Memorandum from Passenger Focus (TPT 36)
INTRODUCTION
1.1 Passenger Focus[34],
the independent national rail consumer watchdog, welcomes the
opportunity to respond to the Committee's investigation into aspects
of ticketing, many of which have long been a source of concern
to us and our predecessor organisations. Given our remit, we have
largely restricted our response to rail matters, though this has
been exceeded in certain cases of readily available through ticketing
between rail and other modes.
1.2 We recognise the benefits which integrated
ticketing can provide for passengers and want such through-fare
and inter-modal options enhanced and extended. Their efficacy
in the conurbations is proven and the same flexibility should
not be denied to passengers elsewhere.
1.3 Responses to many questions have been
amalgamated where there is a cross-over between question themes
and to avoid repetition in the response.
INTEGRATED TICKETING
Q1: Is ticketing sufficiently integrated
across different modes of transport and between different geographical
areas?
Q2: Does the Government have an adequate
strategy for developing the integration of ticketing systems?
2.1 Several types of integrated ticketing
already apply:
— "Travelcard" and similar
schemes which allow an unlimited number of journeys by all modes
and operators covered by the scheme within a certain area or zone(s);
— interavailable and through ticketing,
as stipulated in franchise agreements and required of open-access
operators, between any two rail stations by any number of train
operators on "permitted routes";
— PlusBus—add-on to rail tickets
allowing a day's unlimited bus travel at origin or destination;
and
— through ticketing involving other
operators; eg for the sea element to the Isle of Wight; where
the through fare, however, undercuts each individual element if
purchased independently.
2.2 These schemes illustrate that such integration
is possible. However, "travelcard"-type deals are usually
available only in metropolitan areas and are usually negotiated
by or purchased by the local authority rather than stemming from
an initiative of the transport undertakings involved. They are
usually subsidised by the local authorities and a cliff-face fares
increase can occur at the boundary stations of such schemes—even
where two Passenger Transport Executive (PTE) areas abut. [35]
2.3 The provision of products such as multi-modal
and/or multi-operator travelcards, however, is dependent upon
block exemptions to avoid infringement of competition law. (The
range of names for such tickets, which largely fulfil the same
function, is in itself a source for confusion: eg Travelcard
in London; MetroCard in West Yorkshire; Travelmaster
in South Yorkshire; Trio in Merseyside; System One
in Manchester; Zone Card in Strathclyde.)
2.4 As a result, large areas of the country—even
where rail or bus, or choice of bus companies, are viable options
for some journeys—are without such a scheme. Many passengers
may thus have to pay considerably more to enjoy the flexibility
which urban users take for granted. In any case, co-operation
between operators may well be deemed anti-competitive collusion.
Despite a clear passenger benefit in being able to use the same
ticket on the service of any operator or mode, according to choice
and convenience, especially on the homeward leg of return tickets
or if one mode is disrupted or delayed, such activity is interpreted
as anti-competitive and against the public interest.
2.5 PlusBus, despite more imaginative marketing
of late, is still relatively unknown to passengers and even to
some members of staff. A much more aggressive campaign is required
to increase patronage of the scheme. We welcome stations' improved
and expanded displays of connecting bus and/or tram information
and signage to the stops and trust that this will be built upon
to further publicise the service.
2.6 Many rail and bus interchanges are poor
or non-existent, and many rail stations are poorly served by bus
services. We have made recommendations to improve this situation
in our report[36]
aimed at offering practical advice on deliverable rail strategies
to those local transport authorities then in the process of preparing
their second local transport plans, supplementing the Department
for Transport's guidance but emphasising the rail element.
2.7 Integrated ticketing requires integrated
planning and transport provision to enable passengers to plan
and execute a seamless journey. We welcome the fact that although
through tickets can be booked from rail stations to destinations
such as those on the Nexus metro system[37],
no connecting train information is available through the National
Rail Enquiries website. Neither does the website yet offer PlusBus
options, as this add-on has to be specifically sought out by those
in the know. Transport Direct[38]
is a step in the right direction, but at times the system is unhelpful.
TOCs still fail to fully promote their own wares to best advantage,
and therefore a major change in approach is needed to encompass
integrated ticketing. Integrated information and purpose-built
interchanges are crucial to popularise intermodal travel. The
Government needs to play a role in joining services up.
2.8 While with PlusBus, the add-on cost
is available at the time of purchase and previous enquiry, it
is difficult to discover bus fares for one-off journeys in much
of the country through existing media—it can prove awkward
to discover which company operates which route, especially in
an area with which the enquirer is unfamiliar. The disparate fare
levels, doubtless reflecting presence or absence of local subsidy,
further add to confusion and further impede inter-modal ticketing
outside the metropoli.
2.9 The size of the United Kingdom militates
against the likelihood of the introduction of a zonal-based national
ticketing structure such as operates in the Netherlands. There
travel by any mode (rail, urban bus or tram, local train or metro)
can be prepaid by purchasing any one of a range of "strip
tickets".[39]
The absence of a common fare structure (not only on rail but also
on other modes) in Britain makes such a scheme virtually impossible
to implement at an attractive fare. The Swiss transport system
is generally held to be the most integrated with through fares
and ticketing and easy-to-find information across all modes: long-distance,
local and regional rail; trams; local and longer-distance buses;
boats; cable-cars and funiculars—with virtually all transport
undertakings willing to participate in the scheme.
2.10 At present, government's strategy towards
integrated ticketing is not immediately apparent, save for the
move toward smartcard technology in recent franchises. There appears
to be no drive towards the creation of additional PTE-type arrangements.
2.11 Until such time as all the relevant
journey validity details can be contained on the ticket[40],
in its various likely formats, there is no real hope of fully
integrated ticketing. No amount of through fares/ticketing will
succeed without adequate publicity of what is on offer.
2.12 Payment by all common methods needs
to be available: no buses accept credit/debit cards, despite the
often high fares for longer journeys. No buses can issue the outward
PlusBus deals, which have to be booked at stations or aboard the
train.
2.13 Despite all the improvements in integration
in London and the South East culminating in the recent introduction
of National Rail zonal fares, it is still not possible to buy
a through ticket from an Underground station to a destination
outside London; eg for a journey from Tooting Broadway to Dartford,
the passenger will need to rebook en route to avoid being charged
a penalty fare.
THE USE
OF SMARTCARD
TECHNOLOGIES
Q3: Is the industry taking up smartcard technologies
adequately and appropriately?
3.1 This strategy is barely in its infancy.
We welcome the extension of the benefits of smartcard technology
to National Rail passengers in the South East, but regret the
failure to install Oyster readers at National Rail stations in
Greater London to coincide with deployment by London Underground.
If the franchising process is expected to deliver smartcard technology
across the entire National Rail network, it could take decades
to achieve nationwide coverage.
3.2 Stored value cards are best suited for
payment for urban short-distance "low-value" journeys;
their applicability for longer journeys is open to some question,
though we welcome the decision to extend the scheme to South West
Trains. We have some concerns that the level of fares for long-distance
travel by National Rail will far exceed the level which passengers
are likely to want to load up in advance. London zonal fares are
all below £10 and can be checked in advance—though
the TfL website cannot at present calculate fares from Underground
stations to National Rail destinations, even within the six zones.
Is it probable that passengers would be willing to load the level
of credit necessary to finance a journey such as London to Derby,
where the fare may not be known? The propensity for touching in
and out on such long-distance journeys must be more limited than
on urban local journeys.
3.3 Beyond smartcard, other media may well
take the place of traditional paper-based tickets. Ticketing by
SMS message is already a reality and more sophisticated use of
this medium is in course of trial. We welcome the harnessing of
technology to simplify travel arrangements for passengers who
are comfortable and conversant with such methods - and provided
that passengers without access to the required gadgetry are not
disadvantaged.
Q4: Does the ITSO system cater for the needs
of all passengers and travel providers?
Q5: What can be learned from the experiences
of areas such as London and Scotland where smartcard technology
is already in place?
3.4. ITSO is not in itself a ticket-recognition
system, but is rather the philosophy underlying inter-operability
and prepayment. Few such systems are yet in operation. The most
vital element is to ensure that when operators install systems,
where these are not uniform, that they are mutually compatible.
Open-access operators need also to be brought into the fold to
ensure that interavailable and through ticketing is not jeopardised.
3.5 Concern has been expressed that Oyster
is a monopoly supplier. While many Oyster cards have been issued
(each with a deposit of several pounds), many of them are used
only occasionally. The present policy of increasing cash fares
well in excess of prepaid fares will ensure a long-term future
for smartcard technology though this might equally well be borne
by travel chips in credit cards or mobile phone messages inter
alia. Credit/debit cards (as Barclays are doing with Oyster) can
add a separate travel chip. Subscribers to the scheme provider
can benefit from this additional travel feature without the need
for an additional card; we see this as a useful means of smartcard
payment for longer-distance fares.
3.6 Although there have been losers as a
result of zoning National Rail fares in London, this is a vital
precursor to smartcard ticketing availability for journeys on
both National Rail and London Underground.
3.7 Despite enquiries, we have been unable
to locate any smartcard schemes in Scotland applicable to rail
services.
REVENUE PROTECTION
AND THE
POWERS OF
TICKET INSPECTORS
Q6: Is the legal framework within which the
ticket inspectors function appropriate?
Q7: What appeal mechanisms exist for passengers
and are they adequate?
Q8: Are the rights of passengers and the
powers of ticket inspectors well-balanced?
Q9: Do operators of public transport take
adequate measure to protect fares revenue?
4.1 Passenger Focus and its predecessor
organisations have long called for measures to ensure that all
monies due as fare revenue are collected and have welcomed in
principle the various penalty fares schemes to that end to protect
the interests of fare-payers. We are particularly anxious, however,
at the variance between schemes, particularly at stations where
two or more companies' trains call.
4.2 Passengers need clarity about when and
where penalty fares apply and the likely result if they wilfully
disregard the provisions. Absence of consistency is a major cause
for concern. It is unfair and illogical that on some services
(as happens, for instance, on SWT's Basingstoke-Waterloo route)
on-train staff will sell fares at booking-office prices whereas
on other days the full rigour of the Penalty Fare provisions will
be brought down on the same individuals. We remain vigilant to
the length of ticket-office queues as a reason for passengers
failing to buy tickets before boarding. We are becoming increasingly
perturbed as to whether sufficient flexibility is accorded in
cases of queue length exceeding maximum queueing times. We expect
passengers to allow a reasonable time[41]
to obtain a ticket; after that time, we believe that the industry
has failed to provide the necessary facilities and that penalty
fares should be suspended until such time as ticket issue can
conform to the prescribed timescales.
4.3 Adequate publicity of the existence
of penalty fares at specific stations and on specific routes is
vital (and is a requirement of each penalty fare scheme) and robust
safeguards must be in place to avoid innocent passengers who have
inadvertently infringed the rules being issued with a penalty
fare notice. Revenue protection inspectors have discretion as
to whether to issue a Penalty fare, in addition to the appeals
mechanism. The appeal mechanisms are, in our view, clear, though
they are arguably not well publicised. All aspects of penalty
fare schemes must be transparent; our principal areas of concern
regarding Penalty fares remain: (a) ticket office queueing times
preventing passengers from pre-purchasing a ticket without missing
the train; (b) inconsistency of approach—as mentioned above;
and (c) the perceived impartiality of the system. We have concerns
over the perceived fairness of the appeals system where the industry
(its appointed penalty fares inspectors and, of greater worry,
the appeals processing staff) are judge and jury in the same case.
Even as statutory passenger representatives we have no right to
challenge upheld appeals—except to investigate whether they
were conducted in accordance with the (unpublished) guidelines
and (publicised) penalty fares procedures.
4.4 The provisions of the Bye-laws and National
Rail Conditions of Carriage, which ultimately set out the rights
and duties of both passengers and carriers, are almost wholly
unknown to most passengers. Despite major improvements in the
Conditions as a result of revisions in recent years, there is
still much to do to enhance passenger benefits.
4.5 It is clearly evident that too frequently
rail operators do not protect farebox revenue sufficiently robustly—for
instance, through failure to police ticketless travel on board
trains and at stations. Another failing is the frequent absence
of facilities for those passengers who intend to pay but can find
no means of doing so because either the station is unstaffed or
because on-train staff fail to sell them a ticket. In either case,
valuable income is lost which results in higher fares overall
for those who do pay.
4.6 Interim details of research[42]
undertaken by Passenger Focus late in 2006 show an unacceptably
high level of uncollected fares on one set of rural/semi-urban
routes from unstaffed stations. Passengers were unable to pay
their fare in advance and also unable to pay aboard the train
due to non-appearance of on-train staff. Either this means that
the railway is losing revenue or the passenger is inconvenienced
by having to queue at his destination to pay the fare. [43]In
our survey researchers alighted at unstaffed stations so that
revenue was lost.
4.7 There is an urgent and growing need
for wider implementation of automatic ticket gates at stations
with the highest footfall; it is equally vital to ensure that
gates are staffed while ever trains are running. Installing gates
results in a major increase in revenue to the extent that such
facilities have paid for themselves within a year or so. Greater
vigilance is also required to reduce the level of under-payment,
such as adults travelling on Child fare tickets or with Railcard
reductions to which they have no entitlement, alongside non-payment.
4.8 Too often the gates are left unattended
and open after mid-evening, with the result that late-night trains
carry a number of non-paying passengers, who probably feel that
they can travel without being challenged to show a valid ticket.
As gates permit holders of all valid tickets to pass through,
there is a need for on-train ticket examination to prevent over-riding
and also, ultimately, for gates at lesser-used stations to ensure
that passengers pay the correct fare for their journey. A ticket
to the next station will work the entry gates perfectly adequately;
a fraudulent passenger getting off at an ungated destination ten
or more stations down the line need only pay the fare to the first
station to access the system.
4.9 It is virtually impossible for staff
to check tickets accurately at non-automated ticket barriers at
busy times under normal circumstances.
4.10 "Blitzing" ungated stations
with ticket inspectors and, where necessary, the British Transport
Police, is necessary to prevent as far as possible, fraudulent
travel to and from such locations. Such action is also beneficial
at major interchange points and at terminals, especially those
without automatic gates.
4.11 On-train inspection is also important
on longer-distance routes to ensure that passengers have a valid
ticket for the entire journey—not merely a short section
at either end; in any case, regular and frequent appearance of
on-train staff provides an enhanced level of customer service
beyond revenue protection duties: enhanced sense of personal security;
a deterrent against vandalism; and assistance for those passengers
in need, which in themselves may persuade more passengers to make
further rail journeys and increase farebox revenue.
CONCESSIONARY FARES—THE
RIGHT STRATEGY?
Q10: Is the government's concessionary fares
strategy, including the proposed scheme for concessionary bus
travel, adequate?
Q11: Are concessionary fare schemes sufficiently
integrated across different modes of transport and different geographical
areas?
5.1 We welcome the regulation of the Senior,
Disabled Persons and Young Persons Railcard. We would urge other
operators to emulate Virgin's more relaxed policy on the use of
Railcard-reduced fares at peak times for leisure journeys.
5.2 We are disappointed that full-time pupils
aged 16 to 18 in secondary education are still expected to pay
full adult fares when travelling between their home and place
of education, save for some instances where local authorities
intervene with reduced-rate travel schemes.
5.3 The question of concessionary bus fares
falls outwith our remit and we therefore make no comment except
for those cases where no practicable bus service is provided (eg
central Wales or the far north of Scotland) but where rail services
do operate. We understand both the distress of those holders of
unusable travel concessions and train companies who operate non-remunerative
services in such areas and trust that local authorities can resolve
such anomalies.
5.4 Conversely, free bus travel for pass-holders
aged over 60 has reduced patronage on some rail services.
5.5 Recent correspondence[44]
in the trade press suggests that the cost to extend free local
rail travel to Community Rail projects would prove a negligible;
(eg £32,000 on the Tamar Valley line in Cornwall). Long-distance
free rail travel would have a major cost implication (perhaps
£250 million per annum) and as such is unlikely to be entertained.
March 2007
34 Passenger Focus is the operating name of the Rail
Passengers Council. Back
35
Consider the situation of the adjoining Greater Manchester (boundary
station Greenfield) and West Yorkshire (boundary station Marsden)
PTEs. The standard single from Greenfield to central Manchester
(12¾ miles) is £3.45, whereas from Marsden (19 miles)
it costs £6.50. Marsden to Huddersfield (7 miles) costs £1.45;
from Greenfield, over the boundary, it costs £6.30 for the
13 miles. The single between Marsden and Greenfield (6 miles)
is £4.10. Back
36
Strategy to Reality-using local transport plans to deliver
on rail, Rail Passengers Council (February 2005). Back
37
Formerly Tyne & Wear Metro-light rail services, largely on
erstwhile British Rail track beds, on Tyneside and Wearside operated
by the Passenger Transport Executive. Back
38
A nationwide web-based route planning service for rail, coach,
air (within Scotland only) and car journeys. Back
39
The Strippenkaart is a pre-paid ticket for any journey
wholly within the Netherlands. Passengers deduct from their ticket
the relevant number of zones through which they intend to travel
when they embark on the first leg of the journey, which can be
made by any transport mode, in any combination within the zones.
In the absence of overall validity limit on the overall ticket
remaining units can be used at any time. Back
40
By "ticket" we mean not only traditional electronic-strip
card tickets, but Smartcards, mobile telephone ticketing, print-at-home
tickets with bar codes etc. Back
41
The Ticketing and Settlement Agreement, operated by ATOC
Rail Settlement Plan, to which all operators are party, states
that passengers should be served within five minutes at peak times
and three minutes at other times. We concur that these limits
are reasonable and that they should be adhered to. Back
42
The research, due for publication mid to late March 2007, covers
purchase facilities for tickets at stations (booking offices/ticket
machines), telesales, websites and aboard trains. Details will
be forwarded to the Transport Committee. Back
43
Not only does this unduly and unnecessarily delay passengers,
it can contribute to them missing connections. This is intolerable-more
so where onward services are infrequent. Back
44
Local Transport Today, issue 462 (15 to 28 February 2007). Back
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