Submission by Bus Go Dunedin – Bus Users Support Group Otepoti-Dunedin to the Otago Regional Council's Draft Regional Public Transport Plan 2014

Dunedin, 22 August 2014


Bus Go Dunedin is an advocacy group for public transport in Dunedin. We work to gain a clear understanding of best public transport practice, to gather the views of bus users and to represent them to providers and operators of public transport. Our decisions are made by consensus at meetings open to the general public. We regard all Dunedin bus users as equally empowered to influence and approve our representations on behalf of users.

The 2014 draft Plan is the best public transport plan the Otago Regional Council has ever produced. We are particularly impressed with the skill and care with which council staff have applied the dictates of the NZTA's Passenger Transport Operating Model to our local bus network. We do not wish our objections (and there are quite a few!) to detract from our overall satisfaction with the Draft Plan.

Bus Go Dunedin regards this draft plan as a constructive step towards handing Dunedin public transport management over to the Dunedin City Council in the best possible state. We also wish to stress that our preference for city-led management is in no way a criticism of the regional council and its staff.

We appreciate the ORC's willingness to consult with us, and to listen to our suggestions for a better bus service. And we're particularly gratified to see our suggestions acted upon.

Bus Go Dunedin supports all parts of the Plan which we have not commented on.

Summary of requested changes to the plan

Bus routes

We support the "main roads" design approach used in the Draft Plan. We state our opposition to proposed major changes to the Brockville, Belleknowes and Concord routes and express concerns and suggestions for several other routes.

The Hub

We express reservation about the effect of the proposed Hub on scheduling and interruption of through routes and describe our concept for a hub.

Service and operations

We make several comments and suggestions about signs and numbers, branding and present a cost-saving option regarding bus doors.


We oppose the proposed fare changes: while supporting simplification of cash fares, we see no need to simplify electronic fares and view the proposal as unfair.


An Appendix lists all our requested changes to the Plan; included here are many small matters of policy and practice not brought up earlier.

The routes

In this part of our submission we wish to describe any concerns we have with changes to routes, with suggestions for adjustment to the Plan. We will not generally name routes by their proposed new number, as the assignment of paired suburbs and route numbers is arbitrary, a procedural matter and subject to change. Please note that we support the design of any planned routes that we do not mention below.

ORC's route design policies

Bus Go Dunedin supports the plans for through routes linked via a central hub. We also support the move to main roads not back streets as being in the long-term interest of the development of the bus network. We accept that the city's arterial road network generally follows the same geographical form as is needed for a public transport network (radial from a hub with the odd orbital route) We therefore support the move generally to place buses on the main road network.

In particular we support the following statements in the Plan:

P40 “Public transport will always be slower...this difference can be minimised by having more direct routes...”

P47 Network design principles “routes that are direct as possible without unnecessary impedance, deviation or variation”

P48 Patronage principles “routes designed to provide acceptable travel time compared to other common travel modes”

P49 “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey.”

Unofficial design approaches used by council staff

We note there are some features shown in the maps of the Plan's proposed network that are not backed up by any policy in the Plan's text. There appears to be unofficial design rules indicating a move away from looped services and that once out of the CBD, routes shouldn't converge or cross each other in the suburbs. Both these biases have affected the layout of the proposed network. This can result in some irritating “change for the sake of change” of well-established service patterns.


Loops allow a bus nearing the end of its journey to turn around gradually in a way that does not interrupt its journey. It should be realised that it costs about 50c to stop a bus and start off again, so it can be seen that a situation where passengers get off at the same time as others are getting on is preferable to a situation where the last several stops on a route are only used by those getting off, the bus does a U-turn, then the first several stops are only to board passengers. If the bus has to turn around anyway it might as well do something useful and cover a couple more streets.

There are two kinds of loops. Two-way loops involve a bus service travelling in both directions along a circular route. Examples in the existing bus service include Brockville-Halfway Bush (with which we disagree as those suburbs are far apart and the connecting road has very few residents) and Corstorphine (which we support as the layout of that suburb lends itself to such a loop).

One-way loops are supported in the Plan's text (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey” We feel it could be applied in a few more places. We give examples below of routes where one-way loops could be added to improve operational efficiency and service quality.


We disagree with any notion that once out of the CBD, routes shouldn't converge. It is not a Policy anywhere in the Plan and it would negate many benefits of the planned change to a transfer system. The more routes interconnect, the more connecting journeys are enabled.

Bus Go Dunedin requests that these undocumented, unofficial design biases against loops and convergence be removed from the proposed network design or re-opened for consultation as official policies.


Bus Go Dunedin opposes the huge cuts to the Brockville bus service being proposed.

At present Brockville is served by a bus every 40 minutes. The list of “network essential services” (P57) cuts this to every 60 minutes in the off-peak.

The proposed removal of all direct services to Brockville and combination of Brockville with the Belleknowes service represents a further service cut. Buses travelling via Belleknowes would take a huge time penalty before they even begin to serve the suburb of Brockville.

Of all the bus service plans described in the Draft Plan, Brockville would receive the greatest reductions in service. It would end up with the equal-worst bus service of any city suburb, as its service frequency would be reduced (along with Belleknowes) to the same level of Waverley.

The social justice issues surrounding this proposal demonstrate its unfairness. For over 20 years, Brockville residents have had to "pay their own way" — unlike almost all other parts of Dunedin, they have not had any Government or Regional Council subsidy for their daily bus service. This is in spite of their being one of the more socio-economically deprived areas of Dunedin, with low incomes and low car ownership.

See for example the data here:

Brockville has more single parent households (23.4%) than the rest of Dn (16%), and it is rated 8 on the University of Otago deprivation index (10=max deprivation).

Brockville's physical isolation from the city centre with steep hills makes other alternative transport, such as cycling, unavailable to many people.

To add an extra unfairness to the reduction in bus service, the Draft Plan proposes to upgrade the adjacent suburb, Halfway Bush, to a 15-minute frequency. At present, both suburbs have an identical bus service and a broadly similar social profile. We do not understand how this decision could be arrived at. Present ticketing data would not provide sufficient separation of journeys to and from Brockville and Halfway Bush on the present combined service for the council to make a fair decision so heavily weighted against one part of the present route.

The proposed routing of Brockville services via Belleknowes breaches the following parts of the Draft Plan:

P40 “Public transport will always be slower...this difference can be minimised by having more direct routes...”

P47 Network design priinciples “routes that are direct as possible without unneccessary impedance, deviation or variation”

P48 Patronage principles “routes designed to provide acceptable travel time compared to other common travel modes”

It appears the frequency cut has arisen from the policy that routes should run through the city centre to another suburb on the other side of town. Having picked Waverley as Brockville's paired suburb, the writers of the Draft Plan saw fit to drag Brockville down to Waverley's service frequency. We support the policy of a through-route structure but we do not support the route structure being used to lower the frequency on both ends of a newly-joined route.

Bus Go Dunedin requests that Brockville be served with a similar frequency to Halfway Bush with a direct route via Stuart St, Kaikorai valley Rd and Brockville Rd.

We suggest that Brockville services should end with a one-way loop on back streets of upper Brockville in keeping with the design principle (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey”


Bus Go Dunedin opposes the reduction of frequency for Belleknowes. We request that this suburb continue to be served half-hourly.

We support moving this route on to main roads. We recommend the extension down Stone St be deleted; this has not become an important feature of the existing route in the few years it has operated as the street has few residences.

We oppose the removal of service from the Arthur St area. We think a one way loop including this area is a fair, accessible and affordable design for a Belleknowes service in keeping with the "main roads" policy.

Bus Go Dunedin requests that Belleknowes be served by a one-way "Belleknowes Loop" service up Rattray St, City Rd, Ross St, down Kenmure Rd and Mailer St to Mornington, then down Hawthorn Ave and Maori Rd to Arthur St. See this Google map:

Belleknowes loop


We believe an hourly frequency is not sufficient to provide Waverley with a quality service but we note that this is not a reduction from the present service level. We would support any call by Waverley users for an improvement to their off-peak frequency to half-hourly. Waverley could be served very frequently as part of a large Waverley-Shiel Hill two-way loop of alternating clockwise and anticlockwise services.

Shiel Hill

See Waverley above. If the two suburbs were looped together at the same time that the increased frequency is applied, a situation whereby no-one is worse off and everyone is better off could be achieved. See this Google map:

Shiel hill loop

Corstorphine and St Clair Park

Bus Go Dunedin opposes the separation of this route proposed in the Draft Plan. This would be a further change services to this suburb and would follow the previous July 2013 service changes which had a disasterous effect on passenger numbers.

The users of the Corstorphine service made clear their desire for a reversion to the 2013 route in a recent popular petition. We note that the present service allows all parts of the suburb to chose between access to South Dunedin and the opportunities there for low-cost shopping as well as the faster route to town via South Rd.

We note that the Draft Plan indicates a higher frequency for the proposed Corstorphine (only) service but we fail to see why this portion of this suburb is proposed to have a higher frequency than the Kew-St Clair Park service.

If the service were to remain as at present we note that the present deviations through St Clair Park and Stenhope Crescent would clash with the Draft Plan's state aims of “main road” not “back street” service. We ask the regional council to investigate this matter further and we propose a solution below where we discuss the Concord route.

Bus Go Dunedin requests that both sides of Corstorphine continue to be served by a two-way loop service.


Bus Go Dunedin opposes the extension of the Kenmure route to Concord. We ask that it instead end in a large one-way loop following the design principle (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey” using Elgin Rd, Barr St, Kaikorai Valley Rd (west side to serve the College), Bryant St, Kenmure Rd, then back up to Mailer St. See this Google map:

Kenmure loop

Halfway Bush

We support the proposed improvement to frequency. We wonder if the frequency is a little too generous as some of our suggestions for adjacent routes would provide extra journey opportunities. We support the permanent loop via Ashmore St. We question the need for the dog-leg to Ashburn Hall as conrary to some of the Plan's network design principles but we would support its retention if a genuine need can be established there.

Wakari and Helensburgh

These suburbs are a little challenging for route planning as they have a fairly high population but all the main roads are around the edges.

Wakari 3 Hospitals Link

We oppose the extension of the Wakari route (marked 6) up Centennial Ave as this breaks all the “back street” rules and is unnecessary. On the other hand most of the Wakari route needs to be in back streets as this suburb is just one big back street. So we suggest turning this to advantage and using smaller buses for a “3 Hospitals Link" via Dunedin Hospital, Moana Pool, Olveston, Mercy Hospital, Lynn St and Chapman St to Summerset Village, then up Shetland St to Taieri Rd and into Wakari Hospital grounds.

We note that Wakari Hospital is a destination for some passengers with lower cognitive abilities and there was documented trouble in past years when some Wakari buses did not go to the hospital with that name. This has been remedied in the past several years as all buses carrying the destination "Wakari" have terminated close to the hospital. We request that this principle continue.

"3" would be a good number for this route, to go with the three hospitals.

See this Google map:

3 Hospitals bus


We support the planned route up Pitt St via Maori Hill. We recommend a fast route from there via Balmacewan Rd. An end one-way loop for this route is ready made: Helensburgh Rd, Taieri Rd, Wakari Rd and back down Helensburgh Rd. This will increase transfer opportunities around Wakari Hospital and augment the Halfway Bush route. See this Google map:

Helensburgh bus

Kaikorai Valley-Concord

Bus Go Dunedin opposes the deletion of this route. The present Route 38 meets many of the design principles included in the Plan, as a fast route along a main corridor. It should be developed and marketed as an outer orbital route, perhaps called "The Concorde". With little increase in route mileage, the Concord route could extend the full length of Mulford St to take over the Stenhope Crescent and St Clair park extensions of the Corstorphine route, enabling the latter to become a streamlined, fast loop service (see above). The Concord route should continue to intersect with Halfway Bush, Brockville, Kenmure, Mosgiel and aditionally Corstorphine and St Clair routes to provide many transfer opportunities for the new transfer-based system. In the distant future, we envisage this route extending down Bay View Rd to Andersons Bay and Portsmouth Dr.

Bus Go Dunedin request that the Concord route be retained as an orbital route and extended via St Clair Park to St Clair Beach. See this Google map:

The Concorde

Port Chalmers and Mosgiel

These two routes are not meeting their full potential as journey times are very long. We believe that any service frequency improvements to these routes be in the form of express services wholly on State Highways 1, 87 and 88 with stops at safe locations along the highways but no deviations. We support the continuation of regular parallel “slow” services along older back roads which include Roseneath, Fairfield etc. On the southern route, new highway bus stops at at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Saddle Hill and Mosgiel interchange should be built. These would also benefit long-distance coach passengers. Some of these could be superstops to enable interchange with local routes.

Port Chalmers and Mosgiel should be paired as a through route, because they would both need the same type of bus.

Bus Go Dunedin requests that improvements to the Port Chalmers and Mosgiel frequencies be in the form of regular high-speed direct express services stopping only alongside state highways with no deviations.


The Draft Plan proposes to delete the service from Wingatui, which has been served by public transport for over a century, just as the area has the fastest population growth it has ever experienced.

We ask that the Wingatui service be retained and expanded to allow practical and fast public transport to to the Heathfield, Owhiro Park, Gladstone Oaks, Highland Park, Silver Springs, Glenrothes, Puddle Alley and numerous smaller developments in the area. The regional council should develop a strategy for providing transport in growth areas in a similar manner to the way the DCC does with roading, water and drainage infrastructure, so that public transport can be provided pro-actively as part of the development rather than re-actively after the residents have moved in and made their transport decisions.

We would like buses not running for general public use to not display route numbers; this would set them apart from services open to the public. (referring to "Cruise Ship Shuttle, Route 88")

Woodhaugh-Ross Creek

We welcome the recent re-naming. This route operates below its full potential but is a tricky route to make money on due to low population density. We suggest it be run using smaller buses, and routed up Rockside Rd and Tanner Rd to form a clockwise one-way loop. This would reduce route mileage to lower costs as well as serve more homes to increase revenue. There are serious constraints to a large vehicle on our suggested route and it would have to be implemented with support of residents. We recommend pairing this route with our suggested Three Hospitals service also with smaller buses. See this Google map:

Ross Creek loop

Otago Peninsula

Including an extension of 1.3km on the route from the Harington Point terminus to the Royal Albatross Centre at Taiaroa Head would enable the ORC to market this route to tourists, thereby making it much more commercially viable. Extra zone boundaries could be loaded on to the new section to maximise revenue. This genuine "meet the locals" service would be particularly attractive to independent travellers/backpackers who usually avoid packaged sightseeing tours, so there need be no adverse effect on the tourist coach industry. Encouraging more Peninsula tourists on to buses would also reduce traffic hazards caused by drivers of campervans on this unfamiliar route.

Bus Go Dunedin requests that the Harington Point bus service be extended to Taiaroa Head, to make it more commercially viable.

The current Harrington Point service is also inconvenienced as a result of being routed via Harwood. Harwood is simply not "on the way" to Harington Point, being up a long side road from the main route.

Bus Go Dunedin requests that Harwood and Harington Point bus services be run separately, perhaps by alternating each service from Portobello to either of the two destinations, rather than trying to serve both areas with one route.

We note the deviation from the present Andersons Bay Rd route to run behind Mitre 10 Mega. We do not agree with this unnecessary twiddling with the route.

Ocean Grove

Please make official the present unofficial practice of buses running up from the present terminus to a gravel carpark; it provides a turning area eliminating a dangerous 3-point turn and allows passengers closer access to their homes.

We note the deviation from the present Marlow St route to along Ravelston St. We do not agree with this unnecessary twiddling with the route. The present route is well-known and fitted with good shelter.

Ridge Rider

We give wholehearted support to this route. To reach its full potential, it may be a good idea to “complete the circle” and run it from South Dunedin via the back of the Railway Station and Harbourside to the University (in both directions). This route should receive special marketing to tourists as it will provide a scenic tour of the city.

Stadium (route “2” on maps)

Seriously? It would be better to serve the center of the University and Otago Polytechnic. The stadium is an large-event-based venue; the proposed route would be always either too much or not enough to effectively serve that destination.

We do, however, suggest that all sixteen proposed bus routes be served by special departures from the Stadium organised by the regional council and its contractors after large events there. A shuttle service from the city centre to ths stadium before events would also benefit from being organised as part of the public transport network.

Operational matters

Destination signs and route numbers

We welcome the simplification of the numbering system, with routes having the same number in either direction. There will be some confusion with the renumbering, so we offer a solution: Bus Go Dunedin requests that all re-numbered routes carry the prefix "0" (zero) or "O" (capital O) to distinguish them from old route numbers. This could become part of the new network's brand image. O for Otago.

It would be ideal for bus route numbers to become the standard "names" for bus routes (rather than "the Normanby bus, the Port Chalmers bus" etc). Numbers are legible to more people including Chinese tourists and people with reading problems.

Many bus routes in Dunedin are labelled with witty or highly stylised destination signs to the great amusement of many but to the detriment of those who have difficulty reading, and ALL CAPS text is commonplace. Bus Go Dunedin requests ask that the best practice for destination signs be used This is detailed in NZTA's 'Requirements for Urban Buses':

Use of upper/lower case: RNZFB and the Association of Blind Citizens of New Zealand recommend that except for the first letter, all letters should be in lower case. When signs are written in upper case letters, they cannot be read easily by vision-impaired people. The exception to this would be place names such as Lower Hutt, North City.


We are not particularly bothered about whether the network has its own brand. A brand could make it more difficult to move buses around the country as contracts rotate, affecting operational efficiency and affordability. A simple "Otago Regional Council" sticker should suffice. If there were to be a brand, say "AcmeBus," it could be flashed on the destination sign alongside the route number, as in "AcmeBus 17" alternating with "Brockville 17". We note that many buses arrive from Christchurch with that city's branding attached and it appears reasonably difficult to remove.

The regional council could sell bus route naming rights to corporate sponsors, as in "Coca Cola Route 7 to [wherever]" - this would ultimately lower costs to passengers and ratepayers, and provide a continuity of identity to a route as its contractors change. Perhaps the sponsors' corporate colours could match the route map colours.

Bus company branding advertises that company's own corporate image, helping them to sell other bus hire services; what's good for bus companies is good for passengers. All-over advertising brings money into the industry and ultimately lowers costs to passengers and ratepayers. However, Bus Go Dunedin opposes advertising that covers bus windows.

Hub and superstops

Bus Go Dunedin welcomes the proposal to establish a hub for all routes to interconnect in the city centre

We do not want a hub to worsen the present situation where some through services run with long, seemingly random halts halfway along routes. This ties up millions of dollars worth of buses, often with their engines running causing pollution, blocking light from shop frontages, detaining passengers on board a stopped bus during their journey and generally bringing the bus service into disrepute. Bus Go Dunedin asks that ORC not allocate waiting times to routes at the Hub, rather operate a "just in time" timetable here.

The hub should be more of an idea than a structure. Dunedin does not need an elaborate bus station or terminal, just a place where all the routes touch each other. The hub should consist mainly of quality bus stops with correct kerb height, well-maintained glass bus shelters and seating. The hub should have a clean 24-hour toilet.

"The Hub Pub" and "Bus Stop Cafe" We suggest that the Hub needs two local food and beverage outlets, one licensed and one alcohol free; all these need to have apart from all the normal features of such a place is a large TV screen displaying arriving and departing bus times. Waiting passengers would be subject to the normal right of admission reserved by management and might need for example to purchase refreshments in order to wait inside or use toilets.

It would be a good idea for the Hub to have a small Drivers' Lounge with secure access and its own toilets. This should be provided at cost to the contractors.

Rear doors

We support the adoption of 'Requirements for Urban Buses' (P80 Policy 25), but with an exception for rear doors. We do not regard rear doors as an essential feature on buses for Dunedin, and safety, operational efficiency and affordability gains could be made from removing the requirement for rear doors.


Rear doors are always further from the kerb than front doors. They often align with driveway ramps or grass verges, if the driver has taken care to align the front door with a good boarding point or a waiting passenger, it is often impossible to get a good alignment for the rear door at the same time.


Visibility by the driver of passengers in the rear doorway is poor and passengers are often struck by doors, which can cause injury. There are examples elsewhere of passengers being dragged by rear doors and seriously injured or killed. Children exiting a bus by its rear door are able to walk behind the bus much faster, before it has moved off, and they are then more likely to be struck by cars travelling in the opposite direction. Best practice in the school bus industry is to put rear doors out of use enroute, and this practice could well be applied to public buses.


Rear doors are an expensive addition to a bus body. They occupy valuable revenue space. The tag-on-tag-off fare system could be introduced far more cheaply if tag devices do not need to be installed at rear doors.

Operational efficiency

It is noted that the lack of a rear door can inctrease dwell time at bus stops. But this would occur only rarely in Dunedin. On the other hand, rear doors often cause delays as it is not possible for a driver to safely open or close a rear door while carrying out any other duty..


Space occupied by doorways could provide extra room for standing passengers and prams (only those containing a child and able to be immediately moved).

We note that NZTA's 'Requirements for Urban Buses' allows a small bus to have one door and larger vehicles that will be used on longer-distance urban express/limited stop style services may use only one door with regional council approval.

Bus Go Dunedin requests that the requirement for rear doors be exempted and that contractors be allowed to put existing rear doors out of normal use except in emergencies or as directed by drivers.'

Christmas, Good Friday and Easter

Bus Go Dunedin requests that normal contracted integrated network public holiday services be operated on Christmas, Good Friday and Easter. The Draft Plan is silent on whether service would be extended to include these religious holidays. This is an omission given that all buses run on these days on the ORC's network in Queenstown.

We support and congratulate the Otago Heritage Bus Society for its Suburban Rumbler public transport service on Christmas, Good Friday and Easter, when no other public transport is operating. Our request above for contracted service on these three days is notwithstanding the excellent volunteer service that the Society provides. We note that the heritage service is inaccessible to some disabled users and only operates on two routes. We hope that extended integrated network service on these days would build on the outstanding achievement of the Society.

We believe Policy 8 and Policy 9 (P29) could bring about the end of the Suburban Rumbler. That service operates under exactly the same regulations and levels of safety as the proposed exempt “ii. School bus services not contracted to the Ministry of Education or ORC” (sometimes using the same make and model of bus).

Bus Go Dunedin supports the continuation of Otago Heritage Bus Society's Suburban Rumbler for as long as that Society wishes to operate it and requests that Policy 8 be changed to include “iii. Other services operating within an area normally covered by an integrated public transport network on days when this network is not operating” and that Policy 9 be amended to allow legally operable heritage vehicles providing an earlier standard of amenity including their noise and exhaust output within legal limits.

Service and operational principles and practice

General principles

  1. Predictable: no bus should ever depart a stop before its scheduled departure time. Patrons accept that buses can be late because of traffic etc., but early is never acceptable.
  2. Transparency and accountability: all buses should be fitted with GPS units so that adherence to contract conditions regarding scheduling can be monitored, as well as providing more accurate scheduling information for patrons
  3. Fares should be structured according to achieve these aims (with financial feasibility taken as read)
    1. Encourage growth in (a) number of patrons; and (b) number of trips
    2. Avoid further disadvantaging, and if possible enhancing the quality of life, of patrons who are disadvantaged financially, physically or cognitively.
    3. Encourage the use of electronic payment
  4. To grow passenger numbers, travelling by bus should be seen not only as cost-effective compared to private transport, but actually pleasant.
  5. The whole journey must be considered, for example it has to be safe to cross the road near bus stops
  6. The ageing population represents a growing market for buses, but they have to be convenient and easy to use.

Added features

Many features that could make the integrated network more effective could be introduced, and need not be expensive.

  1. Providing (preferably free) WiFi onboard, for example, makes the journey to work, or a tour for a visitor, more enjoyable and productive, and is a benefit that can't be obtained while driving
  2. Facilitate development of accessible, medium-cost door to door shared taxi-van service for late nights (not for ORC to subsidise, but to encourage). The aim would be to provide a similar pattern to bus routes when buses are not operating.

PTOM units

Bus Go Dunedin asks that there be two or three very small units These would be operable by a hypothetical small “mum and dad” bus company. We intend no criticism of large corporate bus companies but we wish to record the well-deserved reputation for friendly service achieved in the past by smaller firms such as Otago Road Services, Newtons Coachways, Peninsula Motor Service and Mosgiel Coach Services. The latter introduced several innovative electronic fare options on their new Concord service including student fares and weekly and monthly passes, as well as park & ride; most of these disappeared when they became part of a larger company. A variety of PTOM unit sizes is the best way to achieve the nurturing of innovation and close personal service. We note that there would be nothing stopping large bus companies successfully tendering to operate small units.

Fares and zones

Bus Go Dunedin opposes the proposed fare structure

We support the intent of the proposed changes but we feel the principle behind them is unclear. We wish to draw a distinction between cash fares, which we agree should be greatly simplified, indeed further than the Plan proposes, and electronic fares, for which we see no need for simplification, only fairness.

Cash: make it simple

Bus Go supports a greatly simplified system of zones for cash fares. It is quite absurd for a modern bus, worth $300 000, to be held up at a bus stop while its driver is searching for a millionth of that amount to give as change on a $2.70 fare.

We request that all cash fares be rounded up to the next dollar value and that electronic ticketing be encouraged. We would support a greatly simplified zone structure for cash fares, simplified further than proposed in the Draft Plan and amalgamating the proposed central Zones 1 and 2. This would eliminate all but four zone boundary points (between the ORC's proposed Zones 2 and 3; at St Peter Chanel, Sunnyvale, Roseneath and St Ronans; also possibly approaching Taiaroa Head in our proposal for that route). It is boundary points, needing to be learned and uinderstood by passengers and drivers, that make a cash fare system "complicated" and hard to use.

We believe that the cash fare scale should give a clear message that electronic ticketing is preferred. Transfers need not be available on cash fares. We accept that our proposed cash fare policy could lead to hardship for some passengers. We believe that concerns about affordability should be addressed through changes to the electronic ticketing system, which we will explain in Affordability below.

We note that the industry is concerned about muggings of drivers and that a “no change given” policy may arise as nationwide policy in future.

Electronic ticketing: keep it fair

Bus Go supports a system of fares reflecting the actual distance travelled for electronic card users We fully endorse all the documented advantages of a tag-on-tag-off electronic fare system, with its reduction of fraud, prevention of ticket over-running and, speeding of boarding (and therefore service speed). The Draft Plan has failed to grasp the advantages of tag-on-tag-off in its assertion that there is a need for simplicity in the electronic fare structure. With tag-on-tag-off, passengers don't need to know their destination zone, or the name of the street where they are heading. Drivers don't need to memorise zone boundaries. Passengers can even change their mind mid-journey and divert to a different destination; the ticket system will adjust their fare automatically.

We assert that an electronic system of fares does not need to be simplified, it just needs to be fair. For regular passengers, distance is the only equitable means to levy fares. The more zones there are, the more closely the fare will reflect the distance travelled. (The tag-on-tag-off system could even charge passengers per kilometre, which would be a great marketing tool as it would allow a direct comparison with taxi fares and car running costs.)

We oppose the proposal that everyone in Musselburgh, St Kilda, South Dunedin, Kew, Caversham, Mornington, Kaikorai, Wakari, Woodhaugh, Liberton, Dalmore, Northeast Valley, and most of Opoho, as well as Fairfield, Waldronville, Sawyers Bay and Macandrew Bay, would have their fares to the city centre increased.

Bus Go Dunedin requests that there be no fewer than the present number of zones for electronic card users.


Now that the bus fleet is wheelchair friendly, another barrier to many people's mobility is becoming more obvious. Bus Go Dunedin often recieves information that people are unable to afford bus travel. We hear of people who use their car because it has petrol in the tank but their GoCard is empty. We hear of people scrounging their home and family members for loose change to travel by bus on a more expensive cash fare because they can't afford the dent in their food budget that a minimum $10 GoCard top-up entails. Although we proposed above a fairly punitive cash fare scale, we feel that the electronic fare system holds great scope for assisting with affordability. We note the recent student 25% discount trial which resulted in acceptance of the lower fare level by contractors and a gradual uptake by students.

Replace Go Card Extra with CSC discount

We also note the continued problem that people with disabilities who use Go Card Extra are put to great incovenience in collecting and renewing their cards from the ORC's premises. Citizens from rural areas visiting Dunedin health services are unable to temporarily gain the discount. We understand that all Go Card Extra holders are also Community Services Card holders. Community Service Cards are received and renewed by post. We note that all Community Services Card holders (including those visiting from Otago) get a travel discount in Hawkes Bay, New Plymouth and Palmerston North. We note that this would widen the present discount to many more people including all unemployment, sickness and domestic purposes beneficiaries and many low-paid workers. Therefore we accept that this discount should be introduced as a trial to ensure that it enhances mobility rather than merely lowing revenue. Bus Go Dunedin requests a fare discount trial extending a 25% discount to all Community Services Card holders, and that the discount be made permanent if it causes a significant increase in mobility of low-income people.

One Last Journey

Passengers stuck in the suburbs with no cash to put on their card can't get to the bank to get the cash, and people stuck in town late need to get home. In London, a 'one last journey' facility allows anyone with any card balance above zero to travel, and the fare is deducted at their next top-up. Bus Go Dunedin requests that a One Last Journey facility be included in the new electronic ticketing system

Minimum top-up

The present minimum top-up unfairly prevents low-income people to get access to discounted travel as they can't scrape together $10 for the minimum top-up. Bus Go Dunedin requests that the minimum top-up threshold be reduced to $5.

GoCard "travel bank"

We suggest that ORC organise a "travel bank" like a food bank, where people could donate Go Card top-up vouchers to be distributed by social agencies to transport-disadvantaged people.


Bus Go supports the move to a transfer system

We have already expressed our concerns at the lack of interconnecting routes which would negate some of the benefits of a transfer system.

The proposed system does not seem to be very generous: "free transfers within a single zone" (P82, Policy 29g). We believe passengers should be able to make cross-town, orbital and any other reasonable route with no penalty (other than the time-consuming transfer itself). So for example, it should be the same fare from Normanby to Brockville (with a transfer) as Normanby to St Clair (direct), as should weird and wonderful routes that nobody at the ORC ever imagined that people might need to take, such as from the Exchange to Balaclava then transferring at Lookout Point to Caversham.

Bus Go requests that all transfer journeys be levied the same fare that would be payable if there were a direct bus covering that route, no matter how many times the passenger needs to transfer.

Fare innovation and value maximisation

We accept the need to maintain or increase present revenue in the industry. We feel that there is great scope for increasing use through novel marketing schemes. A general principle should be that using public transport is a rational economic decision: it's slower and somewhat less convenient than private transport, but it's cheaper. We note that while bus fares are reasonably comparable with car running costs for a single motorist, filling the seats of a car destroys bus travel's cost advantage.

The present discounts do not reflect discounting behaviour in other parts of the transport indistry. A quick search of for flights to Auckland shows $249 on Friday 15 August but only $99 for a flight on 25 October. That's 60% off, which makes Dunedin's 10% for "frequent flyers" (Go Card users) or 25% for students look less generous. Could explain some of the empty bus seats.

We note that a recent ORC contractor, Mosgiel Coach Services, ran several promotional fares. Discounting could be ORC-led system-wide or route-based by contractors, but we would like to see some more innovation.


  • Concessions for a carload of adults and children travelling together (fare to be set lower than running costs for a car). Travel together to be determined by the group adjacently boarding/alighting on the tag-on-tag-off system.
  • Concessions for constant users who make the same return trip every work or study day, such as every fifth or tenth day free, or free weekend travel for two adults and some children. The "Flybuys" or "coffee card"-style points could accrue automatically as they use the tag-on-tag-off system.
  • Bus pass deal with schools. At present some schools send a van around the suburbs and charge parents $1 each way per day. If they are able to do so at this price, surely a similar deal could be offered to fill empty seats on bus routes. Schools could buy concession cards in bulk and sell them to pupils.

21st Century fare systems

Principle: with smartphones and tablets becoming ubiquitous, these technologies can be leveraged to provide a more user-friendly experience for patrons, and lower costs for service providers.

  • Explore options for payment via smartphone, for example with NFC, WiFi, Mobile Data or Bluetooth technology, and (possibly) an app or web service that functions as a "card", i.e. can be topped up, balance checked etc. Maybe using Google Wallet and similar services.
  • Explore options for partnering with ISPs and telecom operators such that using your phone as a bus card and searching for route information on ORC or Google Transit will not incur usage charges, or count against a quota.
  • Explore options for extending WiFi to more than the occasional experiment on a couple of buses. Obviously free would be preferable, but maybe access could be linked to use of the bus "card" on one's phone.

Appendix: page-by-page requested changes to the plan

This part of our submission will take the form of page-by-page requested changes to the Plan. Minor quibbles are listed along with major objections. Major changes requested in this section are addressed in detail earlier in the submission, but we ask that attention be given to minor policy changes included in the following list.

All parts of the plan: Many chapters of the plan present “policies” written in bold, while in other places, assertions as to future practice and requirements are stated less clearly, as goals, strategies, as data in tables. We would like the Plan to clearly mark all policy; this would lead to roughly a doubling of the numbered policies. We suggest that each policy be given a chapter and policy number (as Policy 1.1 to Policy 9.999) We want it to be clear what is policy and what is general expanatory text. We want to be able to measure actual performance against this Plan's clearly stated policy. Where the Plan makes an statement about required performance which is not marked as Policy, we will from time to time request this be elevated to a numbered policy point.

P12 “representatives of groups...” Please name the groups.

P27 Total Mobility: Please make “we will implement these policies” as a numbered Policy in itself.

P29 Policy 8, Policy 9: Bus Go Dunedin requests a change to these policies. We will present this in a earlier part of this submission.

P30: Tables 4 and 5: please identify these as Policy

P30 table 5: Please amend heading to read “Long distance coach stops” not “bus termini” and under Dunedin City include existing coach stops at Botanic Garden, Great King St North, Countdown Cumberland St, forecourt of Dunedin Railway Station. Bus Go Dunedin also desires coach stops at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Mosgiel interchange.

P38 “trialling a student discount” This is now ORC policy in Annual Plan; please amend to read “introducing a student discount”

P40 Table 5: (Note there is already a table 5. Better perhaps to number tables by chapter) “Proposed response” please elevate to numbered Policy.

P44 What we want to achieve (and table 6 on P45): Please elevate these goals, objectives, measures and targets to numbered Policies.

P45 Table 6: “Fully accessible public transport” Please change to “ Fully accessible buses” and insert new row “Fully accessible bus stops” | “Proportion of bus stops with correct entry and exit of bus to stop, kerb height and safe pavement surface” and give current performance and future target (which latter Bus Go hopes will be “excellent”)

P45 Table 6 “Idling of buses does not...” Please amend to read “...public health or amenity values”; amend next cell to read “...limits for health and does not attract complaints”

P45 Table 6 Please add new row “Buses do not clutter city centre” | “Buses are scheduled and operated in order to arrive 'just in time' for each departure from the city and do not need to be stored downtown in large numbers for long periods while they await their next departure” and give current performance and future target (which latter Bus Go hopes will be “excellent”)

P47-48: Please upgrade all objectives and principles in this chapter to numbered Policies.

P48 Access and mobility principles: Please add new point “accessible design standards of bus stops with correct entry and exit of bus to stop, kerb height and safe pavement surface”

P48 Efficiency principles “scheduling that makes good use...” and “scheduling that avoids...” - Please add “and operating practice” to read “scheduling and operating practice that makes good use...” and “scheduling and operating practice that avoids...”

P50-55: Bus route maps

We give a critique of the proposed routes earlier in this submission.

P57 Table 7: Bus Go Dunedin objects to the severe reduction of initial weekday frequency of 60 minutes off peak for Belleknowes and Brockville and also seeks adjustments to the frequencies of Waverley, Mosgiel and Northern Services. All these are detailed earlier in this submission.

P62: Bus Go Dunedin opposes some of the changes to electronic zones and fares and will request changes to the proposed cash fares. All these are detailed earlier in this submission.

P64-65: Bus Go Dunedin has views on the city bus hub, superstops and real-time information. All these are detailed earlier in this submission.

P67 Services important to the wider public transport network: Bus Go Dunedin asks that the regional council go beyond merely “acknowledging the importance” of inter-regional, exempt and excluded public transport, but rather give public and political support (not necessarily money) to these services, for example: a page in the public timetable summarising these services, links from the council website, inclusion in the Journey Planner. Bus Go Dunedin also desires coach stops at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Mosgiel interchange.

P69: Principles of the unit design: upgrade to Policy

P70-71: Dunedin PTOM units: please note our requested change to include some smaller units.

P73 Policy 12 (a) “without services tailored to different customers”: We note that this policy is at odds with the Policy 8's provision for exempt and excluded services; for example school buses are certainly “tailored to different customers” - we ask that the Plan text explain this in a preamble to this Policy.

P74 7.2 Network structure... “ORC will implement these policies”:needs in itself to be a Policy.

P75 Policy 18: add “(e) Bus stops to meet design specifications in 'Guidelines for public transport infrastructure and facilities' NZRTA 2014

P76-84 Standards I-XIII: restate all these as numbered Policies.

P76 Standard I (a) “peak periods: at least 10 passengers per trip” Bus Go Dunedin objects to this provision and wonders if it is written in error. At peak periods it is common for trips in one direction to be full and then run empty on the return to pick up the next load. We wonder if it was intended that peak trips therefore need to have 20 people on all directional commuting loads. We ask that Standard I (a) be amended to read “peak periods: at least 10 passengers per return trip”

P77 Policy 19 (a) “defining quality standards”: Please add “... for buses, bus stops, bus routes and operation of services”

P77 Policy 21: This seems to be written as a catch-all disclaimer to exonerate ORC's contractors. Please rewrite this as a list of what contractors “are” liable for, what “is” in their control. This Policy should also mention that the Consumer Guarantees Act gives passengers rights as consumers.

P77 Policy 22 (b): Please add a note that standing on an urban bus is legal and safe, if rather uncomfortable.

P78 Standard II: Bus Go Dunedin objects to the 59 second tolerance allowing early departure from timing points. We ask that this tolerance be amended to read “0 seconds to 6 minutes and zero seconds after the departure time” Bus Go Dunedin accepts that bus services in order to be operationally efficient, safe and affordable may often run slightly late, but we insist that early running should be clamped down on wherever it occurs.

We also ask that the following text be added: “en-route timing points should be scheduled, and contractors should operate buses in traffic, so that the bus arrives at the timing point 'just in time' with no undue interruption to the continuation of the journey, except to await connecting passengers.”

P79 Policy X: Please add text “Prams containing resting or sleeping children should be recognised as a mobility aid in use by a passenger, not viewed as an obstruction to other passengers, and drivers shall allow prams containing children to occupy any part of a bus where passengers are allowed to stand, provided that the pram can be easily moved (off and back on the bus if necessary) as required to allow safe movement of other passengers”

P80 Policy 25: We support the adoption of 'Requirements for Urban Buses' with an exception for rear doors. All these are detailed earlier in this submission.

P80 Policy 27 “0-10 years... Equal or greater than 50%”: Bus Go Dunedin opposes this policy on grounds of affordability. A bus is a bus. We desire buses of a high standard of cleanliness, safety and comfort, but we do not accept age (within the proposed 19-year age limit) as a determinant of bus quality. Any bus meeting the NZTA RUB is acceptable. We understand that the RUB gives 50% 0-10 years as a “desired fleet profile” not a requirement. There are good reasons to operate old (cheap) buses, especially to allow a reserve fleet for peak or emergency use. Bus companies will use new buses according to their needs to lower running costs.

P82 Policy 29 (g): Bus Go Dunedin opposes the proposed changes to electronic fares and zones and seeks changes to the proposed cash fares. We detail these matters, along with transfers, earlier in this submission.

P82 Policy 29 (h): Please list all the mandatory concessions, not just child fares.

P84-85 Provisions for Contracts A-D: Please re-state these Provisions as Policies.

P86 Policy 31: Replace with “Public transport infrastructure meets the design standards in 'Guidelines for public transport infrastructure and facilities' NZTA 2014”

P86 7.7 “We will implement these policies through” - Please re-state the implementation as itself a policy.

Please add policy points as follows: (a) timetable booklet to be designed in consultation with users to be clearly legible (b) delivery of booklet to households (c) hours of operation of call centre (which Bus Go would like to be all hours of operation (d) call centre target waiting time

P87 Policy 34 (b): Please make it clear that ORC is to provide timetable booklets which contractors should make available on buses and that contractors provide timetables of their own indvidual routes on their buses at their own cost.

P92 Table 17: Please elevate this table to the status of Policy.

P94-95 Policy on significance: Please present the policies here as numbered policies.

P94 Non-significant variations: Add “and user groups” to each point to indicate that user groups should be consulted.

P97 Table (un-numbered): Please make clear that this table is Policy. Please add “and user groups” at each place where it is stated that ORC will consult with operators or local authorities.

In the third row of this table, Bus Go Dunedin would support a regime of contract-lengthening as an incentive where performance targets are being met. Lengthening contracts reduces disruption to users, contractors and their employees and is a worthy reward for good performance.

P99, top “We developed this assessment...”: please change “Blind Foundation” to “Royal New Zealand Foundation of the Blind”, “Bus Go Group” to “Bus Go Dunedin – Bus users support group Otepoti Dunedin”, “VICTA” to “VICTA - Visual Impairment Charitable Trust Aotearoa NZ”, NZTA to New Zealand Transport Agency

P108 St Kilda to halfway Bush and Brockville and return: change “20 minutes” (a very rarely applied peak frequency) to “40 minutes” to reflect the usual frequency.

P124 Appendix 6 table 23: Please indicate that this table is Policy. Please add in the row “Public satisfaction..” the source “Complaints and compliments to contractors and to the ORC and in the media about bus services” Please add in the row “Indicator of reduced emissions” the source “Complaints to ORC, to contractors and in the media about bus exhaust”