Wednesday, October 9, 2013

Response to NTA consultation on gradual opening of competition in bus markets from 2016

Sirs/madams,
I support the gradual approach to competitive tendering that the NTA is proposing. Time is needed to allow the state operators to adjust and downsize their operations as a more competitive market emerges -but of course, we must make a start somewhere and the sooner the better.

However, I think the current proposal lacks a means to continue the current advantage of allowing profitable routes subsidise PSO routes. At present, PSO routes are subsidised by subvention, but also by cross-subsidisation from profitable routes. The funding model for PSO routes at present is not replicated in these 2 proposals which simply propose to put a portion of less profitable routes out to tender, without cross-subsidisation from the profitable routes. The result could be higher subvention to make the PSO routes viable. It would also leave the state operators with a more profitable basket of routes.

Therefore, I think that we must consider levying the profitable routes in order to supplement subvention. In particular, imposing a levy from 2016 when the transition occurs. Otherwise, we will be asking bidders to provide the PSO routes with only part of the financial support the PSO routes enjoy at present. This could result in a poorly subscribed tendering process robbing the whole project of credibility.

Eventually we need to arrive at a system where profitable routes are auctioned and the proceeds used to boost subvention of unprofitable routes.

Secondly, the use of fixed assets -stops, stations and depots, needs to be guaranteed to all. There would be no advantage of having new contractors replicating existing infrastructure. A reasonable contribution towards the maintenance and use of these facilities needs to be part of the tendering process. More importantly, sharing of these services with the private operators needs to be part of the renewed contract signed by the state operators.
sincerely

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