Action for Public Transport (N.S.W.) Inc.

We are very disappointed with your proposal to alter the ferry conditions for MyMulti tickets from 1st September, and we urge you to reconsider this regrettable decision.

First, to summarise the background. When the MyZone system was introduced in April 2010, APT applauded it as a welcome and additional step along the road to simplifying Sydney's fares and integrating the tickets. All ferry trips (and all buses) were included in the MyMulti1 ticket. This may have been over-generous and too simple, but the government at the time was in rescue mode. Your proposal to remove all ferry travel from the MyMulti1 ticket and make ferry travellers use a MyMulti2 or MyMulti3 ticket, thus increasing their weekly travel costs, is a gross and ill-advised over-correction.

We object to the proposal on the following grounds:

1. You will destroy the integrity of the MyMulti ticket range. The MyMulti1 ticket will no longer be "Multi". It will be a "MyPartly" or a "MySemi" ticket.

2. Customers and ticket selling agents will be confused as to which MyMulti tickets are valid on the ferry and which ones are not.

3. We believe that, if there was an anomaly, and an adjustment had to be made, then the MyMulti1 ticket could have been contracted for use only on the shorter distance ferries - up to 9km. This is the same split that applies to the MyFerry1 and My Ferry2 tickets. All services east of the bridge (except Manly and possibly Watsons Bay) would have been included, and all services west as far as Cabarita.

4. The trips beyond 9 km could then have been made available to holders of a MyMulti2 ticket - much simpler, more consistent, still some additional revenue, and no outrage from the Manly constituents.

5. There are anomalies in every fare system - distance based, time or zone based or flat fare. Passengers on the Bondi bus subsidise passengers on the Warragamba Dam bus. Some people win, some lose. We have to live with that for the sake of simplicity.

6. MyMulti1 applies to all buses in Sydney. Passengers can travel from Palm Beach to the city on a MyMulti1 ticket. If they choose to travel to Manly and catch the ferry to town they will need a MyMulti3 from 1st September . Now THAT'S an anomaly.

7. We note your statement that the Independent Pricing and Regulatory Tribunal (IPART) estimated that rail and bus passengers subsidised certain ferry passengers by a certain amount. We are not sure whether IPART actually recommended a change, but that is irrelevant. In the past, governments of all persuasions have occasionally ignored IPART recommendations. Governments are not bound by IPART recommendations, other than not to increase fares beyond a prescribed maximum.

8. We do not question your calculations on who is subsidising whom and by how much, and we have not checked them. However, we should let you know that in our experience of many years assessing the prices of TravelPass tickets, we have sometimes found the Ministry to make wild guesses about the use of TravelPasses by different holders. On one occasion there were even errors in the Ministry's simple arithmetic.

9. In those years, the Ministry, in its submissions, would accuse TravelPass holders of "abusing" the ticket and getting generous discounts. This was despite the fact that the trips available on the tickets were cheerfully advertised on the brochures. In fact, the current MyZone brochure, on page 11, tells ferry users that " . . . you may find that a MyMulti is the best value ticket for you".

10. Anyway, we thought that those days of pitting travellers on one mode against travellers on another were well past. We thought that the public transport system was being presented and funded as one entity, not a collection of jealous fiefdoms. Your actions in this aspect have so far been commendable. Most people don't have a choice of bus, train or ferry - they have to take what is provided. Until recently, there was only one way to travel from Manly to the city, and that was by ferry. It wasn't the fault of the passengers that the subsidies were askew.

11. Your media release quotes the following statistics:
    • the subsidies in question total about $5.5 million dollars a year
    • ferry trips made on MyMulti tickets equate to 0.05% of all public transport journeys
    Total ferry trips (all types of tickets) are 14 million out of 600 million trips on all modes. It is difficult to find total public transport operating costs and revenues from budget figures, but surely $5.5 million must be a drop in the ocean.

12. It is anomalous, nay bizarre, that in the same week as the government announced new express buses to take peak-hour commuters to and from Manly Wharf, the government also announced that people using the bus and ferry combination would need to pay an additional $10 or $20 a week for their MyMulti tickets. Does not the department's right hand know what the left hand is doing?

13. The increases in ferry fares will lead to lower ferry patronage, crowded buses and more road congestion. The ferries have to run, so it would make sense to fill them.

14. Discounts don't all work in favour of the passenger. The provider gets the money up front before the customer uses any service, and on occasions, the customer may not use up all of the available journeys.

Your responses to our comments above would be appreciated.

Yours faithfully
Allan Miles
Secretary
Action for Public Transport (NSW)