Consultation is ‘flawed’

I’ve reviewed the ESCC Bus Service consultation document and made my comments. These focused on the potential impact on the Language Student business in Hastings of losing evening and Sunday services.

The ESCC Consultation Document has a section marked Related Documents “List of Services which may be affected”. Clicking on this leads to a two page listing. The second item on the list refers to routes 20, 21, 22 and under the section marked “Proposed frequency” has the wording “Remove from 7pm Mon-Sat and completely on Sunday”. Anyone using routes 20A, 21A, 22A or 22C, which are regular all-day Sunday routes, might reasonably conclude that their service is not under threat and therefore not respond to the consultation document.

However, the Sunday bus service is integrated: buses arrive at terminii and often change route number before heading back in the opposite direction. For example the Rte 20A bus which arrives at Ore, Down Farm at 44 minutes past the hour becomes a Rte 20 bus leaving at 49 minutes past the hour. Some buses actually change route number en route (22 to 22A or 21A to 21 at Hastings Station). I contacted the County Council and they checked to see if some Sunday journeys are commercial (and therefore out of scope for the consultation) and others supported (and therefore in scope). The verbal response from the manager ‘running the consultation’ was that this is not the case and that they are all supported and therefore liable to ‘removal’.

The ESCC view appears to be that reference to 20, 21 and 22 implies reference to 20A, 21A, 22A and 22C (there will also be the odd evening B route as well), that these latter are ‘subsidiary routes’ and therefore covered in their consultation. But no-one travelling to Tile Barn Estate would ever regard the 22A as being the same route as a 22 or someone travelling to Parker Road that a 21 was the same route as a 21A. Indeed on Sundays all buses that go to or from Malvern Way are on Route 21A; users might therefore reasonably see the “List of Services which may be affected” and conclude that, as Rte 21A is not on it, their Sunday bus is not under threat. To my eyes the consultation is flawed and though this is not my area of expertise, open to judicial review.

If the County Council is not listing on a “List of Services which may be affected” services which are under threat this is slip-shod and makes a mockery of the Public Consultation. If they had to re-run the consultation the opportunity to further mobilise opposition to this removal of evening and Sunday services would become available.

Philip Crow

Harley Shute Road