The Great British Rip-Off: Why the Williams-Shapps Plan will fail to deliver

Despite four years work on the Williams-Shapps Plan, the government has failed to come up with any credible answers for the complete market failure of the railway.

Its promise that Great British Railways (GBR) will be an integrated guiding mind “maximising social and economic value in the public interest” is fundamentally unachievable while privatisation remains in place.

Grant Shapps knows this. That’s why he’s deciding the future of essential passenger services such as fares, ticketing, staffing and station management in backroom talks with private train companies; exempting these areas from consultation. Meanwhile, the Williams-Shapps Plan offers a set of incoherent legislative proposals, which fail to clarify which essential services will be run by GBR; and which will remain in the hands of train companies.

The Williams-Shapps Plan for Rail consultation is clear about just one thing – the reasons for market failure. In the government’s own terms, this has been caused by: 1. Moral Hazard – where profit motivations conflict with the public interest, also known as “perverse incentives”; and 2. Information Failure – where inferior decisions are made due to fragmentation and lack of accountability.

However, both of these problems are certain to remain. Here’s why the Williams-Shapps Plan will fail to deliver:

1. Competition law prevents integration

While rail privatisation remains, the restrictions of competition law will permanently prevent the integration of cross-industry functions such as timetabling, ticketing and passenger data. Competition law also requires a ‘level playing field’, meaning that decisions must not cause an adverse financial impact to private train companies.

The Williams-Shapps plan has failed to find a solution for ‘track access’, the process by which train companies negotiate their use of the timetable. The government has suggested a slightly heavier weighting on public interest factors when timetabling, but this suggestion is likely to be impossible under competition law. Integration will be impossible, with timetabling dominated by private interests, thus minimising the influence of devolved and regional governments.

As the ORR has emphasised in its new consultation response, the government’s proposals actually unleash even more competition concerns, likely to conflict with multiple existing regulations. It even suggests that GBR might have to be split into two distinct parts – to avoid the possibility of breaching competition law by collaborating across retail and operations within itself.

2. Incoherent legislation will prevent reform

Given the undisputable fact that privatisation leads to market failure, the government wants to amend the Railways Act 1993 to make it easier for ‘direct awards’ to publicly-owned operators when private companies fail. However, it wants publicly-owned operators to remain banned from actually competing for contracts because the better value they provide is seen as an ‘unfair advantage’ over private train companies.

The government also wants to retain EU Regulation 1370/2007; making it easier to navigate issues around state aid. These changes are welcome and could greatly increase the ability of local and national governments to directly award contracts to publicly owned companies. However, this approach is logically in conflict with the Bus Services Act 2017, which bans municipal ownership and severely limits the powers of local authorities to regulate their buses. Unless these changes are taken together holistically, it will be impossible to achieve integrated, multi-modal travel across bus and rail.

Finally, the government wants to sign up to the Luxembourg Rail Protocol; a way of liberalising and globalising the Rolling Stock Companies (ROSCOs), making it easier for the big banks to get involved. However, the leasing of trains under the ROSCO system is already one of the most dysfunctional areas of the railway; as well as the biggest site of profit leakage.

3. Accessibility proposals will fail to deliver

According to the submission made by the Disabled Persons Transport Advisory Committee (DPTAC), the government’s proposals will be “insufficient to achieve real cultural change.” The government had previously ignored DPTAC’s recommendation for a £6 billion investment for full station accessibility by 2060, offering just a ‘nationwide station audit’ instead.

Last week, we published a confidential DPTAC report that suggests investment in station accessibility is being jeopardised by the “perverse incentives” of train operators. It is important to note that publicly-owned operators such as LNER are directly subject to the public sector equality duty, whereas private operators are not.

One positive suggestion in the Williams-Shapps plan is to expand the role of DPTAC, which has proved itself to be a competent and independent advisor to the government; never failing to oppose “toxic” and “illegal” policies of railway destaffing. However, there is now an urgent need to ensure DPTAC is sufficiently resourced to guarantee its independence, and has clear guidelines around its publishing and transparency policies. This is the only way to avoid the potential for political interference – especially in relation to the controversy around railway destaffing.

4. Passenger representation – a new role for Transport Focus

The Williams-Shapps Plan suggests that all passenger representation should be conducted by Transport Focus, part of a planned expansion of the organisation. Though it is an excellent research organisation, Transport Focus does not have the independence or credibility required to perform the function of a “passenger champion”; especially as relates to its new role representing disabled passengers. The inflation of Transport Focus to perform all of these vital roles appears to be a quick and cheap way to tick the ‘passenger rights’ boxes without any real consideration of what it would take to gain passengers’ trust and actual representation within the railway.

We Own It and Bring Back British Rail have published an excellent guide to the consultation, which calls for a ‘passenger board’ including representatives from every region of the country, as well as rail workers. Such a model is common in Europe and would greatly increase passenger involvement and trust.

How to respond to the consultation

The Williams-Shapps Plan for Rail consultation closes at midnight tonight, and we urgently need your help. The online response form is complicated, but the information in this blog, plus this excellent guide from We Own It, should help you to demand public ownership with just 15 minutes of your time.

Despite four years work on ‘reinventing the wheel’ of railway privatisation, the government has: 1. Failed to consider public ownership and 2. Failed to provide any proper economic analysis or predictions in support of its plans.

It’s vital to demand that legislative changes work holistically, creating the conditions necessary to “maximise social and economic value” – only possible under public ownership. However, legislative changes alone will not be enough. We’re also demanding a new ‘public sector value test’ to enshrine the benefits of: economic and social value, levelling-up, equality, decarbonisation and modal shift as determining factors in all government contracting decisions. These aims should never be compromised by competition law, especially the duty to avoid ‘financial impact’ on operators.

Any private train companies continuing to operate on the British railway must at minimum be treated as public sector bodies, and made subject to the Freedom of Information Act and the public sector equality duty – as the publicly-owned operators are already.

For more information: contact@abcommuters.com

EXCLUSIVE: ‘Rail Workforce Reform Case Study’ proves economic value of railway staffing

A groundbreaking new report on ‘Rail Workforce Reform’ has concluded that inadequate railway staffing is undermining the value of billions of public investments. It also finds that destaffing policies are creating “perverse incentives” for train operators; jeopardising further investment in station accessibility and step-free access.

The confidential report was drafted in February 2022 by the Disabled Persons Transport Advisory Committee (DPTAC): statutory advisors on accessibility to the Department for Transport (DfT). DPTAC has been warning the government about the “toxic combination of driver-only operation and unstaffed stations” since 2016; insisting that railway destaffing breaches multiple areas of equality law.

DPTAC’s new report uses the ‘Sutton loop’ in South London as a case study to “provide real-world examples of the consequences of policy options” as well as analysing the “current and future impact of staff roles and availability”. Its groundbreaking conclusions on financial impact represent a whole new economic argument for the full staffing of Britain’s railways.

“The toxic combination of driver-only operation and unstaffed stations”

The “Rail Workforce Reform Case Study – Sutton Loop” assessed 20 stations served by the Thameslink (GTR) service from London Blackfriars to Sutton. 11 of these stations also have regular services on other routes, provided by Southern (GTR), South Western and Southeastern. Except for South Western, all services are driver-only operated, so boarding assistance is entirely dependent on station-based staff. The report concludes that:

“Assistance and/or auxiliary aids cannot routinely be provided at all times trains are running, at 14 of 20 stations on the Study Route, even if requested in advance – and certainly not on a ‘turn up and go’ basis…. It is clear that the current staffing levels on this route are completely inadequate to deliver an accessible railway, and to ensure disabled people can use train services on the same terms as other passengers….As things stand, the toxic combination of Driver Only Operated (DOO) trains and unstaffed stations means many disabled people are excluded from using the route to access employment, services, leisure and health facilities.”

Of the 20 stations on the Study Route, 10 have no step-free access from street to platform; and only 5 have step-free access to modern standards (consistent with the national situation.) Only London Blackfriars has level access between the train and platform, so wheelchair users rely on a staff member for boarding assistance at every other station on the route. DPTAC concludes that:

“The ability of staff to provide assistance is the only effective way of mitigating the continued partial physical inaccessibility of many of the stations on the loop, which will take many years to address fully. However, the toxic combination of inadequate station staffing and Driver Only Operated trains in particular, undermines the ability of staff to mitigate physical inaccessibility on a reliable basis, and leads directly to the exclusion of disabled people from the Study Route.”

Railway destaffing undermines the value of investments

The Sutton Loop is part of the Thameslink network, which has received over £6 billion in public investment since 2009, as part of the ‘Thameslink Programme.’ This includes a fleet of modern, accessible Class 700 trains; and platform-train level access at London Blackfriars and St. Pancras. DPTAC argues that railway destaffing has devalued these accessibility investments: as well as over a hundred million invested in 30 other stations directly served by the Study Route stations; and indirect implications for multi-billion investments on the wider network.

“A current lack of adequate staffing renders much of the Study Route inaccessible to many disabled people for much of the time, significantly undermining the investment in accessibility already made, depriving rail of an important market, and perpetuating the exclusion of many disabled people from a vital public service to the detriment of both their lives and the wider economy.

It is impossible to divorce consideration of operating costs from the return on investment in station infrastructure…any reduction in staffing then has the potential to undermine the business case for future investment in accessible facilities, where these are dependent on staff presence – as by definition their benefit reduces as staffing reduces. It may also undermine the willingness of rail management to seek accessibility improvements.”

DPTAC suggests that further investment in station accessibilty is already being jeopardised due to this conflict of interest; recommending that the short to medium term priority is to ensure there are no “perverse incentives” for train operators that would discourage the development of step-free access schemes.

DPTAC’s recommendations:

DPTAC’s “Rail Workforce Reform Case Study” concludes that:

“The benefits of staff presence are widespread and include not only the provision of assistance, but e.g.: personal security reassurance; ensuring toilets and waiting rooms are available; provision of information; and management of disruption etc. Poor staffing levels are likely to suppress demand at a time when the success of the rail nework depends on attracting more customers.

“Any reductions in current staffing levels will result in the Study Route becoming even less accessible with both direct (e.g. the provision of assistance) and indirect (e.g. the opening times of waiting rooms) impacts on accessibility.

“Such reductions in accessibilty will undermine (and in some cases virtually eliminate) the benefit of both previous and potential future investment in the physical accessibility of stations and rail vehicles, and of connecting accessible transport modes…Until radical improvements in physical accessibility can be implemented, staff will remain the key way of ensuring that accessibility is maximised.”

The Rail Workforce Reform Case Study was released to us via a Freedom of Information request. For more information: contact@abcommuters.com

The Great British Cover-Up: What Grant Shapps is hiding about the future of the railways

While everyone’s talking about the Tory leadership contest and RMT industrial action, we’re about to lose our last chance to save Britain’s railway from its most dangerous privatisation project yet.

A government consultation on the new public body Great British Railways– including major changes to legislation – is about to be rushed through without any public awareness. It’s a key part of the government’s secret plan to cut billions in public spending, including a massive destaffing project allegedly involving the closure of every ticket office in England.

Today, we’ve demanded that Grant Shapps extends the 4th August deadline and starts publicly promoting the consultation – in a joint letter with campaign group Bring Back British Rail. The consultation is far too short for a holiday period and has been completely hidden from view by the “National Headquarters Competition for GBR”. If he refuses, the Williams-Shapps Plan will lose even more credibility with the public.

However, this is only the first of the weaknesses in the consultation. The private rail industry has been in backroom talks with the government for months; making vital decisions on all the most important areas affecting passengers.  Most of these areas – such as timetabling, fares, and accessibility – have been exempted from the consultation (2.14) and are being negotiated as part of a market engagement process with train companies. They are now set to be decided without any public input whatsoever.

Screenshot of a Sunday Times headline: Secret plan to close all railway ticket offices as strikes grip Britain
This Sunday Times article was deleted after it went viral. View the archived version here.

Great British Railways and the public-private power struggle:

Beginning in 2018, the purpose of the Williams-Shapps review was to fix the fragmentation that caused the nationwide timetable collapse of that year. The process has concluded that the railway experienced complete market failure; caused by the perverse incentives of private companies within the system.

Consequently, the main commitment of the 2021 Williams-Shapps White Paper was to bring all “critical cross-industry functions” under a new public body, Great British Railways, including: timetable planning, fares and ticketing, open data, and station management. This commitment requires the removal of the operational role of the Rail Delivery Group, which currently controls the National Rail Enquiries ticketing system and many other cross-industry functions – as well as acting as a powerful trade association for private companies.

In October 2021, a secret market engagement process began, to decide the details of the new style of GBR contract – Passenger Service Contracts (PSCs). The Rail Delivery Group simultaneously published their own report on behalf of the private train companies; demanding that GBR should be scaled down to set only “base level requirements” and that train operators should retain most of their critical cross-industry functions, including: “active or leading roles in all three phases of the timetable specification;” key roles in marketing and ticket retailing; maximum autonomy over fare pricing; and the commercial and operational management of stations.

Essential passenger services are now under greater threat than ever, and all the details of these policies have been hidden from public view.

  1. Fare Reform

There has been no proper consultation on rail fare reform for Great British Railways. A major ‘Pay As You Go’ smart-ticketing consultation was held in 2019, but this never reported to the public. Nor was there any consultation behind Great British Railway’s first policy rollout – ‘flexi-tickets’, launched in June 2021. The Department for Transport even ignored their own focus group research, which shows a strongly adverse reaction to the flexi policy they eventually chose – giving just a 5% discount on the price of a daily ticket.

A ‘formal one-year review’ of the flexi-ticket scheme is currently underway, but this is being hidden from the public due to train companies’ demands for commercial confidentiality. For the same reason, the Rail Delivery Group refuses to release any flexi-ticket sales data, despite the scheme being a government policy and fully funded by the taxpayer.

Most shockingly of all, the Rail Delivery Group has been put in charge of implementing a whole new smart ticketing system on behalf of Great British Railways.

2. Accessibility

Disabled people’s equal right to travel has been under threat for years, due to a compromised relationship between government and industry in which they have secretly developed long-term destaffing programs – previously revealed by whistleblowers on this website. The plan to close every ticket office in England is the latest example of this cover-up.

The Williams-Shapps Plan’s proposals for accessibility have never been consulted on, and essential advice from the government’s accessibility advisors has been ignored. The National Disability Strategy was recently declared unlawful by the high court for its failure to properly consult, and it seems that many of the same weaknesses are now being repeated in the Williams-Shapps consultation.

3. Workers’ rights

Currently, Grant Shapps refuses to step in on the strikes, and the blame for the industrial relations crisis has landed on the government. But this does not mean that the private rail industry is any more sympathetic. As reported in The Times, the industry is pushing for ‘minimum service levels’ legislation; which would virtually end the effectiveness of industrial action and trade union negotiating power.

In its lobbying on Passenger Services Contracts, the Rail Delivery Group has said that the industry wants more control over stations, and the development of automation technologies.  One of their central demands is for the new contracts to directly incentivise them to cut costs – which will ensure permanent conflict in industrial relations, with the government continuing to negotiate by proxy.

What happens next?

We are still only scratching the surface of the ‘Great British Cover-Up’ and the Williams-Shapps Plan for Rail consultation. The Department for Transport has refused to comment.

It’s vital that we get Grant Shapps to agree to an extension within the next few days, so that passengers, campaigners and trade unions can prepare their responses. Please join us by writing to him at shappsg@parliament.uk

The private rail industry’s ‘perverse incentives’ have stood in the way of passengers’ rights for much too long. We are now gathering evidence of the industry’s many conflicts of interest, to show that this is the true cause of the crisis in passenger trust – as well as the failure to modernise.

For more information, or to share your comments: contact@abcommuters.com

[This page was updated on 03/08/2022 to better reflect changes to the consultation principles in 2018]

New campaign demands transparency from Department for Transport’s accessibility advisors

Today, we reveal years of transparency failures at the Disabled Persons Transport Advisory Committee (DPTAC), statutory advisors on accessibility to the Department for Transport. Our evidence proves that many vital consultation responses remain unpublished; as well as formal letters warning about the illegality of unstaffed stations and driver-only operation.

In response, DPTAC has agreed that it needs to review its approach to transparency ‘as a matter of priority’ and is now working on its first ever ‘clear publishing policy.’ If they keep this promise, we can expect many controversial documents to shortly be released into the public domain. These are sure to become vital campaigning tools for disabled people and organisations across all forms of transport.

This report aims to ensure DPTAC’s publishing policy goes forward; and that their work is protected from political interference by the Department for Transport.

DPTAC reference frame: working towards a fully accessible railway

In April 2022, Disability News Service (DNS) reported that the late publication of a vital DPTAC report in February prevented disabled people and campaigners being able to use it for major government consultations such as the National Disability Strategy. The ‘DPTAC reference frame’ report includes a damning critique of railway structure and culture, calling for a ‘whole system’ approach that makes accessibility a ‘fundamental’ part of the railway. It also proposes new regulations and more than £6 billion investment to set a timeline for full station accessibility by 2060.

We can now reveal that DPTAC gave inaccurate information about the origin of the ‘reference frame’ report, dating it November 2020 in both their response to DNS and the official publication on their website. The report is actually DPTAC’s May 2019 submission to the Williams Rail Review, meaning that its official publication comes almost three years late.

DPTAC’s submission to the Williams Rail Review, May 2019

The ‘DPTAC reference frame’ report was formally submitted to the Williams Review, the DfT and the Office of Rail and Road (ORR) in May 2019. It was first published on this website in July 2019 as part of a batch of documents received through an FOI request to DPTAC.  Following its public endorsement from the ORR, who recommended that DPTAC be put in charge of ‘developing criteria to support a whole-system approach to accessibility’, we published a dedicated blog post on the report in September 2019; explaining that it had just become ‘the most important document on accessibility in the entire Williams Review.’

The ‘reference frame’ report has since had a significant presence in the ‘Great British Railways’ project, with some of its lower-cost proposals already being taken forward. In March 2022, it was revealed in a Transport Select Committee hearing that DPTAC is now playing a key role in the new ‘National Rail Accessibility Strategy’ and a nationwide station audit – one of the report’s urgent recommendations.

Despite the obvious significance of the report’s origin, it has been published on the gov.uk website with the date of November 2020. This version of the ‘DPTAC reference frame report’ is exactly the same as their May 2019 Williams Review submission; edited for timeline purposes alone.

The Chair of DPTAC, Keith Richards, commented: “Whenever we have revisited the rail paper with the view to using it in subsequent meetings and discussions internally with DfT (often with new teams of officials) we have reviewed it and changed the date as necessary (whether there were any substantive changes to the text or not) simply to show that it reflected our current thinking (despite the passing of time since the original drafting in May 2019).”

In regard to the inaccurate claim that the report had been released to us under FOI in November 2020, Keith Richards said: “when corresponding with DNS and yourself recently I had forgotten that your earlier FOI had resulted in the release of the paper back in July 2019. That’s my mistake and was certainly not from any attempt to mislead anyone.

He did not respond on whether DPTAC would be changing the date of November 2020 on their official publication.

Railway staffing and driver-only operation

DPTAC’s transparency problem goes back much further, regarding one of the most controversial issues in the history of the railway: driver-only operation (DOO). Their May 2019 ‘reference frame report’ was dispatched to the DfT as an attachment to a formal warning letter about the illegality of DOO and unstaffed stations. Following the letter, DPTAC met with ministers to urge them to seek legal advice and adopt an ‘explicit policy’ on DOO; guaranteeing that a guard or member of station staff would be available at all times to provide unbooked assistance.

The letter to ministers followed years of warnings going back to April 2016, when DPTAC wrote to the DfT’s Peter Wilkinson, the DfT civil servant widely believed to be the architect of the industrial dispute over DOO. They warned: ‘The toxic combination of driver-only operated trains and unstaffed stations fails to deliver a service that meets the needs of many disabled passengers. As a result DPTAC is seeking a guarantee that such policies cannot undermine the fundamental principle of accessibility – which would in any event be illegal.’

The letter to Peter Wilkinson was first revealed on this website in July 2018, but, six years after writing, it has still not been officially published by DPTAC. We now host the only publicly-available archive of these documents.

The Chair of DPTAC, Keith Richards, responded: “…the need for DPTAC to have a new publishing policy is clear. There are a number of reasons why we do not and cannot publish everything we may draft for our own internal use and which we use as tools to inform early-stage policy thinking within the DfT,  but I suspect that we have sometimes taken an overly cautious approach and that may not be helpful to our external stakeholders who would value and potentially benefit from knowing what advice DPTAC is providing on key transport accessibility issues across all modes of transport and the built environment.  

So, you are absolutely right that we need to review our approach to publication and I have put that in place already and as a matter of priority I will be working on a clear policy with the members of DPTAC who chair our working groups. Going forward, DPTAC will live up to our responsibility to proactively ensure transparency. This will avoid placing an unfair burden on our stakeholders to seek information through the FOI process, which has regrettably been the case at times in recent years.”

Political pressure from the Department for Transport?

Though we welcome DPTAC’s commitment to creating a ‘clear publishing policy’, there may still be an obstacle in their path. Our evidence suggests that DPTAC has been subject to political pressure from the DfT, and that the DfT may have interfered in their publishing decisions.

In July 2019, we published a viral blog post about DPTAC’s letter to ministers, exposing the existence of ‘wholly inadequate‘ guidance on DOO, developed by the Rail Delivery Group. An email from the DfT to DPTAC in August 2019 suggests they ran significant crisis management on the story: ‘Activity around the Association of British Commuters FOI has unfortunately taken up the resource and time we had set aside to make progress on [getting legal advice on DOO] over the summer.’

Meeting minutes from September 2019 show that three members of DPTAC were then required to sign non-disclosure agreements in regard to their engagement with the Williams Review; restricting what they could share with the rest of the Committee from that point onward.

In an October 2019 discussion about whether to adopt a social media strategy, one member commented ‘DPTAC are monitored by DfT’s Press Office in terms of what can be communicated and when’, and another member suggested ‘DPTAC can work with DfT to plan the material and timing of publications.’ The Chair noted that ‘DPTAC’s social media presence is an early step to explore a soft approach to DPTAC’s outward facing profile, which aims to build trust in DfT’s Press Office.’  To date, DPTAC has not launched the social media strategy.

The Department for Transport commented: ‘A small secretariat in DfT provides administrative support to DPTAC and its members, all of whom work part-time. This includes administrative support in relation to publication of DPTAC documents which are hosted on gov.uk and ensuring documents for publication meet broader gov.uk accessibility standards. As an independent expert committee advising the Secretary of State for Transport, DPTAC are independent of Government and make their own decisions about which documents to publish.’

The Department for Transport did not comment on why it had required members of DPTAC to sign non-disclosure agreements for their work with the Williams Review, the rail reform program still underway under the banner of ‘Great British Railways’.

The urgent need for transparency at DPTAC

Our evidence suggests that DPTAC has failed to fulfil its obligations under Section 19 of the Freedom of Information Act, which requires public authorities to proactively publish documents and ensure the prompt availability of newly-created information. Guidance from the Information Commissioner’s Office (ICO) requires DPTAC to adopt a ‘model publication scheme’, making their reports, policy positions and meeting minutes ‘routinely available’ to the public.

DPTAC must adopt the ICO’s guidance as part of a clear publishing policy that provides transparency to disabled people and the general public. It is vital that the new policy is protected from political interference and ensures DPTAC’s autonomy going forward – as required by their status as an independent statutory body under the 1985 Transport Act.

Upcoming DPTAC publications

We now anticipate the publication of multiple DPTAC consultation responses, including their submission to the Pay As You Go rail consultation (2019), the Future of transport regulatory review (2020), the Law Commission’s consultation on autonomous vehicles (2021) and the National Disability Strategy (2021). There may also be DPTAC research reports available on the Disabled Persons Railcard and the Passenger Assist app.

We have challenged DPTAC to ensure that accuracy is a key part of their new approach, by changing the publication date of their ‘reference frame’ report to May 2019, and including the context that it was in fact DPTAC’s formal submission to the Williams Rail Review. This will be a vital sign of their approach to transparency going forward, and intention to accurately represent the historical record.

Currently, our website hosts the only publicly available archive of DPTAC’s objections to driver-only operation. We demand the official publication of these documents as well as an up-to-date ‘DPTAC position statement’ explaining their concerns about DOO and railway staffing.

For more information: contact@abcommuters.com

[This article was edited on 06.05.2022. to better characterise the fact that the Williams Review rail reform program now continues under the banner of ‘Great British Railways.’]

REVEALED: The economic dangers of the National Bus Strategy

As Parliament comes back into session, there is an urgent need to raise the alarm on the National Bus Strategy. As further detail has emerged this summer, it is clear that the Strategy is in fact an accelerated program of ‘Enhanced Partnerships’ – the purpose of which is to revive the failed policy of bus deregulation. Nearly every local authority in England has now been coerced into starting this path, by the threat of losing access to all future bus funding.

In July, the National Bus Strategy became a source of international controversy when the former UN Rapporteur for Poverty, Philip Alston, accused the UK government of ‘doubling down’ on its ‘extreme form of bus privatisation’, despite already being in breach of multiple human rights obligations. He also raised serious doubts whether the Strategy has any cost-benefit analysis or evidence-based policy behind it. Our investigation now confirms his suspicions that the government has no economic case to offer.

No economic case for the National Bus Strategy

In a recent FOI response, the Department for Transport confirmed to us that they have not conducted any cost-benefit analyses or demand forecasts comparing deregulation with Enhanced Partnerships, franchising and municipal ownership; except for an extremely limited and outdated 2017 study. This is further confirmed by the Department for Transport’s new ‘areas of research’ corporate report, which includes at least a dozen questions relating to unresolved issues in the National Bus Strategy; strongly emphasising the need for economic research, as well as private vs. public operation and the barriers for devolved transport policy. Indeed, the National Bus Strategy itself points out multiple areas requiring further policy work, including the ban on municipal ownership, which it says is ‘ripe for review.’

The truth is that the public control of buses was never intended to be a realistic option for local authorities. Despite promising to update ‘incompatible’ 2017 guidance on Enhanced Partnerships and franchising in Spring, the government failed to meet this commitment in time for the initial deadline of June 30th. This means that nearly every local authority has now been coerced into making a statutory declaration towards an Enhanced Partnership (EP), without the facts in front of them. To add insult to injury, the EP guidance was updated just one day after the deadline, and the guidance for franchising remains to be updated.

‘Bus Service Improvement Plans’ are a public investment giveaway to bus companies

The second stage of the Strategy is now underway and local authorities must complete a ‘Bus Service Improvement Plan’ (BSIP) by October 31st to remain eligible for funding. BSIPs are ‘joint funding proposals’ between councils and bus operators, due to be judged by criteria that revolves almost entirely around short-term measures. As this is an extra, non-statutory stage to the Enhanced Partnership, public consultation is strongly discouraged, despite the fact that BSIP content is expected to be almost fully replicated in the form of an ‘EP Plan’.

The primary condition of BSIP funding is for councils to commit to ambitious public investments – especially an increase in bus priority – while bus companies are encouraged to form a ‘collective joint position’ and a ‘shopping list’ of demands from the earliest possible stage. Invitations for ‘reciprocal investment’ are to be ‘heavily weighted’ towards what local authorities can provide, to allow for the commercial uncertainty felt by bus operators as they emerge from the pandemic. Only minor improvements are expected from bus operators in return, as competition law prevents councils from imposing anything but ‘indispensable’ restrictions on the deregulated market. The ability for councils to cross-subsidise services, set prices or generally lower fares will also be banned by law.

Under these circumstances, the level of profit leakage from public investments has now reached a greater level than ever before. For example, Greater Manchester’s 2019 case for franchising found that it offered almost three times the economic value of the bus companies’ partnership proposal. Under the funding conditions and strict deadlines imposed by the National Bus Strategy, we can expect the disparity to be even greater.  In addition to the £3 billion pledged for bus services, this will have a knock on effect on all public transport, cycling, and walking schemes – preventing the ability to make an integrated plan, or optimise the value of investments.

Urgent action required within the next two months

Having failed to offer any economic case for Enhanced Partnerships, the government’s only justification is that the process is quicker than public control (franchising). However, it is their own legislation that makes the franchising process so difficult, and there is now a near-unanimous consensus that the Bus Services Act (2017) is inadequate to the task. This includes a wide range of respected organisations, including NYU Law School, Centre for Cities, the CPRE, the Transport Select Committee, and even the National Audit Office.

The ultimate solution is for the government to pause the National Bus Strategy and urgently review the legislation behind it, including the ban on municipal ownership. The economic dangers of continuing with bus deregulation are in no doubt, and there is an urgent need for Parliamentary intervention before the BSIP deadline of October 31st. If the Enhanced Partnership program goes forward next April, councils will be locked into bus deregulation for the long-term.

However, this should not let councils off the hook. There are just two months left to complete the BSIP process and it is absolutely vital that they resist pressure from bus companies and create ambitions that can be shown to bring long-term economic value to their communities. Due to the ban on cross-subsidy under deregulation, this will only be possible under public control or ownership (estimated to bring back £340 million or £503 million per year to the British taxpayer, respectively.)

In turn, the government must come through on its promises to update and strengthen the franchising process. Currently, only mayoral combined authorities even have access to the powers to franchise their buses. However, the government has committed to supporting access to these powers ‘for local authorities with the capacity and intention to use them’ and it’s now a priority to call them in on that promise.

In both the BSIP and EP guidance, the government has advised councils to limit the length and scope of public consultation as much as possible. Since the next two months will be crucial to negotiations, local campaigners should do all they can to raise fundamental issues and long-term objectives in relation to bus services. This means putting long-term social, economic and climate justice at the top of the agenda, and demanding that councils incorporate these goals.

References:

-NYU School of Law (2021) Public Transport, Private Profit

-Centre for Cities (2021) Get on board: bus franchising

-CPRE, the countryside charity (2021) Every village, every hour

-Transport Select Committee (2019) Bus services in England

-National Audit Office (2020) Improving local bus services in England

-Transport for Quality of Life (2015) Building a World Class Bus System

This article was edited on 09/09/2021 to include a link to the Bus Services Bill: Impact Assessments (2017). This is the only cost-benefit analysis conducted by the Department for Transport, comparing franchising and enhanced partnerships.

EXCLUSIVE: Accessibility under threat due to increase in driver only trains and unstaffed stations

New research from the Disabled Persons Transport Advisory Committee (DPTAC) indicates a significant withdrawal of rail accessibility since the beginning of lockdown in March. It compiles detailed information on 2556 stations to provide a complete staffing profile; demonstrating the impact of station destaffing and driver-only trains on accessibility.

The data shows that up to 54% of stations are completely unstaffed, with as few as 12% staffed at all times. Most shockingly of all, the ‘toxic combination’ of driver-only trains and unstaffed stations could now be preventing accessibility at up to 16.8% of Britain’s stations (up from 12.1% of stations in February.)

Reductions in assistance capability at stations, DPTAC May 2020 – DOWNLOAD HERE.

According to the data, Govia Thameslink Railway is by far the worst offender for the combination of driver only trains and unstaffed stations. In February, this prevented assistance capability at 126 locations. By May this figure had increased to 215 due to the removal of ontrain staff as well as ticket office closures/reductions.

According to May’s figures, train operators are running unstaffed trains through unstaffed stations at 430 locations: GTR (215), Southeastern (73), Greater Anglia (58), Great Western Railway (32), Chiltern (26), c2c (23), Heathrow Express (3), and Stobart Rail (1).

Our Freedom of Information request to DPTAC

This data was released to us after an FOI request to DPTAC, the Department for Transport’s statutory advisors on accessibility. DPTAC has consistently raised strong objections to the ‘toxic combination’ of driver only trains and unstaffed stations since the beginning of the Southern Rail guards dispute of 2016. The ‘urgent’ and ‘unmet’ need for detailed data on staffing was the headline demand of each of their submissions to the Williams Rail Review, so the release of this information is sure to be highly controversial within the Department for Transport.

In May, the Chair of DPTAC defended their data collection to Rupert Furness, Head of Active and Accessible Travel at the DfT. To view the email, click here.

Another email chain confirms that the Department for Transport has sought legal advice on driver-only trains and unstaffed stations, after warnings from the Equality and Human Rights Commission. To view the document, click here.

Urgent Action Now Required

DPTAC’s research shows that the staffing model on Britain’s railway is not fit for purpose. In particular, it demonstrates the discriminatory effect of driver-only trains and how rapidly they can affect accessibility when there are reductions to the already low levels of station staffing.

With Govia Thameslink Railway once again firmly in the frame for withdrawing assistance capability at stations, it is vital that the Go Ahead Group and the DfT’s Peter Wilkinson are asked to respond to this data at the Transport Select Committee on Wednesday. They were the architects of the removal of guards on GTR, and it’s now clear that this is having a regressive effect on equality of access.

With further cuts to railway staffing being rumoured, we will be calling on the Transport Select Committee and Office of Rail and Road to ensure that this data continues to be published regularly, as the best way to monitor what on-the-ground changes are being made to stafffing. Train operators must already provide this information under the ORR’s new Assisted Travel Policy, so it should require few resources to collate the information in a transparent and centralised manner. This has been a headline demand from DPTAC to the DfT for years, and they have made clear that accurate, up-to-date data is the only possible basis for a ‘whole system’ overview of railway accessibility.

For further information on DPTAC’s demands for data and accessibility see their January 2019 and May 2019 submissions to the Williams Rail Review.

For a background of our FOI requests to DPTAC, click here.

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Government forced to release Steer report on disabled access and driver only operation

In a major victory for our campaign, the government has just been forced to release the controversial Steer report on driver only operation (DOO) and disabled access. We had been pursuing this report through freedom of information requests to the Department for Transport since the summer, but without success. However, a copy was sent to Lilian Greenwood last month and – in one of her final acts as Chair of the Transport Select Committee – she has now published it on the Committee’s website.

With this decisive action, Lilian has ensured that the Steer report has been revealed before the general election ‘purdah’ period kicks in, which is a victory for campaigners – and an unexpected embarrassment for both the government and the rail industry.

A ‘wholly inadequate’ report – approach with ‘extreme caution’

We knew that the content of the Steer report would be controversial because of this damning letter from the Disabled Person’s Transport Committee (DPTAC), the DfT’s statutory advisors on accessibility. The letter urges ministers to approach the report with ‘extreme caution’, warning that it is ‘wholly inadequate’ in providing mitigations for the ‘toxic combination’ of driver only trains and unstaffed stations. Both the DPTAC letter and an accompanying email question whether the DfT and train operating companies are meeting their legal duties under the Equality Act.

As documents from DPTAC demonstrate, there is an ‘urgent and unmet need for research’ relating to disabled access, staffing levels and modes of operation. And it’s been three years since the Transport Select Committee first requested an equality impact assessment on the issue. The unacceptable delay to research in this area is in our view due to two reasons: 1) the absence of staff cannot be mitigated by any other means except staff – therefore it is logically impossible to create a report showing that DOO can be introduced without regressing disabled access by normalising pre-booking instead of asserting the right to spontaneous travel. 2) The fragmented industry structure and constrained contractual relationships create a toxic mix where research and policy is developed not in the public interest, but dominated by train operating companies (via the Rail Delivery Group) in the interests of profit.

The Steer report is supposed to give clear guidance on the mitigations required to assist and protect disabled passengers when there are no staff on the train or station. However, it drastically fails to meet that objective, and in fact demonstrates that no mitigation is possible – and therefore that a full staffing model is the only solution. The report reads precisely as if it was strung together from a desired conclusion, and its release is undoubtedly highly embarrassing for its authors, the government and the rail industry.

The Equality and Human Rights Commission is now treating access to transport as a priority issue and has established a fund to support legal challenges. Equality law firm Fry Law has even been sending out cameras to assist disabled passengers in capturing evidence for the inevitable legal cases to come. In a situation where unstaffed trains are calling at unstaffed stations about 10% of the time (according to DPTAC’s estimate), it can only be a matter of time before we see new legal precedents set in this area.

DOWNLOAD THE STEER REPORT HERE

For the rest of Lilian Greenwood’s correspondence on this topic, click here and here.

Important links on disabled access and destaffing:

2018 DTAC documents

2019 DPTAC documents

DPTAC’s submission to the Williams Rail Review

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The fundamental right to travel: DPTAC gives us the ONLY advice we can trust on accessibility

The Disabled Persons Transport Advisory Committee (DPTAC) are statutory advisors to the Department for Transport on accessibility, making them the best possible source for an expert opinion with a front row seat on policy issues. We have previously published dozens of documents detailing their opposition to driver only operation and station destaffing; in which they cite their concerns about the potential Equality and Human Rights Committee legal action on this issue.

With this in mind, we believe that the Office of Rail and Road’s new ‘Accessible Travel Policy’ contains a regulatory hole around accessibility. Their new guidance to train companies aims to reduce the advance booking period from twenty-four to two hours by 2022, but includes no obligation to spontaneous ‘turn up and go’ travel. The ORR says that staffing issues are not part of its remit, but in view of their own duty under section 149 of the Equality Act, we asked them to comment. Unfortunately, they informed us that they would only be reconsidering this issue if government, the Williams Review or ‘other regulators’ took decisions in this policy area.

But, all is not lost. In the ORR’s July submission to the Williams Review, they place a strong emphasis on the need for a whole system approach to accessibility, based on clear criteria for both funding and staffing. And the ORR has made a very clear recommendation that this ‘whole system approach’ should be led by DPTAC.

Why are the DPTAC documents so important?

DPTAC’s May 2019 submission to the Williams Review provides exactly this outline of a ‘whole system’ approach. With the ORR’s backing, it is now undoubtedly the most important document on accessibility in the entire Williams Review:

DOWNLOAD HERE

quote bubble dptac orgs.PNGDPTAC recommends a ‘paradigm shift’ in which accessibility becomes a ‘fundamental’ part of the industry, rather then just an ‘add on’. Their May submission to the Williams Review includes a damning analysis of rail industry culture and structure; and calls for a ‘whole system’ approach that embeds accessibility ‘into the heart of what the rail industry does’. DPTAC also argues that rail vehicle accessibility legislation (TSI/RVAR) has provided a ‘relatively strong baseline’, and that there is now a strong case for new regulation with compliance deadlines for station accessibility. This would form part of a long-term funding strategy that could see the timeline to ‘full accessibility’ reduce from 100 to 40 years.

DPTAC’s May submission to the Williams Review is an essential report for all transport and disability rights campaigners and we ask for your help to spread it widely. It is important to remember that the government has set Williams’s remit to be ‘fiscally neutral’ – so it will take a great deal of campaigning and/or legal actions to get these demands over the line.

The ONLY quantified overview of rail accessibility?

Overview of UK rail accessibility

The biggest theme emerging from the latest DPTAC documents is the ‘urgent’ and ‘unmet’ need for research, and the ‘dearth of detailed data’ on staffing levels in particular. They make clear that the problem is endemic, with ‘no agreed approach to quantifying the accessibility of the rail network’ and in many areas ‘a lack of quantified data on specific aspects of network accessibility.’ The state of transparency around accessibility research remains a matter of serious concern to us, with the DfT still refusing to publish the ‘wholly inadequate’ Steer report on modes of train operation following our request for an internal review of their FOI decision.

The above statistics are taken from pages 2 to 3 of DPTAC’s submission to the Williams Review and are drawn almost entirely from the 2015 report ‘On Track for 2020’. This report is considered by DPTAC to be a ‘unique’ overview – and the most up-to-date source of quantified data on rail accessibility. And yet, this report was withheld until June 2017 by the Rail Delivery Group, when we published a copy and forced its official release.

Another important point to make is that the ORR will have gone forward with the publication of their new Accessible Travel Policy (ATP) based in part on the very same Steer research on ‘modes of train operation’ that DPTAC has stated is ‘wholly inadequate’ and should only be approached with ‘extreme caution’. Earlier this week, campaigner Doug Paulley succeeded in getting the ATP sent back to the ORR for a ‘rethink’ after threatening a judicial review over the accessibility of rail replacement buses – so is there scope to go further in other areas of the guidance too? We think it’s time to question whether the ORR is using the full extent of its regulatory powers – especially in regard to the changing landscape of railway staffing.

Other essential DPTAC documents:

  • DPTAC’s reponse to the DfT’s PAYG consultation goes into further detail about the need for a new staffing model at a time of technological change (April 2019): download here.
  • DPTAC’s initial submission to the Williams Rail Review goes into detail about the ‘urgent’ and ‘unmet’ need for research (January 2019): download here.
  • Read the full story of the Steer report controversy here.
  • Read DPTAC’s letter to Ministers about driver only operation and destaffing here.
  • Read DPTAC’s email chain containing urgent questions to Ministers concerning driver only operation and the Equality Act here.

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Exposed AGAIN! Disabled Access cover up at the Department for Transport

It’s been exactly one year since we published documents from the Disabled Person’s Transport Advisory Committee (DPTAC), revealing years of cover ups inside the Department for Transport concerning driver only operation (DOO). A month ago, we repeated our FOI request and can reveal that the situation around DOO and disabled access is now at breaking point.

The latest documents show that since April this year, DPTAC has been in open rebellion against the DfT due to a ‘wholly inadequate’ piece of research: ‘Effects of modes of train operation on passengers with disabilities’ by the consultants Steer. The existence of this report has so far been concealed from the Transport Select Committee and the Equality and Human Rights Commission, as well as the disability charities involved in the DfT’s ‘Inclusive Transport’ campaign.

The Steer Report – ‘Effects of modes of train operation on passengers with disabilities.’

In an outspoken letter sent to ministers on 2nd May this year, DPTAC states: ‘our headline advice is that the results of this work should be used with extreme caution […] our advice is that the research and Guidance Note fall very considerably short of articulating measures that mitigate the potentially very negative consequences of driver-only operation, when combined with unstaffed stations; a toxic combination for many disabled people that excludes them from using the rail network.’

In the letter, DPTAC challenges the legality of the DfT and train operating companies’ plans for DOO, questioning whether the running of unstaffed trains through unstaffed stations is consistent with the Department’s duties under the Equality Act 2010. The full letter to ministers can be viewed here:

After Andrew Jones’ appearance at the Transport Select Committee on 8th May, DPTAC scheduled an urgent meeting with ministers and sent ahead a list of demanding questions, also concerning the legality of plans for DOO:

The DPTAC documents prove us right in our ongoing pursuit of a report by the consultants Steer (formerly Steer Davies Gleave). We had previously understood a 2013 Steer report to be the foundation of the entire DOO project, meaning that this new discovery of a piece of 2018 research is part of a six year history that has so far evaded all Parliamentary scrutiny. The 2018 Steer report ‘Effects of modes of train operation on passengers with disabilities’ is yet a further stage in a process of policy development that’s been going on for years within the closed circle of the DfT, Rail Delivery Group and train operating companies.

Key documents: DPTAC’s Letter to Ministers dated 9th April, sent 2nd May  *  June 2019 emails – DPTAC arrange meeting with Transport Ministers and send urgent questions in advance  *  DPTAC’s second submission to the Williams Review – Working towards a fully accessible railway, 8th May  *  DPTAC’s response to the PAYG consultation, submitted 30th April 2019

The Steer Report – Timeline of Events

Steer Timeline JPEG

Background – the 2013 Steer Report

Since August 2017, we have been pursuing a 2013 Steer report known as “Driver only operation – passenger”, which we believe forms the basis of the entire DOO project. We first drew attention to the existence of this report with our publication of a 2014 email from Michael Woods of the Rail Safey and Standards Board (RSSB). However, the Steer report has been held back by the Rail Delivery Group (RDG), who are not subject to freedom of information legislation. After we broke the story two years ago, the RDG refused to release the report under FOI, giving the following comment to press:

“In 2011, an independent report into making the railway more efficient recommended that driver only operated trains should be the default option across the network. Following this, a more detailed report was commissioned to investigate the financial implications of different ways of enacting this recommendation. As a public service which spends taxpayers’ money to better connect the country, it is only right that we look at ways to make our services more efficient but it is entirely normal that such analysis remains confidential. Where it is being introduced, careful consideration is being given to ensure that a second member of staff, not necessarily a guard, is available wherever appropriate to assist passengers.”

After three years of industrial action and with a looming legal threat against the government from the Equality and Human Rights Commission, there is little need to emphasise the public interest value of the 2013 Steer report. After FOI requests to the DfT, DPTAC, RSSB and the ORR we have discovered that the document is held only by the Rail Delivery Group. This means that the private industry-led consortium has complete control and ownership over a document that we know has been foundational to policy. The fact that this document has been held back by the Rail Delivery Group for six years also provides the rail industry’s most urgent example of the need for FOI legislation to be extended to private contractors.

To date – the 2018 Steer Report

Our FOI request to DPTAC has revealed the existence of a 2018 Steer report on DOO, ‘Effects of modes of operation on passengers with disabilities’. Although we have been able to publish DPTAC’s damning verdict on its contents, the report itself has been withheld under section 22 (1) of the FOI Act – namely that the report is already ‘planned for publication’ by the Department for Transport.

However, it’s clear in the correspondence that ministers are deciding whether to publish, not when. An email from May 30th, where a DFT civil servant chastises a member of DPTAC for referring to the report at an ORR event, states that: ‘Ministers haven’t yet decided whether to share’ and ‘while some of the TOCs at the meeting today might have been aware when you raised it, the disability groups and EHRC definitely wouldn’t be.’

june confidentiality dft.PNGThe DPTAC email correspondence shows the 2018 Steer Report passing through at least three ‘iterations’, a process managed by the Rail Delivery Group in collaboration with consultants Steer – and in which they have sought feedback from train operating companies ‘to ensure recommendations are feasible’. The following excerpts from February 2018 further demonstrate this unhealthy dynamic:

steer report email feb update.PNG

From DPTAC meeting minutes – 12th Feb 2019:

Steer report feb update.PNG

Our requests to the Transport Select Committee:

(1) At his 8th May update to the Transport Select Committee, the Rail Minister Andrew Jones maintained that driver only operation is ‘not policy’. This is no more than an issue of semantics, relating to a behind-the-scenes legal wrangle over who holds the Public Sector Equality Duty in franchise contracts. The documents we’ve published today show that this legal discussion is already going on behind the scenes at the DfT, who are undoubtedly preparing for a legal challenge from the Equality and Human Rights Commission. We call on the Transport Select Committee to seek sight of any legal advice provided to the Department, which could potentially influence changes to legislation following the Williams Review and is therefore in urgent need of oversight.

In particular, please note:

Points 2.6 and 2.7 of the DfT and DPTAC Rail Sub-Group Meeting minutes – 12th Oct 2018:

PSED.PNG

The following paragraph from a DfT civil servant sent to a member of DPTAC on 30th December 2018. dft email to dptac 30 dec 2018

(2) We call on the Transport Select Committee to demand all ‘iterations’ of Steer report(s) on driver only operation since 2013, and to question the Rail Delivery Group thoroughly on the report’s six year history. We will continue to request the 2018 Steer Report under FOI, but our primary concern is that documents are being withheld from the Transport Select Committee, meaning there can be no proper scrutiny of Departmental policy.

(3) We call on the Transport Select Committee to undertake an investigation into transparency and research standards at the DfT. Railway policy has been developed behind closed doors for up to a decade, and it is outrageous that this ‘research’ process appears to have been dominated by the Rail Delivery Group, the majority of whose members are train operating companies. Despite years of industrial conflict on the issue, the TSC has not even been allowed to view the business case for DOO (which we believe to be contained within the earlier 2013 Steer report).

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[This article was edited on 03/05/2022 to remove expired links to documents]

International Women’s Day Protest – Keep The Guard On The Train!

This International Women’s Day, it’s time to demand that the Department for Transport finally listens to passenger concerns about safety, security and access. We’ll be meeting at Great Minster House at midday on Friday 8th March to deliver an 85,000-strong petition to “Keep The Guard On The Train” and we hope that you can join us!

All are welcome, and we are particularly keen to celebrate the women who have done so much to defend against the government-driven attempt to remove guards from trains. Special guests will include; Beth Granter, who began the petition for women’s safety on the railways; Ann Bates OBE, who has campaigned alongside ABC for three years on disabled access; and Michelle Rodgers, the recently elected President of the RMT union and the first woman in its history to hold this position.

Sign up to our Facebook event here or RSVP to contact@abcommuters.com

Why International Women’s Day?

Over the past ten years, sexual offenses on the railways have gone up a staggering 167%, and violent crime has risen by 47%, according to recent figures from the British Transport Police (BTP). In the period 2017-2018, these categories of crime are up 16% and 26% respectively. In the case of sexual offenses, the BTP believes that there are many more crimes of this type that go unreported.

All vulnerable passengers deserve the peace of mind of knowing there will be a safety critical, guaranteed guard on every train, not to mention the deterrent factor in an era of rising crime. In rural areas, including Southern Rail, Northern Rail and South Western Railway, there are long gaps between stops and largely unstaffed stations – so the suggestion to destaff these networks should never have even been up for debate.

Despite this context – and a three-year long industrial dispute on the matter – passengers in England have never been consulted on the issue of driver only trains. During our campaign on the matter, we have dug up multiple documents emphasising concerns around safety and disabled access, but our concerns have been ignored. With the Equality and Human Rights Commission recently stating that they are likely to take action over the roll back of disabled access associated with DOO, we’ll be appealing directly to the DfT and the Williams Rail Review to return to the vision of a fully staffed railway, accessible to all.

Join us to demand a guaranteed and safety critical member of staff on every train – no excuses!