Great Western Railway’s proposed changes to ticket offices: Transport Focus response

Great Western Railway’s proposed changes to ticket

offices: Transport Focus response

Proposed changes to Schedule 17 of the Ticketing and Settlement Agreement

1. Introduction

This is Transport Focus’s formal response to your proposal to change ticket office

opening hours at regulated stations. It outlines responses received during the public

consultation which began on 5 July 2023 and then sets out Transport Focus’s

conclusions.

Transport Focus recognises that the way many passengers buy their ticket has

changed, with increasing numbers choosing to buy online, use apps or Pay As You

Go contactless payment. We accept that this has changed the nature of retailing at

stations – with stations now only accounting for around 12 per cent of sales on

average.

We acknowledge that the proposal was designed to respond to this shift in customer

behaviour, with the aim of bringing staff out from ticket offices to better meet

customer needs. It is important to stress that Transport Focus is not against the

principle of ‘bringing staff out from behind the glass’. Our conclusions below are

based solely on the specific proposals received for each station and the potential

impact on passengers.

2. Executive summary

GWR published details of its original proposal on 5 July. The public consultation on

this ran until 1 September. Transport Focus received 57,825 representations

objecting to GWR’s proposal and 100 representations supporting GWR’s proposal.

Transport Focus used information provided by GWR and the issues raised by

passengers to analyse proposals. We based our assessment on the impact of the

proposals on quality of service for passengers, however we acknowledge that cost

effectiveness is also part of the criteria. Our focus has been on ensuring that

passengers retain access to core products and services at stations rather than the

cost of delivery, but we recognise that there could be efficiency savings within

proposals.

On 6 September we raised concerns with the proposals and asked a number of

clarification questions based on our initial analysis and from the main themes seen in

the public responses at that point. Your response proposed some enhancements to

the original proposal.

Transport Focus acknowledges that GWR has made significant improvements to its

original proposal. Your specific station proposals meet many of the criteria set by

Transport Focus around staffing and access to products and services. However, we

still have a number of industry-wide generic issues which give continued cause for

concern. These are specific to all operators and, while we are willing to continue

engaging with the industry on these, they have not yet been resolved. As a result, we

must object to proposals at all stations. A full list of stations is provided at the end of

this letter.

The main reasons for this are:

• Welcome Points

In response to concerns GWR proposed that ‘Welcome Points’ will be

developed at stations as an initial focal point that provides any customer who

needs support and/or advice a place to start their journey. We think there is

merit in this idea but there is much that still needs to be developed.

Welcome Points were not explained as part of the original consultation, so

passengers have not had the opportunity to comment on these plans or to

highlight potential concerns. We believe it is important that there is further

engagement with the Disabled Persons Transport Advisory Committee

(DPTAC) and with disabled people and representative groups on the concept,

design and implementation of Welcome Points. We also believe they should

be piloted/trialled to establish what works best at different types of stations

and to gather passenger feedback.

• Queuing standards at Ticket Vending Machines

We believe that there is a need for a nationally agreed, and enforceable,

queuing time metric for Ticket Vending Machines (TVMs). This could be

based on the existing standards at ticket office windows (three minutes in the

off-peak and five minutes in the peak). This would create a formal review

mechanism – if queues exceed the targets then action would need to be

taken.

There are a number of assumptions when it comes to future retailing – around

for example, the number of people who will migrate to digital channels, how

many will move to TVMs, that TVMs can absorb future demand. A robust

queuing time regime (with enforcement) will help provide reassurance and

safeguards should industry forecasts not be correct.

• Retail capacity

In addition to these generic issues we have concerns over the ability of the

following stations to cope with sales demand at high-peak periods:

Barnstaple, Bridgewater, Bristol Parkway, Didcot parkway, Maidenhead,

Reading, Swindon and Twyford.

3. The process

The procedure for making a major change to ticket office opening hours is set out in

clause 6-18 of the Ticketing and Settlement Agreement (TSA). This requires a train

company to post details of the change at affected stations and to invite people to

send representations to Transport Focus (or to London TravelWatch if the station is

based in its operating area). Transport Focus analyses these responses and uses

them to help inform its decision on whether to object to the proposals for stations in

its operating area.

The public consultation began on 5 July and was originally scheduled to end on 26

July, 21 days being the consultation period specified in the TSA. 13 train companies

announced their plans simultaneously, of which 12 had stations in Transport Focus’s

operating area, the exception being Southeastern.

The consultation process was challenged, especially over whether people (and

especially disabled people) had adequate information on which to comment. We

note that train companies subsequently made proposals available in alternative

formats and published Equality Impact Assessments. We had written to each train

company requesting they make this information available. The consultation period

was also extended by the train companies to 1 September, giving people longer to

respond. Under the terms of the process set out in the TSA a nil response on the

part of Transport Focus is deemed to be acceptance of the proposals. Therefore we

continued with our role in the process as written

Transport Focus was originally due to respond on 30 August but, when the

consultation period was extended, this moved to 6 October. Due to the

unprecedented volume of responses to the consultation this date was subsequently

extended again, until 31 October, to allow enough time to process and analyse

responses.

4. Responses to the consultation

During the consultation period we received 585,178 responses by email, webform,

freepost and phone. Some were specific to individual stations, some were specific to

train companies as a whole and some were at a network-wide, in other words,

objecting to the proposals by all train companies. In addition, we also received a total

of 257 petitions.

There were two specific campaigns launched which generated a large number of

responses; one by the RMT union which involved emails and ‘postcards’, and

another via the workers’ rights network, Organise, which was via email. While the

majority of these responses followed a standard template some had been

customised. All have been counted and any that have been customised or contain

reference to a specific station identified.

We received 57,825 objections to GWR’s proposals.

The top three themes in responses were concerns over the ability to buy tickets in

future (including difficulties in using TVMs), the provision of information needed to

plan journeys (including during periods of disruption) and how passengers requiring

assistance would receive help and support. The common theme running throughout

responses was the role, and value, of staff in delivering all of these.

In addition, we received 93,185 network-wide objections opposing changes across

all stations.

We also received many responses from stakeholders including MPs, local authorities

and representative organisations.

More detail can be found in Annex 1.

We also received 100 representations supporting GWR’s proposal to close ticket

offices out of a total of 721 nationally.

It is important to note that these are the number of responses to the consultation and

not the number of people who responded. Under the TSA the train companies were,

in effect, seeking views on each station in their area – it was not a national

consultation. Some people sent objections for individual stations, others sent a reply

to each train company objecting to all stations in their area.

5. Criteria for assessment

Under clause 6-18 (1) of the TSA changes to opening hours may be made under the

Major Change procedure if:

(a) the change would represent an improvement on current arrangements in terms of

quality of service and/or cost effectiveness, and

(b) members of the public would continue to enjoy widespread and easy access to

the purchase of, notwithstanding the change.

Transport Focus may object to a proposal on the grounds that the change does not

meet one or both of the criteria above. If we object, the train company can either

withdraw their proposal or refer it to the Secretary of State for a decision. The

Department for Transport has previously published guidance setting out the

approach the Secretary of State (SofS) would take in these circumstances. This

guidance states that the SofS is “content for Transport Focus and the Operator to

continue discussing the proposal, including amending it, if that would enable an

agreement to be reached. If the matter is referred to the SofS, the SofS will decide

whether the objections are valid or not; i.e. the proposed change fails to meet the

criteria, or meets the criteria. Alternatively, the procedure permits an arbitrator to be

appointed to determine if the criteria are met.”

At the same time the consultation was launched, to provide transparency on our role

in the process, Transport Focus published its own criteria (which contain many of the

same themes set out in the Secretary of State’s guidance document). They covered:

• Passengers can easily buy the right ticket for the journey they want to make.

This included the product range available at the station, what support is

available to advise/help with a purchase and access for people who need to

use cash or do not have a smartphone.

• Passengers requiring assistance to travel receive that assistance in a timely

and reliable manner.

This included arrangements for providing booked assistance (using the

Passenger Assist process), assistance provided on a ‘turn-up-and-go’ basis,

the support available when buying a ticket and the ease of requesting

assistance.

• Passengers can get the information they require to plan and make a journey,

including during periods of disruption.

This included the information channels available at the station and the support

available to help passengers who need assistance.

• Passengers feel safe at a station.

This included perceptions of personal security and how train companies will

provide reassurance for passengers wanting to travel.

• Passengers are not penalised if they cannot buy the ticket they require from

the station.

This included arrangements for issuing Penalty Fares or prosecutions for fare

evasion.

• Passengers can continue to use facilities at a station.

This included access to facilities such as waiting rooms, toilets, lifts and car

parking.

Transport Focus made clear it would focus its assessment on the impact of the

proposals on quality of service for passengers, however we acknowledge that cost

effectiveness is also part of the formal criteria. Transport Focus has not received

details on cost effectiveness or cost savings from train companies. Our focus has

been on ensuring that passengers retain access to core products and services at

stations rather than the cost of delivery, but we recognise that there could be

efficiency savings within proposals.

Our published criteria also highlighted that the presence of staff at a station plays a

key role in the railway meeting passengers’ expectations in many of these areas, so

station staffing would be a key consideration in our assessment.

6. Our assessment

Transport Focus used information provided by train companies and the issues raised

by passengers to analyse proposals against the criteria set out above. On 6

September we wrote to each train company raising concerns with the proposals and

asking a number of clarification questions based on our initial analysis and from the

main themes seen in the public responses at that point. GWR replied on 27

September. These letters are attached as Annex 2 and 3.

GWR’s original proposal was to:

• Alter how tickets are sold at 79 stations and, in addition, change Ticket Office

opening hours at 15 of those.

• At the end of an expected transition period of around 12 months, ticket office

windows at 69 stations would close, with staff moving to other areas in the

station, where they are better placed to help customers.

• During a proposed 18-month period of implementation, some ticket office

opening hours at the remaining 10 larger locations would initially be reduced,

along with the number of open sales positions. At the end of this period,

remaining ticket office windows would also close. These 10 stations –

principally major stations, interchanges between networks and locations

where there are significant numbers of customers needing extra assistance to

buy – would initially retain a ticket office with qualified staff able to retail tickets

and help customers with other non-ticketing issues.

• The proposed changes would not result in locations left unstaffed. However,

the proposal would see the creation of muti-skilled roles and some existing

ticket office staff would be retrained to provide additional support to customers

away from the ticket office including providing help with ticket purchasing.

They would not have access to retailing equipment. Instead, passengers

would either buy tickets through TVMs, the GWR app, online or on board

trains.

Following further discussion with Transport Focus your letter of 27 September made

some significant changes to your proposals:

• All stations would now see no change in the staffing hours – with retail staffing

hours reverting to current times. Therefore, retail-trained staff would be

available to assist customers with ticket purchasing for the same hours as

today. This would be subject to DfT support for the additional funding.

• In response to passenger concerns that the proposal would make it hard to

know where to find help and support the proposal now includes the creation of

designated Welcome Points. This would be an initial focal point that provides

any customer who needs support and/or advice a place to start their journey.

The intention is that Welcome Points will be clearly accessibly and visible

from the station entrance and close to TVMs where possible. Each station will

be individually assessed, and an appropriate location agreed, forming part of

updated equality impact assessments for each station.

• These Welcome Points would have a Help at Hand facility. This would be

similar to a ‘call button’ which connects passengers to retail trained staff

should there be no one in the vicinity of the welcome desk. This will allow

customers needing help with retailing to speak directly to the person waiting,

so that staff can give reassurance and advice even while returning to help.

• In response to concern about the loss of access to some core products at the

station and retail capacity, staff will now initially retain access to ticket office

equipment until the introduction of handheld tablets with a ticket retailing

function. These will be used for retailing tickets not available digitally/on TVMs

and for queue busting.

• As a result of these changes you state that, “…we can now provide the same

level of retail service to customers who will not/cannot move to digital. We are

maintaining the current level of retail staffing capability and products will

continue to be available for purchase at the station.”

• TVMs will be upgraded to enable them to retail a wider range of tickets. Some

will have cash facilities enabled and some will be able to sell car parking

tickets where the ticket office currently does this.

• The process towards the closure of all ticket windows will be phased. The

proposal is that ticket office transactions are reviewed on a quarterly basis

through the period from the start of the programme, which is expected to be

March 2024, following discussion with the Department for Transport and trade

union negotiations, through to the expected end state in March 2025

o Stations with one ticket window will remain open until phase two

(potentially June 2024) when Welcome Points and Help at Hand

facilities, along with handheld retail devices are in place.

o For stations with more than ticket window, retail capacity reports will be

reviewed every three months to identify where further phased

reductions maybe possible.

We acknowledge that you have made significant changes to your original proposal in

response to passenger feedback from the consultation, especially in reverting to

current staffing hours in most cases. We know from our research that passengers

value staff at stations highly for safety and security, information, and advice and help

purchasing tickets.

Comments received during the consultation overwhelmingly reinforced this point with

concern about availability of staff at the station the most important theme in the

responses:

“I won't be able to get help when needed. Staff can provide Guidance on

routes, advice and support. This will all stop if the are no staff”. Oxford

passenger

“I and many other people I know rely on the friendly face and knowledgeable

advice given out by the people at the ticket office. Please don’t put profit above

people’s well-being - a human face when navigating rail journeys and finding

the best route is really important”. Stroud passenger

We will now address each of our criteria points in detail against your revised

proposal.

6a) Passengers can easily buy the right ticket for the journey they

want to make

In our letter of 6 September we set out a number of issues arising from passenger

submissions to the consultation and our own analysis. It was clear from the

consultation that this was a key area of concern for passengers.

Complexity of fares and ticketing

We acknowledge that there is a clear trend towards digital sales and away from

sales at the station, and that this is likely to continue. However, a substantial number

of people either cannot or have chosen not to move to digital to date.

Some, such as those who are unbanked and/or have no access to digital channels,

have little choice but to buy from the station. Others are reluctant to move online –

our research shows that this resistance often comes from uncertainty and a lack of

confidence, exacerbated by the complexity and variety of ticket options available.

This is not only a matter of personal preference, it is often for hard, practical reasons

about routing or time restrictions and concern about the consequences of buying the

wrong ticket, including potentially paying more than they needed to. Staff support

often offers confidence that the most appropriate ticket for the journey has been

purchased.

Comments received during the consultation illustrate this point:

“Please don't close offices. Here in St Austell trying to buy a sleeper ticket on

line or from a booth turned me in to a gibbering wreck. The person on the

counter did it with ease. I am older now and need a little help from time to time”.

St Austell passenger.

“The current ticketing system is complex and confusing. Many people either

can’t or don’t want to navigate their way round it, eg deciding whether to split

their tickets (eg at times, it’s cheaper to buy one ticket to Oxford, another from

Oxford to London), or which type of ticket would be cheapest for them”.

Charlbury passenger.

“My main problem with the proposals concerns reform of the ticketing system.

We have long been promised a simplification and rationalisation of the ticketing

system. If that had taken place then I think the use of online booking or a ticket

machine would be okay. However, with our current complex system, the

expertise of staff at ticket offices can be indispensable”. Exeter passenger.

“This will make it particularly difficult for me to renew my season ticket, and

almost certainly end up costing more for journeys that I don't regularly take, as

it is almost impossible for an amateur to find the best tickets without the aid of

trained staff”. Twyford passenger

“As a computer literate, savvy person, my experiences with online ticketing and

using the machine are beyond frustrating…Using the GWR site to find the

optimal ticket for journeys from either Theale, Pangbourne or Cholsey is a

nightmare. I’m literally trying to look online for a ticket for tomorrow and have

given up. I’m scared to book a ticket online as it will most likely not be right.”

Cholsey passenger.

Useability of Ticket Vending Machines

GWR’s proposals place a much greater reliance on sales from Ticket Vending

Machines (TVMs) than at present.

TVMs clearly have an important role to play in retailing tickets, and we know from our

research that many regular users find them quick and easy to use once you know

how. However, it is equally clear from our research and the comments received that

some passengers still have concerns about using them. TVMs are not physically

accessible to all passengers and some people with cognitive disabilities can have

difficulties in using them. Others do not find them user-friendly, requiring a degree of

prior knowledge of the fares structure which some passengers do not possess. In

addition, not all TVMs can offer the same range of products and services as ticket

offices.

Even where staff will still be present at the station it will be important that they have

sufficient expertise to help passengers navigate the complex fares system. In

contrast to many other self-service retail situations, for example a self-checkout at a

supermarket, many passengers will need support not just to use the ticket vending

machine, but also to understand what they should purchase and provide confidence

they are getting the best deal.

An increased reliance on TVMs makes it even more important that they are

monitored and maintained. This applies to operational resilience and to customer

service quality. There are standards for queuing times at ticket offices (three minutes

in the off-peak and five minutes in the peak). It is a requirement that these are

monitored and reported on. There are no such targets for TVMs.

The useability of TVMs came through strongly in the consultation responses as did

frustration at the frequency with which they are found to be out of order and their

poor location. GWR may believe that its service level agreement for fault repair is

among the best, if not the best in the industry, however, it was striking how many

respondees referenced machines being repeatedly out of order for whatever reason.

“The ticket machine does not always work, particularly in hot or cold weather &

frequently we cannot locate the guard on the train so have to queue at Reading

to buy a ticket for onward travel.” Mortimer passenger

“The station does have a single self-service ticket machine, but that is

frequently out of action, is badly sited - the morning sun makes it challenging to

read, and it is very wet when it rains, AND not all ticketing options are available,

e.g. "PlusBus" or booking a bike on a train.” Charlbury passenger

“I recently wanted to travel from Bodmin Parkway to Plymouth, then to

Penzance & back to Bodmin. Knowing that a normal return ticket probably

wouldn't be valid I visited the ticket office and was recommended a Cornwall

Ranger ticket. I have since discovered that these are not available from ticket

machines, so without the ticket office staff I would have either bought an invalid

ticket for my journey or spent a lot more than was necessary”. Bodmin Parkway

passenger

Retail capacity

Closing ticket windows also raises questions of retail capacity at the station – can

TVMs cope with an increased level of sales? If not, then there is a risk of passengers

being faced with unacceptable queues to purchase tickets, of missing trains, or in

boarding without a valid ticket.

Comments received during the consultation included:

“Although I book via app. I do often use the ticket office at Swindon. I’ve never

been there when it hasn’t been busy and I’ve had to queue”. Swindon

Passenger

“We all had experiences before when on Sundays when office is closed and the

machine queue is more than 10mins worth of wait, we had to make a choice of

missing trains or board in the hopes that there is staff member on board for us

to purchase tickets.” Dawlish passenger

Cash

Not everyone has a bank account or access to debit/credit cards – some people are

reliant on cash to buy tickets. The guidance issued by the Secretary of State

specifically mentions the need to take into account accessibility for customers who

need to use cash or do not have a smartphone or access to the internet.

Under the existing National Rail Conditions of Travel if you bought your ticket using

cash (for example, from a TVM) you are entitled to a refund in cash if your train is

cancelled or delayed and you decide not to travel. It is important that this could still

be provided in future. Passengers without a bank account also need to be able to

receive compensation if their train is delayed. Currently ticket offices offer both these

services.

Comments received during the consultation included:

“I use it [ticket office] regularly and don't like using machines - I only use cash”.

Plymouth passenger

“There are many many people in Teignmouth who don’t/can’t use a smartphone

and who prefer to buy with cash after consulting a person about best/cheapest

tickets”. Teignmouth passenger

Product range

Currently ticket offices provide access to a full list of products and services. TVMs do

not sell/serve all of these. For example, GWR’s TVMs do not sell products such as

Railcards, Advance Purchase fares, Ranger/Rovers and National concessions for

disabled people (for wheelchair and visually impaired passengers plus a

companion). Nor do they provide seat reservations, allow you to change

tickets/bookings or provide a means of obtaining a cash refund. At present these are

available at the ticket window.

This came through in the public consultation:

"I will be impacted, I won't be able to buy the ticket I require as its only available

from a booking office”. Newton Abbott passenger.

“My elderly mother uses Teignmouth station ticket office regularly. She has to

use the ticket office as she is a Priv ticket holder and this option is unavailable

on the ticket machines. I am concerned she will now be unable to travel by train

as there is no other way for her to buy her ticket and her seat reservations”.

Teignmouth passenger.

Major stations

Responses from passengers on the proposals for major stations have highlighted a

particular concern about how passengers will still get expert support and advice at

particularly busy stations and where passengers perceive that ticket offices are still

very well used.

“I'm shocked and disappointed you could consider closing ticket counters at

large stations on your network. The explanation "some manned ticket offices

only sell one ticket a day" gives legitimacy to their closure but is nonsense to

use that as an argument for larger stations”. Bristol Temple Meads passenger

“There are 15 platforms at Reading Station as well as very large sprawling

concourses which could result in station staff being a long way away and

hidden from passengers.” Reading stakeholder

GWR’s proposals (as revised) stated:

- In your response dated 27 September you state “Following the consultation

and having listened to feedback from our customers and communities, we

have reviewed this element of our original proposal and our updated proposal

will now see all stations retain retail trained staff for the full period of current

ticket retailing operating hours”. As such staff will be available to assist

customers with ticket purchasing for the same hours as today.

- The primary focus of multi skilled retail trained staff will be supporting

passengers with their ticket purchases.

- Furthermore, retail experts will have same level of training as they do today.

Existing trained retail staff will be redeployed from ticket offices into the multi

skilled role. When training new staff for the multi-skilled role, the competence

level for ticket retailing will be at the same level and require the same training

as it does today. Staff will also be trained to undertake active queue

management at TVMs when queues are longer than a few minutes.

- Retail trained staff will initially retain access to the original ticket office sales

equipment. Following training and procurement, access to ticket office

equipment will be replaced with hand held tablets with a ticket retailing

function, which can be used to retail tickets not available digitally/on the TVM

and for queue busting.

- There will be a phased approach to the closure of ticket windows at larger

stations and stations with higher levels of ticket office sales, to ensure the

combination of TVMs and queue busting hand held devices will work. This will

be based on a quarterly review of ‘retail capacity reports’.

- Passengers will be able to buy all products at the station using cash or card.

- TVMs:

o It is your intention to conduct a review of your TVM fleet to make best

use of the machines in GWR’s possession. You are also committed to

increasing the number of TVMs overall (including the addition of a TVM

at Yeovil Pen Mill) and will also move machines around the network

o You are planning improvements to TVM functionality (covering

Advance Purchase fares, season tickets and seat reservations) – but

this is not planned to be completed until mid-late 2024 with completion

expected by March 2025. It will require engagement with suppliers,

RDG and industry partners and is dependent on funding.

- There are also industry wide proposals to:

o Remove the requirement for a Photocard when purchasing a Season

Ticket. Operators will accept any reasonable alternative form of ID,

such as a driving licence, passport, railcard, student ID, alternative

entitlement card (senior citizens pass) or national ID card. For

customers who do not have access to a suitable alternative form of ID,

a Photocard will still be available from remaining Ticket Offices and via

post from a contact centre or third party retailer.

o Offer people eligible for the national concessions for disabled people a

Disabled Persons Railcard instead.

We acknowledge the reinstatement of staff hours back to the original ticket office

hours and that this will ensure that there is a member of staff present for the same

times as now at all stations. We also acknowledge that they will be trained to the

same level as now and will be able to help passengers buy tickets from TVMs and

via hand held retail devices.

We also acknowledge that GWR’s proposals will still allow passengers at the station

to buy/access all tickets and services currently available at ticket offices. This

includes people who need to pay by cash. This will initially be delivered by retaining

the existing ticket office sales equipment. Following training and procurement you

will replace access to the ticket office equipment with hand held tablets with a ticket

retailing function, which trained retail staff will again use for retailing tickets not

available digitally/on the TVM and for queue busting when necessary.

However, we still have issues with the following:

• Retail capacity

We have assessed the ticket office sales data you provided (on a confidential

basis) and it is clear that some ticket offices are still recording high levels of sales.

You have provided assurances that the combination of TVM capacity and the

retained ticket office equipment will be sufficient to cope with demand. It can be

easy to use TVMs for a simple purchase but not for a more complicated journey,

especially where there are restrictions on which operator or route you can take.

We believe that those transactions could easily take much longer, especially when

the people ‘displaced’ from ticket windows will also potentially be those less

familiar with TVMs and how to use them.

We acknowledge that at stations with one operational ticket window the overall

capacity will be largely the same, as the original ticket office equipment will be

retained initially and later replaced by a handheld device. However, at stations

that currently have two or more ticket windows some will see a reduction in overall

retail capacity.

Having looked at the sales figures provided, and future retail provision, we have

doubts over the ability of the following stations to cope with demand at high-peak

periods: Barnstaple, Bridgewater (where one operational window and a TVM is

not currently enough to cover current demand in the peak), Bristol Parkway,

Didcot Parkway, Maidenhead, Reading, Swindon and Twyford.

We acknowledge your acceptance that the phased closure of windows at stations

with multiple ticket windows should be based on evidence. However, we do not

agree that the suggested ‘retail capacity reports’ are a suitable basis for such

decisions.

We believe that there is a need for a nationally agreed, and enforceable, queuing

time metric for TVMs. This could be based the existing standards at ticket office

windows (three minutes in the off-peak and five minutes in the peak). This would

create a formal review mechanism – if queues exceed the targets then action

would need to be taken (such as issuing staff with hand-held ticket devices so that

they can ‘queue bust’ and/or installing extra TVMs). There is also a strong

argument for putting these results into the public domain, for example in Customer

Reports.

There are a number of assumptions when it comes to future retailing – for

example, how many people will migrate to digital channels, how many will move to

TVMs, can TVMs absorb future demand? A robust queuing time regime (with

enforcement) will help provide reassurance and safeguards should industry

forecasts not be correct.

A commitment to such a queuing time metric would also give assurance at those

stations above where there are larger volumes of sales to absorb onto TVMs. It

would ensure there is a formal mechanism to review sales volumes and, if

projections were wrong, to increase retail capacity.

We also note that full and equivalent sales data has not been provided for

Kemble. We recognise the difficulty of providing accurate sales data however,

without sufficient data we are not able to properly carry out our duty and are

obliged to object. Retail data provided for Charlbury, Henley and Stonehouse

stations covered different time periods for different retail channels, however, we

are satisfied that this provides an indicative picture.

Conclusion

Objection 1: Queuing time targets, monitoring and reporting for TVMs (based on

that currently in use at ticket windows) must be implemented at all stations before

any changes could take place.

Objection 2: We have specific concerns over the retail capacity at the following

stations: Barnstaple, Bridgewater, Bristol Parkway, Didcot parkway, Maidenhead,

Reading, Swindon and Twyford.

Objection 3: We object to the proposal for Kemble.. Without full and equivalent

sales data we are not able to conduct a proper assessment.

• Major stations

We remain concerned at the proposals at major stations where sales volumes and

footfall is still high, especially at peak times. We think there is a greater likelihood

that the system of roving staff will break down as people crowd around staff at the

TVMs or as they are walking somewhere to help another passenger. The potential

lack of any obvious queuing system to get help could easily confuse and frustrate

in equal measure – especially for someone new to the railway or a tourist. At

major stations there are already staff available on the concourse and elsewhere at

the station to provide passengers with information, accessibility assistance and

other support. We also note that many other train operators have proposed to

retain ticket offices at major stations. Therefore, we believe there is still a need for

a staffed retail point at Bristol Temple Meads, Bath Spa, Reading, and Oxford.

Conclusion

Objection 4: We believe there is still a need for a staffed retail point at the

following stations: Bristol Temple Meads, Bath Spa, Reading, and Oxford.

6b) Passengers requiring assistance to travel receive that

assistance in a timely and reliable manner

In our letter of 6 September we set out a number of issues arising from passenger

submissions to the consultation and our own analysis. This was one of passengers’

main concerns during the consultation.

We know through our research that passengers value staff at stations highly. This is

not just related to selling tickets but also in providing assistance and support. A

reduction in staff presence would have an impact on disabled passengers’ ability to

‘turn up and go’. While in many cases staff on the train would have been able to

assist passengers on and off the train, they were unlikely to be able to fully assist

with journey planning, ticket purchase or getting to and from the platform.

Comments received during the consultation included:

“At a month from my 88th birthday, I am still travelling regularly by rail but this

requires managing…If you remove the ticket office staff from Bath Station, I will

no longer have the confidence to travel on my own by rail. This will have a

direct impact on my independence and ultimately on my mental health.” Bath

passenger.

“Please, please don’t close any ticket offices. I am deaf and have a form of

Parkinson’s, travel is difficult and confusing enough as it is.” Bodmin Parkway

passenger

In addition to widespread concern in the consultation about a reduction in staffing at

stations, passengers were also worried that when stations were staffed they may find

it more difficult to find staff. Currently passengers know to approach the ticket office

– it is the focal point. We understand that guide dogs are trained to go to the ticket

window, and it is also the case that ticket windows have induction loops to help

people hear.

“How will visually impaired or blind people find staff to help at ticket machines

as quickly as a ticket office?” Barnstable passenger

“I am totally blind …To be able to travel safely and independently, I rely on

human interactions from staff members and being able to find them reliably in a

fixed location near the entrance to the station”. GWR passenger

“I am a blind person. I am unable to use self-service machines. Even if I don’t

buy my ticket at the station, I need a place to alert staff to my

accessibility/assistance needs. If you abolish the ticket office, how am I to know

who is train station staff? Are you expecting me to approach random strangers

in the hope they can be trusted to help me with my credit card and the ticket

machines?” Bath passenger