Consultation response document

1. A public consultation was launched on 25th May 2007 seeking views on the proposed specifications for the English National Concessionary Travel Pass.

2. The consultation covered 5 main areas:

• The physical design of the pass
• The expiry date of the pass
• If the pass should be a smartcard
• The arrangements for London (re-stickering existing Freedom Passes)
• Transitional arrangements

3. In order to assess opinion of our proposals the consultation asked 13 questions and gave stakeholders the opportunity to provide supporting comments if they wished. This consultation response document presents a summary of the answers and comments received for each question with a response from the Government.

4. The consultation document was published on the Department’s web site and sent electronically to about 400 stakeholders, including all English Travel Concession Authorities, London Councils, and bus operators. The consultation ran for 8 weeks, finishing on 20th July 2007.

5. In total 148 responses were received. These responses can be broken down as follows.

Local Government	92
Large Company	7
Small to Medium Enterprise	5
Representative Organisation	11
Interest Group	6
Member of the Public	27
Total	148

6. The Local Government respondents were mainly lower tier local authorities, who are Travel Concession Authorities (TCAs) and have responsibility for administering concessionary travel schemes. There were also 9 responses from County Councils, all of whom run county-wide schemes on behalf of their districts and a response from the Passenger Transport Executive Group.

7. Five of the large companies were bus operators. The other two were card and equipment manufacturers. The small and medium enterprises included two smartcard consultancies, two pass manufacturers and a community transport organisation.

8. The 'Representative Organisations' and 'Interest Groups' represented a range of stakeholders, mainly representing older and disabled people.

9. A full list of those organisations that responded can be found at Annex A.

Executive summary

10. Overall the responses to the consultation were supportive of our proposals. There have been some minor changes to the design of the passes as a result of responses. In particular we have chosen a hologram as the security feature for passes. Our proposals for there to be expiry dates of no more than five years from the date of issue remain unchanged.

11. On the important issue of smartcards there was a very clear majority who supported our proposals and we intend to specify that the passes should be ITSO compliant smartcards.

12. As a result of concerns expressed we have taken steps to increase the security of re-stickered London Freedom Passes by adding a hologram to the sticker design.

13. The proposals for transitional arrangements were also well supported. We have specified transitional arrangements lasting for six months. The transitional arrangements have been specified in secondary legislation, which was supported by the majority of those who responded.

Next steps

14. The proposals set out in this consultation response will now form the basis for secondary legislation that will be laid before parliament. The transitional arrangements have been included in the Commencement Order for the Concessionary Bus Travel Act. The proposals for the pass design and specifications will be made as regulations which we anticipate will be laid before Parliament in the later this year.

The physical design of the pass

Question 1 - Do you agree that the design of the pass is easily recognisable?”

Summary of responses

Yes	130
No	10
No answer	8

15. There was general agreement that the design was easily identifiable.

16. However, there was a concern raised by respondents that the space given for local authority identifiers was too small. In a linked concern, some felt that the design was “busy”.

17. Of the responses that did not think that the design was easily recognisable, the most common reason was that the pass does not say what it is for, such as “Concessionary Travel Pass” or “Bus Pass”.

Government response

18. We have made some minor changes to the pass design, which is shown below. However, the responses were largely positive and the design is similar to the one consulted on.

19. We have always sought to maximise the area available for local customisation with the design given and the pressures for space on the card. Allowing local authorities to use the reverse of the card as they wish means that features such as the 18 digit card number must feature on the front of the card. This means that the space for local customisation has been maintained as featured in the consultation.

20. The decision has been taken not to give the card a name. There were real problems with any “transport” based name, since most of the names proposed were already in use, creating copyright issues and potential confusion with existing brands.

21. Many local authorities have been keen to retain their local, well recognised brand names (which can be multi-application) and giving the national concessionary pass a name could create branding conflict on the card.

22. A difficulty with writing what the card is for on the face of the card is that it may not be used for the same purpose in different local authority areas. Some TCAs offer rail and tram travel as well as bus travel. Also, some areas use the card for wider applications than just concessionary travel.

23. The latest version of the card does bear the words “concessionary travel funded by HM Government with your local authority”.  The reverse of the card is left blank for local branding, which can include more details about what the card may additionally be used for, including other applications such as library cards, etc.

Question 2 - Do you consider a hologram or laminate overlay appropriate security features?

Summary of responses

Yes	116
No	19
No answer	13

24. Of those who expressed a preference, 24 indicated that they thought a hologram would be more appropriate and 1 specified a preference for a laminate to be used. The rest of the responses did not differentiate between the two.

25. Of the respondents who did not think these are appropriate security features, some suggested that an embossed plate was more appropriate.

26. The other negative responses suggested that the smartcard element of the pass is the most appropriate security measure rather than a physical security feature.

Government response

27. Following the consultation responses and our discussions with manufacturers we believe that a hologram is the most appropriate security device. A high security hologram is now part of the proposed design of the pass

28. The Department agrees that the best security for the card is for it to be used in smart mode as part of a full smart ticketing system. However, until buses throughout England have been equipped with readers the passes will still be used as flash-passes in many areas and so some physical security measures are required to prevent counterfeiting and reduce fraud.

Question 3 - Do you have any further comments to make about the pass design?

Summary of responses

29. Additional comments were made by 86. Many of these centred on how local additions to the national concession could be communicated to drivers. The concern about the lack of space for local customisation was again repeated.

30. There were concerns raised about the use of passes by blind and partially sighted stakeholders and how the pass would be distinguished from other similar cards.

31. An associated suggestion was the addition of another coloured band to denote blind or partially sighted concessionaires to allow bus drivers to identify and assist such passengers. However, we also received some responses that stated there should be no distinction between older and disabled people’s passes in the interests of social inclusion.

32. Some responses suggested that a different colour strip should be introduced for companion passes. Others suggested that a standard “+ companion” could be added to the design.

Government response

33. With regards to the space on the card for local customisation, we have sought to make available as much of the pass as possible for local customisation, given the other pressures on the available space. We have also sought to keep the reverse of the card as free as possible for local authority use.

34. In order to make best use of the space available, only one scheme or TCA identifier will be required and we will not require a county logo to be displayed. Additional logos are at the discretion of the TCA.

35. In response to concerns about the use of the card by blind and partially sighted people, we held a meeting with stakeholder groups about this subject and we intend to produce guidance for local authorities. The guidance is likely to include suggestions such as issuing passes in Braille wallets or ordering Braille tape to attach to the card. However, we will not require this in regulations as local authorities are best placed to chose the most appropriate measures for their circumstances.

36. We intend to maintain the distinction between older and disabled person’s passes. Some TCA areas have different additional concessions for disabled people or older people. The band allows drivers to distinguish between the two groups. For those concessionaires who qualify for both it will be for the issuing local authority to decide which type of pass to issue. 

37. We do not believe it is appropriate to specify a different colour stripe on passes for different disabilities or for one disability in particular. If a local authority believes it is necessary to distinguish between types of disability this can be done in the space reserved for local customisation.

38. With concessionaires who may travel with a companion, it is not appropriate to have a national, standard way of identifying this, since it is only a local concession and is not valid outside the local area it covers. Including a standard way of identifying this entitlement on the card may lead to confusion that the entitlement is nationwide. However, TCAs are free to use the space for local customisation to indicate that a concessionaire can travel with a companion.

39. It is also worth emphasising that only people eligible for the national concession should receive a national pass. If a local authority wishes to issue companion passes then these should not be a national pass or of a design that could easily be mistaken for the national pass.

Proposed pass designs

Older person’s pass

Disabled person’s pass

 

Expiry dates

Question 4 - Do you agree that the passes should have an expiry date?

Summary of response

Yes	126
No	14
No answer	8

40. The vast majority of respondents agreed that an expiry date was essential to maintain accuracy of a database and to reduce fraudulent use of lost and stolen cards. It also provides a clear opportunity for cards to be replaced after natural wear and tear.

41. Of those who disagreed with the inclusion of an expiry date, most stated that a concessionaire’s entitlement to the pass would not change and that renewal was time consuming and difficult for vulnerable groups. This view was shared mainly by stakeholder groups and members of the public who accounted for 10 of the 14 respondents who said the passes should not have an expiry date.

Government response

42. Although in many cases a person’s right to a concessionary pass will not change, there are circumstances when it will. For example if a person moves from one TCA to another they may not be eligible for the same locally provided enhancements, and so would need a new pass. In the case of disabled person’s passes, some types and levels of disability do change over time and could therefore result, in some instances, in the holder no longer being entitled to a pass. Consequently, it should not be assumed that entitlement to the same pass is for life. It is also very important for ensuring that records are accurate that passes are renewed.

43. We therefore intend to specify that all passes must feature an expiry date. Please see below regarding setting an expiry date.

Question 5 – Do you agree that the maximum expiry date should be no more than five years from the date of issue?

Summary of responses

Yes	116
No	23
No answer	9

44. Many local authorities emphasised it was important for them to be able to set their own expiry dates as most appropriate for their local circumstances. Many also stated that it would be beneficial to set different expiry dates for different concessionaires.

45. Of the 23 that stated five years was not appropriate, 12 had also stated that expiry dates should not be used at all (Q4). Amongst the other responses, there was a split between those who wanted a shorter validity period for greater control over passes in circulation and those who wanted a longer maximum period in order to reduce card renewal costs.

46. Two existing smartcard schemes were among those who suggested a longer period as their smartcards have lasted up to 7 years rather than the 5 that had been expected at the time of issue.

Government response

47. We intend to set the maximum expiry date for the card as being no more than 5 years from the date of issue. However, within that local authorities are then free to set the exact expiry date.

48. Our proposals give local authorities the flexibility to set the most appropriate expiry dates for their local circumstances. However, the five year maximum ensures a baseline for security purposes, which is necessary as passes will be accepted nationally.

49. Smartcard technology does give greater flexibility with regards to expiry dates, as cards can be renewed electronically. However, as cards will also be used as flash passes we are proposing that the maximum expiry date will be set at 5 years from the date of issue.

Question 6 – Do you have any other comments about setting an expiry date for all passes?

Summary of responses

50. 68 respondents had further comments to make. Most responses to this question restated the need for local authorities to have a degree of flexibility when setting expiry dates. Most respondents stated that rolling expiry dates were preferable, but some wished to have a single expiry date to allow greater control over changing card formats (such as local add-ons). TCAs can take either approach under our proposals.

51. Another issue raised was setting different expiry dates dependent on the concessionaire’s circumstances. For example, someone with a temporary disability would have a shorter expiry date on their card than someone with a permanent disability. Again, this is possible under our proposals and lets local authorities decide what is most appropriate for their arrangements.

Government response

52. Our proposals are intended to give TCAs flexibility to take the most appropriate approach according to their own circumstances. This means that they can have rolling renewal dates, as suggested in the consultation, or choose to have a single expiry date.

53. TCAs can also have different expiry dates for concessionaires who have a permanent entitlement and those whose entitlement may only be temporary.

Smartcards

Question 7 – Do you agree that passes should be smartcards?

Summary of responses

Yes	119
No	18
No answer	11

54. There was very strong backing for smartcards. The better data that is available from smart ticketing and the enhanced security were cited by many as being essential for the future of concessionary travel. However, almost all respondents commented that there needs to be a coherent strategy for implementing full smart ticketing throughout England. Many respondents also called for funding to be made available for implementing smart ticketing.

55. Almost all of those consulted who thought that the passes should not be smartcards for April 2008 stated that smartcards were desirable over a longer time period. However, as most buses would not be equipped with readers by April 2008 they were an unnecessary expense at this point in time. A common suggestion was to introduce cheaper, non-smart cards for April 08 and smartcards later as part of a national plan to introduce readers and back office systems.

Government response

56. The responses showed a strong backing for smartcards and we intend to specify that the passes must be ITSO compliant smartcards.

57. Although we accept that most of the passes will be used as flash passes rather than smartcards at the start of the national concession, we believe that issuing the cards as smartcards will offer a considerable stimulus to smart ticketing. We have already stated that we intend to pay a grant to cover the new burden of re-issuing exiting passes as smartcards.

58. We also believe that it is more cost effective and more efficient for TCAs to issue all passes as smartcard now, rather than issue passes as non-smart cards for April 2008, only to repeat the pass issuing exercise shortly afterwards with smartcards.

Question 8 - Do you have any further comments about the plans to require all passes to be smartcards?

Summary of responses

59. 79 respondents had further comments about smartcards. The main comments made were concerns about the cost of smartcards and the need for Central Government funding; both for issuing passes and ensuring readers are installed on buses. However, there was general approval of the policy and of mandating that smartcards are ITSO compliant in order to ensure interoperability in future.

60. Some respondents raised concerns about data protection issues associated with smartcards.

Government response

61. We are pleased at the level of support for smart ticketing. We continue to work towards increasing the coverage of smart ticketing in England.

62. With regards to data protection, TCAs have a responsibility to ensure that all concessionary travel schemes comply with the Data Protection Act 1998, which guards against the misuse of personal data.

London

Question 9 – Do you agree that London Freedom Passes should comply with the national design and specifications for 2010?

Summary of responses

Yes	103
No	24
No answer	21

63. Most of those who responded stated that it was important to have one card for the whole scheme as soon as possible but accepted 2010 was the soonest possible date for London. However there was some concern that London was being given “special treatment” compared to other TCAs who had no choice but to issue passes to the national specification from April 2008.

64. All of those who disagreed with the consultation proposals stated that London should be required to comply with the national pass specifications from 2008.

Government response

65. London’s public transport network is larger and more complicated than any other in England. It also has a fully operable smartcard system. It would be impractical and not cost effective to require London authorities to issue a million passes that could not immediately be used as smartcards in London. It would also represent a backwards step in the service offered to concessionaires who would not longer be able to enjoy the benefits of smart ticketing.

66. Work is ongoing to make Oyster and ITSO systems compatible and we intend to require London to issue cards to the national specifications from 2010 onwards. Please see below about arrangements from April 2008 in London.

Question 10 – Do you agree that re-stickering London Freedom Passes with the national concessionary travel logo will enable bus drivers outside London to recognise them as valid for the national concession?

Summary of responses

Yes	83
No	39
No answer	26

67. Many of those that stated yes accepted that although not an ideal solution, it would work as a compromise until 2010, although many said that the success would depend on driver training covering what the stickers meant and why they were there.  However, concerns were raised about the security of the passes when used as flash passes in the rest of the country.

68. Those who stated no thought that this would be too open to fraud and could also cause confusion amongst bus drivers. There was also a concern that the stickers could fall off or be removed.

Government response

69. We are very much aware of the need for appropriate driver training and our communications and marketing teams will be working with bus operators and local authorities to ensure that appropriate materials for training and communications are made available.

70. In order to reduce the possibility of fraud we intend to specify that the sticker must include a hologram as well as the national logo in order to deter forgeries. This hologram will be unique to the re-stickered freedom pass and will not be the same as the hologram on the national pass. The glue used to re-sticker the passes means that it is almost impossible to remove the sticker, and any removal would result in causing real damage to the card and sticker.

71. Freedom passes are also issued with a photo-card. When used outside London the re-stickered freedom passes will have to be presented with their accompanying photo-card to be valid for free travel in line with the national concession.

72. The freedom pass is issued in two colours – blue for older people and orange for disabled people. Examples of stickered freedom passes are shown below (without a photo card, which will not be stickered).

Older person’s stickered freedom pass

Disabled person’s stickered freedom pass

Transitional arrangements

Question 11 - Do you think that a transitional period where existing passes are still valid for travel within a TCA should be introduced?

Summary of responses

 

Yes	101
No	33
No answer	14

73. Most respondents agreed that it was important to have a transitional period so that eligible people could continue to access the existing local concession if they had not applied for their new pass time, or in the event of any problems with the supply of national passes.

74. Those who disagreed stated that the proposal would create confusion and that it was essential that the new passes are delivered on time. There was also a feeling that the existence of a transition period could mean TCAs had less incentive to have all their passes ready for April 2008.

Government response

75. It is inevitable that some concessionaires will not have applied in good time or that some may not realise the new pass is required and we do not want them to be denied access to free local bus services. A transitional period where existing cards are valid for concessionary travel within their original issuing local authority area is therefore necessary.

76.There is sufficient time for all passes to be produced for April 2008 and it will still be a legal requirement for local authorities to issue the new passes from April 2008. Furthermore, concessionaires will need a new pass to access the national concession, so there are very pressing reasons for local authorities to ensure passes are delivered on time.

77. Please see below for further information on how the transitional arrangements will work.

Question 12 - If yes, should the transition period be for three months, six months or some other period (in which case, please specify)?

Summary of responses

 

3 months	42
6 months	41
Other length	6
No answer	59

78. There was no consensus in responses to this question. Practically the same number responded that they though the transitional period should be six as responded three months. Five responded with other lengths, ranging from one month to 18 months, while 59 gave no answer.

Government response

79. The most important thing for the transitional period is to allow concessionaires who have not yet applied or have not received their passes, the ability to access concessionary bus travel. For this reason we intend to specify that the transitional period will be six months.

Question 13 - Do you think the transitional period should be specified in regulations or be a voluntary agreement between TCAs and bus operators?

Summary of responses

 

Regulations	76
Voluntary	22
No Answer	50

80. The most common comment from the responses was that it is necessary to specify in regulations to ensure uniformity throughout the country.

81. Again there was call for flexibility, with some respondents wanting a minimum period specified with the ability to extend it voluntarily. Others wanted a maximum period specified but the flexibility to end it earlier.

82. The respondents who stated that the arrangements should be voluntary generally felt that local authorities would be best placed to make the necessary arrangements at a local level.

Government response

83. We intend to specify the transitional period in secondary legislation in order to ensure consistency throughout England. The arrangements will only apply to trips made within a concessionaire’s TCA. It was considered very important that concessionaires would be able to access local concessionary travel and the responses received suggested that overall this approach would be welcomed.

84. This will mean that existing passes will be valid for trips within a concessionaire’s TCA for six months. However, TCAs will also be able to make voluntary arrangements during this period for travel outside the TCA if they wish. For example, county-wide schemes are able to make transitional arrangements that will continue to allow county wide travel to concessionaires using their old passes.

Additional comments

Summary of responses

85. There were additional comments from 70 respondents. Most of the comments echoed comments that had been made about earlier questions and have been covered earlier in this paper.

86. Of those comments that had not been covered earlier in the paper two main themes arose: that the issuing of passes must be properly funded and of the necessity of a communications plan.

Government response

87. The Department has continually stated its commitment to fund reasonable new burdens caused by issuing passes for April 2008. We have announced that we will be paying a grant to TCAs of £4 per pass currently in circulation, uplifted by 20% to allow for increase in uptake likely to result from the more generous concession, up to a maximum of 100% of eligible population. We have also applied a floor of 30% of eligible population to allow for adequate set up costs in TCAs where pass uptake is currently very low but is reasonably expected to increase due to the national concession.

88. The Department also recognises the need for a co-ordinated communications plan to ensure that accurate messages are conveyed to concessionaires. A communications plan has been developed in partnership with key stakeholders. This involves a national awareness campaign led by DfT complimented by local messages which are necessary to deliver the more detailed messages about any local arrangements, including any local benefits that are in addition to the statutory concession.

Annex A – Organisations that responded

Age Concern England

Ashford Borough Council

Association of Local Bus Managers (ALBUM)

Aylesbury Vale District Council

Banburyshire Community Transport Association Ltd.

Barbergh District Council

Basingstoke & Deane Borough Council

Bath and NE Somerset

Braintree District Council

Brighton & Hove City Council

Bristol City Council

BUILD

Cambridge City Council

Cambridge Older People’s Enterprise (COPE)

Canterbury City Council

Caradon District Council

Castle Point Borough Council

Centro

Cheltenham Borough Council

Cheshire County Council

Colchester Borough Council

Croydon Council Mobility Forum

Croydon Disability Forum and Mobility Forum

Dacorum Borough Council

David Neaves

Derby City Council

Derbyshire County Council

Devon County Council

Dover District Council

East Devon

Ellesmere Port & Neston Borough Council

Elmbridge Borough Council

Epilepsy Action

Epsom & Ewell Borough Council

First Group UK Bus Division

Forest Heath Distric Council

Forest of Dean District Council

Gold Darlington

Gosport Borough Council

Greater Manchester PTE

Havant Borough Council

Help the Aged

Hertfordshire County Council

Hertsmere Borough Council

Hinckley & Bosworth Borough Council

Iosis Associates

Ipswich Borough Council

ITS United Kingdom

Jacobs UK Ltd

Kent Association for the Blind

Kingston upon Hull City Council

Leicestershire County Council

Lesar UK Ltd

Lincolnshire County Council

London borough of Croydon

London Borough of Lambeth

London borough of Newham

London Councils

London TravelWatch

Long Wittenham Parish Council

Maidstone Borough Council

Malden District Council

Medway Council

Mencap

Mick Davies 4ICT Ltd

Milton Keynes Council

Norfolk County Council

North Cornwall District Council

North East Lincolnshire Council

North Kesteven District Council

North Shropshire District Council

North Shropshire District Council.

North Somerset Council

Northampton Borough Council

Northamptonshire County Council

Nottinghamshire County Council

NoWcard

Nuneaton & Bedworth Borough Council

Oswestry Borough Council

Payne Security & Burall InfoSmart

Peterborough City Council

Plymouth City Council

PTEG

Reading Borough Council

Reading Borough Council

Reigate and Banstead Council

Restormel Borough Council

RMT Exeter Branch

Rossendale Transport Ltd

Runnymede District Council

Sevenoaks District Council

SmartCard Networking Forum

Smartran

South Norforlk Council

South Northamptonshire Council

Spelthorne Borough Council

St Edmundsbury Borough Council

Stevenage Borough Council

Stockton-on-Tees Borough Council

Stoke on Trent City Council

Suffolk County Council

Surrey Heath Borough Council.

Swindon Borough Council

Tandridge District Council

The Guide Dogs for the Blind Association and the Joint Committee on Mobility of Blind and Partially Sighted People

Thurrock Council

Tonbridge & Malling Borough Council

Transactions Systems Ltd (Transys)

Transport for London

Travel West Midlands

Tunbridge Wells Borough Council

UNITE, National Federation of Royal Mail and BT Pensioners

Uttlesford District Council

Wandsworth Borough Council

Watford Borough Council

Waveney District Council

Waverley Borough Council

Welwyn Hatfield Council

West Berkshire Council

West Wiltshire District Council

Wychavon District Council

Wycombe District Council