OOOh, this is getting a tad juicy. The
.....
Jacqui Russell
Head of Consumer Team
TOC MDs; and
TOC accessibility leads
[by email]
5 July 2023
Dear Industry Colleagues
Station ticket office reforms
Operators have today published consultations on proposals to make changes to the responsibilities of station staff and to close ticket offices. I am writing to provide an overview of a number potentially relevant regulatory considerations that may be helpful as you refine your plans, and to formally ask you to provide an initial high level review of your proposals against ORR’s Accessible Travel Policy (
ATP▸ ) guidance.
Changes to ticket office opening hours
Changes to ticket office opening hours (including closures) are governed by the processes set out in the Ticketing and Settlement Agreement (
TSA▸ ) and guidance published by the Department for Transport (
DfT» ). Alongside, ORR has a long-term ongoing role in ensuring that passenger interests are protected in key areas, underpinned by licence requirements and consumer law. Under DfT’s guidance, any proposal to close a ticket office is considered to be a major change. Operators must publish details of their proposals, with passengers invited to make representations to Transport Focus (TF) and London TravelWatch (LTW). TF/LTW may then seek amendments to proposals from the operators. Should concerns remain they can raise an objection to the Secretary of State who will make a final decision.
Accessible Travel Policy review
All train and station operators must establish and comply with an ATP as a condition of their licence, setting out their provision for disabled passengers. ATPs must meet the detailed requirements set out in our guidance. While these requirements are particularly relevant to disabled people, such as the provision of assistance to travel, they can equally be applied more widely and, in this context, that includes requirements relating to ticketing and passenger information. The Annex extracts those aspects of the ATP guidance that are potentially relevant to changes to station staffing and ticket offices. To ensure that your ATP remains accurate for passengers and meets the requirements of the ATP guidance we are seeking an initial understanding of the areas where we believe that early engagement on changes will be helpful, including
where we can provide additional clarity or support in this process.
Your response should:
• Provide a high-level summary of the changes that you are proposing to make to ticket offices and station staffing.
• Identify any areas where you anticipate proposing changes to your ATP documents, and where possible outline what those changes would be.
• Identify any other changes that you propose to make at stations to ensure compliance with the ATP guidance, with particular reference to the areas identified in the Annex.
We do not expect to request or receive revised ATP documentation until there is more certainty over the changes that may be implemented. The process for revising ATPs will then follow the usual process. As part of this we will expect you to show how you have sought and considered feedback from local groups, and we will consult with DPTAC, Transport Focus and (where relevant) London TravelWatch where any material changes are proposed.
Please contact David Kimball (
david.kimball@orr.gov.uk) if you have any queries. We will be inviting operators to a meeting to clarify ATP requirements and the review process, and to offer the opportunity to explore any questions you may
have. Please submit your response to
ATP@orr.gov.uk by Friday 21 July.
I am copying this letter to
RDG‡, DfT, Transport Focus, and London TravelWatch.
Yours sincerely
Jacqui Russell