Submission by the
Coach Tourism and Transport Council of Ireland
The National Transport Authority
Bus Rapid Transit (BRT)
Core Dublin Network
7 March 2014
1. Background to the CTTC
The Coach Tourism and Transport Council of Ireland (CTTC) is the representative organisation for Ireland’s coach touring companies, and private coach and bus operators. All of our members are family-owned companies with a combined fleet of over 1,000 coaches, and we employ over 2,000 people directly. The CTTC comments and makes representation regularly on matters of concern to its members such as public transport, school transport, the coach tourism sector and the tourist industry generally. Our members have been to the forefront in providing safe, effective, cost efficient and high quality public transport in the Greater Dublin Area since 1932 without any form of subsidization from the state.
The CTTC welcomes the opportunity to make this submission and also would support any initiative which would increase capacity, reduce journey times and achieve a significant model shift from private cars.
Following an examination by our members of the BRT document we are however of the opinion that this proposal will not achieve these stated objectives. We believe that this study is fundamentally flawed and that the proposal will represent poor value for money, displace private sector enterprise and is will not address the core issues and is in essence, totally unnecessary. More targeted cost effective options are readily available by working in partnership with private enterprise.
2.1 Value for Money
The Authority is under a statutory obligation to have regard to cost-effectiveness and value for money in the discharge of its functions. The BRT system in our view does not represent value for money when consideration is given to the significant disruption; large scale infrastructural works will cause its negative environmental impact and the significant cost to the Exchequer.
2.2 Cost Benefit Analysis
When the above is taken into consideration the disadvantages by far out-weigh the benefits of this short to medium quick fix solution. No detailed cost benefit analysis has been carried out to date and no comparative analysis of this proposed model versus a partnership alternative with private sector bus operators coupled with a series of targeted measures including enhancement of bus stops, QBC’s, priority at junctions, new park and ride facilities and co-ordinated marketing.
2.3 Displacement of Private sector operators
Phase 1 of the project; the proposed Swords to City Centre link by the admission of this report will not satisfy the projected demand which has levels that exceed a modern BRT system. Should the proposed first phase of the BRT system i.e. namely the Swords to City Centre link go ahead, there may be implications for the state in terms of litigation by way of introduction of a subsidised state BRT system competing with already existing commercial services.
While we concur with the report that there is a requirement for increased service provision through to 2030 assuming there is no provision of any light rail system, CTTC would be of the opinion that the proposed BRT system will not deliver value for money and not meet these requirements. Therefore in our opinion the continued usage of existing transport service and their improvement would be more a cost effective option. In addition the report is misleading by not clearly stating that current public transport deficits are being met by private sector operators.
2.4 Segregation using Quality Bus Corridors
To optimise the efficiency of the BRT concept in the Greater Dublin Area, there would need to be full segregation of this mode of transport from other traffic users however the current proposal promotes a moderate capacity BRT system operating within the designated QBCs on the proposed routes.
The proposal outlined the possible exclusive use of QBC’s by the BRT services. This would in essence further compound the displacement of private operators by increasing private service journey times, running costs and competitiveness and in turn creating conditions to squeeze private operators out of the market. The proposal also references looking at routes on a case by case basis. No further evaluation is needed to come to conclusion that removal of private operators from a QBC will result in a combination of reduction in attractiveness of their services and in extreme cases gridlock and have serious implications for the commercial viability of these services.
2.5 Journey times
A strong argument for the introduction for BRTs in the report has been that journey times would be significantly cut. However in an independent survey of journey times on the current transport services on the Swords to City Centre route found the reduced time would amount to six minutes approximately. Furthermore, the same survey found that the majority of passengers using the current transport service were satisfied with the quality and range of services offered by the existing transport providers.
2.6 Automated Ticket vending at bus stops
In Section 2.4.2 (Stops) of the report it states “all stops should be identified by name and clearly displayed. Stops should come as standard with high quality features, such as surfacing, shelters, automatic ticket vending machines and passenger information displays, CCTV systems, and audio systems”. It is the view of the CTTC that if these improvements were made to the existing infrastructure there would be significant improvement in the delivery of the service and the public perception of it.
Proposals to reduce boarding times by the provision of off-bus fare collection and off-vehicle ticket validation and interface with traffic control signals to ensure preferential treatment of buses at junctions and actuation of the green light at signalised junctions upon detection of an approaching bus could also be introduced immediately to increase the competency and quality of existing services.
2.7 Effectiveness of branding and marketing
In Section 2.4.8 (Attractiveness) this document states that “attractiveness is of key importance to any public transport system that is trying to achieve a modal shift from the private car. Branding and marketing are a fundamental aspect of most successful BRT systems”. However we in CTTC would contend that the various branding campaigns by different government departments including the NTA to increase awareness of public transport facilities and reduce car usage have been far from successful.
In summary the CTTC concludes that;
· This project needs a full economic appraisal and cost benefit analysis carried out prior to any further consideration.
· The core issue of displacement of existing private sector operators along the proposed BRT routes has not been fully taken into consideration and the project as presented if progressed would clearly displace private operators servicing these routes leading to loss of jobs.
· Alternatives to a state run BRT service have not been seriously examined and the capacity of the private sector to deliver additional capacity service is not documented.
· Investing a large capital amount in temporary infrastructure is imprudent when alternative measures at much lower costs could effectively deliver equal results. Vehicles could be provided at little or no cost to the taxpayer by private sector bus operators and would represent excellent value for money at a time of austerity.
· Measures to improve journey times along existing route corridors would represent prudent investment of scarce resources. These could include automated ticketing at stops, park and ride facilities, improved QBC’s, priority at junctions.
· Private sector operators would embrace the opportunity to play a critical role in increasing capacity along BRT proposed routes and in coming up with a series of practical solutions to improve journey times.
· The report state on page 72 that the feasibility study demonstrates a clear public sector transport deficit in terms of capacity along the routes outlined. It omits to state that this deficit has been filled already by the private sector at no cost to the tax payer. We would ask the question why replace this with a system that would put enormous additional project development and ongoing running costs on an economy already crippled in debt.