Ticket Office Closure Consultation

[whole diary]

[Western Pathfinder]

https://www.transportfocus.org.uk/about/transparency-and-accountability/board-meetings/
This is happening in Bristol today if it is of any interest.

[grahame]

https://www.transportfocus.org.uk/about/transparency-and-accountability/board-meetings/
This is happening in Bristol today if it is of any interest.

I was there ... much more that just the ticket consultation.   Writeup to follow

[ChrisB]

While we await Graham's  precis of the recent Transport Focus Board Meetng, here's a round up to keep us going on the consultation....

In that Grauniad article posted up-thread, this paragraph caught my eye that wasn't in the Mirror article I posted -

[Andy] "Burnham said the “rushed” consultation “should be declared null and void”, adding: “Section 29 of the Railways Act 2005 sets out a very clear and detailed process which must be followed if a train operating company proposes to close a station or any part of a station. That process has simply not been followed in this instance. It requires a 12-week consultation.”

Anyone care to up on that Section 29? Stuving? What else does it say after the required *12* week consultation?

Also, AND....another legal challenge gone in today by Doug Paulley, a disabled traveller & campaigner -

https://www.leighday.co.uk/news/news/2023-news/disabled-people-launch-legal-challenge-to-consultation-over-planned-closure-of-rail-ticket-offices/

Disabled people launch legal challenge to consultation over planned closure of rail ticket offices
Disabled people launch legal challenge to consultation over planned closure of rail ticket offices
Two disabled rail users have launched a legal challenge to the rail industry’s consultation on planned closure of hundreds of rail ticket offices across England over the next three years.

Regular rail travellers Sarah Leadbetter, who is registered blind, and Doug Paulley, a wheelchair user who has hearing loss, claim that the consultation is unlawful and discriminates against disabled people.

They argue giving people just 21 days to respond to some of the biggest changes to railway operations for a generation is inadequate and breaches legal requirements for such consultations. They also say the format of the consultation is inaccessible to many disabled people and lacks information about how the changes may affect them. This means disabled people, who often rely on ticket offices for assistance, may not have their views heard equally.

The pair, who are represented by law firm Leigh Day, are calling for the four publicly owned Train Operating Companies (TOCs^▸ (Train Operating Company)), and the Transport Secretary, to end the current consultation process and reconsult in a manner which complies with his consultation and equality duties. Their consultations form part of a concerted move by all TOCs within England who run stations to consult upon proposals which, if adopted, would see rail ticket offices being closed in almost every single rail station in the country.

Specifically, they argue that the consultation is unlawful because:

• It should have been carried out when the proposals are still at formative stage. However, the decision to close ticket offices appears to have already been taken given statutory redundancy notices have already been issued to staff.

• There are multiple, serious flaws with the consultation related to accessibility which mean disabled people will not be able to understand the impact of the proposals or provide a meaningful response.

• The time period of 21 days falls far short of what is required to properly consider and respond to these complex and far-reaching proposals; even more so for disabled people given the accessibility issues described above.

• The Defendants have failed to take any steps to avoid or reduce this disadvantage such as extending the consultation period, providing readily accessible alternative formats and proactively consulting with organisations representing disabled people.

• The proposals have been on the table for a significant period of time: there is no reason why the short consultation period could not be extended, and the process adjusted in the manner set out above to ensure it is accessible to all members of the public.

• The consultation process does not eliminate discrimination or advance equality of opportunity for disabled people for the reasons set out above.

Wheelchair user, Doug Paulley said:

“The presence of dependable rail staff is incredibly important for disabled people, including me, who use our often inaccessible railways. The cuts are a fait accompli being pushed through the motions of this sham consultation, with its disingenuous claims and failure to give disabled people the information we need to respond properly. It is appalling that such an important topic is being handled in this manner and the process must be stopped.”

Registered blind rail user, Sarah Leadbetter said:

“People like me, with visual impairments, rely on ticket offices and their staff to help us when we’re travelling and their closure will be a huge blow. To hold a consultation that fails to properly hear the views of those who need assistance the most is woefully inadequate. The government should scrap this unfair process and come up one that gives rail passengers with disabilities an equal say.”

Kate Egerton, senior associate at Leigh Day, added:

“The rail industry’s consultation on the plans to close railway ticket offices across the country, which is overseen by the Department for Transport, is, in our view, clearly unlawful and not fit for purpose. Not only does it fail to provide adequate time for people to respond to one of the biggest changes to our railway network in a generation, it denies a voice to disabled people who rely on ticket office staff for assistance when they travel. The Transport Secretary must now end this inadequate consultation and replace it with a fair process that considers the views of all rail users.”

It's not all over yet....

However, the Government has recently responded in writing to the petition on their website (now still only 54,000 signatures!!)

There has been a significant shift in the way passengers purchase tickets, with just one in every ten transactions taking place at a ticket office in 2022/23, down from one in three a decade earlier. 99% of all transactions made at ticket offices last year could be made at TVMs^▸ (Ticket Vending Machine) or online.

Together with the rail industry, we want to improve and modernise the experience for passengers by moving staff out from behind the ticket office screens to provide more help and advice in customer-focused roles. We have been clear that no currently staffed station will become unstaffed as a result of this reform.

These reforms will bring our stations in tune with what customers expect from other, modern and responsive services, including supermarkets and banks, where customer assistants help with information, support and making digital transactions on the shop floor. To propose any changes to the opening hours of a station ticket office, or to propose its closure, train operating companies must follow the longstanding process set out in the Ticketing and Settlement Agreement (TSA^▸ (Ticketing and Settlement Agreement.)).

Train operators must consult on any proposed changes, advertising them at the relevant stations and inviting members of the public who wish to comment on the proposal to write to the relevant passenger body (Transport Focus or London TravelWatch) within a 21-day public consultation period.

Under the Ticketing and Settlement Agreement, when proposing major changes to ticket office opening hours (including closures) operators are required to take into account the adequacy of the proposed alternatives in relation to the needs of passengers who are disabled, and to include this in the notice of the proposal sent to other operators and passenger groups. We would also expect operators to consider other equality-related needs, and to make this clear in their consultation.

Department for Transport

[stuving]

What does Section 29 of the Railways Act 2005 say? Hard to tell  - at least the relevant bit, which is:
 

(a)  the operator of a station proposes to discontinue the use of a station or of some part of it;

  (b)  the station or, as the case may be, that part of it has, at any time within the preceding five years, been used for or in connection with the provision of services for the carriage of passengers by railway;

  (c)  the station or that part of it is not secured;

  (d)  the station or that part of it is not excluded from the application of this section by an order under section 38; and

  (e)  the proposal is not a proposal for a minor modification.

Even with a professional-grade stringometer it's not clear if a ticket office is "some part of" a station within the meaning of the act.

But if the act does apply, the sequence of events is that the operator does an assessment (not a consultation, though nothing stops them doing one of those if the want to), and then:

(3)  The operator must give notice to the national authority setting out—

  (a)  particulars of the proposal for the closure in question; and

  (b)  a summary of the results of the assessment carried out in accordance with subsection (5).

In England the national authority is DfT^» (Department for Transport - about) (in the name of the SoS).

(7)  If the national authority forms the opinion that the closure should be allowed, it must—

  (a)  carry out a consultation under Schedule 7 about the proposal; and

  (b)  after carrying out that consultation, either notify the operator that it has changed its opinion or refer the proposal (with or without modifications) to the Office of Rail and Road.

So that complaint is right if the act applies in this way - but has it been applied to previous ticket office closures?

[grahame]

https://www.transportfocus.org.uk/about/transparency-and-accountability/board-meetings/
This is happening in Bristol today if it is of any interest.

I was there ... much more that just the ticket consultation.   Writeup to follow

Transport Focus / board meeting in public yesterday, at the Watershed in Bristol. Chrair, Nigel Stevens.  Just over a dozen on the head table, including key speakers, and a couple of dozen stakeholders in the audience in person. "Stakeholders" is a wide definitions and it was good to see that at least it included a light sprinkling of passenger gurus.  When seeing the "in person" audience, I realise just how honoured I was to be there.  But I do note that there could well have been a massive audience out these online.  Anyway - a wonderful chance to network - to catch up with long term contacts, and to make new ones, and a wonderful chance to listen and understand where Transport Focus, speakers, and other contacts are coming from.  I took some 9 sided of notes (and a further two at an electric bus online session from Platform 14 afterwards) and I will attempt to write some of them up today.

Nigel started "Let's address the elephant in the room so that it doesn't take over the whole day" and that's the current Ticket Office Closure proposal and consultation. Mike Hewitson for Transport Focus spoke and I quote as best I can from notes:

"This is not a process of our design, but one written into [statue named] that we are charged with following for England outside the wider London area, where TravelWatch London have the same reponsibilty.

"We have 21 days from the announcment of the consultations to take public inputs on individual station proposals and those 21 days end on 26th July. We then have a further period during which to analyse the inputs on a station by station basis.

"If we object station by station, we can / will raise that with the station opertor concerned with there being three potential outcomes:
a) The operator can withdraw the proposal
b) We can negotiate with the operator an come up with a compromise [I was not sure if that compromise triggers a further consultation]
c) If there is no agreement between TF and operator, it goes to the Secertary of State for a decision

"In considering inputs we will be considering future
* Ease of use
* Provision of assitance
* Information availability
* Penalty Fare / system handling
* Use of other station facilities "
- And I think I noted them all, but may have missed someting

I also had an opportunity to discuss this issue with Nigel (actually ahead of the meeting), and to listen to a couple of questions that concern others who wrote in the online chat and a lady who spoke from the floor. 

For this follow up, I am not going to add personal opinion or analysis - I'm leaving it just for an hour or two as a personal log in the character of a minute of the meeting.   I will also follow up elsewhere with a summary of some other speakers relevant to us, including Mark Hopwood of GWR^▸ (Great Western Railway) and Marcus Jones of Network Rail.

[ChrisB]

There's a typo in the quote - you mean "statute", not 'statue'.

Also, in answer to your question in b), no - no further consultation, just pings back & forth until stalemate or they reach the deadline without agreeing on a time extension

[Sixty3Closure]

Just to add my recent personal experience I had to travel from Carmarthen to Cardiff and use the ticket machine. Ticket office was open but she was on a cigarette break and in no rush to come back 

The machines in Carmarthen were a lot smaller than the ones I was used to in Thames Valley and there weren't a lot of options. There was also no information that I could find about the limitations on the tickets available. There was a button that said 'buy cheapest ticket' but it didn't say what that was or which trains it was valid on. As I was coming back about 4PM I went for the open return which was probably the most expensive option.

Bit frustrating and I (perhaps unwarranted)consider myself reasonably familiar with tickets and technology but I would have appreciated the ticket office at that point. I'm not across all the different types of machines but these ones seemed quite limited.

Next time I guess I'll order online....

[TaplowGreen]

Mark Hopwood's view from tonight's "Meet the Manager" on the issue is interesting;

My key points are that (a) we have to reduce our costs, (b) customers themselves are buying more and more tickets online, (c) other businesses have adapted to the new world of digital commerce and the railway must too. But I want to listen to what is said and I think the wider industry will too.

[PhilWakely]

Just to add my recent personal experience I had to travel from Carmarthen to Cardiff and use the ticket machine. Ticket office was open but she was on a cigarette break and in no rush to come back 
Next time I guess I'll order online....

As a example, Totnes is a single-staffed ticket office, open from 07:25 to 16:10. Allowing for pre-opening and post-closing tasks makes for a 9 hour plus day for that member of staff. The staff member is obviously entitled to a break. I have been sat in the ticket hall when that member of staff has closed the window blind and is enjoying a well-earned lunch in the Signal Box Cafe. You would be surprised at the number of customers who knock on the window demanding to be served!

[onthecushions]

I've sent in my response as follows, for what it's worth:

Dear Sirs,

I  have been a regular user of the railway for both business and pleasure all my life, commuting for 36 years to London.

I wish to object most strongly to the blanket closure of ticket offices which will preclude me and my family from making many journeys and also prevent many others from using the railway whose needs cannot be met by the internet or the ticket machine.

I appreciate that much wider use is made of electronic tickets now and that this reduces the need for the number of counters, however it does not eliminate it. I watched the counters at Reading Station last Sunday, while waiting for a visitor's arrival. There were perhaps only two counters in use but still with a queue while the machines were rarely used. This was because the counter enquiries were complex needing perhaps 5 minutes to resolve, incapable of being answered by a FAQ^▸ (Frequently Asked Questions) menu.

An intelligent response to the change in ticket patterns would be driven by customer demand. While this would probably allow the closure of some ticket offices (I believe 43% of stations are presently unstaffed), it would require alternative provision in on board advice and sales or payment at destination (assuming an open ticket office). It would also require the end of the Penalty Fare system as many more passengers would have no or incorrect tickets without intent to avoid payment. It would not justify ever, the closure of some ticket offices at main points of departure and arrival.

Reading General is one of the busiest stations in the country and total closure is a most preposterous idea, clearly the product of an ill-informed imagination, driven only by a balance sheet and whose travel experience is limited to LUL^▸ (London Underground Ltd)'s Zone 1. What is the point of spending £850M on a new station at Reading if the ticket office cannot be staffed?

I appreciate that the railway is in a precarious situation financially but this is due to the large payments to finance houses, both by Network rail and by the TOC^▸ (Train Operating Company)'s (because of the silly belief that new rolling stock will be cheaper than existing non life-expired trains). Attacking staffing that supports customer service will not address the reasons for the railways' losses and will only reduce earned income and hence increase deficits disproportionately.

It is disappointing that so low a value is placed on customer service, though not I imagine by the TOC.

Yours faithfully,

OTC

[old original]

Front page of the Daily Mirror (via BBC^» (British Broadcasting Corporation - home page) website) reporting a possible delay

https://www.bbc.co.uk/news/blogs-the-papers-66308660

[grahame]

Front page of the Daily Mirror (via BBC^» (British Broadcasting Corporation - home page) website) reporting a possible delay

https://www.bbc.co.uk/news/blogs-the-papers-66308660

https://www.mirror.co.uk/news/politics/train-ticket-office-cull-chaos-30552780

EXCLUSIVE: Train ticket office cull in CHAOS as crisis talks over closures could last until September

Ministers and train companies have been spooked over legal challenges to how the process has been conducted, amid claims that the 21 day consultation was too short and unlawful

[Timmer]

EXCLUSIVE: Train ticket office cull in CHAOS as crisis talks over closures could last until September

Ministers and train companies have been spooked over legal challenges to how the process has been conducted, amid claims that the 21 day consultation was too short and unlawful

Well what did they expect? Everyone to say fine, good idea, get on and close them all? 

[old original]

Consultation period extended to 1st September

https://www.bbc.co.uk/news/business-66311238

[grahame]

Consultation period extended to 1st September

https://www.bbc.co.uk/news/business-66311238

Classic!

The consultation into the plan to close hundreds of ticket offices in England has been extended until 1 September.

Organisers of the consultation said some train companies did not provide accessible formats, preventing people from being able to respond to plans.

More than 170,000 responses have been received according to watchdogs Transport Focus and London TravelWatch.

Three weeks was indecent haste.   Another month gives anyone who's not yet responded to make a more measured (and better consulted within their communities) input.