It’s Not About the Doors introduction:
Below we reprint an email distributed to union reps (with our amendments for comprehension). It argues that the real reason for GTR/Southern Rail’s axing of the guard is not to improve customer service but to meet franchise commitments for revenue protection. It’s a win-win for GTR/Southern: save on staffing costs while meeting targets and achieving bonuses. However, unsurprisingly, there appear to be no bonuses at stake for improving accessibility for disabled and vulnerable passengers. They will be a major loser as ‘turn up and go’ access is sacrificed for increased profits. Any further extension to DOO should be halted until its effect on disabled and vulnerable passsengers has been properly assessed.
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Concerns are being raised regarding the effect Govia Thameslink Railway’s (GTR) “modernisation” plans will have on the rights of disabled passengers to turn up and access rail services without pre-booking.

Those sharing these concerns will note with interest the following point from the Transport Select Committee (TSC) report released on Friday 14 October 2016:


We are concerned that no official impact assessment has been made of the potential effects of DOO [Driver Operated Only] on disabled people’s access to the railway. We recommend the DfT [Department for Transport] and the Association of Train Operating Companies (ATOC) jointly commission research into the potential effects of DOO on the “turn up and go” accessibility of the railway to disabled people who require assistance getting on and off trains. The Department should draw on this research to issue guidance to train operating companies on the measures that should be taken to mitigate potential detrimental effects on disabled people’s access. It should ensure that actions are taken to guarantee that disabled rail passengers receive the support to which they are entitled. The research should be conducted, and guidance published, before summer 2017.

GTR’s intention to introduce DOO over the Southern network will remove the right afforded to the disabled under the 2010 Equality Act to be able to access train services without pre-booking like everyone else. The requirement to provide the right of access to disabled customers is met at present within the Non-DOO area by the necessity to have the guarantee of the second Safety Critical member of staff on every service before it can run. Once DOO is introduced the requirement to pre-book assistance by giving 24 hours notice or face delay to their journey will apply to all those who require assistance to board train services. 
Listed below are the majority of the stations where disabled access will be negatively affected by this DOO extension:
 

Aldrington, Fishersgate, Southwick, Shoreham by Sea, Lancing, East Worthing, West Worthing, Durrington, Goring, Angmering, Ford, Chichester, Fishbourne, Bosham, Nutbourne, Southbourne, Emsworth, Warblington, Havant, Bedhampton, Hilsea, Fratton, Cosham, Portchester, Farnham, Eastleigh, Southampton Parkway, Swanwick, Burlesdon, Hamble, Netley, Sholing, Woolston, St Denys, Arundel, Amberly, Pulborough, Billingshurst, Christs Hospital, Littlehaven, Faygate, Ifield, Crawley, London Road, Moulscoomb, Falmer, Southease, Newhaven Town, Newhaven Harbour, Bishopstone, Seaford, Glynde, Berwick, Polegate, Hampden Park, Pevensey&Westham, Pevensey Bay, Normans Bay, Cooden Beach, Collington, Bexhill, St Leonard’s Warrior Square, Ore, Warnham, Ockley, Holmwood, Dorking, Uckfield, Buxted, Crowborough, Ashhurst, Cowden, Hever, Edenbridge Town, Hurst Green, Oxted, Woldingham, Upper Woldingham, Riddlestone, Sanderstead.

The TSC report also makes reference to the On Board Supervisor (OBS) role GTR are creating, by combining the Revenue Protection and Conductor grades,  and their claim that it will be a Customer Service role not a Revenue Protection role and indicating that this will give a greater level of service to all customers but particularly those who require disabled assistance.

Below is a Notice from the DfT published in May 2015 which shows clearly that this cannot be the case: 

Notice Summary

Title: Ticketless Travel Survey
Notice type: Prior Information Notice
Authority: DfT
Nature of contract: Services
Procedure: Not applicable
Short Description: The Thameslink Southern Great Northern (TSGN) franchise is operated by Govia Thameslink Railway Limited and will operate from 14th September 2014 to 19th September 2021. Within this franchise, passenger revenue risk has been assumed by the DfT and all ticketing and fares revenue is paid to it. Because the franchisee does not take revenue risk, the Secretary of State (SoS) has a requirement to ensure that the franchisee is operating in the same way it would if it was taking revenue risk. To ensure that passenger revenue is being maximised, the Franchise Agreement contains a requirement on the part of the SoS to undertake Ticketless Travel Surveys across the franchise. The Surveys are expected to be carried out quarterly with the first Survey to be completed before the 14th September 2015 and subsequent surveys starting in the quarter October – December 2015. The level of ticketless travel across the lifetime of the franchise will be a key measure of operator performance. There are a number of committed obligations in support of a reduction in ticketless and fraudulent travel including making it easier to purchase a ticket, e.g. increased number of ticket vending machines, mobile ticketing and a higher compliment of revenue protection inspectors (RPI). Benchmarks have been agreed between the franchisee and the SoS in support of a reduction in ticketless travel. To encourage the franchisee to meet and improve upon these benchmarks, financial incentives have been put in place. Should the franchisee not meet the benchmark target, it will be required to pay the SoS compensation for such failure. A methodology has been agreed by both parties which the surveys, provided under this contract, must follow. Each survey should identify rates for ticketless travel and revenue at risk. The Term of this contract is three years with the option to extend for a further 12 months. This Procurement is being run by Crown Commercial Service on behalf of DfT and we are aiming to launch the OJEU by the end of May 2015.
Published: 07/05/2015 10:49


This report states clearly that to avoid financial penalties and to be in a position to accrue financial bonuses GTR must operate with an increased Revenue Protection team. This exposes as ‘inaccurate’ GTR’s assertion that the OBS role would be Customer Service focused.
What they have done is remove the second Safety Critical member of staff from the train at the expense of Safety, Accessibility and Security to meet their obligations under the franchise to have a larger Revenue Protection team (OBS), without employing more staff. 

 
The DfT must ensure that the analysis recommended by the Transport Select Committee with regard to the effects of DOO on disabled access is commissioned without delay.
 
GTR’s “modernisation plans” have the extension of DOO at their core and therefore the DFT should ensure that they are not implemented until such time as the analysis recommended by the Select committee is completed .

It cannot be acceptable in a civilised society for plans to be implemented, under the guise of improving Customer Service, that restrict the ability of disabled customers to access rail services.

It is the responsibility of all the Stakeholders including the Department for Transport, Transport Select Committee, Politicians, Trade Unions, Rail Customers and Employees to ensure that this is not allowed to happen on Southern Rail.

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