Memorandum by Central Rail Users Consultative
Committee (IT 59)
INTEGRATED TRANSPORT WHITE PAPER
The Central Rail Users' Consultative Committee
(CRUCC) welcomes the opportunity to submit written evidence to
the Environment, Transport and Regional Affairs Committee on this
topic of crucial importance. The CRUCC has sought the views of
the Rail Users' Consultative Committees (RUCCs), the London Regional
Passengers' Committee and of its own independent members in drawing
up this response. While a range of views is inevitably expressed,
the present memorandum seeks to balance the views put forward
by the various contributors. For sake of completeness, copies
of the individual written submissions are appended for reference
at Appendix 1.
We note with considerable pleasure the gratifying
comments regarding the Committees, made in the White Paper, which
we consider recognition of the tireless campaigning on behalf
of rail users that has been the hallmark of our work for 50 years.
The CRUCC is gravely concerned that, given the
urgent need for integration of public transport, recent rumours
suggest that other commitments may delay the presentation of the
necessary Bill to Parliament and would urge that this matter be
given urgent priority.
The CRUCC submitted written evidence last year
to the Environment, Transport and the Regional Affairs Committee's
inquiry into the proposed Strategic Rail Authority (SRA) and Rail
Regulation and also gave oral evidence later in the year.
The resources available to the CRUCC and RUCCs,
both in terms of accommodation, staff and facilities, are reaching
breaking point and are inadequate to deal even with the current
workload, which has increased dramatically since the restructuring
of the industry. The need to liaise with the number of rail organisations,
(OPRAF, ORR, train operators, Railtrack etc.) coupled with a radical
increase in workload (monitoring performance of operators, consultation
on fares, charges and timetables, handling complaints which have
increased four-fold in the last few years and which continue to
increase at an alarming rate) is exerting unsustainable pressure
on the Committees, in terms of both staff and members. The requirement
for the Committees to become involved with other modes of transport
will further add to our workload, putting an unbearable strain
on existing resources; quite simply, the Committees will not be
able to carry out their statutory duties. It is imperative that
CRUCC and RUCC facilities in addition to staffing and membership
levels are reviewed to take this into account, especially in view
of the increased powers which it is proposed the Committees should
have. The question of whether it is realistic for RUCC members
to remain unpaid and the current level of remuneration of Chairmen
should also be reviewed, given the current tremendous increase
In order for the passenger's voice to be heard
at the highest level, the Committee network will need to be represented
on the board of the SRA. At least one senior RUCC representative
should be able to sit on the SRA Board without compromising the
Committee network's independence. The CRUCC and RUCC role of representing
passengers' interests cannot be compromised. The right
of the Committee network to retain all aspects of current policy
independence from its sponsoring department is absolutely paramount.
This needs to be enshrined in legislation.
The Committee network particularly welcomes
the greater prominence for the views of rail users and the protection
of passengers' interests which the creation of the SRA should
bring. The Committees' powers need to be strengthened so that
they can refer to the SRA perceived breaches of franchise agreements
rather than only breaches of passenger and station licences. Indeed,
the Committees would press for their powers to be strengthened
to encompass, inter alia, amendments to franchise agreements,
franchise extensions, and Passenger Service Requirement changes.
We anticipate that with strengthened powers and an adequate level
of funding our effectiveness in defending and enhancing passengers'
interests will escalate significantly.
The extension of the Committee network's remit
to include open-access operators will extend the protection offered
by the CRUCC and RUCCs to all rail passengers, for which we lobbied
hard, but unsuccessfully, during the passage of the Railways Bill.
It is important for all passengers to have statutory rights, irrespective
of service provider. There is a lack of consistency at present
as to whether users of light rail services can benefit from the
Committees' statutory protection; all light rail schemes should
fall under the Committee network's remit.
The Committees suffer from the lack of readily-available,
timely and affordable legal advice, a situation which needs to
be remedied if the Committees' powers are to be enhanced to enable
them to act as passengers' champions.
The requirement to co-operate with bus user
representative bodies such as the National Bus Users' Federation
and to contribute jointly to the development of regional transport
strategies, which will form part of Regional Planning Guidance,
makes sense, although potential difficulties could arise in that
the CRUCC and RUCC are statutory bodies, whereas bus user groups
are not. Such new conduits of liaison cannot, however, operate
without substantial increase of Committee resources. Some Traffic
Commissioners, while not statutorily required to do so, do represent
passengers' interests; there is a need to ensure that there is
no duplication of effort. It needs to be recognised that few rail
users are entirely dependent on that mode; most need some other
form of feeder transport to/from the station. Many PTEs also have
bus user organisations and there are numerous independent bus
user groups. At this stage, it is not at all clear how these various
bodies will function without the danger of overlapping responsibilities.
It seems sensible to ensure from the outset, that identical schemes
are available throughout the country. There may well be scope
for the RUCCs to work at a strategic level in conjunction with
bus user bodies which the Regional Development Agencies may establish.
We look forward to discussing with government
our future role, our term of reference and the implications that
these will have.
The SRA needs to be adequately funded to ensure
that it can deliver schemes which make a significant impact. The
£300 million additional investment to relieve congestion
on the busiest stretches of the railway network, while welcome,
is too small, given the scale of the task. The source of the £300
million investment is unclear; this needs to be new money, not
syphoned from elsewhere in the overall railway support budget.
The SRA's capital budget needs to be sufficient to enable it to
embark on more than a few minor projects at any one time.
The Committees welcome the White Paper's aim
to provide a level playing field between road and public transport
users. However, real incentives to switch to public transport
need to be in place in the form of safe, reliable, affordable
and frequent services before penalties for road users are introduced.
Parking at "parkway"-style stations should for example
be free of charge.
There is also a need to recognise that there
may be occasions where the RUCCs and the bus users' representatives
cannot find common ground. The need to represent the interests
of the users of each mode of public transport must be retained
and harmonised where possible. Certainly co-operation between
bus and rail modes should improve interchange arrangements.
ORR should remain as a separate organisation,
to regulate infrastructure and to oversee the ROSCOs. The Committee
endorses the view that the Regulator needs to reach agreement
with the rolling stock leasing companies. It was a major flaw
in the Railways Act that the ROSCOs are subject to no regulation
and the opportunity to rectify this omission is welcome and overdue.
The Committee has long campaigned for an improved
telephone enquiry service with a lo-call number and its persistence
finally paid off with the creation of the National Rail Enquiry
Service. However, we see this merely as a first stage to a nationwide
multi-modal public transport information system, capable of one-stop
shopping, from enquiry to ticket issue in a single transaction.
As statutory responsibility for the production of the Great Britain
Passenger rail Timetable lies with Railtrack, that organisation
may be best placed to develop an integrated bus and rail timetable.
The creation of new investment funds is welcome.
There is scope for fines imposed on rail operators for poor service
to be channelled into such pools rather than returning to the
Treasury. This would ensure that funds originally earmarked for
rail services are spent within the industry. Five-year planning,
covering all forms of transport, and starting in the financial
years 2000-01 to 2004-05, should provide sufficient breadth of
vision for the future and break the mould of traditional government
The requirement for local authorities to develop
local transport strategies, and be required to consult with the
Committees, is welcome and logical, although will add considerably
to the burden already borne by the RUCC network. Indeed, an extension
of the successful PTEs concept has been put forward by the Committees
on a number of occasions and is repeated again here. Public transport
needs to be improved to encourage use; only then are drivers likely
to accept work-place car park fees and road charges. Making public
transport accessible, affordable and safe is the only means by
which passengers will be encouraged to spurn their cars. Tackling
crime in the transport system needs a high priority. However safe
public transport may actually be, public perception is not in
line with it. The SRA should act as the catalyst to promote greater
multi-modal public transport usage together with measures to encourage
cycling to/from stations.
The CRUCC and RUCCs are concerned that access
by public transport to railway stations is generally poor and
made more difficult as few buses are wheelchair-accessible. Sight
should also not be lost of the need to improve pedestrian access
to railway stations, which are geared primarily to rubber-tyred
In the Committee network's view, the requirement
for the Highways Agency and Railtrack to co-operate can only bring
benefits to both organisations and their users.
The sale of land belonging to the British Railways
Board has already been suspended to determine whether any might
be of potential value to the passenger or freight railway. The
CRUCC and RUCCs have long expressed concern that the piecemeal
sale of parcels of land could, in the longer term, jeopardise
train operators' or Railtrack's ability to enhance facilities
for rail users, for example, increased car-parking facilities
In respect of the proposal for RUCC reports
on public hearings into rail closures to go direct to the Secretary
of State for independent decision, the Committee believes that
this will limit the means of appeal if its recommendations are
not accepted. The Committee would rather recommend a two-stage
mechanism, retaining the right of appeal to the Secretary of State.
The Committee network welcomes Government's
decision to consider franchise extensions but the franchisee must
be able to prove that such an extension will be of benefit to
the passenger. When franchises are re-let there needs to be a
public hearing allowing passengers and their representatives,
the CRUCC and the RUCCs, the opportunity to comment on the appropriateness
of franchise bids, in the light of their experience. There should
e a guarantee that the RUCCs are consulted within a meaningful
timescale prior to renewal or changes to franchise agreements
and franchise commitments.
More demanding targets are required for some
operators together with stiffer penalties for those who fail to
meet them. Operators need to be held to account for the level
of service which they provide. Where the opportunity arises, new
terms need to be negotiated with operators to put an end to the
capricious nature of those performance incentive regimes which
still result in poorly-performing companies receiving bonus subsidy
payments. Fines levied for poor performance should be redirected
into the investment fund pool to keep the money within the industry,
as mentioned above.
The SRA should be able to step in and terminate
any franchise where the operator consistently puts in a poor performance
and where not significant improvement is likely. If no alternative
franchise operator is available, the Government must take responsibility
for ensuring that a satisfactory rail service continues to operate.
While Railtrack may be investing at a higher
level than at any previous time, in view of the backlog that needs
to be addressed, it is still insufficient to match passengers'
and operators' demands. The Committee would also welcome a review
of the access charges as we have concerns that the present charging
regime may be inhibiting the development of new services. Benchmarks
with timescales need to be set for levels of investment throughout
In performing OPRAF's current role, Government
needs to consider carefully the level of funding available to
SRA to subsidise services after the first term of franchises.
It remains to be seen how well in reality TOCs manage to deal
with reducing levels of subsidy.
No mention is made of how enhancements to the
current rail passenger network may be effected. A mechanism needs
to be put in place to kick-start expansion of the network: new
stations, line re-openings and so on.
The Committee network considers it negative
thinking to accept that there is little scope for controlling
currently unregulated fares. Greater clarity of the fares structure
is required to make it more comprehensible to passengers. The
threat of "windfall taxes" on profits of train operators
which abuse market position and power should be sufficient deterrent
to bring about voluntary controls. The Committees would also advocate
a commitment to more integrated ticket schemes in the style of
the London Travelcard.
We are concerned at the lack of policy detail
in the White Paper and look forward to being consulted on the
proposals in due course. As the only organisation with the express
purpose of representing rail passengers' interests the Committee
network is in a unique position, following its 50 years' experience,
to make an invaluable contribution in this crucial area.
25 September 1998