs with better amenities, be they the $1.10 pensioner excursion fare or just better libraries or even water views, invariably pay higher rents or other taxes as a consequence of those better amenities. In other words, the elderly choose what they pay for by where they choose to live.

APPENDIXES

A. Train users in Sydney

On page 172 the report says, "61 percent of all trains trips are made with the payment of full fare, compared with only 35 percent of bus trips". While this is true, it gives a misleading view of the bus situation. In Appendix B it says that 47 percent of STA bus passengers pay full fare, while only 20 percent of private bus passengers pay full fares.

Other figures in the appendix for Ticket Type, Labour Force Status, and Personal Income of bus users are similarly distorted by combining STA and private bus users, for no good reason.

 

B. Bus users in Sydney

The footnotes to table B.1 (Summary of bus travel in Sydney) say:

  1. "For residents of Sydney only. Excludes bus travel by visitors and tourists."
  2. APT asks, How do they know? Why are visitors and tourists excluded?

  3. "Trips to return home are allocated to a ‘priority purpose’." What does this mean?

The figure of 18 percent for cash ticket sales on STA buses is lower than that quoted by the STA in recent IPART papers.

 

C. CityRail service and reliability standards

The on-time and reliability standards for CityRail trains cover only certain stations, certain times of day, certain days and certain directions. APT considers that sample (repeat "sample") checks should also be made;

 

D. Achieving the efficient use and provision of roads

No comments.

 

E Examples of charging for road use

No comments.

 

F Submissions

No comments.

 

OTHER COMMENTS

 

What’s Next?

We have many questions to ask about the future of this Inquiry. Here are the Top Ten.

  1. Is there an overall project plan, saying who is to do what, and when?
  2. When the final report with recommendations goes to the Minister, how will each option be rated for priority? By cost/benefit analysis, by urgency, by simplicity, by political expediency?
  3. What will the process be after the Minister has received the final report?
  4. Who will make the final approvals?
  5. Considering that the options fall into many ministerial baskets, who will co-ordinate and guide them through to completion? Who will "own" the project?
  6. Who will pay for the implementation of the changes?
  7. Who will monitor the implementation of each change through the various stages?
  8. How will the implementation process be reported back to the public?
  9. How will the actual running costs and revenue for each project, after implementation, be reported against the projected running costs and revenue?
  10. How will the public be sure that any net revenue gained is actually put back into improving public transport, which was the whole purpose of the exercise in the first place?

 

 

 

 

 

ABBREVIATIONS

IPART Independent Pricing and Regulatory Tribunal of New South Wales

PET Pensioner Excursion Ticket

RTA Roads and Traffic Authority

SRA State Rail Authority

SSTS School Student Transport Scheme

STA State Transit Authority

 

Submission by Action for Public Transport

ATTACHMENT A

Here are some word counts from the Interim Report, courtesy of the computer "find" option.

Mentions of "discount/s/ed/ing" - 29

  1. Overview, page xiv - "heavily discounted concession travel"
  2. Overview, page xviii – "providing discounts only for off-peak travel ….."
  3. Overview, page xviii – "tying discounts to higher levels of stored value"
  4. Section 5.3, page 61 – "changes to discounts for longer distance trips"
  5. Section 6, page 83 – "various discounted periodical and multiple trip … products"
  6. Section 6.2, page 89 – "there are fare and discount variations"
  7. Table 6.3, page 89 – "discount from single fare"
  8. Table 6.4, page 89 – "effective average discount from standard single fare"
  9. Section 6.2, page 90 – "users of the heavily discounted weekly tickets"
  10. Section 6.2, page 90 – " relatively heavily discounted to those who can … "
  11. Section 6.3, page 92 – "the only discounts from this (a standard ticket) would be…."
  12. Section 6.3, page 92 – "offering some ‘value stored’ discount".
  13. Section 6.3, page 92 – "ending the heavy discounting of …."
  14. Section 6.3, page 92 – "existing unsustainably high discount levels"
  15. Section 6.3, page 93 – "the current arrangements build in discounts and .. "
  16. Section 6.3, page 93 – "with discounts limited to off-peak, concessions and.."
  17. Section 6.4.2, page 95 – "via so-called discount tickets"
  18. Section 6.4.4, page 98 – "there is significant discounting of off-peak rail fares"
  19. Section 6.5, page 100 – "excessive discounts are available to purchasers of …"
  20. Section 9.3, page 139 – "…into present values by discounting" (NPV)
  21. Section 10.1.1, page 151 – "discounted excursion tickets"
  22. Section 10.1.1, page 152 – "discounted excursion tickets’
  23. Section 10.2.1, page 158 – "would normally receive some discount on the …"
  24. Section 10.2.2, page 162 – "increased to $2.50, the discount remains very large"
  25. Section 10.2.6, page 166 – "heavily discounted licence plates" (wheelchair taxis)
  26. Appendix E.1, page 188 – " ….. and discounts available" (congestion charging)
  27. Glossary, page 202 – "discounting the future costs" (Net Present Value)
  28. Glossary, page 202 – "discounted tickets available to pensioners"
  29. Glossary, page 202 – "flat discounted fare for travel…"

Not all of these references are to discounted tickets, but most of them are. Note that "discount" is accompanied by "heavily, heavy, significant, unsustainably high, excessive, very large" on seven occasions.

 

Mentions of "prepaid, pre-paid, prepurchased, pre-purchased, prepay, off-bus, off-vehicle", etc – zero.

 

 

 

 

 

Submission by Action for Public Transport

ATTACHMENT B

All The Old Lines

 

In the business section of the Sydney Morning Herald on 15/09/03, journalist Ross Gittins gave a list of seven basic rules for organisations mounting political campaigns.

Some of them have surfaced in this report, either in their pure form, or in the corollary.


These are just the basic rules. There is more detail in the article.

Rule number 8 was added by us.

  1. No matter how big and rich you are, find some poor people to hide behind.
  2. (Corollary: Attack the rich.)

  3. Claim it won't be you who'll suffer, you'll just pass the tax on to your poor customers.
  4. Always claim the tax change is "regressive".
  1. Claim the tax will put firms out of business and people out of jobs.
  2. Commission a consultant's report that plays up the economic costs, but omits to mention the economic benefits.
  3. Don't be afraid of double counting or mutually contradictory arguments.
  4. Don't feel obliged to counter inconvenient arguments that weaken your case - simply ignore them.
  5. If you are a union, claim the changes will affect public safety.

 

END