My Submission to House of Commons Transport Committee

The House of Commons Transport Committee is looking to improve the main aspects of a rail journey from the perspective of the passenger.

You can send them submissions about your own experience or concerns, but the deadline is Wednesday 25th May.

Below is my submission.


This email raises the following issues:

  • The failure of connecting trains to connect.
  • Poor information when things go wrong.
  • Lack of integrated smart travel options.
  • Lack of availability of tickets.
  • Concerns about:
    • Train Operating Companies (TOCs) running dubious incentive schemes for Revenue Protection Officers (RPOs).
    • Failure to declassify first class on packed trains.
    • Unjust Penalty Fares.
    • That rail staff may be defrauding passengers by issuing illegal Penalty Fares or failing to sell the cheapest ticket.
    • GTR’s poor identification policy & the consequences of this. This may apply to other TOCs too.
    • Risk of criminals posing as ticket inspectors to steal contactless card details, etc.
  • Whether TfL or a similarly accountable body should take over responsibility for rail services in the south east.


I write as someone who has commuted for 27 years, originally daily, then weekly and now intermittently.

During recent years the majority of my rail experiences have been with Southern Rail (GTR).

My experience with GTR is so bad that I actively avoid travelling by rail except when I absolutely have to.

If I can make the journey by car, even if it costs me twice as much, I will do so because I have got so fed up with cancelled trains, missed connections, rude staff, poor information & the risk of an unfair Penalty Fare due to lack of purchasing facilities and the dodgy way revenue protection has been applied.


Connecting Trains that Do Not Connect

On a journey from London Victoria to Seaford Sussex, it is necessary to switch to a connecting train at Lewes.

  • This train regularly fails to connect, leaving passengers waiting half an hour for the next service.
  • There was until recently only 6 minutes to make this connection. I move fast & can do it in 2 minutes (without crowds). The elderly & disabled may be much slower.
  • Delays often occur due to congestion on the outbound journey from London or due to previous operating problems on the network.
  • Southern refuses to hold the connecting train more than 4 minutes past the scheduled departure. In a number of instances there scope in the timetable to hold it for at least 10 minutes without impacting other services.
  • No other trains use the platform during that period and the connecting train goes down a single branch line, meaning there is no impact on points or hold up for other trains.
  • After repeatedly complaining to Southern & escalating to Transport Focus, they arranged for me to meet their Head of Train Planning. Since then they have added 2 extra minutes for the connection. This improves things slight. But they refuse to hold the train longer or explain why they cannot do so.

Poor Information When Things Go Wrong

All commuters accept that sometimes things go wrong. A common problem is lack of information to advise passengers what do to.

  • Often there is no information about which alternative route to take or when trains will be available.
  • On the London Victoria to Seaford route, it is not uncommon to be diverted via Brighton when problems arise.
  • In Brighton there has often been a distinct lack of information on boards and staff seem equally ill-informed.
  • A number of times we have been directed to the wrong platform when a train has been waiting somewhere else.

Lack of Integrated Smart Travel Options

Here is something I really want to be able to do but cannot:

  • Touch in with my Oyster card at my local station in Sussex.
  • Travel to London.
  • Use the tube, tram, bus, etc. in London.
  • Return to Sussex in the evening.
  • And automatically be charged the cheapest available fare for doing all of the above.

It is really disappointing that I cannot do this as it would:

  • Save me standing in a queue for a ticket machine or office.
  • Guarantee me the cheapest price for my journey.
  • Reduce the risk of me being issued a Penalty Fare if I had either no means to purchase or difficulty in purchasing a ticket before boarding.
  • Allow me to review my travel costs in a single place.

It is particularly disappointing that GTR and Southeastern have been allowed to introduce their own (apparently rather flaky) alternative smart card system (the Key) rather than extending the Oyster system.

Lack of Availability of Tickets

It can be difficult to get either the right ticket or even a ticket at all before boarding.

  • Some stations on my route, e.g. Bishopstone Sussex, do not have a ticket office or machine.
  • Ticket machines are sometimes broken.
  • Permit to Travel machines are sometimes broken. Someone I know lost a pound in one of these machines and got neither a permit nor a refund from Southern when she contacted them.
  • Machines reportedly (comments made by others on social media) do not always offer the cheapest fare.

Dubious Incentive Scheme for Revenue Protection Officers

I fully understand the reasons why we need revenue protection measures to catch the small minority of passengers who think they can travel for free.

However, a number of Train Operating Companies (TOCs), including GTR, run an incentive scheme for their RPOs that allow them to keep up to 5% commission from the Penalty Fares they issue.

I consider such a scheme highly dubious, as it may motivate greedy staff keen on topping up their salary to:

  • Issue Penalty Fares where in fact discretion should have been shown, e.g. where someone has made a genuine mistake in their ticket purchase or has been forced to board without a ticket due to exceptionally long queues.
  • Issue unlawful (and by extension fraudulent) Penalty Fares to passengers who had no means to purchase a ticket before boarding, e.g.
    • No purchasing facilities exist at their station.
    • Ticket machine is broken.
    • Permit to Travel machine is broken.

Failure to Declassify First Class on Packed Trains

Overcrowded trains run on a frequent basis, either due to high demand at peak times or due to previous train cancellations:

  • Under the circumstances that the train is so crowded that it is hard to move, the appropriate customer service is that the TOC should take is to declassify first class and compensate those who paid for a first class ticket.
  • There are regular complaints that this is not happening.
  • It is natural for some passengers in such circumstances to feel that have the right to stand in first class rather than be jammed into their neighbour’s armpit.
  • Not only are TOCs regularly failing to declassify first class but it seems that RPOs tend to target those standing in first class in such cases to issue Penalty Fares.
  • This leads to the perception those RPOs are using such passengers as a cashpoint.

Unjust Penalty Fares

I have come across a number of accounts on social media and from friends/acquaintances where Penalty Fares seem to have been fairly applied. Here are a couple of examples:

  • Before Oyster was recently extended Gatwick, RPOs were spotted at Gatwick targeting tourists who had not understood that London Gatwick is not in London or that Oyster stopped at the London border. They are very unlikely to be deliberately evading payment: they have just made a mistake. The correct action here is to charge them for the ticket but exercise discretion by not issuing a Penalty Fare. RPOs appeared to be issuing Penalty Fares, as this topped up their bonus by 3 times the amount that just selling the ticket would.
  • In a packed train where first class had not been declassified RPOs were witnessed surrounding first class and issuing Penalty Fares (whilst failing to check any other ticket in the carriage). This included using one to a man standing in the corridor in standard class but whose foot had slipped over the line into first class.

Rail Staff Defrauding Passengers

Where passengers are forced to board trains without a ticket because there is no ticket machine/office or such facilities are broken/closed, it seems that RPOs may be fraudulently issuing Penalty Fares:

  • Under these circumstances section 7.3 of the SRA 2002 Penalty Fare Rules prohibits a Penalty Fare from being issued.
  • However, there is anecdotal evidence on social media that such passengers are regularly being issued with (unlawful) Penalty Fares.
  • According to the 2002 Penalty Fares Policy document, RPOs are supposed to check whether machines are broken. If they cannot find this out they are supposed to give the passenger the benefit of the doubt. Anecdotally – on social media – they seem not to be doing so.
  • Many passengers are not familiar with the Penalty Fare Rules and may either not know how to or have time to appeal, so end up paying money they do not owe.
  • Given that RPOs are trained in, and therefore are expected to be familiar with these rules, they must know that they are not allowed to issue Penalty Fares under these circumstances.
  • This leads to the suspicion that these RPOs are actively defrauding passengers, particularly in the light of the dubious incentive scheme run by some TOCs.

Poor Identification Leads to the Risk of Fraud

Some TOCs have a very poor identification policy for their staff, which may place passengers at risk from crime by people posing as ticket inspectors. A fake ticket inspector could commit crimes such as the following:

  • Using a near-field reader with modified software to steal the 16-digit number and expiry date from contactless cards. Consumer group Which? recently proved that they could break the security on all 10 contactless cards they tried. Although it is not possible to read the CVV number, you do not need this number to make purchase on some websites, e.g. Amazon. The stolen details are not subject to the £30 contactless limit when used online.
  • Reading valuable personal data, online banking & social media logins, etc. from ApplePay devices and other mobile phones, as further contactless payment options are rolled out.
  • Insisting that a passenger (e.g. a young woman) must leave the train at an isolated station and then committing a sexual assault.
  • Less probably (but still problematic for the passenger if it happens):
    • Stealing credit from Oyster cards / other smart cards.
    • Stealing a paper ticket from a passenger, leaving them to pay for their journey a second time + a Penalty Fare … or get a criminal record for fare evasion, if their account is not believed.

GTR’s Dubious Identification Policy

In particular, GTR’s identification policy causes concern. I have had a lengthy series of exchanges with their executive customer services team on this subject.

On the plus side they do assure me that their RPOs are obliged to produce a photo ID bearing first and last name.

The concern is with their remaining staff such as conductors + the new role of station hosts, selling tickets on platforms.  For these staff GTR claims that a “recognised uniform” + name badge containing just the employee’s first name constitutes identification.

This claim is very suspect because:

  • The wording of section 24.3 or the Railway Byelaws is very clearly not talking about a uniform – you do not “produce” a uniform on request!
  • Neither a uniform nor a name badge has the following:
    • A photograph from which the employee can clearly be recognised, i.e. the item of uniform or badge may be stolen from or lost by a genuine staff member.
    • A means of identifying the individual: this would either be a unique employee number, or first name + last name.

I would also note here that:

  • Often GTR staff do not have much that is recognisable uniform, typically relying on a jumper or jacket as the sole item of “uniform”.
  • The general public often see more uniform than is actually there, e.g. a smart suit can be mistaken for a uniform, particularly if someone has pinned a stolen Southern badge to it.
  • People do not always realise it is a uniform from another company entirely, e.g. London Underground staff are sometimes approached on GTR trains on the assumption they are staff members, as are staff working for airlines.

Rude and Unprofessional Behaviour From Staff

A further risk of poor identification is that some rail staff seem to think they can get away with rude behaviour and poor customer service. Examples I have person seen over the years are:

  • Running a ticket check like they are running a boot camp, expecting everyone to have their ticket out and ready to make job easier and giving passengers still looking for their ticket a dose of surly attitude or threats that they’ll “be getting off at the next stop”. Here I would expect the customer service of conductors/RPOs approaching each passenger individually.
  • Refusal to show ID on request. Producing ID is a legal requirement covered in the Railway Byelaws #24.3, TfL’s Railway Byelaws #25 and the 2002 Penalty Fare Rules #5.4.
  • Asking to see a ticket and then walking away without checking it.
  • Exhibiting threatening behaviour (a criminal offence!) when asked to produce ID.

Is It Time TfL Took Over?

I would very much welcome Transport for London (TfL) or a similar regionally accountable body to take over the lines that extend from London to the South East.

Here is why:

  • TfL actively tries to refund passengers when there is a delay to their journey, whereas GTR seems to make it as difficult as possible.
  • It is hard to imagine TfL tolerating staff refusal to show ID.
  • TfL would be unlikely to let a connecting service depart when there was spare capacity in the timetable to hold the train.
  • Where TfL has taken over lines (TFL Rail, London Overground) fares have been cut, stations have been cleaned and staffed properly, and generally people seem happier with the service.
  • Oyster would apply from my local station.
  • TfL is accountable to City Hall. They are also accountable to the general public under Freedom of Information. Neither of these things applies to GTR.