So, what does a punctual bus service look like? Featuring “We hate early running…”
24 April 2015
The Senior Traffic Commissioner (STC) has just published her revised, statutory, guidance on bus punctuality – important stuff as this is what compliance is measured against.
It is important this reflects passenger expectations – we did research that informed the whole consultation process. This research broadly backed up the up to five minutes late and one minute early rules.
So it is good to see this rule re-affirmed in the new guidance. Earlier in the STC’s consultation process up to seven minutes late and one minute early was proposed, so the continuation of the status quo is something of a success. Our basic stance in our consultation responses was to have a realistic figure – i.e. one that is practicable, rather than one that looks good on paper. We also emphasised passenger angst at early running. Our research is clear that this is the sin – and early drafts of the guidance also reflected this, referring to it as ‘pernicious’ and something to be avoided.
Outside of that the main thrust of the new guidance seems to be the adoption of a ‘reasonable endeavours’ approach when it comes to compliance. Operators have the ability to come up with a ‘reasonable excuse’ for failing to meet targets. Such a definition may be better for lawyers, who've made a living out of defining ‘reasonable’, but its vagueness can often be harder for observers and stakeholders.
However, and to me this is where the document suddenly comes to life and takes on real value, the STC has effectively set out what ‘reasonable’ looks like. The Annex to the guidance sets out examples of good practice . It may be worded in terms of it being a ‘checklist’ and things the STC would ‘expect to see’, but by being a detailed list it does rather create a benchmark against which ‘reasonable endeavours’ can be assessed. Some of these were dotted about in the original guidance, but they have now all been brought together into a single list.
Rather encouragingly we can see what we have asked for throughout the Annex. It encompasses many of our recommendations from our bus punctuality research project, as well as other statements. For example:
- the timetable needs to be realistic
- more use made of electronic bus service registration.
- use automatic vehicle locaters where available
- monitor performance (utilising drivers and roadside monitoring) and keep sufficient records to demonstrate that there is proper monitoring
- publish punctuality targets
- share data with local transport authorities
- have dedicated resource of service performance management
- have proper systems in place for doing something about problems
- have a proper complaint handling process in place to deal with complaints from passengers
- consult with passengers to understand preferences between simplicity, speed and punctuality.
There’s a high degree of read across with our bus punctuality work, especially about the importance of gathering good performance data and having dedicated resources available to analyse it and do something about it. Including these aims – even in an Annex – gives them some power. If you do not do the things listed in the Annex then how can you demonstrate that you have taken reasonable efforts to comply?
It also feels like it is a step forward in culture as well in that the vision of what a good operator looks like also takes into account engagement with passengers (i.e. asking their views on priorities/preferences, complaints handling and data transparency). This fits with our ‘bus passenger power’ arguments about improved transparency and empowering bus passengers.
The guidance also provides for a useful hook as to why the industry should come to our planned bus punctuality road shows later this year which will focus on what we have learned from our local case studies alongside hearing from the traffic commissioner and Transport Focus about our wider work for bus passengers.
There is certainly scope for more in this regard, but it feels like a positive move. It would have been easy for technical guidance to focus solely on technical issues of gathering and analysing data. So a warm welcome for this from Transport Focus.