It’s always rather amusing to read an article which argues with a case you have made, only to find that the person is arguing with something he thinks you said rather than what you actually said.

It’s also occasionally frustrating, because it becomes quite clear that the people doing the arguing have either not read or not understood the argument you were making.

Such is the case with the new edition of “New Transit” magazine published this week, in which a Mr Abrantes, an economist with PTEG, has taken issue with the evidence TAS submitted to the Competition Commission in April.

He spends some considerable time in his article attempting to prove that some bus companies in some areas make more money than Barclays or BT (though why this should amount to a hill of beans is rather beyond me, I am afraid). He then wanders off into the minutiae of game playing about marginal services being deregistered in order to win back contracts.

And finally he seems to take the view that the TAS evidence to the Competition Commission argues against further regulation of the bus industry.

Most of which bears only a passing resemblance to what we either said or (in case it’s our fault) were trying to say to the Competition Commission.

So here’s another go, in a quick ten-point summary:

(1) Entrepreneurs do not enter the bus industry because there are much easier ways of earning a living than running bus services – especially in the era of the internet and other creative businesses which have low entry barriers and costs and from which there are huge opportunities to make money, without the risk of having to compete with large and powerful incumbents and cope with local authority bureaucracy.

(2) Bus demand falls mainly for demographic reasons to do with car ownership and reducing trip rates amongst the non car-owning population.

(3) Bus services have difficulty competing with the private car because the generalised cost of bus travel is, on average, more than three times that of the equivalent car journey (watch this video to understand this point).

(4) Over 60% of bus operating costs are accounted for by labour costs. For all but a very few of the last 50 years, labour costs have risen by more than inflation, therefore bus industry costs have also risen by more than inflation. That is not likely to change.

(5) Falling patronage and rising costs increase unit cost per passenger carried, and there is no alternative to increasing industry revenue other than putting the fares up or increasing public subsidy (which the country cannot afford).

(6) On the road competition is irrelevant to all the above, and having one, two or 86 bus companies on one route changes none of it.

(7) Putting local authorities in charge of planning bus services changes none of the above, simply transferring the risk to the public sector which (a) cannot afford it (b) is not good at managing it and (c) has not got the staff or resources available to run it.

(8) If we must have more regulation, the solution does NOT lie with local authorities. For several reasons:

• Given their influence over the key matters of product design (journey time) reliability (through traffic control) and point of sale (bus stations, stops and shelters) local authorities are part of the problem, not part of the solution – and need regulating in the interests of the passenger as much, if not more than, the bus companies.

• If we learned one thing from the last time local authorities were in charge of bus services from 1974 to 1986, it is that operators come to view authorities as the customer rather than the passenger, resulting in disconnection in that vital relationship and poorer standards of service.

• Putting local politicians in charge of bus network design means risk aversion, leads to networks set in stone rather than being able to develop and respond to changing patterns of demand, and increasing costs.

(9) We know from experience that partnership between enlightened local authorities and strong local operators works and there are huge numbers of examples all over the country. Why can’t we learn from what works and implement it everywhere?

(10) If local authorities really want to change all or any of the above they need to implement bus priority measures, put up parking charges and take measures to increase the generalised cost of the car relative to public transport; if they’re not prepared to do this, then all the rest is pointless posturing.

Hope that’s clear.