Author: Association of British Commuters

The Railways Bill enters its Committee Stage tomorrow- a line by line discussion lasting four weeks that is the first chance for MPs to table amendments, and the first major opportunity for the public to influence the Bill.

It is vital that the Committee starts by confronting the Bill’s fundamental problem: it is built on the same competition-based legal framework that was the main cause of failure under privatisation. This discredited framework could now prevent the key goal of this once-in-a generation rail reform: the full integration of the railway, across finances, timetables and infrastructure.

Without strong amendments, competition and subsidy restrictions will spread throughout the legislation: forcing structural fragmentation, preventing integrated policy and restricting the value of public money. 

We are joining We Own It and Bring Back British Rail to demand that the Bill Committee gets off to a strong start by committing to the following priorities:

1.       All discussions must centre the fundamental problem with the Bill – its competition-based legal framework, which continues all the worst effects of fragmentation under privatisation. The entire Bill is subject to default compliance with competition and subsidy law, and must not go forward without proper, rail-specific exemptions and protections for public money.[1]

2.       The Committee must analyse the Bill according to the main principle of ‘vertical integration’. This means full financial and operational integration and has been the main purpose of rail reform for five years, supported by successive governments, academic consensus and the rail industry itself. [2]

3.     The government must be made to justify its decisions to continue competition in open access and ticket retail: this is the ultimate cause of the problems because they spread structural fragmentation throughout the system. Comparative economic evidence must be provided to the Committee on alternative legislative approaches, as the current cost-impact assessment for the Bill failed to make any estimate of the economic benefits of the approach.[3]

4. The Committee must demand much stronger, modern standards for passenger rights, with the Bill still using the terms and concepts of the Railways Act 1993, rather than any rights-based standards. Consumer rights and accessibility are also significantly deregulated by moving to a weak ‘Passenger Watchdog’ with an overriding duty of cost-efficiency.[4] Climate and sustainable development have been dropped from the Bill entirely, putting England out of alignment with Scotland on targets for modal shift and failing to incorporate UK duties under the Climate Act 2008.[5]

Rail integration prevented by competition and subsidy controls

The publication of the Railways Bill follows five years of attempts to create an organisational design and structure for Great British Railways (GBR). The aim has always been to create a ‘guiding mind’ that would integrate infrastructure, train operations and timetabling to maximise the social and economic benefits of rail.[6]

However, the Railways Bill has fundamentally failed in these objectives, due to its default compliance with competition and subsidy control law. This includes the Railways Act 1993; Railways Access Regulations 2016 and Competition Act 1998, as under privatisation; and is updated to include the more recent Subsidy Control Act 2022 (retained EU rules on State aid); and Digital Markets Competition and Consumers Act 2024. It is further damaged in its public interest values by the Deregulation Act 2015, which commits the Office of Rail and Road to take regulatory action only when ‘necessary’ and ‘proportionate’, protecting competition above the interests and rights of passengers.

Without strong amendments, the above framework will dictate GBR’s organisational design, forcing structural separation from the start.

Financial Fragmentation

Infrastructure and operations budgets have been strictly separated, including a ban on cross-subsidy.[7] This is due to the Bill’s default compliance with the Subsidy Control Act 2022, which puts severe restraints on any public funding that ‘confers an economic advantage’ to GBR and ‘has, or is capable of having’ an effect on competition.[8] This central split between GBR’s budgets will now restrict the value of public money and prevent integrated policy-making.

The Subsidy Control Act 2022 allows unrestricted funding for the primary purpose of infrastructure because it is seen as of ‘general’ benefit to the market. However, every other GBR function is made subject to strict subsidy controls that restrict public interest policy-making because they require policies to be designed to minimize negative effects on competition and ‘proportionate to their specific policy objective and limited to what is necessary to achieve it.’[9] This also applies to infrastructure funding that is for primarily public interest reasons, such as accessibility and climate.

Restrictions on GBR profit and growth

The conditions of the SCA22 mean that GBR will be forced to prioritise cost-efficiency and actively restrict its own profits and returns on investment whenever using public subsidies or making policy interventions.This follows a key subsidy control condition of the SCA22, where for subsidies given for Services of Public Economic Interest, the public authority ‘must be satisfied that the amount of the subsidy is limited to what is necessary to deliver the SPEI services, having regard to – (a) costs in delivering the SPEI services, and (b) reasonable profits to be made in doing so.’[10]

This must be the reason that the government has failed to include a passenger growth duty, despite this being strongly supported by public and industry and vital to creating a ‘virtuous circle’ of increased revenue and investment. Under the subsidy control regime it could have such a growth duty, commanding much more public investment from the start. However, this funding would have to be of ‘general’ benefit to the market, not favouring GBR’s own enterprises, making it a poor value investment from the taxpayer’s perspective.

Operational fragmentation  

The Railways Bill makes just one assertive move – bringing network access and timetabling decisions into GBR. However, it has been unable to integrate infrastructure, timetabling and operations under one public body, due to competition restraints in the Railway Access Regs 2016.[11]

Instead, the government intends to create ‘regional business units’; however, due to the split in infrastructure and operations budgets it will also be impossible to achieve integration within these bodies, also preventing the integration of management into a single legal entity.[12] It is unclear to what extent the ‘regional business units’ will be allowed to collaborate with each other and be nationally co-ordinated.

There will also be fragmentation within the Main GBR, including unclear and overlapping duties between a proposed ‘Network Organisation’ and ‘System Operator’ function.[13] As yet there is no clarity on how it will co-ordinate Network Rail functions such as infrastructure management and timetabling with the network access function of the ORR; and how this will affect Board and governance structures.

Ticket Retail and Fares

The Bill has made all GBR’s passenger-facing functions subject to the same competition rules as the private sector, but with one major difference. Because GBR is a ‘dominant’ in the competitive market, it will have to be under extra restraints to prevent it from favouring its profit or socioeconomic interest in decisions, because this would give it an ‘unfair’ advantage over the private sector.[14]

In ticket retailing and other cross-network services this means structural fragmentation and a high risk of ‘perverse incentives’ and conflicts of interest:

1. GBR Retail will be structurally separated and banned from cross-subsidy or collaboration with other parts of GBR, preventing integrated policy-making. In a worst case scenario, it might even be run by a private company.[15]
2. GBR’s cross network functions such as digital and ticketing infrastructure and information systems will have to be structurally separated to prevent a competitive advantage. 
3. Third-party licensing function must be separated from GBR to prevent any ‘unfair’ advantage to its own operations. This function will be moving to the pro-competition regulator ORR, blocking the democratic control of policy in passenger-facing services.
4. Research and development is also subject to the rules of the free market, which has long prevented the urgent project of national fares and ticketing reform. The results are clear in the current activities of the private sector trade body, Rail Delivery Group, which is procuring multiple ticketing trial contracts with companies like Trainline. This wastes public money by duplicating the work, and creates fragmentation that will make it impossible to integrate these systems later. The government has no plan for how to abolish the Rail Delivery Group, but it is likely its research and development and procurement functions will also need to be structurally separated.
5. Rail fares are also thrown out to the free market and could be almost entirely deregulated. The competition requirements will make public interest fares policies impossible; with signs that the industry is instead developing ‘dynamic pricing’ methods.[16]

Conclusion

In its current form, the Bill will cause severe and permanent restrictions on the value of public money. Currently, the Bill leaves space to deal with these conflicts later, but the opportunity to solve them will be much narrower if left until later regulations. The Bill must not go forward until rail-specific exemptions from competition law are created, ensuring the maximum of integration and proper safeguards for passenger rights and the value of public money.

Take action

The Committee stage begins on Tuesday 20th January and is expected to report by Thursday 12th February, 5pm. The public is invited to submit written evidence, which should be sent as soon as possible to scrutiny@parliament.uk

We will be lobbying the Committee and MPs with regular briefings and demands throughout the next month, especially stronger public interest duties; increased rail integration and protections for public money. 

A full list of members and contact emails is available to download here.

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REFERENCES:

[1] This relates in particular to the relationship between Sec 3 General Functions and Sec 18 General Duties of the Railways Bill.  These must be analysed according to the competition framework that takes precedence over the entire Bill. See Railways Act 1993, sec 67(3) on competition regulation, (including greatly increased powers of ORR and CMA under recent competition changes); Rail Access Regulations 2016, Regs; 9, 10, 12, 14(9), 19(4) on structural separation; Competition Act 1998 Competition Act 1998 prohibitions on ‘agreements that distort competition’ and ‘abuse of market dominance’, sec 9 on block exemptions and Schedule 3 exemptions; Deregulation Act 2015, sec 108 on competition regulation; Enterprise Act 2002 and Digital Markets Competition and Consumers Act 2024 on structural separation; Sec 2, 3, 27 and Schedule 1 subsidy control principles of the Subsidy Control Act 2022.

[2] The causes of rail failure have been identified by successive governments and academic consensus as: information and co-ordination failure; principal-agent issues and perverse incentives; lack of attention to externalities and lack of protection for public money; and productive inefficiency due to fragmentation and duplication in procurement. DfT, Railways Bill Impact Assessment (2025), 5-10; Williams-Shapps Plan for Rail Impact Assessment (2022), 8-9;  M Abbott, B Cohen, Vertical integration, separation in the rail industry EJTIR, Issue 17(2), 2017, p 209, 213-214; e.CA economics, Final Report: Vertical Integration, competition and efficiency in the rail industry, 60-62.

[3] Railways Bill 2025 cost impact assessment.

[4] Sec 36, Railways Bill. Standard-setting and monitoring in consumer rights and accessibility are also being moved from the Office of Rail to the much weaker Passenger Watchdog, which does not have enforcement powers and is under an overall duty of cost efficiency.

[5] Under the Climate Change (Scotland) Act 2009, public bodies must exercise their functions in the way “best calculated to contribute to” emissions‑reduction targets, adaptation, and “in the way that they consider most sustainable,” with annual reporting duties on modal shift from private car to public transport.

[6] GBR White Paper 2021, Williams Shapps consultation 2022, Railways Bill 2025 cost impact assessment.

[7] Railways Bill, Schedule 2, Part 3; Schedule 2, Part 1 (paras 6,7). Transport Committee Oral evidence: Railways Bill, HC 1472 (7 Jan 2026).

[8] Sec 2(1) Subsidy Control Act 2022.

[9] Subsidy Control Principles, Schedule 1, Schedule 2, Subsidy Control Act 2022.

[10] Sec 29(2) Subsidy Control Act 2022.

[11] Rail Access Regulations, Regs 14(9); 19(4)

[12] Rail Access Regulations, Regs 9,10, 12,15

[13] Railways Bill consultation response (2025), 14-15.

[14] Competition Act 1998 prohibitions on ‘agreements that distort competition’ and ‘abuse of market dominance’; Enterprise Act 2002 and Digital Markets Competition and Consumers Act 2024 on structural separation.

[15] See Railways Bill consultation submission from lobbying group, Independent Rail Retailers (April 2025) representing a worst-case scenario, with GBR Retail put out to tender.

[16] The Department for Transport showed significant confusion on this issue in a recent Transport Committee Oral hearing: Oral evidence: Railways Bill, HC 1472 (7 Jan 2026), Q327-Q341.

New evidence reveals that Tory Task force Great British Railways Transition Team (GBRTT) remained the main advisor to the Department for Transport on rail reform until March this year, giving extensive input into designing the structure of the new public body.

Official advice reports on ‘GBR Organisational Design’ were submitted to ministers as recently as November and December 2024, influencing the government’s decision to abandon GBR’s longstanding socioeconomic, accessibility and environment duties, and shift to a new ‘streamlined model’.[1]

There is also concerning evidence of corporate capture of parts of GBRTT, with ‘Rail Partners’ (transport owning groups First, Arriva, Transport UK and the Rail Delivery Group) operating deep inside the task force and even co-authoring official policy advice to ministers until at least late 2023. Their involvement continued until this year, including a significant role developing ‘passenger revenue growth strategies’. Though Rail Partners itself was wound down last month, the Rail Delivery Group, run by the very same owning groups, now continues this work.[2]

This report is the first in a series explaining the crisis behind GBR’s organisational design – and the dangers presented by the aggressive lobbying of private companies. The standoff between corporate and public interests is now at peak threat level, and the only way to solve it is the complete repeal of competition law from rail legislation.

GBR Organisational Design – what is the Department for Transport hiding?

GBR Organisational Design means deciding the financial framework for combining the Profit and Loss accounts of the entire railway – over £12 billion per year of taxpayers money. The upcoming Railways Bill will establish this framework and a consultation has just taken place on the legislation. However, the government’s new proposal for GBR was revealed in February to have dropped its longstanding socioeconomic duties for the sake of a new ‘streamlined model’. No cost impact assessment was published with the consultation, and no explanation given for the radical shift in direction.[3]

So, why is GBR’s Organisational Design so controversial that it needs to be hidden from the public? The answer is the railway’s biggest taboo – the restrictions of competition law on the interests of passengers and taxpayers.

Competition Vs Public Interest: Impact on passengers

Competition law conflicts have been the main impediment to rail integration since the 2021 White Paper of the previous government. This continues to be the case because the DfT is trying to reconcile two completely opposing objectives: integrating the railway; and stimulating competition for private companies.

The reason that rail integration and public interest aspects of GBR have repeatedly been found to be impossible is because under competition requirements, GBR is considered a ‘market participant’. This puts it under a complex web of legal duties not to provide additional economic benefits to the public beyond those that can be accessed by private companies.[4] This fundamental constraint still applies, despite the move towards public ownership and the change of government.

The new proposal of a ‘streamlined GBR’ should be seen as a competition-friendly model that leaves room for private companies to fight out the details later. The following ticket retail and cross-sector passenger services are currently under threat:

1. Integrated GBR ticket retail platform

Integrated ticket retail is impossible while the government keeps up its objective of ‘stimulating competition in the third-party retail market.’ The previous government dropped this idea entirely because it would have meant the financial separation of its rail and ticket retail arms.

Claims by the government that it will create a ‘government-backed’ app should be treated with scepticism. In fact, the influence of competition law means GBR will have to be designed according to at least some level of internal division between its railway and ticket retail arms. Under the restrictions imposed by the Competition Act 1998, this would mean in the best-case scenario a divided structure unable to integrate fare and ticketing policies or cross-subsidise its operations. In the worst-case scenario, the combination of industry lobbying and competition law restrictions could even open the door to a public-private partnership as GBR’s ticket retail arm.

The loss of integrated ticket retail is now a clear and present danger, with the ‘Independent Rail Retailers’, an entity set up to lobby on GBR third party retail reform, demanding the full separation of GBR’s retail activities, additional controls on cross-subsidy and a stronger role for the Competition and Markets Authority.[5] It is now being widely reported that both the IRR and its biggest member, Trainline, are ramping up their lobbying efforts.

2. Rail Delivery Group dominating ticket retail and rail accessibility

The removal of the Rail Delivery Group was the first priority of the 2021 White Paper on GBR, due to it being named as a major cause of market failure and perverse incentives. In fact, the absorption of the RDG’s cross-sector passenger functions was so much a priority for the previous government that it was the GBRRT’s entire first year workstream. This was suddenly abandoned in June 2022, with no explanation ever given to the public.[6] Meanwhile the Rail Delivery Group has become more powerful than ever and remains in place of the entire country’s ticket retail system and many other ‘cross-sector passenger functions’, including multi-million pound network-wide projects such as ticketless travel and assistance infrastructure for disabled travellers.[7]

Competition-based conflicts are the cause of the RDG remaining lodged in place and make its removal extremely difficult for the government. For example, under the original plan, collaboration between train operators was supposed to be enabled by carefully legislated ‘exemptions’ to competition law. However, the previous government found even the most limited exemptions impossible due the effect of the Competition Act 1998, which tightly controls any collaboration within competitive markets.[8] In the current context, these restrictions impede even the publicly owned operators collaborating even with each other, lest they gain an advantage over private companies.

Furthermore, the responsibility of licensing the third-party ticket retail market cannot lie with either GBR or a hypothetical separated GBR retail arm, since under competition law, this would be seen as risking prejudice towards the interests of passengers and taxpayers, thus disadvantaging third party retailers.[9] Currently, the RDG remains in its licensing role to third parties, meaning it has now become entrenched as both gatekeeper and dominator of the third-party retail market.

3. No public consultation on fare policies or ticket retail

Due to the commercial confidentiality demanded by transport owning groups and the RDG, there has been no consultation on fares or ticket retail policy since 2019, which never reported back to the public. In fact, all cross sector passenger functions have been exempted from consultation throughout many years of rail reform for this reason.[10] Our new evidence proves that the development of fare and ticket growth strategies and policy has been, and continues to be, entirely within the domain of the owning groups and RDG.

With the highest rail fares in Europe, fare and ticketing policies should be considered a priority matter by the DfT. Instead, this issue has been buried for years, and if a competition-based retail model is established, we can expect there to be significant constraints on synchronising fares and ticketing with public policy. Integration will be seen, inherently, as a ‘conflict of interest’ that could discriminate against private companies and therefore creates a ‘chilling effect’ on the new laws and regulation because GBR will have to be carefully designed to avoid legal challenge.

Part Two: Impact on taxpayers

The next part of this series will focus on the impact of competition law and industry lobbying on taxpayers, and will dispatch further evidence warning of the potential outcomes if GBR is allowed to be captured by corporations.

The restrictions of competition law are the biggest obstacle to rail integration and the public/socioeconomic interest. The only solution is the full repeal of all competition clauses from rail legislation, and the removal of the role of the Competition and Markets Authority and competition duties of the Office of Rail and Road.

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References

[1] The Rail Minister Lord Peter Hendy has been receiving the same high-level policy advice he had previously signed off on as Chair of Network Rail, while ‘Shadow GBR’, established by the current government in October, has remained barely operational. See Transport Committee, Oral evidence: Shadow Great British Railways, HC 554 and The Times, ‘No minutes from ‘robust’ meetings to create Great British Railways’ (26 Jan 2025).

[2] In addition to its control of the UK’s entire ticket retail system, ‘National Rail’, the Rail Delivery Group is developing and enacting Railway Policy and Strategy, including decarbonisation, stations, network planning, accessibility technologies and workforce reform. (Confirmed via FOI request).

[3] The reports on GBR organisational design were withheld from release by ministerial veto. Other FOI requests show that the DfT is holding back economic and cost modelling it has conducted on the plans, and the Sunday Telegraph recently reported that the DfT has received a report finding that private ‘open access’ operators on the network could cost the taxpayer billions over the next decade.

[4] See Competition and Markets Authority (CMA) response to GBR consultation (April 2025); CMA response to GBR consultation (Aug 2022); ORR response to GBR consultation (July 2022).

[5] Railway Gazette, ‘Rail ticket retailers call for a level playing field’ (8 May 2025).

[6] Confirmed by FOI requests. See also ORR Meeting Minutes, (June 2022).

[7] Despite delivering ‘public functions’ and developing and enacting public policy, RDG is unregulated by the ORR, has no requirement to consult passengers on retail and assistance reform, and is not subject to the Public Sector Equality Duty.

[8] DfT, Plan for Rail consultation outcome (Feb 2024), page 57.

[9] DfT, A railway fit for the future, GBR consultation (Feb 2025), pages 37-38.

[10] ABC, The Great British Cover-Up (July 2022); ABC, The Great British Rip-Off: Why the Williams-Shapps Plan will fail to deliver (Aug 2022).

New documents reveal years of ‘stealth destaffing’ at Southeastern, as its network is exposed to be severely understaffed, with ticket offices meeting their scheduled hours at an average of just 74% for the last two years. It has now begun a secretive new ‘Ticket Office Project’, involving the removal of afternoon shifts, and piloting of new job roles at 14 Kent stations.

Our freedom of information requests to Southeastern show that 14 stations are due to have their ticket office opening hours cut by half: a daily loss of 6-7 hours staffing hours, for 5-7 days per week.

The stations due to lose their afternoon shifts are: Beckenham Jn*, Bexleyheath*, Hayes (Kent), Mottingham*, New Cross*, New Eltham*, Petts Wood*, Welling* (Metro area stations); and Battle, Bearsted, Deal, Otford*, Wadhurst, West Malling (located across Kent). *The nine starred stations are served by driver-only trains.

When the afternoon shifts are removed, passengers will be unable to access retail advice, or the full range of affordable tickets. If staff are completely removed from the stations, toilets and waiting rooms will be made unavailable, and where stations are served by driver-only trains, boarding and alighting assistance can’t be provided – preventing disabled people’s right to ‘turn up and go’.

David Wornham, Southeastern’s Passenger Services Director said:

“Recently, changes were made at Otford and Deal, which both typically see no more than 10 ticket sales per hour each shift. We plan to adjust hours at another 12 ticket offices in 2025. Stations will remain staffed, with accessibility and safeguarding assistance provided by platform staff.”

Southeastern is making the changes without consultation

Despite the slashing of around 50% of ticket office staffing hours at the 14 stations, the changes did not go through any sort of public consultation and have been kept secret until now. This is because they were originally approved by the DfT in January 2022, when Southeastern used the ‘Minor Change Process’ of Schedule 17 of the Ticketing and Settlement agreement to notify of the changes. It is only now that Southeastern has begun the process of permanently removing the shifts.

Of the list of 14 stations, just Deal and Otford have lost their afternoon ticket office shifts so far; and Southeastern plans to cut afternoon shifts at the remaining 12 early next year. This is all being done against a background of long-term ticket office under-staffing across the whole Southeastern network, averaging just 74.31% for the last 26 months.

Southeastern said: “Following a national consultation confirming that no ticket offices will close we are recruiting and training around 100 additional ticket office staff this year. To date we have recruited 97 of these and this will lead to significantly increased ticket office hours.”

A long-term strategy of stealth destaffing

The new documents suggest that Southeastern had been conducting a long-term strategy to shed ticket office staff. In an Equality Impact Assessment (EqIA) from October 2024, Southeastern states:

‘In 2022 [redacted] went through the ticketing settlement agreement minor change process to remove the requirement for an afternoon shift at these locations. At the same time staffing was reduced through a voluntary severance scheme to leaving [sic] enough staff remaining only for a morning shift. Customer-facing information was not changed at this time. The objective is to confirm the future staffing makeup of [redacted] align the customer facing information with the ticket office staffing times.’ (EqIA, page 8)

Though heavily redacted, the document shows that Southeastern’s current Ticket Office Project is part of a “change programme”, which appears to relate to a new staffing strategy “…which will focus on less shift work and more fixed shifts”.  “The majority of positions that would be affected by this change are currently vacant” and there is “increased working outside” as part of a “change [that] will help our people start to think differently about their roles and prioritise the customer service they are brilliant at giving rather than primarily being an underused sales point.”

No Equality Impact Assessments for the Schedule 17 changes

We have confirmed that no EqiAs were completed for these changes when they were approved by the Department for Transport in 2022. However, Southeastern provided us with a draft EqIA (Oct 2024) for the removal of the afternoon shift that recently took place at Deal and Otford stations. The heavily redacted document shows little evidence that the impact on passengers, especially disabled people, has been considered.

According to Southeastern: “we currently only have the EqIA for Otford and Deal approved. EqIAs for the other locations will be approved before formal changes are made…These changes, which are supported by an Equalities Impact Assessment, were approved under the previous government. Future changes will need to be approved by the current government.”

We asked the Department for Transport 1) whether they had approved Southeastern’s current ‘Ticket Office Project’; 2) whether other operators were conducting similar stealth destaffing programmes; 3) and whether they intended to take action on Southeastern’s 74% average compliance with ticket office staffing obligations.

The DfT responded: “We recognise the vital role ticket offices play in the journeys of people with disabilities, and we have no plans to close them. These ticket office changes were agreed under the previous Government. The Department is now examining Southeastern’s plans to ensure passengers remain supported.”

Future dangers of ticket office closures and stealth destaffing

Southeastern’s actions prove the ongoing dangers of Schedule 17 of the Ticketing and Settlement agreement (TSA) – re the ways it can enable train operators to destaff their networks by stealth.  In this example, Southeastern was able to play the system to cut around 6-7 hours per day of ticket office staffing without consultation by calling it a ‘minor change.’

Schedule 17 is an out-of-date and inadequate process, allowing train operators to close ticket offices based on sales figures alone, without taking account of other passenger needs, especially accessibility. The TSA is technically an agreement between operators and the unregulated Rail Delivery Group, and the fact that Southeastern’s compliance figures have been running at 74% for so long suggests it is not being enforced. The Schedule 17 process has clearly been facilitating a vicious cycle of managed decline, where operators can secretly make drastic changes to opening hours, based on sales figures from ticket offices that are not complying with their opening hours in the first place. 

Most concerning of all is that the TSA is the only way that any staff hours are regulated – ie, in this case we only have Southeastern’s figures for ticket office staffing, with no way of obtaining the figures for station staff, etc; which are essential to assessing the true scale of the cuts.

These warnings about Schedule 17 and stealth destaffing were also the subject of our 2023 campaign letter against ticket office closures, which spells out the dangers in more detail.

The government must take responsibility

The Department for Transport must act immediately to stop the secret programme of ticket office cuts at Southeastern. It must then take responsibility for staffing strategy across the entire railway, beginning with the immediate enforcement of Schedule 17 hours, and ensuring compliance figures are published regularly by all operators.

We also need to see new, nationwide standards for staffing, ensuring there is always a member of staff available to provide safety, security, information, retail services and assistance – also an absolute necessity for disabled people’s right to ‘turn up and go’. Regulatory measures should be updated to include transparent reporting of staff figures of all types, with a requirement to publicly consult on all changes to retail, staffing and accessibility.

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For the full set of documents from our Southeastern investigation, download zip folder here.

For more information: contact@abcommuters.com

*Note: this blog was edited shortly after publication to include the Department for Transport’s comment.