Some of the opposition to the Regional Fuel Tax has come from those concerned about the ability of low income households to afford the extra costs

This article by Manukau Ward Councilor Efeso Collins lays out many of those concerns.

Due to low household incomes, my community doesn’t have the luxury of paying additional tax now, to benefit future generations. For those who are struggling to provide basic necessities for their whānau, further tax, no matter how well-intentioned in principle, can seem impossible. In Māngere-Ōtāhuhu and Ōtara-Papatoetoe local board areas the median household incomes combined average $59,950, one of the lowest figures across Tāmaki Makaurau.

This got us thinking about how the public transport system can better serve the needs of low income earners. Much of what we advocate for we do so because it benefits all Aucklanders, from across the city, and from different backgrounds and income levels.

I think we have made some progress in recent years, but we also have a long way to go. On the positive side:

  • Major rapid transit investments like Light Rail to Mangere and the Northwest will transform how people move around Auckland, and help connect people to jobs and opportunities across the city, without having to rely on a car.
  • The new network does a much better job at providing for cross-town trips, particularly across south Auckland. The old bus network basically focused on ferrying people into the city centre, which doesn’t make much sense when a pretty small proportion of residents living in the south work in the city centre.
  • The zone-based fare system has made cross-town trips much cheaper than they used to be by generally placing these trips within a single zone – even if they’re quite long. For example, a trip from Mangere to East Tamaki, or Otara to the Airport are all within a single zone – under $2 a trip with a Hop Card.

On the flip-side, there is still much to do to make public transport services better cater for complex trip patterns, including shifts. Some of the recent cuts to some bus services in South Auckland are a step in the wrong direction.

Furthermore, for some people and some trips, public transport fares remain a high burden and either discourage people from using these services, or use up precious money needed for other things like rent and food. In general we are not in favour of across the board fare cuts, for the simple reason summarised by Jarrett Walker:

If you want transit to be mainly for low-income people who have a low value of time, cut fares, as this is an improvement  targeted to benefit only the cost-sensitive.  By not improving service, this choice may also lead to an increased “stigma” around transit as it is perceived, with increasing accuracy, as a low-quality experience that is of no relevance to people who have choices.

If you want transit to be useful to a broad spectrum of the population, increase service.

However, what could be a good idea is ensuring that our approach to concessionary fares are, well, fair. Currently the following groups are given concessions on full fares:

  • Child and Secondary Students – 40-50%
  • Tertiary Students – approximately 25%
  • Over 65 years – Free Travel after 9am weekdays & all day weekends with the SuperGold Card
  • Accessible Fares – 40-50% for those with a Blind Foundation ID or if deemed eligible for the Total Mobility Scheme

What is missing in this list is support for those on low incomes or benefits (unless they are over 65!)

These types of concessions are common overseas. Note in Australia concession usually means a flat 50% discount of full fares.

Cards eligible for concessions in Canberra

One complexity of fare concessions is they generally require an existing government card to prove eligibility both when the concession is loaded onto the electronic card, as well as when fare inspections are undertaken. However I’m sure there are ways of getting around this issue and linking it with people who are eligible for a ‘Community Services Card’.

Eligibility for a community services card is somewhat complex, but includes:

  • Those on a benefit get automatic access
  • Student Allowance
  • Single people earning under $26,000
  • Family of 2 earning under about $50,000, with the threshold rising by about $8,000 per child.

If there’s a concern about how this might be funded, I think the first place to look would be getting rid of the Waiheke Island Super Gold Card rort that was exposed by The Spinoff recently:

It revealed just how concentrated the benefits of this scheme are: the data showed that the top 1000 users of the scheme used almost $1.9m in the 22 months to May 2018 – an average total of over $1,800 per pensioner, and over half of total payments to ferry operators.

The top 100 users have an even more shocking slice – they have claimed over $400,000 in free rides in less than two years: an average of $4,087 each.

The cost of an adult return fare to Waiheke is $38, and there is no discount for HOP card users or seniors who don’t hold a Supergold card. The upshot is that the 100 most frequent users of the service are using over 10% of the total budget for ferry travel to Waiheke.

Who needs a bit of extra help – rich pensioners commuting from Waiheke Island and costing us $38 per return trip, or struggling south Auckland families who would just need a $1-2 subsidy per trip to halve their public transport costs?

We need to make our fares fairer.

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75 comments

  1. Yes Waiheke shouldn’t be completely free for Supergold it should only be part subsidised. Perhaps $10 off

    1. I did a trip to Auckland today and paid a cash fare of $29.00 and if I went over night it would be $32.50 with using my Captains Club Card , but if I used my AThop Card it would have cost me $19.00 each way . So why doesn’t AT try to get a special rate from Fullers to reduce the cost when using the Gold Card or is that in the too hard basket for AT . Back before the Gold card came about Fullers use to have pensioner discounts for both Ferry’s and Buses . The cheaper of the fares is off Island only

  2. i also wonder why supergold users get premium services like the 91 airport flyer in the capital. Seems like a way to increase the cost of supergold card provision.

    1. They kept increasing the fares for ordinary passengers to the point where the buses were used almost exclusively by SuperGold card holders.

  3. I agree with the principle of making PT more affordable and fairer in its application.
    But why can we not dispense with zoning altogether and let fares be simply based on distance plus a flat fee for tagging on, e.g. say $1 to tag on (to cover the overhead cost of the transaction) plus say 50c a kilometre travelled (the numbers I suggest are just a “starter-for-ten”). This would eliminate the situation where people who board just before a zone boundary and get off within the next zone are charged for a 2 zone trip even though their journey may equate to less than a full zone travelled. The necessary calculation would be easily managed by the existing system and result in fares that more accurately reflected the distance travelled.

    1. Then you get the unfairness of paying more for your trip because their was no direct PT option – for example if you have to go into the city and back out again.
      Also distance is not the main cost of the service, time is the main cost. A bus doing 5km/hr costs almost the same to run per hour than one doing 50km/hr.

      1. Distance based as the crow flys, I’ve thought about this before. Problem is over water eg Mangere Bridge to Sylvia Park in which case special predefined waypoints that the straight distance lines could wrap around if necessary. Cash could continue with the same zone based structure due to its prepay nature.

    2. Good outcomes for equity, given that the distant regions are usually poorer. Good outcomes for mode shift. There’s still an incentive to live closer to town, because of the time savings, but it allows money to not be the barrier to access. Accompanied by much more funding for public transport to allow all fares to be low, and congestion pricing, it would work. Without that increased funding, it wouldn’t.

    3. To complicated, people like to know what they are paying for.

      If the idea is to incourage people to use PT, then large zone system with fare caps (so people know they won’t spend over certain amount) works best. If you are not concerned about increasing PT use, then distance based on point to point fare is best.

  4. Reducing farebox recovery rates as required by NZTA will give AT leeway to introduce these sorts of fares.

    But bear in mind that would be AT implementing what really is a central government function/policy. Doesn’t mean AT shouldn’t have a social outcomes requirement, but it needs to be spelled out and be transparent.

    But this “we can’t afford the PT fares” is merely yet another symptom of the working poor situation that is becoming so prevalent even entrenched in NZ. I think targeted assistance is great but as a crutch for actually making the hard decisions on wage rates and other big picture things – I think its a poor substitute and not a long term answer.

    The Gold Card for Waiheke [and other similar high cost trips] should be a concession which has a capped benefit, i.e. maximum of 10, 20 or whatever free Waiheke trips. per “financial/rating year” [which is 1 July to 30 June] , its automatically loaded on your Goldcard linked HOP each year, and you can only claim it with your Gold Card linked HOP card. When they’re spent, they’re gone until next year.

    Still provides a huge benefit, but not an all day every day freebie as it has been used by some.

    1. Yeah, I’d prefer a capped number of Waiheke trips to a partial subsidy. It lets retired people on Waiheke with low incomes (there must be some still?) come to the city when they need to, but 65+ employed people don’t get their daily commute paid for.

      1. Retired people work in city who work hours between 10am and 2:30PM ??
        Remember Gold card only available for journeys between 9am and 3pm and after 6.30pm

        1. Not in Auckland – the council picks up the tag for all day travel after 9.00 am. It’s only in other regions where the afternoon peak is excluded from the gold card free travel.

  5. The zone system isn’t based on any idea of fairness. It is based on the proximity to the CBD even though most trips are not going there. Long trips within the same zone are far cheaper than a short trip across the edge. PT should be priced to include the positive externality of the car trip avoided. That would make long trips cheaper than short ones. Maybe that is too extreme but certainly a single price for all trips would be fairer than the current system.

  6. Ive lived for some time in a poor area of south auckland and understand some aspects of what is a complex problem. Most of the poor people I know living around me have large families and work weird hours with shift work. They also tend to look after their elderly parents at home, don’t use day care and tend to be renters. Teenage family members leave school early to get minimum wage jobs to help contribute to family expenses. Overcrowding and poor insulation means they are sick often. They also may not be very financially literate which just makes things worse. These factors make it difficult to use PT because it can be quite expensive. I don’t know what the solution is, but a costly, low frequency PT service isn’t helping.

    1. +1
      They have big families in 7 seaters.

      It is always cheaper to drive compare to 7 paying persons – as well as to buy 7 hop cards, which most of them don’t have that money.

      1. The quote says it all:
        “…my community doesn’t have the luxury of paying additional tax now, to benefit future generations. For those who are struggling to provide basic necessities for their whānau…”

        It’s a luxury to have a large family. People that can’t afford to pay for ‘future generations’ (or even the current generations) might want to think twice before expecting a subsidy.

        1. How dare these poor people expect to life fulfilling lives with healthy families, right?

          Sarcasm, obviously.

  7. I have very mixed feelings about dealing with the Waiheke Island “rort”. On the one hand, there’s a strong sense (indeed, fanned in this blog) that some people are using the free ride in a way that was not anticipated. But when you boil it down, the $4,000 spent by the most frequent users represents just just over 100 trips a year, or two return trips a week to the city for a small number of Waiheke pensioners, and considerably less than that for the average pensioner. Is that excessive? I really don’t think so. I’m sure that there are many, many pensioners on the isthmus who make more than two return trips a week into the city.

    The issue is not the number of pensioners using the ferry, but the cost of the ferry ride itself – which is plain and simple extortion. At an average of $19 each way for a 22 km ride, it’s waaaaay more expensive than the HOP fare for a 34 km trip from Britomart to Papakura. Surely this is more a case of Fullers ripping off the passenger, and the taxpayer, rather than pensioners rorting the system.

    I say this is a strong argument for addressing the root cause, rather than the symptom. The root cause being the fact that (a) Fullers’ Waiheke and Devonport services operate outside of PTOM, and (b) there is a fare bias against ferries which in the new PT nirvana should be abolished so that the fare structure is “mode-neutral”. The way things stand, the fare structure actively discriminates against passengers from those parts of the city where the best (and sometimes only) mode of public transport is by water.

      1. Buses and trains don’t have the same cost structure, either, but we charge the same fares because it’s equitable. Some suburbs are well-served by train, some by bus. And, I would argue, some (like Devonport) are well-served by ferry but have mediocre bus service. The current fare structure actively discriminates against people who live in places like Devonport or Beachlands-Maraetai – in fact, against anyone for whom the ferry is the obvious PT choice. Why would we want to discourage these people from using public transport?

        I once asked someone in the know at AT about why there wasn’t a mode-neutral fare structure; the answer I got was that if ferry fares were lowered, then too many people would use the ferries, and there would need to be significant investment in infrastructure and new boats. What a terrible problem to have (and one which we just bite the bullet on when it comes to buses and trains, it seems).

        Who knows, if there was a drop in ferry fares and more people started using them, then the traffic congestion along Lake Road between Devonport and Takapuna might magically clear up, and we might be able to save some of the gazillions of dollars that will be thrown at that corridor.

        1. The thing that hasn’t been said is the Ferry to Waiheke does not get any subsides what so ever where as all the others do so when you come to the Island is the full cost or in other words users pays

        2. And if the Waiheke and Devonport routes were part of PTOM, then there would be the opportunity to provide them with the same level of subsidy that everyone else in the entire region gets for their public transport. If I was a resident of Devonport or Waiheke I would be up in arms about the inequity that flows from Fullers’ refusal to play ball with AT. In the name of profit.

    1. Surely these big users are commuters. Should people receiving both the pension and their probable high income also be getting $4000 p/a in transport subsidy? It makes me sick. Even if the fare was a quarter of what it is now (or a millionth), they shouldn’t be getting a cent.

      1. Don’t be sick. There aren’t 22 months in a year. The highest users are travelling once a week. Therefore most users much less than once a week. Their ‘probable high incomes’ are a myth.

      2. How do we know the reasons for travel for a person who makes a couple of trips from the suburbs to the city in the course of a week? But the point is that we don’t restrict people who use the bus twice a week or the train twice a week – just the ferry passengers. Why them? Purely and simply because Fullers charge them an extortionate fare which AT and NZTA then have to subsidise. The issue is the fare level, not the subsidy.

        1. Why is $19 one way extortionate ? Its $4.80 for the shorter Devonport run so is 4 x that for a much longer run.
          A bus can just drop passengers at the kerb, ferries have to pay expensive wharf fees

        2. It’s only $7.50 one way to Half Moon Bay or Hobsonville and they’re more than half the distance and take the same amount of time (speed limits).

        3. In what other part of Auckland do you pay $19 for a 22 km public transport journey?

        4. Is it because the Waiheke ferries arent a subsidised service ( except for concessions) ?

          “The petition is calling for a change in the rules so Fullers Ferries operates under contract to Auckland Council like the rest of the region’s transport companies.

          Barnes said the problem is that monopoly operator Fullers Ferries is not regulated under the Land Transport Management Act or Auckland Council’s Regional Public Transport Plan.”

          So thats it, its not covered by the general rule that passengers pay 50% more or less of overall cost like the other ferrys, trains, buses
          https://www.stuff.co.nz/auckland/local-news/82215948/new-waiheke-group-calls-for-fair-competition-on-ferry-route

    2. DavidByrne is absolutely right here.

      Except that on my reading the $4,000 is spent over the course of two years, not one year. So in fact the *heaviest* users of the Super Gold Card are in fact using the ferry to travel to town and back *once a week*. How is that rorting the system? It certainly isn’t ‘commuting’ as suggested in the original post. And the corollary is that the majority of Super Gold Card holders aren’t travelling even close to once a week.

      I also take issue with the characterization of Waiheke pensioners as rich (the ones I know are not), contrasted with the poor of South Auckland (median household income $59,950). Waiheke’s median household income is less than that of South Auckland, at just $51,000. I frequently see the suggestion to ‘do some research before you post comments’. That must go doubly for article writers.

      1. Yeah I agree – the author should have stuck rigidly to discussing the per-trip subsidy instead of mentioning side issues that have allowed you to try to distract with tangential (and possibly self-interested?) arguments. Simple fact is Waiheke SGers are soaking up far more transport subsidy per trip than anyone else, and this isn’t fair.

        1. I think the simple fact is that Waiheke ferry travel costs too much. Because unlike other transport in Auckland it is not subsidised under the PTOM. Quite the opposite, it’s a profit-making exercise. The buses and trains (and roads for other vehicles) get public funding. So do most of the ferry routes. But Waiheke ferry passengers pay the full cost of operation, plus the profits of the operator, plus wharf taxes. If you want fairness, then you want that to change. (As for self-interest…yep I live on Waiheke. But no, I’m a long way off getting a Super Gold Card).

        2. Just like many bus, train, ferry and airplane tickets around the country, are you suggesting these should all be subsidised?

      2. My rant wasn’t really about waiheke so much – although if you choose to live there it’s a bit rough to expect the tax payer to pay for your travel. My rant was more about the super gold card in general. Some of the richest people I know both in terms of income and assets get a free commute to work and back and a free trip to waiheke etc when they feel like it.
        It should at least be income tested shouldn’t it?
        Also I can’t believe there isn’t anyone commuting from waiheke to city over 65. Why not?

        1. I’d have no issue with it being income tested. Nor any issue with the idea of offering discounted public transport fees to those on low incomes or benefits.

    3. Regarding the Waiheke Island “rort” article. It does advise in the article that the figures are over 22 months (from the supergold hop card switch over to present) which makes the math –

      Average Supergold:

      $1800 / 22 months = $81.81 per month
      $81.81 / $19 = 4.3 one way or 2 return trips per month.

      Top 100 Supergold:

      $4087 / 22 Months = $185.77 per month
      $185.77 / $19 = 9.78 one way or just over 4 return trips per month

      Personal opinion is that this would be a shopping trip to the mainland or something similar.

    4. Average Supergold:

      $1800 / 22 months = $81.81 per month
      $81.81 / $19 = 4.3 one way or 2 return trips per month.

      Top 100 Supergold:

      $4087 / 22 Months = $185.77 per month
      $185.77 / $19 = 9.78 one way or just over 4 return trips per month

      The article does mention that the figures are over 22 months, but then glosses over it.

      Personal opinion is that this would be a shopping trip to the mainland or something similar.

  8. Another issue is a perception of safety in poor suburbs when using PT.

    The major bus station in Otahuhu town centre has a lot of homeless people begging for money. There are vandalism everywhere at the station, as well as on the bus. The bus are not clean and a lot of things like seats, windows, and handrails are intentionally damaged.

    The whole experience is not very pleasant, compare to.. say the clean north shore nex bus and stations.

      1. The bus station at manson ave used to be nice and fresh. But after one year it get trashed.

        Otahuhu old town centre bus station has a few people asking for money whenever some wealthy looking people pass by.

        1. So does Queen Street. That’s not rally a public transport issue or a poor suburbs issue, is it.

  9. I think you need to be a little careful about subsidising transit different amounts for different users. Surely it would be best to just give them more cash, so they can make the appropriate transport choices? That way you benefit those that can take public transit as well as those who can’t (due to lack of route/convenience etc). Yes, improve the transit network so they *have* choice, but you benefit them more if they can use those funds for what they most need (food/shelter/health/transport).

      1. Absolutely, if that’s what they wish to spend their money on. Why shouldn’t they get to spend it how they like, just like I have the fortune of doing? The research is clear: Cash with no restrictions is the best way to help those in poverty.

        If you wish to deal with societal ills, then you deal with them with addiction programs and the like. They’re not solely a problem of the poor, after all.

        The poor lack agency enough already. Let’s not burden them further by reducing that agency.

        1. Because it’s our money that we give to them – they didn’t earn it.

        2. I consider that my income over the years has been possible because of the luck of my birth. If I’d been born into a family with different values or opportunities, or if I’d been born in a 3rd world country, chances are that the same effort wouldn’t have led to the same income or lifestyle. Thus, my money is mine only to a certain degree. And given that capitalism unashamedly benefits from having a certain percentage of the workforce out of work, in order to keep wages low in the market, it’s pretty clear why some people “didn’t earn it”.

    1. jmarshall, I agree. I think subsidies and benefits, though, are about acknowledging deficiencies in our systems. Our transport system has developed without due regard to equity, access, safety, urban form or the environment. We all miss out on what Auckland could be as a result, but some people feel the financial effect more than others. I think subsidies are appropriate but proper funding to reverse the car dependency and to improve access and affordability by sustainable modes is paramount. Research does show that one of the most effective ways to enable poor people to improve their lot is actually to just provide them with more money. But there are two goals here – equity and a better transport system. We need to influence travel behaviour of all groups in society; I don’t think offering discounts to poorer people for public transport is unethical. Not providing them with enough for living in dignity, and not fixing the other mismanaged systems that affect them with better funding, most definitely is.

      1. Access can be improved even if you keep pricing the same. Many travel off-peak or at hours when frequency isn’t there, or the service isn’t there. Fixing that is what matters more in my view than reducing the price of existing, poor, services. I don’t think pricing is necessarily that far out: In many cases it’s cheaper and more convenient to take public transit where the frequency and service is high enough. In my view that’s the key: Getting the frequency and service high for everyone where practical.

  10. One aspect of Councilor Collin’s article that interests me is when he talks of the people with multiple jobs or tradies who need a car to get around. I realise this may not be a “Transport” matter but worth considering- nowadays most of the tradies and labourers are sub contractors and are told to get to a site under their own steam, provide all their own tools and dont get paid holidays etc. At a HNZ site on my road there were 13 vehicles associated with the build parked on the road last week ( only one had a trade logo -the rest just standard family cars now used as a work vehicle). When I started out my working career as a labourer I rode a bike to the builders yard and then went in the truck with the team to site.

    1. I guess it depends on the outfit. Much to my chargrin my neighbour’s staff all converge outside his house (about 10m from my bedroom) at 6:45am every morning and load up together in the truck to head to the site.

  11. Jarrett Walker maintains that you are better off to increase service rather than reduce fares if you want to increase usage.

    On the other hand, Sam Warburton reckons (and he’s never wrong apparently) that PT is the domain of the wealthy and poor people use their cars.

  12. As I’ve noted in feedback on other articles I’d like to see central government fully fund “true public transport” to meet social outcomes.

    – a full coverage network running 24/7 with maximum 30 minute headways & pulsed transfers where possible.

    – the network can be a mix of on-demand services (where fixed routes are not cost effective) + fixed routes varying by time of day along with demand changes.

    Local government can then fund the majority of service level improvements over and above this.

  13. One of those regular Waiheke day-trippers is a friend of mine. 92 years old, lives in a south Auckland retirement home. He takes regular trips on the gold card just to get out of the place, have lunch somewhere interesting, talk to someone else for a change, breathe some sea air. This isn’t a man rorting anyone. He’s getting by, on what’s left after a long career as a contributor. Strength to him.

    1. And he’s paid far more in taxes over his 92 years than any of the young commentators.

      This is actually a really poor attack by Matt of the Super Gold Card. Yes, he never went into solving the real problem, privately owned public transport rorting the system. But as pro PPP for light rail he can’t be seen to attack business anymore.

      Sell out to business or just a poorly thought out opinion piece showing Matt’s true colours?

      1. I’m certainly no fan of privately owned public transport either, and think it should all be taken back under public control. Nor am I a fan of PPP’s.

        But anyone who understands how car dependency is hurting Aucklanders will be enthusiastic about the light rail project getting a boost from the Super Fund’s proposal. Finally, despite the right’s bias towards a polluting, socially destructive, and highly subsidised road network for the private car, this much needed addition to the public transport network looks like an actual possibility.

        Matt’s not being a purist, and that’s because he cares about Aucklanders and the lack of opportunities some have in our city. Thanks to Matt we have so much information passed our way that is really important and useful.

        We can throw anecdotal stories of 92 year olds around all we like, and I have a few myself, but the fact remains that many of us who pay tax and rates would prefer to subsidise people in poverty than subsidise people who are rich. We’re not wanting to discriminate by age, but that’s exactly what the Super Gold Card does.

      2. I don’t begrudge this guy making use of this opportunity at all, but just because he has paid taxes all his life doesn’t mean he is entitled to free transport to Waiheke.

        Super gold card is very arbitrary, we don’t provide free trips on Intercity buses to visit relatives in Tauranga and we don’t provide free trips on the Stewart Island ferry, yet for some reason we do subsidise trips on the Waiheke ferry.

  14. Supergold concessions should definitely be capped. Those $38 Waiheke Island fares fully subsidised from the taxpayer are just taking the piss.

  15. If the waiheke ferry was made public and received the 50% farebox subsidy, then the fares would be $9.75. Let’s do that first and take the subsidy from the correct pot.

    I strongly disagree with means tested super gold cards. The rich hide their income in trusts so that means testing punishes the middle class and discourages superannuitants from working at all. Just raise the retirement age if we can’t afford to pay for these benefits.

    Tertiary concessions should be removed with a community services concession added with students made eligible for community services cards based on the same criteria as the rest of the community.

    Wrt fare zone boundary issues, the obvious solution is to widen the overlap buffers between zones.

  16. The logical fallacy is Jarret Walker’s framing: EITHER we cut fares OR we improve services. In the immortal words of that little Hispanic girl, why not both?

    1. Obviously you can do “a bit of both” but ultimately every dollar you spend on cutting fares is a dollar that could have been spent on better services.

      1. Meh. Huge shift in funding from roads to PT is required so we can stop having to make the distinction between healthy low fares and healthy good services.

  17. If we simply make, say under 18, free with a HOP card, we not only encourage transit use amongst the next generation but also allow larger families to travel together for minimal or no extra cost over and above the parents fares. It need not even be free but perhaps a daily (or weekly?) Capped fare – say $2 – so that some income is received but at a nominal rate.

    1. Yeah it says interesting things about our society that we charge 6 year olds to use PT, but it’s free for over 65s.

      1. Mmmm, our group of local boys who bus together to gym has now grown to four. They love using the bus together; for some it’s the only PT they use. The cost is huge compared to the parents doing it by car; worth it for the long-term benefits of raising comfortable PT users. Not really a financial option for most families (if they have to have a car anyway.)

    2. +1 to free child fares allow family PT travel. In addition to your ideas (1. completely free 2. capped fare) I’d add 3. free during off-peak times.

      Would enforcement be difficult? I’m not sure if many kids have proof of age.

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