| 26th October 2007 |
James P. Cox
Chief Executive Officer
Independent Pricing and Regulatory Tribunal of New South Wales
Level 2, 44 Market St, Sydney NSW 2000
PO Box Q290, QVB Post Office NSW 1230
transport@ipart.nsw.gov.au
Dear Mr Cox,
Herewith is the submission from Action for Public Transport (APT) to the Tribunal’s review of maximum fares that can be charged by private ferry operators from January 2008.
The data provided by the Commercial Vessel Association (CVA) continues to be devoid of almost all information, apart from costs, that is needed to make a sound decision on fares.
Details concerning revenue, patronage, service quality and related matters are absent from the submission despite being specifically requested by the Tribunal after last year’s determination.
Over the past year, there have been no changes to private ferry services, for better or for worse.
We have no objections to a reasonable fare rise to cover increased costs, provided they are efficient costs and that efforts have been made to increase revenue by building patronage.
The marketing of private ferry services should be combined with those of Sydney Ferries Corporation for the sake of passenger convenience.
Consideration should be given to taking the operations of the private and government ferries in Sydney into a contract system similar to the Ministry of Transport contract system for buses. The private ferry fares could then be harmonised with those of Sydney Ferries Corporation.
In the CVA submission, costs are treated to an almost absurd level of detail, including such esoteric measures as the “Commonwealth Bond Bank Bill Swap Reference Rates” and the “Business Mortgage Instalment Loan Rate”, quarterly for the past ten years! They seem half a world away from boats on the water. Seeing as the final fare price is rounded to an even twenty cents, one wonders what is the point of these arithmetical gymnastics.
APT does not wish to deny ferry operators any reimbursement for efficient cost increases, but there must be a simpler way for ferry operators and IPART to come to an agreement.
In contrast to the detail given for costs, the CVA submission barely touches on any other topic.
The other major players in the public transport arena have to provide detailed arguments to substantiate requests for fare increases. The CityRail submission to IPART, for example, covers many topics that are not even hinted at in the CVA submission. Admittedly, not all the CityRail topics are relevant, but many can be "translated" into relevancy. Also, CityRail is one very large organisation. The CVA represents many several proprietors with no link.
However, a comparison is useful to see how much information is missing from the CVA submission.
| Item in CityRail Submission | Equivalent in CVA Submission | Mentioned in CVA Submission? |
|---|---|---|
| 2. CityRail’s business environment | Ferry business environment | Not mentioned |
| 2.1 The CityRail network (statistics, etc) | Description of the ferry network | Not mentioned |
| 2.2 Our customers | Our customers | Not mentioned |
| 2.2.2 The demand for CityRail services | The demand for ferry services | Not mentioned |
| 2.3 Capital expenditure | Capital expenditure | Not mentioned |
| 2.3.1 Sectorisation and the Rail Clearways Plan | Perhaps congestion at Circular Quay and Darling Harbour | Not applicable |
| 2.3.2. Track maintenance | Wharf maintenance | Not mentioned |
| 2.3.3 Signalling equipment | Radar and radio equipment | Not mentioned |
| 2.3.4 New carriages | New vessels | Not mentioned |
| 2.3.5 Matching demand and capacity | Matching demand and capacity | Not mentioned |
| 2.3.6 Station upgrades and accessibility (wheelchairs?) | Wharf maintenance | Not mentioned |
| 2.4 Cost Recovery | Cost recovery | Yes |
| 2.5 Inflation | Inflation | Yes |
| 2.6 “Hidden” costs to society Better labelled “hidden benefits to society” | Hidden benefits to society | Not mentioned |
| 3. CityRail’s current performance | Ferries’ current performance | Not mentioned |
| 3.1 Key Performance Indicators (KPIs) | Key Performance Indicators (KPIs) | Not mentioned |
| 3.1.1 Key Performance Indicators (KPIs) | Key Performance Indicators (KPIs) | Not mentioned |
| 3.1.2 Infrastructure maintenance and cost per track km | Not relevant | Not relevant |
| 3.1.3 Rolling stock maintenance cost per car km | Not relevant | Not relevant |
| 3.1.4 Lost time injury frequency rate | Not relevant | Not relevant |
| 3.1.5 Improving corporate efficiency | Improving administrative efficiency | Not mentioned (maybe not applic) |
| 3.2 Safety | Safety | Not mentioned |
| 3.3 Reliability | Reliability | Not mentioned |
| 3.3.1 On-time running | On-time running | Not mentioned |
| 3.3.2 Disrupted services – skipped stops and cancelled services | Disrupted services – skipped stops and cancelled services | Not mentioned |
| 3.3.3 Delays from infrastructure incidents | Not applicable | Not applicable |
| 3.3.4 Delays from door motors | Not applicable | Not applicable |
| 3.3.5 Rolling stock failures | Vessel failures | Not mentioned |
| 3.3.6 Equipment failures | Equipment failures | Not mentioned |
| 3.4 Passenger security | Passenger security | Not mentioned |
| 3.4.1 Vandalism and graffiti | Vandalism and graffiti | Not mentioned |
| 3.5 Customer service | Customer service | Not mentioned |
| 3.5.1 How do we know what aspects of service quality to focus on? | How do we know what aspects of service quality to focus on? | Not mentioned |
| 3.5.2 ITSSR annual customer survey | ITSSR annual customer survey | Not mentioned |
| 3.5.3 Customer expectations met | Customer expectations met | Not mentioned |
| 3.5.4 Customer expectations not met | Customer expectations not met | Not mentioned |
| 3.5.5 Customer complaints data | Customer complaints data | Not mentioned |
| 3.5.6 Providing customer feedback | Providing customer feedback | Not mentioned |
| 3.6 The future | The future | Not mentioned |
| 4. Proposed fare changes | Proposed fare changes | Not mentioned |
Apart from a plethora of details on costs, the only information regarding services is a table of percentage changes to patronage.
It must be possible, and should be required, that someone compile a composite description of the services provided (routes, vessels, patronage, etc) and some measures of performance. These statistics should also be compared with those of previous years and the differences satisfactorily explained.
Maybe give them a form to fill in.
There is no mention of revenue. How do we know that, although costs have risen, the revenue has not also risen to cover these costs?
Recommendation 2 of the IPART Private Ferry Fares Determination, December 2006, says:
That each private ferry operator (either directly or through the CVA) be required to provide the Tribunal with the following information for the 2007 fare review:
3.4 This information should be provided for each operator, as information aggregated at the industry level is not sufficient for the Tribunal's processes.
The CVA submission provides no data relative to the third and fourth points above.
Paragraph 4.1 also highlights deficiencies by the operators and by the Ministry of Transport in these areas. “As in past reviews, neither the private ferry operators nor the Ministry of Transport provided data on service quality, reliability and safety. Therefore the Tribunal was unable to determine how the industry's service performance has varied compared to previous years.”
For the record, the current fares, as far as can be established from the various websites, are listed in Attachment “A”.
As far as we are aware, there have been no changes to ferry routes or services during the past year – either for better or for worse.
There are no records available on the quality of service provided – that is, reliability, breakdowns, on-time running, safety incidents, etc.
In any case, it would not be fair to blame the industry generally for the faults of one operator, or to give praise to the industry generally for one operator’s distinguished performance. Ultimately the Ministry should take any blame or credit for seeing that standards are met.
In the greater Sydney area all bus services are run under a contract system managed by the Ministry of Transport. Service standards are set, all revenue is sent to a central pool and distributed to operators according to a formula, and there are incentives to increase patronage. It should not be too difficult to control the scheduled ferry services under a similar arrangement.
In its previous determination, the Tribunal questioned the need for private ferry fares to be regulated. The Tribunal’s reasons (in summary) were:
We sympathise with the small ferry operators who would rather be showing tourists around the beautiful waterways of Sydney than carrying complaining passengers or compiling reports for bureaucracies.
APT has no objection to any reasonable fare rise being awarded to operators to enable them to continue providing a public transport service at a fair profit.
However, a new method of controlling the fares and the services is required. This could be by deregulation or an umbrella contract system, as mentioned above, some combination of the two, or some other approach.
Yours faithfully,
Allan Miles
Secretary
Action for Public Transport
For the record, these are the current fares, as far as can be established from the various websites. Where the fare cannot be found from an operator’s web site, the maximum determined by the Tribunal is shown. In some cases, operators charge the single fare at less than the maximum allowed, and these are indicated by (*). For private ferries the prices of tickets other than singles (return, all-day, ten-trip and family tickets) are at the operator’s discretion.
Cronulla – Bundeena Ferry
Adults $5.30, children and concessions $2.70, Family $14.50
http://www.cronullaferries.com.au/
Matilda
http://www.matilda.com.au/
The web site says that these fares are valid until 31st March 2008.
Matilda – City Loop (Circular Quay/Luna Park/Darling Harbour)
| Adult Single $5.70 (*) | Adult Ferry10 $55.00 |
| Child/Concession Single $2.80 | Child/Concession Ferry10 $27.50 |
| Family $14.20 | |
| Adult All Day $11.00 | Adult 3-Day $22.00 |
| Child/Concession All Day $5.50 | Child/Concession 3-Day $11.00 |
| Family All Day $27.50 | Family 3-Day $55.00 |
Note that the All Day ticket is in reality a discounted Return Ticket.
Matilda – Lane Cove to Circular Quay
| Adult Single $5.70 (*) | Adult Ferry10 $55.00 |
| Child/Concession Single $2.80 | Child/Concession Ferry10 $27.50 |
| Family $14.20 |
Palm Beach Ferries
http://www.palmbeachferry.com.au
Palm Beach – Ettalong – Wagstaff
Palm Beach – Basin - Mackerel
Central Coast Ferries
http://www.centralcoastferries.com.au/
Woy Woy to Empire Bay
Empire Bay to Davistown
Woy Woy to Ettalong
Ettalong to Wagstaff
Church Point Ferry Service – Church Point to Scotland Island
No web site.
Maximum fare allowed by Tribunal is $6.20.
Dangar Island Ferry Service – Brooklyn to Dangar Island
No web site
Maximum fare allowed by Tribunal is $5.30.
Sydney Ferries Corporation – for comparison
http://www.131500.com.au/ticketandfares/fares/
| Route(s) | Adult Single | Concession Single | Adult FerryTen | Concession FerryTen |
|---|---|---|---|---|
| Inner Harbour Zone 1 | 5.20 | 2.60 | 33.00 | 16.70 |
| Inner Harbour Zone 2 | 5.50 | 2.70 | 35.60 | 17.80 |
| Rydalmere | 6.40 | 3.20 | 48.10 | 24.00 |
| Parramatta | 7.70 | 3.50 | 54.30 | 27.10 |
| Manly | 6.40 | 3.20 | 48.10 | 24.00 |
| Manly Jet Cat | 8.20 | n/a | 67.80 | n/a |