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Submission to the ORC on the proposed changes to the Dunedin bus service publicly notified on 28 November 2013.

by

Bus Go Dunedin: Bus Users Support Group Ōtepoti Dunedin

20 December 2013

Our mission is to advocate for bus users, and to promote the establishment and maintenance of fast, clean, efficient, low-cost public transport in Otepoti Dunedin.

While acknowledging that public transport is currently the Otago Regional Council's responsibility, Bus Go Dunedin notes that public transport is a vital component of the Dunedin City Council's vision for Dunedin as "one of the world's great small cities", and a key part of the DCC's Integrated Transport Strategy 2013. The DCC's 2011 Your City Your Future consultation found that "the Dunedin community sees improvements in public transport services as a top priority for transport in Dunedin." Bus Go Dunedin considers that, to be effective, changes to the bus service must be made in the context of the Dunedin City Integrated Transport Strategy

Bus Go Dunedin regards the goals, objectives, principles, and policies outlined in the ORC's Public Transport Plan as a sound basis for growing the patronage on Dunedin's bus service. To assist the ORC in its decision making, we have tested the proposed changes against these goals, objectives, princlples and policies. 

Summary of Bus Go Dunedin's submission

These points will reappear in the text below, in bold type.

  • Because effective public consultation is a significant factor in helping the ORC achieve its target of public satisfaction with the standard of service, Bus Go Dunedin requests:
    • that consultation on changes affecting University routes be reopened in the new academic year with invitations extended to students and staff of Logan Park High School, Otago Polytechnic and University of Otago;
    • that passengers with print disabilities be advised of future consultations via notices on local radio and messages to organisations such as the Royal New Zealand Foundation of the Blind;
    • that when changes are made to one part of a bus route, the ORC make every effort to ensure that bus users on the entire route, and on connecting routes, are informed;
    • that the ORC recognise complaints from the public and low bus patronage figures on specified routes as important forms of consumer feedback requiring prompt and constructive responses.
  • Bus Go Dunedin requests that ORC be cognisant of its duties under the Public Transport Management Act 2008, New Zealand Bill of Rights Act 1990, Human Rights Act 1993 with regard to transport disadvantaged persons and persons with disabilities.
  • Bus Go Dunedin urges the ORC to give high priority to repairing the damage done to the Corstorphine bus service, and to restoring the credibility of the ORC, by reinstating the main features of the Corstorphine bus service that operated prior to 1 July 2013. We appreciate that this may not be any easy task. Bus Go Dunedin would welcome the opportunity to work constructively with the ORC to address this challenge.
  • Bus Go Dunedin requests that ORC takes particular care not to reduce services in upper Ravensbourne, Harwood, Harington Point
  • Bus Go Dunedin supports the ORC's proposal to re-package the Garden Village bus service as the "Ross Creek" service to promote the bus as a means to recreation opportunities in the Ross Creek lake and forest areas.
  • Bus Go Dunedin requests that the Harington Point bus service be extended to Taiaroa Head, to make it more commercially viable.
  • Bus Go Dunedin requests that Harwood and Harington Point bus services be run separately, perhaps by alternating each service from Portobello to either of the two destinations, rather than trying to serve both areas with one route.
  • Bus Go Dunedin supports ORC's moves to ensure that bus timetables keep buses moving to maximise revenue and productivity. We ask that ORC give particular attention to deleting waiting times from the middle of routes.
  • Bus Go Dunedin requests that regular "Express" services, serving stops only on State Highway 88, be included in any review of the Port Chalmers route, while continuing to serve all the settlements along the harbour with a local "all stops" service.
  • Bus Go Dunedin requests that extra time be added to both the Peninsula and Waverley bus timetables to provide more manageable service speeds and improve passenger comfort, safety and timekeeping , as part of this service review.
  • Bus Go Dunedin supports ORC's proposal to increase the frequency of buses at busy times.

1: Format and timing of ORC's consultation

The consultation opened after University of Otago students had completed their studies for the year and many had left the University and city. Students of Otago Polytechnic and Logan Park High School were completing their exams and winding up their school year. We are advised that Logan Park High School was not made aware of the proposals and therefore was unable to circulate information in its school newsletter. Yet the University, Polytechnic and Logan Park area is greatly affected by the proposed changes.

In other parts of the city, on-board posters and newspaper advertising were more likely to be effective. However, we are advised that visually impaired passengers were not made aware of the consultation period and were left to "word of mouth" to be made aware.

We feel there would be advantages in ORC consulting directly with leadership of affected bodies: Logan Park High School, Otago Polytechnic and University of Otago and the tourist industry on Otago Peninsula.

Because effective public consultation is a significant factor in helping the ORC achieve its target of "public satisfaction with the standard of service", Bus Go Dunedin requests:

  • that consultation on changes affecting University routes be reopened in the new academic year with invitations extended to students and staff of Logan Park High School, Otago Polytechnic and University of Otago;
  • that passengers with print disabilities be advised of future consultations via notices on local radio and messages to organisations such as the Royal New Zealand Foundation of the Blind;
  • that when changes are made to one part of a bus route, the ORC make every effort to ensure that bus users on the entire route, and on connecting routes, are informed;
  • that the ORC recognise complaints from the public and low bus patronage figures on specified routes as important forms of consumer feedback requiring prompt and constructive responses.

2: Transport disadvantaged people/persons with disabilities

Bus Go Dunedin notes that people with disabilities, and people who live in households without access to a motor vehicle, are disproportionately disadvantaged by cuts to their bus services.  Bus Go Dunedin therefore urges the ORC to observe its legal responsibilities in this regard, and to take particular care not to cut services to areas where transport disadvantaged people live.

The Public Transport Management Act 2008 states: "transport disadvantaged means people whom the regional council has reasonable grounds to believe are the least able to get to basic community activities and services (for example, work, education, health care, welfare, and food shopping)"

The Human Rights Act 1993 states (1): "For the purposes of this Act, the prohibited grounds of discrimination are— (h) disability, which means— (i) physical disability or impairment: (v) any other loss or abnormality of psychological, physiological, or anatomical structure or function: (vi) reliance on a guide dog, wheelchair, or other remedial means:"

The New Zealand Bill of Rights Act 1990 states: 19 Freedom from discrimination (1) "Everyone has the right to freedom from discrimination on the grounds of discrimination in the Human Rights Act 1993."

The New Zealand Bill of Rights Act 1990 states: 3 Application "This Bill of Rights applies only to acts done— (b) by any person or body in the performance of any public function, power, or duty conferred or imposed on that person or body by or pursuant to law."

Bus Go Dunedin requests that ORC be cognisant of its duties under the Public Transport Management Act 2008, New Zealand Bill of Rights Act 1990, Human Rights Act 1993 with regard to transport disadvantaged persons and persons with disabilities.

Bus Go Dunedin has reviewed all aspects of the proposed cuts and changes. Our analysis includes identifying the percentage of households without access to a motor vehicle on the affected bus routes using data from the 2006 census (comparable data from the 2013 census is not yet available).

Bus Go Dunedin notes that, in Appendix 3 of the Otago Regional Transport Plan 2012, the ORC equates transport disadvantage with disability. Bus Go Dunedin applauds the ORC's willingness to recognise and address the transport needs of people with disabilities, but we believe the ORC's failure to extend that recognition to the thousands of able-bodied Dunedin residents who rely on public transport is not in accordance with the Public Transport management Act 2008 which defines "transport disadvantaged" as "...least able to get to basic community activities and services..." All transport disadvantaged people, not just those among them who have disabilities, want a bus service that enables them to contribute fully to the economic, educational, social and cultural life of our city.

Bus Go Dunedin is confident that any initiatives to recognise and address the needs of all transport disadvantaged Dunedin residents, both disabled and able-bodied, will not only establish a core patronage of frequent, regular and loyal passengers who use the bus out of necessity: the convenience of the service will encourage other potential patrons to use the bus by choice. Conversely, changes and cuts of any sort have a disproportionately severe flow-on effect on the lives of transport disadvantaged bus users, on bus patronage, and on the economic life of the entire city (people late for work, hospital appointments missed, meetings cancelled, and so on).

2a: Localities of concern

Corstorphine

Following the bus service changes of 1 July 2013, complaints to the ORC about the Corstorphine routes rose 130%, and patronage fell 30%. This response reflects the importance of a reliable bus service to all the transport disadvantaged people of Corstorphine. The complaints focussed on four main issues:

  • the delays and disruptions caused by the addition of unwanted and unneeded diversions through Sutcliffe St and St Clair Close;
  • the complex and confusing timetable, and the irregular departure times, which make figuring out where and when to catch a bus an infuriating and ongoing struggle;
  • the route and timetable changes that have eliminated the regular, convenient, predictable and heavily-used loop service that transport-disadvantaged Corstorphine residents relied on "to get to basic community activities and services (for example, work, education, health care, welfare, and food shopping)". 
  • the termination at the Octagon of a service formerly used by passengers to travel to Moana Pool or Wakari Hospital, and from supermarkets and shops further north.

The recent Bus Go Dunedin meeting held to discuss the proposed bus service changes was attended by what can only be described as an angry mob of Corstorphine residents. They are distressed that the ORC's only response to their complaints about the 1 July changes is to propose further cuts to their service. They want their pre-1 July bus service reinstated.

Bus Go Dunedin urges the ORC to give high priority to repairing the damage done to the Corstorphine bus service, and to restoring the credibility of the ORC, by reinstating the main features of the Corstorphine bus service that operated prior to 1 July 2013. We appreciate that this may not be any easy task. Bus Go Dunedin would welcome the opportunity to work constructively with the ORC to address this challenge.

Bus Go Dunedin is concerned that the ORC's credibility has been severely damaged by the widespread dissatisfaction resulting from the 2013 changes to the Corstorphine bus service. We  urge the ORC to address the current dissatisfaction before making any further changes.

We recognise that contractual obligations may prevent a re-connection with the Helensburgh service, and offer the suggestion of extending Corstorphine to City services from the Exchange to Countdown and the Centre City New World terminus, thence back to Corstorphine along George St.

We note that a transfer ticketing system would go some way to restoring the journey opportunities lost on this route.

Upper Ravensbourne, Harwood, Harington Point

Bus Go Dunedin notes that Upper Ravensbourne, Harwood and Harington Point all have a significant proportion of households without access to a motor vehicle.

Bus Go Dunedin requests that ORC takes particular care not to reduce services in upper Ravensbourne, Harwood, Harington Point

3: Increasing bus patronage

Many of the proposed service changes under consultation amount to cutbacks. Bus Go Dunedin considers that the needs of passengers must remain paramount, and that any changes likely to reduce patronage are counter-productive. Bus Go Dunedin offers the following suggestions for increasing patronage and improving the viability of the bus service.

Bus Go Dunedin supports the ORC's intentions for setting public transport service hours and frequencies as outlined in the Otago Regional Public Transport Plan 2012, and notes that low patronage and complaints about bus services often reflect the ORC's failure to turn its own stated intentions into reality. In particular, Bus Go Dunedin supports the ORC's intention stated in the 2012 plan to:

  • "ensure easily learnt and understood routes and timetables".
  • "operate services at times people travel".
  • "ensure reliability by having routes that bus drivers can readily learn".
  • "simplify timetables to assist in the production of accurate timetable information after any change in routes and services."

3a: tourism

Ross Creek

Bus Go Dunedin supports the ORC's proposal to re-package the Garden Village bus service as the "Ross Creek" service to promote the bus as a means to recreation opportunities in the Ross Creek lake and forest areas.

Harington Point

Including an extension of 1.3km on the route from the Harington Point terminus to the Royal Albatross Centre at Taiaroa Head would enable the ORC to market this route to tourists, thereby making it much more commercially viable. Zone boundaries could be loaded on to the new section to maximise revenue. This genuine "meet the locals" service would be particularly attractive to independent travellers/backpackers who usually avoid packaged sightseeing tours, so there need be no adverse effect on the tourist coach industry. Encouraging more Peninsula tourists on to buses would also reduce traffic hazards caused by drivers of campervans on this unfamiliar route.

Bus Go Dunedin requests that the Harington Point bus service be extended to Taiaroa Head, to make it more commercially viable.

The current Harrington Point service is also inconvenienced as a result of being routed via Harwood. Harwood is simply not "on the way" to Harington Point, being up a long side road from the main route.

Bus Go Dunedin requests that Harwood and Harington Point bus services be run separately, perhaps by alternating each service from Portobello to either of the two destinations, rather than trying to serve both areas with one route.

3b: Service efficiency

Many routes are run inefficiently, with long, seemingly random halts halfway along routes. This ties up millions of dollars worth of buses, often with their engines running causing pollution, blocking light from shop frontages, detaining passengers on board a stopped bus during their journey and generally bringing the bus service into disrepute. However Bus Go Dunedin believes bus drivers need regular opportunities to use toilets or take refreshment during their duties.

Bus Go Dunedin supports ORC's moves to ensure that bus timetables keep buses moving to maximise revenue and productivity. We ask that ORC give particular attention to deleting waiting times from the middle of routes.

3c: Longer-distance commuting

Routes to satellite towns like Mosgiel and Port Chalmers seem designed to meet the needs of passengers along the route while neglecting through travellers. The end-to-end journey times on such routes are very slow and unlikely to attract motorists to the service. We understand that nothing much can be done about Mosgiel as that route is not under review, but we would like some Port Chalmers services to be sped up.

Bus Go Dunedin requests that regular "Express" services, serving stops only on State Highway 88, be included in any review of the Port Chalmers route, while continuing to serve all the settlements along the harbour with a local "all stops" service.

3d: Speed versus comfort

Peninsula, Waverley routes

The bus services to the Peninsula and Waverley run to very tight timetables in spite of their narrow roads with many hazards. Drivers are forced to make unacceptable compromises to balance timekeeping with passenger comfort and safety. This consultation and review of services, since it will require a rewrite of service specifications and contracts, provides an opportunity for timetable adjustments.

Bus Go Dunedin requests that extra time be added to both the Peninsula and Waverley bus timetables to provide more manageable service speeds and improve passenger comfort, safety and timekeeping, as part of this service review.

3e: Service frequency

Bus Go Dunedin supports ORC's proposal to increase the frequency of buses at busy times.

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