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Submission on Government Policy Statement on Transport 2018

Name, the organisation you are submitting feedback on behalf of (if relevant) and your address:

Peter Dowden, co-president, Bus Users Support Group Otepoti-Dunedin, c/o 12 Woodhaugh St, Dunedin 9010

The GPS helps guide investment in transport by providing a longer term strategic view of how we prioritise things in the transport network, and why. We welcome your thoughts on all elements of the draft GPS however there are some parts of the GPS we would like to draw your attention to:

The strategic direction The draft GPS has four strategic priorities; access, safety, environment and value for money. • Safety and access have been given higher priority than the other priorities. We are interested in feedback on this prioritisation. Investment in land transport • Funding has been reprioritised to reflect the new strategic direction for land transport. • There are two new activity classes; rapid transit and transitional rail.

Bus Users Support Group Otepoti-Dunedin supports all of the above changes to policy

Please provide any further comments you may have:

School transport

We support the following GPS objective regarding school transport:

"Section 2.3.2 Access Objective: GPS 2018 supports investment in:...projects focused on increasing the uptake of children using safe and active travel, especially to and from school."

We note that many rural areas have a Ministry of Education free school bus while most urban areas do not. This causes disparity and is unjust as school transport assistance is not provided based on need or affordability, rather only based on rural versus urban location. This creates pockets of privilege and deprivation.

Ministry of Education school buses are often the only form of transport in small rural communities, but non-pupils are not encouraged to use them even when there is spare capacity. The rural school bus network has potential to be expended at slight incremental cost to become of far greater use to all people in rural communities.

On the fringes of urban areas, school buses are inefficiently provided in parallel with urban buses (which may have spare capacity) and commercial school buses. There is no integration across the three types of transport where great efficiencies could be possible

Bus Users Support Group Otepoti Dunedin asks that responsibility for school transport be transferred from education authorities to transport authorities and be fully integrated with the rest of the public transport system, including allowing passengers other than eligible pupils to travel at a reasonable fare where spare capacity exists. We accept that school pupils attending their in-zone school should have priority where capacity is constrained.

Ministry of Education allows non-accessible school buses to be used on school runs. This is unfair and illegally discriminates against pupils with disabilities, requiring them to travel segregated from their peers. There are plenty of super low floor urban buses ready to enter "semi retirement" and these could have a good second career as school buses, perhaps with overhauls and engine emission upgrades.

Bus Users Support Group Otepoti Dunedin asks that the importation or manufacture of non-accessible school buses be immediately banned We accept the continued use of existing buses before their life expiry, provided they are redeployed on to routes with no special accessibility requirement.

Bus Users Support Group Otepoti Dunedin asks that Special Education School Transport Assistance ("Sesta") for pupils with disabilities be offered in the first instance on accessible school buses, so that peers are not segregated according to their disability. We accept that some whanau may prefer to use the Sesta vans.

Accessibility for bus users

There have been huge gains in accessibility and safety resulting from the Requirements for urban buses. Wheelchair accessibility forms the "gold standard" for physical accessibility as it usually implies accessibility for people with impaired walking ability, luggage, small children or prams as well. But there are problems when a $300 000 bus arrives at a $100 bus stop which may have poor road marking and signage, kerbside obstructions or poor pavement height or quality. We are not realising the full potential of accessible buses due to our inaccessible bus stops. The NZTA has produced Guidelines for public transport infrastructure and facilities which would resolve all these issues, but the trouble is, they are guidelines, not requirements.

Long-distance and charter coaches are not required to be accessible and this discriminates against those least likely to have any other alternative such as car travel. In this day and age it is ridiculous that non-accessible long-distance, tour, sightseeing and charter coaches are allowed to be imported or newly-manufactured.

Bus Users Support Group Otepoti Dunedin asks that the NZTA Guidelines for public transport infrastructure and facilities be made compulsory requirements for bus stop design on all public roads, thereby requiring all roading authorities to reinstate bus stops and build new ones in accordance whenever roads are maintained or built.

Bus Users Support Group Otepoti Dunedin asks that the NZTA Requirements for Urban Buses be adapted to include accessibility requirements for long-distance, tour, sightseeing and charter coaches, and that an immediate ban be placed on importing or manufacturing non-complying coaches.

Road safety of bus users

The whole door to door journey needs to be workable for public transport users. Every bus stop needs a safe method of crossing the road; this may be simply by having a good road alignment requiring no extra aids to pedestrian safety, or, where needed, central pedestrian refuges or kerb protrusions right up to zebra crossings, traffic lights, underpasses or overbridges.

Bus Users Support Group Otepoti-Dunedin asks that the route between origin/destination of bus users and their bus stops be safe in accordance with World Heath Organisation's WHO Healthy Cities programme

Public Transport governance

We note the benefits of unified management of public transport by roading authorities that exists in Auckland, Gisborne and Invercargill and the cooperative management in Queenstown. Unified and cooperative management makes sure public transport "fits" on roading networks, and that managers of buses and roads are not undermining each other's work.

Bus Users Support Group Otepoti-Dunedin asks that Government encourage further close integration of public transport management with roading authorities to enable continuous improvement of public transport. Note that this should include NZTA integrating long-distance land transport into its state highway network, so that proposals to upgrade rail passenger trains or coach routes can be made alongside highway proposals.