Bus Éireann PSO Competition question

horseburger

PickTheCherry wrote: »

What horseburger is outlining, is there is nothing to stop an operator dropping stops from routes such as those operated by JJ Kavanagh, Aircoach and Citylink and the public would then be left with no services and stranded by the roadside and would be unable to get to school, work or studies.

For example, there was nothing to stop Aircoach dropping the intermediate towns when they went non stop from DUblin to Cork but Bus Eireann still serve such towns because they are not interested in profit. JJ KAvanagh switched many of their services out of Towns and there was nothing to stop them despite the fact passengers in some cases lot their jobs.

I just have a serious doubt that other companies would be interested in operating the rural PSO routes, for example the rural PSO routes, that at the moment, are only operated by Bus Éireann.

This issue of the NTA being unable to stop operators from discontinuing to serve intermediate towns, on commercial services, was highlighted in the Oireachtas Transport debate on 22nd February 2017, in a discussion between Anne Graham of the NTA and Robert Troy of Fianna Fáil.

Robert Troy stated:

"Ms Graham has said the NTA's role in issuing licenses is to determine timetables and stopping places for licensed services. If somebody, be it Bus Éireann or a private contractor, gets a license based on certain timetables and stopping in certain locations, then goes back to the NTA and shows it is not commercially viable, what consequences can the NTA impose as an authority to ensure it carries out its obligations based on the application that it made?"

Anne Graham responded:

"It is their decision to make. If the service is not commercially viable, they are not obliged to continue with that service. They may make a decision to withdraw or amend their licence by reducing the stopping points or they may make a decision to withdraw their licence altogether. We have no way to stop that under the legislation. That is a decision made by the private operator itself".

Robert Troy stated in response:

"To be clear, there are no consequences for somebody who tenders for a particular route to service particular towns at particular times if they come back and say it is not commercially viable to continue. The NTA has no way of forcing them or penalising them. There are no consequences for them.

Anne Graham replied:

"I make the distinction that where services are tendered by us, any changes to the timetables are regulated by us and we make the decisions on that. Where there are licensed services, which are commercial services, that make a decision to withdraw, there are no consequences for the operator. There are consequences for us in terms of trying to ensure there are services to those communities if they are left without services. That is where we step in to try to ensure that, if there is a public service obligation in those areas, we provide the services for those communities".

http://www.oireachtas.ie/viewdoc.asp?DocID=34662&&CatID=127

http://oireachtasdebates.oireachtas.ie/Debates%20Authoring/DebatesWebPack.nsf/committeetakes/TTJ2017022200002?opendocument#C00100

Night Falls

horseburger wrote: »

This issue of the NTA being unable to stop operators from discontinuing to serve intermediate towns, on commercial services, was highlighted in the Oireachtas Transport debate on 22nd February 2017, in a discussion between Anne Graham of the NTA and Robert Troy of Fianna Fáil.

Robert Troy stated:

"Ms Graham has said the NTA's role in issuing licenses is to determine timetables and stopping places for licensed services. If somebody, be it Bus Éireann or a private contractor, gets a license based on certain timetables and stopping in certain locations, then goes back to the NTA and shows it is not commercially viable, what consequences can the NTA impose as an authority to ensure it carries out its obligations based on the application that it made?"

Anne Graham responded:

"It is their decision to make. If the service is not commercially viable, they are not obliged to continue with that service. They may make a decision to withdraw or amend their licence by reducing the stopping points or they may make a decision to withdraw their licence altogether. We have no way to stop that under the legislation. That is a decision made by the private operator itself".

Robert Troy stated in response:

"To be clear, there are no consequences for somebody who tenders for a particular route to service particular towns at particular times if they come back and say it is not commercially viable to continue. The NTA has no way of forcing them or penalising them. There are no consequences for them.

Anne Graham replied:

"I make the distinction that where services are tendered by us, any changes to the timetables are regulated by us and we make the decisions on that. Where there are licensed services, which are commercial services, that make a decision to withdraw, there are no consequences for the operator. There are consequences for us in terms of trying to ensure there are services to those communities if they are left without services. That is where we step in to try to ensure that, if there is a public service obligation in those areas, we provide the services for those communities".

http://www.oireachtas.ie/viewdoc.asp?DocID=34662&&CatID=127

http://oireachtasdebates.oireachtas.ie/Debates%20Authoring/DebatesWebPack.nsf/committeetakes/TTJ2017022200002?opendocument#C00100

That bit in bold is pretty crucial.
1. Timetables and service levels of tendered routes remain in the control of the NTA.
2. Timetables and service levels of licensed services are a matter for commercial operators.
3. Commercial services that are withdrawn are reviewed by the NTA and new PSO services are developed if required.

horseburger

Night Falls wrote: »

That bit in bold is pretty crucial.
1. Timetables and service levels of tendered routes remain in the control of the NTA.
2. Timetables and service levels of licensed services are a matter for commercial operators.
3. Commercial services that are withdrawn are reviewed by the NTA and new PSO services are developed if required.

The issue is, would it be any less expensive for a private company to operate a PSO route, than it is for Bus Éireann.

I just have a serious doubt that other companies would be interested in operating the rural PSO routes, for example the rural PSO routes, that at the moment, are only operated by Bus Éireann.

I guess we will find out in 2019.

Night Falls

https://www.rte.ie/news/ireland/2017/1123/922317-bus-eireann/

Looks as if BÉ wouldn't be averse to dropping services either.

horseburger

Night Falls wrote: »

https://www.rte.ie/news/ireland/2017/1123/922317-bus-eireann/

Looks as if BÉ wouldn't be averse to dropping services either.

I would imagine that that is just a threat from the CEO, to try to ensure "its cost reduction programme is rolled out as planned".

Night Falls

The hilarious thing in all of this is that while i'd support the tendering out of PSO services, if BÉ or Dublin Bus were to win the tender then I'd be happy for them to do it as they'd have won the job fairly. It's others on here who can't seem to accept that any other operator would be able to run a PSO service to the NTA's requirements, which smacks of self-interest.

horseburger

Night Falls wrote: »

The hilarious thing in all of this is that while i'd support the tendering out of PSO services, if BÉ or Dublin Bus were to win the tender then I'd be happy for them to do it as they'd have won the job fairly. It's others on here who can't seem to accept that any other operator would be able to run a PSO service to the NTA's requirements, which smacks of self-interest.

it's a question of whether other operators would be interested in operating such routes, and if it'd be any less costly to operate such routes in terms of the subsidy received.

A lot people don't like the fact that Bus Éireann receives support which includes a subsidy, but what evidence is there, that such PSO services would be any less costly to operate, if another company only operated these PSO routes, on the basis of getting that same support.

Night Falls

horseburger wrote: »

it's a question of whether other operators would be interested in operating such routes, and if it'd be any less costly to operate such routes in terms of the subsidy received.

A lot people don't like the fact that Bus Éireann receives support which includes a subsidy, but what evidence is there, that such PSO services would be any less costly to operate, if another company only operated these PSO routes, on the basis of getting that same support.

To be clear, I think BÉ and all public transport operators are perfectly entitled to get a subsidy for operating PSO services. But equally I believe that PSO routes operated by private operators should be be paid for carrying out those services, particularly as they don't get fare revenue. I really didn't think that was a particularly controversial position to hold.

horseburger

Night Falls wrote: »

To be clear, I think BÉ and all public transport operators are perfectly entitled to get a subsidy for operating PSO services. But equally I believe that PSO routes operated by private operators should be be paid for carrying out those services, particularly as they don't get fare revenue. I really didn't think that was a particularly controversial position to hold.

You seem to be trying to change the subject.

I never asked you if you thought any company was or was not entitled to a subsidy.

I asked if another company only operates a PSO route on the basis of receiving the support that Bus Éireann receives for operating its PSO routes, which includes a subsidy - and considering the criticism Bus Éireann receives is often on the basis that it receives a subsidy - would it be any less costly for any other company to operate such a service?

monument

horseburger wrote: »

I think you are doing your best to avoid addressing the specific examples I gave, and the routes, about which I specifically asked.:)

Why does that not answer the specific examples you gave?

The newer routes to/from Balbriggan, Ashbourne, Swords, Lusk, and other parts of Fingal, have, for example, a mix of different intermediate stops / terminus and frequencies.

monument

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GM228

devnull wrote: »

Out of that list in your last post, the only commercial operator who operates a comprehensive service in significant competition with a PSO operator is Swords Express and that service was licensed in 2007 and before the passing of the 2009 Road Transport Passenger Act.

Something I had forgot about, there was a High Court case in 2010 in relation to their second licence where competition with Dublin Bus was the issue.

http://www.bailii.org/ie/cases/IEHC/2010/H311.html

The case touched on the fact that state funding can't be given to a PSO operator who are in competition with a non-funded operator. It meant that SE could continue to operate, but DB would not be funded for the 41X.

To appreciate fully the background to the dispute, one other significant piece of information is relevant. The notice party is entitled to various subsidies for its services when its services do not compete with other non-subsidised service providers. Such subsidies were considered necessary if the notice party was to provide services on uneconomic routes to areas which were not heavily populated. The logic seems to have been that if there is competition in providing the service or in servicing the route, the argument for a subsidy would not hold up and indeed, such a subsidy might be anti-competitive. The parties agreed in submissions to the Court, however, that the dispute here does not primarily relate to the State subsidies given to the notice party, (which involves the question of E.U. law primarily) but rather is one where the applicant alleges that the decision taken by or on behalf of the Minister notified to the applicant by letter on the 17th August, 2009, is in breach of national legislation and, in particular, is in breach of s. 25 of the Act of 1958 quoted above.

Being a HC ruling the part in bold seems to settle the argument as to why commercial services can't compete with PSO services and why no licences would be issued to compete with PSO as it would mean PSO funding could not continue.

Also to note is that the ruling concerned licences and PSO funding in relation to pre the 2009 Act, as such it potentially raises questions regarding licences issued under the 1932 Act (as previously mentioned by Devnull) and competition with PSO routes.

devnull

GM228 wrote: »

Something I had forgot about, there was a High Court case in 2010 in relation to their second licence where competition with Dublin Bus was the issue.

http://www.bailii.org/ie/cases/IEHC/2010/H311.html

The case touched on the fact that state funding can't be given to a PSO operator who are in competition with a non-funded operator. It meant that SE could continue to operate, but DB would not be funded for the 41X.

Being a HC ruling the part in bold seems to settle the argument as to why commercial services can't compete with PSO services.

Although bear in mind that whilst the High Court case was heard in 2010, the issuing of said licenses and the proceedings date back to a time when the PTR Act 2009 had not been passed and the licensing regulations that are now in place did not exist.

Threfore case brought by Digital Messenger t/a Swords Express was in relation to licensing decisions that were made under the act dating back to 1932 Act and the the Road Transport Act 1958 rather than the current licensing system.

I would assume that the latest version of the licensing guidelines dated November 2010 that are underpinned by PTR Act 2009 takes into account this judgement.

horseburger

monument wrote: »

Why does that not answer the specific examples you gave?

The newer routes to/from Balbriggan, Ashbourne, Swords, Lusk, and other parts of Fingal, have, for example, a mix of different intermediate stops / terminus and frequencies.

I had asked specifically about the particular services and what would the reasons be, that those bus services were granted approval, and the response I got was a general response which did not address the particular services that I referenced.

I asked about those specific routes, because I had been asking if it is the case, that they got approval, because the routes are not identical to already existing services operated by Bus Éireann and Dublin Bus.

devnull replied that he did not make the argument about services being identical as a reason for refusal of proposed routes, and I replied by showing that in a previous discussion that devnull had used the argument of proposed routes being "identical" "or very similar", as being a reason for refusal of proposed services. https://www.boards.ie/vbulletin/showpost.php?p=103169052&postcount=2187

devnull stated:

"As part of the Public Transport Regulation Act of 2009 routes that were identical to an existing PSO service or very similar were not approved on the basis that on PSO routes ithe incumbent who gets PSO has an exclusive contract for that route".

On that basis I am asking - with reference to the complaint often made about Bus Éireann where some people suggest it has a monopoly on routes, where they try and suggest that no other company can operate a route where Bus Éireann operate, for example the 109 route mentioned in the first post in this thread - that it appears that Bus Éireann does not have a monopoly and that there would be nothing prohibiting any company from proposing and possibly getting approval, to operate to and from locations that are currently served by other companies, as long as their proposed services are different and contain intermediate connections not already served on other routes.

I asked the question of how the various bus services got approval to operate such services, in relation to the issue, that many people try to suggest that Bus Éireann has a monopoly on routes.

I gave those examples, of the services to and from Dublin, Balbriggan, Ashbourne, Swords, to indicate that it doesn't appear that there is anything prohibiting any other company from operating a route that covers towns already served by another company, as long as it can be shown that the proposed new service has different connections and different intermediate stops.

Dare I say it, it sounds like you agree with my suggestion, that the reason the Asbourne, Balbriggan, Swords and Fingal bus services were granted approval, is because they offer different connections to services that were already in operation by Bus Éireann and Dublin Bus.

devnull

horseburger wrote: »

I had asked specifically about the particular services and what would the reasons be, that those bus services were granted approval, and the response I got was a general response which did not address the particular services that I referenced.

I have repeatedly answered the questions in relation to how licensing works and have mentioned time and time again how the licensing system works, backed up by using the relevant paragraphs from the licensing guidelines that are underpinned by the PTR 2009 Act.

I asked the question of how the various bus services got approval to operate such services, in relation to the issue, that many people try to suggest that Bus Éireann has a monopoly on routes.

I have never used the word monopoly.

I gave those examples, of the services to and from Dublin, Balbriggan, Ashbourne, Swords, to indicate that it doesn't appear that there is anything prohibiting any other company from operating a route that covers towns already served by another company, as long as it can be shown that the proposed new service has different connections and different intermediate stops.

And I've explained to you time and time again that how an incoming commercial license application is judged when an existing route is present depends on whether the existing route is a PSO route or a commercial route and you have yet to acknowledge that this is absolutely key in how the NTA comes to a decision about whether to issue a license or not and is explicit in the NTA licensing guidelines.

The Swords Express route was granted under the 1932 Transport act and was subject to legal review, so again it's outside the scope of licensing guidelines that have been in place since 2009 for new services because the current rules did not apply when it was issued which has been explained to you several times so it's not relevant to a discussion on licensing since the 2009 Act was passed.

The other routes are limited service routes which generally operate the majority of their services in peak times and may offer something different from the PSO service. In addition because of this and the fact that they are limited services it means that they will not have as big of impact on the PSO services, therefore they are more likely to be licensed.

horseburger

devnull wrote: »

I have repeatedly answered the questions in relation to how licensing works and have mentioned time and time again how the licensing system works, backed up by using the relevant paragraphs from the licensing guidelines that are underpinned by the PTR 2009 Act.



I have never used the word monopoly.

And I

And I've explained to you time and time again that how an incoming commercial license application is judged when an existing route is present depends on whether the existing route is a PSO route or a commercial route and you have yet to acknowledge that this is absolutely key in how the NTA comes to a decision about whether to issue a license or not and is explicit in the NTA licensing guidelines.

The Swords Express route was granted under the 1932 Transport act and was subject to legal review, so again it's outside the scope of licensing guidelines that have been in place since 2009 for new services because the current rules did not apply when it was issued which has been explained to you several times so it's not relevant to a discussion on licensing since the 2009 Act was passed.

The other routes are limited service routes which generally operate the majority of their services in peak times and may offer something different from the PSO service. In addition because of this and the fact that they are limited services it means that they will not have as big of impact on the PSO services, therefore they are more likely to be licensed.

I never said that you used the word monopoly. I clearly stated earlier, that it was suggested earlier this year during the bus strike by a number of posters.

Are you saying that if a bus company applied to operate a service starting from Cavan and Virginia, that didn't serve either Kells, Navan or Dunshaughlin, but served Dublin, that it would be refused?

It could be argued by that company that its propsed service differs from the 109X Cavan service, and differs from the Donegal Dublin number 30 service, in that passengers on the proposed route wouldn't have to go through Kells, or go through Navan every two hours, or have to go to the airport.

Do you think that the companies that operate the limited service routes at peak times, would be inclined to operate services outside peak times, for example to and from Dublin much later in the evening, or even the rural local PSO services, if ever a situation arose where Bus Éireann ended?

If they only operated PSO routes on the basis that they got government support including a subsidy, would it be any less expensive to operate?

I ask this in relation to calls made by a number of posters during the bus strike, for the ending of Bus Éireann, and for all its routes to be operated by other companies.

devnull

horseburger wrote: »

Do you think that the companies that operate the limited service routes at peak times, would be inclined to operate services outside peak times, for example to and from Dublin much later in the evening?

Unfortunately the more comprehensive and similar the new commercial service is to the existing PSO service the less likely it would be to be licensed since the more services, the more significantly it will effect the efficiency of the PSO service and how significantly it effects the PSO service is a big factor considered when deciding whether to issue a license.

Every time a Public Service Obligation route has been offered to tender commercial operators have always bid to operate such routes and currently hold a number of contracts in this regard. You will note that six bidders made bids for the recent Waterford Network services so there is at least six companies who are willing to operate said services. Plus in addition M&A Coaches and Whartons also operate such services and shortly JJ Kavanagh will operate such a service.

When commercial operators have been able to run services on the same terms as Bus Eireann PSO routes, with access to the same benefits that come with a PSO service, they have always been interested.

horseburger

devnull wrote: »

Unfortunately the more comprehensive and similar the new commercial service is to the existing PSO service the less likely it would be to be licensed since the more services, the more significantly it will effect the efficiency of the PSO service and how significantly it effects the PSO service is a big factor considered when deciding whether to issue a license.

Every time a Public Service Obligation route has been offered to tender commercial operators have always bid to operate such routes and currently hold a number of contracts in this regard. You will note that six bidders made bids for the recent Waterford Network services so there is at least six companies who are willing to operate said services. Plus in addition M&A Coaches and Whartons also operate such services and shortly JJ Kavanagh will operate such a service.

When commercial operators have been able to run services on the same terms as Bus Eireann PSO routes, with access to the same benefits that come with a PSO service, they have always been interested.

Are you saying that if a bus company applied to operate a service starting from Cavan to Dublin, that also served Virginia, that didn't serve either Kells, Navan or Dunshaughlin, but served Dublin, that it would be refused?

It could be argued by that company that its propsed service differs from the 109X Cavan service, and differs from the Donegal Dublin number 30 service, in that passengers on the proposed route wouldn't have to go through Kells, or go through Navan every two hours, or have to go to the airport before Dublin City Centre.

devnull

horseburger wrote: »

If they only operated PSO routes on the basis that they got government support including a subsidy, would it be any less expensive to operate?

Bus Eireann operate PSO routes as they are contracted to do so by the state, given funding and assets to do so by the state. They're not running them out of the kindness of their heart and they probably wouldn't be able to anyway because the routes technically are owned by the NTA not Bus Eireann.

The fact that it was recently confirmed that Bus Eireann were not the cheapest in the recent Waterford City tender shows that it can be done for less even when profit is taken into account and when the commercial operator would have to acquire a depot, a cost that Bus Eireann would not have.

horseburger

devnull wrote: »

Bus Eireann operate PSO routes as they are contracted to do so by the state, given funding and assets to do so by the state. They're not running them out of the kindness of their heart and they probably wouldn't be able to anyway because the routes technically are owned by the NTA not Bus Eireann.

The fact that it was recently confirmed that Bus Eireann were not the cheapest in the recent Waterford City tender shows that it can be done for less even when profit is taken into account and when the commercial operator would have to acquire a depot, a cost that Bus Eireann would not have.

I never said that Bus Éireann run services out of kindness. I asked the particular question, to query if other companies would be interested in operating such routes, the routes that are currently operated by Bus Éireann.

devnull

horseburger wrote: »

Are you saying that if a bus company applied to operate a service starting from Cavan to Dublin, that also served Virginia, that didn't serve either Kells, Navan or Dunshaughlin, but served Dublin, that it would be refused?

I'm saying that the NTA would be required to consider if that service would significantly effect the efficiency of the existing PSO service and if it did they would not issue the license because that is what the guidelines say.

It could be argued by that company that its propsed service differs from the 109X Cavan service, and differs from the Donegal Dublin number 30 service, in that passengers on the proposed route wouldn't have to go through Kells, or go through Navan every two hours, or have to go to the airport before Dublin City Centre.

That's a very complicated question to answer because it involves a new commercial route, an existing commercial route and an existing PSO route and as such there is no straightforward way to answer that because there would be different considerations that would have to be given for the new commercial route against the PSO route and then separate additional considerations given for the new commercial route against the existing commercial route.

When there is an existing commercial route
In areas where Bus Eireann Expressway and where other commercial companies operate if another commercial company applied to operate later or more frequent services or services with different intermediate stops, it is possible their applications would be approved as long as they showed that they served terminus and bus stops not already in use on other competing commercial services and complied with time separation guidelines and there were not already two Interurban Express or Interurban services operating on the main artery of the route a license would be granted.

Where there is an existing PSO route
On routes where a Public Service obligation contract is in place, if a commercial company applied to operate another route, an application will only be considered if the NTA believed that this would not have a significant impact on the efficiency or provision of public service obligation routes that are presently operated and enhanced the services and connections available to that of the traveling public and would need to be time separated from the PSO service it is running alongside and from a different terminus and not share the same stops as the PSO operator.

As I've said before there is no one fits all answer - each application is judged on it's own merits under the PTR Act 2009 and the licensing guidelines which I've produced earlier in this thread.

monument

Re-reg troll banned and posts deleted again.

horseburger

devnull wrote: »

I'm saying that the NTA would be required to consider if that service would significantly effect the efficiency of the existing PSO service and if it did they would not issue the license because that is what the guidelines say.



That's a very complicated question to answer because it involves a new commercial route, an existing commercial route and an existing PSO route and as such there is no straightforward way to answer that because there would be different considerations that would have to be given for the new commercial route against the PSO route and then separate additional considerations given for the new commercial route against the existing commercial route.



As I've said before there is no one fits all answer - each application is judged on it's own merits under the PTR Act 2009 and the licensing guidelines which I've produced earlier in this thread.

But surely it could be argued that a service connecting Cavan and Virginia and Dublin City Centre, might not significantly affect the Bus Éireann 109X or number 30 services, in that, you would still have passengers using the 109X, because a lot of those 109X passengers would want to get to and from Cavan and Virginia and Kells and Navan, for whom neither the Bus Éireann Donegal Dublin number 30 bus, or a Cavan Virginia Dublin service would be an option, and you would still have passengers using the number 30 bus from Cavan and Virginia, who would be going to and from Dublin Airport?

devnull

horseburger wrote: »

But surely it could be argued that a service connecting Cavan and Virginia and Dublin City Centre, might not significantly affect the 109X or number 30 services, in that, you would still have passengers using the 109X, because a lot of those 109X passengers would want to get to and from Virginia and Kells and Navan, for whom the other service would not be an option, and you would still have passengers using the number 30 bus from Cavan and Virginia, who would be going to and from Dublin Airport?

Whether a service significantly effects the 30 service doesn't matter because the 30 is not a PSO route and is a commercial route so the commercial considerations will be applied and not the PSO ones.

As for the 109X, the guidelines in relation to significantly affecting a PSO service are more concerned with if a new commercial service would take passengers from the existing PSO service in the areas where it overlaps.

You continue to treat all routes as a collective when they are divided into two different categories which is completely paramount to this discussion and the decision making process with regards to bus licensing.

horseburger

devnull wrote: »

Whether a service significantly effects the 30 service doesn't matter because the 30 is not a PSO route and is a commercial route so the commercial considerations will be applied and not the PSO ones.

As for the 109X, the guidelines in relation to significantly affecting a PSO service are more concerned with if a new commercial service would take passengers from the existing PSO service in the areas where it overlaps.

Do you think a service connecting Cavan and Virginia to Dublin would significantly affect the 109X service, considering the 109X offers connections between Cavan, Virginia, Kells and Navan as well as Dublin, connections to Navan and Kells that wouldn't be available on a service to and from Cavan, Virginia and Dublin?

Another advantage of the Bus Éireann 109X and 109 services, over a service between Cavan, Virginia and Dublin, is that passengers at Cavan and Virginia on the 109X, who want to go to Dunshaughlin, could get out in Kells or Navan to connect with the Bus Éireann 109 to Dunshaughlin.

Another aspect is that passengers at Cavan and Virginia who want to go to Dublin Airport could get the 109X and then get the 109A in Kells or Navan, on occasions when the number 30 Donegal - Dublin Airport - Dublin City Centre bus is full or almost full when arriving at Cavan Bus Station.

(When the previous 109 Cavan Dublin was in operation, Cavan and Virginia passengers, going to and from Dublin, who might opt for the number 30 Dublin Donegal service, were requested to use the 109, when the 30 bus was almost full, for example, when leaving Bus Aras, on occasions when the number 30 bus was looking like it was going to fill, with passengers going further than Cavan.)

It is possible that if a Cavan Virginia Dublin service was operated, that it might not take certain passengers away from the Bus Éireann services.

devnull

horseburger wrote: »

Do you think a service connecting Cavan and Virginia to Dublin would significantly affect the 109X service, considering the 109X offers connections between Cavan, Virginia, Kells and Navan as well as Dublin, connections to Navan and Kells that wouldn't be available on a service to and from Cavan, Virginia and Dublin?

How many passengers do you reckon are using Bus Eireann PSO services from Cavan to Virgina, Virgina to Dublin, Cavan to Dublin and return?

It is possible that if a Cavan Virginia Dublin service was operated, that it might not take certain passengers away from the Bus Éireann services.

Are you saying that there are very few passengers using any Bus Eireann PSO service between Cavan and Virgina, Dublin and Cavan and Virgina and Cavan?

horseburger

devnull wrote: »

How many passengers do you reckon are using Bus Eireann PSO services from Cavan to Virgina, Virgina to Dublin, Cavan to Dublin and return?



Are you saying that there are very few passengers using any Bus Eireann PSO service between Cavan and Virgina, Dublin and Cavan and Virgina and Cavan?

No.

I am suggesting that, if a company started a service to and from Cavan, Virginia and Dublin, that perhaps it might receive approval for such a route, because if the concern is that such a service might impact on existing services, it could be argued that there would still be passengers who would continue to use the already existing 109X service, and perhaps the 109A service, because both the 109X, 109 and 109A would offer connections to and from Cavan and Virginia and Kells, to intermediate locations like Kells, Navan, Dunshaughlin, Raotath, and Ashbourne, with connections to Dublin Airport on the 109A, locations served on the 109X, 109 and 109A, that would not be served on a proposed route that would serve Cavan, Virginia and Dublin city centre.

devnull

horseburger wrote: »

No.

I am suggesting that, if a company started a service to and from Cavan, Virginia and Dublin, that perhaps it might receive approval for such a route, because if the concern is that such a service might impact on existing services, it could be argued that there would still be passengers who would continue to use the 109X service, and perhaps the 109A services, because it would offer connections to intermediate locations like Virginia, Kells, Navan with connections to Dublin Airport on the 109A, locations that would not be served on a proposed route that would serve Cavan, Virginia and Dublin.

How would you describe the number of passengers who were traveling between these places then if it is more than very few?

The adult single fare from Virgina to Dublin for instance currently shows as €17 on the Bus Eireann website which is a significant sum of money that Bus Eireann would be earning from these passengers.

horseburger

devnull wrote: »

How would you describe the number of passengers who were traveling between these places then if it is more than very few?

The adult single fare from Virgina to Dublin for instance currently shows as €17 on the Bus Eireann website which is a significant sum of money that Bus Eireann would be earning from these passengers.

devnull wrote: »

You continue to treat all routes as a collective when they are divided into two different categories which is completely paramount to this discussion and the decision making process with regards to bus licensing.

I was responding to the point you made before, about a consideration being, how a new service might impact on an already existing service.

I was suggesting that the existing service might not lose a certain amount of customers, who would be travelling to and from intermediate stops, if the new service does not serve those intermediate locations.

Do you think a service between Cavan, Virginia and Dublin would receive approval, perhaps with one of the considerations being that an already existing service would still retain passengers going to and from intermediate locations, that are not served on the new service?

I mentioned the number 30 Donegal route, because that service is used by people going to Dublin to and from Cavan, who also used to use the 109 Cavan Dublin services, and who now use the 109X Cavan Dublin services.

Bus Éireann knows that people in Cavan avail of both services, considering that they request that Cavan passengers use the other Cavan Dublin service, previously the 109, now the 109X, in times when the number 30 services are filling with people going between Cavan and Donegal Town.

I mentioned the Dublin Donegal number 30 service in relation to the fact that if you get it from Cavan and Virginia to Dublin, it stops at the airport before stopping in Dublin City Centre. I was highlighting the differences between the two existing services from Cavan, the 30 and 109X, and a service that would connect Cavan, Virginia and Dublin City Centre.

I mentioned it as another example, of where a new service that served Dublin City Centre, but did not serve Dublin Airport, might not impact on the number 30 bus in at least one respect, in that passengers in Cavan and Virginia going to Dublin Airport, would not take a new service to Dublin, that did not go to Dublin Airport because if they did, they'd have to get a separate service from Dublin City Centre to Dublin Airport.

On that issue of services from Dublin City Centre to Dublin Airport, what was the criteria used for giving approval for the Dublin Bus 747 service and the Aircoach Dublin City Centre Dublin Airport service?

Was the Aircoach service given approval on the basis that it serves different locations to the 747 service, or because it operates throughout the night, as opposed to the 747, which has a last service to the airport at 11.30pm each night?

http://www.dublinbus.ie/RTPI/Sources-of-Real-Time-Information/?searchtype=route&searchquery=747
http://www.dublinbus.ie/RTPI/Sources-of-Real-Time-Information/?searchtype=route&searchquery=747
http://www.dublinbus.ie/Your-Journey1/Timetables/All-Timetables/7471121/
http://aircoach.ie/timetables/route-700-dublin-airport-dublin-city-centre

devnull

horseburger wrote: »

I was responding to the point you made before, about a consideration being, how a new service might impact on an already existing service.

I was suggesting that the existing service might not lose a certain amount of customers, who would be travelling to and from intermediate stops, if the new service does not serve those intermediate locations.

Do you think a service between Cavan, Virginia and Dublin would receive approval, perhaps with one of the considerations being that an already existing service would still retain passengers going to and from intermediate locations, that are not served on the new service?

So you believe that a significant number of passengers would not be using PSO services between Virgina and Cavan, Virgin and Dublin and Cavan and Dublin and a more significant number would be using the services for other journeys and those between intermediate stops and other places?

I mentioned the number 30 Donegal route, because that service is used by people going to Dublin to and from Cavan, who also used to use the 109 Cavan Dublin services, and who now use the 109X Cavan Dublin services.

Bus Éireann knows that people in Cavan avail of both services, considering that they request that Cavan passengers use the other Cavan Dublin service, previously the 109, now the 109X, in times when the number 30 services are filling with people going between Cavan and Donegal Town.

I mentioned the Dublin Donegal number 30 service in relation to the fact that if you get it from Cavan and Virginia to Dublin, it stops at the airport before stopping in Dublin City Centre. I was highlighting the differences between the two existing services from Cavan, the 30 and 109X, and a service that would connect Cavan, Virginia and Dublin City Centre.

I mentioned it as another example, of where a new service that served Dublin City Centre, but did not serve Dublin Airport, might not impact on the number 30 bus in at least one respect, in that passengers in Cavan and Virginia going to Dublin Airport, would not take a new service to Dublin, that did not go to Dublin Airport because if they did, they'd have to get a separate service from Dublin City Centre to Dublin Airport.

The number 30 is not really relevant to this discussion in my book because this discussion is about new commercial routes competing with PSO services and the 30 is not a PSO route therefore how the 30 gets impacted is not at all relevant.

On that issue of services from Dublin City Centre to Dublin Airport, what was the criteria used for giving approval for the Dublin Bus 747 service and the Aircoach Dublin City Centre Dublin Airport service?

Was the Aircoach service given approval on the basis that it serves different locations to the 747 service, or because it operates throughout the night, as opposed to the 747, which has a last service to the airport at 11.30pm each night?

Again completely a red herring here because this route was issued almost 20 years ago under the 1932 Act which has since been replaced by the PTR Act 2009 and licensing guidelines last updated in November 2010. Therefore it has no relevance to a discussion in relation to current licensing guidelines because the license was not issued under them.

As for why the license was granted, you should consult the 1932 Act and the related 1958 Act and ask the Minister at the time because at that point there were no clear published guidelines and it very much was a decision made by the Minster at the time who was also later to the subject of legal challenges as indicated by GM228 earlier in the thread. By the way, the 747 timetable that is in place now wasn't the 747 timetable that was in place in 1999/2000 when Aircoach started up.

monument

To be clear the topic here is PSO competition.

Further discussion of commercial routes and routes issued under the 1932 act will be viewed as off-topic and disruptive posting. The differences have been explained enough and it’s time for the thread to move on without this dragging it off-topic.

— moderator

horseburger

devnull wrote: »

So you believe that a significant number of passengers would not be using PSO services between Virgina and Cavan, Virgin and Dublin and Cavan and Dublin and a more significant number would be using the services for other journeys and those between intermediate stops and other places?



The number 30 is not really relevant to this discussion in my book because this discussion is about new commercial routes competing with PSO services and the 30 is not a PSO route therefore how the 30 gets impacted is not at all relevant.



Again completely a red herring here because this route was issued almost 20 years ago under the 1932 Act which has since been replaced by the PTR Act 2009 and licensing guidelines last updated in November 2010. Therefore it has no relevance to a discussion in relation to current licensing guidelines because the license was not issued under them.

As for why the license was granted, you should consult the 1932 Act and the related 1958 Act and ask the Minister at the time because at that point there were no clear published guidelines and it very much was a decision made by the Minster at the time who was also later to the subject of legal challenges as indicated by GM228 earlier in the thread. By the way, the 747 timetable that is in place now wasn't the 747 timetable that was in place in 1999/2000 when Aircoach started up.

I am pointing out the differences between the existing services between Dublin and Cavan and detailing how a proposed route would differ from the existing services to and from Cavan. I was also pointing out the connections available with the existing services, that would not be available on a proposed route that served Cavan, Virginia and Dublin.

I am asking if such differences would be factors that might determine if a new service got approval or not. I asked this in relation to you saying earlier that any new service, would be considered, with regard to how it might impact on existing services, in this case the 109X and 109 and 109A services, which would be the services available to people going to and from Cavan and Dublin, where you would have people from Virginia and Cavan who would be going to and from Kells, Navan, or even Dunshaughlin, where people at Virginia or Cavan could connect with a 109 or 109A in Kells or Navan, if they wanted to go to and from Dunshaughlin.

I mention this connection option to and from Dunshaughlin and Virginia and Cavan with the 109X and 109 and 109A, because whenever there are timetable changes where a particular location ends up having less services - and in this case you can no longer get a service that starts and ends in Cavan and Dublin which drops off and picks up in Dunshaughlin - on the press releases issued, where it is stressed that such changes received approval from the NTA, where if one location is no longer served, it is usually emphasized what other connections are available to and from that location.

For example, this press release in November 2013, when Duleek was removed as a stop on the Drogheda Navan Trim service and it was no longer possible to get to Navan from Duleek on the Drogheda Navan Trim service.

Here is the relevant quote from the press release:

"From Sunday, 24 November 2013, revised Route 190/190A will no longer operate via Duleek. Customers wishing to travel from Duleek to Drogheda should now travel on Route 189/189A.
Customers wishing to travel from Duleek to Navan can either travel on revised Route 189/A and connect with our Route 190/190A service in Drogheda or travel on revised Route 189/189A service to Ashbourne and change to the connecting Route 109A service to Navan. The changes to Route 190/190A will come into effect on Sunday, 24 November 2013.
These changes have been approved by the National Transport Authority.
Wednesday, 13th November, 2013".

http://www.buseireann.ie/news.php?id=1394&month=Nov


You keep referring to guidelines in place at the time particular services received approval, and speaking in general rather than saying what the particular reasons were that specific routes were granted approval.

I have not contested anything of what you said about the guidelines that were in place at any particular time.

I just simply asked what you think were the reasons that specific routes were granted approval, and asked if it was because one service differs from another service.

That's a relevant question no matter what guidelines were in place at the time that any particular route was granted approval.

devnull

I am asking if such differences would be factors that might determine if a new service got approval or not.

And I have on several occasions pointed out the relevant paragraphs in the licensing guidelines that are underpinned by the PTR Act 2009 which is the de-facto standard to how bus services are licensed in the state and this is not my opinion, this is the actual rules so you can speculate all you like but this fact will remain.

I mention this connection option to and from Dunshaughlin and Virginia and Cavan with the 109X and 109 and 109A, because whenever there are timetable changes where a particular location ends up having less services, on the press releases issued, where it is stressed that such changes received approval from the NTA, where if one location is no longer served, it is usually emphasized what other connections are available to and from that location.

For example, this press release in November 2013, when Duleek was removed as a stop on the Drogheda Navan Trim service and it was no longer possible to get to Navan from Duleek on the Drogheda Navan Trim service.

Unrelated to the topic at hand because of all of these services are PSO, this topic is in relation to commercial competition with PSO services and now you're talking about PSO services being changed and the impact on other PSO services which again is not what we are talking about here.

I just simply asked what you think were the reasons that specific routes were granted approval, and asked if it was because one service differs from another service.

And I told you previously that prior to the publication of the PTR Act 2009 there were was a 1932 Act and the guidelines on licensing were not clearly published and there was doubt about them which ultimately led to them being challenged in court on a number of occasions such as the Swords Express case that has been outlined.

devnull

The previous discussion was in relation to a prospective new commercial service calling only at Virgina, Cavan and Dublin.

You previously seemed to indicate whilst there was not very few passengers traveling between Virgina, Cavan and Dublin there was not a significant number of passengers who are doing so, therefore it would not significantly effect the existing network of PSO services.

Is this because you believe a significant number of people are going to stops on the 109 series of routes to intermediate stops and additional locations that would not be served by a prospective new service calling only at Virgina, Cavan and Dublin.?

horseburger

devnull wrote: »

The previous discussion was in relation to a prospective new commercial service calling only at Virgina, Cavan and Dublin.

You previously seemed to indicate whilst there was not very few passengers traveling between Virgina, Cavan and Dublin there was not a significant number of passengers who are doing so, therefore it would not significantly effect the existing network of PSO services.

Is this because you believe a significant number of people are going to stops on the 109 series of routes to intermediate stops and additional locations that would not be served by a prospective new service calling only at Virgina, Cavan and Dublin.?

I did not "seem to indicate" anything like what you are trying to suggest I said.

I was pointing out the differences between the existing services on the 109X, 109 and 109A, and a service that would operate between Cavan, Virginia and Dublin, to ask - with reference to the comment you made before about one of the considerations for or against approval of new services being how a new service would impact on an existing PSO route - if the differences between the existing service and a proposed route, might be a factor which could result in a new service being granted approval.

The differences that I pointed out, show that with the connections available to intermediate locations on the 109X, 109 and 109A between Cavan Virginia, Kells, Navan and even Dunshaughlin, Ratoath, Ashbourne and Dublin Airport, that it is arguable that a new service would not impact on the existing 109X, 109 or 109A services because a service to and from Cavan, Virginia and Dublin, would not be of use for anyone at Cavan and Virginia who would want to to go to or from Kells, Navan, Dunshaughlin, or Ratoath, or Ashbourne or Dublin Airport.

The point is that, in such a situation, if ever there was a service between just Cavan, Virginia and Dublin City Centre, passengers who would want to go to or from Cavan and Virginia, going to or from Kells, Navan, Dunshaughlin, or Ratoath, or Ashbourne or Dublin Airport, would continue to use the existing 109X, 109 and 109A services.

In such a scenario, a service between Dublin, Virginia and Dublin City Centre, which would not serve Kells, Navan, Dunshaughlin, Ratoath, Ashbourne or Dublin Airport, would not take passengers - passengers who would be going to and from these intermediate locations - from the existing 109X, 109 and 109A services.

devnull

horseburger wrote: »

devnull wrote: »

You previously seemed to indicate whilst there was not very few passengers traveling between Virgina, Cavan and Dublin there was not a significant number of passengers who are doing so, therefore it would not significantly effect the existing network of PSO services.

I did not "seem to indicate" anything like what you are trying to suggest I said.

I asked you

Are you saying that there are very few passengers using any Bus Eireann PSO service between Cavan and Virgina, Dublin and Cavan and Virgina and Cavan?

You replied

No.

The point is that, in such a situation, if ever there was a service between just Cavan, Virginia and Dublin City Centre, passengers who would want to go to or from Cavan and Virginia, going to or from Kells, Navan, Dunshaughlin, or Ratoath, or Ashbourne or Dublin Airport, would continue to use the existing 109X, 109 and 109A services.

In such a scenario, a service between Dublin, Virginia and Dublin City Centre, which would not serve Kells, Navan, Dunshaughlin, Ratoath, Ashbourne or Dublin Airport, would not take passengers - passengers who would be going to and from these intermediate locations - from the existing 109X, 109 and 109A services.

So you believe that if such a proposed commercial service existed it would not have significant effect on the PSO service because of the reasons that you have outlined as a significant number of passengers on the existing PSO services that serviced Cavan, Virgin and Dublin would be going to/from Kells, Navan, Dunshaughlin, Ratoath, Ashbourne or Dublin Airport which would not be served by such service.