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

Submission to competition policy review

posted Thursday 20 November 2014

Action for Public Transport (NSW) has called on the Harper inquiry to give priority to the experience and concerns of real consumers over the hypothetical consumer beloved of economic modellers – the one with perfect knowledge and nothing better to do than spend all day combing through fine print to find the best deal for essential services. Its submission to the Inquiry argues that the radical “small government” or “privatisation” agenda proposed in the Inquiry’s Draft Report does not originate with consumers but with big business and development lobbyists. Consumer groups including Action for Public Transport, it says, value the traditional consumer protection role of the ACCC above this radical agenda. Its members see themselves as citizens living in a society, not as consumers living in an economy.

APTNSW also called on the Inquiry to look carefully at who is served by its identification of “planning and zoning rules” as a priority for reform. It suggests that the statements on which the Inquiry relies come in the main from a handful of developer lobby groups keen to develop outside established centres. The group says that “concentrating activity in well-established centres is good for the passengers we represent, as services to central points can be, and usually are, more frequent and direct. It argues that there is less competition, not more, if retailers end up as tenants in freestanding, single-owner shopping centres dominated by chain retailers. The group also accuses the Draft Report of brushing aside the concerns of regional towns which do not want to end up with dead town centres.

APTNSW describes the running of a public transport system as a “complex and highly specialised endeavour that requires a deep understanding not only of passenger behaviour, but also the operation of the system as a system. It says the NCP approach is the wrong approach, “assuming that a better outcome for consumers is the intended outcome”. It calls on the Harper Inquiry to resist the urge to break up the system into unconnected separate parts, and to leave public transport to experts in transit network planning.

APTNSW's submission can be seen here.

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