Evidence from Bus Users UK


Transport for Wales is the delivery arm for Welsh Government transport policy. As such, it is important that the future development of TfW truly recognises the challenges and opportunities for transport in Wales.

Bus Users UK therefore welcomes the opportunity to respond to the Economy, Infrastructure and Skills Committee inquiry into the future development of Transport for Wales.


1.       The consultation asks whether the current governance, structure and funding of Transport for Wales are effective and transparent

Transport for Wales (TfW) was set up to be the delivery arm of Welsh Government Transport policy. Whilst TfW has the ability to make independent operational decisions, Welsh Government still controls the overall goals and performance at a strategic level.

We consider that the governance, structure and funding are reasonably transparent, accepting the control relationship between Welsh Government and TfW. However, we would like to see further transparency.  In order to establish if the governance, structure and funding are effective, we would like to see more accountability and appropriate scrutiny of actions and decisions.

2.     The consultation asks what action should be taken to develop these aspects of the organisation? What other governance models and good practice are available?

The obvious comparison is with Transport for London (TfL). 

One area where TfW can learn from TfL is in the transparent way in which TfL conducts its board meetings.  Whilst TfW publish notes of their board meetings, these meetings are not open to members of the public to attend as an observer. TfL publishes a notice of the date, time and venue for meetings on this website as well as at TfL head office and the meeting venue. The meetings are held in public unless information that is exempt from publication needs to be discussed. All papers (unless exempt from publication) are published five clear working days before each meeting. TfL board meetings are also recorded and webcast live. We would like to see TfW adopt similar practices to become more transparent.

TfL publishes and publicises an annual report, presenting an objective and easily readable account of activities, achievements, financial position and performance. We would like to see TfW adopt this approach, combined with a series of road shows to key stakeholders to highlight success. One such event would be a presentation at the annual Welsh Bus Summit.

Public focus

Of particular concern is the apparent lack of public focus by TfW. Whilst this has improved recently with TfW attending events and explaining what they are doing and hope to achieve, most members of the public have little idea what TfW is and what its purpose is. Bus Users UK is concerned at the lack of opportunity for members of the public to engage with TfW. The Minister recently made a decision to bring the Public Transport Users Advisory panel (of which Bus Users UK was a member) to a close. The rationale for the closure of the panel is that it was considered that the topics discussed sat better within the TfW advisory architecture. While there is an argument to be made for this, we are concerned at the lack of independent user input into the process. This needs to be urgently addressed.  

Returning to comparisons with TfL, it has in place arrangements designed to encourage individuals and groups from all sections of the community to engage with, contribute to and participate in its work. We would urge TfW to develop a plan to improve its public engagement and user input options.

3.     The consultation requests input on the future role of Transport for Wales in delivering transport policy. What additional responsibilities should it take on and how should these integrate with the role of the Welsh Government, local Government and emerging regional transport authorities?

TfW is beginning to look at bus services. We understand that three work streams have been developed tasked with feeding into the business plan to be completed in March 2019.

       Ticketing and Back Office

       Integrated Responsive Travel

       National Bus Network

We welcome the stated interest of TfW in improving bus services and making them more accessible to all bus users. Over the past two years, parts of North Wales in particular have seen drastic changes to the bus services network due to various factors. This has caused significant hardship for a number of bus users, particularly those in rural areas who have seen service frequencies dramatically reduced or even lost. Bus services in rural areas are a lifeline for many. The bus plays a key part in enabling people to play a full part in society. Maintaining rural bus networks will be an important challenge for TfW. Bus Users UK has been working on this issue for some time and is happy to advise on addressing the problems, as follows. 

Rural Bus Networks

Particular groups of people rely on bus services more than others. They can be characterised as:

a)     Young people, pre-driving age, mostly associated with journeys to school, training or weekend jobs

b)    Young adults, often increasingly now choosing not to either learn to drive or own a car

c)     Younger adults going out in groups for social or leisure activities

d)    Adults or families with insufficient disposable income to own and use a car

e)     Adults who have lost their driving licence for one of the 182 current medical reasons listed by DVLA

f)       Adults who have temporary suspensions to their driver’s licence

g)     Older people with cars who make optional trips by bus using free bus passes

h)    Very elderly people for whom the bus is the only form of mobility and contact with other people.

 The reliance that each group of people has on bus services will differ, as it will between urban and rural isolated communities. Based on the analysis above, those in groups a, d and h are most impacted by standards and levels of service provision whereas those in b, c, e, f and g are less so, not least because statistics suggest the majority will have or could choose to have access to private cars or taxis. However, a good quality bus service which is attractive to them also serves the more vulnerable groups better as well, so growing their use benefits the whole of society in a way that targeting only the more vulnerable does not.

The provision of services to isolated communities is increasingly fragile, as local authorities reduce expenditure, especially in this budget heading. It is not a statutory requirement, although it is generally assumed that the original legislators would not have envisaged a situation in which a local authority would consider a social need, understand the devastating impact of not providing it and choosing not to do so. As the legal requirement is only to consider the social implications of reduced or no bus services, more and more Local Authorities are choosing to target their resources elsewhere and shrug their shoulders at the problems left behind, until the Adult Social Care budget has to be increased to deal with the consequences. This is an untenable situation and the requirement could swiftly be reworded in order to make it a statutory duty, a change which would be welcomed by many Local Authorities.

The model of provision of bus services is increasingly now making delivering services to isolated communities more fragile too. As funding has reduced, so regulatory cost pressures, especially those concerning Community Transport operators, have increased. This is causing unprecedented problems for those attempting to provide any kind of transport service for isolated communities, especially rural ones and has increasing potential to cause real social isolation with attendant health and welfare consequences. We would suggest that it would be timely to trial a new model of provision in selected geographical areas, reducing the more onerous regulatory barriers for a period to encourage new providers in the chosen areas. Radical though it may sound, the community interest or cooperative model has had many successful examples in the public house trade and community shop/post office operations.

Using a not-for-profit model such as a social enterprise, community cooperative or Community Interest Company could develop a new style of community-based transport provision. This would offer a new option which addresses the safety and driving competence concerns of mainstream operators, while also limiting the opportunities to become a direct competitor to a commercial operator, an area of concern often expressed.

TfW could also model the social and economic impacts in an area which has had a complete withdrawal of bus services, ask for and examine any suggested new model(s) in practice and publish and use this to inform its bus strategy. We also believe it would be in the interests of communities if TfW would make special provision for local authorities to take temporary control of service provision in an area where there is wholescale withdrawal by commercial operators, with the regulatory authorities tasked with ensuring that sufficient discs are available, in a timely manner, to plan and deliver replacement services. This would serve to reassure communities whose residents fear the complete loss of transport options when a main operator announces a large withdrawal of service.

Passenger Representation

Bus Users UK is the independent representative body for bus users in Wales.

Bus Users UK is highly respected for its work in Wales. It is critical that there continues to be an independent voice for the passenger and Bus Users UK is the obvious choice for this.

We have extensive knowledge of the bus sector in Wales. 

Through our Your Bus Matters events programme, we understand what passengers in Wales think about and require from their bus services.

Our Bus Compliance Officers perform a vital role in monitoring services and driving up standards of service provision within Wales.

We understand the varying barriers to people using bus services and what can be done to overcome them.

About Bus Users UK

We are an approved Alternative Dispute Resolution (ADR) Body for bus and coach passengers, and the body dealing with complaints under the European Passenger Rights Regulation (Outside London). These rights will continue beyond Brexit. 

We have worked closely with the Department for Transport to advise on passenger rights, the passenger involvement aspects of the Bus Services Act 2017, the detail of the proposed Accessible Information Regulation and all other matters where input on behalf of passengers is needed. 

We have worked closely with Welsh Government for many years to advise on transport policy, current practice and new ideas. We also deal with Welsh bus passengers complaints which come either directly from the passenger or via their Assembly Members, and we work alongside communities to try to make the case for continuing service provision and subsidy. We also hold regular events in rural and urban settings throughout Wales to enable residents to make local transport providers and policymakers understand their needs and the impact of poor transport on people at risk of social exclusion. We employ 3 bus compliance officers who conduct roadside monitoring, often as a result of complaints received. They also supply evidence when the results of the monitoring result in a Public Inquiry led by the Traffic Commissioner.