ANGLICARE has urged the Economic Regulator to focus on the state's disadvantaged in its review of Metro's pricing.
Anglicare did extensive research and interviewed more than 20 bus-users before making its submission, which recommended that Metro concession bus fares remain at a flat rate regardless of the time of travel.
A draft report, released in March, suggested a differential pricing system dependent on time.
Anglicare chief executive Chris Jones said it was incorrect to assume that people on low- incomes could fit their travel into off-peak times.
Dr Jones said the limited number of buses on certain routes also meant people were often forced to travel in peak periods.
"The timing of travel is often beyond their control," Dr Jones said.
"People are working, volunteering, going to appointments at the hospital and so on.
"Some need to be back for school pick-up time in the afternoon."
The report said: "Anglicare argues that the government should take into account in its budgeting the cost savings that investing in public transport brings through decreased costs for roads, carbon emissions, car parking facilities and health".
"Even a small increase in the cost of bus fares would cause hardship," Dr Jones said.
An anonymous submission on the Economic Regulator's website argues the system is more equitable than a proposed zonal system.
This year's pricing review is the sixth investigation into Metro's pricing policies.
The service has suffered declining numbers through its Burnie, Hobart and Launceston operations for several years.
Metro is set to release its final report to the government on May 31.