Window dressing

Some said Neoplan Centroliner buses would scrap its bottom at China Ferry Pier Bus Terminus and could not run on KMB Route 3C. The pictured bus was running a short-haul trip from Lung Cheung Government Secondary School, which was seen as a suspicion of window dressing.

Window dressing, or Accounting manipulation or "fudging" (造數、篤數、造假帳), refers to the improper or dishonest manipulation or falsification of accounts by a business organisation to make the accounts show a company operating better than it really is.

Franchised bus companies are required to disclose the accuracy and punctuality of their schedules to the Transport Department on a regular basis, and can be penalised by the authorities if there are serious lost trips or delays. It is also a common practice to arrange for buses to depart from an intermediate stop near the terminus and return directly to the terminus, counting this as a full frequency, or to run empty buses on the road pretending to carry passengers, or to run routes similar to other routes but with higher fares and start carrying passengers at intermediate stops farther away from the starting point (most of which are far away from their original main service targets) in order to deceive the Transport Department and falsify the actual frequency, even with the intention of raising fare revenue. As these trips appear for no apparent reason and most of them have no or very few passengers, some media have described them as "Ghost Buses" or more common wording - "Phantom Buses" (鬼巴、鬼車).

It is important to note that intermediate stop services or shuffle services (starting the journey at an intermediate stop) and some unwritten special departures are not necessarily number-crunching. In most cases, shuffle services and some unwritten special frequencies are done for proper frequency adjustment or to meet passenger demand, and only unreasonable short-haul trips that are constantly made could be counted as window dressing, which makes some window dressing cases to be debated by bus fans.

The incident

In 2011, the lost trip rates of Kowloon Motor Bus (KMB) was as high as 7.2%. As a result, the Transport Department issued two warning letters in December and March of the following year, instructing the company to improve the frequency accuracy by the end of June 2012, failing which the company would be penalised.

In view of this, KMB arranged depot running orders (mostly starting with D, e.g. 5C-D01) on a number of routes with more serious lost trips, and sent buses to run very short trips continuously, picking up and returning to the terminus at several bus stops before the terminal of each route (e.g. Route 5C started from Fu Yau Building and went to Tsz Wan Shan (Central), and then went to Fu Yau Building again as deadheading bus, starting another round of operations until the end of the day).

This behaviour became a regular occurrence in May and mid-June 2012 and was reported in a number of newspapers. (Oriental Daily News and Apple Daily)

In response to the reports and complaints about lost trips, The Ombudsman decided to launch a direct investigation in October 2012 to examine the effectiveness of the Transport Department's mechanism for monitoring the frequency of franchised buses, in particular KMB. The investigation report was released in January 2014.

Related examples

The following are the KMB routes that have been uncovered by the media or observed by netizens.

KMB Routes suspected of window dressing
Routes	Short-haul trip starting stop	Short-haul trip terminal stop	No. of observed stops (with first and last stops)	No. of stops for the whole route (with first and last stops)	Source
2A	Regal Oriental Hotel	Lok Wah	9	29
3C (Running Order 91M-N01)	Lung Cheung Government Secondary School	Tsz Wan Shan (North)	9	28
5	Choi Hung	Fu Shan	4	23
5C (Running Order D01)	Fu Yau Building	Tsz Wan Shan (Central)	7	29
35A	Butterfly Valley Village	Tsim Sha Tsui East	18	27
49X	Chung On Street Tsuen Wan	Tsing Yi Ferry	7	22
96R	Sai Kung Bus Terminus	Wong Shek Pier	25	52

Responses

KMB

KMB issued a statement on 21 June 2012, claiming that "the use of unscheduled special trips to increase the number of trips is absolutely not allowed. If irregular scheduling is found, it will be thoroughly investigated", and that the two routes in question, 3C and 5C, were "additional trips" outside the Transport Department's Schedule of Services (i.e. the TD's schedule of bus services) and could not be counted as "actual trips" and therefore could not be used to improve lost trip rates. However, KMB has not explained why there are short-haul trips on routes 3C and 5C which have been reported by the media.

Transport Department

In June 2012, the Transport Department wrote to KMB and held a meeting with its management, instructing the bus company to keep clear records of schedules. After investigation, there was no conclusive evidence to prove that the bus company had been involved in arranging for the so-called "phantom buses" to run on the routes.

Office of the Ombudsman

The Department considers that sometimes it is necessary for bus companies to arrange temporary special trips to pick up passengers at an intermediate stop. However, the Department considers that the allegation of "ghost buses" is a very serious allegation and that it is unacceptable for a bus to run a ghost bus simply to avoid lost trips. The Department also requested the Transport Department to closely monitor the reports, follow up on the investigation and provide an account of the situation to the public in due course.

Legal Profession

Some barristers have pointed out that the "fudging" of figures by the bus companies could be a common law offence of conspiracy to defraud, which carries a maximum penalty of 14 years in prison.

Related Laws

Further, under the Crimes Ordinance, Cap. 200, Laws of Hong Kong:

71. A person who makes a false instrument, with the intention that he or another shall use it to induce somebody to accept it as genuine, and by reason of so accepting it to do or not to do some act to his own or any other person’s prejudice, commits the offence of forgery and is liable on conviction on indictment to imprisonment for 14 years. 73. A person who uses an instrument which is, and which he knows or believes to be, false, with the intention of inducing somebody to accept it as genuine, and by reason of so accepting it to do or not to do some act to his own or any other person’s prejudice, commits an offence and is liable on conviction on indictment to imprisonment for 14 years. 75. (1) A person who has in his custody or under his control an instrument which is, and which he knows or believes to be, false, with the intention that he or another shall use it to induce somebody to accept it as genuine, and by reason of so accepting it to do or not to do some act to his own or any other person’s prejudice, commits an offence and is liable on conviction on indictment to imprisonment for 14 years. (2) A person who, without lawful authority or excuse, has in his custody or under his control an instrument which is, and which he knows or believes to be, false, commits an offence and is liable on conviction on indictment to imprisonment for 3 years.

Related Articles

• Lost Trips
• Withdrawn From Service
• Intermediate Stop Service
• Special Departure

External Links

• 5C開短途特車當完成完整班次上左報 (KMB Route 5C's short-haul special departures as one full trip made its way on newspapers), hkitalk.net
• KMB Press Archives: 九巴就特別班次編訂的聲明 (KMB's statement on special departures)), 21 June 2012.

Template:BusRouteList Navbox

To facilitate quoting and enquiries, the following redirect page(s) will direct to this page:

Accounting Manipulation, Fudging, Phantom Bus, Phantom Buses, Ghost Bus and Ghost Buses