Transport Scotland bus open data consultation

Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses that purchase, use or receive in Scotland goods or services supplied by a business, profession, not for profit enterprise, or public body.

Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:

• to enhance understanding and awareness of consumer issues by strengthening the evidence base
• to serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
• to enable the active participation of consumers in a fairer economy by improving access to information and support

Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, sustainability and redress.

The Consumer Principles are a set of principles developed by consumer organisations in the UK and overseas.

Consumer Scotland uses the Consumer Principles as a framework through which to analyse the evidence on markets and related issues from a consumer perspective.

The Consumer Principles are:

• Access: Can people get the goods or services they need or want?
• Choice: Is there any?
• Safety: Are the goods or services dangerous to health or welfare?
• Information: Is it available, accurate and useful?
• Fairness: Are some or all consumers unfairly discriminated against?
• Representation: Do consumers have a say in how goods or services are provided?
• Redress: If things go wrong, is there a system for making things right?
• Sustainability: Are consumers enabled to make sustainable choices?

We have identified information and choice as being particularly relevant to the consultation proposal that we are responding to.

Consumer Scotland welcomes the opportunity to respond to this consultation. Access to accurate information is crucial to consumers being able to make informed decisions. For this reason, we support more open data being made available and consider that it will have a number of benefits for different groups:

• It will support consumers directly in making decisions about their use of bus services
• It will provide a valuable tool for providers, stakeholders and representative groups monitoring service delivery in the bus transport market
• It will support consumer representatives to identify opportunities for improvement in the provision of services and to advocate for these.  

The proposals are in line with bus data provisions elsewhere in the UK, and will help to ensure that consumers, consumer bodies and those managing the provision of bus services can access similar levels of information on services in Scotland, compared to those available in other nations. This may also enable better comparison of performance across the UK, which can help to identify good practice that can be built upon as well as opportunities for improvement.  

We do have some concerns that potential inconsistencies in the collection and presentation of some of the data could result in unintended challenges for consumers. We also note that the collation and sharing of information will have resource implications. Operators may have different formats for how they record this data, and this will require a process of validation and data cleansing before being shared with consumers. The amount of data being proposed for collection is large and ongoing, and to collect and publish it in a way that ensures it is up to date and accurate will be likely to require significant resource. We recognise that the proposed standardisation of the format of the information being requested will, over time, reduce the administrative burden but there may be a need for some short-term support with implementation. As noted below, these are issues that can be addressed as part of the process of implementation and the proposed phasing should allow for this work.

Type of Services

Question 1. Do you agree with our approach that only services registered with the Traffic Commissioner, or within a Local Transport Authority franchise area should be required to provide open data?

Consumer Scotland agrees with this proposal. As the services included in this definition include standard, flexible and registered community bus services, the range of services covered is appropriate.

We also consider that the kinds of services that are not covered by these proposals is largely appropriate. However, while a service that picks up and drops off passengers within 15 miles is the Traffic Commissioner for Scotland’s definition of a local service[1], Consumer Scotland considers that, in remote rural areas, services of such length are more common and consumers therefore may be more reliant on bus provision for longer journeys of this kind.[2] We would welcome clarification on any challenges or barriers that would prevent the inclusion of longer distance services in the requirement to provide open data. We would welcome consideration of any actions may be available to address these issues in order to maximise good consumer outcomes, particularly for remote rural consumers.

Use and Disclosure of Information

Question 3. Do you have any concerns over the use of the open data in this way?

Consumer Scotland does not have any concerns over the proposed use of open data. The proposed open data is not personal data, and the regulations propose access without charge, ensuring access to it is fair.

The Prescribed Information - Passenger Views

Consumer Scotland is the statutory, independent body for consumers in Scotland. As such, we will be answering the following questions from viewpoint of both of what we consider to be useful for consumers, as well as for Consumer Scotland to carry out our functions as a consumer advocate.

Question 5. Routine information that you would find useful if made available to you when planning a bus journey.

In general, Consumer Scotland supports providing data to help consumers make more informed decisions when planning their journeys. We suggest that as part of the implementation process, appropriate work is undertaken to ensure any user interface is easy to use and does not risk consumers being overwhelmed by the volume of information provided.[3] We would recommend that user testing of any interface take place with a range of consumers to ensure that it is designed appropriately and is user-friendly. We also note that the required information will be provided on a phased basis which will allow work to maximise the accuracy of the data made available to consumers. We would also wish to see monitoring of the data to ensure that it is accurate.

We consider that the proposed data points could be useful to consumers, and especially the following :

• The days and times the bus will arrive/depart from each bus stop 
• The cost of the ticket 
• The difference in price if you bought it in another format or in another way 
• The service(s) a ticket is valid on
• Where you can buy tickets (e.g. online, in person at a shop, or only on the bus, etc). 
• The ways that you can pay the fare (e.g. cash, contactless, etc) 
• The name or number of the services (e.g. the X8, ‘The Town Service’, etc) 
• Who operates the bus service (e.g. which bus company runs the service) 
• The names of the bus stops the bus will call at, in order 
• What format the ticket will be in (paper, smartcard, digital, tap on/off, etc) 
• The places you will you see information about fares, tickets, special offers or routes 

One piece of routine information that may require more thought before being made available to consumers is the information about what the bus might look like. While this could be useful for some consumers, it could risk confusion for consumers in certain circumstances. This is because the appearance of buses is not always consistent per route, or in cases when there are breakdowns and different-looking buses may be sent out as an alternative. For example, some buses may have different colours/liveries for different routes or services. If these buses are deployed on different routes due to need, consumers could be given potentially misleading information about the appearance of the bus they are expecting. Phasing or piloting of provision of this information may provide the opportunity to check that it is working effectively for consumers. Once implemented, ongoing monitoring should ensure that the information is being captured accurately and is proving useful for consumers. This monitoring should assess if the right data is being made available, or if different data may be more beneficial to consumers.

These comments could also apply to provision of the real-time data being proposed in question 7, and could potentially be done via Transport Focus’ Your Bus Journey surveys, supplemented by targeted feedback from key stakeholders such as operators, local authorities or consumer advocacy bodies.[4]

Question 6. Assuming all of the routine information you would find useful were available, how would you prefer to obtain a ticket for travel?

Consumer Scotland does not have evidence regarding consumer preferences for how they would prefer to obtain bus tickets. However, we offer the following comments on potential mediums.

I would like to obtain a paper ticket for a specific journey, using cash, contactless payment, or mobile payment (for example, Apple Pay)
An estimated 15% of Scotland’s adult population lack foundation level digital skills.[5] Access to a paper ticket is likely to be particularly beneficial for these consumers. Meanwhile, evidence suggests that for some consumers, having a paper ticket can provide a greater feeling of certainty and security that they have successfully booked for and paid for their journey. In some cases, a paper ticket can also make it easier for consumers to claim travel expenses, if applicable.[6] Consumer Scotland supports the continuation of cash acceptance for public transport given that some consumers in vulnerable circumstances may be more reliant on cash use.[7]

I would like to ‘tap’ a personal bank card or electronic bank card to make unlimited journeys up to a set fare cap
This form of payment works well for many consumers who have the ability to pay with contactless cards, allowing them to pay the best fare for their journey, with a cap on spending that can be especially beneficial for frequent passengers.[8] One issue consumers may face with this method, however, is in relation to tap-on-tap-off services, where they may end up paying a higher fare than they should if they forget or are unable to tap off at the end of their journey.[9] Improved signage and communication from providers reminding tap-on-tap-off consumers of the importance of ‘tapping off’ may help to mitigate the risk of overcharging.

I would like to hold a physical (plastic) card that I can add a balance to or that would result in a ‘Bill’ at the end of a set period
This form of payment, most similar to Transport for London’s Oyster Card,[10] shares some of the benefits of tap-on-tap-off methods, while allowing the consumer to maintain the security of a physical token specific to their travel. Further, it helps consumers to better monitor and control their spending on bus travel due to its requirement to be topped up regularly and the potential ability to track spending on the card.[11] This manual topping up of the card does, however, make it less easy and convenient to use than tap-on-tap-off methods via bank cards.

I would like to use a app on an electronic device which allows me to pre-pay for a journey (or a number of journeys)
For those able to utilise electronic apps, they can be a convenient method of ticket purchase, allowing consumers to both plan their journeys and purchase tickets in advance. Major bus companies in Scotland already offer this service, meaning it will already be familiar to some consumers, though these are often individual apps per operator. Responses to the 2017 consultation for the Transport (Scotland) Act 2019 showed that a central data hub may be even more convenient for consumers, and so we support exploration of those proposals.[12]

Though there is a clear trend towards ticketing for bus travel and wider public transport via contactless and digital platforms, Consumer Scotland recommends that as long as there are still significant numbers of people who are reliant on cash or non-digital booking and payment methods, consumers should continue to have a choice of payment methods and platforms. This will help maintain straightforward access to bus for the broadest range of consumers, including consumers in vulnerable circumstances.

Question 7. Which of the following ‘real time’ information would you find useful in planning your use of a specific service/services, if it were available?

Consumer Scotland is in favour of journey-related information being made available to consumers to help inform their decisions, as long as this is presented in a way which manages any risk of information overload, and is subject to procedures that maximise its accuracy.

We have grouped the different kinds of information being consulted on based on how it will be updated and its likely relevancy to consumers. We have also noted any potential risks with the reliability and accuracy of information which may require action to mitigate risks.

There are a number of categories of information that would be helpful to consumers, allowing them to stay informed about their forward journey, ensuring they know what to expect and allowing them to react to any potential disruption. These data points are likely to be updated automatically and less likely to change in real-time. We consider those items of information to be:

• Live bus stop arrival and departure times 
• Live timetables 
• Live disruption updates 
• If the bus has audio/visual capability
• Which payment types the bus can accept e.g. cash, contactless, card, etc. 
• The emissions created by the bus

In our recent research on consumer attitudes on sustainable transport the time a journey takes was considered a barrier to public transport by 53% of respondents.[13] Live data about bus arrival and departure times, as well as live information about potential disruptions will help consumers make choices about their journey and plan for any disruptions. Given the importance of journey times to consumers, consumers would benefit from real-time information about when the bus they plan to use is expected to reach the subsequent stops on its route.

For consumers with sensory impairments, the provision of audio/visual displays and announcements assist them to travel safely and efficiently,[14] and so reliable real-time data about whether buses feature these capabilities would be extremely helpful for them.

While there is a general trend in the UK towards digital and contactless payments,[15] cash remains an important method of payment for some consumers, including on transport.[16] With this in mind, information about whether buses accept cash for those who prefer to pay that way, or other methods for people who don’t use cash, will be important for some consumers.

Consumer Scotland has published a number of reports over the past year on consumer attitudes and behaviours in relation to climate change and the actions required to enable consumers to make more environmentally friendly choices. Our research found that 65% of consumers would like to reduce their emissions via the transport modes they choose.[17] We welcome the proposal to provide information to consumers on bus emissions as this will allow consumers to track their emissions and become more aware of the impact of their transport choices.

There are a number of additional items of information that would be valuable for consumers, providing appropriate systems are in place to capture and provide this information accurately to consumers. Many of these pieces of information may be more likely to change as the journey progresses. These are:

• On-board capacity (e.g. how full the bus is) 
• Number of wheelchair accessible spaces and if they are in use 
• If there are toilets on board, and if they are operational
• If there are wi-fi/power/charging facilities, and if they are operational 

Robust systems will be required to provide this information to consumers in real-time. It is important that these systems are able to produce this information quickly and accurately, whether through driver input or technology including ticket machines. Incorrect information could create problems for consumers and may even risk the safety of some consumers in vulnerable circumstances.

For example, for consumers who use wheelchairs, being unable to enter a bus which they expected to can pose significant safety concerns.[18] Some consumers in vulnerable circumstances are also more likely to have an increased need to access a toilet when travelling, making accurate reporting of their availability and functionality important.[19] Accurate recording and provision of information is important to enable these consumers to make appropriate and informed choices about their journeys.   

We agree that there are clear consumer benefits of having wi-fi[20] and charging ports[21] on buses, but we note the same potential issues around the accuracy of the information in practice, especially as faulty facilities may need to be reported by consumers to operators.

Given the need to consider these practical aspects, we welcome the proposed phased introduction of these information requirements to allow for the establishment of procedures for collecting and sharing this data. We also recommend that guidance for operators and drivers should be made available ahead of implementation, alongside user testing of updated journey planning platforms before rollout, to provide further safeguards for consumers.

For Transport Scotland, consumer bodies and other interested parties, collection of the various data points described above may allow better overview of trends for certain categories over time, such as, for example, how full buses tend to be, instances of disruption, and the number of buses with audio/visual capability. This may allow us to better understand and respond to consumer needs and priorities.

Question 8, Specifically thinking about the bus stop or stopping place of the bus, which of the following would you find useful to planning your journey, if it were available?

The information available at bus stops is crucial for consumers to feel confident in their expectations related to their journey. A recent Transport Focus survey of consumers about bus stop design showed that 75% used paper timetable information and 63% used digital information at the bus stop ‘at least very occasionally’.[22] There is an opportunity to maximise the information available for consumers by providing more, relevant information.

Accessibility features 
The same survey by Transport Focus shows that only 51% of disabled consumers consider bus stops generally accessible for all, a number which decreases for those with hearing or mobility impairments.[23] The satisfaction levels for disabled consumers with the accessibility of their bus stop increases however, when considering the bus stop they usually use.[24] This suggests that the ability to choose a bus stop that is familiar and suits them can help buses become more accessible. Information about the accessibility features of local bus stops, as well as information about whether bus stops include shelter and seating, could benefit disabled consumers and those with long-term health conditions.

An overview of the percentage of bus stops that feature individual accessibility features, and where, may be useful for consumer advocacy groups to help understand the experiences for consumers in vulnerable circumstances and identify opportunities to improve this experience.

Name of the bus stop (for the purposes of finding it on a timetable) 
Including this information would be consistent with the requirement for open data on the names of bus stops that buses will stop at, and it could help consumers to follow timetables and understand where their stop is placed in a wider journey. Knowing the name of bus stops may help consumers travelling to specific stops feel more confident when requesting tickets to that destination.

Location description (busy streets may have multiple similarly named stops)
Where people are unfamiliar with an area or where there are multiple stops with similar names, this information could be beneficial. It would be important that there are appropriate systems to keep this information up to date as appearances of places may be subject to change and inaccuracies in any information of this kind could lead to unnecessary confusion for consumers.

It may be helpful, for this category of information, to have clear guidance on how to accurately share descriptions of local areas, and how frequently it should be reviewed to maximise ongoing accuracy.