Why is the DfT not listening – and briefing?
In my conversations with CPT members and staff, I am aware that, although the CPT was caught out by the sudden inclusion of registered home-to-school services in BODS – which drags coach operators into very useful scheme for bus services – it has for some weeks been explaining the problems this creates.
For that reason, it is inexplicable that Ben and Lisa, representing the scheme, seemed surprised at the nature of the objections. Let me be clear; I do not think the blame for the chaotic nature of the on-line event falls to them. The DfT has plenty of staff who understand road transport law, for whom all of the operators’ objections would have made sense. For some reason, nobody at the DfT thought to brief Ben and Lisa on the likely criticisms they would face and how to defend them.
In the guidance document in October of last year it said: ‘Services that are out of scope of legal requirements for data publication include those operating under Section 19 or Section 22 permits, coach services, tour services, dedicated school services and heritage vehicles.’
Make no mistake, the DfT had specifically exempted home-to-school services from BODS. In the guidance document in October of last year it said: ‘Services that are out of scope of legal requirements for data publication include those operating under Section 19 or Section 22 permits, coach services, tour services, dedicated school services and heritage vehicles.’
The duties of BODS are quite onerous, involving providing accurate geodata for stops, timetabling, fare structure and, in January, real-time vehicle location. This is expensive and time-consuming, and serves no purpose at all in the context of school buses, since the public for whom this data is intended cannot travel on them. Furthermore, providing the precise details, to the minute, of when a small child is dropped off in winter darkness on a rural road is dangerous, and schools should be told this is what the DfT is proposing to do.
BODS could be applied to only those services which are eligible for BSOG, but there is no social reason why home-to-school services should be registered with the Traffic Area Office; the legislation is hung up on the point that fares are taken but as the intention of Section 6 is to monitor provision of regular bus services, this is irrelevant in the context of H2S. If the DfT rushes through a change to remove the need for school service registration (and other contracted, closed-door services) it can resolve this quickly.
At the same time, BODS can include registered services run under Section 22 Community Bus Permits, as these definitely do need to be in scope.