InterCity West Coast Consultation ~ Response from Campaign for Better Transport

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1 InterCity West Coast Consultation ~ Response from Campaign for Better Transport Introduction We welcome the opportunity to comment on the future of the InterCity West Coast franchise. Campaign for Better Transport s interest in this topic is primarily to ensure that we have a growing railway which takes a bigger share of passenger (and freight) journeys. Our view is that rail is an essential public service and should be planned and funded to meet public policy goals. In summary, our overarching views on the Government s revised franchise policy, which is first being applied to the new InterCity West Coast franchise, are: We note that the direction of travel is towards greater commercial freedom, and we are concerned that unless franchises have the right controls and incentives, train companies could be narrowly focussed on short term profit maximisation, rather than wider policy outcomes or on growing the market for rail. We were pleased to see that the revised policy acknowledges the need to specify socially necessary services such as off-peak train times and frequencies and certain station facilities in franchises. We are not convinced that longer franchises are in the best interests of passengers. There is no conclusive evidence about the impact of franchise length on performance. Competition through the bidding process is an important way of ensuring that franchises provide good value for money. Longer franchises are also not a precondition to greater private investment incentives and specifications are important as well, and the key issue here is the treatment of residual value for any investment made. In assessing bids, we believe that cost is currently given too high a priority. The franchise should be awarded on the basis of the best package of outputs for passengers and the environment achieved at the best cost. In practice, the difference between the highest and lowest bid is often relatively small, so quality comparisons are even more important to ensure value for money. We welcome the emphasis on a more qualitative approach to assessing passenger satisfaction. However, passenger opinion measures must not replace, but should be in addition to, deliverable outputs that can be concretely measured. In addition, we would like to comment in more detail on several areas relating to passenger experience, cost and investment and reducing environmental impact through rail with specific reference to the InterCity West Coast (ICWC) franchise. Fares: cost, complexity and value for money Expensive fares, a complex ticket structure and perceptions of poor value for money are significant challenges facing the rail industry. High fares are a barrier to modal shift towards the railway, and undermine the Government s aims of supporting the economy, reducing road congestion, cutting carbon dioxide emissions and improving social inclusion. Expensive rail fares also damage the UK s

2 competitiveness: some season tickets now cost the equivalent of a fifth of the average UK salary, 1 and commuting to London and other major UK cities is significantly more expensive than equivalent commuter journeys in Europe 2. Value for money has been identified by Passenger Focus research as the top area for improvement on four out of the five main routes on the current ICWC franchise. 3 To avoid pricing people off the railway and reversing the trend towards greater rail use, passengers must be protected. Sir Roy McNulty s Rail Value for Money study has identified potential cost savings of up to 1 billion per year from the rail industry. 4 We urge the Government to take forward these measures before pursuing further fare rises. The ticketing system is complex and appears unfair to passengers. Ticket restrictions are excessive and not transparent, resulting in seemingly disproportionate penalties. Lack of information about the cheapest available fares results in passengers assuming that rail travel is more costly than it is. Anomalies in the system mean that some people pay more than others for equivalent journeys. Collectively, this complexity causes confusion and lack of trust in the system, and is also a barrier to greater rail use. 5 Seventeen per cent of ICWC passengers are not confident that they are finding the right ticket to suit their needs. 6 Although we welcome the emphasis in the consultation document on improving understanding of available fare options, clear information can only go so far. It is the underlying problem of a highly complicated fare structure that needs addressing. The new ICWC franchise is therefore an opportunity to move towards more affordable fares and logical, transparent and fair ticket structures, through measures including: Allow Advance tickets to be bought right up to the train s departure from its originating station. Availability of cheap fares at the last minute could tap into new markets and increase revenue. To tackle the current high premium that must be paid for flexible travel, set the Off-Peak single price at 50% of the Off-Peak return, instead of 1 less as is the case currently. This would give passengers the opportunity to mix their use of train-specific Advance single tickets with more flexible options. Preserve the current facility which allows railcard holders to use discounted Off-Peak return tickets on any Virgin West Coast service in the new franchise. This is a much-valued scheme which helps to fill seats on peak trains which otherwise would be empty. Require the new ICWC operator to participate in multi-operator ticketing schemes, in regards to both new and existing products, and incentivise the roll-out of multi-modal smartcards across the franchise, which would help to boost rail use and revenue. Smartcards must not be used as part of a strategy to price off peak-time demand. Help part-time workers by introducing a smartcard based pro-rata annual season ticket, or a measure with equivalent benefit (eg. carnets of 10 for the price of 8 tickets for commuter routes). Allow passengers to pay the difference between what they have paid already for an Advance ticket and the appropriate new ticket if they miss their train or need to change their plans. Require that the cheapest ticket for a particular journey is clearly displayed and offered, and require that the through fare never exceeds the sum of walk-on fares for individual legs of the journey (except where a journey takes place partly at peak time and partly not). 1 Campaign for Better Transport, Train fares set to rise four times faster than wages, April Passenger Focus, Fares and Ticketing Study, February Passenger Focus, What passengers want from the ICWC franchise, February Sir Roy McNulty, Rail Value for Money Review: Interim Submission to Secretary of State, September Passenger Focus, Fares and Ticketing Study Final Report, February Passenger Focus, What passengers want from the ICWC franchise, February 2011

3 Incentivise the implementation of marketing strategies to target new passengers and increase rail use in general, and in less busy times and places specifically. Capacity and franchise investment Overcrowding is a serious problem on many parts of the ICWC franchise, and getting a seat ranks among the top three priority areas for improvement among ICWC passengers. 7 We welcome the Government s plans to measure overcrowding consistently across the rail network outside London, which will help to provide a complete picture of the problem for the first time. The specification for the new ICWC franchise should require that data on crowding is comprehensively measured (by automated counters and additional manual counts where necessary). The resulting data should be made publicly available and published by route, rather than as a single figure for the whole franchise. The consultation document indicates that Government will seek strategies to encourage the new ICWC franchisee to contribute a greater share of investment in the rail network, which is very welcome. More broadly, the Government s revised franchise policy statement suggested that much of the responsibility for tackling overcrowding would be transferred to train operators but with no new resources to help them do so. It is therefore unclear as to who will pay for much needed additional capacity. The fare-box must not be relied upon as the sole source of funds to pay for additional capacity and other improvements to the new ICWC franchise. Rail improvements bring benefits to non-users in terms of reduced congestion, pollution and other external costs, as well as wider economic benefits. Other countries have a wider range of mechanisms for capturing non-user benefits and this translates into lower fares and higher levels of investment. Equally, there is a concerning trend towards using unfair pricing mechanisms as a means of demand management, in both the ICWC consultation document and the Government s new franchise policy. The incumbent, for example, has proposed sharp price rises and the end of walk-on fares in favour of an advance booking only system as a means of addressing overcrowding on Friday evening services from London Euston. Preserving affordable walk-on fares is vital to allow passengers to take advantage of the high frequency of services available on many parts of the ICWC network. In any case, increasing already high peak fares in commuter markets will only succeed in shifting demand to the inter-peak if it is accompanied by policies to allow more flexible working patterns (something the Government is currently considering). However, the current work culture is heavily geared towards city-centre, 9-5 working patterns, and shifting these will be a slow process. In the meantime, increasing peak fares will simply price off demand, with wider consequences for the labour market and the economy, and will not have the effect of spreading the peak and reducing the requirements for increased capacity. Ultimately, pricing alone cannot deal with overcrowding, and additional capacity continues to be needed. The specification for the new ICWC franchise should therefore require the introduction of the full increment of 106 carriages (which must pass minimum standards for comfort and accessibility) to the timescale set out in HLOS. The successful bidder should also provide proposals to fund increased capacity to meet the demand that is expected during the franchise term without resorting to raising fares. Further innovative proposals should relate to the allocation of First Class seating; neither commuter nor long-distance passengers should face standing-room only conditions in Standard when First Class is empty or significantly under-used. 7 Passenger Focus, What passengers want from the ICWC franchise, February 2011

4 Service level and quality The consultation document refers to allowing reductions in mileage, frequency and other aspects of service levels during the franchise term if economic growth is slower than predicted. We are very concerned that provisions for such flexibility could allow socially necessary (but perhaps not profitable) services to be cut to make way for more lucrative routes. More broadly, frequently changing services are known to be much disliked by passengers, and do not help to challenge public perceptions of the unreliability of the railway. We are also not clear on how provisions for flexibility would work in practice: it would appear to require a double standard of flexibility that allows for improvements and not service cuts. Alternatively, frequent mid-franchise re-negotiations might be required, which would incur significant costs. Strong and precise specifications are therefore needed to protect the passenger services that have been contracted, and that the Government has paid for. We recommend that the new ICWC franchise include the following provisions: Frequency: Research by Passenger Focus shows that there is significant demand for earlier and later trains on the ICWC franchise, particularly at weekends. 8 First and last train times and minimum service frequency should therefore be contractualised, and should take account of latent demand and the possibilities for modal shift. Adequate frequency of evening and weekend services should also be included, to address changing travel patterns and support the move towards a 7-day railway. Performance: The PPM figure is currently only produced for the train company as a whole and is not broken down by route. This means that performance on a problematic route may be masked by better performance elsewhere. The new franchise should therefore require reporting of the percentage of trains arriving late at key intermediate stations, and the publishing of data by individual route so passengers can track the performance of their train. Compensation: Delay compensation should include additional protection for regular travellers, by lowering the threshold at which compensation must be paid for season ticket holders. Connections: The present performance regime encourages train operators not to hold connections by penalising them with fines if they do so. Holding connections provides more seamless journeys and allows rail to better compete with the car. Maximum waiting times for connections at calling points such as Stockport and Crewe should therefore be contractualised. Station Travel Plans: the specification should include a requirement to implement Station Travel Plans, as happened with the Southern franchise, in order to ensure that station access is treated holistically, and door-to-door journeys are improved. Localism and third party involvement It is often said that funding for rail must come from taxpayers or fare payers. In practice, third parties such as councils, developers, businesses, charities or other public bodies have been prepared to fund rail services, facilities and developments. We therefore welcome the recognition in the consultation document that the new franchisee must work closely with local transport authorities and Passenger Transport Executives, which will make local services more relevant to community needs and integrate the franchise more strongly with local and 8 Passenger Focus, What passengers want from the ICWC franchise, February 2011

5 regional transport. We would also like to see PTEs and other local transport authorities as co-signatories to the franchise, as happened in the past. In addition, we believe the new ICWC franchise would benefit from: Incentivising operators to work in partnership with third parties to develop stations and other services and facilities. Including formal mechanisms to include community views in the next stages of specifying and assessing the ICWC franchise bid. The role that Passenger Focus has been given in the new franchising regime is very welcome, and we encourage Government to implement Passenger Focus recommendations, which are currently the only way passengers have a voice in this process. We would also like to see a greater role for Community Rail Partnerships and/or rail user groups. Being linked to region-wide planning for integrated public transport, as well as any regional restructuring of Network Rail. Reducing environmental impacts through rail Rail is the low carbon option and the ICWC franchise should include the objective of modal shift in order to achieve environmental and social goals. This requires specifying fares and service levels that will encourage such modal shift. Shifting freight from road to rail is also essential in reducing environmental impact, and should also be a key objective of the new franchise. The West Coast Main Line is the most important rail freight route in the country and there are strong growth forecasts particularly in the deep sea and domestic intermodal sectors. Growth in freight services must therefore be planned alongside passenger services. Unless freight access, and reserved capacity to allow for growth, is included in the franchise agreement, there is a danger of freight taking a low priority behind local and long distance passenger services in planning and investment. This has broader implications for road congestion, environment and other issues which need to be considered. The opening of HS2 will provide welcome released capacity on the West Coast Main Line, and the successful bidder should include proposals as to how this capacity could be best used for wider benefits such as cutting carbon through modal shift for passengers and freight. Although we believe that reducing the environmental impact of railway activities is secondary in terms of overall environmental benefit to encouraging passenger and freight modal shift, we welcome the plans to require environmental impact reduction strategies that are suggested in the consultation document, and encourage these to be contractualised: Monitor and publish annually the overall environmental performance of the franchise. Set targets for improving the environmental performance of the franchise, including traction and non-traction CO2 emissions, waste generation, recycling, water consumption and other environmental impacts. Reduce non-traction electricity consumption within the life of the franchise.

6 April 2011 Alexandra Woodsworth Campaign for Better Transport Campaign for Better Transport is the leading transport NGO. Our compelling arguments and ideas have won us the support of national decision-makers and local activists, enabling us to secure transport policies and programmes that improve people s lives and reduce environmental impact. 16 Waterside, Wharf Road, London N1 7UX Registered Charity Company limited by guarantee, registered in England and Wales: