Committee for Regional Development
Transport Bill
Response to the Invitation for written submissions
on the clauses of the Transport Bill 2010
16 August 2010
The Community Transport Association
The CTA is a national charity giving voice and providing leadership, learning and enterprise support to member organisations, which are delivering innovative transport solutions to achieve social change. CTA UK promotes excellence through providing training, publications, advice and information on voluntary, accessible and community transport.
Voluntary and community transport exists to meet the travel and social needs of people to whom these would otherwise be denied, providing accessible and affordable transport to achieve social inclusion.
The CTA is the representative body for third sector passenger transport operators in the UK. CTA Member organisations are involved in the provision of transport, especially accessible services. Our membership consists of 1400 organisations.
CTA response to the Transport Bill clauses
The CTA welcomes the opportunity to contribute to The DRD Committee’s considerations on the clauses of the proposed Transport Bill 2010.
Contact Details
Any queries regarding this response should be directed to:
Kellie Armstrong
Director for Northern Ireland
Community Transport Association
Room 109, CityEast
68-72 Newtownards Road
Belfast
BT4 1GW
028 9094 1661
Email: kellie@ctauk.org
1. The CTA has reviewed the content of the Transport Bill 2010 and propose the following considerations be addressed before the Bill is presented
2. The CTA congratulates the informed and progressive approach taken throughout the Bill. There are however areas where legislation and policy development of other government departments may make parts of this Bill obsolete
3. Section 6 (1) (e) the need for ensuring fair completion among persons providing public passenger transport services - The CTA would ask regard is made to allow provisions for innovative, non-economical routes that could be delivered by not-for-profit, community transport providers operating under the s10b permit regime. By its nature, not-for-profit transport delivered by and for the community remains outside commercial competition rules. The validity of transport routes on the basis of competition is mute in areas where there will be low patronage but much needed access links will ensure social exclusion and rural isolation are addressed.
4. Section 6 (2) (b) The CTA recommends consideration should be sought from the local community. By taking into account community need the Transport Bill will ensure isolation and exclusion zones are not created through ‘cherry picking’ of economically advantageous routes.
The CTA plays an integral role in supporting community led transport planning. We would urge the Transport Bill to include the CTA alongside the Consumer Council in representing community issues.
5. The Bill refers to revocation, suspension and curtailment of permits (Section 10) or disqualification of permit (Section 11) – it does not however state clearly how transport can be delivered during times when transport is affected by the above. Section 11 (6) states while a permit is suspended no alternative services may be provided through that permit. CTA would encourage an additional clause is included to allow the Department to continue transport provision through issue of a temporary permit to enable another supplier to deliver transport services in the interim and until the original permit is out of suspension or awarded to an alternate supplier.
6. Section 33 (2) The reference to the ‘section 10b permit’ may be mute. The DoENI Review of Operator Licensing (June 2010) proposes a fundamental change in licensing arrangement for all community and voluntary sector transport provision. The consultation proffers the DoE’s preference to remove in its entirety the s10b bus operating permit replacing it with a yet confirmed Community Licence Tier 3 and a semi commercial license Tier 2. Given the high level of community outrage and concern over the proposal to decimate community led transport solutions it is expected DoE will restructure proposals and reissue a new consultation autumn 2010. This could have impact on the progress of the Transport Bill.
7. Section 35 The CTA congratulates the Department’s consideration to provide a grant in support of advice, information, support or training. The CTA has particular investment in this clause as without provision the advisory, legal and technical services of CTA could not be funded. There is no other funding available for a regional transport infrastructure body through DoE, DSD or any other government department.
8. Interpretation Section 47 (b) refers to the section 10b permit which may or may not exist post 2010. |
