## 'Measuring Up' Annual Rail Consumer Report

JULY 2017 

## 'Measuring Up' Annual Rail Consumer Report July 2017 1. Measuring Up: Foreword

With rail passengers today funding three quarters of the total costs of running the railway there is rightly a very public focus on fares, value for money and the level of service and performance that passengers expect in return. An important part of our role is protecting the interests of rail users. In this report we look at the performance of Network Rail and train companies in four important areas: ticket retailing; how they provide passenger information; passenger assistance; and complaints handling and compensation. In all of these areas it's good service which makes the difference between a good experience or frustration. Providing poor help or assistance means some people could have difficulty accessing the rail network at all. All this reinforces the importance of our work to set standards in these areas, monitor whether these standards are met, and report on them. Through this we are able to drive improvements where necessary. In gathering the evidence for this report, we have found examples of both good practice on the part of the train operators and areas requiring improvement. By collecting evidence on how the industry is performing in a number of areas, we seek to highlight the instances of good practice as an example for others, while drawing attention to poor practice to seek improvement. We have found promising examples of where train companies have sought to improve services on their own initiative. For example, we found examples of good practice in providing help from train companies and asked experts to provide input on the impact of these practices, and any others which could be implemented, including from other sectors. We will now share these good practices more widely to encourage other train companies to take action.

In other areas, we saw improvement from train 
companies following ORR's own intervention. 
For example, at our request train companies and 
Network Rail have begun to provide us with more 
in-depth data, allowing us to monitor areas such 
as assistance provision and complaints handling 
in greater detail. We have agreed with companies 
they will provide us with even more data from the 
2017-18 reporting year. Our ticket machine research 
identified a number of areas of good practice where 
train companies should focus their efforts. We 
recommended that they make a price guarantee for 
these passengers; 11 train companies have done so.

There are however areas where we have found 
there has been little improvement and still much 
work to do. For example, we commissioned 
independent research on passenger satisfaction of 
how complaints are handled. We found generally 
low levels of satisfaction with both the process of 
complaints handling and the outcome achieved. This 
year we will increase our understanding of why some 
train companies are consistently performing better 
than others and will share good practices to raise 
standards in this area.

So whilst there are areas where performance is 
good, the overall picture is still mixed and as many 
passengers who use the railway regularly will 
know; there is still room for improvement. These 
challenges are only going to increase as passenger 
numbers grow - albeit at a slower rate than in 
recent years - and funding for improving the rail 
network remains tight.

## 2. Executive Summary

1.	
The Office of Rail and Road (ORR) is the combined economic and health and safety regulator for Great Britain's rail network and the economic monitor for England's strategic road network. This report covers our work for rail passengers, which derives from the passenger-facing obligations in train companies' and Network Rail's operating licences and from our consumer law role. 
2.	
Our strategic objective is to support better customer service in the specific areas that we regulate. Therefore, we focus on:
■
■Ticket retailing, specifically the ease with 
which passengers can buy tickets; 
■
■The provision of passenger information, 
including at times of disruption; 
■
■The provision of assistance to passengers 
who require additional support to make their journey; and 
■
■The provision of an accessible, effective 
and efficient complaints handling service, including providing compensation where passengers are subject to delay. 
3.	
This report demonstrates the work we are doing to recognise success and build a clear evidence base on which to press for improvement. We monitor performance over time in particular by improving the range and quality of data provided to us. We carry out targeted research to tell us what is happening in practice and through this create insights needed to effect change for rail passengers. 
4.	
The industry has continued to engage constructively with us in collecting data and carrying out research, and we have observed good practices in a number of areas. 
5.	
Throughout the report we have given examples of where we have, or intend to use this evidence base to support better customer service in the areas that we regulate. Table 1 below sets out a summary of our next steps in key areas.
 

## Ticket Retailing And Ticket Vending Machines

6.	
In the last year passenger complaints about online ticket sales, ticket booking offices or ticket vending machines, and smartcards increased to 17.5% of all complaints received (this is up from 11.5% in the previous year). In 2016 we worked with the Department for Transport (DfT), the Rail Delivery Group (RDG), *Which?*, and Transport Focus to identify actions that will improve fares and ticketing for passengers1. The resulting Action Plan is being 
implemented by train companies now and is reported against in section 4.
7.	
As part of this work we commissioned an audit of train company websites against the retail information Code of Practice2 (the 'Code'). The 
Code was designed to help improve standards for providing passengers with information when they choose, buy and use rail tickets. Overall, the audit3 found that most of the 
information that passengers are likely to need when planning journeys and buying tickets is provided on websites. However, there are exceptions to this, with some information not always being available or made suitably prominent. This specifically relates to information about:
■
■GroupSave discounts (discounts for groups 
of people travelling together);
■
■Live journey information; and
■
■Key terms and conditions.

## 8. We Have Therefore Asked Companies To Make Improvements In These Areas. We Will Undertake A Further Review Of Websites And Publish An Update In December.

9.	
In February, we also published the results of our research into passengers' experience of Ticket Vending Machines (TVMs).4 Across the 
industry the results showed that although 80% of mystery shoppers selected the most 
appropriate ticket for their journey from a TVM, one in five mystery shoppers were unable to do this. 13% of shoppers would have suffered financial detriment as a result of not selecting the cheapest fare for their journey.

10.	
Many train companies are already improving their TVMs to make them easier to use and provide better information so that the most appropriate ticket can be purchased. However, our research identified specific areas of good practice where all train companies need to take action. These include:
■
■The provision of clear, useable and timely 
information on the range of products available from TVMs; 
■
■Information about ticket restrictions and 
validities; and 
■
■Information in relation to on and off 
peak sales.
11.	
We have asked all companies what actions they have taken in light of the research findings and what further improvements they have planned. We have also recommended to train companies that they introduce a voluntary TVM price guarantee to give a refund of the additional ticket costs to passengers who find that they could have bought a cheaper ticket for the same journey. At this time 12 train companies have a TVM price guarantee in place. 
12.	
We will repeat our mystery shopping research later this year to see what improvements have been made over the last 12 months. We expect to publish the results early next year.

## Passenger Information

13.	
Since the publication of detailed research by Transport Focus5 in 2014 into rail passengers' 
experiences and needs when trains are unexpectedly disrupted, train companies and Network Rail have been working towards the delivery of 46 industry actions (such as using banners to highlight disruption information on website homepages) to improve the provision 

of information to passengers. We have 
worked with train companies, Network Rail, 
and Rail Delivery Group (RDG) to ensure the 
effective delivery of these actions. Most have 
now been delivered. We have also clarified 
the coverage of the passenger information 
licence condition with the industry to make it 
clear that the condition applies to all aspects 
of the passenger journey, including the 
provision of information regarding passenger 
compensation.

14.	
However, recent research published6 by 
RDG for the period April 2016 to March 2017 (sample of 12,690 customers) has found that the overall rating of how a train company deals with delays and cancellations is poor, with four times as many negative ratings as positive. Information provision is rated poorly, particularly when given at stations, whilst information provided by text alerts is rated best overall. The areas of information provision that most need to be looked at are: 
■
■The availability of alternative transport if the 
train service could not continue;
■
■The time taken to resolve the problem;
■
■The amount of information provided; and
■
■The frequency of updates. 
15.	
In the coming months we will establish the gaps between the current industry 
work and what actions train companies 
and Network Rail may need to prioritise to deliver improvement in each of these areas.

## Passenger Assistance

16.	
Over the past year we have been undertaking a large-scale programme of consumer research looking in depth at the provision of access and travel assistance for passengers with disabilities. This is a key area for passengers and in 2016-17, 1.2 million instances of passenger assistance were booked to help passengers complete their journey, a 4.4% increase compared to 2015-16. 
17.	
The findings of this wide-ranging research will be published in the autumn, together with a plan of our future work in this area.

## Complaints And Compensation

18.	
The complaints rate7 has increased to 29.4 
complaints per 100,000 passenger journeys for franchised companies in 2016-17. Whilst this is an increase of 7.5% when compared to 2015- 16, it is just above levels in 2014-15. Overall this represents just over 500,000 complaints for franchised operators.
19.	
Train companies are required to provide a full response to 95% of complaints within 20 working days. 12 of 24 train companies have failed to achieve this regulatory obligation consistently in 2016-17. Over the last year we have worked with train companies to gain better insight into the passenger experience of making a complaint. We commissioned an independent research company to measure passenger satisfaction over a range of indicators relating to the complaints process and outcome. 
20.	
A summary of the national results compared with individual company performance can be found in the data sheets in section 6. Overall, the survey highlights some positive aspects of complaint handling, such as the ease of making a complaint and the politeness of staff. However, while performance across the participating companies varies, it shows there is generally a greater level of passenger dissatisfaction than satisfaction with both the process of complaints handling and the outcome achieved. 
21.	
We will continue to concentrate on improving train companies' complaints handling, with a key focus on the obligation to respond to complaints within the required timescales. 
22.	
We intend to increase our understanding of why some train companies are consistently performing better than others and will be sharing more widely their good practices as a way of raising standards in this area. 
23.	
In other sectors, binding Alternative Dispute Resolution (ADR) offers a quicker and cheaper alternative to resolving individual complaints instead of having to go to the small claims court. It can strengthen consumer protection 
 
and improve consumer confidence. We welcome the discussions the Rail Minister has been leading in this area and have fed in our views of what a good ADR scheme looks like; to both support its development for passengers and make things clear and workable for train companies. 

## 24. We Will Continue To Be Proactively Involved In Discussions As Arrangements For Adr In The Rail Sector Are Further Explored.

25.	
Following our work on the rail passenger super-complaint on delay compensation,8 
train companies have improved information against the five standards we identified as good practice. Our latest mystery shopping survey showed that one third (34%) of mystery shoppers received accurate information on all four of the main elements of their customer enquiry on the arrangements and conditions for claiming compensation. This represents an improvement of 4 percentage points from 2016 for the headline measure of train company staff performance.
26.	
Based on a range of evidence we have concluded that since March 2016, when we published our response to the rail passenger super-complaint on delay compensation arrangements there has been an increase of around 10 percentage points in the proportion of due compensation that has been paid to passengers. This represents important progress, although a substantial proportion of potential payouts still goes unclaimed. 
27.	
We will now look to RDG to reflect the findings from our compensation work within the industry good practice guidelines currently under development and due to be completed in summer 2017.
28.	
We have notified train companies that we are intending to expand our current core data requirement to include key performance indicators relating to delay compensation. This will help us track the volume of delay compensation claims each train company receives, the methods used to submit claims, the speed with which they process claims, and the methods they use to pay compensation. 
29.	
The Consumer Rights Act 2015 (CRA) came fully into force in rail on 1 October 2016. It provides consumers with remedies where services are not provided to the required standard. This includes the right to a refund in the original payment method. We have worked with RDG and individual train companies to help them meet this new requirement and also to expand the range of methods by which they pay compensation for delays.
30.	
Over the coming year, we will continue to work with stakeholders to promote awareness and understanding of the CRA and its application to rail passenger services. We will also be reviewing key passenger terms and conditions in order to identify, for example, where there might be scope to improve their clarity and prominence.

## Case Studies

31.	
Finally, the 'business as usual' work we carry out day to day engaging with train companies to effect improvements for passengers is illustrated via a selection of case studies throughout this report. These are highlighted in the relevant sections below and demonstrate some of the ongoing work we do along with the outcomes for passengers. 

## Next Steps

32.	
This is our second report in this area. In our first report we set out our overall strategy and approach in carrying out our consumer role. Over the last year we have been working to implement this strategy. We will continue to recognise success and build a clear evidence base on which to press for improvements in the service passengers receive in areas such as ticket machines, complaint handling and compensation for delays. We will sharpen our focus on outcomes for passengers, ensuring that train companies and Network Rail comply with their regulatory obligations and deliver better customer service in the key areas that we regulate. Table 1 summarises some of the key actions that we will now be taking forward.
33.	
We welcome views to assist us in the development of future publications. We would be grateful for comments on the content, format and scope of this document. Responses should be sent to ConsumerObligations.Report@orr.gov.uk 
no later than 29 September 2017.

| Area                                                      | ORR next steps                                          |
|-----------------------------------------------------------|---------------------------------------------------------|
| Ticket retailing                                          | Undertake a further review of train company websites to |
| make sure that passengers can find the information they   |                                                         |
| need when planning journeys and buying tickets, and       |                                                         |
| publish an update.                                        |                                                         |
| Ticket retailing                                          | Repeat our TVM mystery shopping research to see what    |
| improvements have been made over the last 12 months.      |                                                         |
| Passenger                                                 |                                                         |
| information                                               |                                                         |
| Establish the actions train companies/Network Rail may    |                                                         |
| need to take to deliver improvements to information       |                                                         |
| provided to passengers in light of new research findings. |                                                         |
| Passenger                                                 |                                                         |
| assistance                                                |                                                         |
| Publish the findings of our wide-ranging research,        |                                                         |
| together with a plan of our future work in this area.     |                                                         |
| Complaints and                                            |                                                         |
| compensation                                              |                                                         |
| Focus on improving complaints handling with a key focus   |                                                         |
| on the obligation to respond to complaints within the     |                                                         |
| required timescales.                                      |                                                         |
| Complaints and                                            |                                                         |
| compensation                                              |                                                         |
| Increase our understanding of why some train              |                                                         |
| companies perform better than others. Share good          |                                                         |
| practices to raise standards.                             |                                                         |
| Complaints and                                            |                                                         |
| compensation                                              |                                                         |
| Continue to be proactively involved in discussions as     |                                                         |
| arrangements for ADR in the rail sector are further       |                                                         |
| explored.                                                 |                                                         |
| Complaints and                                            |                                                         |
| compensation                                              |                                                         |
| Continue to promote awareness and understanding of        |                                                         |
| the Consumer Rights Act 2015 and its application to rail  |                                                         |
| passenger services.                                       |                                                         |
| Complaints and                                            |                                                         |
| compensation                                              |                                                         |
| Expand our current core data requirement to include key   |                                                         |
| performance indicators relating to delay compensation.    |                                                         |

 

December 2017
Spring 2018
Autumn 2017 
Autumn 2017 
Ongoing 
January 2018 
Ongoing 
Ongoing 
April 2018 

## 3. Background 3.1	Our Role

34.	
The Office of Rail and Road (ORR) is the combined economic and health and safety regulator for the UK's rail network and the economic monitor for England's strategic road network. 
35.	
The rising number of rail passengers increases the importance of our role in protecting their interests. Our consumer work derives from our statutory responsibilities around consumer and competition law, and from the provisions made in train companies' and Network Rail's licences. These statutory responsibilities require us to focus on four important aspects of the customer experience that feed into our strategic objective of better rail customer service as shown in Figure 1. 
36.	
We are not responsible for setting fares, franchising train companies, or setting the level of public subsidy in the railway. Government sets these parameters. 
We are working to ensure: 

■
■**Ticket retailing** - the provision of clear, 

accurate and complete information on 
rail products and services sold through, 
for example, ticket offices, ticket vending 
machines and websites. Consumers should 
be able to choose the most appropriate ticket 
for their journey, understand how they can 
use their ticket and where necessary exercise 
their rights, for example under the National 
Rail Conditions of Travel.

■
■**Passenger information** - the provision 
of appropriate, accurate and timely information to enable railway passengers (and prospective passengers) to plan and 

make their journeys with a reasonable 
degree of assurance, including when 
there is disruption to services. In this we 
include the provision of information about 
compensation in the event of disruption 
(whether this information is given during or 
after the journey itself).

■
■**Passenger assistance** - the ability for 
passengers with a disability to make their journeys easily and confidently, whether those journeys are made on a 'turn up and go' basis or where travel assistance has been booked in advance.
■
■**Complaints and compensation** - the 

provision of an easily accessible, effective 
and efficient complaints and compensation 
service. We aim to ensure continuous 
improvements in passengers' experience 
of rail, through train and station companies 
acting on the feedback received through 
customer complaints.

37.	
Our consumer responsibilities cover the franchised train operating companies as well as a number of concession and open access train companies. In addition, Network Rail owns and operates 18 of Great Britain's largest and busiest stations - including 10 stations in London - and is subject to similar regulatory obligations as train companies in relation to passenger information, the provision of passenger assistance, and the handling of passenger complaints.
38.	
Annex A provides detail on our consumer law powers that have particular relevance to ticket retailing and passenger rights, and describes the specific regulatory obligations in train companies' and Network Rail's licences.

## 3.2	Our Approach To Regulation

39.	
We **engage** with train companies and Network Rail to seek improvement to customer service by providing guidance on what is required, challenging understanding and ensuring clarity. Our approach depends on individual circumstances but can include regulatory statements, formal guidance, the identification and sharing of best practice, and contributing to the development of codes of practice. This is in addition to the 'business as usual' work we carry out day to day, engaging with companies, illustrated via a selection of case studies throughout this report. 
40.	
We **monitor** performance over time to 
ensure there is a **clear evidence base**, in particular by improving the range and quality of data provided to us by train companies and Network Rail. We support this by targeting consumer research to tell us what is happening in practice and through this create insights to effect real change for rail passengers.
41.	
Our **analysis** enables us to strengthen 
incentives for companies to deliver better outcomes for their passengers, and by putting more information into the public domain in a systematic way we can create a clear reputational incentive for companies to deliver better customer service. We also use our evidence and analysis to strengthen our engagement with companies where it is clear that improvement and behavioural change is necessary to provide better customer service. This can include:
■
■Stakeholder workshops; 
■
■Site visits; 
■
■Use of independent auditors; 
■
■Targeted reporting from individual 
companies; and 
■
■Corrective action plans. 
 

42.	
Where an issue has not been resolved in a timely manner or if we are not satisfied with explanations or planned corrective action we can add it to our internal register of concerns which is visible to the ORR Board. This enables us to formally rate, track and record issues that if unresolved may then be subject to enforcement action. 
43.	
Where we discuss with train companies their performance or compliance with regulatory obligations, we balance the need for transparency with the need for productive engagement and investigation of potential concerns. We are committed to ensuring that our decision-making is clear and predictable and where appropriate we will publish formal correspondence (ORR letters and company responses) on such issues at an appropriate time, likely to be when we have concluded our formal consideration of the issues raised. This approach will provide useful insight for stakeholders and enable other companies to consider the issues raised and compare these to their own particular circumstances. 
44.	
Where appropriate we can also use our enforcement powers, to ensure that train companies and Network Rail comply with their licences and so work in the public interest. Our economic enforcement policy and penalties statement9 explains our policy. 
It sets out in detail what powers we have to enforce compliance with licences, the remedies available to us if licence holders are not compliant, and how we will decide whether and when to use them.
45.	
Our overall approach to carrying out our regulatory functions is set out in Figure 2 below. 

## 3.3	The Regulatory Environment

46.	
Our statutory responsibilities around consumer and competition law, and the provisions made in train companies' and Network Rail's licences shape the way we focus on passengers and the benefits we can deliver. 
47.	
Franchising involves the government setting out what it would like a rail franchise to deliver over a set period (level of service, upgrades, performance etc.). Companies then bid for the right to operate a franchise to that specification. The government selects whichever company it thinks will deliver the best overall package for the franchise and give the best value for money. Franchise agreements include details of the performance standards that franchisees must meet and arrangements for the termination of a 
quality of data provided to us by train operating companies Network 
franchise in the case of failure to meet these standards. While ORR does not have a role in specifying franchises, we work closely with the DfT, Transport Scotland, the Welsh Government, and Transport for London, as well as sub-national transport bodies, since our role interfaces with the services and obligations set out in the franchise agreements that they manage.

48.	
We also work closely with Transport Focus, the independent watchdog representing the interests of Britain's rail passengers, and with London TravelWatch, the independent, statutory watchdog for transport users in and around London. These organisations provide valuable insight and evidence on key passenger issues and through this enable further work with the industry to deliver improvement in a wide range of areas. 

## 3.4	Structure And Scope

49.	
This is our second Annual Consumer Report. Our initial report10 was an interim report and 
this is the first time that we have included a full year of monitoring data in the areas of passenger assistance and complaints handling. 
50.	
The report covers the reporting year from April 2016 to March 2017.
51.	
It is broadly structured to follow the potential passenger experience (recognising that not all passengers will require assistance or choose to make a complaint or compensation claim) and focuses on the following areas: 
■
■Ticket retailing;
■
■Passenger information;
■
■Passenger assistance; and
■
■Complaints and compensation.
52.	
We have provided separate information and data on Network Rail in section 5. The data sheets in section 6 show how each train company has performed across the key consumer areas that we regulate. We have also given examples of where we already have, or intend to use this monitoring data to work with the industry to:
■
■Identify where policy may need to be 
clarified or developed to improve outcomes 
for consumers;
■
■Understand more fully the experience of 
consumers, providing a basis for specific actions, or wider change to deliver better customer service; and
■
■Improve compliance with relevant legislation, 
licences and codes and through this ensure that consumers receive the quality and consistency of service that they expect.
 

53.	
Finally, we report on further progress on the super-complaint (Compensation arrangements in the market for passenger rail services) concerning passengers' awareness and experience of claiming compensation from train companies as a result of train delays. 
54.	
We have not included information of smaller heritage railways, charter companies or smaller station licence holders (such as Prestwick Airport). 
55.	
We are currently formulating our response to a consultation on regulation for some smaller categories of licence holder on Complaints Handling Procedures and Disabled People's Protection Policies and will reconsider their inclusion in further reports once this consultation has concluded. For this reason we report on Tyne and Wear Metro in the main report but we have not provided a data sheet in section 6, as currently Tyne and Wear Metro do not report the full core data set. 
56.	
This report does not cover ORR's role in relation to England's strategic road network. Annex G provides further detail on this aspect. 

## 4. Our Passenger Work Orr Works To Ensure Better Service On The Railways

57.	
It is important that passengers can get the information they need to help them plan their journey, choose and buy tickets, receive assistance where they need it, and redress when things go wrong.
58.	
This section sets out the work that we have undertaken across the passenger facing areas for which we are responsible. This includes licence obligations dealing with how train companies provide assistance and journey information, how they deal with complaints, and general consumer law that applies to things like the selling of tickets and passenger rights.
59.	
We have dealt with each of these in turn below. The performance of individual train companies against their licence obligations is set out in section 6.

## 4.1	Ticket Retailing Introduction

60.	
Over the last year we looked at various aspects of ticket retailing, including via ticket vending machines and websites. Here we set out the work that we have undertaken over this period to make ticket retailing easier and clearer, and why this is important for rail consumers. 

## Retail Market Review

61.	
The rail retail market has developed since privatisation with passengers now having a wider range of ways to buy tickets and more choice in what form of ticket they use. Much of this reflects the efforts the industry is making to drive innovation. Improving rail ticketing will deliver a better customer experience and also facilitate cost efficiencies for the industry. 
62.	
Government and the industry committed to deliver smart ticketing11 on the national 
rail network in England and Wales by the end of 2018. With this in mind we wanted to review the regulations, conduct, processes and systems in the retail market to consider whether they created any undue barriers to the development of ticketing and retailing for the benefit of passengers.
63.	
Our Retail Market Review was launched in February 2014 and concluded in October 2016. It involved three public consultations, two industry workshops and primary research including research on passengers' views on ticketing. 
64.	
Our full recommendations are set out in our Retail Market Review Conclusions.12 Together 
with longer term recommendations around ticketing strategy we made a number of other nearer term recommendations designed to ensure that third party retailers continue to play a full role in the market. These recommendations included:
■
■The establishment of a formal working 
group for online third party retailers;
■
■The establishment of an enhanced dispute 
mechanism to provide independent arbitration for third party retailers;
 

■
■That train companies should actively consider 
the merits of making all fares and products available to third party retailers; and 
■
■The industry should identify and address 
the barriers smaller retailers face from selling tickets.
65.	
Other recommendations relate to the industry processes through which new products are introduced and the procurement processes that can suppress the potential for innovation from providers of ticket vending machines.
66.	
Most of our nearer term recommendations have now been adopted by the industry and government. RDG has, for example, developed a more consultative approach with third party retailers in the delivery of change. A number of the other recommendations are being taken forward by way of an Action Plan for Information on Rail Fares and Ticketing, which we report on below. 

## Progress Review: Action Plan For Information On Rail Fares And Ticketing

67.	
In 2016, we worked with the Department for Transport (DfT), *Which?*, RDG and Transport Focus to identify actions that will improve fares and ticketing for passengers. The resulting Action Plan13 is being implemented now. 
68.	
These organisations have met monthly to provide oversight and to monitor progress. The Action Plan is designed to run for 12 months and has set out a series of actions in four themes.
69.	
This report is an interim update on delivery against the Action Plan objectives. There are different timescales for each separate action to be completed. 

## How You Choose Your Ticket

70.	
Work is progressing to remove jargon and provide clearer names for tickets, and definitions that passengers can understand. In May 2017, the first tranche of a phased series of changes removed and simplified over 90% of some jargon terms from TVMs, and this work-stream remains on course to complete by the end of 2017.
71.	
The action to notify customers using long distance companies' websites when Advance tickets remaining at that price are running low (fewer than nine) has been completed.
72.	
A change to online purchases to tell customers if they could get a cheaper ticket by changing their travel time was completed in May 2017. This change is being included on TVMs from July 2017. This completion date was rescheduled to align with other activities in RDG's TVM 10 Point Improvement Plan. These are outlined in the 'How you buy your ticket' section below. 

## What You Buy

73.	
The action to provide online customers with a 'plain English' explanation of the ticket they have chosen before making payment is on course to be completed in August 2017.
74.	
The Action Plan committed longer distance companies to make Advance Purchase on the Day (or 'APOD') fares available on the day in question. They were previously only available up to the night before. Since the introduction of APOD in 2014, Arriva Cross Country has sold one million of these tickets. Three additional longer distance train companies (First TransPennine Express, Virgin Trains East Coast and Virgin Trains West Coast) have now also introduced APOD. Greater Anglia and ScotRail are on course to deliver this in the summer, and East Midland Trains are on course to deliver it by late summer, completing this action.
75.	
The Action Plan committed members to take forward a small number of trials designed to simplify the fares and ticketing structure and over which they are now providing oversight. These trials will look at single-leg pricing, through ticketing, and route simplification in changing valid routes to give passengers a better understanding of what they are paying for in respect of their journey. In order to make progress on the trials, industry and DfT have established a framework that enables discussions to take place within the context of competition law. Detailed planning for the trials is underway to address technical challenges, with the expectation that these will run for around 18 months (and therefore extend beyond the life of the Action Plan). 

## Where You Buy Your Ticket

76.	
A key area of the Action Plan is opening up the ticket retail market to enable third party retailers to play a greater role. RDG has reformed its governance structure with Trainline, who represent all independent third party retailers, sitting on RDG's Retail Board. By the end of summer 2017, RDG will have enabled third party retailers to sell all permanent fares and the underpinning data needed to do this. In addition, RDG will waive the fee for access to this data. DfT has started work with recent and potential market entrants to understand their views in order to identify any changes that could further reduce barriers to entry in the retail ticket market.

## How You Buy Your Ticket

77.	
TVM improvements are another area of significant focus within the Action Plan. RDG is working with train companies and TVM suppliers to make improvements in the capabilities of current TVMs, under the TVM 10 Point Improvement Plan14. The first completed 
TVM improvement action has been to print the name of the train company on a ticket instead of a "short code" abbreviation which passengers may not have understood, for example 'Virgin Trains East Coast' instead of 'VTEC'.
78.	
Looking to the future, RDG has held a series of workshops to understand how further, more strategic, improvements to TVMs can be made. The product of these will be developed over the summer and autumn period. RDG is on track to produce an audit of the capabilities of all current TVMs in July 2017.
79.	
The Action Plan also included measures to improve the clarity of information on train company websites. As part of this work ORR undertook an audit of train company websites. The findings of this audit were published in June 2017 and are discussed further below. 
80.	
As a separate action, RDG will be undertaking quarterly reviews of train company websites and will promote best practice. In February 2017, train companies announced that railcard holders who forgot to take their railcard with them will, on the first occasion, now be able to reclaim any additional expense if they provide proof of the railcard. 
81.	
Finally, DfT has started work, including reviewing research and liaising with stakeholders such as the Disabled Persons Transport Advisory Committee, to identify what improvements could be made to the ticket buying process for disabled and vulnerable passengers.
82.	
The Action Plan final report on the progress achieved is due to be published in December 2017. 
83.	
Annex C provides an update on all of the planned actions to improve rail fares and ticketing. 

## Audit Of Websites Against The Retail Information Code Of Practice

84.	
In February 2017, we commissioned an audit of train company websites against the retail 
information Code of Practice15 (the 'Code'). The 
Code was designed to help improve standards for providing passengers with information when they choose, buy and use rail tickets. It reflects consumer law and complements industry obligations to retail fairly and impartially. 
85.	
The purpose of the audit was to evaluate train company websites against the principles set out in the Code to help understand the extent to which these websites provide the information that passengers need. The audit was an action from the Action Plan for information on rail fares and ticketing16 
that was published in December 2016 and is discussed above.
86.	
Overall, the audit carried out by independent research company Deeson,17 found that most 
of the information that passengers are likely to need when planning journeys and buying tickets is provided.
87.	
However, there were exceptions to this, with some information not always being available or suitably prominent, for example only found by hovering over a word or area or the explanation for it was behind a small (or unintuitive) icon, and some use of potentially unclear industry jargon.
 

88.	
The audit also found good practice where, for example, relevant discounts were added automatically and were clearly explained, passengers were advised when a cheaper option was available, and additional information was prominent and well sign-posted.

## Next Steps

89.	
We have written to train companies to highlight the general findings of the audit and to recommend that they review these in the context of their own websites and consider what actions they can take to improve the information they provide to passengers.
90.	
In addition to this, there are three specific issues that we think warrant immediate attention. These relate to the provision of information about:
■
■GroupSave discounts (discounts for groups 
of people travelling together);
■
■Live journey information; and
■
■Key terms and conditions.
91.	
For each of these areas we have asked train companies to confirm the issues as they relate to their website and provide details of how they intend to address them, where relevant, and the time scales for doing so.
92.	
We will also work with RDG to help develop its website best practice guidance for train companies.
93.	
We will continue to work with DfT, RDG, Transport Focus and *Which?* to monitor the delivery of other actions18 to which the industry 
has already committed, some of which relate to issues identified in the audit. These are:
■
■Reducing/explaining jargon and plain English 
ticket explanations;
■
■Identifying cheaper tickets; and
■
■Better information about terms and 
conditions.
94.	
We have asked companies to make improvements in these areas. We will undertake a further review of websites and publish an update report in December.

## Ticket Vending Machines (Tvms) Introduction

95.	
For some time there have been concerns expressed about the quality of information provided to passengers using TVMs to enable them to select the most appropriate ticket for their journey. We therefore committed in our Business Plan for 2016-17 to publish a report19 
on the information train companies provide to passengers when they are buying tickets from TVMs. As part of this we conducted mystery shopping research, and worked directly with train companies, RDG, and TVM suppliers.

## Mystery Shopping Research

96.	
721 mystery shops were carried out covering the most popular journey routes and ticket types on TVMs for each train company. Mystery shoppers were given a range of travel time and priority scenarios covering the cheapest ticket, flexibility of route or train company, and flexibility for time of return. 

## Findings

97.	
The results showed that whilst the majority of shoppers (80%) selected the most appropriate ticket for their journey from the TVM, across the industry one in five mystery shoppers were unable to do so. 7% did not select the most flexible ticket for their journey (with the majority risking a penalty fare). 13% of shoppers would have suffered financial detriment as a result of not selecting the cheapest fare for their journey.
98.	
The research also identified a number of areas of good practice where train companies should focus their efforts. These include: 
■
■*On the range of products available*, where 
many mystery shoppers did not see any information about the types of tickets that could be purchased from the TVM or that other, possibly cheaper fares might be available from the ticket office;
■
■On the information about ticket restrictions 
and validities, where many mystery shoppers could not find any information alongside ticket prices and of those that did, many found it difficult to locate; and
■
■*In relation to on and off-peak tickets*, where 
many mystery shoppers found it difficult to get information about times, could not find information about when tickets could be used, and did not understand the restrictions on travel.

## Areas For Action

99.	
It is important that rail passengers can be confident that they are paying the right amount for their ticket when making a purchase using a TVM. We therefore called upon train companies to introduce a price guarantee, refunding the additional ticket costs where a passenger finds that they could have bought a cheaper ticket for their journey. Most train companies responded positively to our recommendation, and 12 have introduced a price guarantee. 

TVM Price 
Guarantee 
Train company 
for 
passengers
Arriva Trains Wales 

https://www.arrivatrainswales.co.uk/Refunds/
Chiltern 

https://www.chilternrailways.co.uk/ticket-types-fares
c2c*
 
http://www.c2c-online.co.uk/about-us/our-policies/rightticket-right-price-commitment/
East Midlands Trains 

https://www.eastmidlandstrains.co.uk/frequently-askedquestions/#wrong-ticket
Govia Thameslink Railway 

Greater Anglia

https://www.greateranglia.co.uk/tickets-fares/ticket-vendingmachine-price-promise
Great Western Railway

https://www.gwr.com/plan-journey/tickets-railcards-andseason-tickets/ticket-types
Heathrow Express

https://www.heathrowexpress.com/faqs/ticket-faqs
London Midland 

Merseyrail

https://www.merseyrail.org/tickets-passes/refunds.aspx
Northern 

https://www.northernrailway.co.uk/faq/tickets
Scotrail*

https://www.scotrail.co.uk/about-scotrail/our-price-promise
Southeastern 

South West Trains 

Transpennine Express

http://www.tpexpress.co.uk/help/contact-us/price-promise
Virgin Trains East Coast 

https://www.virgintrainseastcoast.com/faq/ticketsbooking/#cid_9272_0__832
Virgin Trains West Coast 
 

*Note: c2c and Scotrail had a TVM Price Guarantee in place prior to publication of the ORR report in February 2017. 

 

Web link to TVM Price Guarantee 

100.	 We also wrote to RDG to ask that they set 

out what improvements they expect to be 
delivered at an individual train company 
level in the good practice areas in the next 
six months. Their response predominately 
focused on fares reform rather than ticket 
vending machines. We published this on our 
website.20 As a result we will be following up 
instead with individual train companies to 
understand what improvements they expect 
to deliver at an individual train company level 
in the good practice areas. In the meantime, 
as noted earlier, in July 2017 RDG will be 
producing an audit of the capabilities of all 
current TVMs as part of the action plan for 
information on rail fares and ticketing.

## Next Steps

101.	 We will now follow up with individual train 
companies to understand what improvements they expect to deliver in the good practice areas.
102.	 We will repeat our mystery shopping research 
to see what improvements have been made over the last 12 months. We expect to publish the results early next year.

## 4.2 Provision Of Passenger Information Introduction

103.	
Having correct and relevant information is a key requirement for those planning or making a journey. The passenger information licence condition in passenger, station and Network Rail's licences was introduced in 2012. Since then numerous initiatives to improve the provision of information have been delivered. However, in the same period, the expectations of passengers have increased. Information is now available at their fingertips, whether at home, on the train or at the station. As new technology is introduced, the industry must continue to review the services that can be provided, whilst also ensuring that the basic information at the heart of the system is correct, especially when services are disrupted. 

## Progress This Year

104.	
Last year in our first annual rail consumer report we set out the detail of work carried out under the passenger information licence condition since it was introduced. This year we focus on changes since the last report. 

## Clarification Of The Passenger Information Licence Condition

105.	
In 2012, we published guidance to support the passenger information licence condition that gave more information about what is expected and how it will be enforced. 
106.	 We updated the guidance21 in June 
2016, following a super-complaint about compensation for passengers who have been delayed. While the licence conditions did not change, we clarified that the condition applies to all parts of a passenger journey. This is discussed further in section 4.4 below.

## Revised Code Of Practice On Provision Of Information

107.	 Our licence condition on passenger 
information requires companies to publish a 
 
code of practice ('the Code') that sets out how they will deliver information to passengers, including during disruption. The Association of Train Operating Companies (now known as RDG) code of practice from July 2014, was the current version when our guidance was updated. All train companies currently follow this industry Code which is principles-based. 

108.	 During the summer of 2016, the industry 

revised its Code to reflect the stages of the 
passenger journey and include a variety 
of improvements. We recommended this 
approach to ensure that improvements to 
passenger information are embedded in the 
operating practices of companies, including 
when rail franchises change and when 
new companies enter the market. The new 
document has a wider scope including the 
need to provide information about station 
facilities, delay compensation and the use of 
station help points. The new version of the 
Code was published by RDG in October 2016.22 

109.	 A 'local plan' based on the Code sets out 
how individual train companies will provide information and is tailored to how they run their services. To ensure compliance with the passenger information licence condition we ensure that every train company has a local plan which conforms to the Code. Local plans should be published on the train company's website, along with a link to the Code itself and an annual statement of progress. We have included this information in the data sheets (in section 6), following a review of train company websites carried out in May 2017. 
110.	 Although train companies should review their 
local plans annually, few plans were updated during summer 2016 while the Code was being revised. This has resulted in some temporary non compliance. We have said that we are content for the plans to be updated as their annual review becomes due and therefore expect all train companies to have published a plan that complies with the new Code by autumn 2017. 
111.	 Network Rail has a similar licence condition 
and has published its own guidance which applies to its managed stations and regional control centres.

## Progress With Delivery Of Industry Actions

112.	 Following the Transport Focus report into 
passenger information in 2014, the industry developed a set of actions designed to address the issues Transport Focus had identified. There are 46 industry actions in total. The majority of these were due to be delivered before the end of 2017. In 2016-17, there were six actions that were due for completion and RDG told us that all have been delivered by the industry. Their full descriptions can be found in the back of the Code, listed in order of their action number, for example PIDD-01. A summary of the six actions with a March 2017 completion date are:

■
■Prominent disruption warning banners 
on websites, apps and mobile sites during disruption (PIDD-01);
■
■Integration of a real time feed into journey 
planners so that passengers cannot book onto trains that have already been cancelled (PIDD-03);
■
■Integration of a national disruption feed 
into the live information parts of company websites so that disruption information for other train companies used on a planned journey is available (PIDD-07);
■
■Manual announcements to be made during 
disruption including messages to passengers on trains from control centres (PIDD-15);
■
■Passengers should not be forced to pay 
more because of disruption (PIDD-25); and
■
■Allow train company controllers to make 
live broadcasts to passengers on trains (PIDD-39).
113.	 However, our retail code of practice audit23 

in February 2017 (see above section 4.1 
on the website audit), found that not all 
journey planners showed when services were 
disrupted. As this should have been delivered 
by actions PIDD 03 and PIDD 07 we will be 
looking again for evidence that the train 
companies have delivered these actions.

114.	 Some actions from previous years have yet to 
be delivered by all companies, often because of funding issues:
■
■List of revised reasons for delay to be 
implemented in station information screens and automated announcements (PIDD- 13B24. PIDD-13A allowed new reasons to be 
used in freeform systems such as websites and Twitter in May 2015);
■
■Removal of repeated automated apologies 
(PIDD-16); and,
■
■Changing the way the industry communicates 
suicides on the railway - use of "emergency services dealing with an incident" rather than "person hit by a train" (PIDD-50).
115.	 Of particular note has been the completion 
in 2016 of the technically complex 'Darwin25 
Customer Information Screens' project which linked station information screens and company websites to the central Darwin system for the first time - ensuring what passengers see on their phones is the same as the information at the station.

## Industry Governance

116.	 Governance of the industry's programme was 
under the National Task Force but during 2016 this was changed to RDG. Their Customer Experience During Disruption Programme has the aim that:

"Customers will receive timely, accurate and 
relevant information through the channel of their 
choice enabling them to make decisions that 
are right for them and the journey they wish to 
make. Should, for whatever reason, the customer 
require additional support to make that journey 
the industry will ensure it is resourced to assist 
and to make that journey easy."

117.	 The remaining industry actions and new 
initiatives to improve the information that passengers receive have now been divided into three workstreams:
■
■Empower customers - giving them the 
information and tools to make the right decision.
■
■Empower staff - giving them the tools and 
training to support customers when they need it.
■
■Enablers - providing a good customer 
experience during disruption through efficient processes, technology and procedures.

## Industry Research

118.	 RDG has recently published research,26 
undertaken between April 2016 and March 2017, which records the views of passengers who have experienced disruption. The overall rating of how a train company deals with delays/cancellations is poor, with four times as many negative ratings as positive. 
119.	 Information provision was rated poorly, 
particularly when given at stations. The report suggests 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 amount of information provided; and
■
■Frequency of updates.
120.	 Information provided by text alerts was bestrated overall and information provided by staff on train tended to receive more positive ratings than that given through social media, websites, apps or station departure screens. Information provided by email was also wellrated in comparison to other information sources and notably rated better than information provided by staff at stations.
 

121.	 Those passengers who receive information 
about disruptions or cancellations from departure screens at station (the primary source of information) gave relatively low ratings for all aspects.
122.	 The passenger survey remains open and a 
link27 is provided for all incidents reported on 
the National Rail Enquiries website. 
123.	 We continue to monitor the provision of 

information during disruption by focusing on 
major incidents on the network. This gives an 
opportunity to see how the train companies 
put their published plans into practice. Our 
prioritisation criteria looks not only for the 
largest number of delay minutes but also the 
impact on passengers, taking into account 
the time of day, type of passengers affected, 
local geography and whether any passengers 
were trapped on trains outside stations. 
These reviews can be shared with the train 
companies - who commit in their local plan 
to reviewing serious incidents and learning 
lessons from a passenger perspective.

## Information During Disruption At Charing Cross Station

The Code of Practice encourages companies to make use of 'disruption mode' when there is serious disruption. This means that the information screens only show trains that are known to be running and removes all the cancelled trains, so it is easier for passengers to identify those trains that are running. In March 2017, a security alert at London Bridge disrupted services in the evening peak. There were reports that during the disruption information screens at Charing Cross station were blank for a period of time. Because of the number of people affected by the disruption we undertook a review of the information provided during the incident. Network Rail had tried to implement 'disruption mode' but did so incorrectly, which meant that instead of showing trains running all of the information screens were blank and trains that did depart weren't advertised. Procedures have now been changed to ensure that correct information is given during disruption in future. 

## Next Steps

124.	 In the coming months we will establish the 
gaps between the current industry work and what actions train companies and Network Rail may need to prioritise to deliver improvement for passengers in each of these areas. We also want to see:
■
■Delivery of the remaining industry actions 
and other initiatives being developed by the industry programme; 
■
■Routine publication of RDG's passenger 
research including a breakdown of progress by train company; and
■
■Improvements for passengers delivered 
through actions published in local plans.

## 4.3 Passenger Assistance Introduction

125.	 Train companies and Network Rail need to 
comply with an operating licence condition which supports improvements in the accessibility of rail travel. We approve policies and monitor compliance with this condition: 
■
■To empower confident use of the railway 
by passengers with disabilities; and 	
■
■To promote awareness of the advice and 
help available.
126.	 This year we completed a large-scale review of 

Disabled People's Protection Policies (DPPPs) 
to make sure they comply with the standards 
for rail passengers that we expect. The 
result is that all the written policies are now 
published, available to passengers online and 
at stations, and are compliant with guidance28 
in this area. Through this process of approval 
we ensure that companies have policies that 
set out to passengers that they will receive a 
consistent level of assistance throughout their 
journey, even where this involves different 
train companies. 

127.	 This year we have collated good practices that 
we have found via our stakeholder engagement and we have consulted on these with:
■
■Industry - to check it represented all of the 
good practices in use; and 
■
■Specialist stakeholders - to provide input on 
the impact of the practices and any others which could be implemented, including from other sectors. 
128.	 We will share these practices more widely with 
companies to consider when reviewing their DPPPs annually and with DfT for consideration when creating franchise specifications in order to further our aim to empower confident use of the railways by passengers with disabilities. For example in recent franchises, DfT has begun to specify reductions to the booking time of 24 hours', and will look to procure further reductions through forthcoming franchise competitions.
 

129.	 A number of improvements to policies have 
been made following our discussions with companies during this process of approval. Our focus is now on ensuring that these written policies are consistently carried out in practice and that passengers receive the services that are outlined by train companies and Network Rail in this area. In line with our commitments to monitor performance and develop a clear evidence base, we continue to:
■
■Engage with train companies and Network 
Rail to provide clarity on what is required and to drive improvements where needed. Our work throughout the year is illustrated using case studies; 
■
■Collect core data on the: 
-	 Number of assisted journeys booked by 
passengers;
-	 Proportion of complaints concerning 
accessibility;
-	 Number of staff who undertook disability 
awareness training; and
-	 Volume of alternative accessible transport 
(such as taxis) booked by each train company.

■
■Carry out bespoke research where 
necessary to provide further insight. 
130.	 Our work in these areas is set out in more 
detail below. 

## Core Data

131.	 Providing data on performance is an important 
way in which train companies and Network Rail can demonstrate that they are complying with their regulatory obligations. 
132.	 Sometimes passengers who need assistance 

prefer to book ahead using the Passenger 
Assist system (a central system provided 
by RDG which means passengers can book 
assistance without having to contact more 
than one company). We receive data on 
assistances booked through Passenger 
Assist from RDG. This data shows a total of 
1.2 million booked assists in 2016-17, a 4.4% 
increase compared to 2015-16 (1.1 million 
booked assists).29

133.	 In contrast to this rising trend in booked 
assistances, five companies provided fewer booked assistances than last year. Companies such as Merseyrail, London Overground and TfL Rail provide a large proportion of unbooked (or 'turn up and go') assistance, which may account for their lower volumes of booked assistance. 
Source: Rail Delivery Group (RDG)

134.	 In addition to booked assists, many 
passengers also arrive without having booked assistance ahead. We refer to this as unbooked assistance or 'turn up and go' and we intend to measure this in future. This will help us to understand the overall volume of assists that happen and over time to assess whether there are trends in preference between booked or unbooked assistance. 

135.	 In June 2015, we agreed with industry that 
it would provide us with this information on unbooked assistance as part of our core data compliance monitoring. Specifically, we requested data on the number of unbooked assistance requests each train company received in each rail period, how many of those requests were met and passenger feedback on their level of satisfaction with the assistance provided. At the time we acknowledged that this was a challenge for industry because the vast majority of train companies had no formal processes in place to record the information. In practice, only four companies had working arrangements in place for their staff to log when an unbooked assistance had been requested and delivered. 

136.	 To meet our requirements, in late 2015, RDG 
proposed to initiate a long-term mystery shopping survey of unbooked assistance provision across Great Britain to assess the quality of assistance being provided by its members. However, by spring 2016, RDG alerted us that they could not deliver this research as planned since the funding they had allocated to this was no longer available. For 2016-17 this resulted in a gap in our unbooked assistance core data monitoring. 

137.	 Nonetheless, four companies subsequently 
provided data on unbooked assistance volumes for 2016-17:
■
■Merseyrail provided 67,978 unbooked 
assists; 
■
■London Overground provided 20,939 
unbooked assists;
■
■Hull Trains provided 1,646 unbooked assists 
(data from August 2016 to March 2017 only); and 
■
■TfL Rail provided 772 unbooked assists. 
 

138.	 We have now reached an agreement with RDG 
and its members that they will provide us with data on unbooked assists. This will include RDG collating data from a central webform which train companies and Network Rail will be able to update for their respective stations.
139.	 In the longer-term, the solution we have 

agreed with industry to address the 
compliance reporting gap is for it to be met 
by the new Rail Accessibility Reservation 
System, which is due to replace the current 
Passenger Assist system in September 2018. 
The new system should record both booked 
and unbooked assistance requests, assistance 
completions, and will automatically request 
passenger feedback on the quality of the 
assistance they received.

140.	 We measure complaints made to train 

companies about accessibility issues. 
The volume of complaints which concern 
accessibility is relatively low, less than 1 
complaint per 100,000 journeys for the 
majority of companies. However, in some cases 
a single complaint can indicate a serious issue. 
In this context we intend to take a closer look 
at some sub-categories of assistance-related 
complaints where we have noted an increase in 
volume. We will wish to examine, for example, 
whether this is a continuing trend. 

Source: Train Operating Companies

141.	 ORR receives complaints and intelligence 

directly in some instances and (although 
we do not generally intervene in individual 
complaints) sometimes this can alert us 
to wider issues. This year, for example, we 
received a complaint from a local access 
group regarding Shenfield station. We visited 
the station in question and engaged with the 

train company to resolve the issue. Following 
this, we will remind all train companies of 
their obligations under the DfT Code of 
Practice on Design Standards for Accessible 
Railway Stations and provide clarification on 
when the Code is likely to be triggered. More 
detail is provided in the following case study. 

## Making Stations Accessible

When train companies and Network Rail carry out work at stations they need to have regard to the Department for Transport Code of Practice on Design Standards for Accessible Railway Stations (the Code). This makes sure that when work at stations is carried out recognition of accessibility needs is incorporated. The Code applies at the point at which a company installs, renews or replaces infrastructure or facilities. In addition to complying with the Code, we also expect companies to consult with key organisations such as local access groups, in particular when planning and undertaking works at stations. We received a complaint from a local access group that Abellio Greater Anglia had not complied with the Code at Shenfield station and had not listened when they tried to engage with the company to resolve the problem. This included issues with Blue Badge parking spaces and signage. We visited Shenfield station to see the situation in practice. We then worked with the train company to resolve the situation at this station, and identify works across its station estate which may engage the Code and make sure that in future these are carried out in compliance. We are pleased that AGA and latterly the new holder of the franchise Abellio East Anglia (AEA) agreed to address a number of the issues at Shenfield including by way of a pilot exercise that is designed to see whether relocation of the Blue Badge Parking spaces will attract more passengers. This pilot is, we understand, currently underway and a number of other issues including signage have also been addressed.

## We Are Still Working With Aea Towards Achieving Compliance At Other Stations.

This year we will be reminding all station and train companies of their obligations under the Code, in particular to refresh understanding of the low threshold at which the Code is triggered and the process for seeking a derogation or dispensation where this is appropriate. In addition we will consider our own approach to ensure that companies are held to account for their responsibilities in this area. 

142.	 We continue to engage with companies 

to ensure that the data provided to us is 
consistent and reliable. We have noted an 
improvement in the information on training 
provided by companies this year, including 
clearer information on what type of training 
was undertaken, what this entailed, and how 
it helped staff to provide a good service. Our 
own research and conversations with our 
stakeholders underline just how important a 
good standard of training is, and that a good 
experience with an assisting staff member 
can have a huge impact in terms of the 
passenger experience. 

 

143.	 Training is equally important for staff in call 
centres and managers responsible for setting policy, as well as for front line staff delivering assistance on the ground. We monitor both the volume of staff undertaking disability and equality training each year and the type of training provided. This is highlighted in the individual train company data sheets in section 6 of this report. All companies carried out some form of training this year.

## Notice Periods For Booking Assistance

It is important that all train companies and Network Rail meet the standards set out in the guidance, and that passengers receive consistent messages about how much notice they need to give to book assistance. We were concerned that although all policy documents complied with the guidance and stated that people booking assistance would not be asked to give more than 24 hours' notice, in practice some companies were asking for more via certain booking channels (such as on e-booking forms) and in information provided on websites. In February 2017, we wrote to five train companies (Arriva Trains Wales, East Midlands Trains, London Midland, ScotRail and Virgin Trains East Coast) setting out our concerns and asking them to make changes. Following our engagement, all five companies quickly amended the relevant information to make clear that passengers do not need to give more than 24 hours' notice. We also asked RDG to update the assistance page on the National Rail Enquiries website. This now makes clear that passengers can book assistance at short notice and do not need to give more than 24 hours' notice. We will continue to keep this area under review.

## Website Audit

144.	 We expect train companies and Network 

Rail to provide accurate and consistent 
information to passengers who require 
assistance, and take their needs into account 
when doing so. This year we carried out a 
review of the information provided online to 
ensure it is accessible and clear in promoting 
the assistance available, and communicates 
effectively with passengers who may have 
different communication needs. We assessed: 

■
■The technical accessibility of websites using 
both screen reader and magnification technology; and
■
■The navigability, readability and content 
of websites with a particular focus on the provision of information for those with cognitive impairments.30
145.	 Screen readers allow users to access text that 
is displayed on the computer screen via speech and are used by people who prefer to use audio instead of text. Magnification software is used by people who need the information on screen to be larger.
 

146.	 The technical website review highlighted that 
websites may not be accessible for users of screen readers or magnification technology. This may prevent users with visual impairments in particular from accessing information on assistance and even from booking journeys and their required assistance online. 
147.	 Common issues occurring were:
■
■The use of calendars which were often 
inaccessible for screen reader users; 
■
■The use of form fields which passengers fill 
out to book tickets or assistance. These are often not labelled clearly if at all, meaning that screen reader users do not know how to use or fill in these fields; and 
■
■Text only booking sites can be easier 
to access for screen reader users, but companies providing these should ensure they are structured in a logical way allowing users to move through the required fields. 
148.	 The website content review looked 
at navigability (the effectiveness of signposting to accessibility and assistance information); content (the usefulness and comprehensiveness of the information provided); and readability (the extent to which the information provided is clear and well presented). We recommended a series of improvements under each of these headings. These included: 

■
■Ensuring information on station and train 
accessibility is available;
■
■Including more rounded information on 
the assistance which can be provided for passengers with a range of different impairments;
■
■Providing information on notice periods for 
assistance bookings;
■
■Better provision of information on 
unbooked assistance;
■
■Providing information on personal safety 
and security when travelling;
■
■Making information available using 
shorter sentences, free from jargon and set out clearly using pictures to support understanding; and 
■
■Using augmented and alternative 
communication such as films or easy-read content. 

149.	 We shared our review findings with individual 
train companies to make sure they are aware of the specific steps they can take to improve the accessibility and provision of information on their websites. 
150.	 We will continue to keep this area under 
review as operators now make changes to their websites. 

## Awareness Of Assistance

151.	 In autumn 2016, we commissioned ComRes, 
a specialist research agency, to undertake primary research to help us better understand if current, or prospective, passengers who require support to travel by rail were aware of the assisted travel services offered by train companies. The research covered: 
■
■Disabled people's awareness of the assistance 
available to them on the rail network; 
 

■
■The barriers to awareness that exist; 
■
■Factors that deter people with disabilities 
from using the rail network; and 
■
■What can be done to overcome barriers 
to awareness and concerns that prevent rail use.
152.	 The fieldwork involved quantitative telephone 

and online surveys with 1,000 people who 
were both current users and non-users of rail 
but who self-identified as requiring support 
when travelling by train. The respondents were 
broadly representative of the population of 
those who would most likely require assistance 
to access the railway. The quantitative phase 
was then followed up with ten qualitative 
depth interviews to explore some respondents' 
views and experiences in more detail. 

153.	 While the detailed findings will be published 
in the full research report, to be published in autumn 2017, the main findings were as follows: 
■
■Awareness of current assistance 

programmes is low. Just half (51%) of 
respondents had heard of assistance 
schemes at all, only two in five (43%) had 
heard of Passenger Assist and just one in 
six (16%) had heard of the option to 'turn up 
and go'. 14% of all disabled adults surveyed 
had used Passenger Assist and 5% had used 
unbooked assistance.

■
■However, once those currently 'unaware' were 
made aware of the services available, there were high levels of interest in making use of Passenger Assist and 'turn up and go' in the future. To enable this they requested that more information is made available to them on the types of assistance available, how to book, and on what arrangements there are for when things do not go as planned.
■
■Those passengers who have made use of 
these assistance schemes tend to be positive about their experiences, suggesting that the assistance currently available does meet the needs of most of those who use it.
154.	 The principal recommendation from the 
report, therefore, is for industry to do more to promote Passenger Assist and unbooked assistance more widely and proactively to prospective passengers. This should in turn lead to a natural increase in the uptake of assisted travel services. 

## Experience Of Unbooked Assistance

155.	 In January 2017 we commissioned Aecom to 
conduct research into passengers' experience of unbooked assistance. While conducting research with 'real' users was preferable, the challenges associated with this, in the sense that there is no formal database with user details due to the nature of unbooked assistance, meant we instead had to employ a mystery shopping strategy for the fieldwork. Aecom subsequently recruited 65 members of the public who self-identified as requiring assistance when travelling by rail to act as mystery shoppers. The fieldwork was conducted in March and April 2017. 

156.	 Each mystery shopper was asked to undertake 
2-3 return journeys on pre-selected services and to produce a detailed account of what they observed and experienced. This resulted in a total of 318 mystery shops overall, covering all the main train companies in Great Britain as well as the majority of the large Network Rail managed stations. To ensure the research was as representative as possible, Aecom recruited a cohort of mystery shoppers with a wide range of impairments and assistance requirements. 
157.	 We specified that the mystery shoppers should 
test as many aspects of unbooked assistance as possible, including where possible: 

■
■Accessing the station;
■
■Finding information about turn-up-and-go 
assistance in the station;
■
■Requesting assistance and reporting on how 
effectively it was subsequently provided whether in the station or on train;
■
■Testing the arrangements for assistance 
at journey interchange points such as changing trains;
■
■Testing station and on-train staff knowledge 
by way of pre-agreed lines of questioning and generally assessing the helpfulness of staff during any interactions; and 
■
■Testing the arrangements for assistance 
during disruption (if disruption occurred).
158.	 We also sought to understand how 
experiences of the above vary in relation to the following factors:
■
■Geography; 
■
■Journey type; 
■
■Disability type;
■
■Assistance requirement; 
■
■Station type; and 
■
■Train staffing arrangements. 
159.	 The research report is in the process of being 
finalised and we plan to publish it in the autumn alongside our work on awareness of assistance and our survey of Passenger Assist users. 

## Experience Of Passenger Assist

160.	 We are in the process of completing a large-scale 

piece of primary research into the experiences 
of users of the booked assistance scheme, 
Passenger Assist. This involves quantitative 
online and telephone interviews with 4,000 
Passenger Assist users to better understand 
their views, experiences and preferences 
relating to the service. The scale of the research 
means we can generate results for each train 
company and use the insight to inform our wider 
compliance monitoring as to how well individual 
train companies are meeting booked assistance 
requirements. It also means we can get a much 
deeper understanding of how passengers' 
experiences vary when booking assistance at 
different points across the network. 

161.	 In particular, the research will help us to 
understand: 
■
■Who Passenger Assist users are, including 
their demographic characteristics, assistance needs, journey purpose, frequency of rail travel and booked assistance use;
■
■Users' experiences of the Passenger Assist 
booking process, including their reflections on what could be done to improve it;
■
■Users' experiences of actual assistance 
provision such as boarding and alighting trains;
■
■Users' experiences of interactions with train 
company staff for example their attitude, helpfulness and awareness of how to assist a passenger with additional support requirements; and
■
■Users' overall satisfaction with the quality 
of assistance provided to them, and their general reflections on how well Passenger Assist is working for them in so far as meeting their needs and preferences. 
162.	 The fieldwork was undertaken by research 
company Breaking Blue from February 2017 to July 2017. The final research report is being finalised and we expect it to be published alongside our work on unbooked assistance and awareness of assistance in autumn 2017. 

## Next Steps

163.	 The findings of our wide-ranging research will 

be published in autumn, together with a plan 
of our future work in this area. Depending 
on the results of the research, we may also 
consider reviewing the 2009 Guidance on How 
to Write your Disabled People's Protection Policy, 
a Guide for Train and Station Operators, which 
was published in 2009, and which we use as 
the basis for our approval of policies.

164.	 We will continue to collect and improve core 
data. This year our focus will particularly be on receiving data on unbooked assists and on ensuring that the new Rail Accessibility Reservation System is designed and set up in a way that means our data reporting requirements are met. 
165.	 We will focus on complaints concerning 
accessibility, including looking in depth at any trends within sub-categories of this complaints category and reasons. 
 

166.	 Staff training also continues to be an important 
focus. This year we will review in depth the information provided by train companies on staff training and we will consider how good training practices could be better recognised and disseminated.
167.	 This year we will work with the DfT and remind 
all train companies of their obligations under the Code of Practice on Design Standards for Accessible Railway Stations and provide clarification on when the Code is likely to be triggered.
168.	 In addition to this we are working to 

understand more around the systems and 
process being employed in relation to Driver 
Controlled Operation services and will be 
returning to this in the autumn, once we have 
finalised and published the results of our 
research, detailed above. 

## 4.4 Complaints And Compensation Introduction

169.	 Effective redress is important. It provides 
consumers with a means to expose companies to failings in service provision and to claim compensation where appropriate. It also provides important insight for companies so that they know where to make improvements. To be effective, a complaints system must be accessible and individual complaints should be dealt with in a fair, effective and timely manner. Information about complaints should also be used to drive service improvements through service providers acting on the feedback received. When a complaint cannot be easily resolved, any appeal mechanism or dispute resolution scheme should be able to offer quick, fair and effective redress and provide transparency about company performance and wider trends. 

## Complaints Handling

170.	 For the reasons set out above, it is important 
that we understand the reasons for, and take prompt and effective action to address, individual train companies' poor complaints handling performance. We also want to help train companies to improve their service which should prevent issues from arising in the first place. 
171.	 In September 2015, we published updated 
guidance on Complaints Handling Procedures. All companies then updated their own complaints handling documents to comply with the new guidance. We reviewed and approved these revised policies throughout 2016. Following completion of this process our focus is now on monitoring compliance to ensure that passengers receive the level of service that they have committed to provide to passengers. 

## Data Quality

172.	 We have worked to improve the quality of the 
data provided to us. We use core data to check that companies are doing what they have said they will. Our visits to companies have been useful in helping us identify a number of inconsistencies, for example, in the way that complaints are recorded between companies. We held a workshop with all train companies in February 2017 to set out what we had found and to agree processes that should be adopted across the industry. Following that workshop we published new data guidance.31 We have 
also improved our internal data collection and validation procedures. These new procedures allow us to identify any data errors as soon as we receive the data, and for the train company to then resolve these in a timely manner.

## Core Data

173.	 There were 29.4 complaints per 100,000 

journeys in 2016-17 for franchised companies. 
Overall 13 train companies had a lower 
complaints rate, and eight train companies had 
a higher complaints rate, than 2015-16. 

Source: Train Operating Companies

174.	 The top reasons to complain in 2016-17 
include complaints about: 
■
■Punctuality/reliability (26.5% of complaints);
■
■Online ticket sales (7.3%); 
■
■Facilities on board (7.1%); 
■
■Ticket buying facilities (7.0%); and
■
■Ticketing and refunds policy (6.8%).
175.	 Punctuality was the most common reason for 
complaints. This corresponds to a downward trend in the punctuality of trains, as recorded 
 
by the Public Performance Measure32, which reached its lowest level since 2005-0633. 

176.	 Complaints about ticketing include complaints 
about online ticket sales, problems with ticket booking offices or ticket vending machines, policies around refunds, and smartcards. A number of these issues have been identified and reported on in detail in our work on ticket vending machines and go to some of the actions in The Action Plan for Information on Rail Fares & Ticketing (both described in more detail above).
177.	 Sufficient room, facilities on board, and 
attitude and helpfulness of staff at stations are also key drivers of complaints. We have seen a number of initiatives reported this year designed to improve these areas. These include improved wifi, better catering, refurbished trains with improvements to areas such as lighting and seating, and staff training programmes to improve customer service. 
178.	 Train companies are required to provide a 
full response to 95% of complaints within 20 working days. 12 of 24 train companies have failed to achieve this regulatory obligation consistently in 2016-17. We recognise that unexpected incidents can cause a sharp increase in complaints. However, we expect companies to have plans in place to deal with spikes and to have the capability to recover and maintain customer service. This means not only responding within the required timeframes but also maintaining the capacity to provide good quality responses. 

## Complaints Backlog

Companies have a regulatory obligation to respond to 95% of complaints within 20 working days. Through our compliance monitoring we identified that Arriva Trains Wales (ATW) had failed to meet its complaints handling obligations and that the trend in performance was downward. A backlog of responses to complaints and contacts of over 9,400 had also built up. We had been in contact with ATW to understand the situation and decided to visit ATW to conduct an end-to-end review of its complaint handling process. This thorough review, and ATW's positive approach to this engagement, enabled the areas where ATW's current arrangements for handling complaints could be improved to be identified, such as arrangements for dealing with the backlog in complaints which had developed. Progress against ATW's resulting improvement plans has been monitored through weekly reporting and ATW has swiftly now returned to compliance with its complaints performance obligations. This took effect from the start of the 2017-18 reporting year and so is not reflected in the reporting data in this report. 

## Contact Centre Move

In November 2016, FirstGroup companies Great Western Railway (GWR) and TransPennine Express (TPE) proactively complied with the requirement to inform us where regulatory regulatory obligations are unlikely to be met. The failure to deal with 95% of complaints within 20 working days arose as a result of FirstGroup companies moving their contact centre, which created a backlog in complaints. At its peak, the outstanding caseload of contacts and complaints was more than 53,000 cases. Following dialogue with ORR, both TPE and GWR provided a detailed action plan and recovery milestones. We subsequently met with them to test their ambition to put matters right for consumers. Through weekly monitoring reports and engagement with Transport Focus we were able to gauge progress and identify further areas where consumers were not getting the required service, such as the quality of responses and information about delays. This collaborative approach proved successful with both train companies returning to full compliance with their obligations by the start of the 2017-18 reporting year.

 

## Planned Engineering Works

In October 2016 we formally raised concerns with Merseyrail that it had not been meeting the timescales for responding to complaints for an extended period of time. Merseyrail took actions to implement a new Customer Relationship management system, appointed a new team leader and better matched resources to projected demand, assigned extra staff to complaints handling, and made sure oversight of the team's performance became more visible to the Executive Leadership team to ensure challenge. This meant it was able to return to meeting the relevant timescales for responding to complaints. In addition, between January and June 2017 Merseyrail undertook a significant programme of engineering works as part of the Wirral Loop Line Track Renewal. Merseyrail took proactive steps to inform ORR of its plans to let consumers know about the upcoming works. It also explained how it planned to deal with any associated uplift in complaints. Steps taken included forming a new team to support the provision of real time customer information during the work. Merseyrail also worked with other companies to understand the impact of similar programmes of work on their networks. Although Merseyrail has experienced some increase in complaints since the start of the track works it has met the relevant timescales for responding to complaints since December 2016 (rail period 9, 2016-17). 

179.	 It is important that consumers are able to take 
their complaints further when they remain unhappy with train companies' complaints handling. In their second substantive response to complainants, train companies are required to inform (or signpost) consumers that they can seek assistance from the appeals bodies Transport Focus and London TravelWatch as appropriate. Through our data gathering we identified that complainants were not being told consistently that this option existed. As a result, we reaffirmed train companies' obligations to signpost and clarified reporting requirements to strengthen our monitoring data. We have now seen an increase in the number of consumers correctly signposted to the appeals bodies, and appeals have increased by 33% compared to the year before.34

## Satisfaction With Complaints Handling Survey

180.	 In order to gain better insight into the 

passenger experience of making a complaint, 
we have been conducting a survey of 
passenger satisfaction with train companies' 
complaints handling. We commissioned an 
independent research company to carry out 
this research and satisfaction is measured over 
a range of indicators relating to the complaints 

process and outcome. Participation in the survey has grown over time, and all train companies will shortly be full participants in this important research. 
181.	 A summary of the national results compared 

with individual train company performance 
has been published in the train companies 
tables in section 6.35 Overall there were some 
welcome positive aspects of complaints 
handling highlighted in the survey findings, 
such as the ease of making a complaint and 
the politeness of staff. However, performance 
across the participating companies generally 
showed a greater level of dissatisfaction than 
satisfaction with train companies complaints 
handling. One important aspect to note is how 
the way the complaint is handled affects how 
the passenger feels about the train company.

182.	 The survey is an important part of our 
compliance monitoring. We expect that companies will also make use of this valuable information to gain a better insight into what is driving complainant dissatisfaction. Focusing attention and making improvements in these areas of performance provides an opportunity for companies to meet passengers' expectations and increase trust in their business.

## Alternative Dispute Resolution

183.	 Where consumers are unable to reach a 
satisfactory outcome to their complaint it is important that they can get redress in a way which is independent of the company. Transport Focus and London TravelWatch currently act as the appeals bodies for complainants who are unhappy with the train company's response to their complaint. However, they have no formal powers to compel train companies to act or compensate individual passengers and the only form of binding outcome for passengers is via the Courts.

184.	 Binding Alternative Dispute Resolution (ADR) 
arrangements have become more widespread in both the regulated and non-regulated sectors. The results of our satisfaction survey show a disappointing level of passenger satisfaction with complaints handling and support the case for the introduction of ADR in the rail sector. We therefore welcome the discussions the Rail Minister has been leading in this area and have fed in views of what a good ADR scheme looks like, to support developments and improve redress for consumers. These include key features that we would expect to see in a good ADR scheme such as:

■
■Independence;
■
■Decisions which are binding on the company 
but not the consumer;
■
■Accessible - the consumer should have to 
make minimal effort in order to get to the scheme;
■
■Free to the consumer; 
■
■Visible, accountable, and effective; and
■
■Be a driver for improved complaints 
handling and performance.
 

## Next Steps

185.	 We intend to increase our understanding of 
why some train companies are consistently performing better than others and will be sharing more widely their good practices as a way of raising standards in this area. We will also focus on ensuring that train companies respond to complaints within the required timescales. 
186.	 We will publish the results of our complaints 
satisfaction survey on a quarterly basis so that passengers are able to see how each train company is performing. We will use the information it provides to obtain a more rounded view of how train companies are meeting their passengers' expectations.
187.	 We will also establish whether there are any 
lessons to be learnt and shared from contact centre moves, and work to understand what preparations train companies are making to handle increases in complaints arising from known events such as planned track closures.
188.	 We will continue to be proactively involved in 
discussions as arrangements for ADR in the rail sector are further explored.

## Compensation

189.	 In December 2015, *Which?* submitted a super-

complaint to us which raised concerns that 
most delayed rail passengers are not aware of, 
nor apply for, the compensation to which they 
are entitled and that there are features of the 
passenger rail market in Great Britain, which 
contributed to this. We published the results36 
of our investigation and recommendations 
in March 2016. We published an update 
report37 in December 2016 (the December 
report) setting out progress against the 
recommendations and what further actions 
were needed. We committed in the December 
report to provide details of any further 
progress by way of this report.

## Claims Process Information

190.	 In the December report, we identified five 
standards of good practice which would provide passengers with simple, clear and accessible information and an easy-to-use claims process ('static information').38 
191.	 We completed a follow-up audit in March 2017 
which included verifying the accuracy of our audit information with the train companies, to identify any further improved adherence to the five standards.
192.	 We found that, since our December 
report, train companies have improved the information they provide on delay compensation in relation to the five standards we identified. In summary:
■
■Two more companies now have a dedicated 
paper delay claim form (leaving a residual two companies without);
■
■Three more companies now have a 
dedicated information poster or contact card (leaving a residual one company without);
■
■Two more train companies now have 
a website home page link to delay compensation information (leaving a residual one company without);
■
■One more train company now has a PDF 
delay claim form available on the website (leaving a residual three companies without); and
■
■Two more companies now have a dedicated 
online claim process which means that all companies have now adopted this good practice standard.
193.	 The table below shows progress since 
March 2016. 
 

Train operating company
Dedicated paper 
Dedicated poster 

claims form
or contact card
Mar-16
Dec-16
Mar-17
Mar-16
Dec-16
Mar-17
Mar-16
Dec-16
Mar-17
Mar-16
Dec-16
Mar-17
Mar-16
Dec-16
Mar-17
Arriva Trains Wales
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
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c2c
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
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Caledonian Sleeper









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
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Chiltern Railways
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Cross Country
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East Midlands Trains
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









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Govia Thameslink Railway
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



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
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Grand Central
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Greater Anglia
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Great Western Railway
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Heathrow Express
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Hull Trains
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London Midland
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Merseyrail
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Northern
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ScotRail





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Southeastern

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South West Trains
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Transpennine Express
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Virgin Trains East Coast

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
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
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Virgin Trains West Coast

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| Direct link from    | PDF delay claim    | Dedicated online    |
|---------------------|--------------------|---------------------|
| home page           | form on website    | claim process       |

194.	 We acknowledge the positive engagement 
from train companies in working towards meeting our five standards. We continue to encourage train companies to adhere to all five of the standards but appreciate that some information and claim methods may not be relevant across the whole range of business models. We will, however, continue to keep this under review and may contact companies in response to passenger concern or where, for example, the data shows that the way that passengers make compensation claims across the industry as a whole is at variance with the way in which passengers make compensation claims to companies who do not have the full range of claiming methods. 

## Standard Response Timescales And Keeping Passengers Informed About Their Claim'S Progress

195.	 In our December report, we committed to 
"work with train companies to understand what more can be done to keep passengers informed about the progress of their claim and discuss the possibility of publishing standard response timescales". 

196.	 The National Rail Conditions of Travel40 set out 
a commitment by train companies to pay a compensation claim within 14 days of having agreed it, within an overall commitment of one month from receipt of the claim to final payment.
197.	 Passenger research showed that only half 
of eligible passengers were satisfied with the speed of the response to their delay compensation claim and a quarter who had received a response needed to prompt the train company about their claim. 

198.	 In March 2017 we asked train companies for 
information on the current position on their target response timescales and how they kept passengers informed of progress with their claim.
199.	 Our information request found that: 
■
■Companies all commit to keeping within the 

maximum timescales set out in the National 
Rail Conditions of Travel but in practice 
generally process claims as they would 
complaints. This means that most companies 

aim to pay compensation within 20 working 
days of receipt of a claim, which is consistent 
with our regulatory requirement on 
complaints41, with a number of companies 
aiming for much shorter timescales than 
that. The lowest target for the number of 
days between application to payment is five 
working days and the highest is 20, though 
this number varied between companies. 
The most common receipt to payment 
period is around 10 days.

■
■Consistent with good practice, all but one 
company acknowledge receipt of the claim and of these, all but two companies do that as an automatic process for claims submitted electronically. 
■
■All but two companies confirm validation 
of the claim and that payment will be made in one contact (most told us that this also includes information about the timescale for payment). The remaining two train companies contact the passenger at the point that the payment is being processed. Greater Anglia and Scotrail allow passengers to check the progress of their claim online.
■
■Most companies proactively contact 

passengers (by email, letter or phone) when 
target timescales might be missed and some 
companies post a message on their website 
(but this requires the passenger to actively 
look for this information). Some companies 
update their auto-acknowledgement email 
(but obviously this would not by itself 
inform those who already had claims in the 
system). Five train companies do not inform 
the passenger. However, two of these train 
companies told us that they are making 
changes to their systems to enable an 
update to be provided.

200.	 We recognise that the processing of claims is 
affected by peaks in volume resulting from disruption and that some claims are more complex to process than others particularly where there is a suspicion of fraud. However, improvements are clearly needed. Our research has shown that the time taken to process a claim and the lack of information when published timescales are not met is a leading driver of passenger concern. The different ways in which train companies 
address this may create some confusion in the eyes of the passenger and there may be value in moving toward greater consistency in approach with the industry drawing on some of the better practice that we have observed. To this end we welcome RDG's commitment to develop compensation good practice principles for train companies (see further below). 

201.	 We will continue to closely monitor progress 
in this area through the scrutiny of core data that we are currently developing with companies. This data is likely to include data on the number of claims received during a rail period by claim method; the total number of delay compensation claims paid out during a rail period; the average time taken to process a claim (by claim method); and the number of claims rejected. 
202.	 We will consider the case for further 
intervention in the light of what that data tells us, including potentially revisiting our complaints handling guidance to reflect the fact that companies have told us that they deal with compensation claims in the same way. As such we may be able to deliver further consumer benefit by clarifying what our expectations are in terms of processing a claim. 

## Method Of Payment For Compensation

203.	 We set out in our December report 
that companies have made significant improvements in this area over the last year - having moved away from offering vouchers as the default means of payment - and now are giving passengers a choice of payment methods, including a range of 'cash' options.
204.	 Some have gone further than others, offering 
all the methods they accept for payment as 'standard' compensation methods. Where train companies offer a more limited 'standard' range, they have confirmed to us that they are capable of paying compensation by other methods (such as to a credit card) where requested to do so and/or where required to do so under the Consumer Rights Act 2015 (see below).
205.	 We will use the intelligence we collect, 
including data on compensation payments, to monitor on-going compliance in this area 
 

and will consider taking action if we receive 
evidence to suggest that passengers are losing 
out by the way in which payment methods are 
presented.

## Mystery Shop - Staff Knowledge Of Delay Compensation

206.	 As part of our super-complaint investigation, 

we also commissioned a research company to 
carry out over 300 mystery shopping exercises 
at stations and on trains to test staff knowledge 
of delay compensation payments and how easy 
it was for passengers to locate information 
about delay compensation themselves. Our 
findings were published in March 2016, along 
with our response report.42 During April and 
May 2016, we met with individual companies 
to discuss their results and what could be done 
to improve them. In our December report we 
committed to undertake a further mystery 
shop in 2017 to test progress. 

207.	 Our repeat mystery shopping research took 

place in February and March 2017. The 2016 
mystery shop had given us a firm baseline 
against which to track change so we focused 
on the same 22 train companies and retained 
the same methodology as previously but 
enlarged our sample.43

208.	 Mystery shoppers requested four basic pieces 
of information a potential claimant is likely to 
need to know:
■
■The delay threshold for compensation;
■
■The level of compensation payable;
■
■whether compensation was available in cash 
(or in vouchers which could be exchanged for cash); and
■
■How to make a claim.
209.	 Around one third (34%) of the mystery 

shoppers received accurate information on 
all four primary elements of their customer 
enquiry - 82% of which were handled at the 
ticket office - regarding the arrangements and 
conditions for claiming compensation. This 
represents a 4% improvement from 2016 for 
the headline measure of train company staff 
performance on the provision of basic delay 
compensation information. 

Base: All Staff Enquiries = 537

210.	 Visual information on delays and delay 
compensation arrangements was seen at a greater proportion of stations than in 2016: 
■
■39% of staffed stations (up 9% on 2016);
■
■29% of un-staffed stations (up 15% on 
2016); and 
■
■On 30% of trains (the same level as 2016). 
211.	 When asked to evaluate the content of this 

written information, 86% of the mystery 
shoppers said that they believed the information 
available was sufficient to inform them as to 
when they would be entitled to claim, and 
91% felt it was sufficient to inform them how 
to claim. This suggests that when the written 
information was available, it was normally 
considered to be useful to a potential claimant.

212.	 The results of the mystery shopping will be 
published in autumn 2017. 

## Clarification Of The Information For Passengers Licence Condition

213.	 As noted previously, a further action from the 

compensation super-complaint work in early 
2016 was to clarify the Passenger Information 
licence condition to make it clear that it 
covered all the stages of the journey. Although 
compensation for delays was not mentioned 
in the original version of the Regulatory 

Statement we issued in 2012, we noted that 
most companies referred to actions under 
passenger information related workstreams 
when we asked them about the work they 
were doing to promote compensation. 

214.	 We therefore published new guidance44 
('the guidance') in June 2016, after receiving acceptance from all licence holders that information about compensation did indeed fall within scope. During the process we were able to clarify some concerns raised by train companies:
■
■The need to provide customers with 
information about their rights to compensation in the event of disruption or delay only applies when the relevant compensation threshold has been exceeded.
■
■Although DfT franchise agreements include 
the requirement to promote compensation arrangements when due, the range of franchise agreements that currently exist impose different requirements across the industry. The clarification about compensation in the guidance was made with the agreement of DfT and the guidance makes provision to ensure that there is no double jeopardy should enforcement on this issue be required.
215.	 Further to this, train companies have now 
put actions around delivering various improvements to information provision, such as website banners and announcements on trains to let people know when they have been delayed and are entitled to claim compensation, into a new code (ACOP014)45 
which was published in October 2016. Further information on this can be found in section 4.2.
216.	 We recommended this approach since it 
ensures that improvements to information provision are embedded in delivery, including when franchises change and when new companies enter the market. ACOP014 includes compensation, help points and also publishes the industry actions as an appendix.

## Government Commitments On Compensation

217.	 In its November 2016 report, "Improving 
access to passenger compensation for delays and cancellations: Response following the ORR's investigation of the Which? super-complaint",46 
DfT made a number of commitments in response to our recommendations. We note progress against each commitment below:
■
■Commitment 1: DfT would work to complete 

the roll-out, at the earliest available 
opportunity, of the franchise requirement 
to use all reasonable endeavours to 
make passengers aware of their right to 
compensation, using harmonised wording 
for this requirement where possible.'

­
-	 *Update since November 2016:* The latest 'all 

reasonable endeavours' text is included 
in the new South Western franchise 
agreement and will be included in franchise 
agreements when other new franchises are 
let, for example, West Midlands and South 
Eastern. DfT is working towards including 
this text when introducing Delay Repay 15 
through negotiated changes to franchise 
agreements.

■
■Commitment 2: DfT would require 

franchisees to deliver a report outlining the 
steps they are, and will be, taking to fulfil the 
requirement and use the available evidence 
and industry best practice to evaluate 
compliance and would repeat the exercise 
after a further 18 months.

 

­
-	 *Update since November 2016:* DfT wrote 
to franchisees in March 2017 requesting that they provide a report on the steps that they are taking, or are planning to take, to ensure that passengers are aware of their right to claim compensation; and including evidence on levels of awareness among passengers of their right to compensation. DfT is discussing these reports with the franchisees and, if needed, seeking to agree further steps to raise passenger awareness of their right to claim compensation.

## Promoting Awareness

218.	 Following our March 2016 report and in 
response to our recommendation, RDG worked with all train companies to run an eight week compensation awareness campaign, and to increase the quality and frequency of their compensation communications across a number of customer touch points. 
219.	 It ran a series of adverts in the printed national 
press, and displayed information on station posters and screens to raise awareness, and through social media promoted both awareness and the eligibility to make specific claims. RDG worked with train companies to increase the quality and frequency of their compensation communications, supplementing them with RDG's materials where necessary.
220.	 Over 2,000 people were interviewed online 

on RDG's behalf in October 2016, before it 
ran the campaign and an equivalent group 
were interviewed online in December 2016, on 
completion of the campaign, and awareness 
was found to have been raised by 6 percentage 
points (from 44% to 50%). 

221.	 RDG has stated it is committed to seeing 

awareness of compensation continue to rise. 
It is currently producing a compensation best 
practice guide for train companies which will 
be used to drive further improvements. This 
best practice guide is due to be completed 
in summer 2017, and we are told will include 
best practice on how to present information 
online and on printed forms, and principles 
for raising awareness.

## Compensation Gap

222.	 One of the mechanisms we are using to assess 
the extent to which the actions described above are having an impact in terms of passengers actually making claims is what we call our 'compensation gap' analysis, which measures the difference between compensation that is due and compensation that is paid. 
223.	 In our March 2016 response to the rail 
passenger super-complaint on delay compensation arrangements we summarised a range of evidence on the compensation gap. This range included:
■
■Survey evidence, obtained by asking eligible 
passengers whether they had claimed delay compensation; and
■
■The results of original top-down analysis 
carried out by ORR in early 2016.
224.	 As described in Annex B, we have now 
updated our analysis with a view to determining how the take-up of compensation is changing over time.

225.	 The evidence that we looked at during our 
update suggested that there has been an increase in the proportion of potential claims that is successfully claimed by delayed passengers. We estimate this increase to represent around 10 percentage points of all potential claims. A substantial proportion of potential payouts still goes unclaimed, however. 

## Next Steps

226.	 We have notified industry via the Information 

Request issued in March 2017, that we are 
intending to expand our current core data 
requirement to include key performance 
indicators relating to delay compensation. 
The final composition of this data and its date 
for implementation are yet to be confirmed, 
but at a basic level it will help us track the 
volume of delay compensation claims each 
train company receives, the methods used 
to submit claims, the speed with which they 
process claims, and the methods they use to 
pay compensation. 

227.	 We will monitor trends from this data to check 
the effectiveness of delay compensation claim processes and information. We will also use consumer insight gained by way of individual consumer complaints made to us, Transport Focus and London TravelWatch, and from any future research studies or audits. 
228.	 We will now look to RDG to reflect the findings 
from our compensation work within the industry good practice guidelines currently under development and due to be completed in summer 2017.

## Consumer Rights Act And The Rail Sector

229.	 In addition to the industry-specific 
arrangements for compensation for delays, referred to above, the Consumer Rights Act 2015 ('the Act'), which came fully into force in the rail sector on 1 October 2016 provides consumers with remedies where services are not provided to the required standard.
230.	 The Act requires that services must be 
provided "with reasonable care and skill" and in conformity with information that is provided about the service (if the consumer has taken it into account when making a decision about the service).
231.	 Where a service does not comply with these 
requirements, the Act provides consumers with remedies, which include repeat performance (receiving the service again) or a reduction in price (or refund where the service has already been paid for).
232.	 The amount by which the price may be 
reduced, or the amount of any refund, is not stipulated in the Act but may be an "appropriate amount" up to the price paid for the service.
233.	 Under the Act, any such refund must be paid 
within 14 days of a claim having been agreed by the company concerned and must be paid in the same form as the consumer used to pay for the service (unless the consumer agrees otherwise).

## What The Act Means For Train Companies And Rail Passengers

234.	 With regard to delays, most train companies 
are now signed-up to the 'Delay Repay' scheme, which provides compensation where a passenger's journey is delayed by a certain amount of time, regardless of the cause of the delay or the 'fault' of the train company.

235.	 Passengers will continue to benefit from these 
industry-specific compensation arrangements but the Act may provide an additional route of redress. For example, where passengers experience a delay below the relevant time threshold, they do not think the amount of delay compensation they have received is appropriate or they experience a problem with another aspect of their service.

 

236.	 However, the application of the Act will 
depend, as described above, on the train company not providing the service with reasonable care and skill or in conformity with what the passenger has been told about the service.
237.	 In addition to the remedies provided for in the 
Act, the Act does not prevent consumers from seeking other remedies, including claiming damages over and above the price they paid for the service, although train companies may seek to limit their liability in this regard.

## Orr'S Work In This Area

238.	 It is the responsibility of train companies (and 
other relevant service providers) to ensure that they are compliant with their obligations under the Act.
239.	 However, given that the Act creates some new 
obligations, we have worked with RDG, train companies, and other key stakeholders over the last year to help develop an understanding of some of its key provisions.
240.	 In the context of our work on passenger 
compensation more generally, this has led train companies to now offer a much wider range of payment methods 'as standard' and, where they do not offer all possible methods (such as credit card payments) as standard, being capable of making such payments where the Act requires it.
241.	 We also held a workshop in November 2016, 
with train companies and representatives of RDG, DfT, Transport Focus, and London TravelWatch, to discuss the key provisions of the Act and their implications for rail passenger services. One of the conclusions of the discussion was the need for train companies to review their current policies and approaches relating to complaints handling to ensure consistency with the Act.

## Next Steps

242.	 Over the coming year, we will continue to work 
with stakeholders to promote awareness and understanding of the Act and its application to rail passenger services. We are currently developing our approach to how we could monitor compliance with consumer law generally across the sector. 

## 5. Network Rail Network Rail'S Role

243.	 The national rail network (track and related 
infrastructure, including 18 main line stations) is owned and operated by Network Rail. Network Rail is regulated by ORR under both a network and station licence. The company owns and operates 18 of Britain's largest and busiest stations - including 10 stations in London - and it is this passenger facing role that is the key area of focus for this report.
244.	 Network Rail has a devolved structure that is 
now organised around eight geographic route businesses, a freight and national passenger operator route, a system operator function, and centrally-based business units providing services to the routes such as infrastructure projects.
245.	 This structure presents an opportunity for us to 
improve how we regulate Network Rail. It will allow us to put a greater reliance on comparison between the route businesses and to make more use of reputational incentives by formally and transparently recognising the achievement of route teams in delivering improvements. We are currently developing our approach to route-level regulation as part of our 2018 periodic review, which we will implement in control period 6.50 

## Network Rail'S Licence Obligations

246.	 The key passenger facing obligations that 
apply to Network Rail fall within its station licence51 and therefore relate only to its 
managed stations. These obligations impose requirements on Network Rail to: 
■
■Provide information to passengers during 
service disruption (condition 3 of Network Rail's station licence). Network Rail is required to provide appropriate, accurate and timely information to enable passengers to plan and make their journeys, including when there is train service disruption;
■
■Establish and comply with a Disabled 
People's Protection Policy (DPPP) which sets out how Network Rail will support improvements in the accessibility of rail for users of its managed stations (condition 4 of Network Rail's station licence); and
■
■Establish and comply with a procedure for 
handling complaints relating to licensed activities from customers (condition 5 of Network Rail's station licence). 
247.	 In addition, we monitor whether Network 
Rail's commitments are being delivered in practice by focusing on the outcomes that are being achieved. As part of this, we look at a core data set of measures against which Network Rail reports. 

## Information For Passengers

248.	 Like the train companies, Network Rail has 
to set out how it will provide information for passengers in a Code of Practice. The Network Rail guidance note for the provision of information during disruption applies to its control, response and station staff. This is published on the Network Rail website.52
249.	 While many of the industry actions to improve 

the provision of passenger information 
during disruption are to be delivered by train 
companies, a number are specifically related to 
Network Rail. Last year Network Rail delivered 
the following actions:

■
■Making manual announcements at its 
stations during disruption;
■
■Removing an apology message where 
repeated automated announcements are broadcast;
■
■Providing additional coaching for staff who 
produce the prioritised plans ;53
■
■Reporting on the number of prioritised 
plans that have been produced;
■
■Publication of a Network Rail Guidance 
note for control, response and station staff: information during disruption on its website;
■
■Holding periodic cross industry reviews of 
local plans; and
■
■Ensuring that customers have access to the 
full details of their journey when there are engineering works. 
250.	 In addition, each Network Rail managed 
station has its own customer information plan which is developed with the train companies that use the station. We have continued our programme of local plan audits including meeting the local station teams in Edinburgh, Charing Cross and Liverpool Lime Street.
 

## Passenger Assistance

251.	 Network Rail had its DPPP reviewed and 
finalised by us on 4 August 2016.54 Areas of 
good practice were identified, such as Network Rail's Built Environment Accessibility Panel that provides both technical and experiential advice on the design and management of Network Rail built environment proposals and plans. Network Rail notes that it has also introduced Diversity Impact Assessments, which help to identify and reduce barriers to inclusion, particularly the physical and attitudinal barriers related to the built environment. 
252.	 Although passengers book assistance via the 
train company, Network Rail is responsible for providing this assistance at its managed stations. Data received from RDG (Figure 8 below) shows there were 345,305 booked assistances requested at Network Rail managed stations in 2016-17, an increase of 4.4% compared to the same period in the previous year. This is 29% of all booked assistance requests made nationally in 2016-17.
253.	 In 2016 we reported that we were working 

with Network Rail to establish stronger 
reporting mechanisms to demonstrate that it 
is complying with its obligations in the area of 
accessibility. We said we would be looking to 
collect further information including details 
of disability and equality awareness training 
undertaken by Network Rail staff and Network 
Rail agreed to provide this information. It 
confirmed it has delivered inclusive service 
training to 106 station staff as part of its 
induction course this reporting year. It reports 
the training is co-presented by trainers with 
disabilities and aims to:

■
■Provide delegates with the skills and 
underpinning knowledge required to provide inclusive front line customer services to meet the needs of passengers and other station users more effectively; 
■
■Understand the key role an accessible public 
transport system plays in creating a fairer and more inclusive society;
■
■Provide delegates with the ability to assess 
their own preconceptions and knowledge of disability;
■
■Develop a greater understanding of the 
effect of pre-conceptions; and 
■
■Explore the 'myths' around disability 
knowledge within society.
Note: 'Other' category includes complaints about lost property, car parks and retail. Source: Network Rail

## Complaints Handling

254.	 Network Rail had its Complaints Handling Policy 
(CHP) reviewed and finalised by us on 11 August 2016.55 The following areas of good practice have 
been identified in Network Rail's CHP:
■
■A sampling mechanism, which reviews three 
contacts per staff member per week. These are used to provide a quality review and highlight any training requirements to line managers;
■
■A commitment to carry out mystery shopping 
to review the level of service offered to passengers that complain and ensure compliance with the CHP; and
■
■A 24/7 customer contact centre.
255.	 In 2016-17, Network Rail received 2,473 
complaints related to its managed stations. Station complaints are a small subset of all Network Rail customer contacts, which also relate to areas of operations outside of its managed stations and thus outside of the scope of the CHP. This includes contacts about things such as lineside maintenance, vegetation or fly tipping which can affect those who live alongside tracks.
256.	 In terms of managed stations, the largest 
complaints category related to customer care, which accounted for 21% of the total complaints relating to Network Rail managed stations, followed by complaints on the provision of information (17%). Complaints about Network Rail staff accounted for 13% of the total station complaints (Figure 9 below).
257.	 Licence holders are required to respond to 
95% of complaints within 20 working days. In June 2016 Network Rail set a target of resolving all contacts (including station complaints) within 20 working days by March 2017. 
258.	 Our monitoring of Network Rail's performance 
on complaints handling in 2016-17 showed that 91.4% of complaints were responded to within 20 working days. Network Rail reports that the average age of all contacts received was at 29 days (20 working days) at the end of the reporting year.

259.	 In order to ensure licence holders are 
learning from the valuable feedback that complaints provide, we ask them to provide us with explanations of the steps they are taking to address the issues that are generating the highest numbers of complaints from passengers. 

260.	 In the 2015-16 reporting year Network Rail 
outlined how it was seeking to address complaints about the impact of upgrades and maintenance work being carried out across the network by improving the way it notified people in advance of the works. In 2016-17 Network Rail reports that the highest volume of contact related to issues such as ticket information and refund requests, which would fall to train companies to deal with rather than Network Rail itself.

261.	 Aside from these issues, and information 
requests, the category that Network Rail is contacted about most is 'railway work'. Network Rail has committed to reducing the volume of railway work complaints on each of its route scorecards in 2017-18. Additionally, it reports its station managers meet regularly to share best practice to continually improve passenger satisfaction at its managed stations.
262.	 Following discussion with Network Rail in 
2016, we reached agreement that it would not participate in the complaints handling survey for train companies. This is because we only require complaints data relevant to Network Rail's large managed stations. Complaints about other aspects of Network Rail's business, such as complaints from line side residents, fall outside scope of our monitoring. However, Network Rail finds it difficult to extract this complaints data about managed stations 
 

in isolation. As an alternative, therefore, 
Network Rail agreed that it would provide 
us with 'equivalent data' by implementing its 
own complaints handling survey that largely 
replicated our own, and provide the survey 
outputs to us to satisfy our compliance 
reporting requirement. 

263.	 We only began receiving this data in February 
2017 and it is still being assessed in terms of whether or not it meets our reporting standards, so it is not ready for publication at this time. We will continue to engage with Network Rail on this issue with a view to publishing its survey results later this year.
264.	 We will continue to engage with Network 
Rail through reporting and monitoring, as it aims to continue to improve its complaints handling, with a key focus on the obligation to respond to complaints within the required timescales. We intend to increase our understanding of why some train companies are performing better than others and will be sharing more widely, including with Network Rail, good practices as a way of raising standards in complaints handling across the industry.
265.	 Finally, we anticipate that Network Rail 
complaints handling will be part of any discussions about arrangements for ADR in the rail sector as they are further explored.

## 6. Findings By Train Company

266.	 For each train company, below, we have 
provided both quantitative and qualitative data alongside relevant narrative. This shows how each company is fulfilling its obligations to provide information to passengers; assistance for those passengers who need it; and an effective and accessible process for managing passenger complaints. 
267.	 The data sheets also contain relevant 
contextual information for each train company including the owning group, number of stations it operates, the number of staff, the operating sector, and the number of passenger journeys per annum. 
268.	 The example data sheet below provides 
further guidance on how to read the data and information presented for each train company. 
269.	 It is important to note that the rail industry 
reports data on a periodic basis different to the widely recognised reporting cycles such as monthly or quarterly. 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. The length of a rail 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. 
270.	 Some of the data used in our data sheets 
comes from the National Rail Passenger Survey (NRPS), carried out by Transport Focus. The NRPS takes place twice a year, in spring and autumn. We used data up to autumn 2016, which is the latest published. The next data is due to be published in late July 2017. 

## Guidance Notes On How To Read The Train Company Reports Provision Of Information To Passengers 

Key facts Owner group: This is the parent company which owns the train operating company.

Operator: Train operating company. Franchise: Name of the franchise the train company operates.

Franchise period: Period of time for which the train company has been contracted to run the franchise.

Employees: Number of employees the train company has.

Operated stations: Number of stations the train company operates.

Sector: Long distance, Regional or London and South East. Passenger journeys per annum: Number of annual passenger journeys on the train operating company.

## Passenger Satisfaction With How Well The Train Company Deals With Delays

Passenger satisfaction with how well the train company deals with delays, available at both train operating company and a national level.

The data is sourced from the Transport Focus twice yearly 
National Rail Passenger Survey (NRPS). Data is included 
from 2012 to 2016. A new wave of the NRPS is due to be 
published in July 2017. 

The side arrows indicate the percentage point change from 
Autumn 2015 to Autumn 2016.

Source: Transport Focus, National Rail Passenger Survey Source: Transport Focus, National Rail Passenger Survey

## Transparency And Accountability

Train companies produce a 'Local Plan' setting out how they will provide information to passengers. This can be tailored to how they run their services. Train companies need to publish their Local Plan (or a public facing version of it), a link to the current Code of Practice for the provision of customer information and an annual progress report. All operators were compliant with this in October 2015 but in October 2016 the industry changed its Code of Practice. This box records whether the operator has updated its website in accordance with the new Code of Practice. An audit of operator websites was undertaken in May 2017. 

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Passenger satisfaction with the usefulness of information provided to passengers when delays occur, available at both train operating company and a national level.

The data is sourced from the Transport Focus twice yearly 
National Rail Passenger Survey (NRPS). Data is included 
from 2012 to 2016. A new wave of the NRPS is due to be 
published in July 2017. 

The side arrows indicate the percentage point change from 
Autumn 2015 to Autumn 2016. 

Source: Transport Focus, National Rail Passenger Survey

## Passenger Satisfaction With The Provision Of Information During The Journey

Passenger satisfaction with the provision of information during the journey, available at both train operating company and a national level.

The data is sourced from the Transport Focus twice yearly 
National Rail Passenger Survey (NRPS). Data is included 
from 2012 to 2016. A new wave of the NRPS is due to be 
published in July 2017. 

The side arrows indicate the percentage point change from 
Autumn 2015 to Autumn 2016.

## Actions To Improve Information For Passengers 2016-17

The information in this box outlines the actions the train 
company has informed ORR that it has taken in the 
period 2016-17 to improve the quantity and or quality of 
information it is providing to its passengers. 

Examples may have been supplied direct by the train 
company or taken from its Local Plan.

## Train Operating Company Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

The information in this box outlines the actions the train company has informed ORR that it has taken in the period 2016-17 to improve accessible rail travel on its services. A link is also provided to the train company's approved Disabled People's Protection Policy.

The number of passenger assists requested. These assists were booked through the National Passenger Assistance Booking System, known as Passenger Assist, managed by the Rail Delivery Group (RDG). The number of booked assistance requests are shown for each company that manages a station, and therefore not necessarily against the train company which the passenger travels with. For example, if a passenger requests an assist at Darlington station for a Cross Country train journey, the assist will be recorded against Virgin Trains East Coast, as Virgin Trains East Coast manage the station. This is why we do not have any data for those train companies who do not manage any stations. 

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

The volume of accessibility complaints per 100,000 journeys. This is shown for both the train company and at a national level. Accessibility rate is calculated using the complaint categories which train companies submit to ORR.

## Alternative Accessible Transport

The number of instances where the train company provided Alternative Accessible Transport (AAT) in 2016-17.

All operators must provide free alternative transport to take 
passengers to the nearest or most convenient accessible 
station in certain circumstances, for example when the 
station is inaccessible to the passenger or when rail 
replacement services are inaccessible.

The volume of AAT may be high because an operator has a 
large number of inaccessible stations (for example) so it is 
important to view the figures in context. 

It should be noted that this only relates to AAT provided in 
relation to pre-booked assistance.

Source: Train Operating Companies 

The data in this box also does not include un-booked 
assistance volumes. Un-booked assistance, often carried 
out under the name 'Turn Up and Go', is something train 
companies and Network Rail must also provide. Therefore, 
assists reported on in this box may underrepresent all 
assists provided by each company, as it includes only those 
assists recorded through the National Passenger Assistance 
Booking System.

Data is shown in rail periods. 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.

The information in this box outlines the staff training in relation to disability and equality awareness issues the train company reports it has undertaken in 2016-17 with a view to improving the quality of service it provides to passengers who require additional support when travelling on its services.

## Train Operating Company Complaints Handling Complaints Rate (Per 100,000 Journeys) And Complaints Response Rate

The volume of complaint correspondence closed per 
100,000 journeys. Complaints are normalised by passenger 
journeys to allow effective comparison of data between time 
periods and train operating companies.

Our regulatory requirement is to provide a full response to 
95% of complaints within 20 working days.

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17

This survey asks passengers who have complained to a train company to offer feedback on how well they felt the company handled their complaint. The chart in this box shows how passengers rated their satisfaction with each aspect of the train company's complaint handling process. 'Satisfied' is a combination of 'satisfied' and 'very satisfied'. 'Dissatisfied' is a combination of 'dissatisfied' and 'very dissatisfied'. Arrows indicate how the train company compares to the national average of those 'satisfied'. 

The number of survey respondents for each train company is also shown. National results are weighted by complaint volumes to ensure the survey is representative of the complaints received by train companies.

Source: ORR - Passenger satisfaction with complaint handling survey Data tables: Passenger satisfaction with complaints handling Note: Figures may not total exactly 100% due to rounding.

## Top 5 Reasons For Complaints 2016-17

The data in this box shows the top five causes of 
complaints for the train company in 2016-17. The table also 
shows what proportion of complaints each of the top five 
complaints issues accounted for and the percentage point 
change for each complaint category versus 2015-16.

## Passenger Satisfaction With Complaint Handling Process 2016-17

This survey asks passengers who have complained to a train company to offer feedback on how well they felt the company handled their complaint. The first chart shows how passengers rated their satisfaction with the train company's overall complaints handling process. The second chart shows how passengers rated their satisfaction with the outcome of the complaint they made to the train company. 'Satisfied' is a combination of 'satisfied' and 'very satisfied'. 'Dissatisfied' is a combination of 'dissatisfied' and 'very dissatisfied'.

The number of survey respondents for each train company is also shown. National results are weighted by complaint volumes to ensure the survey is representative of the complaints received by train companies. TOC stands for Train Operating company.

Source: ORR - Passenger satisfaction with complaint handling survey Data tables: Passenger satisfaction with complaints handling Note: Figures may not total exactly 100% due to rounding. 

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17

This survey asks passengers who have complained to a train company to offer feedback on how well they felt the company handled their complaint. 

The chart in this box shows how passengers rated their 
view of the train company in light of how it handled their 
complaint, namely: more positive about them; no different; 
more negative about them. 

The number of survey respondents for each train company 
is also shown. National results are weighted by complaint 
volumes to ensure the survey is representative of the 
complaints received by train companies.

Source: ORR - Passenger satisfaction with complaint handling survey
Data tables: Passenger satisfaction with complaints handling
Note: Figures may not total exactly 100% due to rounding.

## Actions To Improve Services For Passengers 2016-17

The information in this box outlines the steps that each 
train company reports it has taken in 2016-17 to address 
issues highlighted in passenger complaints. This relates 
to the requirement for each licensee to demonstrate how 
it is embedding a culture of continuous improvement in its 
complaint handling.

A link to the company's approved Complaints Handling 
Procedure is also provided. 

Source: Train Operating Companies

## Arriva Trains Wales Provision Of Information To Passengers Key Facts  Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - March 2017 

https://goo.gl/9X3juP

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

ATW has created a ticket acceptance arrangement 
with local bus services. This means during periods of 
disruption, passengers can show their rail ticket and 
continue their journey without having to wait for rail 
replacement bus services.

A pool of volunteers from head office can be called upon 
to provide information to passengers at times of major 
disruption at Cardiff Central. 

## Arriva Trains Wales Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

ATW has established **Customer Panels** that meet on a quarterly basis to hear the views and opinions of its passengers on different aspects of its services. 

These Panels also carry out **mystery shopping** exercises every month with the results fed back to the company and discussed at passenger experience strategy meetings.

ATW's **Disabled People's Protection Policy** is available at: http://www.orr.gov.uk/__data/assets/pdf_ file/0020/22736/atw-chp-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
254 times by ATW.

requests in 2016-17
This accounted for 4.8% 
of all booked assists 
made nationally in 

In total 731 ATW staff undertook some form of disability and equality training in 2016-17: 

•	 All frontline staff have to have dedicated training on providing 
assistance to ensure they are aware of differing disabilities, how to cater for their needs and how to operate the equipment provided. 
•	 All ATW customer facing staff receive a briefing during their annual 
development day which is focused on the needs of customers that require assistance and provides any updates that they need to be aware of. 
•	 Initial accessibility and inclusion related information is also 
covered at length during the induction for new starters.

## Arriva Trains Wales Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Punctuality/reliability
-4.6 PP
0.6 PP
9.5%
Sufficient room for all passengers to sit/stand 
-1.8 PP
4.1%
Ticket buying facilities 
0.3 PP
3.7%
 The helpfulness and attitude of staff on train  
0.9 PP
3.1%
Provision of information about train times/platforms   

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 Satisfaction With How The Complaints Handled Overall How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

ATW's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0020/22736/ atw-chp-letter.pdf ATW reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	Worked with the TVM supplier to change the internal 
mechanism to dispense tickets which has improved the functionality and reliability of the 10 worst performing machines.
•	Committed to investing £1,000,000 in 2017 to further improving 
the ticket buying facilities by updating TVM software.
•	Invested £400,000 to enhance the on-board environment of 
their older fleet.

## C2C Provision Of Information To Passengers Key Facts

and revenue database)

## Passenger Satisfaction With How Well The Train Company Deals With Delays

Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - no link published  •	 Local Plan - February 2017 

https://goo.gl/rKpwnD
Although updated in 2017, the Local Plan refers to the previous Code of Practice. A fully compliant version needs to be shared with ORR  by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Source:  Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey

Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

Information screens at stations have been upgraded to show the "next fastest train to…" when a train is cancelled. A further upgrade means screens also warn passengers where a train is likely to be delayed after leaving the station. c2c is working to introduce announcements to alert passengers when they may be due compensation for delays. Service pattern and compensation threshold will be considered before the automatic announcements are made.

## C2C Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

c2c commits to allowing passengers to provide **4 hours'** notice for requesting assistance on its services. A **new app** has been developed to allow passengers to book assistance in advance and notify the assisted travel team of their arrival at stations.

c2c commits to apologise and provide **compensation** of twice the cost of passengers tickets if assistance booked through Passenger Assist fails.

c2c's **Disabled People's Protection Policy** is at: 

www.orr.gov.uk/__data/assets/pdf_file/0010/22132/ c2c-review-dppp-letter.pdf 

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 0 
times by c2c.

In total **620** c2c staff undertook some form of disability and equality training in 2016-17: 

•	 c2c has an Equality, Diversity & Inclusion group and 2 
local equality representatives.
•	 It works with the National Centre of Diversity and follow 
the Investors in Diversity Framework.

## C2C Complaints Handling Complaints Rate (Per 100,000 Journeys) Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
32.2%
Smartcards 
11.8%
Punctuality/reliability 
| 10.1%                        |
|------------------------------|
| 0.9 PP                       |
| 4.6 PP                       |
| 9.6%                         |
| No response from train       |
| company                      |
| -1.1 PP                      |
| 4.4%                         |
| How request to station staff |
| was handled                  |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

c2c's Complaints Handling Procedure is available at: www.orr.gov.
uk/__data/assets/pdf_file/0011/19694/chp-approval-c2c-essex-
thameside-nxet-20141027.pdf 
c2c reports it has taken some of the following actions to address 
issues highlighted in passenger complaints: 

•	 Delivered training to telephone and customer relations staff, and 
implemented processes to quickly identify and report faults, reducing smartcard complaints.
•	 Increased frequency of services within peak times. •	 Is rolling out a new system to highlight potential issues with trains 
before failure so that maintenance can be carried out proactively.
•	 Designed a training module for all front line staff, focused on the 
customer journey and highlighting role model behaviour for front line staff so more complaints can be dealt with at the station. 

## Caledonian Sleeper Provision Of Information To Passengers Key Facts

Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database)
Data tables: TOC Key statistics

## Passenger Satisfaction With How Well The Train Company Deals With Delays

*see note above for information about the source of this data

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - no link published  •	 Local Plan - no link published 
ORR is working with Caledonian Sleeper to ensure that they have a compliant local plan by the Autumn 2017 deadline.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

***Note:** Caledonian Sleeper does not participate in the National Rail Passenger Survey.  Instead, Transport Focus carry out an individual survey for Caledonian Sleeper. Comparisons with the NRPS should therefore be treated with caution due to some differences in methodology. These differences include the Caledonian Sleeper survey being online only, some differences in the questions asked, data collected every rail period rather than just Spring and Autumn, and differences in timings for completion of the survey following the journey.

## Passenger Satisfaction With The Provision Of Information During The Journey

*see note above for information about the source of this data

## Actions To Improve Information For Passengers 2016-17

Caledonian Sleeper has not provided any information on the actions it has taken to improve the information it provides to passengers. 

## Caledonian Sleeper Accessibility And Inclusion Alternative Accessible Transport Actions To Improve Accessible Travel 2016-17

Caledonian Sleeper is working to install *Totem* information points at all the stations it serves by 2018.

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
Caledonian Sleeper's Disabled People's Protection Policy is available at: http://www.orr.gov.uk/__data/
assets/pdf_file/0009/24597/caledonian_sleeper_dppp.pdf

not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 0 
times by Caledonian Sleeper.

Data on the volume of booked assistance is available from the Rail Delivery Group for each train company that manages a station. Caledonian Sleeper does not currently manage any stations which means this data is not available to report on. 

## Disability And Equality Staff Training In 2016-17 Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Change 
Change 

28 Caledonian Sleeper staff undertook some form of disability and equality training in 2016-17: 

on last year
on last year

•	 All new staff received general disability training at their 

Data not 
16.4%
0.3
Data not 
available
available for 

induction. An annual refresher course is also in place for all existing staff.

last year

•	 Managers involved in the Guest Experience function have 

Caledonian 
National
Sleeper

been trained to ensure that decisions they take affecting disabled passengers are evidence based and consistent.
•	 A dedicated disability and equality training programme 
Note: Caledonian Sleeper did not provide data for the full reporting year 2016-17 
but reports it received 1 complaint on accessibility in rail periods 8-13 2016-17. Caledonian Sleeper data not available for 2015-16.

Source: Train Operating Companies Data tables: Complaints by NRPS category by TOC - Table 14.5
has recently been developed and is in the process of being implemented. 

## Caledonian Sleeper Complaints Handling

Complaints rate (per 100,000 journeys) and complaints response rate
% answered 
99.7
in 20 
working 
days
Complaints 
rate (per 
Data not 
available
100,000 
journeys)

Note: Caledonian Sleeper did not provide data for the full reporting year 2016-17 
so the complaints rate is not available. Caledonian Sleeper data not available for 2015-16.

PP = percentage point change Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database)

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17

Caledonian Sleeper did not participate in our complaint handling survey during 2016-17. This has recently been resolved and they have been participating in the survey since rail period 2 2017-18. 

## Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Change on last year*
19.8%
Punctuality/reliability 
13.2%
Ticketing and refunds policy 
10.3%
Ticket buying facilities
8.2%
Miscellaneous
7.8%
Aspects of complaints handling

*Data is not available for last year PP = percentage point change  **Source:** Train Operating Companies Data tables: Complaints by NRPS category by TOC - Table 14.5

## Passenger Satisfaction With Complaint Handling Process 2016-17

Caledonian Sleeper did not participate in our complaint 
handling survey during 2016-17. This has recently been 
resolved and they have been participating in the survey 
since rail period 2 2017-18. 

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17

Caledonian Sleeper did not participate in our complaint 
handling survey during 2016-17. This has recently been 
resolved and they have been participating in the survey 
since rail period 2 2017-18. 

## Actions To Improve Services For Passengers 2016-17

Caledonian Sleeper's Complaints Handling Procedure is available at: http://www.orr.gov.uk/__data/assets/pdf_file/0010/19693/ orr-approval-to-serco-chp-and-dppp.pdf Caledonian Sleeper reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 Appointed a dedicated manager within the customer contact 
centre, with the specific remit of improving customer interaction.
•	 Working to meet their commitment to replace their full fleet with 
new trains in 2018.
•	 Committed to enhance the station facilities open to passengers 
at key locations by mid-2018.

## Chiltern Railways Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - October 2016 

https://goo.gl/556YsQ 
As the Code of Practice has changed since the  Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Chiltern is working with Aston University to review its 
disruption management plans and information provision. 
The project is due to complete with recommendations in 
December 2017.

Station 'disruption kits' have been introduced at stations 
to ensure staff have the resources they need to inform 
passengers during disruption. The on train wifi upgrade will be completed by September 
2017 and will enable passengers to access live train running 
information while they are on the train. 

## Chiltern Railways Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Passengers who have used booked assistance are 
asked to complete a survey on the service provided. 
Comments are monitored and actions are taken where 
assistance has not been provided to the expected level.

Chiltern's Disabled People's Protection Policy is at:   

http://www.orr.gov.uk/__data/assets/pdf_
file/0019/24436/chiltern_railways_dppp_review_letter.
pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
147 times by Chiltern.

booked assistance 
requests in 2016-17
This accounted for 1.0% 
of all booked assists made 
nationally in 2016-17

In total 71 staff undertook some form of disability and equality training in 2016-17: •	 All new entrants are trained in Disability Awareness as part of 

their induction. 
•	 The course is a half-day session delivered by an external 
company. 
•	 It covers 5 areas, including awareness of the Equality Act 
2010, understanding the social model of disability, being able to suggest practical ways to reduce barriers, and encouraging good practice within the organisation. 
•	 Resources used to complete the training include presentations, 
classroom discussion and practical experience such as how to position a ramp. 

## Chiltern Railways Complaints Handling Complaints Rate (Per 100,000 Journeys) Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 11.8%                   | Ticket buying facilities    |
|-------------------------|-----------------------------|
| 8.4 PP                  |                             |
| 7.7%                    | Company policy (misc)       |
| 5.4 PP                  |                             |
| 2.4 PP                  |                             |
| 6.2%                    |                             |
| Sufficient room for all |                             |
| passengers to sit/stand |                             |
| 5.8%                    | Facilities for car parking  |
| 4.8 PP                  |                             |

PP = percentage point change Source: Train Operating Companies Data tables: Complaints by NRPS category by TOC - Table 14.5

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17 Chiltern'S Complaints Handling Procedure Is At: Http://Www.Orr. Gov.Uk/__Data/Assets/Pdf_File/0005/22919/Chiltern_Railway_ Chp_Approval_Letter.Pdf

Chiltern reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Introducing new TVMs throughout 2017. •	 Introduced performance schemes to demonstrate the 
importance of trains running on time to front line staff.
•	 Ensures an amended timetable is in place when events take 
place along the route to cater for additional passengers wishing to travel.
•	 Introduced additional car parking spaces at two locations and 
is trialling a scheme to make car parking quicker and easier to pay for. 

## Crosscountry Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - August 2016 

https://goo.gl/96GHDs
As the Code of Practice has changed since the  Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

All frontline staff have access to real-time information via a smartphone with customer information apps. All announcements on trains are made by staff who have a duty to be visible to passengers during the journey. CrossCountry's 'HELPER' process reminds staff what they need to do during disruption. The @crosscountryUK twitter account is managed from within the control centre which helps to ensure the social media team have up to date information. 

## Crosscountry Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

CrossCountry now enables passengers to book assistance up until 8pm the night before travel.

CrossCountry's Disabled People's Protection Policy is 
available at:  

http://www.orr.gov.uk/__data/assets/pdf_
file/0004/22729/xc-trains-dppp-letter.pdf 

Data on the volume of booked assistance requests received in each rail period is available for each train operator that manages a station. This data is therefore not available for CrossCountry because they do not manage any stations.  

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned engineering works for example); or 

•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
141 times by CrossCountry. 

131 CrossCountry staff undertook some form of disability and equality training in 2016-17: 

•	 All new staff receive mandatory disability awareness and 
equality training.  
•	 All Frontline Managers have attended a one day course on 
equality training.
•	 All call centre staff who handle Passenger Assist bookings 
have ongoing disability awareness and equality training.
•	 Staff are also regularly taken out on the network to build up 
their practical understanding of the hazards and obstacles that disabled customers may experience when travelling.
CrossCountry are in the process of launching a new Equality, Diversity and Inclusion training and briefing initiative/module to all customer facing staff incorporating the latest thinking and industry expert advice. 

## Crosscountry Complaints Handling Complaints Rate (Per 100,000 Journeys) Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 26.5%                        | Facilities on board    |
|------------------------------|------------------------|
| 3.3 PP                       |                        |
| 3.2 PP                       |                        |
| 13.5%                        |                        |
| Sufficient room for all      |                        |
| passengers to sit/stand      |                        |
| 3.5 PP                       |                        |
| 5.3%                         |                        |
| The helpfulness and attitude |                        |
| of staff on train            |                        |
| 2.8%                         | The toilet facilities  |
| 0.4 PP                       |                        |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

CrossCountry's Complaints Handling Procedure is available at: 
http://www.orr.gov.uk/__data/assets/pdf_file/0012/22251/ crosscountry-chp-letter.pdf CrossCountry reports it has taken the following actions to address issues highlighted in passenger complaints

•	 Introduced additional catering resource on Sundays around 
Birmingham area.
•	 Committed to undertaking some research on what customers 
value from their catering service.
•	 Established quarterly reliability surveys on the operation of each 
train.
•	 Offered advance tickets on the day of purchase, up to 15 
minutes before the customers starts their journey.

## East Midlands Trains Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

## •	 Code Of Practice - September 2016 

•	 Local Plan - December 2016 

https://goo.gl/4gmuW6

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey

The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

A new staff app that allows staff to filter information by subscribing to individual routes has been introduced. E-poster boards showing live digital content have been introduced at key stations. During disruption this information can include alternative route maps and advice from the control centre which is staffed 24 hours. Phase 2 of the "Great Service During Disruption" programme is being rolled out to on train staff to help ensure staff are able to inform passengers during disruption. 

## East Midlands Trains Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Passengers booking assistance need to provide 12 hours' notice when traveling on EMT services. 

If booked assistance is not provided then EMT will provide passengers with **a full refund** for their journey.

EMT has established a 'Customer Voice' forum which allows passengers to meet with Senior Management to discuss their views on the service being provided.

East Midlands Trains' Disabled People's Protection Policy is available at: www.orr.gov.uk/__data/assets/pdf_
file/0014/21065/emt-review-of-dppp-letter.pdf 

Note: This excludes un-booked assistance. 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. 

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
3,906 times by EMT.

In total 78 EMT staff undertook some form of disability and equality training in in 2016-17: 

•	 As part of induction training frontline staff (including 
customer hosts, train guards, train managers and gateline staff) undertook a dedicated module on disability awareness and equality. 
•	 EMT aims to make this dedicated module mandatory for all 
Customer Experience staff.
•	 Training is delivered in-house and involves both classroom 
training and practical elements such as use of equipment.

## East Midlands Trains Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 16.9%                        | Facilities on board      |
|------------------------------|--------------------------|
| 6.7 PP                       |                          |
| 2.4 PP                       |                          |
| 14.0%                        |                          |
| Sufficient room for all      |                          |
| passengers to sit/stand      |                          |
| -0.6 PP                      |                          |
| 6.6%                         | Ticket buying facilities |
| 0.5 PP                       |                          |
| 4.3%                         |                          |
| The helpfulness and attitude |                          |
| of staff on train            |                          |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Operator Actions To Improve Services For Passengers 2016-17

EMT's Complaints Handling Procedure is available at: www.orr. gov.uk/__data/assets/pdf_file/0018/20835/approval-emt-chpletter.pdf EMT reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Introduced free 15 minutes of WiFi in standard class to address 
complaints about provision of WiFi.
•	 Proactively issues customer information on Twitter and website 
about services which will have short formations.
•	 Offers compensation for passengers who had a seat 
reservation but could not access their seat. 
•	 Introduced a new customer experience training program 
for front line staff called 'Permission to Act' to empower all employees to make decisions on the spot to help customers.

## Govia Thameslink Railway Provision Of Information To Passengers


Key facts Owner group: Govia Operator: Govia Thameslink Railway (GTR) Franchise: Southern / Thameslink / Great Northern / 
Gatwick Express Franchise period: 14 September 2014 - 

01 September 2021 
Employees: 7,129 Operated stations: 236 Sector: London and South East Passenger journeys per annum: 320.7 million Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database)
Data tables: TOC Key statistics

## Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - July 2017 

https://goo.gl/NoEjgB
Each document is published on all four of the GTR 

brand websites.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Data for GTR is shown under the 4 brands it currently operates: 
PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

New websites that prioritise travel information during periods of disruption have been introduced for Great Northern, Thameslink and Gatwick Express. Real-time service updates are now provided to passengers during the journey on the class 377/387 fleet. A review of procedures at London Victoria station is looking at options for deploying mobile information screens for passengers in hotspot areas. Improvements have been made to information screens at Thameslink core stations and on class 700 trains.

## Govia Thameslink Railway Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

GTR has relaunched its priority seat card initiative. This is a mechanism that allows passengers with accessibility needs to seek dedicated seating on all GTR services. GTR has appointed members of its front line teams to its Accessibility Ambassador scheme to ensure consistency across all assisted travel services.

Delivered 12 'Try a Train' days to give disabled passengers the opportunity to experience travelling by train. Established an assisted travel support team within its Control to provide dedicated support to disabled customers on Southern services.

GTR's **Disabled People's Protection Policy** is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0011/22043/gtrdppp-review-letter.pdf 

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG)

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
617 times by GTR.

GTR received 44,615 
booked assistance 
requests in 2016-17
This accounted for 
3.7% of all booked 
assists made 
nationally in 2016-17

696 GTR staff undertook some form of disability and equality training in 2016-17:

•	 Since integration of the GTR franchise all new staff complete 
accessibility awareness training as part of their induction training.
•	 The scope of the induction training includes topics such 
as: what is disability?, differences between disabilities and 
impairments, hidden vs visible impairments and how to 
approach people with access needs. 
•	 A new eLearning module has also been developed with 590 
staff (240 managers) so far having completed it. The e-learning will be undertaken every two years.

## Govia Thameslink Railway Complaints Handling

revenue database)

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

last year
| 26.4%                    | Punctuality/reliability      |
|--------------------------|------------------------------|
| 11.1 PP                  |                              |
| 11.3%                    | Ticket buying facilities     |
| 2.8 PP                   |                              |
| -4.7 PP                  |                              |
| 6.4%                     | Ticketing and refunds policy |
| 5.3%                     | Speed of response            |
| 5.3 PP                   |                              |
| 4.7 PP                   |                              |
| 4.7%                     |                              |
| Delay compensation claim |                              |
| rejected                 |                              |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 Satisfaction With Complaints Handling Process

Source: ORR - Passenger satisfaction with complaint handling survey 

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

GTR's Complaints Handling Procedure is available at: http://www. orr.gov.uk/__data/assets/pdf_file/0016/23038/approval-gtrchp.pdf GTR reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Sought to improve complaints response times by employing 
more staff in the customer contact centre.
•	 Introduced Delay Repay 15 (DR15). •	 Made improvements to the end-to-end booking process. •	 Made improvements to the website to ensure it can act as a 
hub for all customer information and feedback. A further 4 GTR websites will be designed based on this model.

## Grand Central Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays

-3.4 PP
Note: Data for Grand Central is not available for all waves of the NRPS due to low response rates Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - September 2015  

https://goo.gl/c9FbqY
As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Note: Data for Grand Central is not available for all waves of the NRPS due to low response rates Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey

Note: Data for Grand Central is not available for all waves of the NRPS due to low response rates Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

Grand Central Twitter (@GC_Rail) is now available from 
0600 to 2200 (0800 to 2200 on Sundays) and can provide 
passengers with the latest travel information and operate as 
a channel for any customer enquiries. 

## Grand Central Accessibility And Inclusion Alternative Accessible Transport Actions To Improve Accessible Travel 2016-17

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 
Grand Central have committed to ensuring their website and information for passengers is updated within 24 hours of any changes.

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
Grand Central's **Disabled People's Protection Policy** 

is available at: http://www.orr.gov.uk/__data/assets/
pdf_file/0004/23962/grand-central-review-dppp.pdf not accessible to the passenger (because of planned engineering works for example); or 

•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was only provided 1 time by Grand Central. 

Data on the volume of booked assistance is available from the Rail Delivery Group for each train company that manages a station. Grand Central does not currently manage any stations which means this data is not available to report on.

## Disability And Equality Staff Training In 2016-17 Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

7 Grand Central staff undertook some form of disability and equality training in 2016-17:

•	 7 Senior Conductors were trained as part of Grand 
Central's ongoing Senior Conductor training programme on disability awareness.
•	 The classroom based training module includes role 
play exercises, followed by a group discussion, which identifies best practice. 
PP = percentage point change Source: Train Operating Companies

## Grand Central Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

of complaints
Complaint type
-9.8 PP
23.1%
Punctuality/reliability  
-5.3 PP
8.9%
Sufficient room for all passengers to sit/stand 
2.4 PP
5.0%
The helpfulness and attitude of staff on train 
-1.3 PP
3.9%
Ticketing and refunds policy  

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Grand Central's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0020/24158/ grand-central-chp-dec-letter.pdf Grand Central reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Upgraded Wi-Fi on every train and have introduced a Wi-Fi portal 
that offers a range of TV shows, movies, music and books.
•	 Enhanced the on-board cleaning service •	 Developed a new mobile website to offer a faster and simpler way 
to purchase tickets.

## Great Western Railway Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - April 2016 

https://goo.gl/JJXLtR
A new Local Plan is currently being reviewed by ORR and should be published shortly.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

GWR drivers in the Thames Valley can now receive 
announcements direct from the control centre during 
disruption allowing them to give better information 
to passengers.

To assist staff to answer customer queries, on-train hosts 
and station staff are being given hand held devices which 
will provide up-to-date and accurate information.

## Great Western Railway Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

GWR provide passengers with a **full refund** if their booked assistance is not provided and provides **free parking** for passengers holding disabled parking badges.

GWR carries out independent research to monitor the quality of its assisted travel service. 

It has also established customer panels and stakeholder advisory groups to look at improvements to the things customers are concerned about.

GWR's **Disabled People's Protection Policy** is available at:

http://www.orr.gov.uk/__data/assets/pdf_file/0004/24943/ first_gwr_dpp_review_letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
822 times by GWR.

In total 186 GWR staff undertook some form of disability and equality training:  

•	 All new staff in a customer facing role received 1 day 
training on vulnerable customers as part of their induction. 
•	 The course focuses on elements such as: the Equality 
Act 2010, ways in which GWR trains and stations are accessible, recognising different types of disability and being able to explain how different needs can be met, and being able to explain the GWR Priority Seat Card. 
•	 The course has been reviewed (and content supplied by) 
organisations including Purple Angels; MyGuide; Autism West Midlands and Parkinsons UK.

## Great Western Railway Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

24.4 PP
10.6%
Ticket buying facilities 
4.7 PP
9.4%
Ticket buying facilities - other 
2.5 PP
-2.1 PP
8.7%
Sufficient room for all passengers to sit/stand 
-4.5 PP
8.4%
Punctuality/reliability

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

GWR's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0015/23154/gwrchp-letter.pdf GWR reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 A large proportion of the 'miscellaneous' complaints relate 
to compensation. GWR is working with the Department for Transport to implement a Delay Repay 15 scheme, which would allow customer to seek compensation for delay of 15 minutes or more.
•	 It will look at the ORR research on TVMs in detail to understand 
what changes can be made to deliver improvements. 
•	 Introduced Electrostar trains between Hayes and Paddington 
which have increased capacity at peak times on this route, and will introduce Inter City Express trains later this year.

## Greater Anglia Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - July 2014  •	 Local Plan - January 2015  

https://goo.gl/VoZgGr
As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Greater Anglia has not provided any information on the actions it has taken to improve the information it provides to passengers.

## Greater Anglia Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Greater Anglia **call back** 5% of users of pre-booked assistance. Feedback is then used to monitor performance and data will be shared with stakeholders. Greater Anglia also uses an external organisation to complete mystery shops to help assess and monitor the accessibility of its services. 

Greater Anglia's Disabled People's Protection Policy is 
available at:

http://www.orr.gov.uk/__data/assets/pdf_file/0014/23036/
greater-anglia-dppp-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG)

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
392 times by Greater Anglia.

received 33,976 
booked assistance 
requests in 2016-17
assists made 
nationally in 2016-17

In total 978 staff undertook some form of disability and equality training in 2016-17: 

•	 Induction training •	 Refresher courses •	 Ticket office and train dispatch courses
Greater Anglia reports using DVDs and PowerPoint presentations, as well as referring to Rail Delivery Group training materials. Some use is made of practical sessions, including how to escort a partially sighted person, as well as safe use of ramps and wheelchairs.

## Greater Anglia Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

-7.0 PP
14.2%
Ticket buying facilities 
-8.9 PP
8.3%
Ticketing and refunds policy 
5.7%
Compensation claims process
5.7 PP
3.3%
Compensation claim rejected 
3.3 PP

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Greater Anglia's Complaints Handling Procedure is available at:  
http://www.orr.gov.uk/__data/assets/pdf_file/0013/23035/ greater-anglia-chp-letter.pdf Greater Anglia reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 A 'Right Time Railway' project to work with Network Rail on 
initiatives including: increased vegetation clearance, trespass and vandalism prevention measures, proactive cable testing, flooding prevention measures and fencing improvements.
•	 A 'one strike' policy for forgotten Railcard refund requests and 
relaxation of the duplicate season ticket policy, as well as staff training on how to deal with claims.
•	 A working group to improve processing of Delay Repay claims. 

## Heathrow Express Provision Of Information To Passengers Key Facts 

Owner group: Heathrow Airport Holdings Operator: Heathrow Express Source: Heathrow Express Data tables: TOC Key statistics

## Passenger Satisfaction With How Well The Train Company Deals With Delays

Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

## •	 Code Of Practice - No Link Published 

•	 Local Plan - no link published 
ORR is working with Heathrow Express to ensure that it has a compliant local plan by the Autumn 2017 deadline.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey

Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

Heathrow Express has not provided any information on the actions it has taken to improve the information it provides to passengers. 

## Heathrow Express Accessibility And Inclusion Alternative Accessible Transport Actions To Improve Accessible Travel 2016-17

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 
The Heathrow Express Disabled People's Protection Policy is currently in the process of being reviewed. 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 0 
times by Heathrow Express.

Note: This excludes un-booked assistance. 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. 

Source: Rail Delivery Group (RDG)

## Disability And Equality Staff Training In 2016-17 Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

This data is not available for Heathrow Express. 

All staff receive disability awareness training as part of their induction into the company. Refresher training for all staff takes place annually.

## Heathrow Express Complaints Handling

Complaints rate (per 100,000 journeys) and complaints response rate
Complaints 
457.7
rate (per 
100,000 
journeys)
Data not 
% answered 
in 20 
available
85.2
working 
days
2015-16
2016-17

PP = percentage point change
*Data not available for last year Source: Heathrow Express Data tables: Complaints rate by train operating company - Table 14.9

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17

Heathrow Express did not participate in our complaint handling survey during 2016-17. This has recently been resolved and they have been participating in the survey since rail period 2 2017-18.  

## Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Change on last year*
37.7%
Punctuality/reliability (i.e. the train arriving/departing on time) 
27.3%
Ticket buying facilities 
25.3%
Ticketing and refunds policy
6.0%
Provision of information on website or mobile apps
1.3%
The attitude and helpfulness of the staff at station

*Data is not available for last year PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17

Heathrow Express did not participate in our complaint 
handling survey during 2016-17. This has recently been 
resolved and they have been participating in the survey 
since rail period 2 2017-18. 

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17

Heathrow Express did not participate in our complaint 
handling survey during 2016-17. This has recently been 
resolved and they have been participating in the survey 
since rail period 2 2017-18. 

## Actions To Improve Services For Passengers 2016-17

The Heathrow Express Complaints Handling Procedure is available at: www.orr.gov.uk/__data/assets/pdf_file/0008/24200/ approval-heathrow-express-cph.pdf Heathrow Express reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 Rectified fleet issues to ensure a full service can be run. •	 Committed to re-evaluating the company's refund policy. •	 Created a new website and mobile app to improve how tickets 
can be purchased

## Hull Trains Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays

35%
-3.4 PP
Note: Data for Hull Trains is not available for all waves of the NRPS due to low response rates. Therefore, the change from last year is not available Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - May 2017 

## Https://Goo.Gl/Dk1Qa4

Although updated in 2017, the Local Plan refers to the previous Code of Practice. A fully compliant version needs to be shared with ORR  by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

Note: Data for Hull Trains is not available for all waves of the NRPS due to low response rates. Therefore, the change from last year is not available Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information On The Journey

PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

Hull Trains vehicles are equipped with a real-time onboard information system which gives connection information and updated arrival times during the journey. Hull Trains provides information about changes to individual services using Journeycheck, a website that gives detailed service information about each train. 

## Hull Trains Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Hull Trains surveys at least 5% of customers using its assisted travel service to get feedback and monitor performance. Hull Trains supports **Blue Assist** and all staff have been trained in the scheme. 

An Accessible Travel Group meets twice yearly to 
discuss performance and potential improvements. Outputs 
are also shared with station operators so they can consider 
improvements.

The Hull Train's Disabled People's Protection Policy 
is available at: http://www.orr.gov.uk/__data/assets/
pdf_file/0003/22872/hull-trains-dppp-letter.pdf

Data on the volume of booked assistance is available from the Rail Delivery Group for each train company that manages a station. Hull Trains does not currently manage any stations which means this data is not available to report on. 

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

for Hull Trains has not been provided Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 0 
times by Hull Trains.

In total 23 Hull Trains staff undertook some form of disability and equality training in 2016-17: 

•	 Training was given to on board managers, customer 
hosts and members of the customer service team.  
•	 Training was provided in two ways: a general Disability 
Awareness course which all customer-facing staff are expected to attend and a pilot sign language course. 
•	 The Disability Awareness training was provided by 
another train company in the same owning group (First Group) as a dedicated disability awareness and equality course. This encompassed a wide range of visible and non-visible disabilities.
•	 A bespoke sign language course was also provided 
separately by a local charity to meet staff needs at a specific station. 

## Hull Trains Complaints Handling

and complaints response rate

and revenue  database)

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

of complaints
Complaint type
| 11.1%                        | Upkeep and repair of the train    |
|------------------------------|-----------------------------------|
| 6.0 PP                       |                                   |
| 9.0%                         | Ticket buying facilities - other  |
| 2.3 PP                       |                                   |
| 1.6 PP                       |                                   |
| 8.9%                         |                                   |
| Sufficient room for all      |                                   |
| passengers to sit/stand      |                                   |
| 4.1 PP                       |                                   |
| 8.5%                         |                                   |
| The helpfulness and attitude |                                   |
| of staff on train            |                                   |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 Satisfaction With Complaints Handling Process How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

http://www.orr.gov.uk/__data/assets/pdf_file/0019/22861/hulltrains-chp-letter.pdf Hull Trains reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 A programme of staff training to improve the helpfulness and 
attitude of staff, and make sure all passengers have face to face contact with a member of staff before boarding a train. 
•	 To address performance areas within its control Hull Trains 
reports it has tackled key areas of failure by making sure trains can couple better, overhauling wheelsets, and improving the systems which cool the engines so they don't overheat.
•	 Improvements have been made to toilets, plug sockets, air 
conditioning, and cleaning on trains. 

## London Midland Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Operator Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - December 2016 

https://goo.gl/MySn3N
The Local Plan refers to the previous Code of Practice. A fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Station based staff have been equipped with tablets to give them easier access to real-time travel information. London Midland Twitter is now available between 7am and 7pm on weekdays to provide information to passengers.

## London Midland Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

London Midland commits to providing free access to its services for guide dogs in training. It provides a refund of the full cost of the affected journey if booked assistance is not carried out. It also provides posters at stations showing the morning peak trains on which it is easier to find a seat.

London Midland's Disabled People's Protection Policy 
is available at:  

http://www.orr.gov.uk/__data/assets/pdf_
file/0007/22687/london-midland-dppp-review-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
179 times by London Midland.

172 staff undertook some form of disability and equality training in total: 

•	 Training is provided in-house and the London Midland 
'Making Rail Accessible' booklet is given to relevant staff. 
•	 Some Rail Delivery Group training materials are also used. •	 Ramp deployment is covered as part of safety training.

## London Midland Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

of complaints
-1.6 PP
10.7%
Sufficient room for all passengers to sit/stand 
-1.0 PP
7.4%
Ticket buying facilities
4.9%
Ticket buying facilities - other 
0.1 PP
-0.3 PP
4.7%
Ticketing and refunds policy

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Operator Actions To Improve Services For Passengers 2016-17

London Midland's Complaints Handling Procedure is available at: 
http://www.orr.gov.uk/__data/assets/pdf_file/0020/23069/ approval-london-and-birmingham-chp-letter.pdf London Midland reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Worked to drive down the number of cancelled trains to 
improve reliability. 
•	 Implemented a number of short term actions to resolve short 
formations and taken steps to ensure the busiest services are not short-formed.
•	 Installed 28 new TVMs. •	 Taken steps to improve problems with a new booking engine, 
including putting FAQs on the website and briefing staff.

## London Overground Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Operator Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - November 2016 

https://goo.gl/J2TNEE 
The Local Plan refers to the previous Code of Practice. A fully compliant version needs to be shared with ORR by Autumn 2017. Documents are on the ARL website not TfL.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Online activities including Twitter are provided by TfL. All London Overground stations are staffed when trains are running and the station staff can make local announcements to keep passengers informed. 

An upgrade to class 378 trains to allow them to report 
passengers loadings in real-time for each carriage was 
completed in June 2017. This will help staff to direct 
passengers to less busy parts of the train.

## London Overground Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

London Overground advertises a **'Turn Up and Go'** service for assisting disabled and older passengers who wish to arrive and travel on its services without booking in advance.

It also carries out **accessibility mystery traveller surveys** 
in order to ensure continuous improvement to its services.

London Overground's Disabled People's Protection 
Policy is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0019/23068/
arriva-rail-london-dppp-approval-letter.pdf 

Note: London Overground provided 20,939 unbooked assists during 2016-17, these are excluded from the statistics above. 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. 

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided once by London Overground.

London Overground has committed to ensuring all of its employees undertake Diversity, Equality and Inclusion training by November 2017. Currently 46% of employees have undertaken this training. 45 more training sessions are planned for remaining employees. London Overground will also provide refresher training every two years. The training takes the form of drama based sessions. It also covers the Equality Act 2010 and unconscious bias. 

## London Overground Complaints Handling Complaints Rate (Per 100,000 Journeys) And Complaints Response Rate Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Change on last year
-0.8 PP
34.7%
Punctuality/reliability 
3.4 PP
11.7%
The attitudes and helpfulness of the staff at station  
-4.7 PP
7.7%
Ticket buying facilities
0.1 PP
6.1%
Provision of information about train times/platforms 
0.3 PP
3.8%
How request to station staff was handled 

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17

Note: London Overground participated in the survey from P1-P8 in 2016-17 and then for reasons beyond their control had to suspend participation. We are currently in discussions with London Overground and Transport for London about them rejoining the survey.

Source: ORR - Passenger satisfaction with complaint handling survey Data tables: Passenger satisfaction with complaints handling

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

London Overground's Complaints Handling Procedure is available at: http://www.orr.gov.uk/__data/assets/pdf_file/0013/23143/ arl-chp-letter.pdf London Overground reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 Worked closely with other train companies across its network 
to minimise the effects of disruption.
•	 Invested in staff training for all front line staff. •	 Provided prompts for staff to use for announcements 
during disruption.
•	 Started carrying out proactive servicing of its TVMs. •	 Explored the idea of enabling staff to carry out announcements 
via portable devices.

## Merseyrail Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays

*Not all data  available for Merseyrail due to low response rate for this question Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - July 2014  •	 Local Plan - October 2015 

## Https://Goo.Gl/1Qhtpn

As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

*Not all data available for Merseyrail due to low response rate for this question PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey

PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

The Wirral Line renewals work presented a challenge 
with the Central Liverpool Loop closed. An extensive 
and dedicated marketing campaign was undertaken to 
inform passengers about the disruption and to make 
them aware of the alternative arrangements, such as 
replacement bus services, that were being put in place.

Twitter operating hours were also increased during the 
Wirral Line works to give extra information and support 
to passengers. 

## Merseyrail Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Passengers requiring booked assistance only need to give 1 hours notice. Merseyrail have installed help points with induction loops on all platforms. Merseyrail record and report on the number of unbooked assistances their staff deliver.

Merseyrail's Disabled People's Protection Policy is 
available at:  

http://www.orr.gov.uk/__data/assets/pdf_
file/0006/22767/review-merseyrail-dppp-letter.pdf

Note: Merseyrail provided 67,978 unbooked assists during 2016-17, these are excluded from the statistics above. 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. 

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances:

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
351 times by Merseyrail.

68 Merseyrail staff undertook some form of disability and equality training in 2016-17, including: 

•	 Inclusion Training being run as a refresher to all managers 
in Merseyrail.
•	 Disability Awareness Refresher training for all station 
grades will be rolled out in 2017.
•	 Disability awareness training is delivered by an in house 
trainer and the inclusion training is provided by a trainer from the National Centre for Diversity.

## Merseyrail Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

of complaints
Complaint type
3.4 PP
5.2%
The attitudes and helpfulness of the staff at station 
-2.8 PP
4.9%
Miscellaneous
3.6%
Ticket buying facilities  
1.6 PP 3.5 PP
3.5%
Connections with other forms of public transport 

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Merseyrail's Complaints Handling Procedure is available at: http://
www.orr.gov.uk/__data/assets/pdf_file/0014/21353/merseyrail-
chp-dec-letter.pdf
Merseyrail reports it has taken some of the following actions to 
address issues highlighted in passenger complaints:

•	 Developed a customer relations improvement plan to ensure 
complaint response times are met. 
•	 Introduced periodic quality checks with staff. •	 Set up a periodic Service Improvement Group to review 
disruption from a customer's perspective.
•	 Developed a new communications approach between 
customer relations and station staff.
•	 Produced a new leaflet and online delay compensation claim 
form to provide more information on refunds and make the claims process easier for passengers.

## Northern Provision Of Information To Passengers Key Facts  Passenger Satisfaction With How Well The Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

## •	 Code Of Practice - October 2016 

•	 Local Plan - April 2016 

https://goo.gl/q782js
As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Northern has implemented a '2468' training programme which reminds guards of the need to keep passengers informed when trains are late. To make claiming delay compensation easier for passengers, Northern have created a dedicated web address at www.northernrailway.co.uk/delayrepay Mobile tickets are now available for passengers using the Northern app.

## Northern Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Northern have committed to participating in the Blue Assist card scheme. Northern has provided a step free map of its network.

Northern has committed to carry out post travel surveys 
for passengers who have booked assistance to ensure 
that the assistance was provided satisfactorily and to seek 
suggestions for further improvements.

Northern's Disabled People's Protection Policy is 
available at:   

http://www.orr.gov.uk/__data/assets/pdf_file/0005/24953/
arriva-rail-north-dppp-approval.pdf

Note: This excludes un-booked assistance. 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. 

Source: Rail Delivery Group (RDG)

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Source: Train Operating Companies Data tables: Complaints by NRPS category by TOC - Table 14.5

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
278 times by Northern. 

338 Northern staff undertook some form of disability and equality training in 2016-17:

•	 225 staff attended a drop-in roadshow. •	 Roadshows were completed at 17 depots on a total of 
33 days, including the Customer Experience Centre in Sheffield.
•	 80 new staff attended a 1 day Disability Awareness course •	 32 staff completed level 1 Deaf awareness training. •	 Northern have recently formed a partnership with UK 
disabled persons charity 'Enhance the UK' and Blue Assist.

## Northern Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 11.5%                         | Miscellaneous    |
|-------------------------------|------------------|
| 11.5 PP                       |                  |
| 2.1                           | PP               |
| 10.1%                         |                  |
| Sufficient room for all       |                  |
| passengers to sit/stand       |                  |
| 4.7 PP                        |                  |
| 6.8%                          |                  |
| The attitudes and helpfulness |                  |
| of the staff at station       |                  |
| 2.2 PP                        |                  |
| 6.3%                          |                  |
| The helpfulness and attitude  |                  |
| of staff on train             |                  |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Northern's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0016/21355/ northern-chp-dec-letter.pdf Northern reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Recruited 250+ staff into the role of 'On-Time Champions' to 
provide frontline insight into how performance can be improved.
•	 Worked with Transport Focus to refine its response template for 
performance related complaints.
•	 Enlisted help from a sister train company to help expedite the 
processing of Delay Repay claims. 

## Scotrail Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - September 2016   •	 Local Plan - May 2017  

https://goo.gl/pPwUWa 

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Research showed that passengers were reluctant to press 
the Help Point, thinking it was for emergency use only. 
These are now being rebranded to make their purpose 
clearer and a poster campaign has been run.

Onward connection screens are to be provided at 16 
stations and an updated passenger app was launched in 
April 2017.

Countdown mode (e.g. 'next train departs in X minutes') 
has been introduced at Glasgow low level stations where 
frequent services operate.

## Scotrail Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Abellio ScotRail has set up a Stakeholder Equality Group to improve involvement with disabled people and customers with reduced mobility. The group offers guidance on matters relating to equality, social inclusion and accessibility.

Abellio ScotRail provides **free parking** for all disabled badge holders at station car parks.

Abellio ScotRail's **Disabled People's Protection Policy** 
is available at: http://www.orr.gov.uk/__data/assets/pdf_ file/0008/22013/scotrail-dppp-review-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
1,097 times by Abellio ScotRail.

•	 All customer facing Abellio ScotRail staff receive disability 
awareness training when they join the company.
•	 Ongoing refresher training is given through Operations 
Learning and Development Teams.
•	 Training is delivered by ScotRail Accredited Trainers and 
Deaf Blind Scotland.

## Scotrail Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 21.1%                        | Punctuality/reliability      |
|------------------------------|------------------------------|
| 2.1 PP                       |                              |
| -3.4 PP                      |                              |
| 8.0%                         |                              |
| Sufficient room for all      |                              |
| passengers to sit/stand      |                              |
| 1.0 PP                       |                              |
| 7.8%                         |                              |
| The attitude and helpfulness |                              |
| of the staff at station      |                              |
| 7.5%                         | Ticketing and refunds policy |
| -4.6 PP                      |                              |
| 5.9%                         | Ticket buying facilities     |
| 1.1 PP                       |                              |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Abellio Scotrail's Complaints Handling Procedure is available at: 
http://www.orr.gov.uk/_data/assets/pdf_file/0011/
Abellio Scotrail reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 Developed a Performance Improvement Plan which has helped 
to lower complaints in relation to both delays and capacity.
•	 Undertaken staff engagement and re-launched the Inspire 
programme.
•	 A mystery shop programme is in place to proactively identify 
issues, and also allows for rapid feedback on any staff issues.

## South West Trains Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - June 2017 

https://goo.gl/5Lb98w

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

In addition to promoting the national disruption survey, SWT runs its own which can be accessed at www.tellswt.co.uk/
In response to passenger feedback from its surveys, SWT has changed the way it reports incidents to reduce the use of railway jargon.

## South West Trains Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

SWT allows passengers travelling with an assistance dog to upgrade to First Class for free if there are no Standard Class seats available.

A **new type of ticket machine** at some stations provides video connection with a remote ticket agent who can assist with the ticket purchase if necessary.

SWT commits to ensuring passengers who cannot access the on-train catering are able to buy refreshments.

SWT's **Disabled People's Protection Policy** is available at: 
 

http://www.orr.gov.uk/__data/assets/pdf_file/0020/22871/ swt-dppp-letter.pdf 

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
145 times by SWT.

At least 253 SWT staff undertook some form of disability and equality training in 2016-17: 

•	 253 staff new to customer facing roles received disability and 
equality training. 
•	 The training was one full day and consisted of a mix of 
powerpoint, flipchart and video clips. 
•	 Practical training was also part of the training day and staff practiced 
assisting visually impaired customers and wheelchair users.
•	 In February 2017 an internal accessibility awareness campaign 
also took place where staff were re-briefed. These figures are not included in the above total as the numbers were not recorded reliably.

## South West Trains Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 38.6%                        | Punctuality/reliability          |
|------------------------------|----------------------------------|
| 21.7%                        | Ticket buying facilities - other |
| 19.9 PP                      |                                  |
| -1.3 PP                      |                                  |
| 4.6%                         |                                  |
| Attitudes and helpfulness of |                                  |
| staff at station             |                                  |
| -1.9 PP                      |                                  |
| 4.3%                         | Ticket buying facilities         |
| 2.2 PP                       |                                  |
| 3.6%                         |                                  |
| Provision of information on  |                                  |
| website or mobile apps       |                                  |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

South West Trains' Complaints Handling Procedure is available at: 
http://www.orr.gov.uk/__data/assets/pdf_file/0009/22896/ stagecoach-south-western-trains-chp-letter.pdf South West Trains reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 A Performance Director has been appointed to improve 
punctuality. The major Wessex Capacity Improvement Programme is being undertaken, which will include longer platforms and new trains.
•	 91 new ticket machines have been installed that connect via 
video link to a new Video Contact Centre.
•	 Changes are being made to the staff complaint process to 
make sure issues are addressed through training.
•	 A new website was introduced in 2016. Changes have since 
been made to improve functionality.

## Southeastern Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - October 2015 

https://goo.gl/DbofX1 
As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

A new website was launched in 2016 giving full integration of the National Rail Enquiries disruption feed. A new format for disruption messages has been introduced and is being used by National Rail Enquiries for Southeastern incidents. Realtime information is incorporated in the journey planner, offering consistent information with National Rail Enquiries.

## Southeastern Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Southeastern ask for **12 hours' notice** to book assistance on their own services. 

The Southeastern website includes the 'Recite Me' app which makes information more accessible by including a screen reader to assist the visually impaired and the ability to increase font size and change background colours to suit users' requirements.

A **priority seat card** initiative allows disabled passengers to find seats on services more easily. 

Southeastern's **Disabled People's Protection Policy** 
is available at:  http://orr.gov.uk/__data/assets/pdf_ file/0017/21770/southeastern-dppp-review-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
1,194 times by Southeastern. 

475 Southeastern staff undertook a  2-day course,1.5 days of which covered disability issues and how these affect customer service, this included:

•	 426 operational staff such as drivers, conductors, station staff 
and revenue protection staff;
•	 14 'customer ambassadors' who play a customer facing 
assistance role; and
•	 35 staff based at the customer services call centre.
Training is classroom based, with opportunities for the trainees to carry out practical tasks such as assisting a wheelchair user. Hidden disabilities are also covered so that delegates have a better appreciation of how this may affect individuals and what they can do to make a difference. 

## Southeastern Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

| 18.1%   | Punctuality/reliability      |
|---------|------------------------------|
| -14.3PP |                              |
| 8.3%    | Smartcards                   |
| 8.3 PP  |                              |
| 6.8%    | Ticketing and refunds policy |
| -4.0 PP |                              |
| 5.9%    | Delay claim rejected         |
| 5.9 PP  |                              |
| 5.7%    | Facilities on board          |
| 1.0 PP  |                              |

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

Southeastern's Complaints Handling Procedure is available at: http://orr.

gov.uk/__data/assets/pdf_file/0020/22727/southeastern-chp-letter.pdf Southeastern reports it has taken some of the following actions to address issues highlighted in passenger complaints :

•	 Working with Network Rail to more efficiently diagnose root causes of 
delays to reduce their frequency and impact. 
•	 Moving to the 'Right Time' metric to measure performance, and being 
one of the first companies to do so. 
•	 Making improvements to 'Key' smartcard in response to passenger 
complaints. 
•	 The penalty fares appeals process has been made easier and moved online. •	 The main area of complaint around 'facilities on board' has been overcrowding and Southeastern is in discussions to run longer trains with more capacity. 

## Tfl Rail Provision Of Information To Passengers Key Facts 

Source: Train Operating Companies and LENNON (the rail industry's ticketing and revenue database)

## Passenger Satisfaction With How Well The Operator Deals With Delays

*Note: This data is not published in the National Rail Passenger Survey due to a low response rate of fewer than 50 people.

PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016   •	 Local Plan - May 2015  

https://goo.gl/dWG9Qe 
As the Code of Practice has changed since the Local Plan was published, ORR is working with TfL Rail to produce a updated Local Plan. Documents are published on the MTR Crossrail website rather than TfL.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur

*Note: This data is not published in the National Rail Passenger Survey due to a low response rate of fewer than 50 people.

PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Passenger Satisfaction With The Provision Of Information During The Journey

Note: not all data available due to low response for this question PP = percentage point change Source: Transport Focus, National Rail Passenger Survey The NRPS takes place twice a year, in Spring (S) and Autumn (A)

## Actions To Improve Information For Passengers 2016-17

New Crossrail trains were introduced during 2017. Their advanced passenger information system  includes connection information when arriving at stations. Upgrades of the station information system at stations on the Shenfield line will allow local announcements to be made by staff at the station during disruption This year the Customer Experience Director and Head of Customer Experience delivered communication during disruption training to all customer facing staff.

## Tfl Rail Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

TfL Rail advertises a 'Turn Up and Go' service for assisting 
disabled and older passengers who wish to arrive and 
travel on TfL Rail services without booking in advance. This 
includes help with luggage. 

TfL Rail's Disabled People's Protection Policy is 
available at: http://www.orr.gov.uk/__data/assets/pdf_
file/0013/23044/review-tfl-rail-dppp.pdf

Note: TfL Rail provided 772 unbooked assistances during 2016-17. These are excluded from the statistics above. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

Note: TfL Rail received a low number of accessibility complaints (9 in 2015-16, and 21 in 2016-17). Due to the low numbers a  percentage change for TfL Rail has not been provided Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
55 times by TfL Rail.

TfL Rail reports that all 754 employees attended a company induction which included disability and equality training. In addition all employees attended an equality workshop. TfL Rail reports that it runs specific accessibility training four times per year for frontline staff and managers. This covers the Social Model of Disability within a railway context. 260 staff and managers completed ramp training during April and May 2017

## Tfl Rail Complaints Handling

Complaints rate (per 100,000 journeys) and complaints response rate

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17

TfL did not participate in the ORR complaints handling survey in 2016-17 but are in discussions with us to join the survey for 2017-18.

## Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Change on last year
36.9%
Punctuality/reliability 
2.2 PP
-2.0 PP
9.0%
Attitudes and helpfulness of staff at station  
1.6 PP
5.6%
Personal security whilst using station  
5.2%
Facilities and services   
0.2 PP
4.3%
Personal security on board
0.2 PP

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17

TfL did not participate in the ORR complaints handling survey in 2016-17 but are in discussions with us to join the survey for 2017-18.

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17

TfL did not participate in the ORR complaints handling survey in 2016-17 but are in discussions with us to join the survey for 2017-18.

## Actions To Improve Services For Passengers 2016-17

TfL Rail's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0013/23125/ approval-mtr-corporation-trading-as-tfl-chp-letter.pdf TfL Rail reports it has taken some of the following actions to address issues highlighted in passenger complaints: 

•	 Reviewed all service performance complaints to identify how 
improvements to communication during disruption could be made and invested in a new employee app and a new radio system so that teams can communicate easily during disruption.
•	 Developed a new procedure to investigate complaints about staff. •	 Implemented measures to prevent crowding on stations and trains. •	 Closely managing cleaning standards and recently changed 
cleaning supplier.

## Transpennine Express Provision Of Information To Passengers Key Facts Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - June 2014 

https://goo.gl/1ahVGp
As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017. An early draft has been reviewed.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

A new customer app was launched in 2016 which includes a real-time multi-modal journey planner. New ticket machines that include real time departure information have been introduced. New customer information screen software is rolling out to all 19 TPE stations, including Manchester Airport for the first time.

## Transpennine Express Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

TPE provides **free car parking for blue badge holders**. It provides **compensation** for passengers if booked assistance is not provided. It runs an Accessibility Consultation Forum, made up of a group of passengers with accessibility needs with whom it consults on access improvements.

TPE's **Disabled People's Protection Policy** is available at:  

http://www.orr.gov.uk/__data/assets/pdf_file/0010/21142/ tpe-review-of-dppp-letter.pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG)

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
50 times by TPE.

In total **564** members of staff undertook some form of disability and equality training in 2016-17:

•	 As part of their new franchise TPE committed to providing 
disability awareness training for all customer service staff.
•	 564 staff (91% of frontline staff) undertook disability and equality 
training in total, including conductors, catering hosts, revenue protection staff and managers.
•	 The course lasts 1 day and is delivered in-house. It was 
developed in partnership with Action on Hearing Loss, RNIB and Dementia Friends. Part of the programme involves e-learning which takes place in advance of the course using materials from Action on Hearing Loss and Dementia Friends. Materials supplied by RNIB for a practical exercise are also used. 

## Transpennine Express Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

10.6 PP
21.2%
Sufficient room for all passengers to sit/stand 
-12.1 PP
10.4%
Punctuality/reliability
-8.7 PP
9.3%
Facilities on board
8.5%
Ticketing and refunds policy
3.0 PP
6.7%
Ticket buying facilities - other 
1.5 PP

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

TPE's Complaints Handling Procedure is available at: http://www. orr.gov.uk/__data/assets/pdf_file/0012/21144/tpe-review-ofchp-letter.pdf TPE reports it has taken some of the following actions to address issues highlighted in passenger complaints: •	 220 new trains on order to provide more seats. Until it starts to 

receive the first new trains in Spring 2018 it will ensure planning of service capacity and train maintenance maximises current rolling stock.
•	 On-board catering has been improved, including by opening a 
depot for customer hosts in Edinburgh.
•	 Introduction of a 'buy on board' card for times when the 
booking office is busy. Staff have been deployed to floor walk, sell tickets and train customers on new TVMs.
•	 Changes have been made to the mobile app, including 
improvements to the Live Departure boards information.

## Virgin Trains East Coast Provision Of Information To Passengers Key Facts  Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - October 2016  •	 Local Plan - March 2017 

https://goo.gl/zcfmfC 
Although updated in 2017, the Local Plan refers to the previous Code of Practice. A fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

The @Virgin_trainsEC Twitter account now provides a 24 
hour service to over 136,000 followers to provide service information updates and answer queries. 

## Virgin Trains East Coast Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

VTEC commit to providing a free upgrade to the first 
class wheelchair space (if available) for a passenger and 
companion when a standard wheelchair space is not 
available to book.

VTEC is piloting the Virgin Explorer App at King's Cross 
and Peterborough stations. It is designed to help with 
wayfinding around the stations and provide location based 
engagement e.g. relevant notifications.

VTEC's Disabled People's Protection Policy is 
available at: http://www.orr.gov.uk/__data/assets/pdf_
file/0019/22906/vtec-dppp.pdf

Note: This excludes unbooked assistance. 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.

Source:  Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17 Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers. 
In 2016-17 alternative accessible transport was provided 
80 times by VTEC.

352 VTEC staff undertook some form of disability and equality training in 2016-17:

•	 299 staff attended induction training covering an introduction 
to disability awareness. Of these 119 front line staff went on to attend the full disability awareness training course. 
•	 A 'Front Line Ready' training workshop also took place and was 
attended by 53 non-frontline mangers and covered aspects of disability awareness.
VTEC are also piloting a new practice-based approach to training staff who assist disabled passengers. It is intended to make staff more confident when interacting with passengers in real life situations.

## Virgin Trains East Coast Complaints Handling Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17 Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
last year
23.9%
Facilities on board  
5.0 PP
12.8%
Ticket buying facilities - other  
8.2 PP 4.8 PP
10.7%
Sufficient room for all passengers to sit/stand 
5.9%
Company policy (misc)
5.6 PP
-1.1 PP
5.6%
Ticketing and refunds policy  

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17 How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17 Actions To Improve Services For Passengers 2016-17

VTEC's Complaints Handling Procedure is available at: 

http://www.orr.gov.uk/__data/assets/pdf_file/0019/22933/ vtec-chp-letter.pdf VTEC reports it has taken some of the following actions in 2016-17 to address issues highlighted in passenger complaints: 

•	Refurbished all trains with new seats and lighting, improved 
wifi and quality of food. 
•	Made improvements to on-board toilets. •	Installed new, easier to use ticket machines. •	Improved information screens to give arrival time information. •	Introduced an infographic to help customers without a 
reservation find a seat.

## Virgin Trains West Coast Provision Of Information To Passengers Key Facts  Passenger Satisfaction With How Well The Train Company Deals With Delays Transparency And Accountability

All train operators should publish the actions they are taking to improve passenger information in a **Local Plan**, together with the industry **Code of Practice** and an Annual Progress Report. Local Plans should be reviewed annually.

•	 Code of Practice - July 2014  •	 Local Plan - September 2015 

## Https://Goo.Gl/K8Zq3Z

As the Code of Practice has changed since the Local Plan was published, a fully compliant version needs to be shared with ORR by Autumn 2017.

## Passenger Satisfaction With The Usefulness Of Information When Delays Occur Passenger Satisfaction With The Provision Of Information During The Journey Actions To Improve Information For Passengers 2016-17

Smart devices continue to be rolled out to frontline staff to give them access to the latest information during periods of disruption. Train Managers have been through a refresher training programme to remind them of their responsibilities during periods of disruption. 

## Virgin Trains West Coast Accessibility And Inclusion Actions To Improve Accessible Travel 2016-17

Virgin Trains West Coast has a cross-functional Journey Care Group which meets regularly to review feedback from: frontline teams, customer research (conducted twice per year by an independent agency) and customer correspondence. The group reviews and considers suggestions for improvements. 

Virgin Trains West Coast's Disabled People's Protection 
Policy is available at:  

http://www.orr.gov.uk/__data/assets/pdf_
file/0012/23331/review-west-coast-trains-dppp-letter.
pdf

Note: This excludes unbooked assistance. 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.

Source: Rail Delivery Group (RDG) Data tables: Rail passenger assists by station operator - Table 16.03

## Accessibility Complaints Rate (Per 100,000 Journeys) 2016-17

PP = percentage point change Source: Train Operating Companies 

## Alternative Accessible Transport

All operators must provide free alternative transport to take passengers to the nearest or most convenient accessible station in certain circumstances: 

•	 When a station is inaccessible to the passenger; •	 When rail replacement services are running that are 
not accessible to the passenger (because of planned 
engineering works for example); or 
•	 When there is disruption to services at short notice that, 
for whatever reason, makes services inaccessible to disabled passengers.
In 2016-17 alternative accessible transport was provided 
86 times by Virgin Trains West Coast. 

booked assistance 
requests in 2016-17
This accounted for 9.2% 
of all booked assists 
made nationally in 

2016-17.

In total 98 staff undertook some form of disability and equality training in 2016-17: 

•	 The training was provided to new station and on-train 
team members as part of orientation training for new starters. 
•	 The training was delivered by VTWC specialist in-house 
trainers using materials developed by both VTWC and the Rail Delivery Group.  

## Virgin Trains West Coast Complaints Handling

Complaints rate (per 100,000 journeys) and complaints response rate
Change 
Complaints 
on last year
rate (per 
100,000 
181.8
154.3
-15.1%
journeys)
% answered 
in 20 
88.4
working 
days

## Passenger Satisfaction With Each Aspect Of Complaint Handling Process 2016-17

Virgin Trains West Coast currently conducts 
its own customer satisfaction survey into 
complaints handling, and did not participate 
in the ORR complaints handling survey during 
2016-17. It has since committed to joining the 
ORR survey during the course of 2017-18.

## Top 5 Reasons For Complaints 2016-17

Percentage of complaints
Complaint type
Change on last year
20.6%
Facilities on board  
0.3 PP
-0.7 PP
11.7%
Ticketing and refunds policy 
-10.1 PP
11.3%
Punctuality/reliability
11.0%
Ticket buying facilities - other  
4.3 PP
7.2%
Ticket buying facilities
2.6 PP

PP = percentage point change Source: Train Operating Companies 

## Passenger Satisfaction With Complaint Handling Process 2016-17

Virgin Trains West Coast currently conducts 
its own customer satisfaction survey into 
complaints handling, and did not participate 
in the ORR complaints handling survey during 
2016-17. It has since committed to joining the 
ORR survey during the course of 2017-18.

## How Did The Passenger Feel About The Train Company In Light Of How Their Complaint Was Handled 2016-17

Virgin Trains West Coast currently conducts 
its own customer satisfaction survey into 
complaints handling, and did not participate 
in the ORR complaints handling survey during 
2016-17. It has since committed to joining the 
ORR survey during the course of 2017-18.

## Actions To Improve Services For Passengers 2016-17

Virgin Trains West Coast's Complaints Handling Procedure is available at: http://www.orr.gov.uk/__data/assets/pdf_ file/0008/22895/virgin-trains-chp-letter.pdf Virgin Trains West Coast reports it has taken some of the following actions to address issues highlighted in passenger complaints:

•	 Mobile ticketing is promoted as one of the easiest methods for 
customers and in November 2016 the e-ticket was added to the Apple Wallet to make it easier to access.
•	 An app called BEAM can now be downloaded to provide free 
onboard entertainment. 
•	 Where customers are delayed by more than 30 minutes, 
automatic compensation is reimbursed to those who booked Advance tickets via its website or app. 

## Annexes And Glossary 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. DfT - The Department for Transport; 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 - 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.

National Rail Conditions of Travel - 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 18 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 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.

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 - 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.

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.

## Annex A - Passenger And Station Licences And Orr'S Consumer Law Enforcement Powers Passenger And Station Licences

Licensing is one of ORR's core statutory functions. 
Any entity that wants to operate a train, station, 
network or light maintenance depot must be covered 
by a licence or licence exemption.

In relation to our consumer role, there are three 
important passenger and station licence conditions: 
passenger information including during disruption 
(PIDD), disabled people's protection policies (DPPP) 
and complaints handling procedures (CHP). These 
conditions are covered in the main report, as well as 
in the individual data sheets for each train company. 

Model licences and more information can be found 
on our website: http://www.orr.gov.uk/rail/licensing/
licensing-the-railway/model-licences-and-statements-
of-national-regulatory-provisions-snrps. 

## Consumer Law Enterprise Act 2002

ORR is a designated enforcer of consumer law under 
Part 8 of the Enterprise Act 200256. As such, ORR 
can take action in relation to breaches of certain 
pieces of consumer law, where there is evidence of 
"harm to the collective interests of consumer". We 
have published guidance on our approach to the 
enforcement of consumer law in the rail sector57.

The most relevant pieces of consumer law are the Consumer Rights Act 201558 and the Consumer Protection (from Unfair Trading Regulations) 200859.

 

## The Consumer Rights Act 2015

The Consumer Rights Act 2015 came fully into force 
in rail on 1 October 2016. The Act provides individual 
consumers with rights in relation to the sale and 
supply of goods, services, and digital content and 
contains provisions relating to the fairness of 
contract terms.

For example, services must be provided with 
"reasonable care and skill" and in accordance 
with how the trader describes the service. Where 
services don't comply with these requirements, the 
Act provides remedies to consumers, which include 
a reduction in the price (or a refund where the 
consumer has already paid for the service).

## The Consumer Protection (From Unfair Trading) Regulations 2008 (Cprs)

The Regulations prohibit unfair, misleading, and 
aggressive commercial practices. Commercial 
practices can mislead by act or omission and traders 
are effectively required to provide consumers with 
the information that is material to their decision, for 
example to buy a ticket or exercise their rights, and to 
do so in a way that is clear, unambiguous, and timely.

The industry's Retail Information Code of Practice 
provides guidance on how these information 
requirements translate to the rail context60.

## Annex B - Compensation Gap: Methodology And Background

One of the mechanisms we are using to assess 
the extent to which the actions and progress 
described above are having an impact in terms of 
passengers actually making claims is what we call 
our 'compensation gap' analysis, which measures the 
difference between compensation that is due and 
compensation that is paid.

In our March 2016 response report61 we summarised 
a range of evidence on the compensation gap. This 
range included:

■
■Survey evidence, obtained by asking eligible 
passengers whether they had claimed delay compensation; and
■
■The results of original top-down analysis carried 
out by ORR in early 2016.

In our March 2016 response report we noted that the 
full range of estimates available at the time 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 that "overall 
it seemed fairly likely to us that on the basis of 
volume around 80% or more of potential claims 
go unclaimed… but … value-based estimates are 
suggestive of a considerably smaller compensation 
gap." We reached this view based on our assessment 
of all of the information available to us at the time. 

In the March 2016 response report we committed to 
carrying out an update, described in the remainder 
of this Annex, specifically to, "…working with the 
industry to agree…indicators that will show how the 
take-up of compensation is changing over time".

In June 2016 we wrote to train companies asking for 
their comments on a proposed framework for our 
update. The proposal was essentially to carry out 
a repeat of our March 2016 exercise. This proposal 
received broad agreement from train companies, 
albeit with some concerns, particularly regarding the 
potential for misleading comparisons to be made 
between train companies. Reflecting these concerns 
we said in December 201662 that we, "…[did] not plan 
to publish any train company-specific estimates of 
the compensation gap without further engagement 
with the relevant stakeholders." 

In our update we looked for progress by comparing:

■
■Estimates of the compensation gap that were 
available in March 2016, i.e. at the time we published our response report, with
■
■Estimates of the compensation gap obtained 
from surveys carried out subsequent to March 2016, and from ORR's own estimates updated by drawing on the most recent data possible.

## Updated Top Down Analysis - Approach

Our update closely followed the previous 
methodology, meaning that the key description 
and caveats set out in Chapter 7 of the March 2016 
response report apply equally to this update. The 
principal refinements that we made in our update 
were as follows:

■
■Unit of measurement - in our March 2016 
response report we published estimates calculated based on both the monetary value and number of pay-outs. In this 2017 update we focus on the latter measure only. ­ -	 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.
­ -	 A second and more important reason reflects 

the limitations of the approach used in our 
March 2016 response report, whereby we 
assumed that all delayed passengers had paid 
the average fare for the train company they 
were travelling with. This means that:

■
■	 Focusing on the number of pay-outs rather 
than their value reduces the number of approximate assumptions used in our calculations.
■
■	 Given that average fares only change slowly 
over time, trends over time in volume and value-based results would be very similar.
■
■Time period - in this update we restricted our 
analysis to data from rail periods 9 through 13 inclusive only, i.e. between mid-November and the end of March. We collected a dataset that included these periods in three financial years: 2014-15, 2015-16, and 2016-17. We followed this approach in order to: -­
	 Use the newest possible data at the time of 
writing, so as to attempt to capture the impact of the measures put in place by train companies in the months following the March 2016 response report; and also to
-­
	 Make comparisons with earlier years without 
the need for seasonal adjustment.
■
■Range of estimates - in March 2016 we estimated 
the amount of compensation due by assuming that train companies would be liable to pay delay 
compensation for all delays of 30 minutes63 or 
more, calculated as the sum of both delay minutes and deemed minutes64. In our update we present 
figures as a range whereby we estimate:
-­
	 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
-­
	 Secondly, compensation due calculated (as in 
our March 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

## - ■Other - Various, Most Notably:

­ -	 We modified our approach in order to arrive at 
more accurate estimates of the average number of passengers per service by stop; and
­ -	 Due to data issues we arrived at our final 
estimates of the compensation gap by excluding the information submitted to us by GTR.

## Results And Conclusions Survey Evidence

The survey evidence that has become available since we wrote the March 2016 response report suggests that there has been an increase in the proportion of due compensation that is claimed.

 

Between March and April 2016 we, together with 
Transport Focus and DfT, conducted passenger 
research into delay compensation. This research 
showed that 35% of eligible passengers claimed 
compensation or received automatic compensation 
for their most recent delay. This represented 
a significant increase from the 12% of eligible 
passengers found to be claiming in previous 
Transport Focus research65 carried out in 2013.

We have additionally considered newer results from 
Transport Focus's bi-annual National Rail Passenger 
Survey (NRPS)66. As shown in the Figure at the end of 
this Annex, this source also shows an increased take-
up in delay compensation.

## Results Of Our Updated Top-Down Analysis

We describe the results of our updated analysis in 
the paragraphs below. In the light of the limitations 
of our approach and the important differences 
that exist between train companies67 we have not 
published results relating to individual firms.

We estimated the 'payout ratio' (the proportion 
of compensation due that is paid out by train 
companies) for all train companies individually, and 
found, across our three years of comparison, an 
improved payout ratio for around three quarters of 
train companies. This still left around a quarter of 
train companies for whom we had observed a fall in 
the proportion of due compensation, but for all of 
these there were possible mitigating circumstances, 
for example that:

■
■The fall in the payout ratio was small enough (e.g. 
around a single percentage point) to fall within the possible margins of error given the limitations of our approach;
■
■The number of successful claims had increased 
but this increase had been outweighed by an increase in the number of passengers eligible to claim; and
■
■The fall in the payout ratio had been at least in part 
caused by a move from a passenger charter to delay repay scheme, leading to a significant increase in the number of eligible passengers that had been accompanied by a proportionately smaller increase in the number of potential claims.

At an aggregate (all train companies) level the 
proportion of potential compensation claims that 
were paid out increased as follows (as above, periods 
9 to 13 inclusive only). The ranges of our estimate of 
the compensation paid are detailed in the Figure at 
the end of this Annex:

■
■2014-15: between 13% and 31%;
■
■2015-16: between 17% and 39%; and
■
■2016-17: between 21% and 53%.
The bottom ends of these ranges, calculated using the sum of delay minutes and deemed minutes, correspond to the estimates cited in the March 2016 response report. 

## All Evidence - Summary And Conclusions

As outlined in the previous section, all the data 
sources (surveys and our own top-down analysis) 
described in this Annex show an increase in the 
proportion of potential claims that are successfully 
claimed by delayed passengers. This improvement is 
summarised in the Figure at the end of this section.

## In Summary:

■
■The April 2016 ORR/Transport Focus survey 

shows a claim rate (35%) some 23 percentage 
points higher than in the findings of the 2013 
survey evidence (12%). It is not possible for us to 
determine how much of this improvement was due 
to ORR's intervention following the Which? super-
complaint. Firstly, the two results were obtained 
three years apart68, and, secondly, methodological 
differences between the two mean that results 
are not directly comparable69. But at a minimum 
the improvement offers support to the increases 
found using other methods (see below).

■
■Successive waves of the NRPS show a continued 
improvement over 2013-2016, with an improvement of around 3 percentage points occurring between the autumn 2015 and autumn 2016 survey waves, i.e. since the publication of our March 2016 response report. In our final assessment we have placed less weight on this result than either our top-down analysis or the survey evidence referred to in the previous bullet, which was focused on compensation issues and had a much larger sample size.
■
■The ORR top down analysis shows an increase 
in claim rates as follows between 2014-15 rail periods 9-13 and 2016-17 rail periods 9-13 with an overall range of 7 to 22 percentage points: ­ -	 Bottom of range: 7 percentage points; -­
	 Midpoint of range: 15 percentage points; and
­ -	 Top of range: 22 percentage points.

The high increase in the top of the ORR range relative 
to the bottom reflects significantly greater growth 
in the volume of payouts than in the number of 
services that were significantly late, which was partly 
offset by a relatively high increase in the number of 
services that were cancelled.

Given the measurement difficulties summarised 
in our response report it would be not be possible 
for us to arrive at a single definitive estimate of the 
proportion of due compensation that is now being 
claimed. The various available results were obtained 
using in some cases very different methodologies 
and datasets. We consider, however, based on the 
available evidence, that it would be reasonable for us 
to conclude that since March 2016 when we published 
our response to the Which? super-complaint there has 
been an increase of around 10 percentage points in 
the proportion of due compensation that has paid to 
passengers. This represents important progress.

We reached this view by rounding up the 7% 
increase at the bottom of the ORR analysis range to 
the nearest 10%. We carried out this rounding up in 
order to place some weight on the improvements 
in takeup implied by the ORR/Transport Focus 
survey evidence (23%) and also to some extent the 
increases shown by our survey results , whilst taking 
the view that:

■
■We should place relatively low weight on the survey 
results given the issues involved in comparing the 2013 and 2016 results (see above); and
■
■Within the ORR top-down ranges we should place 

most weight on the bottom ends of the ranges, 
where, as explained above, we estimated total 
compensation liability using the sum of delay 
minutes and deemed minutes. These represent 
in some respects our single best estimate of 
the payout ratio, given that both delays and 
cancellations have the potential to lead to 

compensation liabilities. But we have also placing 
some weight on the midpoint of our range, whereby 
less than 100% weight is given to deemed minutes, 
given the potential for over-estimation of the total 
compensation liability using this method.

It remains the case, however, that a substantial proportion of potential payouts still go unclaimed.

 

## Annex C - Update On Status Of Planned Actions To Improve Rail Fares And Ticketing

Action Theme
Action Number
Owner
Action Description
Action 1
RDG & Train Operating Companies
How you choose your ticket
Less jargon will be used on TVMs, websites and tickets, and include easily available information to explain terminology.
Action 2 
RDG & Train Operating Companies
How you choose your ticket
Train companies will make information available to inform customers when Advance tickets for long distance companies are running low to ensure that customers don't miss out on the best price if there are only a few left.
Action 3 
RDG & Train Operating Companies
How you choose your ticket
When purchasing a ticket, customers will be told if they could get a cheaper ticket by changing the time of travel.
What you buy
Action 4
RDG & Train Operating Companies
Online customers will get a plain English explanation of the ticket they have chosen before making final payment.
What you buy
Action 5
RDG, Train Operating Companies and DfT
Customers will be able to purchase cheaper Advance tickets [Advance purchase tickets on the day (APOD)] on the day of travel from longer distance companies (currently only possible for CrossCountry customers).
Status
Original completion date
December 2017
Four types of terminology have been identified and their removal will be complete by December 2017.
April 2017
COMPLETED in April 2017.
May 2017
Online COMPLETED in May 2017 TVM completion by July 2017.
August 2017
Completion by August 2017.
COMPLETED in April 2017 by TransPennine Express, Northern, Virgin Trains West Coast & Virgin Trains East Coast. East Midlands Trains will adopt in September 2017.
April 2017 for TransPennine Express, Northern, Virgin Trains East Coast and Virgin Trains West Coast. September 2017 for East Midlands Trains.
Action Theme
Action Number
Owner
Action Description
What you buy
Action 6 
RDG & DfT
The industry will run a small number of fares pilots to test some key strategic principles that could form the basis of fares reform. 
Where to buy your ticket 
Action 7
RDG
We will provide better and more targeted information to website and app developers to enable them to develop new products and services for consumers. This information includes timetable and fares data and live running information. 
Where to buy your ticket 
Action 8 
RDG & DfT
We will take steps to open up the ticket retail market, enabling third party retailers to play a greater role, and removing barriers to entry for new market entrants. This should lead to increased competition, and better outcomes for consumers. 
How to buy your ticket
Action 9
RDG, Train Operating Companies and DfT
Customers should have access to a clear and understandable choice of tickets when buying from vending machines, including information on relevant cheaper options that could be bought by waiting a short time or travelling on a different service.

 

Status
Original completion date
May 2017
Planning meetings are being held with the 4 train companies involved - CrossCountry, East Midlands Trains, Virgin Trains West Coast and Virgin Trains East Coast.
December 2017
Completion by December 2017.
June 2017
RDG reforming its governance structure: COMPLETED in April 2017. Third Party Retailers to have access to fares data by Summer 2017DfT has initiated liaison with Third Party Retailers to identify market barriers.
July 2017
RDG will produce a description of current TVM capability by July 2017. RDG and train operating companies engaged in delivering on TVM 10 Point Plan.
Action Theme
Action Number
Owner
Action Description
How to buy your ticket
Action 10 
ORR
Train company websites will be reviewed against existing industry code of practice to ensure that they are fully compliant in meeting the required standards for customers 
How to buy your ticket
Action 11
RDG
Train company websites will be monitored by RDG, and best practice will be promoted to all train operating companies
How to buy your ticket
Action 12 
RDG & DfT
Customers will have access to all relevant terms and conditions in a simple to understand format when choosing and buying ticket 
How to buy your ticket
Action 13 
RDG
Where a customer holding a valid railcard forgets it at the time of travel, they will on the first occasion be able to claim back any additional expense, including the cost of any extra fare and any penalty fare issued. 
How to buy your ticket
Action 14 
DfT
We will work with the Disabled Persons Transport Advisory Committee (DPTAC) to assess what we can do to improve the experience for disabled and vulnerable passengers and build awareness of passenger rights, acting on research from Transport Focus, ORR and DfT, including through the franchising process. 
Status
Original completion date
March 2017
Audit COMPLETED in March 2017Publication in Summer 2017.
Quarterly 
Commencing Summer 2017.
June 2017
Completion in June 2017.
February 2017
COMPLETED in February 2017.
December 2017
DfT and DPTAC liaison has begun, due for completion in December 2017. 

## Annex D - Relevant Regulatory Statements And Guidance Passenger Information

■
■Information for passengers: Guidance on meeting 
the licence condition
Published June 2016 Available at: http://www.orr.gov.uk/__data/assets/
pdf_file/0015/4353/information-for-passengersguidance-on-meeting-the-licence-condition.pdf 

■
■The approved code of practice for the provision of 
customer information (ACOP014, version 2)
Published October 2016 

Can be downloaded from the Rail Delivery 
Group's website: http://www.raildeliverygroup.
com/about-us/publications.html?task=file.
download&id=469771025

## Passenger Assistance

■
■Disabled people's protection policies - a 
regulatory statement
Published July 2014 Available at: http://www.orr.gov.uk/__data/assets/
pdf_file/0010/13996/dppp-regulatory-statement. pdf 

■
■Guidance on How to write your Disabled People's 
Protection Policy, a Guide for Train and Station Operators (Department for Transport)
Published November 2009 Available at: http://www.orr.gov.uk/__data/assets/
pdf_file/0015/5604/how-to-write-your-dppp.pdf
 

## Complaints Handling

■
■Guidance on complaints handling procedures for 
licence holders
Published September 2015 Available at: http://www.orr.gov.uk/__data/ assets/pdf_file/0020/19370/complaints-handlingprocedure-guidance-2015.pdf 

■
■Complaints handling procedures - a regulatory 
statement
Published July 2014 Available at: http://www.orr.gov.uk/__data/assets/ pdf_file/0009/13995/chp-regulatory-statement.pdf 

## Other

■
■Reference guide for complaints and CHP/DPPP 
indicators data reporting
Published March 2017 http://www.orr.gov.uk/__data/assets/pdf_ file/0004/3874/Reference-guide-for-complaintsdata-2017-18.pdf

■
■ORR's economic enforcement policy and penalties 
statement for Railway licence holders
December 2015 Available at: http://www.orr.gov.uk/__data/assets/ pdf_file/0018/4716/economic-enforcementstatement.pdf

## Annex E - Core Data Indicators

Train and station operators are required by their operating licences to establish and comply with policies on Complaints Handling (CHP) and Disabled 

Total number of complaints received
CHP Guidance - section 4.1, ORR's monitoring approach.
Percentage of complaints responded to within specified targets
CHP Guidance - section on response times, para 3.31 and 3.32. 
Total number of complaints received by complaint category
CHP Guidance - section 4.1, ORR's monitoring approach.
Complaints about complaint handling process
CHP Guidance - section on quality assurance, para 3.62.
Customer satisfaction with the complaints handling process
CHP Guidance - section on quality assurance, para 3.62.
Satisfaction with complaint outcome
CHP Guidance - section on quality assurance, para 3.62.
Frivolous and vexatious complaint volumes
CHP Guidance section on dealing with frivolous and vexatious complaints, paras 3.43 - 3.45.
Continuous improvement in complaint handling
CHP Guidance - 1.7 and 1.8 regarding continuous improvement. Requires evidence of a good complaints handling procedure that leads to continuous improvement, so that in the medium term the root causes of complaints are addressed and systemic solutions are put in place. 
Complaint appeals
CHP Guidance - 3.41,'passenger should be signposted to TF or LTW and ADR after they have received the second substantive response from the licence holder.'
Disabled Person Railcard journey data
Ensures train operators are fulfilling their obligations to DPRC card holders as per DPPP Guidance section C). 

People's Protection (DPPP). These must be approved by ORR. Licensees provide data to us to demonstrate their compliance in these areas. This data is outlined below. 

Data is collected on a periodic basis and published on the ORR Data Portal. 
Data is collected on a periodic basis and published on the ORR Data Portal.
Data is collected on a periodic basis and published on the ORR Data Portal.
Data is collected on a periodic basis and published on the ORR Data Portal.
This data is collected via a passenger survey commissioned by ORR. The first data is included in this report. 
This data is collected via the same survey noted above. 
We collected this data for the reporting year 2015-16 but dropped it for 2016-17 because of the small number of cases train operators were reporting. 
This data is collected on a one-off annual basis by us and reported in this report. 
This data started being collected by licensees from 1st April 2016. In future it will be published on the ORR Data Portal. 
We retrieve this data from the LENNON database and publish it on the Data Portal. 
Total number of complaints received
CHP Guidance - section 4.1, ORR's monitoring approach.
DPPP Guidance - D6 on staff training. 
Staff who have received relevant disability awareness training or disability equality training
Assisted journeys
DPPP Guidance - C2 'assistance for passengers' 
CHP Guidance - section 4.1, ORR's monitoring approach.
Number of complaints where there was a service problem relating to a passenger's disability
Passenger Assist satisfaction data
DPPP Guidance - D3 'monitoring and evaluation of performance in delivering services and facilities to disabled passengers'.
Alternative accessible transport
DPPP Guidance - C3 requirements around the provision of Alternative Accessible Transport. 

 

Data is collected on a periodic basis and published on the ORR Data Portal. 
This data is collected on a one-off annual basis by us and reported in this report.
We receive data on the number of requests (bookings) made for assisted travel received by each train operator via the Rail Delivery Group. We publish this information on our Data Portal. We are continue to engage with industry to receive further data (such as the volume of volume of turn-up-and-go assistance provided by each train operator) and have recently reached agreement - this is set out in detail in section 4.3 of the main report.  
Data is collected on a periodic basis and published on the ORR Data Portal.
Data is being gathered by us via research with real users of the Passenger Assist system and will be published in autumn 2017. 
This data is collected on a one-off annual basis by us and reported in this report.

## Annex F - Orr Consumer Team Publications 2016-17

■
■Audit of train company websites against the retail 
information code of practice
Published 29 June 2017

Available at: http://www.orr.gov.uk/rail/
publications/reports/audit-of-train-company-
websites-against-the-retail-information-code-of-
practice 

■
■Research into passengers' experience of ticket 
vending machines - Report of findings
Published 10 February 2017 Available at: http://www.orr.gov.uk/rail/
publications/reports/ticket-machines 

■
■Rail compensation - update report (an update on 
our response to the rail passenger super-complaint on delay compensation arrangements)
Published 20 December 2016 Available at: http://www.orr.gov.uk/rail/
publications/reports/rail-compensation-supercomplaint 

■
■Retail market review conclusions document
Published October 2016 Available at: http://www.orr.gov.uk/rail/ consultations/closed-consultations/consumerconsultations/retail-market-review

■
■Consultation on the scope of regulation for 
some categories of licence holder for Complaints Handling Procedures and Disabled People's Protection Policies
Published October 2016 Available at: http://www.orr.gov.uk/__data/assets/ pdf_file/0015/23055/consultation-on-licenceoutliers-october-2016.pdf

■
■Information for passengers: Guidance on meeting 
the licence condition
Published June 2016

Available at: http://www.orr.gov.uk/__data/
assets/ pdf_file/0015/4353/information-for-
passengersguidance-on-meeting-the-licence-
condition.pdf

## Annex G - Orr'S Highways Role

ORR independently monitors Highways England's management of the strategic road network - the motorways and main A-roads in England - holding Highways England to account for its performance and efficiency targets. Our focus is on securing better performance and value for money from the strategic road network, to benefit road users and the wider public. We aim to ensure that Highways England is delivering a road network which meets the needs of road users. The Road Investment Strategy specifies the eight outcomes that Highways England must deliver during the road period up to 2020. It sets 11 key performance indicators, against which we measure Highways England's performance. This includes a target to achieve, and maintain, user satisfaction of at least 90% by March 2017, as measured by the National Road User Satisfaction Survey. Our work on monitoring the road user satisfaction measure has focussed on interventions Highways England has put in place to achieve and maintain its target and how it plans to improve areas that the survey shows as having the lowest level of satisfaction. We are also responsible for providing advice to government on the development of the second Road Investment Strategy (RIS2). We are pressing the need for RIS2 to be based on strong evidence and stakeholder engagement, to develop a robust and resilient set of proposals. Therefore, In March 2017, ORR and Transport Focus jointly published "Measuring Performance of England's Strategic Roads: what users want". This research focuses on what road users want from England's motorways and major A-roads, and how they would like to see that measured and reported to help deliver better outcomes. Highways England is using these findings to influence and inform the development of its proposed metrics. For more information on our highways role, our annual assessment of Highways England's performance for 2016-17 is due to be published in July 2017. 

 

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