5Meaningful consultation and proper impact assessment
110.A survey conducted by the consumer group Which? on 12 and 13 June 2018 found that 65% of passengers affected by the timetabling crisis did not believe they had been adequately consulted about the May timetable changes.148 In this chapter, we examine train companies’ approaches to consultation ahead of May 2018, including an example of best practice, and consider how more consistent, ongoing and meaningful consultation could be key to restoring passengers’ trust in the railway. Some passengers and groups reported to us that they had been substantially disadvantaged by the May timetable change, irrespective of the implementation problems since 20 May.149 We examine some of these effects and consider how the impacts could be better assessed and mitigated now and in the future.
Passenger views on the consultation process
111.Evidence from passengers and other groups reflected the Which? survey results. Almost all who expressed a view had concerns about consultation prior to the 20 May timetable change. Consultations were described as “box-ticking” exercises;150 services were thought to have been “sneakily removed” from the timetable;151 some believed there was a “culture of secrecy” in the rail industry.152
112.There were some examples of good practice. Hasting and Rother Rail Users Group (RUG), for example, reported GTR’s “positive approach to public consultation” in relation to its local train services. The operator had engaged in “direct and detailed negotiations with local RUGs over a long period”. Hastings and Rother RUG had been invited by GTR to “participate fully in designing” local services. This collaboration led to a fourth hourly service being introduced without the need for additional rolling stock (an idea devised by the local RUG during the negotiations). Despite some implementation and performance problems since 20 May, the overall experience had been positive. GTR was “now holding regular review meetings with the RUGs, providing a positive forum to address current problems and plan for the December timetable.”153
113.Anthony Smith from the national passenger Watchdog, Transport Focus, told us that, while Northern’s and TPE’s consultations were “a bit old school” and “perfunctory”, GTR’s initial consultation on the changes planned for May 2018 was “quite good” and “quite extensive”. He confirmed that GTR had “made considerable efforts to go and talk to rail user groups and stakeholder groups.”154
114.Alex Hayman of Which? called for much better and more consistently applied approach to consultation across all passenger operators on the network. His view was that effective passenger consultation was an ongoing process and should not only be undertaken in the run up to major changes such as this May’s timetable change. He believed the railway could learn much from other sectors, and that rail passengers ought to be given increased opportunities to “challenge train companies”. He noted the example of “customer challenge groups (CCGs)” in the water sector, in which companies were obliged to “engage in a meaningful way with CCGs” about proposed price rises.155
Late changes before May 2018 and waiving the obligation to consult
115.Anthony Smith noted that much of passengers’ dissatisfaction had arisen after consultation on the May timetable had been completed. This was in part because GTR was “trying to mesh with what East Midlands Trains was trying to do, and nobody took an overall view; hence the mess we ended up in.”156
116.This came through very strongly in evidence from passengers. For example, Emily Ketchin of Harpenden Thameslink Commuters’ Group told us that GTR’s consultation on the changes, undertaken in 2017, had included “more services at Harpenden”, totalling “eight fast and four slow services—12 services an hour.” Changes made to the plan since then meant that what was delivered from 20 May was “a far cry” from what had been consulted on. The Harpenden group wrote:
“In the morning, under the full May 2018 timetable, key Harpenden services are cut by one third [ … ]. In numerical terms there is a reduction from 23 trains to 18 and from 212 carriages to 176 for all services–and a reduction from 19 to 12 in the key faster services. [ … ] On Saturdays services have been cut by 75% versus the pre-May timetable (2 trains an hour from 8)–with direct services to many stations removed altogether.”157
117.The Harpenden Group’s, and other witnesses’, understanding of why Thameslink services were cut by the May timetable change was:
“[ … ] the introduction of ‘Thameslink Express’ services, which stop only at Bedford, Luton, St. Albans and London stations. These were introduced to mitigate complaints of Bedford commuters when EMT [East Midlands Trains] services were stopped from calling at Bedford during peak. There is no evidence that the consequential impact on Harpenden, Luton Airport Parkway, Leagrave, Harlington or Flitwick of removing stops was considered.”158
St Albans Commuter and Passenger Action Group believed that the decision to stop Thameslink services calling at intermediate stations between Bedford and London was “made to satisfy the DfT’s insistence of a journey time of 47 minutes from Bedford to London [ … ] following the removal of EMT services stopping at Bedford in the morning and evening peaks.”159
118.Harpenden Thameslink Commuters’ Group’s submission set out some of the effects of the service reductions on people’s daily routines, including having to leave home for work earlier in the morning and getting home later in the evening to the detriment of family life. For example, one commuter, writing in mid-August, told us:
“Since 20th May I have been home and had dinner with my family probably twice. Not twice per week. Twice in total. At work I have to make excuses as to why I can’t work late as I fear beyond 8pm the trains will be non-existent. What is harder to measure is the stress on me and my family due to all of this.”160
Emily Ketchin described the experience of Harpenden commuters:
“What is happening is that we are standing there on very crowded platforms [ … ] We are standing on platforms where those trains are whizzing past. We can see that they are lightly loaded, so the full capacity of the railway is not being properly used. [ … ] as a result of the Thameslink Express trains being introduced, we have fewer train services at Leagrave, Harlington, Flitwick, Luton Airport Parkway and Harpenden. That is 10.5 million passengers per year. That is not, on any view, a small minority.”161
119.Ms Ketchin argued there was “a viable alternative”:
“The Thameslink Express trains should have a different stopping pattern that better matches passenger needs. Instead of five, five, zero, it should have been three Luton, three Harpenden and four St Albans. It is disingenuous to suggest that there was no other viable option. [ … ].”162
120.The Harpenden group noted remarks by the then rail Minister, Jo Johnson MP, in a debate on Thameslink upgrades in the House of Commons on 18 April 2018. In answer to points about the lack of consultation on late changes to the May plan, Mr Johnson confirmed that ongoing upgrades to the Midland Mainline, including a fourth track from Bedford to Kettering, meant that “some difficult decisions have had to be taken”, including fast Thameslink services no longer stopping at Harpenden [and the other intermediate stations]. He said, “the impact of the midland main line works only became apparent to us in November 2017”, meaning “a specific consultation for Harpenden passengers was simply not a viable option.”163
121.Passengers and representative groups felt understandably aggrieved by this. The Association of Public Transport Users noted “there was too much uncertainty at the time of the consultations” and that the timetabling process as a whole failed to allow sufficient time to consult on what was actually delivered on 20 May.164 Witnesses pointed to train operating companies’ obligation to consult on all “significant alterations” to services, as set out, for example, in section 4.1 of GTR’s franchise agreement.165 Harpenden Thameslink Commuters’ Group believed this was clearly intended to be an “absolute” obligation, and that the DfT had set a “dangerous precedent” in waiving it.166
122.Paul Blomfield MP raised similar concerns about an apparent lack of consultation about cuts to EMT services from London St Pancras to Sheffield, noting that the five pre-20 May late afternoon/early evening services had been reduced to three on 20 May. EMT’s information to passengers about the 20 May timetable change did not appear specifically to mention the reduction in London/Sheffield services, merely making a general announcement that “in order for GTR to increase the number of services on our shared lines into London, we have had to make changes to our timetable.”167
123.Hitchin Rail Commuters Group and Hitchin Rail Users Group reported that GTR had consulted in 2017 on Great Northern service improvements at Hitchin, including more fast services to London Kings Cross and substantial additional capacity, including an increase in morning peak trains from 22 to 24. The Hitchin groups believed that GTR’s “positive statements meant that many Hitchin rail users felt no need to take part in the consultation”. Notwithstanding the chaotic implementation of the new timetable, what the May 2018 timetable delivered did not meet Hitchin passengers’ expectations. For example, it entailed a reduction in morning and evening peak services and loss of express Hitchin to London services.168
124.In relation to Thameslink service reductions at Harpenden, Luton Airport Parkway, Leagrave, Harlington and Flitwick, Ruth Hannant claimed they were an unavoidable consequence of the Thameslink phasing decision (see paragraphs 34-42 in Chapter 2). She also said GTR had:
“[ … ] acted to introduce extra services where they can. For example, in the case of Harpenden, on balance, even though there were fewer trains, they were longer trains, and in total I think they only lost four carriages in the peak, but, given the concerns that were raised, the operator is introducing two extra services via Harpenden from December. They have listened to concerns when they have been raised, but at the time, consultation on the specific operational changes, because of the issues we have been discussing, was not possible at that point.”169
125.The Secretary of State said that the upgrades to the Midland Mainline had meant there were “slightly fewer services running” but would ultimately enable a more substantial timetable when the works were completed in 2020. When we asked him whether he thought the approach to consultation could be improved, he said:
“I think it was very comprehensive, so I see no particular reason to do that. As far as I can see, there has been very extensive consultation. People are not always happy with the outcome of the consultation, and people are not always happy with the outcome of the decisions you have to take. When you put in place infrastructure changes, there are disruptions to passengers. […] but I do not think that the process is wrong.”170
126.After the DfT’s evidence on 22 October, Emily Ketchin wrote to us on behalf of Harpenden Thameslink Commuters’ Group to take issue with several points. She pointed out, for example, that, contrary to Ruth Hannant’s evidence, the Thameslink service reductions were a consequence of the “Bedford Express” decision in late 2017. As noted above, this had been acknowledged by the then rail Minister in April this year. Ms Ketchin’s understanding was therefore that the service reductions were not related in any way to the phasing decision. She reiterated that the then rail Minister had, also during the debate in April, acknowledged that the Department waived GTR’s obligation to consult on the service reductions. Ms Ketchin objected to Mr Grayling’s reference to “slightly fewer” services running until 2020, arguing that “one third of key services” could not reasonably be described as such. She claimed that no new services had been introduced and, in fact, “current services still fail to meet even the low bar set in the May 2018 timetable.” She rebutted Ms Hannant’s claim that service reductions in the peak had been largely mitigated by longer trains with more carriages and seats, noting that the Department and GTR were using an unreasonable definition of “peak”, including trains leaving Harpenden for London up to 10am.171 We invited the DfT to respond to Emily Ketchin’s rebuttals of the evidence given by ministers and officials, but the Department chose not to submit further evidence to our inquiry.
127.A key lesson from the May 2018 timetable change is that a significant proportion of rail users do not feel the industry is listening to them and taking proper account of their needs. If trust in the railway is to be restored the rail industry must substantially improve its engagement with passengers, including through ongoing and meaningful consultation on proposed service changes. Good practice, such as Govia Thameslink Railway’s active engagement with Rail User Groups on the design of some its services, exists but the broader approach to passenger consultation is patchy at best and perfunctory at worse. The Department for Transport’s rail franchising teams must more actively ensure that all passenger rail franchisees adopt best practice and innovative approaches and adhere to their contractual obligations to consult on all significant service changes.
128.Where there are major timetable changes on a complex interrelated network some highly-valued services may have to change, and some passengers may lose out. It is vital in these circumstances that passengers’ voices are heard, and effective mitigations fully explored. This does not appear to have been the case in relation to service alterations affecting East Midlands Trains, Thameslink and Great Northern passengers. Consultations on the May timetable were completed before these changes were planned. This was in part because of knock on effects of work to upgrade the Midland Mainline. Many passengers were consulted on significant service improvements; what they got were substantial reductions. In these circumstances we cannot agree with the Department for Transport that the industry’s consultations on the May 2018 timetable were “very comprehensive”. Future national rail timetable changes must adhere to agreed timescales and allow sufficient time for meaningful consultation with passengers.
129.As set out earlier in this Report, the industry and Network Rail have now adopted a more cautious approach to national rail timetable change in December 2018, and possibly beyond. We recommend the Department for Transport use this period of relative stability to re-assess the effects of the May 2018 timetable change, identifying stations that have lost a significant number of services, particularly at peak times. The Department and Network Rail should work with the operators and engage with passengers to design mitigations that better meet the needs of people travelling to and from the worst-affected stations. Evidence to our inquiry suggests these will include Sheffield, Hitchin, Harpenden, Luton Airport Parkway, Leagrave, Harlington and Flitwick
148 Which? submission to ORR timetabling inquiry
150 Geoff Robinson (RTC0040); Mr Andrew Johnson (RTC0090); APTU (The Association of Public Transport Users) (RTC0059)
151 Mr Andrew Johnson (RTC0090)
152 Nick Winfield (RTC0037); Which? (RTC0077);; Paul Gloess (RTC0076); John Rushton (RTC0065);; St Albans City & District Council (RTC0056); Councillor Emma Hoddinott (RTC0052);
158 Harpenden Thameslink Commuters’ Group (RTC0047); see also St Albans Commuter and Passenger Action Group (RTC0096)
166 Harpenden Thameslink Commuters’ Group (RTC0047)
Published: 4 December 2018