'MEASURING UP' 
ANNUAL RAIL CONSUMER REPORT 
 2019 

## Contents

| 1.    |     | Executive Summary    |     |  5    |
|-------|-----|----------------------|-----|-------|

## Part 1

| 2.    |                    | Introduction    |      |
|-------|--------------------|-----------------|------|
| -     | Background         |                 |  18  |
| -     | Consumer landscape |                 |  20  |

## Part 2

| 3.       |                        | Our passenger work                 |     |    22  |
|----------|------------------------|------------------------------------|-----|--------|
| -        | Ticket retailing       |                                    | 22  |        |
| -        | Passenger information  |                                    | 24  |        |
| -        | Assisted Travel        |                                    | 31  |        |
| -        | Complaints and redress |                                    | 41  |        |
| 4.       |                        | Network Rail                       |     |    51  |
| 5.       |                        | Annex A: Findings by train company |     |    55  |
| 6.       |                        | Annex B: Compensation gap          |     |    56  |
| Glossary |                        | 61                                 |     |        |

## 1. Executive Summary

1.  
The 
 Office 
 of 
 Rail 
 and 
 Road 
 (ORR) 
 is 
 the 
 
combined 
 economic 
 and 
 health 
 and 
 safety 
 
regulator 
 for 
 the 
 GB 
 rail 
 network 
 and 
 the 
 
economic 
 monitor 
 for 
 England's 
 strategic 
 road 
 
network. 
 One 
 of 
 our 
 strategic 
 objectives 
 is 
 to 
 
support 
 better 
 rail 
 customer 
 service. 
 
2.  
Our 
 consumer 
 role 
 is 
 focussed 
 on 
 ensuring 
 
that 
 we 
 have 
 a 
 good 
 understanding 
 of 
 the 
 rail 
 
passenger 
 experience 
 in 
 the 
 consumer 
 areas 
 
for 
 which 
 we 
 have 
 regulatory 
 responsibility, 
 can 
 
recognise 
 success 
 and 
 good 
 practice 
 so 
 that 
 it 
 
can 
 be 
 shared 
 more 
 widely, 
 and 
 take 
 prompt 
 
and 
 effective 
 action 
 to 
 improve 
 the 
 service 
 
that 
 passengers 
 receive 
 where 
 it 
 is 
 required. 
 In 
 
particular, 
 we 
 focus 
 on: 
- 
Ticketing retailing 
 - 
 information 
 to 
 enable 
 
passengers 
 to 
 make 
 informed 
 purchase 
 
decisions; 
- 
Passenger information 
 - 
 information 
 to 
 
help 
 passengers 
 with 
 journey 
 planning, 
 
including 
 when 
 there 
 is 
 disruption; 
- 
Assisted travel 
 - 
 services 
 for 
 passengers 
 
who 
 require 
 assistance 
 to 
 make 
 their 
 
journey; 
 and 
- 
Complaints and redress 
 - 
 an 
 effective 
 
service 
 for 
 handling 
 complaints 
 and 
 redress. 
3.  
This 
 report 
 illustrates 
 the 
 breadth 
 and 
 depth 
 
of 
 our 
 consumer 
 work. 
 Throughout 
 the 
 year, 
 
we 
 have 
 continued 
 to 
 seek 
 the 
 views 
 of 
 our 
 
Consumer Expert Panel1 
  as 
 we 
 develop 
 our 
 
policy 
 work. 
 We 
 summarise 
 our 
 key 
 activities 
 
designed 
 to 
 secure 
 improvements 
 to 
 the 
 
 
service 
provided by rail companies to their passengers, 
 
highlight where progress has been made and 
 
where action has been necessary, and compare 
 
performance across companies.  
 We also 
 
provide summary  
 tables of our compliance 
 
activity, and for each of our consumer areas our 
 
next steps. 

## Ticket Retailing

4.  
This 
 year 
 we 
 completed 
 our 
 research2 
 to 
 help 
 us 
 
understand 
 the 
 extent 
 to 
 which 
 passengers 
 are 
 
aware 
 of, 
 and 
 understand, 
 key 
 ticket 
 restrictions 
 
and 
 terms 
 and 
 conditions 
 (T&C) 
 when 
 buying 
 
and 
 using 
 tickets.  
 
5.  
While 
 it 
 is 
 encouraging 
 that 
 the 
 participants 
 
appear 
 to 
 understand 
 the 
 basic 
 terms 
 and 
 
conditions 
 that 
 apply 
 to 
 their 
 tickets, 
 work 
 is 
 
required 
 to 
 inform 
 passengers 
 of 
 more 
 detailed 
 
and 
 specific 
 terms 
 and 
 conditions. 
 The 
 results 
 
showed: 
n 
84% 
 of 
 respondents 
 said 
 they 
 were 
 familiar 
 
with 
 the 
 T&Cs. 

n 
The 
 relatively 
 low 
 cost 
 of 
 rail 
 tickets 
 did 
 not 
 
merit 
 spending 
 time 
 reading 
 T&Cs. 
n 
Language 
 around 
 season 
 ticket 
 T&Cs 
 was 
 
confusing. 
n 
Concerns 
 around 
 ambiguous 
 language, 
 
particularly 
 relating 
 to 
 fees 
 for 
 refunds. 
n 
Uncertainty 
 of 
 where 
 to 
 find 
 the 
 T&Cs 
 
when 
 buying 
 the 
 ticket. 
n 
Off-peak 
 ticket 
 T&Cs 
 had 
 the 
 lowest 
 
awareness 
 overall. 
n 
Advance 
 tickets, 
 that 
 are 
 not 
 usually 
 
refundable, 
 were 
 perceived 
 as 
 unfair. 

6. 
 
We will now work with industry stakeholders to see how passengers' awareness and understanding of those terms and conditions, which were less well known and understood, can be improved. This will complement work already in progress across the industry such as proposals for fares reform. 
Passenger information 
-  
Replacement 
 buses 
 were 
 used 
 on 
 some 
 
routes 
 but 
 prolonged 
 delays 
 in 
 providing 
 
7.  
One 
 of 
 the 
 findings 
 of 
 the 
 ORR 
 Inquiry 
 into 
 
information 
 in 
 journey 
 planners 
 meant 
 
the 
 May 
 2018 
 timetable 
 disruption 
 was 
 that 
 
many 
 passengers 
 were 
 not 
 aware 
 that 
 they 
 
information 
 provided 
 by 
 Northern 
 and 
 Govia 
 
were 
 available; 
 and 
Thameslink 
 Railway 
 (GTR) 
 to 
 its 
 passengers 
 was 
 
-  
Inadequate 
 internal 
 communication 
 
inadequate 
 which 
 meant 
 that 
 passengers 
 were 
 
often 
 left 
 frontline 
 staff 
 with 
 little 
 or 
 no 
 
unable 
 to 
 plan 
 and 
 make 
 their 
 journeys 
 with 
 
information 
 to 
 assist 
 passengers 
 in 
 making 
 
any 
 certainty. 
 As 
 a 
 result, 
 we 
 initiated 
 a 
 formal 
 
their 
 journey. 
investigation 
 into 
 whether 
 Northern 
 and 
 GTR 
 on 
 
its 
 Great 
 Northern 
 and 
 Thameslink 
 routes 
 had 
 
10.  
As 
 a 
 result, 
 ORR 
 fined 
 GTR 
 £5m 
 for 
 failing 
 
breached 
 their 
 passenger 
 information 
 licence 
 
to 
 provide 
 appropriate, 
 accurate 
 and 
 timely 
 
obligations 
 in 
 the 
 lead 
 up 
 to 
 and 
 after 
 the 
 20 
 
information 
 to 
 passengers 
 following 
 the 
 
May 
 2018. 
introduction 
 of 
 a 
 new 
 timetable 
 in 
 May 
 2018. 
8.  
We 
 undertook 
 detailed 
 and 
 thorough 
 
11.  
Passengers 
 often 
 remain 
 dissatisfied 
 with 
 how 
 
investigations 
 into 
 both 
 companies, 
 which 
 
the 
 rail 
 industry 
 performs 
 when 
 it 
 comes 
 to 
 
included 
 substantial 
 information 
 gathering 
 and 
 
providing 
 them 
 with 
 the 
 information 
 they 
 need. 
 
analysis 
 as 
 well 
 as 
 meetings 
 with 
 the 
 licence 
 
Therefore, 
 this 
 year 
 we 
 commissioned 
 research 
 
holders. 

 For Northern, we found that the 
 
designed to put passengers at the front and 
 

company 
 was 
 not 
 in 
 breach 
 both 
 before 
 the 
 
centre 
 of 
 train 
 companies 
 thinking. At the time 
timetable 
 change 
 on 
 20 
 May 
 2018 
 and 
 in 
 the 
 
of writing we are assessing the results but 
period 
 after. 
 
during the coming year we will work with train companies to implement the findings in 
9.  
Having 
 considered 
 substantial 
 evidence, 
 we 
 
the expectation that passengers will see real 
found 
 that 
 GTR 
 took 
 reasonable 
 steps 
 in 
 making 
 
improvements in this area. 
passengers 
 aware 
 of 
 the 
 planned 
 changes 
 prior 
 
to 
 the 
 new 
 timetable. 
 However, 
 following 
 the 
 
Assisted travel 
timetable 
 change 
 on 
 20 
 May, 
 and 
 in 
 the 
 eight 
 
weeks 
 that 
 followed, 
 it 
 was 
 evident 
 that 
 GTR 
 
12.  
The 
 licences 
 we 
 issue 
 to 
 station 
 and 
 train 
 
failed 
 to 
 appropriately 
 balance 
 the 
 steps 
 it 
 
was taking to improve services with the need 
 
for passenger information to an unacceptable 
 
extent and duration. 

 In particular: 

-  
Trains 
 were 
 permanently 
 removed 
 from 
 the 
 
timetable 
 but 
 passengers 
 were 
 not 
 clearly 
 
informed 
 until 
 several 
 weeks 
 later; 
-  
Further 
 trains 
 were 
 removed 
 or 
 cancelled 
 
on 
 a 
 daily 
 basis 
 leading 
 to 
 very 
 short 
 notice 
 
changes 
 to 
 the 
 timetable 
 and 
 a 
 severe 
 lack 
 
of 
 certainty 
 for 
 passengers 
 up 
 until 
 the 
 point 
 
of 
 travel; 
-  
Some 
 trains 
 were 
 reintroduced 
 but 
 
with 
 insufficient 
 time 
 to 
 input 
 journey 
 
information 
 into 
 systems. 
 These 
 'ghost 
 
trains' 
 arrived 
 at 
 stations 
 with 
 staff 
 and 
 
passengers 
 unaware 
 of 
 their 
 arrival 
 or 
 
where 
 they 
 were 
 expected 
 to 
 stop; 

not been booked in 
 

operators 
 require 
 them 
 to 
 establish 
 and 
 comply 
 
with 
 a 
 Disabled 
 People's 
 Protection 
 Policy 
 
(DPPP), 
 which 
 we 
 approve. 
 We 
 publish 
 guidance 
 
on 
 how 
 they 
 should 
 write 
 their 
 policies, 
 which 
 
requires 
 them 
 to 
 set 
 out 
 their 
 arrangements 
 for 
 
providing 
 assisted 
 travel3 
 to 
 passengers. 
 Over 
 
the 
 last 
 year 
 we 
 have 
 worked 
 extensively, 
 to 
 
further 
 develop 
 the 
 initial 
 proposals 
 we 
 made 
 in 
 
2017 
 to 
 strengthen 
 Assisted 
 Travel 
 and 
 to 
 revise 
 
the 
 guidance. 
 These 
 proposals 
 were 
 based 
 
upon 
 detailed 
 research, 
 which 
 gave 
 us 
 a 
 robust 
 
evidence-base 
 to 
 work 
 from. 
13.  
Securing 
 improvement 
 to 
 the 
 services 
 received 
 
by 
 disabled 
 passengers 
 is 
 an 
 important 
 area 
 
of 
 focus 
 for 
 us. 
 This 
 year 
 we 
 have 
 engaged 
 
extensively 
 with 
 various 
 stakeholders, 
 held 
 
workshops, 
 and 
 carried 
 out 
 station 
 visits 
 to 
 
ensure 
 we 
 obtained 
 a 
 full 
 picture 
 of 
 the 
 relevant 
 
issues. 
 Alongside 
 the 
 responses 
 to 
 the 
 first 
 
consultation, 
 this 
 helped 
 us 
 to 
 further 
 refine 
 our 
 
proposals. 
14.  
In 
 November, 
 we 
 published 
 our 
 detailed 
 proposals 
 to 
 improve 
 the 
 experience 
 of 
 assisted 
 travel 
 and 
 
the 
 provision 
 of 
 information 
 to 
 disabled 
 passengers. 
 We 
 sought 
 views 
 on: 
n 
Ensuring 
 disabled 
 people 
 are 
 involved 
 in 
 a 
 meaningful 
 way 
 in 
 the 
 development 
 and 
 delivery 
 of 
 
staff 
 training 
 and 
 the 
 development 
 and 
 review 
 of 
 policies. 
n 
Improving 
 the 
 quality 
 and 
 reliability 
 of 
 assistance 
 through 
 better 
 customer 
 information 
 
provision 
 at 
 the 
 journey 
 planning 
 and 
 booking 
 stages, 
 and 
 requiring 
 a 
 dedicated 
 assistance 
 line 
 
and 
 handover 
 protocol 
 for 
 station 
 staff. 
n 
Strengthening 
 the 
 content, 
 delivery 
 and 
 frequency 
 of 
 staff 
 training. 
 
n 
Reducing 
 the 
 notice 
 period 
 for 
 booking 
 assistance 
 from 
 24 
 hours 
 to 
 10pm 
 the 
 day 
 before 
 or 
 to 
 
6 
 hours 
 or 
 2 
 hours. 
n 
Ensuring 
 passengers 
 that 
 have 
 booked 
 assistance 
 can 
 easily 
 obtain 
 redress 
 when 
 things 
 go 
 
wrong. 
n 
Ensuring 
 assistance 
 can 
 be 
 provided 
 under 
 different 
 modes 
 of 
 operation 
 through 
 effective 
 risk 
 
assessment 
 and 
 mitigation, 
 flexibility 
 in 
 service 
 delivery 
 and 
 clear 
 information.  
 
n 
Revising, 
 restructuring 
 and 
 renaming 
 DPPPs 
 so 
 passengers 
 understand 
 what 
 assistance 
 options 
 
are 
 available, 
 how 
 to 
 obtain 
 them, 
 what 
 to 
 expect 
 if 
 things 
 go 
 wrong 
 and 
 where 
 to 
 get 
 further 
 
information. 
 
n 
Ensuring 
 passengers 
 know 
 how 
 to 
 contact 
 a 
 member 
 of 
 staff 
 at 
 any 
 station, 
 either 
 in 
 person 
 or 
 
remotely. 
n 
Improving 
 the 
 communication 
 tools 
 capable 
 of 
 being 
 used 
 for 
 booking 
 assistance. 
n 
Improving 
 the 
 service 
 for 
 passengers 
 when 
 rail 
 replacement 
 and 
 alternative 
 accessible 
 
transport 
 is 
 used. 
 
n 
Ensuring 
 clearer 
 information 
 is 
 provided 
 to 
 passengers 
 on 
 the 
 carriage 
 of 
 scooters 
 and 
 other 
 
mobility 
 aids. 
n 
Strengthening 
 how 
 companies 
 consider 
 assistance 
 provision 
 for 
 passengers 
 in 
 different 
 
operating 
 circumstances, 
 focusing 
 on 
 staff 
 availability. 
 
 
15. 
Following review of responses to the 
16.  
It is important that when passengers seek 
consultation we will publish the final DPPP 
assistance they can be confident that it 
guidance shortly and proceed to approve 
will be provided. Therefore, this year we 
train and station operators revised DPPPs 
have continued to monitor train companies 
later this year. 
performance via independent research with 
those passengers who have booked assistance to understand whether they received it and whether they were satisfied with it. 

 
Company 
Overall sample 
size 
Received all 
assistance booked 
Chiltern Railways 
100 
80% 
85% 
79% 
East Midlands 
Trains 
171 
78% 
84% 
81% 
Govia Thameslink 
Railway 
153 
70% 
83% 
79% 
Great Western 
Railway 
570 
76% 
91% 
89% 
Greater Anglia 
155 
75% 
87% 
83% 
London North 
Eastern Railway 
495 
79% 
91% 
89% 
Northern 
291 
64% 
76% 
75% 
ScotRail 
226 
76% 
84% 
83% 
South Western 
Railway 
170 
69% 
87% 
85% 
Southeastern 
83 
75% 
82% 
83% 
TfW Rail 
177 
69% 
83% 
81% 
TransPennine 
Express 
150 
79% 
90% 
89% 
Virgin Trains West 
Coast 
524 
78% 
91% 
89% 
West Midlands 
Trains 
233 
79% 
90% 
85% 
Total/average for 
train operators 
3,542 
75% 
87% 
85% 
 
Network Rail 
1,426 
76% 
89% 
86% 
 
National/Average 
4,968 
76% 
88% 
85% 

*Satisfaction with the whole process from booking assistance to assistance received 

 
 
  

-  
TfW Rail took over the Arriva Train Wales franchise on 14 October 2018. 


-  
London North Eastern Railways took over the Virgin Trains East Coast franchise on 24 June 2018. 


TfL Rail (10 responses). 

 

 

 

Overall 
satisfaction* 
Satisfaction with 
assistance at 
station 


 

 

 

 


17. 
The results of the research above demonstrates clearly that train companies need to improve to provide the service passengers require. We are pleased that two train companies - SWR and Northern - and Network Rail have agreed to take part in a trial 
of our proposed reliability safeguard measures 
designed to improve the reliability of Assisted Travel. These proposed measures seek to address a longstanding issue highlighted by both our Assisted Travel research and the research above, which has shown that systemic 
informational and communication issues as 
a result of established practices across the 
network can hinder staffs' ability to provide 
assistance reliably at stations. We will evaluate 
the results of the trial before determining whether to roll them out across the network. 

Percentage of all complaints 
Punctuality/reliability Facilities on board 
 
 
9.3 
Sufficient room for all passengers to sit/stand 


8.3 
Ticketing and refunds policy 


6.1 
Other ticket buying facilities (online ticket sales) 

18. 
We have published today our response to the Williams Review. It asked ORR to consider what more can be done by rail operators to improve 
accessibility for all users, including disabled 
people, and whether more regulatory powers are required to ensure that it happens. 
 
  

 

## Complaints And Redress

19.  
We have continued to focus on train companies 
complaints handling over the course of the year. There were 30.1 complaints per 100,000 
journeys in 2018-19 for franchised train 
companies, and the figure of circa 530,000 complaints is a slight increase on the year before. Our data collection allows us to identify the main reasons for complaints and to see how this changes year on year. The table below shows that whilst it has fallen, punctuality/ reliability remains the main driver of complaints. 

  

Percentage point 
change to 2017-18 
-2.9 
1.3 1.0 0.9 
-1.0 

20.  
One 
 of 
 our 
 key 
 monitoring 
 metrics 
 is 
 the 
 requirement 
 on 
 train 
 companies 
 to 
 respond 
 to 
 95% 
 of 
 
complaints 
 within 
 20 
 working 
 days. 
 Where 
 we 
 see 
 that 
 companies 
 are 
 failing 
 to 
 meet 
 their 
 obligations, 
 we 
 
have 
 taken 
 action 
 to 
 ensure 
 that 
 they 
 return 
 to 
 compliance 
 as 
 soon 
 as 
 possible. 
 Responding 
 to 
 failure, 
 and 
 
making 
 changes 
 to 
 sustain 
 improvement, 
 are 
 key 
 ways 
 train 
 companies 
 can 
 demonstrate 
 that 
 they 
 are 
 
learning 
 from 
 their 
 experience. 

## Case Study - Virgin Trains (Vt) - Improving And Sustaining Performance


 

 

 
In 2017/18 VT was unable to meet its requirements to respond to 95% of complaints within 20 working days in 10 rail periods. As a result, ORR sought a detailed plan for returning to compliance, met with the company, and carried out an audit of processes. 


 

 

 


Following this, VT undertook a full and detailed review to establish where improvements could be made centred around three key areas: people; process; and technology. This lead to a recruitment drive to ensure the Customer Resolutions Centre (CRC) was better resourced with staff with the right skills, attitude and experience supported by a structured training programme and accreditation process. 



The CRC was restructured and KPIs identified to maximise and develop performance management opportunities. Leadership roles were clearly defined so all understood what good looked like and where they could make the positive difference by focussing on the accountabilities of their own roles and leading others towards achieving the overall vision. 


 


Finally, VT introduced a new, user friendly and innovative Customer Management System. This gives richer and more accurate data, and allows more effective planning by targeting resource to keep customer wait times short. 


 


The improvements VT has introduced has enabled it to meet the 95% requirement on complaint handling for 15 consecutive periods. 

21.  
The 
 introduction 
 of 
 the Rail Ombudsman4 
 by 
 
and train companies to ensure that the 
the 
 industry 
 in 
 November 
 was 
 a 
 welcome 
 step 
 
ombudsman arrangements deliver high 
and 
 an 
 acknowledgement 
 that 
 more 
 needed 
 to 
 
quality information and drive improvements 
be 
 done 
 to 
 restore 
 trust 
 in 
 the 
 industry. 
 This 
 was 
 
in complaints handling. 
the 
 culmination 
 of 
 a 
 coordinated 
 effort 
 by 
 the 
 
23.  
Over 
 the 
 last 
 12 
 months 
 we 
 have, 
 for 
 the 
 first 
 
Rail 
 Delivery 
 Group, 
 Transport 
 Focus, 
 London 
 
time, 
 been 
 able 
 to 
 draw 
 upon 
 new 
 enhanced 
 
TravelWatch, 
 Department 
 for 
 Transport 
 (DfT), 
 
monitoring 
 data 
 for 
 **delay compensation**.
and 
 ORR 
 to 
 create 
 the 
 new 
 scheme. 
This 
 has 
 enabled 
 us 
 to 
 focus 
 on 
 those 
 train 
 
22.  
During 
 the 
 course 
 of 
 the 
 year 
 we 
 consulted 
 
companies 
 who 
 are 
 unable 
 to 
 deal 
 with 
 claims 
 
upon 
 making 
 membership 
 of 
 the 
 Rail 
 
for 
 compensation 
 in 
 a 
 timely 
 manner. 
 It 
 is 
 clear 
 
Ombudsman 
 a 
 requirement 
 in 
 licence. 
 This 
 is 
 
from 
 our 
 analysis 
 of 
 data 
 that 
 some 
 companies 
 
necessary 
 to 
 ensure 
 that 
 passengers 
 continue 
 
are 
 able 
 to 
 process 
 claims 
 more 
 efficiently 
 and 
 
to 
 have 
 long-term 
 certainty 
 that 
 they 
 can 
 access 
 
we 
 have 
 taken 
 action 
 where 
 failure 
 to 
 do 
 so 
 has 
 
a 
 free, 
 independent 
 and 
 binding 
 means 
 of 
 
been 
 identified. 
 As 
 the 
 table 
 below 
 illustrates, 
 
redress. 
 We 
 welcome 
 licensees' 
 acceptance 
 
there 
 is 
 a 
 clear 
 difference 
 in 
 the 
 performance 
 
of 
 this 
 licence 
 change. 
 We now look forward 
of 
 train 
 companies 
 in 
 approving, 
 and 
 rejecting, 
 
to working with the Rail Ombudsman 
delay 
 compensation 
 claims.  

 

 

 

 

 


24.  
We have also carried out a review of the 
25. 
proportion of due compensation that had been 
paid to passengers (the difference between due and paid compensation is sometimes referred 
to as the 'compensation gap') based on the 
evidence on the compensation gap that has become available since we published our 2017 
Measuring Up report. The evidence suggests that the proportion of compensation that is 
paid has remained fairly steady over this period. Whilst survey evidence (for Delay Repay 30 schemes) published by DfT/Transport Focus 
in October 20185 suggests a moderate rise in 
compensation payments over 2016 levels, our 
own analysis of train company payout and performance data (based on different criteria and methodology) suggests a marginal decline 
since 2016-17. It remains the case that a substantial proportion of potential payments go unclaimed, and as such that there is more work to be done in this area. 
 
  

 

 
 
We have published today our response to the Williams Review. It asked ORR to consider what more can be done to make it easier for customers to access the **compensation** they are entitled to, advise on what more could be done by rail companies to improve this, and whether more regulatory powers are required to ensure that it happens. 

The following table outlines our engagement on consumer issues to ensure compliance by licence holders from April 2018 to date. 
Area 
Issue 
Operator 
Action/outcome 
Complaints Handling 
 
SWR 
Proactive contact from SWR to explain short 
period of non-compliance. ORR monitoring. Returned to compliance. 
Responding to 95% of complaints within 20 working days 
LNER 
Proactive contact from LNER contact to 
explain short period of non-compliance. ORR monitoring. Returned to compliance. 
TfW Rail 
Proactive contact from TfW to explain short period of non-compliance. ORR monitoring. Returned to compliance. 
Northern 
Letters to Northern seeking explanation and 
detailed recovery plan6, face to face meeting 
at ORR, and enhanced monitoring initiated by ORR. Returned to compliance. 
TPE 
Proactive contact from TPE - recovery plan 
provided. Enhanced monitoring initiated by ORR. Returned to compliance. 
Hull Trains 
Letters to Hull Trains seeking explanation and 
detailed recovery plan7, face to face meeting 
at ORR, and enhanced monitoring initiated by ORR. 
London 
Overground 
Network Rail 
Face to face meeting at ORR, and enhanced 
monitoring voluntarily initiated by NR. 
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| plan        |     |     |     |     |     |     |
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| ORR,        |     |     |     |     |     |     |
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| Returned    |     |     |     |     |     |     |
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| to          |     |     |     |     |     |     |
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|             |     |     |     |     |     |     |
|             |     |     |     |     |     |     |
|             |     |     |     |     |     |     |
|             |     |     |     |     |     |     |
|             |     |     |     |     |     |     |
| Area                  | Issue      |
|-----------------------|------------|
| Eurostar              | Trial      |
|                       |            |
| underway.             |            |
|                       |            |
|                       |            |
| DPPP                  |            |
| Carriage of           |            |
| assistance dogs       |            |
|                       |            |
|                       |            |
| GTR                   | ORR        |
|                       |            |
| sought                |            |
|                       |            |
| clarification         |            |
|                       |            |
| on                    |            |
|                       |            |
| a                     |            |
|                       |            |
| number                |            |
|                       |            |
| of                    |            |
|                       |            |
| issues.               |            |
|                       |            |
| GTR                   |            |
|                       |            |
| revised               |            |
|                       |            |
| its                   |            |
|                       |            |
| 'pit                  |            |
|                       |            |
| stop'                 |            |
|                       |            |
| document              |            |
|                       |            |
| and                   |            |
|                       |            |
| gave                  |            |
|                       |            |
| assurances            |            |
|                       |            |
| that                  |            |
|                       |            |
| the                   |            |
|                       |            |
| document              |            |
|                       |            |
| does                  |            |
|                       |            |
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|                       |            |
| represent             |            |
|                       |            |
| a                     |            |
|                       |            |
| change                |            |
|                       |            |
| in                    |            |
|                       |            |
| the                   |            |
|                       |            |
| way                   |            |
|                       |            |
| passengers            |            |
|                       |            |
| are                   |            |
|                       |            |
| assisted              |            |
|                       |            |
| with                  |            |
|                       |            |
| their                 |            |
|                       |            |
| rail                  |            |
|                       |            |
| journeys.             |            |
| 8                     |            |
| Document              |            |
| produced for          |            |
| station staff to      |            |
| ensure safe and       |            |
| punctual departure    |            |
| of trains             |            |
| Accessibility of rail |            |
| replacement bus       |            |
| services              |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
|                       |            |
| GTR                   | ORR        |
|                       |            |
| sought                |            |
|                       |            |
| assurances            |            |
|                       |            |
| that                  |            |
|                       |            |
| rail                  |            |
|                       |            |
| replacement           |            |
|                       |            |
| services              |            |
|                       |            |
| during                |            |
|                       |            |
| planned               |            |
|                       |            |
| disruption            |            |
|                       |            |
| on                    |            |
|                       |            |
| Brighton              |            |
|                       |            |
| mainline              |            |
|                       |            |
| were                  |            |
|                       |            |
| accessible,           |            |
|                       |            |
| and                   |            |
|                       |            |
| clarification         |            |
|                       |            |
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|                       |            |
| arrangements          |            |
|                       |            |
| in                    |            |
|                       |            |
| place                 |            |
|                       |            |
| on                    |            |
|                       |            |
| routes                |            |
|                       |            |
| without               |            |
|                       |            |
| accessible            |            |
|                       |            |
| buses.                |            |
|                       |            |
| Confirmation          |            |
|                       |            |
| received              |            |
|                       |            |
| from                  |            |
|                       |            |
| GTR.                  |            |
|                       |            |
|                       |            |
|                       |            |
| Accessibility of the  |            |
| Intercity High Speed  |            |
| Trains temporarily    |            |
| introduced into       |            |
| service               |            |
| Hull Trains           | ORR        |
|                       |            |
| sought                |            |
|                       |            |
| clarification         |            |
|                       |            |
| regarding             |            |
|                       |            |
| the                   |            |
|                       |            |
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|                       |            |
| of                    |            |
|                       |            |
| assistance            |            |
|                       |            |
| when                  |            |
|                       |            |
| an                    |            |
|                       |            |
| HST                   |            |
|                       |            |
| temporarily           |            |
|                       |            |
| replaces              |            |
|                       |            |
| the                   |            |
|                       |            |
| usual                 |            |
|                       |            |
| Class                 |            |
|                       |            |
| 180                   |            |
|                       |            |
| train.                |            |
|                       |            |
| Assurances            |            |
|                       |            |
| received              |            |
|                       |            |
| and                   |            |
|                       |            |
| DPPP                  |            |
|                       |            |
| reviewed              |            |
|                       |            |
| and                   |            |
|                       |            |
| updated.              |            |
|                       |            |
| Provision of          |            |
| assistance            |            |
| Network Rail          | Station    |
|                       |            |
| visit                 |            |
|                       |            |
| to                    |            |
|                       |            |
| clarify               |            |
|                       |            |
| how                   |            |
|                       |            |
| assistance            |            |
|                       |            |
| and                   |            |
|                       |            |
| information           |            |
|                       |            |
| is                    |            |
|                       |            |
| provided              |            |
|                       |            |
| at                    |            |
|                       |            |
| mainline              |            |
|                       |            |
| station.              |            |
|                       |            |
|                       |            |
| Provision of booked   |            |
| assistance            |            |
| Northern              | Letter     |
| 9                     |            |
|                       |            |
| to                    |            |
|                       |            |
| Northern              |            |
|                       |            |
| regarding             |            |
|                       |            |
| the                   |            |
|                       |            |
| levels                |            |
|                       |            |
| of                    |            |
|                       |            |
| reliability           |            |
|                       |            |
| and                   |            |
|                       |            |
| plans                 |            |
|                       |            |
| for                   |            |
|                       |            |
| improvement.          |            |
|                       |            |
| Explanation           |            |
|                       |            |
| received              |            |
|                       |            |
| and                   |            |
|                       |            |
| follow                |            |
|                       |            |
| up                    |            |
|                       |            |
| meeting               |            |
|                       |            |
| to                    |            |
|                       |            |
| be                    |            |
|                       |            |
| held.                 |            |
|                       |            |
| Provision of booked   |            |
| assistance            |            |
| SWR                   | Letter     |
| 10                    |            |
|                       |            |
| to                    |            |
|                       |            |
| SWR                   |            |
|                       |            |
| to                    |            |
|                       |            |
| regarding             |            |
|                       |            |
| the                   |            |
|                       |            |
| levels                |            |
|                       |            |
| of                    |            |
|                       |            |
| reliability           |            |
|                       |            |
| and                   |            |
|                       |            |
| plans                 |            |
|                       |            |
| for                   |            |
|                       |            |
| improvement.          |            |
|                       |            |
| Explanation           |            |
|                       |            |
| received              |            |
|                       |            |
| and                   |            |
|                       |            |
| follow                |            |
|                       |            |
| up                    |            |
|                       |            |
| meeting               |            |
|                       |            |
| to                    |            |
|                       |            |
| be                    |            |
|                       |            |
| held.                 |            |
|                       |            |
| Carriage of mobility  |            |
| scooters              |            |
|                       |            |
| Northern              | Engagement |
|                       |            |
| to                    |            |
|                       |            |
| secure                |            |
|                       |            |
| revisions             |            |
|                       |            |
| to                    |            |
|                       |            |
| the                   |            |
|                       |            |
| mobility              |            |
|                       |            |
| scooter               |            |
|                       |            |
| policy                |            |
|                       |            |
| to                    |            |
|                       |            |
| ensure                |            |
|                       |            |
| that,                 |            |
|                       |            |
| where                 |            |
|                       |            |
| it                    |            |
|                       |            |
| is                    |            |
|                       |            |
| safe                  |            |
|                       |            |
| to                    |            |
|                       |            |
| do                    |            |
|                       |            |
| so,                   |            |
|                       |            |
| mobility              |            |
|                       |            |
| scooters              |            |
|                       |            |
| can                   |            |
|                       |            |
| be                    |            |
|                       |            |
| carried               |            |
|                       |            |
| within                |            |
|                       |            |
| the                   |            |
|                       |            |
| constraints           |            |
|                       |            |
| of                    |            |
|                       |            |
| train                 |            |
|                       |            |
| design                |            |
|                       |            |
| and                   |            |
|                       |            |
| station               |            |
|                       |            |
| facilities            |            |
|                       |            |
| and                   |            |
|                       |            |
| infrastructure.       |            |
| 11                    |            |
| Revised               |            |
|                       |            |
| policy                |            |
|                       |            |
| published             |            |
|                       |            |
| in                    |            |
|                       |            |
| February.             |            |
|                       |            |
| Provision of          |            |
| assistance            |            |
|                       |            |
| GWR                   | ORR        |
|                       |            |
| queried               |            |
|                       |            |
| the                   |            |
|                       |            |
| provision             |            |
|                       |            |
| of                    |            |
|                       |            |
| assistance            |            |
|                       |            |
| to                    |            |
|                       |            |
| passengers            |            |
|                       |            |
| at                    |            |
|                       |            |
| Goring                |            |
|                       |            |
| &                     |            |
|                       |            |
| Streatley             |            |
|                       |            |
| and                   |            |
|                       |            |
| other                 |            |
|                       |            |
| accessible            |            |
|                       |            |
| stations              |            |
|                       |            |
| on                    |            |
|                       |            |
| routes                |            |
|                       |            |
| where                 |            |
|                       |            |
| station               |            |
|                       |            |
| staff                 |            |
|                       |            |
| may                   |            |
|                       |            |
| not                   |            |
|                       |            |
| be                    |            |
|                       |            |
| present,              |            |
|                       |            |
| to                    |            |
|                       |            |
| assess                |            |
|                       |            |
| whether               |            |
|                       |            |
| this                  |            |
|                       |            |
| was                   |            |
|                       |            |
| compliant             |            |
|                       |            |
| with                  |            |
|                       |            |
| its                   |            |
|                       |            |
| DPPP.                 |            |
|                       |            |
| GWR                   |            |
|                       |            |
| now                   |            |
|                       |            |
| plans                 |            |
|                       |            |
| to                    |            |
|                       |            |
| introduce             |            |
|                       |            |
| mobile                |            |
|                       |            |
| staff                 |            |
|                       |            |
| based                 |            |
|                       |            |
| at                    |            |
|                       |            |
| Reading               |            |
|                       |            |
| and                   |            |
|                       |            |
| surrounding           |            |
|                       |            |
| stations              |            |
|                       |            |
| to                    |            |
|                       |            |
| provide               |            |
|                       |            |
| assistance.           |            |
|                       |            |

 

 

 

 

  

 


| Area                | Issue         | Operator    | Action/outcome    |
|---------------------|---------------|-------------|-------------------|
| Eurostar            | Processes     |             |                   |
|                     |               |             |                   |
| changed             |               |             |                   |
|                     |               |             |                   |
| following           |               |             |                   |
|                     |               |             |                   |
| ORR                 |               |             |                   |
|                     |               |             |                   |
| contact.            |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
| Consumer            |               |             |                   |
| rights              |               |             |                   |
| Potentially         |               |             |                   |
| misleading          |               |             |                   |
| information         |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
| Hull Trains         | Letter        |             |                   |
| 12                  |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| Hull                |               |             |                   |
|                     |               |             |                   |
| Trains              |               |             |                   |
|                     |               |             |                   |
| seeking             |               |             |                   |
|                     |               |             |                   |
| reasons             |               |             |                   |
|                     |               |             |                   |
| for                 |               |             |                   |
|                     |               |             |                   |
| the                 |               |             |                   |
|                     |               |             |                   |
| performance         |               |             |                   |
|                     |               |             |                   |
| shortfall           |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| improvement         |               |             |                   |
|                     |               |             |                   |
| plan.               |               |             |                   |
|                     |               |             |                   |
| Improvements        |               |             |                   |
|                     |               |             |                   |
| made                |               |             |                   |
|                     |               |             |                   |
| in                  |               |             |                   |
|                     |               |             |                   |
| case                |               |             |                   |
|                     |               |             |                   |
| closure             |               |             |                   |
|                     |               |             |                   |
| timescale           |               |             |                   |
|                     |               |             |                   |
| -                   |               |             |                   |
|                     |               |             |                   |
| ORR                 |               |             |                   |
|                     |               |             |                   |
| monitoring          |               |             |                   |
|                     |               |             |                   |
| continues.          |               |             |                   |
|                     |               |             |                   |
| Processing          |               |             |                   |
| compensation        |               |             |                   |
| claims within one   |               |             |                   |
| month of receipt    |               |             |                   |
|                     |               |             |                   |
| SWR                 | Letter        |             |                   |
| 13                  |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| SWR                 |               |             |                   |
|                     |               |             |                   |
| seeking             |               |             |                   |
|                     |               |             |                   |
| reasons             |               |             |                   |
|                     |               |             |                   |
| for                 |               |             |                   |
|                     |               |             |                   |
| the                 |               |             |                   |
|                     |               |             |                   |
| performance         |               |             |                   |
|                     |               |             |                   |
| shortfall           |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| improvement         |               |             |                   |
|                     |               |             |                   |
| plan.               |               |             |                   |
|                     |               |             |                   |
| SWR                 |               |             |                   |
|                     |               |             |                   |
| identified          |               |             |                   |
|                     |               |             |                   |
| inaccuracies        |               |             |                   |
|                     |               |             |                   |
| in                  |               |             |                   |
|                     |               |             |                   |
| its                 |               |             |                   |
|                     |               |             |                   |
| reporting           |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| resubmitted         |               |             |                   |
|                     |               |             |                   |
| data.               |               |             |                   |
|                     |               |             |                   |
| TPE                 | Letter        |             |                   |
| 14                  |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| TPE                 |               |             |                   |
|                     |               |             |                   |
| seeking             |               |             |                   |
|                     |               |             |                   |
| reasons             |               |             |                   |
|                     |               |             |                   |
| for                 |               |             |                   |
|                     |               |             |                   |
| the                 |               |             |                   |
|                     |               |             |                   |
| performance         |               |             |                   |
|                     |               |             |                   |
| shortfall           |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| improvement         |               |             |                   |
|                     |               |             |                   |
| plan.               |               |             |                   |
|                     |               |             |                   |
| TPE                 |               |             |                   |
|                     |               |             |                   |
| initiated           |               |             |                   |
|                     |               |             |                   |
| a                   |               |             |                   |
|                     |               |             |                   |
| face                |               |             |                   |
|                     |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| face                |               |             |                   |
|                     |               |             |                   |
| meeting             |               |             |                   |
|                     |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| discuss             |               |             |                   |
|                     |               |             |                   |
| plans.              |               |             |                   |
|                     |               |             |                   |
| Improvements        |               |             |                   |
|                     |               |             |                   |
| made                |               |             |                   |
|                     |               |             |                   |
| in                  |               |             |                   |
|                     |               |             |                   |
| case                |               |             |                   |
|                     |               |             |                   |
| closure             |               |             |                   |
|                     |               |             |                   |
| timescale.          |               |             |                   |
|                     |               |             |                   |
| Area                | Issue         | Operator    | Action/outcome    |
|                     |               |             |                   |
| Passenger           |               |             |                   |
| information         |               |             |                   |
| Compliance with     |               |             |                   |
| requirements of     |               |             |                   |
| Licence Condition 4 |               |             |                   |
| GTR                 | Investigation |             |                   |
| 15                  |               |             |                   |
| into                |               |             |                   |
|                     |               |             |                   |
| whether             |               |             |                   |
|                     |               |             |                   |
| licence             |               |             |                   |
|                     |               |             |                   |
| conditions          |               |             |                   |
|                     |               |             |                   |
| were                |               |             |                   |
|                     |               |             |                   |
| breached            |               |             |                   |
|                     |               |             |                   |
| in                  |               |             |                   |
|                     |               |             |                   |
| the                 |               |             |                   |
|                     |               |             |                   |
| pre                 |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| post                |               |             |                   |
|                     |               |             |                   |
| 20                  |               |             |                   |
|                     |               |             |                   |
| May                 |               |             |                   |
|                     |               |             |                   |
| 2018                |               |             |                   |
|                     |               |             |                   |
| timetable           |               |             |                   |
|                     |               |             |                   |
| change.             |               |             |                   |
|                     |               |             |                   |
| Decision            |               |             |                   |
|                     |               |             |                   |
| -                   |               |             |                   |
|                     |               |             |                   |
| breach              |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| penalty             |               |             |                   |
|                     |               |             |                   |
| of                  |               |             |                   |
|                     |               |             |                   |
| £5m.                |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
| Northern            | Investigation |             |                   |
| 16                  |               |             |                   |
| into                |               |             |                   |
|                     |               |             |                   |
| whether             |               |             |                   |
|                     |               |             |                   |
| licence             |               |             |                   |
|                     |               |             |                   |
| conditions          |               |             |                   |
|                     |               |             |                   |
| were                |               |             |                   |
|                     |               |             |                   |
| breached            |               |             |                   |
|                     |               |             |                   |
| in                  |               |             |                   |
|                     |               |             |                   |
| the                 |               |             |                   |
|                     |               |             |                   |
| pre                 |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| post                |               |             |                   |
|                     |               |             |                   |
| 20                  |               |             |                   |
|                     |               |             |                   |
| May                 |               |             |                   |
|                     |               |             |                   |
| 2018                |               |             |                   |
|                     |               |             |                   |
| timetable           |               |             |                   |
|                     |               |             |                   |
| change.             |               |             |                   |
|                     |               |             |                   |
| Decision            |               |             |                   |
|                     |               |             |                   |
| - no                |               |             |                   |
|                     |               |             |                   |
| breach.             |               |             |                   |
|                     |               |             |                   |
|                     |               |             |                   |
| SWR                 | Letter        |             |                   |
| 17                  |               |             |                   |
|                     |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| SWR                 |               |             |                   |
|                     |               |             |                   |
| seeking             |               |             |                   |
|                     |               |             |                   |
| results             |               |             |                   |
|                     |               |             |                   |
| of                  |               |             |                   |
|                     |               |             |                   |
| review              |               |             |                   |
|                     |               |             |                   |
| and                 |               |             |                   |
|                     |               |             |                   |
| learning            |               |             |                   |
|                     |               |             |                   |
| points.             |               |             |                   |
|                     |               |             |                   |
| Face                |               |             |                   |
|                     |               |             |                   |
| to                  |               |             |                   |
|                     |               |             |                   |
| face                |               |             |                   |
|                     |               |             |                   |
| meeting             |               |             |                   |
|                     |               |             |                   |
| held.               |               |             |                   |
|                     |               |             |                   |
| ORR                 |               |             |                   |
|                     |               |             |                   |
| satisfied           |               |             |                   |
|                     |               |             |                   |
| with                |               |             |                   |
|                     |               |             |                   |
| SWR                 |               |             |                   |
|                     |               |             |                   |
| response.           |               |             |                   |
|                     |               |             |                   |
| Overrunning         |               |             |                   |
| engineering work    |               |             |                   |
| at Wimbledon 19     |               |             |                   |
| November 2018       |               |             |                   |
|    |    |    |    |     |     |     |     |
|----|----|----|----|-----|-----|-----|-----|
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
|    |    |    |    |     |     |     |     |
| Area                                               | ORR next steps    | Timing    |
|----------------------------------------------------|-------------------|-----------|
| Ticket retailing                                   |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| industry                                           |                   |           |
|                                                    |                   |           |
| stakeholders                                       |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| improve                                            |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| prominence,                                        |                   |           |
|                                                    |                   |           |
| clarity                                            |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| understanding                                      |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| key terms and conditions                           | .                 |           |
| Ongoing                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Ticket retailing                                   |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| take                                               |                   |           |
|                                                    |                   |           |
| steps                                              |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| raise                                              |                   |           |
|                                                    |                   |           |
| passenger awareness                                | via               |           |
|                                                    |                   |           |
| social                                             |                   |           |
|                                                    |                   |           |
| media                                              |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| ORR's                                              |                   |           |
|                                                    |                   |           |
| website                                            |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| key                                                |                   |           |
|                                                    |                   |           |
| terms                                              |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| conditions                                         |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| passenger                                          |                   |           |
|                                                    |                   |           |
| rights.                                            |                   |           |
|                                                    |                   |           |
| Ongoing                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Ticket retailing                                   |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| DfT                                                |                   |           |
|                                                    |                   |           |
| in                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| light                                              |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| decision                                           |                   |           |
|                                                    |                   |           |
| not                                                |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| renew                                              |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| exemption                                          |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| Rail Passenger Rights and Obligations Regulations. |                   |           |
| Ongoing                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| publish                                            |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| results                                            |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| our                                                |                   |           |
|                                                    |                   |           |
| passenger information research                     | ,                 |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| train                                              |                   |           |
|                                                    |                   |           |
| companies                                          |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| implement                                          |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| findings.                                          |                   |           |
|                                                    |                   |           |
| Summer                                             |                   |           |
|                                                    |                   |           |
| 2019                                               |                   |           |
|                                                    |                   |           |
| Passenger                                          |                   |           |
| information                                        |                   |           |
| Passenger                                          |                   |           |
| information                                        |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| publish                                            |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| results                                            |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| our                                                |                   |           |
|                                                    |                   |           |
| second                                             |                   |           |
|                                                    |                   |           |
| review                                             |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| informed                                           |                   |           |
| traveller principles monitoring                    | and               |           |
|                                                    |                   |           |
| update                                             |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| regulatory                                         |                   |           |
| statement                                          | to                |           |
|                                                    |                   |           |
| take                                               |                   |           |
|                                                    |                   |           |
| into                                               |                   |           |
|                                                    |                   |           |
| account                                            |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| informed                                           |                   |           |
|                                                    |                   |           |
| traveller                                          |                   |           |
|                                                    |                   |           |
| principles.                                        |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Passenger                                          |                   |           |
| information                                        |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| RDG                                                |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| ensure                                             |                   |           |
|                                                    |                   |           |
| industry                                           |                   |           |
|                                                    |                   |           |
| has                                                |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| stretching                                         |                   |           |
|                                                    |                   |           |
| strategy                                           |                   |           |
|                                                    |                   |           |
| for                                                |                   |           |
|                                                    |                   |           |
| customer                                           |                   |           |
|                                                    |                   |           |
| information,                                       |                   |           |
|                                                    |                   |           |
| has                                                |                   |           |
|                                                    |                   |           |
| revised                                            |                   |           |
|                                                    |                   |           |
| its                                                |                   |           |
|                                                    |                   |           |
| code of practice                                   | and               |           |
|                                                    |                   |           |
| is                                                 |                   |           |
|                                                    |                   |           |
| delivering                                         |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| minimum                                            |                   |           |
|                                                    |                   |           |
| standard                                           |                   |           |
|                                                    |                   |           |
| across                                             |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| network.                                           |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Passenger                                          |                   |           |
| information                                        |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| follow-up                                          |                   |           |
|                                                    |                   |           |
| responses from train companies                     | on                |           |
|                                                    |                   |           |
| their                                              |                   |           |
|                                                    |                   |           |
| service                                            |                   |           |
|                                                    |                   |           |
| recovery                                           |                   |           |
|                                                    |                   |           |
| framework,                                         |                   |           |
|                                                    |                   |           |
| crisis                                             |                   |           |
|                                                    |                   |           |
| management                                         |                   |           |
|                                                    |                   |           |
| plans                                              |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| contingency                                        |                   |           |
|                                                    |                   |           |
| plans.                                             |                   |           |
|                                                    |                   |           |
| Summer                                             |                   |           |
|                                                    |                   |           |
| 2019                                               |                   |           |
|                                                    |                   |           |
| Assisted travel                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| publish                                            |                   |           |
|                                                    |                   |           |
| revised DPPP guidanc                               | e                 |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| set                                                |                   |           |
|                                                    |                   |           |
| out                                                |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| timetable                                          |                   |           |
|                                                    |                   |           |
| for                                                |                   |           |
|                                                    |                   |           |
| submission                                         |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| revised                                            |                   |           |
|                                                    |                   |           |
| policies                                           |                   |           |
|                                                    |                   |           |
| for                                                |                   |           |
|                                                    |                   |           |
| ORR                                                |                   |           |
|                                                    |                   |           |
| approval.                                          |                   |           |
|                                                    |                   |           |
| July                                               |                   |           |
|                                                    |                   |           |
| 2019                                               |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Assisted travel                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| publish                                            |                   |           |
|                                                    |                   |           |
| additional                                         |                   |           |
|                                                    |                   |           |
| guidance                                           | for               |           |
|                                                    |                   |           |
| operators                                          |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| heritage                                           |                   |           |
|                                                    |                   |           |
| railways,                                          |                   |           |
|                                                    |                   |           |
| trams                                              |                   |           |
|                                                    |                   |           |
| that                                               |                   |           |
|                                                    |                   |           |
| run                                                |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| national                                           |                   |           |
|                                                    |                   |           |
| network,                                           |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| single                                             |                   |           |
|                                                    |                   |           |
| stations.                                          |                   |           |
|                                                    |                   |           |
| Spring                                             |                   |           |
|                                                    |                   |           |
| 2020                                               |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Assisted travel                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| establish                                          |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| regular                                            |                   |           |
|                                                    |                   |           |
| forum with disabled people's                       |                   |           |
| organisations                                      | ,                 |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| include                                            |                   |           |
|                                                    |                   |           |
| users                                              |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| assisted                                           |                   |           |
|                                                    |                   |           |
| travel,                                            |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| consult                                            |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| accessibility                                      |                   |           |
|                                                    |                   |           |
| issues.                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Assisted travel                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| take                                               |                   |           |
|                                                    |                   |           |
| forward                                            |                   |           |
|                                                    |                   |           |
| any                                                |                   |           |
|                                                    |                   |           |
| further                                            |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| accessibility                                      |                   |           |
|                                                    |                   |           |
| resulting                                          |                   |           |
|                                                    |                   |           |
| from                                               |                   |           |
|                                                    |                   |           |
| ORR's                                              |                   |           |
|                                                    |                   |           |
| submission                                         |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| Williams Review                                    | .                 |           |
| Ongoing                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| publish                                            |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| present                                            |                   |           |
|                                                    |                   |           |
| our                                                |                   |           |
|                                                    |                   |           |
| research                                           |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| reviewing complaints                               |                   |           |
| handling in other regulated sectors                | where             |           |
|                                                    |                   |           |
| they                                               |                   |           |
|                                                    |                   |           |
| have                                               |                   |           |
|                                                    |                   |           |
| an                                                 |                   |           |
|                                                    |                   |           |
| ADR                                                |                   |           |
|                                                    |                   |           |
| scheme.                                            |                   |           |
|                                                    |                   |           |
| Summer                                             |                   |           |
|                                                    |                   |           |
| 2019                                               |                   |           |
|                                                    |                   |           |
| Complaints and                                     |                   |           |
| compensation                                       |                   |           |
| Complaints and                                     |                   |           |
| compensation                                       |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| RDG,                                               |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| Rail                                               |                   |           |
|                                                    |                   |           |
| Ombudsman,                                         |                   |           |
|                                                    |                   |           |
| smaller                                            |                   |           |
|                                                    |                   |           |
| train                                              |                   |           |
|                                                    |                   |           |
| companies                                          |                   |           |
|                                                    |                   |           |
| and                                                |                   |           |
|                                                    |                   |           |
| station                                            |                   |           |
|                                                    |                   |           |
| operators                                          |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| agree                                              |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| timetable                                          |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| join                                               |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| Rail                                               |                   |           |
| Ombudsman.                                         |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| undertake                                          |                   |           |
|                                                    |                   |           |
| further                                            |                   |           |
|                                                    |                   |           |
| analysis                                           |                   |           |
|                                                    |                   |           |
| of                                                 |                   |           |
|                                                    |                   |           |
| delay compensation data                            | ,                 |           |
|                                                    |                   |           |
| with                                               |                   |           |
|                                                    |                   |           |
| a                                                  |                   |           |
|                                                    |                   |           |
| focus                                              |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| difference                                         |                   |           |
|                                                    |                   |           |
| in                                                 |                   |           |
|                                                    |                   |           |
| performance                                        |                   |           |
|                                                    |                   |           |
| in                                                 |                   |           |
|                                                    |                   |           |
| relation                                           |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| rejection                                          |                   |           |
|                                                    |                   |           |
| rates                                              |                   |           |
|                                                    |                   |           |
| Autumn                                             |                   |           |
|                                                    |                   |           |
| 2019                                               |                   |           |
|                                                    |                   |           |
| Complaints and                                     |                   |           |
| compensation                                       |                   |           |
| We                                                 |                   |           |
|                                                    |                   |           |
| will                                               |                   |           |
|                                                    |                   |           |
| take                                               |                   |           |
|                                                    |                   |           |
| forward                                            |                   |           |
|                                                    |                   |           |
| any                                                |                   |           |
|                                                    |                   |           |
| further                                            |                   |           |
|                                                    |                   |           |
| work                                               |                   |           |
|                                                    |                   |           |
| on                                                 |                   |           |
|                                                    |                   |           |
| delay                                              |                   |           |
|                                                    |                   |           |
| compensation                                       |                   |           |
|                                                    |                   |           |
| resulting                                          |                   |           |
|                                                    |                   |           |
| from                                               |                   |           |
|                                                    |                   |           |
| ORR's                                              |                   |           |
|                                                    |                   |           |
| submission                                         |                   |           |
|                                                    |                   |           |
| to                                                 |                   |           |
|                                                    |                   |           |
| the                                                |                   |           |
|                                                    |                   |           |
| Williams Review                                    | .                 |           |
| Ongoing                                            |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
|                                                    |                   |           |
| Complaints and                                     |                   |           |
| compensation                                       |                   |           |
Summer/ Autumn 2019 
 
 
Ongoing Autumn 2019 
 
Ongoing 

## 2. Introduction

26.  
This 
 is 
 our 
 fourth 
 Annual 
 Consumer 
 Report, 
 
27.  
The 
 first 
 part 
 of 
 this 
 report 
 sets 
 out 
 what 
 we 
 
which, 
 as 
 in 
 previous 
 years, 
 focuses 
 on 
 the 
 four 
 
have 
 done 
 in 
 each 
 of 
 these 
 areas 
 over 
 the 
 last 
 
main 
 areas 
 of 
 our 
 passenger 
 facing 
 work: 
year, 
 and 
 covers 
 both 
 our 
 day-to-day 
 monitoring 
 
and 
 compliance 
 activity 
 together 
 with 
 the 
 
- 
Ticket retailing - 
 the 
 provision 
 of 
 clear, 
 
work 
 we 
 do 
 to 
 improve 
 service 
 quality 
 and 
 
accurate 
 and 
 complete 
 information 
 about 
 
raise 
 standards. 
 It 
 includes 
 examples 
 of 
 our 
 
fares 
 and 
 tickets, 
 so 
 that 
 passengers 
 can 
 
interventions 
 as 
 well 
 as 
 tables 
 that 
 show 
 how 
 
make 
 informed 
 decisions 
 when 
 choosing, 
 
train 
 companies 
 have 
 performed 
 relative 
 to 
 
buying 
 and 
 using 
 rail 
 products. 
each 
 other 
 in 
 a 
 number 
 of 
 areas, 
 notably 
 around 
 
- 
Passenger information - 
 the 
 provision 
 
the 
 provision 
 of 
 assisted 
 travel, 
 complaints 
 
of 
 appropriate, 
 accurate 
 and 
 timely 
 
handling, 
 and 
 for 
 the 
 first 
 time 
 compensation. 
information 
 about 
 services, 
 so 
 that 
 
28.  
The 
 second 
 part 
 of 
 this 
 report, 
 published 
 as 
 a 
 
passengers 
 can 
 plan 
 and 
 make 
 their 
 
separate 
 annex, 
 consists 
 of 
 links 
 to 
 individual 
 
journeys 
 with 
 a 
 reasonable 
 degree 
 
data 
 sheets, 
 which 
 provide 
 information 
 on 
 each 
 
of 
 assurance, 
 including 
 when 
 there 
 is 
 
train 
 company's 
 individual 
 performance 
 across 
 a 
 
disruption. 
range 
 of 
 key 
 indicators, 
 between 
 April 
 2018 
 and 
 
- 
Assisted travel - the 
 ability 
 for 
 passengers 
 
March 
 2019. 
who 
 require 
 assistance 
 to 
 make 
 their 
 
29.  
We 
 have 
 created 
 some 
 interactive 
 tools 
 on 
 our 
 
journey 
 easily 
 and 
 confidently, 
 whether 
 
website 
 to 
 provide 
 access 
 to 
 additional 
 historical 
 
those 
 journeys 
 are 
 made 
 on 
 a 
 'turn-updata 
 where 
 it 
 is 
 has 
 not 
 been 
 possible 
 to 
 include 
 
and-go' 
 basis 
 or 
 where 
 assistance 
 has 
 been 
 
it 
 here. 
 These 
 can 
 be 
 found 
 at: 
 http://orr.gov.uk/ 
booked 
 in 
 advance. 
rail/consumers/annual-rail-consumer-report. 
 
- 
Complaints and redress - 
 the 
 provision 
 of 
 
an 
 easily 
 accessible, 
 effective 
 and 
 efficient 
 
complaints 
 and 
 redress 
 service. 

## Background

Our role 
31.  
Our 
 work 
 derives 
 from 
 the 
 licences 
 we 
 issue 
 to 
 
30.  
The 
 Office 
 of 
 Rail 
 and 
 Road 
 (ORR) 
 is 
 the 
 
combined 
 economic 
 and 
 health 
 and 
 safety 
 
regulator 
 for 
 the 
 GB's 
 rail 
 network 
 and 
 the 
 
economic 
 monitor 
 for 
 England's 
 strategic 
 
road 
 network. 
 With 
 regard 
 to 
 rail 
 passenger 
 
services, 
 which 
 are 
 the 
 subject 
 of 
 this 
 report, 
 
the vast majority of these are provided by train 
 
companies under franchise agreements with 
 
government. 

 These agreements specify many 
 
of the obligations and service standards that 
 
train companies are required to deliver and are 
 
overseen by government. 

 

 
train 
 companies 
 and 
 Network 
 Rail 
 and 
 from 
 our 
 
powers 
 and 
 responsibilities 
 under 
 consumer 
 
and 
 competition 
 law. 
 As 
 a 
 result, 
 our 
 passenger 
 
facing 
 work 
 is 
 focused 
 on 
 four 
 areas 
 outlined 
 
above. 
 Three 
 of 
 these, 
 passenger 
 information, 
 
assisted 
 travel, 
 and 
 complaints 
 handling, 
 are 
 the 
 
subject 
 of 
 conditions 
 in 
 the 
 licences 
 we 
 issue18, 
 
while 
 our 
 interest 
 in 
 ticket 
 retailing 
 stems 
 from 
 
our 
 consumer 
 law 
 powers19. 
32.  
We 
 are 
 not 
 responsible 
 for 
 setting 
 fares, 
 
awarding 
 or 
 monitoring 
 franchises, 
 or 
 for 
 
setting 
 the 
 level 
 of 
 public 
 subsidy 
 in 
 the 
 railways 
 
- 
 these 
 are 
 the 
 responsibility 
 of 
 government. 
 
Nonetheless, 
 we 
 work 
 closely 
 with 
 the 
 DfT, 
 
Transport 
 Scotland, 
 and 
 the 
 Welsh 
 Government, 
 
as 
 well 
 as 
 passenger 
 and 
 consumer 
 bodies, 
 such 
 
as 
 Transport 
 Focus 
 and 
 London 
 TravelWatch. 

## Our Approach

33.  
Our 
 approach 
 to 
 regulation 
 is 
 based 
 on 
 
a 
 process 
 of 
 monitoring, analysis, 
 and 
 
engagement, which 
 enables 
 us 
 to 
 identify 
 
issues 
 and 
 take 
 appropriate 
 and 
 proportionate 
 
action 
 where 
 necessary. 
 Key 
 to 
 this 
 approach 
 
is 
 the 
 collection 
 of 
 data 
 on 
 key 
 performance 
 
indicators. 
 Over 
 the 
 last 
 year 
 we 
 have 
 continued 
 
to 
 work 
 with 
 train 
 companies 
 to 
 enhance 
 the 
 
breadth, 
 depth 
 and 
 quality 
 of 
 this 
 data. 
34.  
To 
 support 
 our 
 monitoring 
 activities 
 we 
 
undertake 
 purposeful 
 and 
 targeted 
 consumer 
 
research. 
 This, 
 and 
 the 
 collection 
 and 
 analysis 
 
of 
 key 
 data, 
 helps 
 to 
 ensure 
 that 
 we 
 have 
 a 
 clear 
 
and 
 robust 
 evidence 
 base 
 to 
 identify 
 issues 
 and 
 
support 
 our 
 interventions. 
 Publication 
 of 
 this 
 
data, 
 particularly 
 where 
 it 
 is 
 possible 
 to 
 compare 
 
relative performance, also helps provide an 
 
incentive on companies to make improvements. 

35.  
Where 
 improvements 
 are 
 not 
 forthcoming, 
 or 
 
are 
 not 
 likely 
 to 
 be 
 delivered 
 in 
 a 
 timely 
 manner, 
 
we 
 take 
 prompt 
 and 
 effective 
 compliance and 
enforcement 
 action. 
 We 
 have 
 a 
 range 
 of 
 tools 
 
at 
 our 
 disposal, 
 depending 
 on 
 the 
 seriousness 
 
of 
 the 
 issue 
 and 
 what 
 is 
 proportionate 
 in 
 
the 
 circumstances. 
 This 
 generally 
 involves 
 
engagement 
 with 
 the 
 company 
 or 
 companies 
 
concerned 
 and 
 can 
 also 
 include 
 targeted 
 
reporting, 
 establishment 
 of 
 corrective 
 actions 
 
plans, 
 audits, 
 and 
 ultimately, 
 enforcement 
 
action. 
 Where 
 appropriate 
 we 
 are 
 transparent 
 
in 
 the 
 action 
 we 
 take, 
 and 
 there 
 are 
 a 
 number 
 of 
 
case 
 studies 
 throughout 
 this 
 report 
 that 
 reflect 
 
this 
 approach. 

## Role And Work Of Orr'S Consumer Expert Panel20


 

 

 

 

To support our work we draw upon the breadth of knowledge and experience provided by an independent Consumer Expert Panel. The Panel operate in an advisory role to review and inform ORR's policy making and research. It provides cross-sectoral insight into consumer behaviour and economics and the application of this in a variety of regulated environments. In the last year the Panel has advised ORR's work in a wide variety of areas including: 
the market review of compensation claims companies; the DPPP guidance review; the monitoring and enforcement policy for Network Rail in CP6; and the market study into TVMs and automatic ticket gates. 

## Consumer Landscape Introduction

36.  
Over 
 the 
 last 
 12 
 months 
 there 
 have 
 been 
 a 
 
number 
 of 
 activities 
 in 
 the 
 rail 
 sector 
 which 
 
have, 
 and 
 continue, 
 to 
 impact 
 on 
 rail 
 passengers 
 
and 
 ORR. 
 We 
 have 
 summarised 
 these 
 below. 

## Independent Inquiry Into The Timetable Disruption In May 2018

37.  
In 
 May 
 2018, 
 the 
 introduction 
 of 
 a 
 new 
 national 
 
timetable 
 for 
 large 
 parts 
 of 
 Britain's 
 railway 
 
network 
 caused 
 major 
 disruption 
 to 
 services 
 
for 
 passengers, 
 especially 
 in 
 the 
 North 
 of 
 
England 
 and 
 in 
 the 
 South 
 East. 
 Many 
 passengers 
 
travelling 
 on 
 Northern 
 and 
 GTR 
 networks 
 
within 
 these 
 regions 
 were 
 severely 
 disrupted 
 
and 
 passengers 
 on 
 many 
 other 
 networks 
 also 
 
suffered 
 knock-on 
 disruption 
 to 
 their 
 services 
 as 
 
a 
 result. 
38.  
In 
 June 
 2018, 
 at 
 the 
 request 
 of 
 the 
 Government, 
 
ORR 
 established 
 an 
 Inquiry 
  into 
 why 
 the 
 
railway 
 system 
 as 
 a 
 whole 
 failed 
 to 
 produce 
 and 
 
implement 
 a 
 satisfactory 
 operational 
 timetable 
 
in 
 May 
 2018. 
39.  
We 
 made 
 recommendations 
 in 
 two 
 phases: 
- 
 
Our **Phase 1**22 
 report 
 published 
 on 
 20 
 
September 
 found 
 that 
 the 
 difficulties 
 endured 
 
by 
 passengers 
 were 
 the 
 result 
 of 
 poor 
 
communication 
 within 
 the 
 industry, 
 a 
 perception 
 
that 
 no 
 one 
 was 
 in 
 overall 
 control 
 of 
 decisionmaking, 
 and 
 a 
 failure 
 to 
 put 
 passengers 
 at 
 the 
 
heart 
 of 
 decision-making. 
-  
In 
 our 
 **Phase 2**23 final 
 report, 
 we 
 recommended 
 
that 
 the 
 interests 
 of 
 passengers 
 are 
 put 
 at 
 the 
 
heart 
 of 
 key 
 decisions 
 for 
 major 
 rail 
 projects, 
 
and 
 that 
 the 
 industry 
 work 
 together 
 to 
 improve 
 
how 
 information 
 is 
 provided 
 to 
 passengers. 
 We 
 
also 
 set 
 out 
 how 
 this 
 could 
 be 
 achieved. 

## Williams Review

40.  
The 
 Williams 
 Rail 
 Review 
 was 
 established 
 in 
 
September 
 2018 
 to 
 look 
 at 
 the 
 structure 
 of 
 the 
 
whole 
 rail 
 industry 
 and 
 the 
 way 
 passenger 
 rail 
 
services 
 are 
 delivered. 
 The 
 review's 
 findings 
 
and 
 recommendations 
 will 
 be 
 published 
 in 
 a 
 
Government 
 white 
 paper 
 due 
 later 
 this 
 year. 
 
ORR 
 has 
 engaged 
 with 
 the 
 Williams 
 Review 
 team 
 
from 
 the 
 outset 
 and 
 are 
 working 
 to 
 consider 
 
the 
 options 
 and 
 recommendations 
 that 
 it 
 will 
 
develop 
 over 
 the 
 second 
 six-months 
 of 
 its 
 work. 
 
41.  
In 
 February 
 2019, 
 Keith 
 Williams 
 asked 
 ORR 
 to 
 
provide 
 submissions 
 to 
 his 
 wide-reaching 
 review 
 
of 
 the 
 UK 
 rail 
 sector, 
 focussing 
 specifically 
 on 
 the 
 
issues 
 of 
 accessibility 
 and 
 compensation: 
 
 "As part of [the issue of passenger trust] we need to do more on making it easier for customers to access the compensation they are entitled to and improving accessibility for all users, including disabled people. I've asked the ORR to advise me on what more could be done by rail operators to improve this, and whether more regulatory powers are required to ensure that it happens. They will report back within the timescale of the Review recommending action to help transform compensation and accessibility across the network." 

42.  
To 
 develop 
 our 
 understanding 
 of 
 the 
 current 
 
situation 
 in 
 the 
 rail 
 industry, 
 and 
 best 
 practice 
 
elsewhere, 
 we 
 have 
 engaged 
 expertise 
 from 
 
within 
 ORR, 
 the 
 broader 
 rail 
 industry, 
 and 
 
beyond. 
 We 
 have 
 published 
 today 
 our 
 response 
 
on 
 these 
 two 
 issues 
 to 
 the 
 Williams 
 Review 

## The Consumer Forum

43.  
The 
 creation 
 of 
 the 
 Consumer 
 Forum,24 
 
chaired 
 by 
 the 
 Minister 
 for 
 Consumers 
 and 
 
Corporate 
 Responsibility, 
 was 
 announced 
 
in 
 the 
 government's 
 Modernising Consumer 
Markets Green 
 Paper25. 
  The 
 Forum's 
 aim 
 is 
 
to 
 enhance 
 collaboration 
 and 
 coordination 
 
between 
 Government 
 and 
 regulators 
 to 
 improve 
 
consumer 
 outcomes. 
 It 
 brings 
 together 
 Chief 
 
Executives 
 from 
 the 
 economic 
 regulators 
 
(including 
 ORR), 
 the 
 Financial 
 Conduct 
 Authority, 
 
and 
 the 
 Competition 
 and 
 Markets 
 Authority, 
 
with 
 ministers 
 from 
 their 
 respective 
 sponsor 
 
departments. 
 The 
 intention 
 is 
 that 
 the 
 Forum 
 
will 
 strengthen 
 how 
 these 
 organisations 
 
collectively interact to address issues that arise 
 
across sectors and where both Government and 
 
regulators could act. 

 

## United Kingdom Regulators Network

44.  
The 
 United 
 Kingdom 
 Regulators 
 Network 
 
(UKRN)26 
 brings together regulators 
 (including 
 
ORR) 
 from the utilities, transport, financial, 
 
health, and legal services sectors. 

 The network 
 
aims to share expertise to help make regulation 
 
work well for consumers and the economy. 

 
Established by regulators in 
 2014, it has 
 
developed strong relationships and a culture 
 
of collaboration and learning and through 
 
the UKRN, regulators work together to share 
 
knowledge, explore cross-cutting issues and 
 
build better ways of working. 

 The UKRN 
 has 
 
committed to undertake some work in response 
 
to the Green Paper such as sharing best practice 
 
to protect interests of vulnerable consumers.  
 

45.  
The 
 UKRN's 
 fourth 
 annual 
 conference 
 held 
 on 
 
24 
 April 
 2019 
 focussed 
 on 
 the 
 theme 
 of 
 "Data, 
 
Innovation 
 and 
 Vulnerable 
 Consumers" 
 - 
 
bringing 
 together 
 regulators 
 with 
 Government 
 
and 
 stakeholders 
 to 
 explore 
 the 
 challenges 
 that 
 
the 
 ever-changing 
 technological 
 landscape 
 has 
 
on 
 consumers, 
 especially 
 the 
 most 
 vulnerable 
 in 
 
our 
 society. 
 

## 3. Our Passenger Work 3.1 Ticket Retailing Introduction

46.  
It is important that passengers get good information when choosing, buying, and using 
rail tickets so that they can make informed decisions. Train companies, like companies in other sectors, are subject to consumer law 
which requires, among other things, that they provide passengers with the information they 
need and do so in a way that is clear and timely. 
  

 
 
  
 
 
47.  
The following sets out the work we have done over the last year to help improve the 
information that is provided to passengers when 
purchasing tickets, including at ticket vending 
machines (TVMs) and online. 

 

## Commitments From Last Year

48.  
In 
 last 
 year's 
 Measuring 
 Up 
 report 
 we 
 set 
 out 
 a 
 
number 
 of 
 actions 
 we 
 intended 
 to 
 take 
 during 
 
the 
 course 
 of 
 this 
 year. 
 A 
 summary 
 of 
 what 
 we 
 
did 
 in 
 relation 
 to 
 these 
 is 
 set 
 out 
 below. 
-  
On **TVMs**, 
 we 
 have 
 enhanced 
 our 
 data 
 
collection 
 to 
 enable 
 us 
 to 
 monitor 
 TVM 
 
complaints 
 and 
 passengers 
 making 
 claims 
 
under 
 the 
 TVM 
 price 
 guarantee. 
 This 
 data 
 
is 
 due 
 to 
 be 
 published 
 as 
 part 
 of 
 our 
 core 
 
data 
 monitoring.  
 
-  
On **train company websites**, 
 we 
 have 
 
now 
 received 
 from 
 RDG 
 the 
 findings 
 of 
 
its 
 audits 
 conducted 
 in 
 February 
 2019, 
 
and 
 will 
 review 
 the 
 results 
 to 
 identify 
 
any areas where further action may be 
 
needed.  
 

-  
On 
 **key ticket restrictions and terms**, 
 
we 
 commissioned 
 research 
 to 
 help 
 
us 
 understand 
 the 
 extent 
 to 
 which 
 
passengers 
 are 
 aware 
 of, 
 and 
 understand, 
 
these 
 when 
 buying 
 and 
 using 
 tickets. 
 We 
 
summarise 
 the 
 findings 
 and 
 our 
 next 
 
steps 
 in 
 this 
 chapter. 
   
 

## Terms And Conditions Research

49.  
One 
 of 
 ORR's 
 key 
 roles 
 in 
 this 
 area 
 is 
 to 
 secure 
 
compliance 
 with 
 consumer 
 law 
 to 
 help 
 ensure 
 
that 
 all 
 rail 
 users 
 get 
 the 
 service 
 to 
 which 
 they 
 
are 
 entitled. 
 These 
 include 
 a 
 requirement 
 on 
 
train 
 companies 
 to 
 provide 
 consumers 
 with 
 
the 
 information 
 they 
 need 
 to 
 make 
 informed 
 
choices 
 for 
 example 
 when 
 buying 
 and 
 using 
 
train 
 tickets, 
 and 
 to 
 have 
 terms 
 and 
 conditions 
 
(T&Cs) 
 that 
 are 
 fair 
 and 
 transparent 
 (written 
 in 
 
plain 
 and 
 intelligible 
 language). 
50.  
Following 
 up 
 on 
 findings 
 of 
 our 
 TVM 
 mystery 
 
shopping 
 work 
 and 
 our 
 website 
 audit 
 (noted 
 in 
 
last 
 year's 
 report) 
 which 
 both 
 suggested 
 that 
 
key ticket restrictions and terms are not always 
 
suitably prominent, we commissioned research 
 
to help us understand the extent to which 
 
passengers are aware of, and understand, these 
 
when buying and using tickets. 

 

51.  
The 
 research27 
 involved 
 an 
 online 
 survey 
 with 
 
the 
 public 
 who 
 had 
 travelled 
 on 
 the 
 national 
 
rail 
 network 
 within 
 the 
 previous 
 nine 
 months. 
 
This 
 was 
 followed 
 by 
 four 
 focus 
 groups 
 with 
 
the 
 public 
 who 
 had 
 travelled 
 on 
 the 
 national 
 
rail 
 network 
 within 
 the 
 last 
 six 
 months 
 with 
 
around 
 eight 
 participants 
 in 
 each 
 group. 
 The 
 key 
 
findings 
 showed: 
  
-  
84% 
 of 
 respondents 
 said 
 they 
 were 
 
familiar 
 with 
 the 
 T&Cs. 
-  
The 
 relatively 
 low 
 cost 
 of 
 rail 
 tickets 
 did 
 
not 
 merit 
 spending 
 time 
 reading 
 T&Cs. 
-  
Language 
 around 
 season 
 ticket 
 T&Cs 
 was 
 
confusing. 
-  
Concerns 
 around 
 ambiguous 
 language, 
 
particularly 
 relating 
 to 
 fees 
 for 
 refunds. 
-  
Uncertainty 
 of 
 where 
 to 
 find 
 the 
 T&Cs 
 
when 
 buying 
 the 
 ticket. 
-  
Off-peak 
 ticket 
 T&Cs 
 had 
 the 
 lowest 
 
awareness 
 overall. 
-  
Advance 
 tickets, 
 that 
 are 
 not 
 usually 
 
refundable, 
 were 
 perceived 
 as 
 unfair. 
52.  
Since 
 publication 
 of 
 the 
 results 
 in 
 March 
 2019, 
 
we 
 have 
 met 
 with 
 key 
 industry 
 stakeholders 
 to 
 
discuss 
 the 
 findings 
 and 
 to 
 start 
 to 
 identify 
 steps 
 
to 
 help 
 improve 
 the 
 prominence 
 and 
 clarity 
 of 
 
key 
 terms 
 and 
 conditions. 
 We 
 will 
 take 
 this 
 work 
 
forward 
 further 
 over 
 this 
 year. 

## Consumer Rights Act

53.  
Following industry changes to the National Rail 
Conditions of Travel to reflect the Consumer 
Rights Act (CRA) 2015 in March 2018, we wrote 
to train companies to ask what steps they had taken to ensure that the information provided 
to passengers reflected those changes. The consumer organisation Which? subsequently carried out a mystery shop of train company 
websites and call centres. In the light of these 
results, we reviewed what train companies had told us in response to our letter about the actions they had taken (or intended to take) 
and wrote to train companies to highlight good practice, outline our remaining areas of concern 
and to set out next steps. 

 


54.  
We have now carried out a further audit of 
websites, and are taking forward the results with 
individual train companies where improvements to the clarity and prominence of the information 
available to passengers about their rights under 
the CRA is needed. 

 

 

## Third-Party Intermediaries

55.  
We 
 have 
 recently 
 been 
 undertaking 
 a 
 market 
 
review 
 into 
 the 
 case 
 for 
 a 
 greater 
 role 
 for 
 delay 
 
repay 
 compensation 
 claims 
 companies 
 known 
 
as 
 third-party 
 intermediaries 
 (TPIs). 
 The 
 focus 
 of 
 
our 
 market 
 review 
 is 
 on 
 both 
 the 
 benefits 
 that 
 
TPIs 
 generate 
 for 
 passengers 
 and 
 the 
 potential 
 
risks 
 that 
 they 
 might 
 carry. 
 

## Next Steps

This year we will: 

n 
work 
 with 
 industry 
 stakeholders 
 to 
 identify 
 and 
 implement 
 ways 
 in 
 which 
 the 
 prominence, 
 clarity 
 
and 
 understanding 
 of 
 **key terms and conditions** can 
 be 
 improved; 
n 
take 
 steps 
 to 
 **raise passenger awareness** via 
 social 
 media 
 and 
 ORR's 
 website 
 on 
 key 
 terms 
 and 
 
conditions 
 and 
 passenger 
 rights 
 for 
 example 
 to 
 compensation; 
 and 
n 
work 
 with 
 the 
 DfT 
 following 
 the 
 decision 
 not 
 to 
 renew 
 the 
 exemption 
 to 
 the 
 Rail Passengers' 
Rights and Obligations Regulation, 
 and 
 take 
 forward 
 any 
 changes 
 to 
 train 
 and 
 station 
 operator 
 
licensing arrangements which may be necessary as a result of the decision. 

  

56.  
TPIs act as an interface between passengers 
and train companies for the purposes of claims made under passenger delay compensation 
schemes. We are looking at the potential role TPIs could play in bringing innovation 
to the market, raising awareness of delay 
repay compensation schemes and assisting 
passengers by making it easier for them 
to claim. We are considering whether TPIs 
might help to drive up claim rates amongst passengers. 

 


57.  
We are also looking at potential risks that TPIs might carry; notably the possibility for increased incidence of fraud, lack of transparency over fees, and, issues around the secure handling of passengers' money. The results of the review have been published today as an annex to our 
response to the Williams Review. 

## European Legislation

58.  
We have continued our role as National Enforcement Body (NEB) for Regulation 1371/2007/EC (Rail Passengers' Rights and 
Obligations Regulation (PRO)), including participating in the European Commission's 
annual meeting for NEBs. We have provided 
comments to the DfT on amendments proposed by the European Parliament as part of the 
'recast' of the Regulation. We have also worked 
with the DfT to understand the implications for the regulation of Great Britain exiting the European Union. 

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59.  
The current exemptions for domestic services in relation to the PRO will fall away in December 
2019 and the Rail Minister has decided that 
these will not be renewed. As NEB for the PRO, we are in dialogue with the DfT and RDG to 
discuss any actions such as changes to licensing 
arrangements which may be required as a result of the Rail Minister's decision. 

 

## 3.2 Passenger Information Introduction

60.  
In 
 all 
 licences, 
 there 
 is 
 a 
 condition 
 relating 
 to 
 
passenger 
 information 
 so 
 that 
 passengers 
 can 
 
plan 
 and 
 make 
 their 
 journeys 
 with 
 a 
 reasonable 
 
degree 
 of 
 assurance, 
 including 
 when 
 there 
 
is 
 disruption. 
 We 
 have 
 previously 
 published 
 
Regulatory 
 Guidance28 
 to 
 support 
 this 
 licence 
 
condition 
 by 
 giving 
 more 
 information 
 about 
 
what 
 is 
 expected 
 from 
 licence 
 holders 
 and 
 how 
 
the 
 condition 
 it 
 will 
 be 
 enforced.  
 
61.  
We 
 have 
 continued 
 to 
 focus 
 on 
 the 
 quality 
 of 
 
information 
 passengers 
 receive 
 about 
 their 
 rail 
 
service. 
 The 
 following 
 section 
 reports 
 on 
 activity 
 
in 
 this 
 area 
 over 
 the 
 last 
 year. 

## Commitments From Last Year

62.  
In 
 last 
 year's 
 Measuring 
 Up 
 report 
 we 
 set 
 out 
 a 
 
number 
 of 
 actions 
 we 
 intended 
 to 
 take 
 during 
 
the 
 course 
 of 
 this 
 year. 
 A 
 summary 
 of 
 what 
 we 
 
did 
 in 
 relation 
 to 
 these 
 is 
 set 
 out 
 below. 
 
-  
We 
 expected 
 to 
 publish revised 
regulatory guidance, 
 but 
 held 
 this 
 in 
 
abeyance 
 pending 
 the 
 outcome 
 of 
 the 
 
investigations 
 into 
 whether 
 GTR 
 and 
 
Northern 
 complied 
 with 
 their 
 passenger 
 
information 
 obligations 
 (summarised 
 in 
 
further 
 detail 
 later 
 in 
 this 
 chapter). 
 We 
 will 
 
take 
 this 
 forward 
 this 
 year. 
 
-  
We 
 have 
 conducted 
 website checks of 
the information provided in advance of major planned disruption such 
 as 
 the 
 
Brighton 
 Main 
 Line 
 Project. 
-  
We 
 have 
 been 
 able 
 to 
 review all the 
local plans 
 published 
 by 
 train 
 companies 
 
this 
 year 
 and 
 have 
 provided 
 feedback 
 on 
 
each. 
 Where 
 possible, 
 we 
 have 
 tried 
 to 
 
note 
 best 
 practice 
 and 
 use 
 this 
 to 
 inform 
 
our 
 feedback 
 processes 
 for 
 the 
 benefit 
 of 
 
the 
 whole 
 industry. 
 
-  
We 
 have 
 initiated 
 work 
 on 
 the 
 extent 
 
to 
 which 
 the 
 Code of Practice on the 
provision of Customer Information is 
 influencing 
 and 
 supporting 
 how 
 
companies 
 are 
 operating. 
 We 
 have 
 met 
 
with those involved in their delivery to 
 
discuss the benefits and limitations and 
 
have undertaken independent research 
 
into this area 
 (summarised in further 
 
detail later in this chapter). 

 Feedback 
 
from the reviews will be used to inform 
 
the RDG 
 review of its code of practice that 
 
is taking place in 
 2019. 

## Timetabling Issues

63.  
We 
 set 
 out 
 in 
 last 
 year's 
 report 
 that 
 the 
 Network 
 
Rail 
 System 
 Operator 
 (SO)29 
 had 
 made 
 changes 
 
to 
 the 
 way 
 that 
 short-term 
 changes 
 to 
 the 
 
timetable 
 were 
 made. 
 This 
 meant 
 that 
 some 
 
train 
 times 
 would 
 not 
 be 
 confirmed 
 until 
 
six 
 weeks 
 in 
 advance 
 of 
 the 
 date 
 of 
 travel, 
 
rather 
 than 
 the 
 usual 
 12 
 weeks 
 (known 
 as 
 the 
 
"Informed 
 Traveller" 
 timescales). 
 We 
 wrote 
 to 
 
train companies to clarify our expectations for 
 
compliance with the licence under three broad 
 
principles we expected them to follow while 
 
the online timetables for passengers remained 
 
unreliable and potentially subject to late change. 

 
We monitored websites against these principles, 
 
and wrote to train companies to set the main 
 
areas of concern identified in our monitoring 
 

prior 
 to 
 publishing 
 the 
 results. 
64.  
We 
 asked 
 train 
 companies 
 to 
 identify 
 the 
 
blockers 
 preventing 
 them 
 from 
 giving 
 
passengers 
 the 
 information 
 they 
 needed 
 to 
 
plan 
 and 
 make 
 their 
 journeys 
 with 
 a 
 reasonable 
 
degree 
 of 
 assurance. 
 Responding 
 to 
 our 
 
letter, 
 some 
 train 
 companies 
 referred 
 to 
 a 
 
lack 
 of 
 functionality 
 on 
 the 
 third-party 
 ticket 
 
engines, 
 provided 
 by 
 Trainline 
 or 
 Worldline 
 
respectively, 
 that 
 they 
 used 
 on 
 their 
 websites. 
 
We 
 subsequently 
 met 
 with 
 train 
 companies 
 
to 
 set 
 out 
 our 
 expectation 
 that 
 all 
 reasonably 
 
practicable 
 steps 
 should 
 be 
 taken 
 to 
 ensure 
 that 
 
warning 
 information 
 in 
 the 
 event 
 of 
 unconfirmed 
 
timetables, 
 and 
 information 
 relating 
 to 
 both 
 
planned 
 and 
 unplanned 
 disruption, 
 is 
 provided 
 
to 
 passengers. 
 In 
 response 
 to 
 our 
 request, 
 
train 
 companies 
 provided 
 details 
 of 
 the 
 
improvements 
 that 
 would 
 be 
 made 
 together 
 
with 
 a 
 timescale 
 for 
 doing 
 so. 
 
65.  
Alongside 
 our 
 action 
 with 
 train 
 companies, 
 
we 
 reminded 
 Trainline 
 and 
 Worldline 
 that 
 
as 
 third-party 
 resellers 
 of 
 tickets, 
 they 
 have 
 
responsibilities 
 under 
 consumer 
 law 
 for 
 which 
 
ORR 
 has enforcement powers. 

 We noted in 
 
particular the lack of warning information about 
 
trains which were known to be unconfirmed and 
 
had been marked as such on the National Rail 
 
Enquiries 
 (NRE) 
 website. 

 

66.  
Our 
 extensive 
 exchanges 
 of 
 correspondence 
 
with 
 train 
 companies 
 and 
 third-party 
 retailers 
 
have 
 been 
 published 
 on 
 the 
 ORR 
 website.30 
 
67.  
We 
 have 
 recently 
 completed 
 a 
 further 
 
monitoring 
 exercise 
 to 
 see 
 whether 
 
improvements 
 have 
 been 
 made 
 and 
 the 
 extent 
 
to 
 which 
 the 
 principles 
 are 
 being 
 met. 
 We 
 are 
 
now 
 collating 
 the 
 results 
 of 
 our 
 review 
 and 
 
will 
 publish 
 a 
 report 
 setting 
 these 
 out 
 and 
 any 
 
further 
 steps 
 which 
 may 
 be 
 appropriate.  
 
68.  
In 
 March 
 2019, 
 the 
 SO 
 announced 
 that 
 the 
 
industry 
 (except 
 GTR) 
 has 
 been 
 able 
 to 
 return 
 
to 
 the 
 standard 
 T-12 
 timescales 
 for 
 publishing 
 
timetables 
 (GTR 
 has 
 made 
 progress 
 and 
 is 
 now 
 

## South Western Railway (Swr) - Overrunning Engineering Work At Wimbledon 19 November 2018

We routinely review incidents on the network that have a high passenger impact. An incident on Monday 
19 November 2018 when engineering work overran in the Wimbledon area is in this category. 


 

 


Whilst such high impact events occur relatively rarely, it is important that when they do they are reviewed and any lessons are learnt. A committed industry action (PIDD-31) makes provision for routine reviews of Customer Service Level 2* incidents focussed on customer impact and this is a commitment that SWR 
makes in its PIDD local plan. 


  

 

  


We wrote to and subsequently met with SWR. We asked to see the results of any review that SWR has carried out about this incident, showing its conclusions and learning points for the future. We were particularly interested in the impact on its passengers, including those travelling through London Waterloo, and how it planned to improve their experience in future as a result. 


 

 
 

We also wanted to understand how the learning points from this and other reviews are tracked by SWR's Customer Experience Improvement Group, including how lessons learnt are acted upon and have oversight from senior managers. Given the advice to passengers was to not travel, we also asked it to set out arrangements for refunds. 


 

SWR responses in writing and in our meeting provided us with confidence that the company has learned lessons from the incident. The measures it is taking, and the improvements it has planned, appear to be robust and should enable the company to improve its incident handling in future. 


  

 

*each company is required to define their Service Disruption Threshold/s above which their passenger information during disruption arrangements will apply. The enhanced level of mobilisation within these thresholds is referred to as Customer Service Level 2 
 
  

 


at T-9). 

 However, we believe that most of our 
 
principles still reflect good practice 
 (or existing 
 
industry initiatives) 
 and we will continue to 
 
expect train companies to follow them. 

 We 
 
intend to revise our Regulatory Guidance this 
 
year to include the principles. 

 

## Monitoring And Insight

69.  
Over 
 the 
 course 
 of 
 the 
 last 
 year, 
 we 
 have 
 
continued 
 to 
 proactively 
 monitor 
 train 
 company 
 
websites. 
 Where 
 we 
 identify 
 problems 
 with 
 
incorrect, 
 inaccurate, 
 or 
 unclear 
 information 
 
we 
 take 
 prompt 
 action, 
 getting 
 in 
 touch 
 with 
 
the relevant Passenger Information During 


Disruption 
 (PIDD) 
 contacts in the train company 


so that changes can be made quickly. We also 


welcome 
 initiatives 
 undertaken 
 by 
 individual 
 
train companies to improve passenger 


information. We have highlighted such 


improvements 
 on 
 the 
 train 
 company 
 data 
 sheets 
 
in 
 the 
 appendices 
 to 
 this 
 document. 
70.  
We 
 also 
 examine 
 specific 
 issues that come to our 


attention including following major incidents. 

## National Rail Passenger Survey And Industry Research

71.  
Data about the performance of the 
industry in delivering information 
to passengers is provided through 
the National Rail Passenger Survey (NRPS), conducted twice a year by Transport Focus. The autumn data 
suggests that the satisfaction with 
provision of information has stayed 
the same at 74% while the usefulness 
of information provided during delay, 
and how well train companies deal 
with delays, have gone down. 

 

 

 
Source: Transport Focus, National Rail Passenger Survey 

72.  
NRPS 
 seeks 
 passengers' 
 views 
 on 
 the 
 journey 
 currently 
 being 
 made 
 and 
 so 
 does 
 not 
 always 
 capture 
 the 
 
opinions 
 of 
 passengers 
 when 
 they 
 have 
 actually 
 been 
 disrupted. 
 In 
 order 
 to 
 fill 
 this 
 gap, 
 the 
 industry 
 
decided 
 to 
 launch 
 its 
 own 
 survey. 
 This 
 has 
 now 
 been 
 running 
 for 
 three 
 years 
 and 
 the 
 latest 
 data 
 (covering 
 
1 
 October 
 2017 
 to 
 30 
 September 
 2018) 
 has 
 now 
 been 
 published 
 in 
 an 
 interim 
 form 
 on 
 the 
 Rail 
 Delivery 
 
Group 
 (RDG) 
 website.31 
73.  
The 
 RDG 
 report 
 set 
 out 
 a 
 ranking 
 system 
 scoring 
 the 
 quality 
 of 
 information 
 by 
 each 
 train 
 company. 
 The 
 
rankings 
 appeared 
 as 
 follows: 
Grand Central 63, West Midlands Railway 30, LNER 246, TransPennine Express 79, East Midlands Trains 
46, c2c 30, ScotRail 91, Great Western Railway 349, Greater Anglia 118, Southeastern 463, Northern 1321, South Western Railways 417, Southern 352, Great Northern 428, Thameslink 585 Note: TOCs with over 30 
responses shown 

74.  
As 
 with 
 last 
 year's 
 results, 
 the 
 survey 
 suggested 
 
that 
 the 
 areas 
 of 
 information 
 provision 
 that 
 
need 
 most 
 attention 
 are: 
 
-  
the 
 availability 
 of 
 alternative 
 transport 
 if 
 
the 
 train 
 service 
 could 
 not 
 continue; 
-  
the 
 time 
 taken 
 to 
 resolve 
 the 
 problem; 
-  
the 
 delivery 
 style; 
 and 
-  
frequency 
 of 
 updates. 
75.  
The 
 RDG 
 results 
 also 
 highlighted 
 that 
 
passengers 
 cared 
 more 
 about 
 the 
 content 
 
of 
 the 
 information 
 than 
 the 
 channel 
 through 
 
which 
 it 
 was 
 received. 
 When 
 ranking 
 the 
 types 
 
of 
 information 
 that 
 had 
 the 
 greatest 
 positive 
 
impact 
 on 
 customer 
 satisfaction, 
 information 
 
about 
 connections 
 and 
 onward 
 travel 
 had 
 the 
 
greatest 
 impact 
 with 
 the 
 length 
 of 
 delay 
 and 
 
an 
 apology 
 being 
 the 
 second 
 and 
 third 
 most 
 
important 
 respectively. 
 On 
 this 
 basis, 
 Transport 
 
Focus 
 has 
 recommended 
 that 
 industry 
 focus 
 on 
 
providing 
 relevant 
 information 
 content 
 and 
 its 
 
dissemination 
 through 
 a 
 range 
 of 
 channels. 
76.  
RDG 
 has 
 stated 
 that 
 its 
 new 
 Customer 
 
Information Board will monitor the progress 
 
of improvements and aim to complete the 
 
outstanding PIDD 
 industry actions. 

 RDG 
 is 
 
also looking to deliver information which is 
 
personalised to the customer and tailored to 
 

the 
 journey 
 purpose 
 or 
 type 
 via 
 the 
 National 


Enquiries app. 

## Orr Research

77.  
The 
 initial 
 findings 
 from 
 our 
 Inquiry32 
 into 
 
the 
 May 
 2018 
 timetable 
 change 
 highlighted 
 
significant 
 concerns 
 regarding 
 the 
 quality 
 
of 
 information 
 provided 
 to 
 passengers 
 to 
 
enable 
 them 
 to 
 plan 
 and 
 make 
 journeys 
 with 
 
a 
 reasonable 
 degree 
 of 
 assurance. 
 Despite 
 
the 
 focus 
 on 
 this 
 area 
 over 
 recent 
 years, 
 
passengers 
 often 
 remain 
 dissatisfied 
 with 
 how 
 
the 
 rail 
 industry 
 performs, 
 particularly 
 as 
 their 
 
expectations 
 are 
 often 
 set 
 or 
 exceeded 
 by 
 
experiences 
 in 
 other 
 sectors. 
 
78.  
Previous 
 work 
 has 
 shown 
 that 
 train 
 companies 
 
often 
 focus 
 on 
 getting 
 information 
 into 
 industry 
 
systems 
 but 
 rarely 
 consider 
 the 
 quality 
 and 
 
usefulness of the information actually received 
 
by passengers online 
 (including apps), on trains 
 
or at stations. 

 Our aim is to help train and 
 
station companies to think like the passengers 
 
that they serve so that appropriate information 
 
is easily available when and where it is needed. 

79.  
Therefore, 
 we 
 commissioned 
 research 
 to 
 
identify 
 what 
 currently 
 works 
 in 
 the 
 interests 
 of 
 
passengers, 
 what 
 is 
 not 
 working 
 and 
 why. 
 We 
 
sought 
 a 
 comprehensive, 
 end 
 to 
 end 
 review 
 of 
 
communication 
 and 
 information 
 flows 
 within 
 
train 
 companies 
 for 
 a 
 number 
 of 
 defined 
 case 
 
studies 
 to 
 identify 
 good 
 practice 
 and 
 potential 
 
deficiencies 
 or 
 disconnects. 
 This 
 involved 
 
considering 
 the 
 needs 
 of 
 different 
 passenger 
 
groups 
 in 
 a 
 number 
 of 
 challenging 
 scenarios, 
 
for 
 four 
 train 
 companies 
 and 
 including 
 some 
 
Network 
 Rail 
 managed 
 stations. 
80.  
From 
 these 
 studies 
 we 
 asked 
 that 
 a 
 maturity 
 
model 
 be 
 developed 
 that 
 provides 
 objective 
 
assessment 
 of 
 the 
 delivery 
 of 
 information 
 to 
 
passengers 
 at 
 each 
 stage 
 of 
 their 
 journey. 
 This 
 
model 
 should 
 also 
 allow 
 the 
 development 
 of 
 
metrics 
 that 
 can 
 form 
 an 
 information 
 dashboard 
 
for 
 each 
 train 
 company. 
 
81.  
We 
 have 
 recently 
 received 
 the 
 final 
 report 
 and 
 
will 
 now 
 discuss 
 the 
 findings 
 with 
 Network 
 Rail, 
  
train 
 companies 
 and 
 key 
 stakeholders 
 with 
 a 
 
view 
 to 
 setting 
 out 
 a 
 clear 
 strategy 
 for 
 sustained 
 
improvement 
 in 
 this 
 fundamental 
 area 
 for 
 
passengers. 

## Passenger Information Licence Investigation


 


82.  
The ORR Inquiry into the May 2018 timetable 
disruption found that information provided by Northern and GTR to its passengers was inadequate which meant that passengers were unable to plan and make their journeys with any certainty. The remit of the Inquiry did not require any consideration into whether 
Northern or GTR were in contravention of or 
had contravened their licence requirements. In October 2018, we opened two investigations into whether Northern and GTR respectively were in contravention of or contravened 
condition 4 of its Statement of National Regulatory Provisions (SNRP), namely the provision of passenger information. 
83.  
Our 
 investigations33 
 focused 
 on 
 Northern's 
 and 
 
GTR's 
 (on 
 its 
 Great 
 Northern 
 and 
 Thameslink 
 
routes) 
 duty 
 to 
 provide 
 appropriate, 
 accurate 
 
and 
 timely 
 information 
 to 
 enable 
 passengers 
 
and 
 prospective 
 passengers 
 to 
 plan 
 and 
 make 
 
their 
 journeys 
 with 
 a 
 reasonable 
 degree 
 of 
 
assurance, 
 including 
 when 
 there 
 is 
 disruption, 
 
and 
 to 
 do 
 so 
 to 
 the 
 greatest 
 extent 
 reasonably 
 
practicable 
 having 
 regard 
 to 
 all 
 relevant 
 
circumstances. 
84.  
As 
 part 
 of 
 the 
 investigations 
 we 
 considered 
 
Northern's 
 and 
 GTR's 
 provision 
 of 
 information 
 
in the lead up to the implementation of the May 
 
2018 
 timetable 
 ('pre-20 
 May 
 20'), and during the 
 
period of disruption following the introduction 
 
of the 
 20 
 May timetable 
 ('post-20 
 May'). 

85.  
A 
 high-level 
 summary 
 of 
 the 
 findings 
 and 
 
outcome 
 of 
 these 
 two 
 investigations 
 are 
 set 
 
out 
 below. 
 Further 
 information 
 about 
 the 
 
investigations 
 including 
 reports, 
 decision 
 letters 
 
and 
 penalty 
 notices 
 can 
 be 
 found 
 on 
 the 
 ORR 
 
website34. 

## Findings And Orr'S Decision - Northern



86.  
We concluded our investigations in March 
2019 and found that Northern took reasonably practicable steps to provide appropriate, accurate and timely information and therefore 
was not in breach of its passenger information 
obligations. 

 

 


87.  
We considered that pre 20-May, Northern's 
communication plan and campaign to bring the timetable change to passengers' attention was broadly successful. For the post 20-May period, we noted that following the implementation of 
the timetable there were two weeks from 20 
May to 4 June, where in many cases Northern 
passengers suffered from particularly poor information which affected their travel and journey planning. Passengers also faced disruption as a result of two RMT strike days on 
24 and 26 May. 

 
 
 
88.  
However, we found evidence to suggest that Northern took steps to provide appropriate, 
accurate and timely information to the greatest 
extent reasonably practicable having regard to the circumstances that it faced. Northern's 

 

  

 


interim timetable was introduced on 4 June, which stabilised service levels, improved performance, reduced last-minute cancellations and enabled the provision of better information to passengers (although it is widely recognised that on some routes passengers continued to experience significant disruption following this period for example on the Lakes Line). We also noted that Northern had conducted a lessons learned exercise and would be implementing its results. We therefore concluded that we would not take any further action in relation to any possible breach of Northern's SNRP. 

## Findings And Orr'S Decision - Gtr

89.  
Our investigation into GTR (on its Great 
Northern and Thameslink routes) concluded that it breached condition 4 of its GB SNRP: 
Passenger licence requirements. For the 
pre 20-May period, GTR implemented a very 
effective communication campaign to inform prospective passengers of the timetable change 
- demonstrating that they took reasonably 
practicable steps to provide appropriate, accurate and timely information to passengers. 
However, there is evidence that post 20-May 
GTR failed to achieve an appropriate balance between service recovery and the need for 
appropriate passenger information to an 
unacceptable extent and duration throughout the initial phases of its Service Recovery Plan. 

 
 
  

 

 


90.  
GTR made efforts to improve and stabilise 
services at an operational level through its 
Recovery Plan. However, the full benefit of this improvement was not felt in passenger outcomes due to the fact that as it was often not supported by appropriate, accurate or 
timely passenger information. There was a 
failure in operational decision-making to give 
adequate regard to the fact that running a train 
service or rail replacement buses is only helpful 
to passengers if they know when and where the service will arrive, where it is going and 
how long the journey will take. We considered that GTR failed to clearly communicate known cancellations in a timely manner undermining the ability of prospective passengers to plan 
ahead and make informed journey decisions. 

 

 

 

 

 

  

 


91.  
Operational 
 decisions 
 taken 
 and 
 implemented 
 
to 
 support 
 the 
 recovery 
 process 
 were, 
 in 
 
many 
 cases, 
 to 
 the 
 detriment 
 of 
 providing 
 
passengers 
 with 
 appropriate, 
 accurate 
 and 
 
timely 
 information 
 to 
 an 
 unacceptable 
 extent 
 
and 
 duration. 
 For 
 example, 
 deleting 
 trains 
 from 
 
the 
 timetable 
 rather 
 than 
 cancelling 
 services 
 
in 
 advance 
 meant 
 that 
 services 
 did 
 not 
 show 
 
as 
 cancelled 
 on 
 journey 
 planners 
 or 
 appear 
 on 
 
Customer 
 Information 
 System 
 screens 
 leaving 
 
passengers 
 uncertain 
 of 
 what 
 services 
 would 
 
run 
 each 
 day 
 as 
 travelling 
 on 
 a 
 particular 
 train 
 
one 
 day 
 was 
 no 
 guarantee 
 that 
 it 
 would 
 run 
 or 
 
be 
 shown 
 on 
 station 
 screens 
 the 
 next 
 day. 
92.  
As 
 a 
 result 
 of 
 the 
 cumulative 
 effect 
 of 
 GTR's 
 
failings 
 we 
 proposed 
 that 
 GTR 
 pays 
 a 
 £5m 
 
financial penalty for contravention of condition 
 
4 
 of its SNRP. 

 Following consideration of 
 
representations from GTR, this penalty was 
 
confirmed on 
 31 
 May 
 2019. 

 

## Next Steps

This year we will: 
 

n 
publish 
 the 
 results 
 of 
 our 
 **passenger information research**, 
 and 
 work 
 with 
 Network 
 Rail, 
 train 
 
companies 
 and 
 stakeholders 
 to 
 implement 
 the 
 findings; 
n 
publish 
 the 
 results 
 of 
 our 
 second 
 review 
 of 
 informed traveller principles monitoring 
 and 
 
update 
 the 
 regulatory statement 
 to 
 take 
 into 
 account 
 the 
 informed 
 traveller 
 principles, 
 and 
 
consider 
 whether 
 any 
 further 
 update 
 is 
 necessary 
 in 
 the 
 light 
 of 
 the 
 two 
 passenger 
 licence 
 
investigations; 
n 
continue 
 to 
 work 
 with 
 RDG 
 to 
 make 
 sure 
 that 
 the 
 industry 
 has 
 a 
 stretching 
 strategy 
 for 
 customer 
 
information, 
 has 
 revised 
 its 
 code of practice 
 and 
 is 
 delivering 
 a 
 minimum 
 standard 
 across 
 the 
 
network; 
n 
analyse, 
 and 
 take 
 any 
 necessary 
 follow-up 
 action, 
 on responses from train companies 
 regarding 
 
their 
 service 
 recovery 
 framework 
 and 
 crisis 
 management 
 plans 
 and 
 contingency 
 plans 
 to 
 support 
 
passengers 
 that 
 require 
 additional 
 assistance 
 to 
 travel; 
 and 
 
n 
work 
 closely 
 with 
 individual 
 train 
 companies 
 to 
 ensure 
 that 
 their 
 successes and innovation 
 are 
 
recognised 
 and 
 shared 
 more 
 widely 
 across 
 the 
 industry. 

## Industry Letters


 

 


93.  Following the outcome of the Northern and 
GTR investigations, we wrote to the industry 
to set out the key principles with which, even 
during periods of unprecedented disruption, they have to the greatest extent considered 
and put in place reasonable measures to meet. 
We asked train companies and Network Rail 
to provide written assurance that any service 
recovery framework and crisis management plans currently in place take adequate account 
of these key principles, and to provide a copy of their arrangements and relevant contingency plans to support passengers that require additional assistance to travel during periods of 
disruption (both planned and unplanned). 

## 3.3 Assisted Travel Introduction

94.  
Rail companies (including Network Rail and 
London Underground for the stations they 
operate on the national rail network) are 
required by the licences we issue to establish and comply with a Disabled People's Protection Policy (DPPP). We publish guidance on how they 
should write their policies, which requires them 
to set out their arrangements for providing assisted travel36 to passengers. We approve train 
companies DPPPs, monitor their compliance 
with them, and carry out research to help us 
identify areas for improvement and address 
weaknesses. 

 

 
95.  
The 
 licences 
 we 
 issue 
 also 
 require 
 that, 
 in 
 
establishing 
 a 
 DPPP 
 and 
 in 
 making 
 any 
 changes 
 
to 
 it, 
 train 
 and 
 station 
 operators 
 shall 
 have 
 "due 
 
regard" 
 to 
 the 
 Design Standards for Accessible 
Railway Stations: A Joint Code of Practice37 
 (the 
 
Code) 
 published 
 by 
 DfT 
 and 
 Transport 
 Scotland. 
 
The 
 Code 
 ensures 
 that 
 any 
 infrastructure 
 work 
 
at 
 stations 
 complies 
 with 
 European 
 or 
 national 
 
standards 
 on 
 accessibility 
 and 
 applies 
 when 
 
a 
 licence 
 holder 
 installs, 
 renews 
 or 
 replaces 
 
infrastructure 
 or 
 facilities. 
 We 
 monitor 
 licence 
 
holders' 
 compliance 
 with 
 the 
 Code. 
96. 
The 
 following 
 sections 
 report 
 on 
 our 
 work 
 
to 
 ensure 
 rail 
 companies 
 comply 
 with 
 their 
 
obligations and to further improve assisted 
 
travel. 

 

## Commitments From Last Year

97.  
In 
 last 
 year's 
 Measuring 
 Up 
 report 
 we 
 set 
 out 
 a 
 
number 
 of 
 actions 
 we 
 intended 
 to 
 take 
 during 
 
the 
 course 
 of 
 this 
 year. 
 A 
 summary 
 of 
 what 
 we 
 
did 
 in 
 relation 
 to 
 these 
 is 
 set 
 out 
 below. 
-  
We 
 said 
 that 
 we 
 would 
 work with our 
Assisted Travel Advisory Group 
 to 
 
further 
 inform 
 our 
 work 
 around 
 the 
 
development 
 of 
 revised 
 DPPP 
 guidance 
 
for 
 train 
 and 
 station 
 companies 
 in 
 how 
 to 
 
provide 
 assistance 
 to 
 passengers. 
 We 
 met 
 
with 
 the 
 Group 
 on 
 three 
 occasions 
 prior 
 
to 
 publishing 
 our 
 consultation 
 on 
 draft 
 
revised 
 guidance 
 in 
 November. 
 Further 
 
details 
 about 
 our 
 work 
 on 
 the 
 guidance 
 is 
 
set 
 out 
 below. 
 
-  
We 
 have 
 continued 
 to 
 monitor train 
companies' performance, 
 analysing 
 
core 
 data 
 returns 
 and 
 using 
 information 
 
to 
 take 
 appropriate 
 action. 
 Examples 
 are 
 
summarised 
 in 
 this 
 report. 
-  
Over 
 the 
 course 
 of 
 the 
 year 
 we 
 have 
 
reviewed and approved eight DPPPs38 
  
from 
 new 
 companies 
 and 
 where 
 material 
 
changes 
 have 
 been 
 made 
 by 
 train 
 
companies 
 to 
 existing 
 DPPPs. 

## Improving Assisted Travel - Orr'S Consultation

98.  
Securing 
 improvement 
 to 
 the 
 services 
 received 
 
by 
 disabled 
 passengers 
 is 
 an 
 important 
 area 
 of 
 
focus 
 for 
 us. 
 The 
 DPPP 
 guidance 
 is 
 an 
 important 
 
tool 
 in 
 setting 
 out 
 the 
 obligations 
 on 
 rail 
 
companies, 
 including 
 Network 
 Rail, 
 to 
 provide 
 
an 
 accessible 
 service 
 for 
 passengers. 
 However, 
 
the 
 current 
 guidance 
 was 
 last 
 published 
 in 
 
2009 
 by 
 DfT 
 and 
 so 
 needed 
 to 
 be 
 updated 
 to 
 
reflect 
 passenger 
 expectations 
 and 
 the 
 changing 
 
operating 
 practices 
 within 
 the 
 industry. 
99.  
As 
 set 
 out 
 in 
 last 
 year's 
 report, 
 in 
 2017 
 we 
 
launched 
 a 
 consultation 
 on 
 the 
 key 
 areas 
 for 
 
improvement 
 in 
 the 
 passenger 
 experience 
 
and 
 awareness 
 of 
 assisted 
 travel, 
 based 
 on 
 
the results of the extensive research we 
 
published at the same time. 

 The responses to 
 
that consultation were published in April 
 2018. 

 
We also wrote to train companies asking them 
 

what 
 progress 
 they 
 had 
 made 
 in 
 improving 
 
their 
 assisted 
 travel 
 services 
 since 
 publication 
 
of 
 our 
 research 
 and 
 what 
 immediate 
 steps 
 they 
 
planned 
 to 
 make 
 to 
 further 
 strengthen 
 their 
 
delivery. 
 We 
 published 
 this 
 letter 
 and 
 their 
 
responses 
 on 
 our 
 website.39  
100.  On 
 14 
 November 
 2018, 
 we 
 published 
 our 
 
'Improving 
 Assisted 
 Travel' 
 consultation 
 on 
 draft 
 
revised 
 DPPP 
 guidance 
 for 
 rail 
 companies.40  
This 
 consultation 
 set 
 out 
 a 
 series 
 of 
 detailed 
 
proposals 
 to 
 improve 
 the 
 experience 
 of 
 assisted 
 
travel 
 and 
 the 
 provision 
 of 
 information 
 to 
 
disabled 
 passengers. 
 These 
 proposals 
 were 
 
informed 
 by 
 work 
 with 
 our 
 Assisted 
 Travel 
 
Advisory 
 Group 
 of 
 experts 
 from 
 disability 
 
organisations, 
 industry 
 bodies, 
 passenger 
 
champions 
 and 
 franchising 
 authorities, 
 which 
 
met three times over the summer of 
 2018. 

 
We also held seven separate workshops with 
 
rail companies and disability organisations 
 
to discuss in detail revisions to the DPPP 
 
guidance, carried out station visits and met with 
 
campaigning groups to ensure we obtained a 
 
full picture of the relevant issues. 

101.  
Our 
 proposals 
 for 
 consultation 
 were: 
n 
Ensuring 
 disabled 
 people 
 are 
 involved 
 in 
 a 
 meaningful 
 way 
 in 
 the 
 development 
 and 
 delivery 
 
of 
 staff 
 training 
 and 
 the 
 development 
 and 
 review 
 of 
 policies. 
n 
Improving 
 the 
 quality 
 and 
 reliability 
 of 
 assistance 
 through 
 better 
 customer 
 information 
 
provision 
 at 
 the 
 journey 
 planning 
 and 
 booking 
 stages, 
 and 
 requiring 
 a 
 dedicated 
 assistance 
 
line 
 and 
 handover 
 protocol 
 for 
 station 
 staff. 
n 
Strengthening 
 the 
 content, 
 delivery 
 and 
 frequency 
 of 
 staff 
 training. 
n 
Reducing 
 the 
 notice 
 period 
 for 
 booking 
 assistance 
 from 
 24 
 hours 
 to 
 10pm 
 the 
 day 
 before 
 or 
 
to 
 6 
 hours 
 or 
 2 
 hours. 
n 
Ensuring 
 passengers 
 that 
 have 
 booked 
 assistance 
 can 
 easily 
 obtain 
 redress 
 when 
 things 
 go 
 
wrong. 
n 
Ensuring 
 assistance 
 can 
 be 
 provided 
 under 
 different 
 modes 
 of 
 operation 
 through 
 effective 
 
risk 
 assessment 
 and 
 mitigation, 
 flexibility 
 in 
 service 
 delivery 
 and 
 clear 
 information. 
 
n 
Revising, 
 restructuring 
 and 
 renaming 
 DPPPs 
 so 
 passengers 
 understand 
 what 
 assistance 
 
options 
 are 
 available, 
 how 
 to 
 obtain 
 them, 
 what 
 to 
 expect 
 if 
 things 
 go 
 wrong 
 and 
 where 
 to 
 get 
 
further 
 information. 
n 
Ensuring 
 passengers 
 know 
 how 
 to 
 contact 
 a 
 member 
 of 
 staff 
 at 
 any 
 station, 
 either 
 in 
 person 
 
or 
 remotely. 
n 
Improving 
 the 
 communication 
 tools 
 capable 
 of 
 being 
 used 
 for 
 booking 
 assistance. 
n 
Improving 
 the 
 service 
 for 
 passengers 
 when 
 rail 
 replacement 
 and 
 alternative 
 accessible 
 
transport 
 is 
 used. 
 
n 
Ensuring 
 clearer 
 information 
 is 
 provided 
 to 
 passengers 
 on 
 the 
 carriage 
 of 
 scooters 
 and 
 other 
 
mobility 
 aids. 
n 
Strengthening 
 how 
 companies 
 consider 
 assistance 
 provision 
 for 
 passengers 
 in 
 different 
 
operating 
 circumstances, 
 focusing 
 on 
 staff 
 availability. 
102.  The consultation closed on 15 February 2019. We will publish our summary of responses to each question, 
and individual responses on our website. At the time of writing, we are finalising the revised guidance 
which we expect to publish in July. The guidance will require DPPPs to be renamed Accessible Travel 
Policies (ATP). 

## Passenger Research

103.  It is important that when passengers seek assistance they can be confident that it will be provided. 
Therefore, this year we have continued to monitor train companies performance via independent research, which we will publish in full this summer, with passengers who have booked assistance to understand whether they received it and whether they were satisfied with it. The table below shows passenger satisfaction with booked assistance in 2018/19. 

  

 

 


Company 
Overall sample 
size 
Received all 
assistance booked 
Chiltern Railways 
100 
80% 
85% 
79% 
East Midlands 
Trains 
171 
78% 
84% 
81% 
Govia Thameslink 
Railway 
153 
70% 
83% 
79% 
Great Western 
Railway 
570 
76% 
91% 
89% 
Greater Anglia 
155 
75% 
87% 
83% 
London North 
Eastern Railway 
495 
79% 
91% 
89% 
Northern 
291 
64% 
76% 
75% 
ScotRail 
226 
76% 
84% 
83% 
South Western 
Railway 
170 
69% 
87% 
85% 
Southeastern 
83 
75% 
82% 
83% 
TfW Rail 
177 
69% 
83% 
81% 
TransPennine 
Express 
150 
79% 
90% 
89% 
Virgin Trains West 
Coast 
524 
78% 
91% 
89% 
West Midlands 
Trains 
233 
79% 
90% 
85% 
Total/average for 
train operators 
3,542 
75% 
87% 
85% 
 
Network Rail 
1,426 
76% 
89% 
86% 
 
National/Average 
4,968 
76% 
88% 
85% 
Overall 
satisfaction* 
Satisfaction with 
assistance at 
station 

## Reliability Trial

104.  The 
 results 
 of 
 the 
 research 
 above 
 show 
 that 
 
train 
 companies 
 need 
 to 
 improve 
 to 
 provide 
 
the 
 service 
 passengers 
 require. 
 Therefore, 
 we 
 
are 
 pleased 
 that 
 two 
 train 
 companies 
 - 
 SWR 
 
and 
 Northern 
 - and 
 Network 
 Rail 
 have 
 agreed 
 
to 
 take 
 part 
 in 
 a 
 trial 
 of 
 our 
 proposed 
 reliability 
 
safeguard measures designed to improve the 
 
reliability of Assisted Travel. 

 A 
 full explanation of 
 
the background to these proposals can be found 
 
in our Improving Assisted Travel consultation41. 

105.  These 
 proposed 
 measures 
 seek 
 to 
 address 
 a 
 
longstanding 
 issue 
 highlighted 
 by 
 ORR 
 research 
 
which 
 has 
 shown 
 that 
 systemic 
 informational 
 
and 
 communication 
 issues 
 as 
 a 
 result 
 of 
 
established 
 practices 
 across 
 the 
 network 
 can 
 
hinder 
 staffs' 
 ability 
 to 
 provide 
 assistance 
 
reliably 
 at 
 stations. 
 ORR 
 is 
 seeking 
 to 
 test 
 three 
 
discreet 
 yet 
 interdependent 
 changes 
 in 
 the 
 
course 
 of 
 trial 
 to 
 assess 
 their 
 effectiveness 
 at 
 
mitigating 
 these 
 issues: 
 
-  
a 
 handover 
 protocol 
 to 
 provide 
 guidance 
 
for 
 station 
 staff 
 on 
 what 
 information 
 they 
 
need 
 to 
 pass 
 on 
 to 
 the 
 next 
 station 
 when 
 
providing 
 assistance; 
 
-  
the 
 introduction 
 of 
 a 
 dedicated 
 assistance 
 
contact 
 number 
 for 
 each 
 station 
 to 
 
provide 
 a 
 dependable 
 means 
 for 
 
receiving 
 and 
 passing 
 on 
 this 
 information; 
 
and 
 
-  
the 
 introduction 
 of 
 a 
 'responsible 
 person' 
 
for 
 assistance 
 at 
 each 
 station 
 (but 
 they 
 
do 
 not 
 have 
 to 
 be 
 physically 
 present) 
 
during 
 operational 
 hours 
 to 
 enhance 
 
accountability 
 for 
 assistance 
 provision. 
1
06.  The 
 trial 
 will 
 help 
 ORR 
 evaluate 
 the 
 efficacy 
 and 
 
impact 
 of 
 these 
 proposals 
 prior 
 to 
 making 
 a 
 
decision 
 about 
 whether 
 to 
 roll 
 them 
 out 
 across 
 
the 
 network. 

## Compliance Monitoring And Action

107.  We have continued to monitor train companies' performance, analysing core data returns and using 
information we receive to take appropriate compliance action. 


Booked assistance  with % change 
108.  The table below shows that there were circa 1.3 million booked assists in 2018/19, an increase of 2% 
on the year before. 

## Volume Of Rail Passenger Booked Assistance, Great Britain, 2018-19

Volume of rail passenger booked assistance, 
Great Britain, 2018-19
Volume of booked 
assistance 
8
3
Network Rail
Great Western Railway
London North Eastern Railway
Virgin Trains West Coast
South Western Railway
ScotRail
East Midlands Trains
TfW Rail
Govia Thameslink Railway
West Midlands Trains
Northern
Greater Anglia
Southeastern
TransPennine Express
Chiltern Railways
17,068 
Merseyrail
8,677 
TfL Rail
London Overground
Other
c2c
Heathrow Express
2,071 
1,272 
1,149 
1,057 
459 

Note: Data on the volume of booked assistance requests received in each rail period is available for each train operator that manages a station. Data is therefore not available for operators that do not manage any stations. 'Other' covers smaller operators whose passengers can book assistance through the Passenger Assist system.  
Note: Data on the volume of booked assistance requests received in each rail period is available for each train operator that manages a station. Data is therefore 

Percentage
change to last 
year (%)
369,958 
2.1%
162,199 
107,820 
-2.1%
-0.4%
105,649 
-10.0%
71,779 
66,981 
-1.8%
-2.6%
63,312 
5.8%
60,443 
0.6%
57,060 
11.6%
52,555 
35.6%
47,209 
38,657 
29,625 
4.5%
7.3%
7.6%
24,270 
1.8%
11.0%
52.9% 48.1%
0.5%
15.2%
-13.1%
-1.5%

109.  We have also continued to monitor train companies compliance with their DPPPs, acted upon the 
complaints we have received directly from consumers and other stakeholders, and followed up where 
issues have been raised via social media. Examples of this activity are shown below. 

## South Western Railway (Swr) And Northern - Providing Assistance To Passengers

In March 2019, we wrote to SWR and Northern regarding our concerns that the ongoing level of reliability of service for passengers who require assistance at their stations is currently below that which passengers and we expect. This was based on our survey of passengers using Assisted Travel, which indicated the proportion of passengers reporting they had not received the assistance they booked was higher than the national average. 


We asked SWR and Northern to explain the reasons for the shortfall in performance, together with the steps they plan to take to improve the reliability of the assistance provided to passengers at stations and on-board trains to achieve the necessary compliance with requirements. 


SWR noted that its own monitoring of the large number of assistance requests it received suggested a significant number of assistance failures were due to passengers not arriving or arriving too late for their booked assistance. It also highlighted the constraints on staff in receiving live information when travel plans change. Northern noted the small number of complaints received compared to the large number of requests for assistance it received. 


 

 

 
 

It is important that passengers can rely on the assistance they have booked being provided and can travel with confidence. We therefore intend to meet with each company shortly to better understand how they ensure as far as possible that assistance is provided. 

  

 
 

## Gtr - 'Pit Stop' Document


 
In June 2018, GTR's internal 'Pit Stop' document, produced for station staff to ensure safe and punctual departure of trains, was published in the media. 


 

 

 

Upon publication, ORR sought clarification on a number of issues. GTR confirmed that the document was produced for station staff to ensure safe and punctual departure of trains and was not a training manual for how to assist passengers with reduced mobility. We received assurance that the document did not represent a change in the way passengers were assisted with their rail journeys. 


 
  

Nonetheless, GTR recognised that the wider circumstances of the need to assist passengers with reduced mobility could have been better reflected in the document. It produced a revised version to clarify this. 

## Great Western Railway (Gwr) - Providing Assistance At Stations

Where reasonably practicable, train companies must commit in their DPPPs to providing assistance at accessible but either partially staffed or unstaffed stations on routes where there is no second person on board the train. 


 

Concerns were raised regarding Goring & Streatley station, where a new footbridge and lifts had been installed in 2016 to provide step-free access to all platforms. The station is only staffed at peak times, and train services have no second person on board to provide assistance to passengers. ORR engaged with GWR on the provision of assistance at Goring & Streatley and other accessible stations on routes where station staff may not be present, to assess whether this was compliant with its DPPP. 


 

 

 

 

GWR now plans to introduce mobile staff based at Reading and surrounding stations to provide assistance to passengers on Thames and Kennet Valley routes where there is no second person on board the train at accessible stations that are otherwise unstaffed or staffed only during busier times of day. We will monitor the success of this initiative for passengers. 


 

## Compliance With The Design Standards For Accessible Stations Code Of Practice

110.  Over 
 the 
 course 
 of 
 the 
 year, 
 we 
 have 
 examined 
 
111.  In 
 each 
 case 
 we 
 have 
 examined 
 what 
 work 
 
a 
 number 
 of 
 cases 
 where 
 it 
 was 
 not 
 immediately 
 
took 
 place 
 including 
 in 
 some 
 cases 
 visiting 
 the 
 
clear 
 whether 
 major 
 works 
 that 
 had 
 taken 
 
station 
 in 
 question, 
 what 
 assessments 
 were 
 
place 
 at 
 a 
 number 
 of 
 stations 
 complied 
 with 
 
made 
 of 
 the 
 need 
 to 
 comply 
 with 
 the 
 relevant 
 
the 
 standards 
 set 
 out 
 in 
 the 
 Code 
 or 
 whether 
 a 
 
Code 
 standards, 
 and 
 whether 
 a 
 dispensation 
 
dispensation 
 or 
 derogation 
 from 
 DfT 
 from 
 those 
 
or 
 derogation 
 was 
 applied 
 for 
 from 
 the 
 DfT 
 
standards 
 had 
 been 
 sought. 
 The 
 Railways 
 Act 
 
and 
 subsequently 
 received 
 or 
 refused. 
 The 
 
1993 
 permits 
 ORR 
 to 
 take 
 enforcement 
 action 
 
following 
 table 
 is 
 an 
 overview 
 of 
 these 
 cases. 
 
in 
 cases 
 where 
 the 
 non-compliance 
 occurred 
 no 
 
Where 
 applicable 
 we 
 will 
 monitor 
 progress 
 to 
 
more 
 than 
 two 
 years 
 previously. 
  
ensure 
 these 
 improvements 
 are 
 delivered 
 for 
 
 
passengers. 

| Issue          | Outcome    | Station    | Operator    |
|----------------|------------|------------|-------------|
| out by         |            |            |             |
| Barnt          | West       |            |             |
|                |            |            |             |
| Network        |            |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| The            |            |            |             |
|                |            |            |             |
| provision      |            |            |             |
|                |            |            |             |
| Open.          | We         |            |             |
|                |            |            |             |
| have           |            |            |             |
|                |            |            |             |
| set            |            |            |             |
|                |            |            |             |
| out            |            |            |             |
|                |            |            |             |
| that           |            |            |             |
|                |            |            |             |
| a              |            |            |             |
|                |            |            |             |
| lift           |            |            |             |
|                |            |            |             |
| must           |            |            |             |
|                |            |            |             |
| be             |            |            |             |
|                |            |            |             |
| Green          | Midlands   |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| (>two          |            |            |             |
|                |            |            |             |
| years          |            |            |             |
|                |            |            |             |
| ago)           |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| lifts          |            |            |             |
|                |            |            |             |
| was            |            |            |             |
|                |            |            |             |
| not            |            |            |             |
|                |            |            |             |
| included       |            |            |             |
|                |            |            |             |
| as             |            |            |             |
|                |            |            |             |
| part           |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| the            |            |            |             |
|                |            |            |             |
| station's      |            |            |             |
|                |            |            |             |
| major          |            |            |             |
|                |            |            |             |
| footbridge     |            |            |             |
|                |            |            |             |
| works.         |            |            |             |
|                |            |            |             |
| London         | Network    |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| Network        |            |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| (>             |            |            |             |
|                |            |            |             |
| The            |            |            |             |
|                |            |            |             |
| provision      |            |            |             |
|                |            |            |             |
| Open           | .          |            |             |
|                |            |            |             |
| We             |            |            |             |
|                |            |            |             |
| have           |            |            |             |
|                |            |            |             |
| set            |            |            |             |
|                |            |            |             |
| out            |            |            |             |
|                |            |            |             |
| that           |            |            |             |
|                |            |            |             |
| a              |            |            |             |
|                |            |            |             |
| Changing       |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
| Euston         | two        |            |             |
|                |            |            |             |
| years          |            |            |             |
|                |            |            |             |
| ago)           |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| a              |            |            |             |
|                |            |            |             |
| compliant      |            |            |             |
|                |            |            |             |
| Changing       |            |            |             |
|                |            |            |             |
| Places         |            |            |             |
|                |            |            |             |
| facility       |            |            |             |
|                |            |            |             |
| was            |            |            |             |
|                |            |            |             |
| not            |            |            |             |
|                |            |            |             |
| included       |            |            |             |
|                |            |            |             |
| as             |            |            |             |
|                |            |            |             |
| part           |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| the            |            |            |             |
|                |            |            |             |
| station's      |            |            |             |
|                |            |            |             |
| toilet         |            |            |             |
|                |            |            |             |
| refurbishment. |            |            |             |
|                |            |            |             |
| Ludlow         | Transport  |            |             |
|                |            |            |             |
| for            |            |            |             |
|                |            |            |             |
| Wales          |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
| Network        |            |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| The            |            |            |             |
|                |            |            |             |
| provision      |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| lifts          |            |            |             |
|                |            |            |             |
| was            |            |            |             |
|                |            |            |             |
| not            |            |            |             |
|                |            |            |             |
| included       |            |            |             |
|                |            |            |             |
| as             |            |            |             |
|                |            |            |             |
| part           |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| the            |            |            |             |
|                |            |            |             |
| station's      |            |            |             |
|                |            |            |             |
| major          |            |            |             |
|                |            |            |             |
| footbridge     |            |            |             |
|                |            |            |             |
| works.         |            |            |             |
|                |            |            |             |
| Tilehurst      | GWR        |            |             |
|                |            |            |             |
| Network        |            |            |             |
|                |            |            |             |
| Rail           |            |            |             |
|                |            |            |             |
| (>             |            |            |             |
|                |            |            |             |
| two            |            |            |             |
|                |            |            |             |
| years          |            |            |             |
|                |            |            |             |
| ago)           |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
|                |            |            |             |
| The            |            |            |             |
|                |            |            |             |
| provision      |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| lifts          |            |            |             |
|                |            |            |             |
| was            |            |            |             |
|                |            |            |             |
| not            |            |            |             |
|                |            |            |             |
| included       |            |            |             |
|                |            |            |             |
| as             |            |            |             |
|                |            |            |             |
| part           |            |            |             |
|                |            |            |             |
| of             |            |            |             |
|                |            |            |             |
| the            |            |            |             |
|                |            |            |             |
| station's      |            |            |             |
|                |            |            |             |
| major          |            |            |             |
|                |            |            |             |
| footbridge     |            |            |             |
|                |            |            |             |
| works.         |            |            |             |
|                |            |            |             |

 

 


installed to achieve compliance with the 
relevant Code standards. Network Rail is 
currently exploring funding options with DfT 
to deliver this in CP6. 
 
We will continue to monitor progress and hold Network Rail to account for securing funding and completion of the works. 

 

 


Places facility must be provided to achieve 
compliance with the relevant Code 
standards. Network Rail has committed to 
securing funding for the installation of a Changing Places facility during the first three 
years of CP6. We will continue to monitor progress and obtain a more detailed timeline for securing funding and completion of the works. 

 


Closed. Further investigation carried out by 
ORR confirmed the type of work completed 
did not require the application of the Code of Practice. The station is however confirmed to receive Access for All Funding 
in CP6. 

 

 


Open. We have set out that a lift must be 
installed to achieve compliance with the 
relevant Code standards. Network Rail is 
currently exploring funding options with DfT 
for lift installation during CP6. 
We will continue to monitor progress and hold Network Rail to account for securing funding and completion of the works. 
| Issue      | Outcome      | Station                | Operator    | Works carried    |
|------------|--------------|------------------------|-------------|------------------|
| out by     |              |                        |             |                  |
| Kidbrooke  | Southeastern |                        |             |                  |
|            |              |                        |             |                  |
| Network    |              |                        |             |                  |
|            |              |                        |             |                  |
| Rail       |              |                        |             |                  |
|            |              |                        |             |                  |
| (>         |              |                        |             |                  |
|            |              |                        |             |                  |
| The        |              |                        |             |                  |
|            |              |                        |             |                  |
| provision  |              |                        |             |                  |
|            |              |                        |             |                  |
| Open       | .            | We are seeking further |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
| & Sidcup   | two          |                        |             |                  |
|            |              |                        |             |                  |
| years      |              |                        |             |                  |
|            |              |                        |             |                  |
| ago)       |              |                        |             |                  |
|            |              |                        |             |                  |
| of         |              |                        |             |                  |
|            |              |                        |             |                  |
| lifts      |              |                        |             |                  |
|            |              |                        |             |                  |
| was        |              |                        |             |                  |
|            |              |                        |             |                  |
| not        |              |                        |             |                  |
|            |              |                        |             |                  |
| included   |              |                        |             |                  |
|            |              |                        |             |                  |
| as         |              |                        |             |                  |
|            |              |                        |             |                  |
| part       |              |                        |             |                  |
|            |              |                        |             |                  |
| of         |              |                        |             |                  |
|            |              |                        |             |                  |
| the        |              |                        |             |                  |
|            |              |                        |             |                  |
| station's  |              |                        |             |                  |
|            |              |                        |             |                  |
| major      |              |                        |             |                  |
|            |              |                        |             |                  |
| footbridge |              |                        |             |                  |
|            |              |                        |             |                  |
| works.     |              |                        |             |                  |
|            |              |                        |             |                  |
| Eltham     | Southeastern |                        |             |                  |
|            |              |                        |             |                  |
| Network    |              |                        |             |                  |
|            |              |                        |             |                  |
| Rail       |              |                        |             |                  |
|            |              |                        |             |                  |
| (TBC)      |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
|            |              |                        |             |                  |
| As         |              |                        |             |                  |
|            |              |                        |             |                  |
| part       |              |                        |             |                  |
|            |              |                        |             |                  |
| of         |              |                        |             |                  |
|            |              |                        |             |                  |
| platform   |              |                        |             |                  |
|            |              |                        |             |                  |
| extension  |              |                        |             |                  |
|            |              |                        |             |                  |
| works,     |              |                        |             |                  |
|            |              |                        |             |                  |
| tactile    |              |                        |             |                  |
|            |              |                        |             |                  |
| paving     |              |                        |             |                  |
|            |              |                        |             |                  |
| was        |              |                        |             |                  |
|            |              |                        |             |                  |
| only       |              |                        |             |                  |
|            |              |                        |             |                  |
| applied    |              |                        |             |                  |
|            |              |                        |             |                  |
| to         |              |                        |             |                  |
|            |              |                        |             |                  |
| the        |              |                        |             |                  |
|            |              |                        |             |                  |
| new        |              |                        |             |                  |
|            |              |                        |             |                  |
| extended   |              |                        |             |                  |
|            |              |                        |             |                  |
| part       |              |                        |             |                  |
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| of         |              |                        |             |                  |
|            |              |                        |             |                  |
| the        |              |                        |             |                  |
|            |              |                        |             |                  |
| platform,  |              |                        |             |                  |
|            |              |                        |             |                  |
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| did        |              |                        |             |                  |
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| the        |              |                        |             |                  |
|            |              |                        |             |                  |
| whole      |              |                        |             |                  |
|            |              |                        |             |                  |
| length     |              |                        |             |                  |
|            |              |                        |             |                  |
| of         |              |                        |             |                  |
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| platform.  |              |                        |             |                  |
|            |              |                        |             |                  |

## Next Steps

This 
 year 
 we 
 will: 
 
n 
publish 
 **revised ATP guidance** and 
 set 
 out 
 a 
 timetable 
 for 
 submission 
 of 
 revised 
 policies 
 for 
 ORR 
 
approval; 
 
n 
publish 
 additional guidance for operators of heritage railways, trams that run on the 
national network, and single stations. 
 As 
 licence 
 holders, 
 these 
 companies 
 are 
 required 
 to 
 
have 
 an 
 Accessible 
 Travel 
 Policy 
 but 
 we 
 recognise 
 that 
 the 
 obligations 
 that 
 can 
 reasonably 
 be 
 
placed 
 on 
 such 
 bespoke 
 operations 
 may 
 be 
 different 
 to 
 larger 
 mainline 
 companies. 
 We 
 will 
 work 
 

with 
 stakeholders 
 to 
 explore 
 what 
 these 
 obligations 
 should 
 be; 
n 
establish 
 a 
 regular 
 **forum with disabled people's organisations**, 
 to 
 include 
 users 
 of 
 assisted 
 
travel, 
 with 
 whom 
 we 
 will 
 consult 
 on 
 accessibility 
 issues; 
n 
continue 
 to 
 **monitor train companies' performance**, 
 analysing 
 core 
 data 
 returns 
 and 
 using 
 
information 
 we 
 receive 
 to 
 take 
 appropriate 
 compliance, 
 and 
 where 
 appropriate 
 enforcement 
 
action; 
 
n 
ensure 
 Network 
 Rail 
 understands 
 its 
 obligations 
 regarding 
 compliance 
 with 
 the 
 Design 
Standards for Accessible Railway Stations Code of Practice 
 when 
 it 
 does 
 work 
 at 
 stations, 
 
and 
 has 
 the 
 processes 
 in 
 place 
 to 
 ensure 
 accessibility 
 is 
 considered 
 early 
 in 
 the 
 development 
 of 
 
station 
 schemes; 
 and 
n 
monitor 
 proposals 
 for 
 station changes 
 by 
 companies, 
 local 
 authorities, 
 developers 
 and 
 other 
 
third 
 parties 
 to 
 ensure 
 they 
 comply 
 with 
 the 
 Code 
 and 
 taking 
 action 
 as 
 necessary 
 where 
 they 
 do 
 
not. 


 


clarification from both Southeastern and Network Rail regarding other access routes 
at each station to understand whether lifts 
are required, including a site visit to the 
stations. 

 


Open. Tactile paving should not cover only part of a platform length. We are currently seeking further clarification from both Southeastern and Network Rail on the original works carried out, and their plans for this station. We are also investigating similar cases elsewhere on the network and will take appropriate action in the light of our findings. 

## 3.4 Complaints And Redress Introduction


  

 

 

  


112.  When complaints arise it is important that train 
and station licence holders take prompt and efficient action to ensure that they are dealt with 
in a fair and effective way. These licence holders are required to have a Complaints Handling 
Procedure (CHP), approved by ORR, which set 
out how they will meet passengers expectations. When they fail to do so, it is important that the 
passenger has recourse to an independent means of redress. This may be through the 
Rail Ombudsman introduced this year or other 
ways such as formal delay compensation 
arrangements. 
113.  In the following section we set out some of our 
main activities in this area. 

## Commitments From Last Year

114.  In 
 last 
 year's 
 Measuring 
 Up 
 report 
 we 
 set 
 out 
 a 
 
number 
 of 
 actions 
 we 
 intended 
 to 
 take 
 during 
 
the 
 course 
 of 
 this 
 year. 
 A 
 summary 
 of 
 what 
 we 
 
did 
 in 
 relation 
 to 
 these 
 is 
 set 
 out 
 below. 
-  
We 
 published 
 documents 
 to 
 modify 
 
rail 
 companies' 
 licences 
 to 
 make 
 
membership of an Alternative Dispute Resolution (ADR) scheme mandatory. Further 
 details 
 about 
 our 
 work 
 in 
 this 
 
area 
 is 
 set 
 out 
 below. 
-  
We 
 conducted 
 research 
 to 
 review 
complaints handling in other regulated sectors where 
 they 
 have 
 an 
 ADR 
 scheme 
 
in 
 place. 
 This 
 year 
 the 
 results 
 will 
 be 
 
presented 
 to 
 train 
 companies 
 to 
 so 
 that 
 
any 
 learning 
 can 
 be 
 applied 
 to 
 the 
 rail 
 
sector, 
 and 
 published 
 on 
 our 
 website. 
-  
We 
 repeated 
 our 
 compensation 'gap' 
analysis on delay compensation 
 to 
 
understand 
 the 
 difference 
 between 
 
the 
 number 
 (and 
 value) 
 of 
 claims 
 that 
 
passengers 
 could 
 in 
 theory 
 choose 
 to 
 
make 
 for 
 compensation 
 and 
 the 
 number 
 
(or 
 value) 
 of 
 claims 
 actually 
 made. 
 Our 
 
findings 
 are 
 detailed 
 in 
 this 
 chapter. 

## Complaints Handling - Monitoring And Insight

115.  Over 
 the 
 course 
 of 
 the 
 last 
 year 
 we 
 have 
 continued 
 to 
 work 
 with 
 companies 
 to 
 improve 
 the 
 quality 
 of 
 their 
 
complaints 
 handling. 
 One 
 way 
 in 
 which 
 we 
 carry 
 this 
 out 
 is 
 via 
 our 
 monitoring 
 of 
 their 
 performance. 
 Train 
 
companies 
 submit 
 data 
 in 
 line 
 with 
 our 
 published 
 guidance. 
 We 
 held 
 a 
 workshop 
 in 
 January 
 2019 
 with 
 
industry 
 stakeholders 
 to 
 discuss 
 our 
 monitoring 
 activity 
 and 
 agree 
 updates 
 to 
 our 
 guidance. 
 To 
 ensure 
 
that 
 all 
 companies 
 are 
 meeting 
 their 
 reporting 
 obligations, 
 we 
 also 
 sought 
 written 
 confirmation 
 from 
 them 
 
that 
 the 
 data 
 provided 
 is 
 accurate. 
116.  Our 
 complaints 
 data 
 shows 
 that 
 there 
 were 
 30.1 
 complaints 
 per 
 100,000 
 journeys 
 in 
 2018-1942 
 for 
 
franchised 
 train 
 companies. 
 The 
 table 
 below 
 sets 
 out 
 the 
 complaints 
 rate 
 per 
 100,000 
 journeys 
 for 
 
2018/19 
 as 
 well 
 as 
 the 
 percentage 
 change 
 compared 
 to 
 2017/18, 
 per 
 train 
 company. 

London North Eastern Railway
Great Western Railway
64
TransPennine Express
60
CrossCountry
59
East Midlands Trains

Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database) Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database) Data tables: Complaints rate by train operating company - Table 14.9 Data tables: Complaints rate by train operating company - Table 14.9 

30
Percentage of 
Percentage point 
all complaints 
change to 2017-18 
22.4 
Punctuality/reliability 
-2.9 
9.3 
Facilities on board 
1.3 
8.3 
Sufficient room for all passengers to sit/stand 
1.0 

117.  Our data collection allows 
us to identify the main drivers of complaints in 2018/19, and to compare that data with the year before. The table opposite sets out the top five reasons for complaint, the order of which remains unchanged from 2017/18, and the percentage change. 

6.1 
Ticketing and refunds policy 
0.9 
4.5 
Other ticket buying facilities (online ticket sales) 
-1.0

118.  Train companies are required to provide a full response to 95% of complaints within 20 working days. The 
table below shows how they performed in each of the 13 rail periods for which train companies submit reports, the performance averaged over that time, together with the number of rail periods for which they were below 95%. All of these metrics are important for our data monitoring. For example, the latter metric can show how a small number of severe non-compliance can affect the average response rate for the whole year. 

Response 
Train operator 
P1 
P2 
P3 
P4 
P5 
P6 
P7 
P8 
P9 
P10 
P11 
P12 
P13
rate 
CrossCountry 
100.0% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Heathrow Express 
100.0% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Southeastern 
100.0% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Chiltern Railways 
99.9% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Govia Thameslink Railway 
99.9% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Merseyrail 
99.9% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
c2c 
99.6% ü•ü•ü•ü•ü•ü•ü•ü•ü
ü
A
•
- ü• ü• ü• ü•
East Midlands Trains 
99.0% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
West Midlands Trains 
98.4% ü•ü•ü•ü•ü•ü•ü•ü• ü• û• ü• ü• ü•
Virgin Trains West Coast 
98.1% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
TfL Rail 
97.7% ü•ü•ü•ü•ü•û•ü•û• ü• ü• ü• û• ü•
Great Western Railway 
97.0% ü•û•û•ü•ü•ü•ü•ü• ü• ü• ü• ü• ü•
Grand Central 
96.7% ü•ü•ü•ü•ü•û•ü•ü• ü• ü• ü• ü• ü•
TfW Rail 
96.3% ü•ü•ü•ü•ü•ü•ü•ü• û• û• û• ü• ü•
London North Eastern Railway 
95.3% ü•ü•û•ü•ü•ü•ü•ü• û• û• û• ü• ü•
London Overground 
94.6% ü•û•ü•ü•û•û•ü•û• û• û• ü• ü• ü•
Greater Anglia 
94.3% 
û•ü•ü•ü•ü•ü•ü•û• û• ü• ü• ü• ü•
ScotRail 
94.2% ü•ü•ü•ü•ü•ü•ü•ü• ü• ü• û• û• ü•
South Western Railway 
91.9% ü•ü•ü•ü•ü•ü•ü•ü• ü• û• û• û• ü•
Caledonian Sleeper 
88.9% ü•û•ü•û•ü•û•û•ü• û• û• ü• ü• û•
TransPennine Express 
85.6% ü•ü•ü•ü•û•û•û•û• ü• ü• ü• ü• ü•
Northern 
68.9% 
û•û•û•û•û•û•û•û• û• ü• ü• ü• ü•
Hull Trains 
60.6% 
û•û•û•û•û•û•û•û• û• û• û• û• û•
Number 
of
periods 
below 
•
95% 
0 0 0 0 0 0 0 0 1 0 3 2 1 3 4 6 3 2 3 7 4 9 
13 

## Complaints Handling - Compliance

119.  Sometimes unexpected situations occur which affect the ability of train companies to meet their 
requirements. When this happens it is important the company act swiftly to ensure that it meets the 
needs of its passengers and returns to compliance. Where we see that companies are failing to meet 
their obligations, we have an array of measures available to us to ensure that they do so. This may 
include enhanced monitoring, senior level meetings, detailed plans to return to compliance, auditing of 
complaints processes, and enforcement action. 

  

 

## Virgin Trains (Vt) - Improving And Sustaining Complaints Handling Performance

  


It is important to highlight instances where improvements have taken place and train companies have taken responsibility for ensuring that they meet the needs of their passengers. 


 

 

 

In 2017/18 VT was unable to meet its requirements to respond to 95% of complaints within 20 working days in 10 rail periods. As a result, ORR sought a detailed plan for returning to compliance, met with the company, and carried out an audit of processes. 


 

 

 

Following this, VT undertook a full and detailed review to establish where improvements could be made centred around three key areas: people; process; and technology. This lead to a recruitment drive to ensure the Customer Resolutions Centre (CRC) was better resourced with staff with the right skills, attitude and experience supported by a structured training programme and accreditation process. 

## 

The CRC was restructured and key performance indicators identified to maximise and develop performance management opportunities. Leadership roles were clearly defined; staff understood what good looked like and where they could make the positive difference by focussing on the accountabilities of their own roles and leading others towards achieving the overall vision. 


 


Finally, VT introduced a new, user friendly and innovative Customer Management System. This gives richer and more accurate data, and allows more effective planning by targeting resource to keep customer wait times short. 


 


The improvements VT has introduced has enabled it to meet the 95% requirement on complaint handling for 15 consecutive periods. 

120.  Where it is necessary to take steps beyond enhanced monitoring, we publish the action we have taken 
on our website43. We have set out below an example of the action taken to secure compliance with 
complaints handling requirements. 
   

## Northern - Failure To Respond To 95% Of Complaints In 20 Working Days


 

Our proactive monitoring of train companies complaints handling identified that Northern was not meeting its obligation to respond to 95% of complaints within 20 working days. We contacted the company to require them to explain the reasons for the failure and to provide a plan for returning swiftly to compliance, and placed them on enhanced monitoring. We also met with the company to discuss its performance. 


 

Northern explained that its complaints handling had been adversely affected by the collapse of its outsourced provider Carillion and the increased number of complaints received following the 20 May 2018 timetable change. Additional resource had been moved to the complaints function to clear the backlog which had arisen and a challenging date by when these measures would result in compliance was provided. 


Through our enhanced monitoring we noted progress to meet compliance had been negligible and followed this up with the company. Northern acknowledged that progress had been slow although the backlog had been reducing and was confident that the measures taken would swiftly achieve the necessary compliance with requirements. Northern did return to compliance as per its plan and once we were satisfied that this improvement was being sustained the enhanced monitoring became unnecessary. 

## Passenger Satisfaction With Complaints Handling

121.  In previous years' we have been able to publish 
data focussed on passengers' satisfaction with the complaints handling process, and outcome. This comparative data has helped us to identify any good practice and challenge those companies which are not performing well. However, this year changes were made to the survey methodology which we understood 
would be necessary in order to comply with 
new General Data Protection Regulations. 
This has had a substantial effect on the number of respondents to the survey with the 
result that the data cannot be relied upon as 
statistically accurate. We have now reviewed 
the methodology and made changes as a 
result which we expect will see numbers rise sufficiently for the data to be robust and able to 
be published in our next report. 

 

 

## Rail Ombudsman

122.  ADR schemes provide consumers with a 
free and independent means of complaints resolution through decisions which are binding 
on the company. Membership of an ADR scheme demonstrates to consumers a strong commitment to customer service and builds trust. Over the year, RDG continued to work 
with its members to develop and implement a voluntary ADR scheme with an independent 
ombudsman. RDG members agreed to join the voluntary ADR scheme known as the Rail Ombudsman from November 2018. 

 

 


123.  Last year we stated that we were "minded 
to" mandate membership of an ADR scheme 
through the licence six months after the start 
of a voluntary ADR scheme. We consulted on detailed proposals to do so in July 2018 setting out the reasons why this was necessary to protect dissatisfied customers. Whilst we 
welcomed the industry's proactive voluntary approach in this area, it is important that passengers have long-term access to a free, independent and binding means of redress. We therefore formally consulted on changing licences in February and, following licensees consent, we will modify licences to require membership by franchise rail companies, 
Open Access Operators and Network Rail from 
1 April 2019. All other rail companies have also consented to the licence change. We are now working with them, RDG, and the Rail 
Ombudsman to agree a sensible timescale for 
joining. 
124.  It is important that the Rail Ombudsman shares 
any learning from complaints with individual train companies as well as the wider sector to raise standards in complaints handling. We also 
look forward to seeing high quality information to enable us to see trends in complaints and 
better identify areas where our intervention may be necessary. 
  

## Delay Compensation

125.  Compensation for a delayed train journey is one way in which train companies can demonstrate that they 
have fallen short of the service the passenger expected when they purchased their ticket. This year we 
have enhanced our data monitoring to capture information about performance on delay compensation. For the first time we are able to see how quickly train companies provide compensation. 
 
  

 

Percentage of delay compensation claims answered within 20 working days by train company, Great Britain, 2018-19 
Southeastern 
London 
 Overground 
100.0% 
Heathrow 
 Express 
100.0% 
TfL 
 Rail 
100.0% 
Caledonian 
 Sleeper 
100.0% 
Merseyrail 
100.0% 
Govia 
 Thameslink 
 Railway 
100.0% 
ScotRail 
99.9% 
c2c 
99.9% 
Greater 
 Anglia 
99.6% 
TfW 
 Rail 
98.4% 
West 
 Midlands 
 Trains 
96.6% 
London 
 North 
 Eastern 
 Railway 
96.4% 
Grand 
 Central 
96.2% 
Chiltern 
 Railways 
96.1% 
South 
 Western 
 Railway 
95.4% 
Northern 
93.3% 
CrossCountry 
93.2% 
 West 
 Coast 
91.2% 
 Midlands 
87.2% 
100.0% 


 

  


126.  Our analysis of this data has enabled us to focus on those train companies which have faced difficulties 
processing claims within the aim set out in the National Rail Conditions of Travel to do so within a month 
(20 working days). As with our approach to when there are failures in complaints handling, we want to 
understand the reasons for the failure in performance and ensure that there is a clear and robust plan for 
improvement. 

## Transpennine Express (Tpe) - Delays In Processing Delay Compensation Claims


 


We wrote to TPE in February 2019 as our compliance monitoring data indicated that TPE had processed an average of 45.7% of compensation claims in rail periods 1-7 2018/19, and that TPE's most recent period data showed no improvement in performance. We asked TPE to explain the reasons for the shortfall in performance and also to provide a detailed, clear and achievable plan for improvement to both meet and remain within the timescales set out in the National Rail Conditions of Travel for compensation. 


 

 

 


In its response TPE explained that a backlog in some delay claims had accumulated following the May 
2018 timetable change. A review involving internal stakeholders and supply partners had been carried out, and areas for improvement identified in reporting and financial processes. A new process for approving delay claims had also been introduced. 

 
  

 

 


TPE sought a meeting with us to explain the challenges it faced and the specific actions it had taken to improve both in the short-term and longer-term. These had resulted in significant improvements in performance which are being sustained. 

127.  Our new monitoring data also allows us to see for the first time the percentage of delay compensation 
claims train companies approve and reject. The table below illustrates the variance in performance, the 
reasons for which we will analyse further this year. 

## Compensation 'Gap'

128.  In 
 our 
 2017 
 Measuring 
 Up 
 report 
 we 
 carried 
 out 
 
a 
 review 
 of 
 the 
 proportion 
 of 
 due 
 compensation 
 
that 
 had 
 been 
 paid 
 to 
 passengers 
 (the 
 difference 
 
between 
 due 
 and 
 paid 
 compensation 
 is 
 
sometimes 
 referred 
 to 
 as 
 the 
 'compensation 
 
gap'). 
 We 
 reviewed 
 evidence 
 spanning 
 the 
 
periods 
 before 
 and 
 after 
 March 
 2016, 
 when 
 we 
 
published 
 our 
 response 
 to 
 the 
 rail 
 passenger 
 
super-complaint. 

 We concluded that over this 
 
period there had been an increase of around 
 
10 
 percentage points in the proportion of due 
 
compensation that has been paid to passengers. 

129.  As 
 part 
 of 
 this 
 year's 
 report 
 we 
 have 
 carried 
 out 
 
a 
 review 
 of 
 the 
 evidence 
 on 
 the 
 compensation 
 
gap 
 that 
 has 
 become 
 available 
 since 
 we 
 
published 
 our 
 2017 
 report. 
 The 
 evidence 
 
suggests 
 that 
 the 
 proportion 
 of 
 compensation 
 
that 
 is 
 paid 
 has 
 remained 
 fairly 
 steady 
 over 
 
this period. 

 Whilst survey evidence 
 (for DR30 
 
schemes) 
 published by DfT/Transport Focus 
 

## Next Steps

This year we will: 

n 
present 
 our 
 research 
 on 
 **reviewing complaints handling in other regulated sectors** where 
 they 
 
have 
 an 
 ADR 
 scheme 
 in 
 place 
 to 
 train 
 companies 
 so 
 that 
 any 
 learning 
 can 
 be 
 applied 
 to 
 the 
 rail 
 
sector, 
 and 
 publish 
 the 
 research 
 on 
 our 
 website; 
n 
work 
 with 
 RDG, 
 the 
 Rail 
 Ombudsman, 
 smaller 
 train 
 and 
 station 
 companies 
 to 
 agree 
 a 
 timetable 
 
which 
 will 
 mean 
 that 
 these 
 companies 
 can 
 join 
 the **Rail Ombudsman** scheme 
 in 
 an 
 orderly 
 
manner; 
 
n 
undertake 
 further 
 analysis 
 of 
 the 
 **delay compensation data**, 
 focussing 
 primarily 
 on 
 the 
 
difference 
 in 
 performance 
 of 
 train 
 companies 
 in 
 relation 
 to 
 rejection 
 rates; 
 and 
n 
take 
 forward 
 any 
 further 
 work 
 on 
 delay 
 compensation 
 resulting 
 from 
 ORR's 
 submission 
 to 
 the 
 
Williams Review. 
in October 201844 suggests a moderate rise in compensation payments over 2016 levels, our own analysis of train companies payout and performance data (based on different criteria and methodology) suggests a marginal decline since 2016-17. It remains the case, therefore, that a substantial proportion of potential payments go unclaimed, and as such that there is more work to be done in this area. The methodology for our assessment is set out in annex B. 


 

 

 

 

 

## Williams Review

130. We have published today our response to 
the Williams Review. It asked ORR to consider 
what more can be done to make it easier for 
customers to access the compensation they are 
entitled to, advise on what more could be done 
by rail operators to improve this, and whether 
more regulatory powers are required to ensure 
that it happens. 
 
  

 

 

## 4. Network Rail Introduction

131.  Network 
 Rail 
 owns 
 and 
 operates 
 the 
 national 
 
rail 
 network. 
 This 
 includes 
 the 
 track 
 and 
 related 
 
infrastructure, 
 and 
 20 
 of 
 Britain's 
 largest 
 and 
 
busiest 
 stations. 
 Of 
 these 
 20 
 stations, 
 11 
 are 
 
in 
 London 
 including 
 Clapham 
 Junction 
 and 
 
Guildford 
 which 
 Network 
 Rail 
 started 
 managing 
 
from 
 1 
 April 
 2018. 
 The 
 key 
 passenger 
 facing 
 
obligations 
 that 
 apply 
 to 
 Network 
 Rail 
 fall 
 within 
 
its 
 station 
 licence45 
 and 
 therefore 
 relate 
 to 
 
the 
 stations 
 it 
 manages 
 (although 
 its 
 network 
 
licence46 
 also 
 includes 
 obligations 
 around 
 
passenger 
 information). 
132.  These 
 passenger 
 facing 
 obligations 
 require 
 
Network 
 Rail 
 to: 
-  
cooperate, 
 as 
 necessary, 
 with 
 train 
 
companies 
 to 
 enable 
 them 
 to 
 provide 
 
appropriate, 
 accurate 
 and 
 timely 
 
information 
 to 
 enable 
 passengers 
 to 
 
plan 
 and 
 make 
 their 
 journeys 
 with 
 
a 
 reasonable 
 degree 
 of 
 assurance, 
 
including 
 when 
 there 
 is 
 train 
 service 
 
disruption 
 (Condition 
 3 
 of 
 Network 
 Rail's 
 
station 
 licence); 
-  
establish 
 and 
 comply 
 with 
 a 
 Disabled 
People's Protection Policy (DPPP) 
 which 
 
sets 
 out 
 the 
 arrangements 
 by 
 which 
 
Network 
 Rail 
 will 
 protect 
 the 
 interests 
 of 
 
rail 
 users 
 who 
 are 
 disabled 
 in 
 their 
 use 
 of 
 
managed 
 stations; 
 and 
-  
establish 
 and 
 comply 
 with 
 a 
 complaints 
handling procedure 
 (CHP) 
 relating 
 
to 
 licensed 
 activities 
 from 
 customers 
 
(Condition 
 5 
 of 
 Network 
 Rail's 
 station 
 
licence). 
 
133.  As 
 with 
 train 
 companies, 
 we 
 use 
 the 
 data 
 we 
 
collect 
 to 
 monitor 
 Network 
 Rail's 
 performance 
 
and 
 compliance 
 with 
 its 
 obligations. 

## Information For Passengers

134.  There 
 are 
 industry 
 systems 
 for 
 setting 
 
timetables 
 and 
 providing 
 passengers 
 with 
 
information. 
 The 
 System 
 Operator 
 (SO), 
 which 
 
is 
 a 
 function 
 within 
 Network 
 Rail, 
 coordinates 
 
the 
 process 
 for 
 fixing 
 a 
 base 
 timetable 
 twice 
 a 
 
year and for making short-term changes to it. 

 
The industry norm is that timetables are agreed 
 
and confirmed at least 
 12 
 weeks ahead of 
 
travel enabling train companies to open ticket 
 
reservations and bookings for passengers 
 (this 
 
is known as T-12). 

 In February 
 2018, the industry 
 
moved to shorter timescales. 

 ORR 
 conducted an 
 

investigation 
 into 
 how 
 this 
 problem 
 arose, 
 and 
 
has 
 found 
 Network 
 Rail 
 in 
 breach 
 of 
 its 
 licence. 
 
Details 
 of 
 the 
 investigation 
 and 
 outcome 
 can 
 
be 
 found 
 on 
 our 
 website47. 
 In 
 March 
 2019, 
 the 
 
SO 
 announced 
 that 
 the 
 industry 
 (except 
 GTR) 
 
has 
 been 
 able 
 to 
 return 
 to 
 the 
 standard 
 T-12 
 
timescales 
 for 
 publishing 
 timetables 
 (GTR 
 has 
 
made 
 progress 
 and 
 is 
 now 
 at 
 T-9). 
135.  As 
 noted 
 earlier 
 in 
 this 
 document, 
 the 
 initial 
 
findings 
 from 
 our 
 Inquiry48 
 into 
 the 
 May 
 2018 
 
timetable 
 change 
 highlighted 
 significant 
 
concerns 
 regarding 
 the 
 quality 
 of 
 information 
 
provided 
 to 
 passengers. 
 We 
 subsequently 
 
commissioned 
 research 
 to 
 identify 
 what 
 
currently 
 works 
 in 
 the 
 interests 
 of 
 passengers, 
 
what 
 is 
 not 
 working 
 and 
 why. 
 As 
 part 
 of 
 the 
 
case 
 studies 
 with 
 four 
 train 
 companies, 
 the 
 
research 
 examined 
 how 
 information 
 is 
 captured, 
 
managed 
 and 
 disseminated 
 to 
 passengers 
 at 
 
some 
 Network 
 Rail 
 managed 
 stations. 
 The 
 onus 
 
on 
 Network 
 Rail 
 here 
 is 
 to 
 effectively 
 cooperate 
 
with 
 train 
 companies 
 to 
 enable 
 them 
 to 
 provide 
 
good 
 quality 
 information 
 to 
 passengers 
 and 
 
prospective 
 passengers, 
 including 
 when 
 there 
 is 
 
disruption. 
136.  We 
 have 
 recently 
 received 
 the 
 final 
 report 
 and 
 
will 
 now 
 discuss 
 the 
 findings 
 with 
 Network 
 Rail, 
  
train 
 companies 
 and 
 key 
 stakeholders 
 with 
 a 
 
view 
 to 
 setting 
 out 
 a 
 clear 
 strategy 
 for 
 sustained 
 
improvement 
 in 
 this 
 fundamental 
 area 
 for 
 
passengers. 

## Assisted Travel

137.  Although 
 passengers 
 usually 
 book 
 assistance 
 via 
 the 
 relevant 
 train 
 company 
 they 
 are 
 travelling 
 with, 
 
Network 
 Rail 
 is 
 responsible 
 for 
 providing 
 assistance 
 at 
 its 
 managed 
 stations. 
 Data 
 received 
 from 
 RDG 
 (see 
 
table 
 below) 
 shows 
 there 
 were  
 369,958 
 booked 
 assistances 
 requested 
 at 
 Network 
 Rail 
 managed 
 stations 
 
in 
 2018-19, 
 an 
 increase 
 of 
 2.1% 
 compared 
 to 
 the 
 same 
 period 
 in 
 the 
 previous 
 year. 
 This 
 represents 
 29% 
 of 
 
all 
 booked 
 assistance 
 requests 
 made 
 nationally 
 in 
 2018-19. 

## Total Volume Of Assisted Journeys Booked At Network Rail Stations By Rail Period 2017-18 And 2018-19

2.1
Change on 
Network Rail received 369,958 booked 
This accounted for 29% of all booked assists 
last year 
assistance requests in 2018-19 
made nationally in 2018-19 



Source: RDG 
 
Note: A 'rail period' is normally 28 days, or four weeks, for business reporting purposes (Sunday to Saturday) and there are 13 rail periods in a financial year. 

  
 
  

 
 

138.  We continue to monitor Network Rail's accessibility provision, and have conducted site visits to major 
London stations including Paddington and Euston. Alongside the train companies, Network Rail's 
managed stations were also included in research we conducted this year to understand passenger experiences of booked assistance. The table below shows how Network Rail performed on the key measures within the research which will be published this summer. 

| Overall satisfaction    | Sample size    |
|-------------------------|----------------|
| received                |                |
| Satisfaction with       |                |
| assistance at           |                |
| station                 |                |
| Network Rail            | 1,426          |
|                         |                |
| 76%                     |                |
|                         |                |
| 89%                     |                |
|                         |                |
| 86%                     |                |

139.  As 
 noted 
 earlier 
 in 
 this 
 document, 
 the 
 
results 
 of 
 the 
 research 
 above 
 show 
 that 
 train 
 
companies 
 need 
 to 
 improve 
 to 
 provide 
 the 
 
service 
 passengers 
 require. 
 We 
 are 
 pleased 
 that 
 
Network 
 Rail, 
 alongside 
 two 
 train 
 companies 
 
- 
 SWR 
 and 
 Northern 
 - has 
 agreed 
 to 
 take 
 part 
 
in 
 a 
 trial 
 of 
 our 
 proposed 
 reliability 
 safeguard 
 
measures 
 designed 
 to 
 improve 
 the 
 reliability 
 
of 
 Assisted 
 Travel. 
 These 
 proposed 
 measures 


seek 
 to 
 address 
 a 
 longstanding 
 issue 
 highlighted
by 
 both 
 our 
 Assisted 
 Travel 
 research 
 and 
 the 
 
research 
 above. 
140.  Network 
 Rail 
 is 
 at 
 the 
 forefront 
 in 
 committing 
 
to 
 our 
 proposals 
 as 
 part 
 of 
 our 
 revised 
 
DPPP 
 guidance. 
 Particular 
 areas 
 of 
 focus 
 are 
 
significantly reducing the notice period for 
 
booked assistance, enhancing their current 
 
training package49 
 to ensure our training 
 
outcomes are met, and providing redress to 
 
passengers where booked assistance fails. 

 
We are currently working closely with key 
 
stakeholders and Network Rail to determine 
 
the exact requirements for Network Rail, to be 
 
included within our final guidance.     


Note: 'Other' category includes complaints about lost property, car parks and retail. 

 
 
Source: Network Rail 

## Complaints Handling


 

 

 


141.  This year Network Rail responded to 2,417 
complaints related to its 20 managed stations, 
which while fewer than last year, are a similar 
volume to two years ago. Station complaints 
are a small subset of all Network Rail's overall customer contacts, the vast majority of contacts 
and complaints it receives relate to areas of operations outside of its managed stations and thus outside of our scope in regulating 
how Network Rail manages complaints under 
its CHP. Therefore, the information reported here excludes contacts from consumers about 
issues such as engineering works, lineside maintenance, and vegetation or fly tipping which 
can affect those who live alongside tracks. 


142.  The chart below details the main complaints 
categories at Network Rail's managed stations. 
143.  We 
 asked 
 Network 
 Rail 
 to 
 set 
 out 
 the 
 measures 
 
it 
 had 
 taken 
 to 
 address 
 the 
 main 
 causes 
 of 
 
complaints. 
 Network 
 Rail 
 reported 
 that 
 it 
 had 
 
introduced 
 free 
 toilet 
 usage 
 at 
 managed 
 stations 
 
and 
 that 
 some 
 station 
 toilets 
 had 
 undergone 
 
refurbishment. 
 It 
 had 
 also 
 increased 
 the 
 
seating capacity at stations to help improve 
 
passenger experiences across the network. 

 
Network Rail had also reviewed its internal 
 
complaints reporting process and introduced 
 
a revised internal reporting system to help 
 
increase complaint response rates and provide 
 
station teams with insights to aid continuous 
 
improvement.  
 

144.  Licence 
 holders 
 are 
 required 
 to 
 respond 
 to 
 
95% 
 of complaints within 
 20 
 working days. 

 
Our monitoring of Network Rail's performance 
 
on complaints handling this year showed that 
 
82.4% 
 of complaints had a response within 
 20 
 
working days. 

 Whilst a relatively small number 
 
(425) 
 missed the 
 20 
 working day timescale, it 
 
is important that all licensees adhere to the 
 
regulatory requirement in this area. 

 We met 
 
with Network Rail to discuss its complaints 
 
handling performance and improvements going 
 
forwards, and it has voluntarily agreed to go on 
 
enhanced monitoring.  
 

145.  Network 
 Rail 
 is 
 operating 
 as 
 a 
 devolved 
 
business; 
 response 
 times 
 for 
 complaints 
 about 
 
managed 
 stations 
 are 
 the 
 responsibility 
 of 
 the 
 
region 
 in 
 which 
 the 
 station 
 is 
 located. 
 This 
 year 
 
Network 
 Rail 
 introduced 
 a 
 new 
 process 
 for 
 
region 
 teams 
 to 
 have 
 oversight 
 of 
 complaints 
 
about 
 its 
 managed 
 stations 
 in 
 order 
 to 
 improve 
 
response 
 times. 
 Performance 
 across 
 Network 
 
Rail's 
 regions 
 varies 
 so 
 over 
 the 
 next 
 year 
 
Network 
 Rail 
 will 
 benchmark 
 complaint 
 handling 
 
response 
 rates 
 across 
 Network 
 Rail 
 regions 
 
to 
 incentivise 
 regions 
 to 
 focus 
 on 
 improving 
 
response 
 times. 
 ORR 
 will 
 have 
 oversight 
 
of 
 Network 
 Rail's 
 region 
 data 
 and 
 will 
 have 
 
quarterly 
 performance 
 meetings 
 to 
 monitor 
 and 
 
help 
 drive 
 improvements 
 in 
 complaint 
 handling 
 
performance.  
 

146.  We worked with Network Rail to help it include 
our complaint handling survey requirement 
into its existing customer feedback processes. 
This meant that Network Rail agreed that it 
would provide us with 'equivalent data' by providing the survey outputs to us to satisfy 
our compliance reporting requirement. This 
year Network Rail received 49 responses to the survey, a number too small for the results to be sufficiently robust for publication. 

 

 

 


147.  As noted earlier in this document, we formally 
consulted on changing licences in February to 
mandate membership of the Rail Ombudsman. 
We welcome Network Rail's consent to doing so, and we will modify its licence to require membership by franchise rail companies, Open Access Operators and Network Rail from 1 
April 2019. 

 

## Annex A:  Findings By Train Company C2C

Caledonian Sleeper Chiltern Railways CrossCountry East Midlands Trains Govia Thameslink Railway Grand Central Great Western Railway Greater Anglia Heathrow Express Hull Trains London North Eastern Railway (LNER) London Overground Merseyrail Northern ScotRail South Western Railway Southeastern TfL Rail TfW Rail (Arriva Trains Wales) TransPennine Express Virgin Trains West Coast West Midlands Trains 

## Annex B: Compensation Gap Introduction

148.  In this annex we summarise recent evidence on 
the so-called 'compensation gap' - that is the difference between delay compensation that is paid out and the compensation that would be paid out if all delayed passengers exercised their right to claim. 

 
  

 

 

## Background

149.  In 
 our 
 March 
 2016 
 response 
 to 
 the 
 Which? 
 
super-complaint 
 (**2016 response report**50) 
 
and 
 July 
 **2017 Measuring Up report**51, 
 we 
 
summarised 
 a 
 range 
 of 
 evidence 
 on 
 the 
 
compensation 
 gap. 
 This 
 included: 
-  
Survey 
 evidence 
 carried 
 out 
 by 
 industry 
 
commentators, 
 obtained 
 by 
 asking 
 
eligible 
 passengers 
 whether 
 they 
 had 
 
claimed delay compensation; 
 and 

-  
The 
 results 
 of 
 'top-down' 
 analysis 
 carried 
 
out 
 by 
 ORR. 
 In 
 this 
 analysis, 
 we 
 obtained 
 
claims 
 data 
 from 
 train 
 companies 
 and 
 
compared 
 this 
 with 
 our 
 own 
 estimates 
 
of 
 the 
 number 
 of 
 passengers 
 that 
 have 
 
been subject to a delay and would qualify 
 
for compensating payouts. 

 We obtained 
 
the latter using a combination of detailed 
 
train performance data supplied by 
 
Network Rail and modelled train loadings 
 
from the MOIRA 
 forecasting model. 

## 

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150.  In our 2016 response report, we reported a 
range of compensation gap estimates available at the time that was wide and sufficiently 
uncertain to make it inappropriate for us to 
arrive at a single point estimate of the size of the 
gap. In summing up, we said: "overall it seemed fairly likely to us that… around 80% or more of potential claims go unclaimed… but … value-based estimates are suggestive of a considerably smaller compensation gap." 

|     |     |     |     |     |     |     |     |
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|     |     |     |     |     |     |     |     |
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151.  In our 2017 Measuring Up report we assessed 
the extent to which progress had been made 
since the time of the Which? super-complaint 
and the publication of our 2016 response report. We carried out this assessment on the 
basis of the (then) newer survey and top-down evidence that had become available subsequent 
to March 2016. We found that there had been 
an "increase of around 10 percentage points [from the estimates available in our 2016 response report] in the proportion of due compensation paid to passengers" and concluded that it remained 
the case that "that a substantial proportion of potential [volume-based] payouts [went] unclaimed." 
152.  This annex (**our 2019 update**) summarises 
evidence on the compensation gap that has become available since we published our 2017 
Measuring Up report, with a view to determining whether there has been further progress since the time of that publication. 

 

## Our Top-Down Methodology

153.  This 
 2019 
 update 
 closely 
 follows 
 our 
 previous 
 
approaches, 
 meaning 
 that 
 the 
 key 
 description 
 
and 
 caveats 
 set 
 out 
 in 
 the 
 2016 
 response 
 
report 
 and 
 2017 
 Measuring 
 Up 
 report 
 are 
 
equally 
 applicable. 
 The 
 principal 
 features 
 of 
 our 
 
approach 
 are 
 as 
 follows. 
-  
Unit 
 of 
 measurement 
 - 
 in 
 our 
 2016 
 
response 
 report 
 we 
 published 
 estimates 
 
calculated 
 based 
 on 
 both 
 the 
 monetary 
 
value 
 and 
 number 
 of 
 payouts. 
 As 
 in 
 our 
 
2017 
 Measuring 
 Up 
 report, 
 this 
 2019 
 
update 
 focuses 
 on 
 the 
 latter 
 measure 
 
only. 
 
i.  A 
 first 
 reason 
 for 
 this 
 was 
 to 
 facilitate 
 
comparison 
 with 
 the 
 available 
 survey 
 
estimates, 
 which 
 are 
 all 
 measured 
 in 
 
terms of number rather than value of 
 
claims. 

ii. A
  
 second 
 and 
 more 
 important 
 
reason 
 reflects 
 the 
 limitations 
 of 
 the 
 
approach used in our previous analysis, 
 
whereby we assumed that all delayed 
 
passengers had paid the average 
 
fare for the train operator they were 
 
travelling with. 

 This means that: 

1.  
 focusing 
 on 
 the 
 number 
 of 
 payouts 
 
rather 
 than 
 their 
 value 
 reduces 
 the 
 
number 
 of 
 assumptions 
 used 
 in 
 our 
 
calculations; 
 and 
2.  
 given 
 that 
 average 
 fares 
 change 
 
slowly 
 over 
 time, 
 trends 
 over 
 time 
 
in 
 volume- and 
 value-based 
 results 
 
would 
 be 
 very 
 similar. 
-  
Time 
 period 
 - 
 we 
 restrict 
 our 
 analysis 
 
to 
 data 
 from 
 rail 
 periods 
 9 
 through 
 
13 
 inclusive 
 only, 
 i.e. 
 between 
 mid-
November 
 and 
 the 
 end 
 of 
 March. 
 We 
 
followed 
 this 
 approach 
 in 
 order 
 to 
 
maximise 
 comparability 
 with 
 the 
 results 
 
published 
 in 
 our 
 2017 
 Measuring 
 Up 
 
report. 
 
-  
Range 
 of 
 estimates 
 - in 
 our 
 2016 
 response 
 
report 
 we 
 estimated 
 the 
 amount 
 of 

 
 
  
 
  
 
  

 

 

 
 
  

 

 

 

 


compensation due by assuming that 
 
train companies would be liable to pay 
 
delay compensation for all delays of 
 30 
 
minutes52 
 or more, calculated as the sum 
 
of actual minutes of delay and deemed 
 
minutes of lateness53. 

 In both our 
 2017 
 
and 
 2019 
 updates we presented figures 
 
as a range, whereby we estimate: 

i.  firstly, 
 compensation 
 due 
 calculated 
 
using 
 delay 
 minutes 
 only, 
 and 
 hence 
 
an 
 upper bound 
 for 
 the 
 proportion 
 
of 
 compensation 
 that 
 train 
 companies 
 
have 
 paid 
 out; 
 and 
ii. secondly,

compensation 
 due 
 calculated 
 
(as 
 in 
 our 
 2016 
 response 
 report) 
 as 
 
the 
 sum 
 of 
 delay 
 minutes 
 and 
 deemed 
 
minutes, 
 and 
 hence 
 a 
 lower bound 
 for 
 
the 
 proportion 
 of 
 compensation 
 that 
 
train 
 companies 
 have 
 paid 
 out; 
 and 
-  
Included 
 train 
 companies: 
i.  in 
 our 
 2017 
 Measuring 
 Up 
 report 
 we 
 
presented 
 estimates 
 which, 
 due 
 to 
 data 
 
issues, 
 excluded 
 data 
 relating 
 to 
 Govia 
 
Thameslink 
 Railway 
 (GTR); 
 and 
ii. In
  
 this 
 2019 
 update, 
 we 
 were 
 obliged 
 
to 
 exclude 
 data 
 for 
 train 
 companies 
 
that 
 employ 
 the 
 Delay 
 Repay 
 15 
 (DR15) 
 
compensation 
 scheme. 
 These 
 train 
 
companies 
 were 
 c2c, 
 GTR, 
 Northern 
 
Railway, 
 South 
 Western 
 Railway, 
 
Transport 
 for 
 Wales 
 and 
 West 
 Midlands 
 
Trains. 
 The 
 reasons 
 for 
 this 
 are 
 as 
 
follows: 
 
1.  
 The 
 need 
 to 
 maximise 
 comparability 
 
with 
 results 
 from 
 earlier 
 years. 
2.  
 Previously 
 published 
 evidence 
 
showing 
 that 
 passengers' 
 
propensity 
 to 
 claim 
 for 
 delays 
 of 
 
15-29 
 minutes 
 differs 
 from 
 that 
 
of 
 other 
 delay 
 length 
 categories.54 
 
This 
 difference 
 would, 
 other 
 things 
 
being 
 equal, 
 result 
 in 
 an 
 artificial 
 
increase 
 in 
 our 
 compensation 
 gap 
 
estimate, 
 reflecting 
 an 
 increase 
 
in 
 compensation 
 due 
 but 
 a 
 
proportionately smaller increase 
 
in claims made. 

 This is especially 
 
important in the context of the 
 
acceleration in the uptake of the 
 
DR15 
 scheme by companies. 

3.  
 Difficulties 
 in 
 separating 
 out 
 relevant 
 
and non-relevant payments in the 
 
case of companies who had moved 
 
to a DR15 
 scheme during one of our 
 
chosen data windows. 

## 2019 Findings Survey Evidence

154.  In 
 our 
 2017 
 Measuring 
 Up 
 report, 
 we 
 explained 
 
that 
 the 
 survey 
 evidence 
 that 
 had 
 become 
 
available 
 since 
 the 
 2016 
 response 
 report 
 
suggested 
 there 
 had 
 been 
 an 
 increase 
 in 
 the 
 
proportion 
 of 
 due 
 compensation 
 that 
 is 
 claimed. 
 
The 
 survey 
 evidence 
 that 
 has 
 become 
 newly 
 
available 
 since 
 the 
 publication 
 of 
 our 
 2017 
 
Measuring 
 Up 
 report 
 is 
 consistent 
 with 
 a 
 further 
 
improvement, 
 albeit 
 at 
 modest 
 levels: 
-  
For 
 DR30, 
 the 
 newest 
 available 
 survey 
 
evidence 
 by 
 DfT/Transport 
 Focus55 
 
suggests 
 that 
 39% 
 of 
 claims 
 were 
 paid 
 
out, 
 an 
 improvement 
 of 
 4 
 percentage 
 
points 
 on 
 the 
 figures 
 that 
 were 
 publicly 
 
available56 
 in 
 spring 
 2017. 
-  
For 
 DR15, 
 the 
 same 
 survey 
 found 
 a 
 claim 
 
rate 
 of 
 18%. 
 This 
 is 
 the 
 first 
 time 
 that 
 a 
 15 
 
minute 
 claim 
 threshold 
 has 
 been 
 included 
 
in 
 this 
 survey, 
 thus 
 we 
 have 
 no 
 historical 
 
comparator. 
155.  In 
 this 
 2019 
 update 
 we 
 were 
 unable 
 to 
 report 
 
on 
 results 
 from 
 Transport 
 Focus's 
 bi-annual 
 
National 
 Rail 
 Passenger 
 Survey 
 (NRPS)57, 
 
which 
 no 
 longer 
 publishes 
 information 
 on 
 the 
 
compensation 
 gap. 

## Top-Down Analysis

156.  As in previous publications, the limitations 


of our approach, together with important 
differences that exist between train companies58, mean that we have not published 
results relating to individual train companies. 
157.  Our estimated proportion of potential 


compensation claims paid out are set out in the table below. Previously published estimates are given in the shaded cells and have been 
somewhat revised due to the removal of 
companies operating DR1559. 

## Orr 'Top-Down' Analysis Results, Railway Periods 9 To 13 Inclusive

|         | Lower bound    | Upper bound    |
|---------|----------------|----------------|
| 2014-15 | 14%            | 32%            |
| 2015-16 | 19%            |                |
|         |                |                |
| 40%     |                |                |
|         |                |                |
| 2016-17 | 25%            | 57%            |
|         |                |                |
| 2017-18 | 15%            | 43%            |
| 2018-19 | 19%            |                |
|         |                |                |
| 57%     |                |                |
|         |                |                |

158.  These 
 results, 
 together 
 with 
 survey 
 results 
 
provided 
 by 
 other 
 industry 
 commentators, 
 are 
 
summarised 
 in 
 the 
 figure 
 at 
 the 
 end 
 of 
 this 
 
annex. 
159.  In 
 considering 
 the 
 extent 
 of 
 any 
 progress 
 
since 
 the 
 publication 
 of 
 our 
 2017 
 Measuring 
 
Up 
 report, 
 we 
 have 
 focused 
 on 
 the 
 difference 
 
between 
 2016/17 
 and 
 2018/19 
 results. 
 A 
 key 
 
reason 
 for 
 excluding 
 2017/18 
 from 
 any 
 direct 
 
comparisons 
 is 
 that 
 our 
 results 
 for 
 that 
 year 
 
appeared 
 to 
 be 
 materially 
 affected 
 by 
 the 
 
extreme weather events60  that occurred during 
 
rail periods 
 12 
 and 
 13 
 of 
 2017/18, a time period 
 
when our data showed passengers' 
 propensity 
 
to make delay compensation claims appeared to 
 
be anomalously low. 

160.  Our 
 analysis 
 shows 
 a 
 moderate 
 decline 
 in 
 
the 
 lower 
 bound 
 (6 
 percentage 
 points) 
 and 
 
midpoint 
 (2 
 percentage 
 points) 
 of 
 the 
 estimated 
 
claim 
 rates 
 between 
 2016-17 
 periods 
 9-13 
 and 
 
2018/19 
 periods 
 9-13, whilst the top of the 
 
range has remained steady. 

 Our results should 
 
be treated with a degree of caution for the 
 
following reasons: 

-  
Modelled 
 passenger 
 numbers 
 from 
 
MOIRA 
 may 
 not 
 reflect 
 actual 
 passenger 
 
flows. 
 It 
 is 
 not 
 possible 
 to 
 obtain 
 actual 
 
passenger 
 numbers 
 on 
 each 
 service 
 
operating 
 on 
 the 
 mainline 
 network 
 for 
 
various 
 reasons, 
 notably 
 that 
 flexible 
 
ticket 
 types 
 do 
 not 
 limit 
 passengers 
 to 
 
a 
 particular 
 service; 
 that 
 many 
 stations 
 
do 
 not 
 operate 
 ticket 
 barriers; 
 and; 
 the 
 
limited 
 current 
 use 
 of 
 smartcards. 
-  
We 
 took 
 payments 
 made 
 figures 
 
submitted 
 by 
 train 
 companies 
 in 
 good 
 
faith, 
 conducting 
 only 
 such 
 validation 
 of 
 
this 
 data 
 as 
 was 
 possible 
 using 
 previous 
 
years' 
 submissions 
 and 
 information 
 that 
 
is 
 in 
 the 
 public 
 domain. 
-  
Whilst 
 we 
 were 
 careful 
 in 
 specifying 
 the 
 
data requirement, we cannot guarantee 
 
the absence of discrepancies in the 
 
way that train companies have treated 
 
payments made data. 

 In particular, 
 
there may be differences in whether the 
 
submitted payment amounts refer to 
 
the Railway Period in which the delay/ 
cancellation was experienced, payments 
 
were made to the customer or the 
 
passenger claimed compensation. 

 It is 
 
likely that this is exacerbated by the short 
 
window of five Railway Periods used 
 
as, with a full year, these discrepancies 
 
would have affected a much smaller 
 
proportion of the data. 

-  
The 
 removal 
 of 
 train 
 companies 
 
employing 
 DR15 
 from 
 our 
 dataset 
 has 
 the 
 
consequence 
 of 
 reducing 
 the 
 number 
 of 
 
companies 
 included 
 in 
 our 
 estimation. 

## Summary And Conclusions

161.  Given 
 the 
 measurement 
 difficulties 
 summarised 
 in 
 our 
 previous 
 reports, 
 it 
 is 
 not 
 possible 
 for 
 us 
 to 
 arrive 
 
at 
 a 
 single 
 definitive 
 estimate 
 of 
 the 
 proportion 
 of 
 due 
 compensation 
 that 
 is 
 now 
 claimed 
 by 
 passengers. 
 
Nor 
 is 
 it 
 possible 
 for 
 us 
 to 
 arrive 
 at 
 a 
 definitive 
 estimate 
 of 
 the 
 extent 
 to 
 which 
 the 
 claim 
 rate 
 has 
 
improved. 
 This 
 is 
 because 
 the 
 various 
 results 
 we 
 have 
 obtained 
 using 
 were 
 in 
 a 
 number 
 of 
 cases 
 arrived 
 
at 
 using 
 different 
 methodologies. 
 We 
 are, 
 however, 
 able 
 to 
 draw 
 broad 
 conclusions 
 on 
 the 
 direction 
 of 
 
change 
 from 
 the 
 results 
 of 
 the 
 various 
 analyses 
 available 
 to 
 us. 

## Estimated Proportion Of Compensation Due That Is Paid Out (%)

162.  The 
 table 
 above 
 summarises 
 the 
 evidence 
 
e 


available 
 from 
 both 
 survey 
 and 
 our 
 top-down 
 
approaches. 
 The 
 blue 
 shaded 
 area 
 represents 
 
the 
 evidence 
 that 
 was 
 available 
 to 
 us 
 at 
 the 
 tim
of 
 and 
 included 
 in 
 our 
 previous 
 publications. 
 As
mentioned 
 above, 
 c2c, 
 GTR, 
 Northern 
 Railway, 
 
South 
 Western 
 Railway, 
 Transport 
 for 
 Wales 
 
and 
 West 
 Midlands 
 Trains 
 were 
 excluded 
 from 
 
y 
 
 
the ORR 
 top-down range estimates due to their operation of the Delay Repay 
 15 
 scheme. 

 Surve evidence encompasses all companies.61  Our finding can be summarised as follows: 

-  
Survey 
 evidence 
 suggests 
 that 
 there 
 has 
 
been 
 a 
 modest 
 improvement 
 since 
 we 
 
published 
 our 
 2017 
 Measuring 
 Up 
 report. 
 
However, 
-  
Top-down 
 analysis 
 indicates 
 that 
 there 
 
may 
 have 
 been 
 a 
 modest 
 decline 
 in 
 claim 
 
rates 
 over 
 the 
 same 
 period. 


163.  Taken together, the available evidence 
suggests that industry performance in paying out compensation claims has, for the DR30 
and Passenger Charter schemes, remained 
broadly steady between 2016-17 and 2018-
19. Ultimately, it remains the case that a substantial proportion of potential payments go unclaimed. 

## Glossary Of Terms

Alternative Dispute Resolution (ADR) - 
 refers to ways 
 
of resolving disputes between consumers and traders 
 
that do not involve going to court. 

 Common forms 
 
of ADR 
 are mediation, where an independent third 
 
party helps the disputing parties to come to a mutually 
 
acceptable outcome; 
 and arbitration, where an 
 
independent third party considers the facts and takes a 
 
decision that is often binding on one or both parties. 

Complaints Handling Procedure (CHP) - 
 train and 
 
station companies are required by their operating 
 
licences to establish and comply with a procedure for 
 
handling complaints relating to licensed activities from 
 
customers and potential customers. 

 This procedure is 
 
known as the 
 'complaints handling procedure' 
 (CHP). 

 
The CHP 
 is approved and monitored by ORR. 

Concession train companies - 
 a concession 
 
involves an agreement between government or a 
 
local authority and a train company to supply rail 
 
services. 

 The main difference from a franchise is that 
 
the train company is paid a fee to run the service 
 
rather than relying on revenue from the passengers 
 
or government subsidy. 

 Typically, revenue raised 
 
is passed back to the public body that appointed 
 
the concession. 

 Concessions are usually very tightly 
 
specified, using incentive or penalty regimes 
 (based 
 
on meeting certain targets) 
 to encourage good 
 
performance. 

 An example of a concession currently 
 
operating in the rail market is Merseyrail, which runs 
 
services for Merseytravel, the body that manages 
 
integrated transport in and around Liverpool. 

Consumer law - 
 protection in place to ensure the 
 
rights of consumers as well as fair trade, competition 
 
and accurate information in the marketplace. 

 In 
 
this document referring to The Enterprise Act 
 2002, 
 
The Consumer Rights Act 
 2015, and The Consumer 
 
Protection 
 (from Unfair Trading) 
 Regulations 
 2008. 

Department for Business, Energy and Industrial Strategy (BEIS) - 
 a ministerial department within 
 
government supported by 
 41 
 agencies and public 
 
bodies. 

 
Department for Transport (DfT) - 
 a ministerial 
 
department within government. 

Disabled People's Protection Policy (DPPP) - train and station companies are required by their 
 
operating licences to establish and comply with a 
 
Disabled People's Protection Policy 
 (DPPP), approved 
 
by ORR. 

 A 
 DPPP 
 sets out, amongst other things, the 
 
arrangements and assistance that a company will 
 
provide to protect the interests of disabled people 
 
using its services and to facilitate such use. 



Disabled Persons Transport Advisory Committee (DPTAC) - advises the government on transport legislation, regulations and guidance concerning the transport needs of disabled people, and works to ensure disabled people have the same access to transport as everyone else. 

   
 
   

 

 

 

 

 


Franchised passenger train companies - a rail franchise is a contract between government or a public authority and a train company to run services within a specified geographic area or route for an agreed period of time. Franchises are awarded through a bidding process where the franchising authority specifies the length of the franchise, service schedules and performance standards, and other requirements such as the passenger compensation scheme that it considers should be in place for passengers within that franchise. 


  


London TravelWatch (LTW) - The independent, statutory body for transport users in and around London. It is funded by the London Assembly and investigates complaints from people unhappy with the response they have received from their transport provider. 

  


MOIRA - a computer model which models the effect of timetable changes on passenger demand and passenger train operator revenue, taking into account factors such as timing and frequency of the proposed services and the location of stops. 

  

 


National Rail Conditions of Travel (NRCoT) - an agreement between a passenger and train company which applies to all domestic (non-international) 
journeys by scheduled passenger train services on the railway network of Great Britain. They set out passengers' and train companies' rights and obligations when travelling by train. 

  

 


National Rail Enquiries (NRE) - the source of customer information for all passenger rail services on the National Rail network in England, Wales and Scotland. The National Rail Enquiries website, run by RDG, includes a real-time journey planner, fares and live departure information. 


 

 

 


National Task Force (NTF) - the body through which the industry cooperated to improve performance. It brought together passenger and freight operators, Network Rail, the Office of Rail and Road and the Department for Transport. It had set three overarching national themes for attention: better timetables; 
better operations; and better assets. It has now been transferred to RDG. 

Network Rail - the national rail network (track and related infrastructure) is owned and operated by Network Rail. It derives its revenue primarily from charges levied on train operators for access to its network and stations, and from a direct financial 
'network grant' from the government. Network Rail also owns and operates 20 of Britain's largest and busiest stations - including 10 stations in London. Part 
5 of this report sets out how Network Rail is fulfilling its obligations to passengers under its station licence. 


 

 

 

 

 


Open access train companies - open access companies do not operate services under a franchise or a concession agreement but they are authorised by ORR to have access to the network on certain routes for a specified amount of time. There are currently three open access companies: Grand Central and First Hull Trains (which operate a small number of services on specified routes in competition to the franchisee on the East Coast main line) and Heathrow Express which runs services from Paddington to Heathrow Terminals. Together they represent less than 1% of passenger miles. 

  

 
 
  

 

 


Other non-franchised companies - these include heritage railways, such as those using steam locomotives, and operating as tourist attractions. 

  


Passenger Assist - the central system provided by RDG, which is used by people booking help. It means passengers are able to book assistance without having to contact more than one company. 

  

 

 


Passenger Information During Disruption (PIDD) 
- in 2012, ORR introduced a new condition on the provision of information for passengers into train company and station licences. The purpose was to ensure that passengers receive appropriate, accurate and timely information about train services so they can plan and make journeys with a reasonable degree of assurance. A code of practice was subsequently published and operators published their own local plans to show how they would comply with this. To ensure the code is delivering benefits for passengers we have worked with stakeholders to develop a list of improvement actions to ensure passengers get the information they need when services are disrupted, at the right time, and through appropriate channels. 


 

 

 

 

 


Rail Delivery Group (RDG) - ATOC (Association of Train Operating Companies) was set up in 1993, as the official voice of passenger train companies. In 2011, it was joined by the Rail Delivery Group which was responsible for policy formulation and communications on behalf of the whole rail industry. In October 2016, the single name of Rail Delivery Group was adopted to describe the two organisations. 


 


Rail Ombudsman - is an independent, not-for-profit organisation offering free, expert service to help sort out unresolved customer complaints about service providers within the rail industry. 

  


Rail Period - the rail industry reports data on a periodic basis different to the widely recognised reporting cycles such as monthly or quarterly. A 'period' is normally 28 days, or four weeks, for business reporting purposes (Sunday to Saturday) and there are 13 periods in a financial year. The length of a period may differ at the end of the financial year, 31 
March, and the beginning of the financial year, 1 April, to ensure that a break is made at 31 March. 


 

 

 
  


Ticket Vending Machine (TVM) - a machine that dispenses train tickets at railway stations, transit tickets at metro stations, and tram tickets at some tram stops and in some trams. The typical transaction consists of using the display interface to select the type and quantity of tickets and then choosing a payment method of cash, credit/debit card or smartcard. It also provides for the collection of pre­ purchased tickets. The ticket or tickets are printed and dispensed to the user. 

  

 


Train company - the term 'company' instead of 
'operator' has been used throughout this report to refer to passenger and/or station licence holders. 



Transport Focus (TF) - Transport Focus (previously Passenger Focus) is the independent transport user representative body. It is structured as an executive non-departmental public body, sponsored by DfT. Its mission is to get the best deal for passengers and road users. 


 

  

 


Transport for London (TfL) - TfL is the local government organisation responsible for most aspects of London's transport system. 

 
  


United Kingdom Regulators' Network (UKRN) - is an association of 11 regulators from the United Kingdom's utility, financial and transport sectors. The network: "fosters close working relationships between member regulators to enhance investment and efficiency for the benefit of consumers in the UK". 



The Williams Review - led by independent chair, Keith Williams was established in September 2018 to look at the structure of the whole rail industry and the way passenger rail services are delivered. The review will make recommendations for reform that prioritise passengers' and taxpayers' interests. The review's findings and recommendations will be published in a government white paper in autumn 2019. Reform will begin in 2020. 


 

## © Crown Copyright 2019

 
  


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