Citizens Advice welcomes the opportunity to respond to the Department for Transport’s consultation on strengthening bus passenger representation.
The CAB service is a network of 432 independent advice centres providing free, confidential and impartial information, advice and advocacy from over 3,000 locations in England, Wales and Northern Ireland. In 2006/07 the CAB service dealt with around 5.7 million new problems across a range of subjects, including 4,200 on public transport.
Although bureaux do not deal with many problems about public transport, it is clear from CAB evidence that affordable and frequent bus services are important to many CAB clients in order to get to work or to access public services, but these are not always available, as the following cases show:
A CAB in Hampshire reported that a widow aged 67 sought advice about finding a replacement NHS dentist as her current dentist was about to retire. She lived in a rural area and did not drive, and so was dependent on public transport. However there were a limited number of bus routes from her home to nearby towns and villages. The CAB contacted NHS helplines, but could find nothing within 10 miles of her home. The nearest dentists only took private patients. As the client was on a limited income, she could not afford this.
A CAB in Northumberland reported that a woman aged 67 suffering from breast cancer and other health problems lived in an outlying village. She did not drive and relied on public transport to get to local towns about ten miles away to do her shopping. There were only two buses a day going through her village. In order to do her shopping, she had to get the first bus to the nearby town, do her shopping in 30 minutes, and then having to fill in several hours before she got the bus home. She found this exhausting in her condition.
Bureaux also report that bus and coach companies do not always provide a good level of customer service:
A CAB in Essex reported that a man needed to catch a bus from his home town to get to Stansted Airport. However, the scheduled service did not run from its normal stop resulting in him missing a vital, coach connection to Heathrow for which he had paid in advance. In order to arrive at Heathrow in time for his plane, his wife had to drive him all the way and incur petrol and parking charges which the bus company refused to reimburse even though it had failed to notify users of the change of pick-up point. The coach company also initially refused to refund the pre-paid for the Stansted to Heathrow journey. When the problem was taken up with the bus and coach companies, they denied any responsibility and hid behind 'terms and conditions', maintaining they were not liable for extra expenses caused by delayed or cancelled services. The CAB eventually persuaded the coach company to refund the pre-paid fare as a 'goodwill gesture'.
Citizens Advice welcomes the government’s intention to provide a national statutory representative body for bus passengers with the capacity to influence bus services. We are concerned that the current provision of non-statutory bodies is too piecemeal to form an effective voice on behalf of bus and coach travellers.
If bus and coach services are to meet the needs of their passengers, it is vital that they are adequately represented. We believe that the good communication envisaged in paragraph 10a can only be realised if the proposed new body has authority. Without this, the competitive environment between bus/coach companies will always take precedence over the consideration of the views and needs of passengers.
We now turn to the questions posed in the consultation paper.
Q1a Do you agree with the aim of our proposal?
Q1b Do you feel that the body should cover any items not included above?
Q1c Do you think that there are any items covered above that shouldn’t be?
Citizens Advice broadly agrees with the aims of the proposed bus watchdog as set out in paragraph 11 of the consultation document. However, we disagree with the statement in paragraph 16, that the new watchdog should not handle complaints. We believe that the watchdog should also be empowered to take up complaints on behalf of passengers, if the bus or coach company does not handle these properly. The complaints would form a useful evidence base to campaign for improvements to bus and coach services and to help the organisation focus on where more in-depth research is needed.
If the new bus watchdog does take on complaints-handling, it needs to learn from other second-tier complaints handling services and ombudsman services to find how to best support for the most vulnerable passengers to make a complaint. In particular the Department for Transport may wish to look at the findings of the Hunt Review of the Financial Ombudsman Service (FOS) which will be published shortly. One of the issues examined in the review is how FOS can become more accessible for vulnerable people, particularly those on lower incomes, who have a complaint about the financial services industry.
We also believe that although the primary focus of the watchdog should be national, it is vital that it also has a regional and local focus, given that, outside London, there is no overall regulator of bus services, and these services are often run on a local or regional basis.
We also believe that it is vital for any bus passenger watchdog to be seen to be independent, if it is to have any credibility with passengers.
Q2a Is option 1 your preferred option and why?
Q2b Do you have any further comments on the role that existing non-statutory bodies may have in representing the interests of bus passengers?
Citizens Advice believes that option 1 would not deliver the aims of the proposed bus watchdog set out in this consultation document. In our view, legislation is needed to ensure that the watchdog is properly resourced and the passengers’ voice is heard and taken account of. Two of the non-statutory bodies are funded and linked to the bus industry, so may lack independence, which we feel is vital to the success of bus passenger representation.
We do not agree with the assertion in paragraph 24 of the consultation that a non-statutory body is more likely to be able to resolve problems in an informal manner than a statutory one. In our experience, energywatch, a statutory consumer voice for fuel consumers, has been able to negotiate solutions with energy companies for the problems of many fuel customers. We also believe that there is a need for the watchdog to become a statutory second-tier complaints handler, which would not be possible if option 1 were chosen.
We have no comments to make on the role of existing non-statutory bodies in representing the interests of bus passengers.
Q3a Is option 2 your preferred option and why?
Q3b What do you think should be the key features of the statutory bus passenger champion body?
Option 2 is preferable to option 1 as it puts the watchdog on a statutory basis. However, a watchdog which covers users of all types of public transport, including light rail and ferry services (which have no passenger representation of any kind at the moment), would be the ideal and would help encourage better integration between different public transport services.
We have highlighted in our answer to question 1 the essential duties for an effective bus passenger watchdog.
Q4a Is option 3A your preferred option and why?
Q4b What changes do you think will be needed in order for Passenger Focus to take on bus work?
Q4c Do you have any further comments on the role that Passenger Focus might take in relation to bus travel?
Q5a Is option 3B your preferred option and why?
Q5b How you do you think that we can ensure that there is no duplication between this committee’s interest in rail and that of Passenger Focus?
Citizens Advice believes that options 3A and 3B are the best options for a bus passenger watchdog out of all those proposed in the consultation paper. We consider that, of the two options, expanding the remit of Passenger Focus to cover users of all types of public transport outside Greater London seems the most suitable. We believe that this would encourage better integration between different public transport services, and it seems to us that this organisation already has the expertise to represent passengers effectively.
We do not agree with the proposal in paragraph 35 that should Passenger Focus become the bus passenger watchdog, it should not extend its current complaints handling service for rail passengers to bus and coach passengers, as this would be inequitable. We have highlighted in our answer to question 1 the need for the new bus passenger watchdog to learn from other consumer groups and complaints handling services how to provide an effective complaints handling service for all consumers.
If Passenger Focus is to become an effective watchdog for bus and coach passengers, as well as continue to represent the views of rail passengers, two further changes are necessary to its current ways of working:
- Resources focused on research - We agree with the Campaign for Better Public Transport that users of bus services are likely to be from more marginalised groups, and therefore may be less likely to complain about poor service. It will therefore be important for the watchdog to spend more of its resources on undertaking research on bus services, than is necessary for rail services, if the views of bus users are to be adequately represented.
- A regional presence – As decisions about bus and coach services are taken at a regional and local level, whereas decisions about rail services are taken at a national level, Passenger Focus would need regional offices to adequately represent the needs of bus passengers. We note that Passenger Focus only has offices in London and Manchester at present.
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