Respond to consultation by 28 October
Our regional transport authority, SPT, have been developing the new Regional Transport Strategy (RTS) for the last three years.
Once finalised, this Strategy becomes a crucial statutory document which will set the direction for public transport in our region for the next 15 years (until 2037).
We need SPT to get it right!
When the final draft RTS was released for consultation earlier in the summer – we were immediately concerned about its lack of clarity, vision and ambition.
None of the recommendations we put forward during the last consultation have been taken on board.
We quickly issued an urgent briefing to SPT Board members to ask them to intervene, and have been lobbying the SPT Board and Officers ever since.
In the final few days of the consultation, we are running an email action to make it simple for you to have your voice heard.
Please click on the link below to auto-generate an email to SPT, then:
- read over the email,
- add and change any bits that you can (the more variation the better),
- make sure you sign it with your name and address at the bottom
- and then send it off!
If you have more time, please respond via the consultation questionnaire. You are welcome to use some of the arguments from our previous consultation response, our briefing to SPT Board members, as well as the email contents below.
Many thanks for your help!
Our Suggested Email to SPT
To: rts@spt.co.uk
Subject: Response to the Regional Transport Strategy consultation
Dear SPT,
Please accept this email as my response to your consultation on the draft Regional Transport Strategy, being carried out by Stantec.
I have chosen to respond in this way because I found your online questionnaire too leading in the way it is structured.
I am an extremely frustrated public transport passenger in the Strathclyde area and it’s essential that my views are heard.
I can confirm I am over 16 years of age and am submitting this response as an individual.
RTS Strategic Framework
The RTS claims to be “unashamedly strong, bold and ambitious”, but yet it completely fails to set out the concrete actions that SPT will take to deliver a fully-integrated, affordable and accessible public transport network for our region ahead of our pressing climate targets in 2030.
We need SPT to show leadership in our region, like regional transport authorities in other parts of the UK are doing – such as Transport for Greater Manchester (TfGM), Merseytravel or Transport for London.
This requires SPT to seize the powers now available in the Transport Act 2019 (as well as the powers the RTS says SPT already has and is not even using) to radically transform the way our region’s public transport is delivered – so that it works in the interests of passengers and not the profit-making private bus companies.
Rather than focussing on “the place”, I expect this RTS to present a clear and compelling vision of what our public transport system could actually look like in 2030, if SPT fully-utilises its new powers to re-regulate the region’s bus network (through ‘franchising’) and to set-up a new publicly-owned bus company for Strathclyde.
This includes illustrating what our improved, integrated route network will look like (across bus, train, Subway, ferry, active travel and the future Clyde Metro), and showing how our new publicly-controlled buses will be designed to ensure that there is a coherent sense of identity across the network.
TfGM and Merseytravel have both set out these visions for their regions (based around a newly re-regulated bus network) and are now working towards delivering them.
This gives people living in these similar regions in England some faith that positive change is taking place.
SPT’s draft RTS does not give me any faith that the dire state of public transport in our region is going to change. It is riddled with vague commitments saying SPT will ‘encourage’, ‘facilitate’, ‘support’, ‘promote’ and ‘develop’ (the word ‘lead’ is conspicuously absent). This is not good enough.
I want SPT to be ambitious – to show leadership and initiative for our region (on behalf our 12 constituent councils), and to actually deliver the change we urgently need.
7.2 Accessing and using transport
In order to be able to set accessibility standards, transport fares and to guarantee the availability of public transport across the region, it’s clear that SPT needs to be able to control all of these elements.
This is why I want to see clear commitments from SPT to fully-utilise its new powers to re-regulate the region’s bus network and to set-up a new publicly-owned bus company for Strathclyde – to provide us with a similar high-quality and affordable service to that provided in Edinburgh by Lothian Buses.
SPT must also commit to working with the new publicly-owned ScotRail to take back control over our region’s suburban rail network, so that train services can be planned and coordinated as part of a fully-integrated regional network (as they are in Merseyside and London).
P.A1 Accessible transport
SPT should set out a clear timetable for making the whole of the network fully-accessible to wheelchair users (currently only 2 of 15 Subway stations are), as well as setting world-leading standards for the bus network, including live on-board route announcements and visual displays. This is vital for ensuring that policies in ‘7.3 Managing demand for car travel’ do not have a disproportionate negative impact on disabled people.
P.A2 Affordable transport
Bus fares in our region are far too expensive! This is why I was one of more than 5,000 people who signed the Fair Fares Now petition which was submitted to SPT on 30 September 2022 to be considered as part of the RTS consultation.
I hope that the outcome of this petition will be clear commitments from SPT in the RTS to using its new powers to regulate, reduce and simplify fares for everyone.
In order to meet the RTS’s Targets (to reduce car kilometres by 20% by 2030 and to ensure 45% of journeys are not made by car by 2030), it is clear that using public transport must always be cheaper that driving. This is key to delivering the policies in ‘7.3 Managing demand for car travel’.
I am therefore disappointed that the RTS currently only commits to “more affordable transport” for certain groups: “people living in poverty, in socio-disadvantaged communities and in rural and remote areas”.
Not only is this far too vague, but it also backs away from the clear commitments made in SPT’s 2021 Transport for Strathclyde paper to deliver an:
“Affordable Network – fair fares for all”
It is vital that this “fair fares for all” commitment is reinstated in the RTS.
I would also like to see more detail on SPT’s plans for a much simpler, fairer fare structure. This should include delivering an affordable daily/weekly price cap for journeys across all transport modes in the region, which works like the current £3.00 daily cap on the Subway. As well as rolling out a ‘hopper’ fare like in London – so you can travel on as many buses as you need to within an hour for just £1.65.
A single on unregulated First Glasgow is currently £2.65, and you need to pay double that if you have to change buses – this is why we urgently need SPT to deliver “fair fares for all”.
P.A3 Availability for transport
As well as ensuring that public transport is always cheaper than driving, to deliver the RTS’s Targets, SPT must also drastically improve the service. This means ensuring there is a comprehensive bus network, which connects all our communities, and regular and reliable services at all times of day/night and weekends, which connect seamlessly with trains, Subway and ferries.
The only way SPT can deliver this is by using the new powers available to it to re-regulate the region’s bus network and to set-up a new publicly-owned bus company for Strathclyde – so that SPT can control all timetables, routes and service standards.
The RTS makes the vague commitment to “Ensure a minimum level of active travel and public transport coverage for all areas in the region to key locations”. This is not good enough. I want to know what ‘minimum level’ SPT is actually committing to.
SPT should instead reinstate the commitment made in its Transport for Strathclyde paper to deliver a:
“Public Transport Guarantee: recognising that access to the public transport network is as vital as any utility, new standards would be developed around access to the network.”
This ‘Guarantee’ can then become the foundation for delivering a public transport system like that in Switzerland, where even the smallest village is guaranteed by law a bus service at least every hour, 6am-midnight, 7 days a week.
7.5 Enhancing quality and integration of public transport
As a frustrated public transport passenger in Strathclyde, I could not agree more with the aim of “enhancing the quality and integration of public transport” – this is long-overdue, particularly as bus services have continued to deteriorate, rather than improve.
What is lacking from this section of the RTS however, is a clear strategy for how to deliver this.
P.PT4 Bus quality and integration
Central to enabling SPT to deliver and fully-integrated and affordable public transport network, is being able to plan and control the bus network to reach all our communities, and to connect seamlessly with trains, Subway and ferries.
The new powers in the Transport Act 2019 – for ‘franchising’ and for setting-up a new publicly-owned bus company for Strathclyde – finally offer SPT the ability to do this, yet the draft RTS makes no clear commitment to using them!
Instead the RTS makes the incredibly vague statement that SPT will: “Facilitate development of bus partnerships, bus franchising and municipal bus operations where appropriate.” This implies a worrying lack of understanding from SPT of the key difference between these three powers.
Bus ‘partnerships’ have been around in Scotland since the Transport Act 2001 – more than 20 years. And they have proved to be completely ineffectual in delivering fully-integrated and affordable public transport. Crucially this is because in a ‘partnership’ each bus company still controls its own network and runs services on its own terms to make a profit for its owners.
This is why the former UN Special Rapporteur for Extreme Poverty & Human Rights, Philip Alston, concluded in his 2021 report into the UK bus sector that:
“It is time partnerships are recognised as a tried-and-failed approach that should be retired in favour of actual regulation of public transport.” p.33
SPT’s own research – the Glasgow & Strathclyde Transport Act Scoping Study (written by Systra and published in February 2022) also concludes that so-called ‘Bus Service Improvement Partnerships’ (BSIPs) are “unsuitable for delivering cheaper and fully-integrated fares”. They are therefore a complete dead end. All reference to bus ‘partnerships’ must be removed from the RTS’s policies and should not be pursued by SPT any further.
Instead, the Systra Study shows that bus ‘franchising’ is “suitable for delivering transformational change in bus infrastructure, bus services and fully integrated/simplified bus fares”, and that this power can and should be used in tandem with the power to establish a new publicly-owned bus operator for Strathclyde.
The Systra Study recommends that SPT sets-up a new, small public operator immediately (between August – December 2022). This would save SPT money in the medium-term by enabling it to run supported services in-house, rather than putting them out to tender and being held to ransom by private operators’ bids. It would also ensure that we have a public-sector operator up-and-running to take over parts of the re-regulated network once ‘franchising’ is rolled out.
SPT’s Transport for Strathclyde paper also commits to:
“integration and planning cross-modally, as well as ensuring network reach which spans from urban to rural and everything in-between… it’s time for one single-brand – Strathclyde Buses – linking rail, ferry, Subway and active travel in every part of the region” (p.16)
Unless these policies are clearly stated in the final RTS, I will lose all faith that SPT knows what it’s doing or has any real ambition to actually “Enhance the quality and integration of public transport”.
8.2 Governance
The draft RTS presents the vague plan to “hold discussions with our local authority partners to consider optimal transport governance arrangements that support the region’s environmental, social, economic and health goals.” This does not constitute a long-term strategy.
As I have made clear in my comments above, if SPT fully-utilises all the powers now available to it, this will mark a massive step-change in transport governance in Strathclyde, with most aspects of the network coming back into SPT’s control.
I expect the RTS to clearly articulate this and to make the case for why SPT is the public body best placed to take forward the transformational change our region’s public transport network requires, because:
- SPT is democratically-accountable, with representatives from all 12 of our region’s constituent councils on its board. It provides the ideal platform for local authorities to collaborate, to share costs, risks and opportunities and to deliver much-needed regional connectivity across local authority boundaries.
- SPT is also an award-winning transport operator, running a regular, reliable and affordable service on the Subway. It therefore has the expertise necessary to take on running more of the bus network, which our individual local authorities do not.
The RTS’s section on governance must make this case to the Scottish Government in order to leverage more funding for our region. SPT must raise its ambitions.
8.6 Funding the RTS
Improving public transport is vital for meeting our climate targets and reducing poverty and inequality across our region. SPT must use the opportunity presented by the RTS to make the case for much greater investment from the Scottish Government, as well as demanding that all funding which Transport Scotland currently gives directly to private bus companies (i.e. the Network Support Grant, National Concessionary Card payments and the ScotZEB scheme to buy new electric buses etc. which currently total more than £326million annually) is channelled through SPT so that it can decide how best to spend it to deliver the best quality services for our region.
Running buses under a privatised and deregulated model is a completely inefficient use of public money, as profits leak out of the system rather than being re-invested in expanding and improving the network.
I want to SPT to present a clear case for how much money could be saved in the long-term by bringing buses back into public control, and by having greater public ownership in the system.
SPT must also be considering new revenue raising measures (such as the road user charging and Workplace Parking Levies powers now available to it) – but it is essential that these are presented as part of a clear vision for how funding will be ring-fenced and spent in order to deliver transformational change to our public transport network. The RTS – in its current state – does not provide this.
I look forward to some major revisions to this document before it is finalised and sent to the Transport Minister for approval, in order to restore my faith in SPT.
Yours sincerely,
