It is very unfortunate that IPART lead fare setting in Sydney. They are a bunch of obstructionist kingdom builders that have prevented fare integration for more than a decade, and they continue to do so. If the Premier would do the right thing, he'd remove their authority completely.Direct statements such as (emphasis mine)...
They have made a number of direct statements about preventing transferring passengers from getting a discount.
"However, we are sympathetic to the view that many passengers who change buses within a single journey effectively pay 2 flagfalls."
"The introduction of electronic ticketing will make it significantly simpler to implement a flagfall rebate for passengers who need to change buses to complete their journey. We consider that this is the most appropriate way to make such a change, and that the Government should consider this issue further in relation to the proposed e-ticket."
"Although we believe it is appropriate to retain different fares for buses, trains and ferries because of the different costs and environmental benefits involved, we consider it appropriate to include a flagfall rebate in the e-ticket regime so that passengers who are not able to make their journey on a single bus are not required to pay multiple flagfalls. The economic case for a flagfall rebate on multi-modal travel is not clear, we consider it likely to be justified on equity grounds."
The above from the 2010 review of bus fares. I cannot reconcile the views implicit in phrases emphasised above with your last statement. If you have statements to the contrary I would be interested in seeing them.
IPART's current view, in my understanding and noting my previous comment about the difficulty of determining "intent", is that there is a difference in cost per passenger kilometre travelled and perhaps quality between modes, and that it is may be appropriate to signal that cost and quality difference to users (if the bus is cheaper than the train for a certain trip - then people should use the bus). But they acknowledge that there is room for debate about this, because in many cases users do not get to choose the mode that the system provides.
(I suspect it is the relatively extreme cost of ferry services that is the real driver here, rather than bus versus train, but I could be wrong.)
IPART's view in this area was certainly the view of the previous government - who explicitly asked for mode specific charging as part of the Opal tender.
With less commitment, IPART have a view that the route length of journey is a better reflection of the costs of providing services, rather than crow flies. But similarly there is room for debate about this, because users don't get to choose where the bus goes or where the train line runs.
As stated above, they definitely don't believe that users should be penalised for changes within a mode.
They are also inclined towards the view that users shouldn't be penalised for changes between modes based on "equity" (again, because the user in most cases doesn't get to choose the mix of modes for a particular journey), but they haven't come up with an economic (i.e. cost) argument as of the time of writing the above (2010).
I don't necessarily agree with (my interpretation of) their views above (my sympathy lies more towards the "because" phrases above, but then I accept that while a user might not control the arrangement for a particular journey, over a longer time period they do have some control over where they live relative to where they regularly travel and where existing transport has been provided), but I can understand their reasons for their views. And none of their views are obstacles to integrated ticketing. On the contrary, in the last couple of determinations they have clearly allowed flexibility to do just that.
It is pretty clear that IPART are not keen on zone based fares, because of the distortions that it introduces in a geographically spread system like that of greater Sydney. I think at times that opposition to zones has been taken to mean opposition to fare integration, but with technology available in this day and age they are not the same concepts. Examples exist to support that, including systems which moved away from zones towards distance charging with the introduction of "integrated" electronic ticketing
And to be clear... the decision anyway is ultimately one for the government of the day. They have the authority and the accountability to set both the policy and the detail around fares.