Cynulliad Cenedlaethol Cymru	National Assembly for Wales
Pwyllgor yr Economi, Seilwaith a Sgiliau	Economy, Infrastructure and Skills Committee
Datblygu Trafnidiaeth Cymru yn y dyfodol	The future development of Transport for Wales
EIS(5) FDTfW21
Ymateb gan Cyd-ffederasiwn Cludwyr Teithwyr Cymru	Evidence from Confederation of Passenger Transport Wales

Cydffederasiwn Cludwyr Teithwyr Cymru/The Confederation of Passenger Transport Wales (CPTCymru) is the professional trade association of the bus and coach industry in Wales and is part of CPT UK. Its members in Wales include operators forming part of large multinational transport operators, municipally owned operators, medium sized independent operators and small family businesses. CPTCymru members provide over 70% of all public transport journeys made across Wales. The bus and coach industry as a whole employs some 5000 people throughout Wales, so, our members are often significant local employers, especially in the rural parts of Wales, and make major contributions to their local economies.

CPTCymru governance includes the Bus Commission Cymru, Coach Commission Cymru and also its Committee for Wales, which all members may attend; and members are consulted widely on the whole range of issues affecting road based public transport.

We are pleased to be able to contribute this submission to the inquiry by the Economy, Infrastructure and Skills Committee of the National Assembly for Wales into the future development of Transport for Wales. We have no objection to this being placed within the public domain, and we would be very happy to appear at a sitting of the Committee and provide oral evidence.

TfW was set up by the Welsh Government over three years ago, in 2015, but little was known about it, its aims or purpose or of its governance for its first years of existence. Its profile increased considerably, however, with the Wales & Borders Rail Franchise process and ultimate award, and, even moreso, since the highly visible launch of the new franchise in October 2018, and then by the disruption to the rail network immediately after the launch.

TfW’s public image has not had a particularly auspicious start, overshadowed by problems with the All Wales Rail Franchise at its launch in October 2018. Whilst the responsibility for some of these problems should not be laid at the door of TfW itself, the adverse publicity was, in part, brought on TfW itself, by its very high profile launch of the new franchise, poor management generally of public expectation before the franchise went live and attempts by TfW management to blame the previous franchise holder for the problems encountered after the handover in October 2018.

There is no public organizational chart of the structure of TfW, and very few staff are directly employed, most are consultants, with many having little knowledge of the bus industry, which is the area with which CPT Cymru is, of course, concerned.

With this background, TfW should learn from its experience before looking to extend its control over other modes of transport.

CPTCymru’s responses to the Committee’s specific questions are given below.

Whether the current governance, structure and funding of Transport for Wales are effective and transparent.

There is insufficient transparency in the relationship between the Welsh Government and Transport for Wales. This applies in all areas – policy making, responsibility for delivery and funding. Lines of control and accountability are equally ill defined. The role of civil servants in the transport function and their relationship with TfW is unclear and it may be more appropriate if the former undertook purely administrative roles under the TfW regime.

What is the organisation structure? Somewhat incredibly, the TfW Board does not include anyone who has been involved in any form of transport. How, therefore, can they question and probe the TfW Executive effectively, as they have no in depth knowledge of a transport undertaking? The perception is that TfW is, in effect, just a rail delivery agent.

This lack of clarity is acutely compounded from a cursory glance through some of the minutes of the TfW Board. Attendees have sometimes included WG staff, sometimes as observers, sometimes for specific agenda items. This lack of clarity has served to muddle the perceptions, by transport providers/professionals, members of the public and indeed politicians themselves. The decision by the Welsh Government not to send observers to TfW Board meetings, as detailed in the 21 November 2018 minutes is a welcome step in this.

What action should be taken to develop these aspects of the organisation? And what other governance models and good practice are available?

This does, in effect, follow on from the response to the previous question. Clear divisions of responsibility need to be established. The Welsh Government could learn from the Scottish model which is clear in that Transport Scotland is responsible for implementation of all policy and funding decisions taken by the Scottish Government, in addition to development of its own initiatives to ensure successful implementation of these. Perhaps this is simply a function of its having been established longer and for the bodies to have established clear working protocols and a division of functions.

The future role of Transport for Wales in delivering transport policy. What additional responsibilities should it take on and how should these integrate with the role of the Welsh Government, local government and emerging regional transport authorities?

There is a need for policy direction to be deployed to assist and guide local and regional authorities, to share best practice and to ensure consistent application of relevant standards. The paucity of suitably experienced and skilled staff at all levels is a serious concern and there is a need to recruit a directly employed senior team that can bring strong leadership and direction to transport policy for the country.

Transport is inextricably linked with infrastructure and land use planning, and whilst responsibility for the latter area is likely to remain with the local or regional authority, the former could be undertaken at the national level to improve consistency, decision making and adoption of best practice. As for the latter, TfW should at least have an increasing contribution into land use planning policy, as this is where transport provision often begins.

Integration of transport and highways functions at the national level would deliver much of this benefit, but guidance on development control will also need to be provided to the lower tier authorities. Strong policy guidance from TfW at a national and local level will be needed to ensure that transport is fully integrated with the health, education and social care functions in respect of planning and funding of services (in the widest sense of the word) and day to day decisions. Finally, administration of concessionary travel reimbursement at a national rather than local level would most likely lead to significant cost savings and ensure consistency across local boundaries.

Conclusion:

TfW cannot be a policy maker and delivery agent, it is one or the other. If it is an agent of delivery then it should be able to contribute toward policy decisions, to influence objectively the policy makers. As shown above, this should include contributing to land planning and highways obligations and coordinating the LTP.

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In essence, WG need to decide what the purpose of TfW is if the LAs retain all of their current powers and, through bodies such as the City Regions, are stronger than TfW. We then have a blurred situation where accountability is difficult to pin down; in effect, who is doing what? This will serve only to add the lack of clarity and transparency, and lines of responsibility or understanding of the remit for TfW will remain unclear.

In summary, CPTCymru are strongly of the view that whatever is decided, there needs to be clear and transparent activity that is within the public domain with full FOI Act implications, and with clear responsibility, accountability, powers, funding, objectives, leadership and governance.